------------------------------------------------------------------- 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. ===================================================================== 1 (Whereupon at the hour of 3:00 P.M., 2 the within proceedings were resumed, reported 3 by Stephanie Zanglis, CSR.) 4 5 EXAMINATION 6 BY MR. BERRY: 7 Q Now, when we left off this morning, you 8 started to tell me about the annual fund-raising luncheon 9 of the Positive Action Center. 10 A Correct. 11 Q When did that happen? 12 A This was approximately February of '85, and 13 they had provided for Patricia Ryan, who was the daughter 14 of Congressman Leo J. Ryan -- 15 Q February of '85 or '88? 16 A February of '88. Leo J. Ryan being the 17 Congressman that was killed in Jonestown. Patricia at that 18 time had just gotten involved in CAN and was talking about 19 the dangers of cults and how it affected her family, being 20 that she lost her father to a cult-related murder. 21 And I was put in charge of making sure that 22 during the fund-raiser and after the fund-raiser when they 23 asked for contributions, that the envelopes containing the 24 contributions were pooled together and put in a hiding 25 place inside Adrian Greek's van. 94 1 Well, that fund-raiser was not a financial 2 success to the Greeks because they lost money on it. They 3 didn't make any money on it. It is my understanding they 4 paid something like $600 for rentals and other expenses and 5 only made $300 off of fund-raising. 6 What the Greeks did not know was that 7 approximately $800 of that went into my pocket and went to 8 the Church of Scientology. 9 Q Who put you in charge of putting the money in 10 the Greeks' van? 11 A Gwen Mayfield. 12 Q Gwen Mayfield was part of the Church of 13 Scientology then? 14 A President. 15 Q How did she ensure that you were the one that 16 was going to put it in the Greeks' van? 17 A I'm the one who had the access; I'm the one 18 that had the relationship with the Greeks; I'm the one that 19 had prearranged with the Greeks to make sure that all the 20 money was collected, all the names and contributors that 21 were there were collected, and to get into the van. 22 I was trusted by Ann Greek at that time to do 23 that. They trusted me to take care of that situation. And 24 I'm the one that went with the Greeks afterwards to the 25 Positive Action Center to count the funds. 95 1 And what they did not know was that the major 2 portion of those proceeds had gone to the Church of 3 Scientology. 4 Q You gave the money to Gwen Mayfield? 5 A That's correct. 6 Q What was her post? 7 A President of Church of Scientology, Portland. 8 Q Now, what was the next significant thing that 9 happened after that luncheon? 10 A In April and May of '88, we got word that an 11 attempted deprogramming had taken place involving a young 12 woman from New Zealand who was a Moonie, and that the woman 13 had escaped and turned or called the police, and that some 14 members of the deprogramming team were on the run from the 15 FBI and the police, and eventually they were arrested, but 16 Bob Brandeberry managed to flee and was in hiding. 17 It was the belief of Gwen Mayfield and she 18 said from other people that she worked with in Scientology 19 that the Greeks knew exactly where Brandeberry was and that 20 they were responsible for hiding him out from the FBI. 21 In June of '88, the Greeks had a telethon -- 22 it was the first time they ever attempted this -- on cable 23 television, and it was during this cablethon that Diane 24 Benscoter, B-e-n-s-c-o-t-e-r, who was an ex-Moonie and 25 deprogrammer, who knew me from the attempted kidnapping and 96 1 deprogramming of the Greeks' daughter back in 1980, who 2 told me that she was also on the run, and that the police 3 and FBI were looking out for her; that she had been 4 involved in this deprogramming in Denver. 5 I told Gwen Mayfield, and following her 6 advice, I contacted the Denver police and told them exactly 7 where they could find Diane Benscoter. 8 I gave a taped deposition to a Detective 9 Wickersham of the Denver Police Department. I was assured 10 by the Denver Police Department and also by the District 11 Attorney in Denver, Diane Balkin, that I would be a 12 confidential informant. 13 However, I learned later that a sergeant in 14 the Denver Police Department -- and I forgot his name -- 15 who was a former board member of CAN -- in fact, I do 16 remember his name. His name is Mark Roggerman, 17 R-o-g-g-e-r-m-a-n. He was alerted to the information that 18 I gave, and that members of CAN were alerted to that. 19 Subsequently, Diane Benscoter was arrested by 20 the Portland police. I talked to a Detective 21 Neuvenschwander of the Portland police. 22 Q Can you spell that? 23 A N-e-u-v-e-n-s-c-h-w-a-n-d-e-r, first name 24 Lynn, L-y-n-n. 25 And basically repeated to him what I told the 97 1 Denver police, and then went and arrested Diane Benscoter. 2 She was booked, charged with felony warrant, and then the 3 Greeks bailed her out of jail. 4 It was around this time -- and this is before 5 Mark Roggerman got word that I was cooperating with the 6 Denver police -- that the Greeks got word from someone that 7 I had spoken with at the DA's office in Denver about the 8 case, and I denied it. 9 And they started to get real suspicious, and 10 acted very suspicious, and they were telling me not to 11 cooperate; if anyone from Denver, any law enforcement 12 authority called me, to ignore them because we needed to 13 protect Bob Brandeberry. 14 It was a few weeks after that -- it was in 15 August -- I'm sorry. Let's go back because something else 16 happened. 17 It was in June and July that the Greeks were 18 also preparing for the National Cult Awareness Conference, 19 which they were hosting in Portland, Oregon, and they were 20 letting me help them prepare the registration pamphlet for 21 the conference, which would be mailed out to CAN members. 22 And I suggested including a photo that I found 23 in a book that was the art work of which came from a friend 24 of mine who gave the Greeks permission to use this cartoon 25 of a bear holding a book under a tree, and that book had 98 1 the words "Cults & Cons," which was the name of the book 2 earlier published by the Greeks about cults. 3 Once the Greeks agreed to use it, and they 4 trusted me that my information was correct, they published 5 the pamphlet with the cartoon of the bear. 6 The cartoonist was a Scientologist who later 7 called the Greeks threatening a lawsuit for trademark 8 infringement. And the Greeks called me and said, "I want 9 the truth. Where did the cartoon come from? Give me the 10 name of the person, your friend, who did the cartoon," and 11 I couldn't do that. 12 Then Ann Greek received a phone call from the 13 woman threatening to sue her for infringing on this cartoon 14 she did without her permission. And then Ann Greek called 15 me and demanded to know who my friend was who gave me 16 permission to do that, and I would not give it to her; told 17 her it was confidential. 18 She said she knew that I was lying, and she 19 wanted to know why I was trying to hurt them because now 20 they would have to on very short notice destroy all 600 21 copies of this pamphlet that they had paid something like 22 $400 of their own money for and redo everything. 23 And what she did not know was that the 24 cartoonist was a Scientologist and was all set up to 25 destroy them or hurt them financially. 99 1 And later I got a phone call from Ann Greek 2 that they had received word from a source in Denver, 3 Colorado, which she would not identify, who I knew to be 4 Mark Roggerman, or I suspected to be Mark Roggerman, that I 5 had been working with at the Denver police, and that I was 6 working against them. 7 I received a letter from Ann Greek saying that 8 although she was concerned about me and she cared about me, 9 they no longer wanted me to be around the Positive Action 10 Center, and that I was being dismissed from them and the 11 Cult Awareness Network. 12 I tried to play out this saga even more by 13 contacting Cynthia Kisser directly and complaining, 14 contacting the president of the Cult Awareness Network, 15 whose name I don't remember right now, but he is a dean of 16 some college on the East Coast, and Cynthia suggested I go 17 before the CAN board, and I said I wanted to do that. 18 I was also scheduled to fly to a conference of 19 physicians and psychiatrists in Dallas, Texas, and that 20 meeting was cancelled. 21 I then got a phone call from Ann Greek a 22 couple of days later telling me that, unknownst to me, that 23 a full-scale investigation had taken place, paid for by the 24 Cult Awareness Network, on me because they had received 25 information that I was actually in the Church of 100 1 Scientology working against the Cult Awareness Network, and 2 that the investigation was being done by Larry Zillios, 3 Z-i-l-l-i-o-s, who is a former agent of the CIA now doing 4 security projects for the Cult Awareness Network and 5 investigations. 6 I contacted Scientology with that information, 7 and they basically said not to worry about it. And in 8 October, I know of members of the Church of Scientology 9 that were present at the CAN conference, but I was not 10 allowed to be present. 11 And I called Adrian Greek, asking him what he 12 would do if I showed up anyway, and they said they simply 13 would not let me on the premises. 14 Q Who did you give the information to at 15 Scientology that you just -- 16 A Gwen Mayfield. And Gwen told me that she had 17 one of her assistants there at the conference, and, in 18 fact, I received a phone call from this unknown person at 19 the conference telling me what was going on, and suggested 20 that I show up anyway on Saturday night, which is the night 21 of their banquet, make my way into the Holiday Inn where 22 the conference was being held, and just walk up on stage 23 and blow them. 24 Q And did you? 25 A No. 101 1 Q So what happened next of significance 2 concerning the Church of Scientology and you? 3 A Nothing with regards to the Cult Awareness 4 Network and the Positive Action Center. There was just a 5 lull period there, nothing happening. 6 Q What was going on between you and the Church 7 of Scientology? 8 A Well, first, emotionally, I had a hard time 9 with it because I made a lot of friends in the Cult 10 Awareness Network who were not knowledgeable about my 11 association with Scientology. And I guess I really was 12 incognizant of the fact of how much I had betrayed people, 13 but when I was no longer invited and, basically, the 14 associations I had with people in CAN were cut off, I 15 tended to -- I didn't leave Scientology, but I intended to 16 distance myself from them. 17 Q There came a point in time, though, when you 18 got involved with OSA and Bowles & Moxon and a lawsuit by 19 you against CAN; correct? 20 A That's correct. 21 Q Are they the next big event in the story? 22 A Well, after that I had attended a service of a 23 local Catholic Church, and got involved in the Catholic 24 Church, and converted to Catholicism, and had considered 25 applying my talent and skills to become a Catholic priest. 102 1 And I was told by the vocations director of 2 the Catholic Church archdiocese to wait one year and give 3 it some thought, get more involved in the Catholic parish, 4 which I did. 5 And after that one-year period, I applied and 6 went through a series of psychological/psychiatric tests 7 and interviews with various priests and was accepted as a 8 candidate, and was scheduled to enter the Catholic seminary 9 in September of 1991. 10 Q This was for the second time, wasn't it? You 11 had earlier -- 12 A No. This was the only time. 13 Q Then what happened? 14 A And the next big event, if you want to call it 15 that, I was called to a meeting in April -- let me make 16 sure the dates are right here. April of '91 into the 17 office of the vocations director, who told me that I was 18 being dismissed as a candidate because I had not fully made 19 aware to them my association with the Church of 20 Scientology. 21 In the application process, I told them that I 22 had been a Scientologist, and that I had taken courses. I 23 did not tell them the dirty works activities, so to speak, 24 that I did against the Positive Action Center. 25 And through their investigation, they spoke 103 1 with the Greeks, and learned from them the full extent of 2 my duties in Scientology that they were aware of and the 3 results of the investigation that CAN did against me, and I 4 was dismissed. 5 Q When was that? 6 A This would have been April of '91. 7 Q Were you still involved with the Church of 8 Scientology at that point in time? 9 A In a casual way. 10 Q What do you mean by "casual"? 11 A I wasn't taking any courses, but I was talking 12 to them, and I could walk into the Mission of Davis as I 13 had done many times and shoot the breeze with people, but I 14 wasn't taking courses. 15 Q Did there come a point in time when your 16 activities and involvement with Scientology increased? 17 A Yes. 18 Q When I say "a point in time," I mean after 19 dismissal by the Roman Catholic Church. 20 A When I was dismissed by the Roman Catholic 21 Church, I appealed it, and the archdiocese wouldn't talk to 22 me. 23 I then called the Greeks and wanted to sit 24 down and talk to them. They said they would prefer to 25 leave things the way they are and would not talk to me. 104 1 I then went to Gwen Mayfield and asked her and 2 begged her to help me out, even go so far as suing the 3 Catholic Church. And I got a lot of obstacles thrown at 4 me, wherein they simply didn't want to intervene, and they 5 said I was wishy-washy. 6 And that is when I wrote a very derogatory 7 letter to the archdiocese director, and I referred to 8 allegations made against members of the Church of 9 Scientology and some activities that had taken place, some 10 which were true and some which were not. 11 And a copy of that letter got down to David 12 Miscavige in Los Angeles, and it wasn't until October that 13 I got a visit from Eugene Ingram. 14 Q This is October when? 15 A '91. 16 Q Was this the visit that you were talking about 17 earlier this morning? 18 A Yes. I need to step out one quick second. Is 19 that okay? 20 Q Sure. 21 (Brief recess.) 22 Q BY MR. BERRY: Now, I think this morning when 23 you were talking about this meeting with Ingram, you told 24 us how you had ridden around in the van, and we ended up 25 with him making you some kind of proposal -- 105 1 A Um-hum. 2 Q -- at which point I think we cut back to the 3 chronology. So at some point in the meeting that you had 4 with Eugene Ingram that stretched over a day or two, your 5 future activities with Scientology were discussed; correct? 6 A That's correct. 7 Q This meeting took place in Portland about 8 when? 9 A This would have been October 5th, 6th, 7th, 10 around that time. I don't remember the specific day 11 because I remember October 6th. 12 Q And it was prompted because -- sorry. Why did 13 Ingram visit you? 14 A The copy of the letter that I sent to Reverend 15 John Kearnes made its way into the hands of David 16 Miscavige. According to Eugene, David Miscavige was 17 extremely upset with the letter, and extremely upset with 18 me writing it, and he referred it over to Tim Bowles and 19 Kendrick Moxon, and they paid Eugene Ingram to fly to 20 Portland to debrief me. 21 Q After you had been debriefed by Ingram, there 22 was a discussion about your future activities for 23 Scientology? 24 A That's correct. 25 Q What was that discussion? Where was it and 106 1 who was there? 2 A I was told I had two options; that, one, I 3 could cooperate with them fully and be forgiven for my past 4 activities, but by doing so I would have to obey every 5 directive that came to me and follow every activity that 6 they sought out without question or I could look at 7 spending the rest of my life in prison and face additional 8 civil penalties. 9 Q Did he explain any of this to you? 10 A Yes, he did. He said that Scientology had 11 been successful in causing a number of people to go into 12 jail for their past activities, and that it would not be 13 difficult for them at all to take all the activities that I 14 had done in the past on behalf of Scientology and 15 distancing themselves from those activities, make it look 16 like I was solely responsible for it, and that they would 17 see to it that I was sent to prison. 18 Q Did they elaborate on that at all? 19 A In what way? 20 Q Did Ingram tell you how or to whom this had 21 happened in the past? 22 A No, no specific news. 23 Q Any specific examples of types of behavior? 24 A I don't understand your question. 25 Q Did he indicate what sorts of things they had 107 1 distanced themselves from leading to people being 2 imprisoned for, for doing them? 3 In other words, I think you said they had 4 people go to prison in the past for things that they had 5 been involved in, but distanced themselves from; correct? 6 A He just said criminal activities, but he 7 wasn't specific about criminal activities, and he didn't 8 mention any names at that time. 9 But he did tell me that I could trust him 10 without question, and I could really trust him. And I 11 expressed to him first that I would -- that I wanted to be 12 forgiven for my past, that I did not want to go to prison, 13 I did not want to be sued because I didn't have the 14 financial ability to hire an attorney to represent myself 15 in a lawsuit, but I wanted some assurance that by 16 cooperating fully and doing what I was told, that they 17 would not come against me in some way. 18 And Eugene Ingram said that, first of all, "If 19 you want, I will get a letter from Tim Bowles to that 20 effect." 21 (Brief interruption.) 22 Q BY MR. BERRY: And a letter from Bowles would 23 say what or deal with what? 24 A Some sort of letter of immunity that they 25 promised not to bring any actions against me in turn for my 108 1 cooperation with them. 2 Q Did Mr. Ingram indicate what they would sue 3 you for if you didn't cooperate? 4 A No. 5 Q Did he indicate what kind of criminal conduct 6 they would try to implicate you in if you didn't cooperate? 7 A Well, he stated that he had copies of all the 8 files on me dating back to 1977, and then he talked about 9 this girl that I had worked with back in '76. 10 So knowing -- and given my experiences in the 11 activities that I did on behalf of the Church of 12 Scientology, which I was directed to do back in '82 and 13 '84, I assumed that he knew what he was talking about. 14 Q And just very briefly, what activities are you 15 referring to? 16 A Compromising my position in employment with 17 the Portland Police Bureau and the Multmomah County 18 Corrections Division, in which I accessed the crime 19 computer for information on individuals. 20 Q What was the other incident that you thought 21 he was referring to? 22 A The other incident is basically stealing files 23 and stealing money from the Positive Action Center, and I 24 just assumed that he could take all that and create 25 something with it and use it against me. 109 1 Q Now, what happened next in your conversation 2 with Mr. Ingram on this occasion? 3 A Mr. Ingram said that he wanted declarations on 4 people involved in the Cult Awareness Network. He provided 5 me with a faxed letter which was faxed to him at the Red 6 Lion Hotel from Bowles & Moxon, and it was a letter waiving 7 any intention on their part to take actions against me for 8 my honest and accurate cooperation with Eugene Ingram in an 9 ongoing investigation of the Cult Awareness Network. 10 Q Do you still have that letter? 11 A I believe the letter is in your files over 12 here. 13 Q The box of files we received from Mr. Leipold? 14 A That's correct. 15 Q Then what happened? 16 A Then they asked me to relay any and all 17 information that I had on specific persons that he wanted 18 to know about; specifically, Cynthia Kisser, Ford Greene, 19 Bob Brandeberry, and the Greeks. 20 And I gave him what information I had, and 21 from that he sat down and created declarations, and told me 22 that he was going to prepare some very basic declarations, 23 and then at a later date he would fly back to Portland and 24 with me we would drive around Oregon and Washington, 25 basically confirming some of the information in the fax 110 1 that I gave him. 2 And from those faxes and information he 3 basically stretched and paraphrased quite a bit and created 4 his own self-styled declaration, which would prove very 5 incriminatory toward Cynthia Kisser and the Cult Awareness 6 Network. 7 In fact, the major declaration, and in the 8 specific declaration, focused towards Cynthia Kisser and 9 accuses her of criminal activities and criminal 10 conspiracies. 11 Q So what happened next? 12 A Well, from the general declaration he produced 13 four separate declarations, one focusing on each 14 individual, Ann Greek, Bob Brandeberry, Cynthia Kisser, 15 Ford Greene. 16 The very next day, he produced those typed 17 copied declarations to me, which he said had been prepared 18 in the Bowles & Moxon office in Los Angeles and sent to him 19 in overnight mail. 20 I told him I was extremely concerned about the 21 information in these declarations because if he was to use 22 these declarations in a criminal or civil case, which he 23 said he would, that they would confirm that a lot of the 24 information in there was bogus and not true. 25 He said, "Don't worry about it because having 111 1 had all the experience that I have had as a Los Angeles 2 Police Department sergeant, and all the experience that I 3 have had with the courts as a police officer and as a 4 private investigator for the last 10 years, I can tell you 5 that you are protected from any type of liability should 6 people question the, quote, facts in these declarations." 7 Also, he said, "Being that you are signing 8 this, quote, under penalty of perjury, but it is simply 9 being witnessed by a notary public who doesn't have any 10 type of judicial power, that if anyone was to try to go 11 against you for slander or libel or anything in these 12 declarations, they simply could not do it because you are 13 not sworn in by a court officer. And that is why I'm not 14 going to have you sworn in because we can get away with 15 this." 16 Q And he hadn't left, as far as you know, 17 Portland at all at this time? 18 A Oh, no. I was with him at all times during 19 that time. 20 Q So these declarations were produced during 21 this visit that he made commencing by appearing at the Red 22 Lion Hotel? 23 A Yes. And at one point, it was the third day 24 he was there in Portland, he produced a declaration which 25 alleges Ford Greene of all kinds of sexual misconduct; that 112 1 Ford Greene tried to rape me, he tried to have oral sex 2 with me, and I said, "I will not support this declaration." 3 And he said, "Well, Garry, we have prior 4 knowledge of you engaging in homosexual activities. It's 5 all in your files. We could really draw a conclusion on 6 that." 7 And I said, "Well, go ahead, but I'm not going 8 to sign it because Ford Greene and I did not have sex." 9 And he stipulated in this deposition or this 10 declaration we did, and I said, "I will not." 11 And so he said, "Okay. That just means I am 12 going to have to revise it a bit." 13 So we drove to my apartment, and he sat in one 14 of my reclining chairs, and got on the phone with Bowles & 15 Moxon, and basically recreated this declaration, and then I 16 signed it. 17 Q And you subsequently recanted the allegations 18 you made in that declaration, didn't you? 19 A Later on after I left the Church, yes. But 20 following the signature of these declarations, 21 approximately a month and-a-half later, Eugene came back to 22 Portland, and we drove up and down Oregon and Washington 23 because between 1980 and '86, I was involved in two 24 deprogrammings; one involving a young man from what the 25 Greeks felt were a Christian-based cult in which Ann Greek 113 1 was involved in, and another one involving a University of 2 Oregon freshman whose parents thought he was involved in a 3 Satanic cult. 4 And Eugene was particularly interested in 5 these two cases because he could draw a connection between 6 these two cases and Cynthia Kisser and the Cult Awareness 7 Network because the Cult Awareness Network has constantly 8 stated its position that although there are members in the 9 Cult Awareness Network who may be involved in 10 deprogramming, the Cult Awareness organization itself does 11 not endorse deprogramming. 12 And it has been the contention of the Church 13 of Scientology to show the Cult Awareness Network being -- 14 actually endorsing illegal deprogrammings, and if they can 15 do that in the courts, then it will invalidate the 16 legitimacy of the Cult Awareness Network and cause it to go 17 under. 18 And he was very specific in wanting to destroy 19 the credibility of Cynthia Kisser and by using the 20 deprogramming issue as a way of destroying the Cult 21 Awareness Network. And he thought he could do that by 22 focusing on the two deprogrammings that I was involved in. 23 Q Was there another occasion on which you also 24 spoke with Ingram about a declaration against Ford Greene 25 as well? 114 1 A We are now talking about -- 2 MR. BERRY: Off the record. 3 (A discussion was held off the record.) 4 Q BY MR. BERRY: So what time period are we 5 talking about here? 6 A We are now talking about October of '91, after 7 the first set of declarations have been signed by me and 8 witnessed by a notary public in Portland. 9 A month-and-a-half later, Bowles & Moxon paid 10 Eugene to fly up to Portland to meet with me, and I took 11 three days off, whereby we traveled to Washington. 12 Q How do you know Bowles & Moxon paid for Eugene 13 to fly up to Portland? 14 A Eugene Ingram has told me that he works for 15 Bowles & Moxon; that Bowles & Moxon pays him to do 16 investigations, and that he has absolutely nothing to do 17 with the Church of Scientology and has absolutely nothing 18 to do with the OSA; that he is part and parcel with 19 Bowles & Moxon. 20 He told me that also because of my having to 21 take three days off from work to assist him, that Bowles & 22 Moxon would pay me $200 a day to assist him. 23 Q Did they? 24 A Yes, they did. 25 Q How did they pay you? 115 1 A Eugene Ingram paid me in a personal check on 2 his account, and he told me that he would bill Bowles & 3 Moxon for that. 4 Q So he came up and visited you again for three 5 days, and what happened? 6 A He came to Portland. He rented a car at 7 Portland International Airport. We drove to Eugene, Oregon 8 looking for the same house where we -- I'm sorry, looking 9 for the home where I had kidnapped this university student 10 and taken him to Bellevue, Washington. 11 Meanwhile, while we were looking for this, he 12 was constantly on the phone with David Butterworth and 13 Roger Stodola assisting us in this investigation. I had 14 also talked to him about -- 15 Q Who is Roger Stodola? 16 A Roger Stodola is the former assistant to David 17 Butterworth. And Roger Stodola now is with the Oregon/San 18 Francisco. 19 And Eugene was constantly on his mobile phone 20 with Stodola and Butterworth, and searching out information 21 because we were trying to find the name of the private 22 investigator who the parents of this kid had hired to keep 23 surveillance on him, and I did not remember this 24 investigator's name. So Eugene was constantly going every 25 which way to find the name of the investigator and the name 116 1 of the person who we deprogrammed because I didn't remember 2 his last name. 3 We spent a great deal of time at the 4 University of Oregon, where he went to the administration 5 office, to the library, to school officials, trying to get 6 information on this young man. 7 We then drove around Bellevue, Washington 8 through every conceivable neighborhood in the Bellevue area 9 looking for this safe house, and I tried to point out to 10 Eugene that six to seven years had lapsed, and by that 11 time, you know, being that the area is growing so much, 12 there is no way we could find the house, but we did. We 13 spent countless hours driving up old alleys looking for 14 this house. 15 It was at that time also in his car that we 16 were on his mobile telephone calling private investigators 17 in the Eugene area trying to determine whether this 18 investigator we called was in fact the one involved in the 19 deprogramming. 20 Through a number of his phone calls to 21 investigators and him talking to investigators, we finally 22 located the gentleman who was involved, at which time we 23 drove straight from Bellevue, Washington for 24 four-and-a-half hours to Eugene, Oregon, arriving there 25 approximately midnight, at which time Eugene talked this 117 1 investigator into getting out of bed and meeting with him 2 at a bar in Eugene, Oregon. 3 Eugene advised me to stay outside the bar 4 while he talked to this investigator, and proceeded to get 5 this investigator drunk. And they stayed in the bar for 6 four hours trying to get the investigator to come out with 7 the name of the person we deprogrammed. 8 At approximately four in the morning, we then 9 drove to the investigator's house where Eugene or this 10 gentleman offered to cook us breakfast. The investigator 11 specifically wanted to know who I was and why we wanted 12 this information. 13 Eugene created the scenario that I was a 14 candidate for the Los Angeles Police Department; that I had 15 been involved in this deprogramming, and that I knew that 16 if this came out, it would be held against me in a 17 background investigation, and so we wanted to set the 18 record straight. 19 We convinced this investigator that I in fact 20 was an L.A.P.D. candidate, and he gave us the name of the 21 individual that I had kidnapped and deprogrammed. 22 Q Do you still have that name? 23 A Eddy Fallon. 24 Q How do you spell Fallon? 25 A F-a-l-l-o-n, Jr. His parents live in North 118 1 Port, New York, which is in the Long Island area. 2 Q And that was the deprogramming you testified 3 at length about in the CAN depositions? 4 A That's correct. 5 Q So what happened next to Mr. Ingram either 6 during or after this tour of Portland? 7 A Mr. Ingram then told me that he was going to 8 compose all the information together and create a more 9 elaborate declaration, which he was going to use in 10 criminal and civil proceedings against the Cult Awareness 11 Network, against the Greeks, and against Cynthia Kisser. 12 He told me that I would be getting a phone 13 call from David Butterworth in Los Angeles, who was the 14 director of the OSA, and that it was expected that I would 15 fly down to the Cult Awareness Network conference in 16 Oklahoma City for the purpose of disrupting the conference, 17 and that they knew -- and I'm talking about the OSA and the 18 Church of Scientology -- knew by my showing up at this 19 conference that it would scare the shit out of the people 20 at the conference, and that they were going to use me to 21 surprise them. 22 Q So what happened next? 23 A I was working, and I was visited by a 24 Scientologist who said that he had been sent to provide me 25 an envelope. He didn't know what was in the envelope, but 119 1 inside the envelope was an airline ticket. 2 Q When was this -- 3 A This was -- 4 Q -- roughly? 5 A -- the end of October '91. 6 Q Where was the airline ticket to? 7 A Oklahoma City, Oklahoma. And there was 8 instructions in the envelope saying that I would be met at 9 the airport by a member, a Church member, and -- 10 Q Did you go? 11 A Yes, I did. 12 Q Is this the CAN conference that you testified 13 at length about in the CAN depositions we identified this 14 morning? 15 A In Oklahoma City, yes. That is where I first 16 met David Butterworth, personally met him. 17 Q Now, what is David Butterworth's position with 18 the Church of Scientology? 19 A At the time, he was a director of Office of 20 Special Affairs of the Church of Scientology International, 21 and I believe he is in that same capacity today. 22 Q Did you have any conversation with 23 Mr. Butterworth at the Oklahoma City conference? 24 A Quite often; quite often. One of our 25 techniques of gaining information at the conference is 120 1 confronting members of the Cult Awareness Network and 2 enveloping them in conversations. 3 What they did not know, that we had hand-held 4 tape-recorders running in the labels or in the pockets of 5 our jackets, and they were constantly running. And I 6 probably produced six or seven tapes of my own. There were 7 six or seven other individuals that also had recorders 8 taping these conversations. 9 And it was the intent of Butterworth to 10 transcribe the conversations in writing and be able to use 11 them against the Cult Awareness Network. 12 Also during the Cult Awareness Network 13 conference, I threatened several people on the telephone, 14 threatening to murder them, and that they would not leave 15 Oklahoma City. And this was encouraged by Mr. Butterworth. 16 Q Who suggested it? 17 A David Butterworth. 18 Q Did he identify the people he wanted you to 19 call? 20 A Yes. Rick Roth, who was a very well known 21 deprogrammer, who deprogrammed Jason Scott, who was one of 22 the people present at the conference and was actually my 23 roommate during the conference. 24 And Cynthia Kisser, whom we could not find 25 out -- we did not know where she was at, but I did talk to 121 1 a woman that I thought was Mary Ellis Chrnaloga, 2 C-h-r-n-a-l-o-g-a, and a couple, last name Davis, who were 3 coordinators at the conference. I don't remember their 4 first names. But I was told that was their room, and 5 whether it was them specifically or not, I don't know. 6 But I told them on the phone that, "If you 7 don't shut up and leave immediately, you are not going to 8 leave Oklahoma City alive." 9 And it was at the CAN conference that Eugene 10 Ingram called me and told me that they had since 11 transcribed the second declaration, and that it was being 12 mailed to David Butterworth, and that I should read it as 13 fast as I can, and then with Ann Laws, L-a-w-s, who was at 14 the conference working with me -- Ann Laws is the OSA 15 director for Dallas, Texas Church of Scientology. With Ann 16 Laws, we drove around Oklahoma City looking for a notary 17 that would notarize the declaration, and we found one. 18 Q Did you discuss that declaration in the CAN 19 depositions that we spoke about this morning? 20 A We did briefly. A lot of questions weren't 21 asked about the declaration, only that the declaration was 22 the final declaration that I signed, and that following my 23 signature of the declaration, Eugene Ingram and David 24 Butterworth told me that they had duplicated this 25 declaration approximately 500 times and sent it out to 122 1 every org within the U.S. and Canada, Church of 2 Scientology. 3 And I believed them because I had talked to 4 several org members in New York, Clearwater, Florida, 5 Chicago, and Seattle, and they all said that they had seen 6 my declaration. So I know that it had gone out around the 7 country. 8 Q Who, to the best of your knowledge, actually 9 drew up the declaration? 10 A Eugene Ingram drew it up. 11 Q Were there any attorneys involved, to your 12 knowledge? 13 A Eugene Ingram told me that he worked for 14 Bowles & Moxon, and that Tim Bowles and Kendrick Moxon were 15 the people he answered to, paid for him to come up and do 16 these declarations. 17 In transcribing these declarations, he was on 18 the phone not only from the Red Lion Hotel, but spent 19 several hours one night in my apartment on the phone with a 20 receptionist at Bowles & Moxon transcribing this over the 21 telephone. 22 And at that specific time, I can't say that I 23 know for a fact that Tim Bowles and Kendrick Moxon was 24 directly involved in that, although I think the evidence 25 would lead you to believe that. But in further contacts 123 1 and experiences with him, I know for a fact that they were 2 intimately involved in all of this. 3 Q Anyone at Bowles & Moxon or just Mr. Moxon and 4 Mr. Bowles? 5 A Tim Bowles and Ken Moxon were the only ones 6 at that time other than I had some conversations with Eric 7 Mason, who is a paralegal at Bowles & Moxon. 8 Q Mr. Bowles I think has submitted a declaration 9 in which he refutes Mason being a paralegal. 10 A No. I can speak to that. 11 Q You are familiar with the declaration I am 12 talking about? 13 A Yes. There is in Portland a television anchor 14 by the name of Eric Mason, and whenever I would talk to 15 Aaron Mason, I often referred to him as Eric, and I would 16 ask for Mr. Mason, and I would always get corrected. 17 So in talking about him, I kept confusing Eric 18 and Aaron Mason with Moran. And in the declaration I 19 talked about my conversations with Eric Moran. 20 Tim Bowles knows exactly who I was talking 21 about, but he played stupid in one of the declarations he 22 filed and tried to submit that he had no idea who I was 23 talking about when in fact he did. Basically, Tim Bowles 24 is a liar. 25 Q Now, this declaration that you signed -- 124 1 A I also thought Aaron Mason, by the way, was an 2 attorney when I first started talking with him, and Aaron, 3 in fact, had represented himself to me as an attorney, and 4 I found out later that, in fact, he was only a paralegal. 5 Q He actually told you he was an attorney? 6 A Yes. 7 Q Did he tell you where he had been licensed to 8 practice law? 9 A No. He said he was an attorney with Bowles & 10 Moxon because during the time that we were preparing my 11 lawsuit against the Cult Awareness Network, the slap suit, 12 Aaron Mason was the one I had the most contact with in 13 drawing up this criminal complaint. 14 Q I take it we are going to get to that shortly? 15 A Yes. 16 Q But returning to the declaration that Ingram 17 gave you in Oklahoma City, large portions of that were 18 incorrect and untrue; is that right? 19 A They were deliberately false. 20 Q Did you put them in your declaration? 21 A Did I put them in there? 22 Q Yes. The statements that were untrue, were 23 you the one who put the statements in your declaration? 24 A No. What I did is I gave him the information 25 from my experiences, and from that information, he is the 125 1 one that created a story from that information, from our 2 confirming information. 3 For example, the people involved in my 4 deprogrammings, I gave him the accurate information from 5 there, and with that information, he created a story and 6 published it, and I signed it. 7 Q This was Ingram? 8 A Eugene Ingram. 9 Q At the time did you express any discomfort at 10 the contents of the declaration? 11 A The only discomfort that I expressed was the 12 fact that people who were serious about confirming the 13 information would find that it was false, and that I could 14 be held liable for that. 15 And he said absolutely not; that from his 16 experience as a private investigator, his experience with 17 the court system, his experience working with Bowles & 18 Moxon, his experience as a former Los Angeles police 19 officer, that there is no way I would be held culpable for 20 any of that misinformation, and that if I was subpoenaed or 21 called to answer to any of that information, that Bowles & 22 Moxon would step in and protect me from any type of 23 liability. 24 Q Was this after Ingram had made the threats 25 that you spoke about before? 126 1 A This was after the threats, that's correct. 2 This is after he said that I could trust him. 3 Q This was after he threatened to bring either 4 criminal or civil proceedings against you if you didn't 5 cooperate? 6 A That's correct. 7 Q So what happened next? 8 A Well, I went to Oklahoma City, of course. 9 Q You signed the declaration. Then what 10 happened after you signed the declaration? 11 A After I signed the declarations, Eugene told 12 me that he was going to use me as a government witness and 13 a prosecution witness; that I had to be very careful in not 14 doing anything that would lead people to believe that I was 15 acting on behalf of the Church of Scientology, but that I 16 would be used as a witness, and that I would be talking a 17 lot with Tim Bowles, Kendrick Moxon and Randy Spencer in 18 the future, and that I would be working directly with them 19 as a witness. 20 But that there would be special projects along 21 the way that OSA would have me do, but we would constantly 22 put out this idea that I'm not associated with the Church 23 of Scientology in any way; that I'm simply a disgruntled 24 former member of the Cult Awareness Network who is alarmed 25 by the criminal activities perpetuated by the Cult 127 1 Awareness Network. 2 Q Did you have any conversation with him about 3 these comments he was making to you and about this 4 arrangement? 5 Did you discuss why it was necessary for you 6 to be distanced from the Church of Scientology network? 7 A Yes. He said that Scientology had a bad rap, 8 in particular with the media; and that I would be expected 9 to do a lot of interviews, and particularly in the Los 10 Angeles area Scientology has gotten a bad rap, particularly 11 from the Los Angeles Times, and the Time Magazine article 12 didn't help them either; and that was the media Scientology 13 intended to pick on. So in order to do a positive thing to 14 the media, I had to come across as an independent witness. 15 And that is exactly what I did in Oklahoma 16 City. I was the main speaker at a press conference. I was 17 on three television stations. I was -- my interview was 18 printed in the newspaper. 19 Q That was on the earlier occasion? That was 20 much earlier, though? 21 A This was in Oklahoma City. This is where I 22 came out on television and said Cynthia Kisser was not only 23 a strip dancer, Cynthia Kisser was also a prostitute in 24 Arizona. 25 Q When was this? 128 1 A October -- well, it was the Halloween weekend, 2 which was October, November of '91. 3 Q This was the same occasion at Oklahoma City 4 that you signed the declaration and also on television 5 and also -- 6 A Press conference on television. 7 Q -- made the phone calls and interfered at the 8 conference, et cetera? 9 A Yes. Also, at the conference I tried to get 10 Gayle Kelly, G-a-y-l-e, K-e-l-l-y, to assault me; tried to 11 provoke him and his security man to assault me. And this 12 was a specific directive by David Butterworth for the 13 purpose that once that happened, and if they even bumped 14 me, we would call in the police, have them charged with 15 assault and battery, and disrupt the conference, and hold 16 Cynthia Kisser responsible because Cynthia Kisser was the 17 one that hired Gayle Kelly to do security for the 18 conference. 19 Q Then what happened? 20 A Well, we had a hospitality room in a portion 21 of the hotel, and we showed videotapes, and we had an 22 elaborate food table laid out, and we invited members of 23 the Cult Awareness Network who are not strong members, 24 simply maybe parents and people that were checking the Cult 25 Awareness Network out, could come down to the hospitality 129 1 room, and we basically spread a lot of disinformation, and 2 tried to convince people to not have any association with 3 the CAN. And I have to say that two or three people that I 4 talked to said they weren't coming back so it was 5 successful. 6 Q Did you identify yourself as being part of the 7 Church of Scientology? 8 A At that time I was not a member of the Church 9 of Scientology. The impression was I was not a member of 10 the Church of Scientology, no. 11 I was a member -- I was a volunteer of the 12 Friends of Freedom Network, which is a national interfaith 13 coalition of pastors and laymen concerned about people's 14 attempts to interfere with religious liberties and 15 religious freedom. 16 Q Is that who sponsored the hospitality room at 17 the Oklahoma City convention? 18 A The name of the sponsor in all the paperwork 19 was Friends of Freedom. The financing came from the Church 20 of Scientology, which funds all of the Friends of Freedom 21 network activities. 22 Its founder, George Robertson, who is a cult 23 leader in Baltimore, Maryland, who travels around the 24 country saying that he has absolutely nothing to do with 25 the Church of Scientology, that he does this on his own 130 1 time and his own funds, when, in fact, it is all 2 Scientology. 3 Q How do you know that? 4 A Because I have assisted George Robertson on 5 several occasions whereby George Robertson has given me 6 information which I found later to be total lies; 7 information that he said which Scientology was not 8 involved. 9 In fact, David Butterworth himself, Tim Bowles 10 himself, Kendrick Moxon himself has challenged in their own 11 conversation. He said that they were the ones responsible, 12 not George Robertson. So I was getting messages from both 13 people, and they were totally different. 14 Q What things were Bowles & Moxon involved in 15 that you recall they claimed? 16 A I'm sorry? 17 Q Let me rephrase that. What sort of things do 18 you recall Bowles & Moxon claiming that they were involved 19 in contrary to Mr. Robertson? 20 A First of all, George Robertson said that an 21 investigation had been done on me, and that Eugene Ingram 22 was sent by George Robertson to come to Portland. Eugene 23 himself told me that Bowles & Moxon paid him to come to 24 Portland. So there is a lie. 25 Also, when they told us to carry hidden audio 131 1 tape-recorders in the pockets of our jackets and tape 2 conversations, there was a concern that taping someone 3 without their consent was a violation of federal law; there 4 was a wire-tapping statute involved. 5 George Robertson stated that he had spoken 6 with the District Attorney, and that everything was all 7 right, that Oklahoma was a one-party tape state, and it was 8 okay. 9 However, David Butterworth told me that George 10 was not involved at all, that it was Tim Bowles that had 11 contact with the District Attorney's office, and they 12 etched it out that it was a one-party tape state. So any 13 conversations that took place with attorneys in Oklahoma 14 came directly from Bowles & Moxon. 15 The airline ticket that I got to Oklahoma City 16 said right on the airline ticket down at the bottom, "Paid 17 by Bowles & Moxon." Again, George Robertson told me 18 verbally that he paid for the way. 19 "How come it says Bowles & Moxon on the 20 ticket?" 21 "Oh, they are just helping us." 22 Q How do you know that Scientology has made 23 payments to Robertson's organization and to Robertson? 24 A It comes from the Scientologists themselves. 25 Q Such people as? 132 1 A Tim Bowles has told me in the past that he 2 helps finance them in their activities. And George 3 Robertson has told me that he gets absolutely no funding 4 from the Church of Scientology. 5 And our Sue Taylor, who was the Director of 6 Public Affairs in Washington, D.C. told me that the entire 7 operation in Oklahoma City, which involved flying me to 8 Oklahoma City and paying my expenses, flying Jason Scott 9 and assisting in the finances of seven other Scientology 10 members in that operation, was all paid for by the Church 11 of Scientology. George Robertson said he paid for it all. 12 Q Did she say which particular Church of 13 Scientology paid for it? 14 A Church of Scientology International. 15 Q Why would the Church of Scientology 16 International engage in that sort of expenditure, if you 17 know? 18 A Because the Church of Scientology -- well, 19 one is they have a fair game policy which they implement 20 very generously against their critics. They are out to 21 destroy people that criticize them. They are out to 22 destroy their perceived enemies. 23 And David Buttterworth, Tim Bowles, Ken Moxon, 24 Randy Spencer, Eugene Ingram, have all told me in several 25 conversations that they want the Cult Awareness Network out 133 1 of the way, and they will do anything they can to destroy 2 it and discredit the personal and professional integrity 3 of its officials. 4 Q When did Tim Bowles tell you this? 5 A This occurred in late November of '91 when the 6 Church of Scientology, specifically Bowles & Moxon, flew me 7 down to Los Angeles to assist them. That was later on, 8 after Oklahoma City. 9 Q Is there anymore to tell me about Oklahoma 10 City in October of '91? 11 A Only that when David Butterworth arrived at 12 the hotel, he never left his room. David was fearful of 13 anyone from CAN knowing of his presence in the hotel, and 14 that he had quite a bit of computer equipment in his room, 15 video equipment in his room. I'm talking about volumes of 16 it in his room. 17 And every time we brought a tape up to his 18 room, he was transcribing this over his computer and 19 relaying that to the Church in Los Angeles. And each time 20 we were in his room, David Butterworth would sit me down 21 and say, "This is what we heard from Los Angeles. Try 22 focusing on this person and get this information out of 23 this person." 24 And it usually had to do with deprogramming. 25 "Try to find out from Rick Roth, from Jerry Whitfield, from 134 1 Hannah Whitfield, Mary Ellis Chrnaloga and other 2 deprogrammers what future cases they may have, what 3 Scientologists may be targeted for future deprogrammings." 4 And that was basically it. But he was getting 5 information from CSI in Los Angeles and passing it on to 6 us. 7 Q So what happened next? 8 A After I got back to Portland, I was told by 9 Gwen Mayfield -- she actually called me up. She says, 10 "There is a very important message for you." 11 And I said -- I asked her what it was. She 12 said, "You need to call David Butterworth in Los Angeles 13 immediately." 14 I called David Butterworth in Los Angeles. He 15 said that they had a special project for me. 16 Q Where did you call him in Los Angeles? 17 A I called him at the OSA office, which is -- I 18 believe the address is 1410 Berendo Street in Los Angeles, 19 the American Saint Hill Organization Building, which is the 20 corporate headquarters for the Church of Scientology 21 International. And David -- 22 Q Do you recall the phone number that you 23 called? 24 A 661-0 something, or rather in my deposition 25 among the evidence is a document which I published 135 1 confidential contacts, and it has approximately 15 names of 2 people that I was associated with in the Church of 3 Scientology. 4 Let me pull the document that is in front of 5 me. It is categorized from 1 to 23, and it states at the 6 top, "Confidential Personal Contacts." 7 And the telephone number I would always call 8 is 661-0836, and from there they would link me directly to 9 David Butterworth. 10 Q That is the same prefix as Bowles & Moxon? 11 A No. Bowles & Moxon is -- it's 213, right, 12 because Bowles & Moxon is situated on the floor directly 13 above the Office of Special Affairs. 14 Bowles & Moxon, in all of its correspondence, 15 lists itself as 6255 Sunset Boulevard, and that is a front 16 for the Church of Scientology. It is simply a room that 17 they use on occasion. But their actual offices are on 18 Berendo Street on the fourth floor of the Saint Hill 19 Organization Building directly above the Office of Special 20 Affairs. 21 Q Now, that is the corporate headquarters you 22 said of the Church of Scientology International? 23 A That is the intelligence division, what I know 24 as the corporate headquarters. That is also the building 25 which was raided by the FBI in 1977. 136 1 Q How do you know it is the intelligence 2 division? 3 A Because I worked for the intelligence 4 division. Office of Special Affairs is the intelligence 5 service for the Church of Scientology International. 6 Q Why would a church have an intelligence 7 division? 8 A Are you talking about a real church or an 9 organization using a church as a guise to hide its 10 activities? 11 Q Well, what I am asking is why does the Church 12 of Scientology International need or have an intelligence 13 operation? 14 A That is a very good question. Maybe the court 15 can answer that. 16 Q Do you have any knowledge on the subject? 17 A No, only that the Church of Scientology, from 18 my experience, is prepared to destroy anyone and everyone 19 that confronts it and criticizes it, including not only 20 individuals like myself, but the FBI and any law 21 enforcement agency that dares to investigate or confront 22 it. 23 Q Now, you received a message to call David 24 Butterworth in Los Angeles, and you did that, and what 25 happened next? 137 1 A I was told that I was going to be flown down 2 to Los Angeles to meet with him and other people down in 3 LA, and that I was not to tell anybody that I was coming to 4 Los Angeles. 5 Q When was this phone call? 6 A It was approximately the second week of 7 November. 8 Q Which year? 9 A 1991. 10 Q So what happened next? 11 A I flew to Los Angeles. I was met at the 12 airport by Matt Bratschi, who was a member of the sea org, 13 and an assistant to Gayle Armstrong, Director of Public 14 Affairs, Church of Scientology International. 15 Q Is that the Office of Special Affairs portion 16 of CSI? 17 A The Public Affairs Office is located in the 18 chambers of the OSA. 19 Q Which is part of the Church of Scientology 20 International? 21 A That's correct. 22 Q Did you fly down on a prepaid ticket or -- 23 A Yes, I did. Roger Stodola called me up and 24 told me exactly where I would be flying to and who would 25 pick me up at the airport, and that I was to tell no one 138 1 because this was a very special project. 2 When I asked him what he went meant by 3 "special," he said he couldn't discuss it. When I 4 challenged and said that I might have a conflict whereby I 5 could not fly to Los Angeles, he told me that this was a 6 very special project that required my presence, and he 7 mentioned that it had the approval -- had the knowledge and 8 approval of David Miscavige. And when I heard that, I 9 assumed that it was something very special, something very 10 important. 11 Q Who was Roger Stodola? 12 A Roger Stodola was the assistant to David 13 Butterworth in the Office of Special Affairs. 14 Q Who is David Miscavige? 15 A David Miscavige is the chairman of RTC, 16 Religious Technologies Center. 17 Q Does he hold any office in the Church of 18 Scientology International? 19 A Well, Scientology wants you to believe that he 20 is the president of the International Church of 21 Scientology, that he is at the very top, and that he holds 22 the highest post within the Church of Scientology. That 23 has been questioned. 24 Q The international association, is that the 25 International Association of Scientologists which you were 139 1 just referring to? 2 A I'm talking about the Church of Scientology 3 International. He is the chairman. 4 Q Have you seen that written anywhere, that he 5 is chairman of Church of Scientology International? 6 A I have seen it in articles that he is chairman 7 of the RTC, but I have also been told prior to my reading 8 that that he was chairman of the RTC, and if I needed to 9 call him -- in fact, I was given some phone numbers, and I 10 don't know if it is in here, where I could contact him at 11 the RTC. 12 Q Do you mean he is also chairman of the Church 13 of Scientology International as well? 14 A That is my understanding. 15 Q And to digress for a moment, are you a member 16 of the International Association of Scientologists? 17 A In the spring of 1992, I sent in $350 to 18 become a member of the International Association of 19 Scientologists, and I received a membership card in the 20 mail, but since leaving the Church, I have never heard a 21 word. 22 Q Now, getting back to what we were talking 23 about, turning back to your personal contact sheet, which I 24 think we will make Exhibit 1, I notice on page 1 under item 25 2, you have David Miscavige, 213 960-3101. 140 1 A Yes. This was a number where I contacted him 2 and reached him directly. 3 (Document referred to was subsequently 4 marked by the reporter as Exhibit 1 for 5 identification and is hereto annexed.) 6 Q BY MR. BERRY: Was that a direct line to him 7 personally? 8 A A woman answered the phone. I told her who I 9 was, and who referred me, and she connected me, and he 10 answered the phone. 11 Q Did the woman announce where it was that you 12 were calling? 13 A She said, "Religious Technologies Center." 14 Q On what occasion did you call Dave Miscavige? 15 A Well, first I called down there to find out 16 exactly why I was going to Los Angeles, and I didn't get a 17 response. 18 The other time that I spoke with David 19 Miscavige was when I was told to because it was announced 20 that David Miscavige was going to be interviewed by Ted 21 Koppel on Night Line, and Scientologists -- the general 22 idea was that it was going to be a heroic opportunity for 23 him to clarify the good deeds of Scientology. 24 And David Butterworth specifically told me to 25 call him and praise him and applaud him, as he was telling 141 1 other people to do, and basically make this man feel worthy 2 of attention because of his interview. 3 Q Returning to your flight to Los Angeles, you 4 were met by Matt Bratschi, and then what happened? 5 A Matt Bratschi asked me if there was anything 6 that I wanted to do. I told him that I wanted to visit the 7 Hollywood Expedition Center, which is a new center opened 8 by Scientology in Hollywood in the former Charlie Chaplin 9 Building. He took me there. The place was closed, but he 10 opened it up and gave me a special tour. 11 At approximately midnight, we then drove to 12 the Office of Special Affairs, where I met with David 13 Butterworth again, and David Butterworth -- 14 Q Whereabouts in the Office of Special Affairs? 15 A This is on the third floor of the Saint Hill 16 Organization Building on Berendo Street. 17 Q Did Matt Bratschi drive you in a car there? 18 A Matt Bratschi had a car, and he drove me. 19 Q Was this the first time you had visited any of 20 the Scientology offices in Los Angeles? 21 A Yes. 22 Q So how did you gain entry to the building? 23 Did you park in an underground lot? 24 A There is no underground lot. It is a former 25 hospital, and there is a parking lot that faces Sunset 142 1 Boulevard. It faces Sunset Boulevard and the Kaiser 2 Hospital across the street. 3 Q Did you have to go through security or -- 4 A No, there was no security there. They had 5 security people walking the building. I assume they knew 6 who Matt Bratschi was because he had an access code which 7 put him through the security doors of the OSA. 8 And during the time that I was in Los Angeles, 9 the four days that I was there, I was questioned by several 10 people, but I told them who I was with, they checked with 11 him, and I was cleared, and I had access. 12 Q How were these people dressed? 13 A In uniform. 14 Q What kind of uniforms? 15 A Blue, a dark Navy blue. They had a lot of 16 senior citizens that dressed in a different uniform; gray 17 pants and blue jacket. And you had security people dressed 18 up in blue. 19 Q Anyone in brown shirts or anything? 20 A No. You had a number of people dressed up in 21 the sea org white uniforms, and a couple of people that had 22 the special sea org braids, the colored braids on their 23 jackets. 24 Q What about weapons? Any of them wearing guns? 25 A I didn't see anyone with a gun. I know that 143 1 there is at least -- I have been told there is armed 2 security on the premises, but no one ever showed a gun to 3 me, and very rarely was I stopped. 4 Q Now, you said you needed security access to 5 the Office of Special Affairs Church of Scientology 6 International. What did you mean by that? 7 A When you go into the Saint Hill Organization 8 Building, on the first floor there is a bookstore, and it 9 is basically a reception area for the public wanting to 10 come in and learn more about Scientology or where 11 Scientologists will bring perspective members in to learn 12 about Scientology. 13 On the second floor, there is classrooms. On 14 the third floor, there are some more classrooms. And then 15 as you go down the hallway, directly in front of you there 16 is two large wooden double doors which are only accessible 17 by an electrical combination system that you have to punch 18 numbers into to get doors to open. 19 There is also a small reception desk in front 20 of the doors, and you have to get to the receptionist 21 before you get to the doors, and the receptionist is the 22 one that answers all the phone calls coming into the OSA. 23 Q Does she just answer for OSA or does she 24 answer for other people as well? 25 A Just OSA. 661-0836 is the number, main OSA 144 1 number, and that is the one that rings into this 2 receptionist. She has approximately 12 phone lines on her 3 switchboard. 4 Q So you gain access through this coded security 5 system on the third floor to OSA; correct? 6 A That's correct. 7 Q What is on the floors above? 8 A On the floor above, directly above, there is 9 another set of doors that you have to enter by a keyed 10 security, the actual offices of Bowles & Moxon. 11 Q So is there an elevator to that floor? 12 A There is no elevator to the floor. It is an 13 old building. You have to walk upstairs or you can enter 14 by the stairwell in the back. There is a stairwell in the 15 back, and both doors are heavy, metal doors, and they are 16 both locked. 17 Q So you walked to the fourth floor of the 18 building. What address, again, was this? 19 A I believe the address is 1401. It is on 20 Berendo Street, and Berendo runs into Sunset Boulevard. 21 The boundaries are Sunset, Berendo and Catalina Street. 22 Q And on the fourth floor, you also have to have 23 security card access? 24 A To get into the OSA or Bowles & Moxon it is a 25 keyed security system that you have to punch numbers into 145 1 to get in. 2 Q On the first night that you were there about 3 midnight, you went to the Office of Special Affairs; 4 correct? 5 A That is correct. 6 Q With Matt Bratschi? 7 A Matt. 8 Q What happened then? 9 A Matt turned me over to David Butterworth. 10 David Butterworth took me down to Public Affairs and 11 introduced me to Gayle Armstrong, who is the Director of 12 Public Affairs. 13 Q When you say took you down to Public Affairs, 14 what do you mean by that? Was that on the same floor? 15 A When you go into the Office of Special 16 Affairs, you have a number of offices. The first office on 17 the left is what they refer to as the Legal Affairs Office, 18 and it is not Bowles & Moxon that they refer to as Legal 19 Affairs. And the best way I can describe it, it deals with 20 the legal issues that come up through the OSA because they 21 had a legal officer in there. 22 You have some other rooms on the left which 23 were simple, like conference rooms and offices, and then in 24 approximately the middle of these chambers is what they 25 refer to as the war room, and there is a series of 146 1 computers, fax machines, in the room, that are on-line all 2 the time. 3 And then there is a huge leader board up 4 against the window facing south, and on this board is a 5 large chart, and it is a chronology of activities that are 6 taken against various members, critics of Scientology, and 7 it has a list of names ranging from Cynthia Kisser, Steve 8 Hassan, Priscilla Coates, a number of deprogrammers. 9 And then on the line above it are the names of 10 Church members assigned to do investigations on each one of 11 these individuals. 12 And in each one of these boxes, it is marked 13 by a slash, and on the left side of this slash is how many 14 phone calls, what kind of information you got on somebody, 15 the number of occurrences that you did on this individual 16 within a week's time, and you mark it on the left side. 17 On the right side of the slash is how many 18 times that actual information has been used to go against 19 that individual. They kept statistics. 20 Q Did it include judges and lawyers as well? 21 A It had the lawyers that -- a lot of lawyers. 22 Well, it had Ford Greene on there, specifically, Margaret 23 Singer, Galen Kelly, a lot of CAN people. 24 I'm trying to remember lawyers that were on 25 there. Oh, they had Martinez -- I forgot his first name. 147 1 He is a lawyer. 2 Q Raul Martinez? 3 A He was an attorney which was earlier bitten 4 by a rattlesnake put in his mailbox. 5 Q Paul Morantz? 6 A Paul, yes. Joe Yanny. Specifically, Gerry 7 and Larry -- 8 Q Gerry? 9 A Gerry Armstrong, Larry Wollersceim, 10 W-o-l-l-e-r-s-c-e-i-m, a Larry Levin, and I don't recall 11 anybody else. 12 Q Did you ever learn that information was being 13 routinely collected on the judges in Scientology cases and 14 the lawyers that were opposing them in Scientology cases? 15 A I'm sorry? 16 Q Did you ever learn that Scientology, 17 specifically, the Office of Special Affairs, was gathering 18 information on the judges that were assigned to Scientology 19 cases and the lawyers that were opposing Scientology in 20 Scientology cases? 21 A Oh, that was just a matter of fact with them, 22 with the OSA, was to get information on whoever you can get 23 information on. 24 Q For what purpose? 25 A Just data on them. That is one of the 148 1 purposes of OSA, is to gather data. 2 Q Did you ever ask why they were gathering this 3 data? 4 A Because the Church of Scientology was very 5 interested in destroying those individuals that were the 6 perceived enemies of Scientology. Anyone who criticized 7 them did not deserve to exist. 8 Q Did that include lawyers opposing it in 9 different cases? 10 A I would assume that to be the case, yes. 11 Q You mentioned the fair game policy. Was this 12 part of the fair game policy? 13 A Yes. 14 Q How did you first learn about the fair game 15 policy? 16 A I heard of the fair game policy -- when I 17 first heard of it? 18 Q When and how. 19 A In November of '91, when Gayle Armstrong said 20 that they were going to take out the fair game policy on 21 Cynthia Kisser, and I did not know what that meant. 22 Q Was that when you went down the hallway to her 23 office? 24 A That's correct. And she went into another 25 room. I didn't see what room. But she brought back a 149 1 huge, green book, light green cover, and she opened up this 2 book, and she showed me -- it was a photocopy of an earlier 3 policy, and it was signed at the bottom -- it had printed, 4 "Copyright," some date, 1968, I believe, "L. Ron Hubbard, 5 Registered," and it said, "Fair Game Policy," and it listed 6 the different elements of the fair game policy, and one of 7 those elements was "trick or be destroyed." 8 Q Was anything ever said about the fair game 9 policy being revoked at any point? 10 A Not from Scientology, no. 11 Q If someone said to you that Scientology 12 claimed to have revoked the fair game policy, what would 13 you say, at least as of October 1991? 14 A I'm sorry. Say that again. 15 Q If in October 1991, Scientology, or one of 16 their officials, had claimed they revoked the fair game 17 policy, what would your response be? 18 A That is a deliberate lie. 19 Q If they said it was revoked against all but 20 SP's, what would your response be? 21 A That would be a deliberate lie. One thing I 22 want to mention, too, is the often comedy atmosphere, 23 almost circus-like atmosphere that some of these 24 conversations had in the OSA. 25 And when it was brought up how someone could 150 1 take the fair game policy or other issues in a very serious 2 manner, how they laughed and said, "Well, it doesn't take a 3 lot for the Church of Scientology to simply say that one of 4 our members were misled and made the mistake of taking an 5 action against somebody, and it was just a personal action. 6 We simply say they did it on their own, and no one would 7 think twice about it." 8 And they laughed about that quite a bit. And 9 Eugene laughed all the time and gloated about how people 10 could accuse him or accuse the Church of doing something 11 that was unethical or even criminal, and he would simply 12 say that the person was responsible, the person made the 13 mistake, and, basically, draw attention away from the 14 Church. 15 And when they talked about this, it wasn't 16 with a serious tone. They are always laughing and joking 17 about how they make this happen. And that the court system 18 was a blow over, and that judges could be fooled, and it 19 was not hard to lie to people and convince them. 20 And I knew that for a fact because I had gone 21 through TRL's, too, and I convinced the Cult Awareness 22 Network that I was legitimate until they started 23 investigating me and found out otherwise. So I 24 successfully lied to these people. 25 Q What are TRL's? 151 1 A A training routine created by the Church of 2 Scientology to teach people how to lie convincingly to go 3 to court, lie in deposition, and even go so far as to be 4 able to pass lie detector tests and lie about it. 5 I have never taken a lie detector test so I 6 don't know if it works. But they told me if ever I was 7 sued, that Tim Bowles and Kendrick Moxon and his staff 8 would teach me how to lie so convincingly that everyone 9 would believe what I had to say. 10 Q Who told -- 11 A This was a training routine that was 12 implemented over and over again. 13 Q Who told you that? 14 A Eugene Ingram and David Butterworth. 15 Q Have you ever heard of something called the 16 witness college? 17 A I have heard of the witness college, also 18 referred to as a witness school. And the first time I 19 heard that was when I was in the Church in 1985 in 20 Portland, and they were teaching Church witnesses that were 21 involved in Julie Christofferson's case to go to the stand 22 and lie in that case and convince them that the Church of 23 Scientology was basically right. 24 Q Did you actually see this happen? 25 A I'm sorry. I saw Scientology witnesses 152 1 testify in court, but I don't know for a fact that they 2 were lying or not, although they were accused of doing so 3 afterward. 4 Q What is the basis of your personal -- do you 5 have personal knowledge? Were you told? Did you see it? 6 Did you read it? 7 A Well, for three years I was perpetuating a lie 8 within the Cult Awareness Network saying I was not 9 Scientology. 10 I was interviewing with the media saying I was 11 not Scientology, while Cynthia Kisser was actively saying 12 that I was Scientology, and I convinced a number of people 13 that Cynthia Kisser was blowing hot air. 14 Q Going back to the Christofferson case, the 15 coaching of witnesses there, how did you obtain that 16 information? 17 A I was told -- and this, again, was a very 18 comedic atmosphere -- by John -- 19 Q John? 20 A -- Carmichael that there was an attorney -- 21 and he said this in a very casual conversation. There was 22 an attorney by the name of Mark Segal who, with Tim Bowles, 23 sat people down and taught them how to lie in a very 24 convincing way to fool a jury into believing what they had 25 to say. 153 1 And I specifically was told how Mark Segal was 2 a wonderful, neat, attorney; very sophisticated, very 3 smart, and very good at what he did, as far as a training 4 routine and lying was concerned. 5 Q Were you led to believe that Bowles was 6 actually present in Portland for the Christofferson trial? 7 A I was led to believe that. Also, later, when 8 Bowles & Moxon drew up the complaint which they were going 9 to file on my behalf, and which Tim Bowles was going to 10 represent me in, I learned from Gwen Mayfield that Gwen 11 used to be a legal clerk for Tim Bowles in Portland, Oregon 12 because Tim Bowles is licensed both in Oregon and 13 California, and that he used to practice in Portland. 14 MR. BERRY: Off the record. 15 (Brief recess.) 16 Q BY MR. BERRY: What else did you know about 17 Tim Bowles coaching witnesses in training routine lying or 18 the witness school for the purpose of coaching witnesses to 19 lie? 20 A That is the extent of it, other than, like I 21 have said before, Eugene assured me that no one that worked 22 with him, cooperated with him, like myself, or even Jason 23 Scott, who in Oklahoma was concerned about his lying, that 24 there was nothing that Bowles & Moxon could not do to 25 prevent us from any type of criminal or civil liability; 154 1 that Bowles & Moxon would step in immediately. 2 And Eugene gloated that they could throw so 3 many legal maneuvers at the courts that they would never 4 have enough time to even address any type of complaint 5 against me or anyone else that had filed a phony complaint. 6 Q What about any other Bowles & Moxon 7 attorney being engaged in training routine lying or 8 coaching witnesses to lie at the witness school? 9 A None that I can be specific about other than 10 the legal complaint which was drawn up on my behalf was 11 drawn up also by Randy Spencer, whom David Butterworth told 12 me was an outside attorney not involved with the Church of 13 Scientology from Chicago. And I learned from Tim Bowles 14 that, in fact, he was on staff at Bowles & Moxon, and that 15 he was a Scientologist. So I got two different stories 16 there. 17 Q Have you ever heard of "hatting the witness"? 18 A I have heard of it, but I don't know 19 specifically what that means. I know what a hat is. 20 Q In Scientology, what is a hat? 21 A A hat is a job. I wore a lot of hats. 22 Q Have you personally known witnesses who have 23 testified on behalf of Scientology in cases before? 24 A On behalf of Scientology? 25 Q Yes. 155 1 A Recently or past? 2 Q Let's strike that question and go off the 3 record. 4 (A discussion was held off the record.) 5 THE WITNESS: Other than Eugene Ingram has lied in 6 deposition. 7 Q BY MR. BERRY: How do you know that? 8 A I recall a conversation I had with Dan Leipold 9 whereby he was asked about the declarations that had my 10 name on it, and Eugene Ingram said that he spent 100 hours 11 interviewing me, and in complaints that he filed with the 12 Attorney General's office, the FBI, the IRS, in which I 13 received copies of and are introduced as evidence in some 14 of my depositions, he stated that he confirmed and 15 collaborated every fact in my declaration, and that is all 16 baloney. 17 If they were to investigate that declaration, 18 they would have found out that Eugene Ingram is a liar, and 19 that he did not collaborate something that cannot be 20 collaborated. 21 Q So all of your facts in your various 22 declarations were not confirmed with you and checked and 23 verified? 24 A Absolutely not. You cannot confirm things 25 that did not take place. And Eugene said that he 156 1 personally -- and he places his license as a private 2 investigator on it -- that he confirmed it. 3 Well, he lied, and he compromised his license 4 as a private investigator. And he claims to be an employee 5 paid by Bowles & Moxon. So right there is your connection. 6 Q So you deny that Ingram ever verified the 7 factual accuracy of the contents of those various 8 declarations that he prepared on your behalf? 9 A There are some instances in that 10 declaration -- if you want, I can go through the 11 declarations that he prepared and show you where he lied. 12 Q I think you did that with Mr. Leipold, didn't 13 you? 14 A I did that a little bit, but not to a great 15 extent. But in the complaints that he has filed with 16 investigatory agencies, like the FBI, the Postmaster 17 General, the Attorney General, whereby he said -- and used 18 my declaration as an example, and stated that I was a 19 former CAN deprogrammer, he claims to have verified the 20 facts in my declaration. 21 He did not do it because he couldn't do it. 22 It was all fabricated. He knew it. And from my experience 23 of knowing Eugene Ingram, he is a very -- he is damn good 24 at what he does. He will compromise anything. He will 25 sell his own grandmother if it will get him some 157 1 information to benefit his clients. He has no ethics 2 whatsoever when it comes to his position as a private 3 investigator. 4 Q Does the Church of Scientology appear to be 5 his only client? 6 A Eugene Ingram told me that he has other 7 clients, but I have never heard of his other clients. He 8 is kept so busy by the Church of Scientology and Bowles & 9 Moxon. 10 Again, he told me that he simply works for 11 Bowles & Moxon; that Bowles & Moxon represents the Church 12 of Scientology, and that they are not connected in any way. 13 But how come their offices are in the Church 14 of Scientology building? How come their members are 15 Scientologists? How come Eugene Ingram is constantly in 16 the offices of the OSA working directly with David 17 Butterworth and they are constantly exchanging information? 18 How come they are always in conspiracy with 19 one another if they have absolutely nothing to do with one 20 other? 21 Q Does Eugene Ingram have an office at Bowles & 22 Moxon? 23 A Eugene Ingram claims to have his own office, 24 although he will not reveal where that office is. Whenever 25 I call him, it has either been on his mobile phone or it 158 1 has been at the OSA. 2 Q Now, you mentioned complaints that Ingram had 3 made to various government entities such as the Post 4 Office. What were these complaints? 5 A I believe you have copies of them present. 6 They were complaints accusing the Cult Awareness Network of 7 violating its 501-C tax exempt status; that it was accused 8 of violating the RICO Act; that it was actively involved in 9 racketeering, fraud, misrepresentation. And as a piece of 10 evidence to validate those accusations, they referred to 11 Garry Scarff and Jonathan Nordquist. 12 Q These are complaints made by Scientology? 13 A Yes. No, not by the Church of Scientology. 14 Again, as I have said, Eugene Ingram deliberately 15 misrepresented himself and states that he has nothing to do 16 with the Church of Scientology, that he is simply an 17 employee of Bowles & Moxon, and that it is the attorneys 18 representing Scientology that are behind these complaints, 19 and that is deliberately falsehood. 20 It is all one big part and parcel package, and 21 it is the Church of Scientology filing its complaints. 22 Q So you are saying that Bowles & Moxon, Eugene 23 Ingram and OSA is all part of the Church of Scientology 24 International? 25 A It is all a working relationship to produce 159 1 the same result. They are all in collaboration with one 2 another. 3 When I worked with OSA, I was constantly in 4 contact with Bowles & Moxon. And if you want to validate 5 that, all you need to look at is my telephone bills for the 6 last two years. I had numerous phone calls made to Bowles 7 & Moxon, the OSA, and they are constantly together all the 8 time. 9 In fact, I made so many phone calls to CSI, to 10 OSA, to Bowles & Moxon, that Bowles & Moxon was reimbursing 11 my telephone bills on a monthly basis through Eugene 12 Ingram. I got a monthly reimbursement check from Eugene 13 Ingram for all of my expenses, not only my telephone 14 expenses, but all the paper that I put out, letters like 15 this (indicating) that I sent out to 500 plus members of 16 the Cult Awareness Network, the list which I received from 17 Bowles & Moxon listing the names and addresses of CAN 18 members, and that was a very expensive project which they 19 reimbursed me for. 20 MR. BERRY: The witness just referred to the word 21 "this." So let's make this Exhibit 2, which is, "An Open 22 Letter To CAN Members" dated August 4, 1992, from Garry 23 Scarff entitled "Viewpoint." 24 (Document referred to was subsequently 25 marked by the reporter as Exhibit 2 for 160 1 identification and is hereto annexed.) 2 THE WITNESS: This letter is referred to as "the 3 dialogue letter." At the time that we were looking at 4 destroying Cynthia Kisser and the Cult Awareness Network, 5 David Butterworth had in his mind to implement this idea to 6 fool people into thinking that they really wanted to 7 dialogue with them. 8 So this is a letter which seeks to dialogue 9 with members of the Cult Awareness Network to open up their 10 minds to the reality of the situation and to show that 11 Cynthia Kisser is a corrupt person that should be removed. 12 Q BY MR. BERRY: Now, going back to training 13 routine lying, what about Martin Samuels? To your 14 knowledge, did he ever lie as a witness? 15 A It is my understanding, from what I can 16 remember, that he has admitted to lying on the stand for 17 Scientology during the time that he was a member of the 18 Church of Scientology, and, in fact, before testifying in 19 the Christofferson case sought immunity from any type of 20 prosecution for that perjury, and that they refused to 21 grant him that immunity. 22 And, I believe, if I am not mistaken, he was 23 cited for that, but I don't know what became of it. He 24 later has admitted that he lied on the stand for 25 Scientology. 161 1 Q Do you know who he admitted that to? 2 A I don't recall exactly. After leaving the 3 Church of Scientology, I had conversations with other 4 ex-members of the Church who validated what I was saying, 5 and said that from their experiences, that they knew 6 exactly what I was talking about and what TRL's were. 7 Q "TRL" is "Training Routine Lying"? 8 A "Training Routine Lying." 9 Q Now, before we started talking about fair game 10 and the witness school and training routine lying, you had 11 been taking Matt Bratschi down the hall or down to see 12 Gayle Armstrong, I think. 13 A Yes. 14 Q That was when you were flown down to Los 15 Angeles for this important project; correct? 16 A That's correct. 17 Q Now, what happened when you went down to see 18 Gayle Armstrong? 19 A Gayle Armstrong -- I am trying to remember 20 when I first talked to her. Well, they introduced me to 21 Gayle, and Gayle told me she was in charge of Public 22 Affairs, and that she would be working closely with me on 23 this project, which at that time had not been revealed to 24 me yet. 25 And David Butterworth told me that he did not 162 1 want to deal specifically with it because it was so late; 2 that he wanted to check me into the motel and then early 3 the next morning we would discuss what he wanted me to do. 4 Q So what happened next? 5 A The next morning we had a meeting. 6 Q I presume you had checked into the motel? 7 A Travel Lodge, yes. 8 Q Is there sleeping accommodations available at 9 Scientology's facilities here? 10 A I'm sorry? 11 Q Do they have sleeping facilities available 12 here? 13 A Yes. In fact, I went to check into the Travel 14 Lodge, and it turned out that someone had goofed up on the 15 reservations, and so I did not stay there, and I was given 16 an opportunity to sleep in what they refer to as pigs 17 berthing, and I knew what that meant when I got there. 18 Q Where is pigs berthing? 19 A It is in a building right adjacent to the 20 Saint Hill Organization Building. They claim to be 21 remodeling it, although I haven't seen them do that. 22 It is a huge, very old building with a series 23 of rooms, approximately 10 floors, that I can remember, 24 which houses a lot of the cadets from the sea org and staff 25 members from the Church. 163 1 You have rooms that hold anywhere from 50 to 2 100 bunk beds, and people are assigned -- those are their 3 living quarters -- as a group living situation. And I 4 ended up taking someone's bunk bed for the night. 5 Q Is that building next door to -- I'm sorry, 6 you said it was next door to the Saint Hill Organization 7 Building? 8 A That's correct. 9 Q Is it the Saint Hill Organization that houses 10 the Office of Special Affairs and Bowles & Moxon? 11 A That is correct. And also on the basement 12 level, there is a huge lunch room, cafeteria. 13 Q Do the Bowles & Moxon attorneys have berths in 14 the pigs berthing area? 15 A It is my understanding that they have 16 apartments in the adjacent building to berthing, which are 17 single apartments. It's the one that is the very light 18 blue, that is kind of V-shaped. 19 Q So after you spent a night in pigs berthing -- 20 A That is what it was. 21 Q -- what happened next? 22 A The next morning, I was told to report to the 23 OSA, that David Butterworth would be waiting for me. At 24 approximately 8:00 in the morning, I went into the Saint 25 Hill Organization Building, and no one was around. I went 164 1 upstairs and waited. No one was there. 2 Q Where did you wait? 3 A I waited outside the offices of the OSA. 4 Q What date are we roughly talking about? 5 A We are talking about November 17th. And it 6 was at that time that I was told my specific reason for 7 being in Los Angeles. 8 Q We are getting ahead now. So you were waiting 9 outside the Office of Special Affairs. Then what happened? 10 A I waited around for an hour until someone from 11 OSA showed up and told me that David Butterworth would be 12 up shortly. And he eventually showed up and was concerned 13 about where Matt Bratschi was, and it turned out the person 14 assigned to be my guide for the weekend was still asleep in 15 berthing, and I was told he was a candidate for RPF since 16 he was not meeting his responsibilities. 17 Q And then? 18 A Then approximately at 9:00 o'clock, we had a 19 meeting in the Office of Special Affairs. 20 Q Who was there? 21 A David Butterworth, Matt, Gayle Armstrong, 22 Wendy -- whose name I don't remember, but she is a member 23 of the sea org, and she is an assistant to Gayle 24 Armstrong -- myself, and that was it. 25 But later, Reverend Peter Paine, who was a 165 1 member of a church bible-based cult out in Illinois, who 2 has a satellite church in San Diego, came into the meeting, 3 and it was told to me then -- 4 Q Just a moment. By "Matt," you mean Matt 5 Bratschi? 6 A Yes. 7 Q Why was this Peter Paine from some satellite 8 church involved? Was this a Scientology satellite church? 9 A No. 10 Q Or will it all become apparent in a moment? 11 A Off the record. 12 (A discussion was held off the record.) 13 Q BY MR. BERRY: Now, back on the record. By 14 "Matt," you mean Matt Bratschi? 15 A Matt Bratschi, right. 16 Q And Peter Paine is a reverend who is involved 17 with another organization; is that right? 18 A Reverend Paine is the pastor of the Christian 19 Fellowship Church in a suburb of Chicago in Illinois who 20 had an association with the Church of Scientology due to a 21 criminal case that they were involved in. 22 Q I think we will talk about that a little 23 later. Now, what happened at this meeting? 24 A I was specifically told that I was going to be 25 the main speaker at a press conference; it was the 13th 166 1 anniversary of the Jonestown tragedy; and that they were 2 going to have me present this conference in front of the 3 Old People's Temple Building in Los Angeles at the corner 4 of Hoover and Alvarado Street, and that Scientology had 5 been working -- the Public Affairs office through Gayle 6 Armstrong had been working fervently, overtaxing the fax 7 machines, sending out press releases to all the media in 8 the Los Angeles area, and that even copies of the press 9 release went to Barrington, Illinois, which is the national 10 office where the national Cult Awareness Network office is 11 located. 12 And the reason for this press conference was 13 that the Cult Awareness Network and the Jewish Federation 14 Council of Los Angeles was sponsoring a Jonestown 15 commemorative memorial service at the Jewish Federation 16 Building, and that they were flying Patricia Ryan in, and 17 that they heard that Patricia Ryan was trying to bring the 18 media into televising this commemoration. And so 19 Scientology wanted to do something to challenge that 20 opportunity. 21 We held the press conference. I spoke from a 22 script. Eugene Ingram was present, making sure that I did 23 everything correctly. And at that press conference, I 24 accused Cynthia Kisser and Patricia Ryan of all kinds of 25 criminal activities, and that Patricia Ryan was a whore 167 1 because she was compromising her professional integrity, 2 her personal integrity, by simply being a marketing tool 3 for the Cult Awareness Network, using her dead father's 4 situation to improve her status in the Cult Awareness 5 Network. 6 Quite a few media people were present, 7 including a gentleman from the Los Angeles Times whom 8 Eugene identified as an associate of the Cult Awareness 9 Network. 10 Q What was his name? 11 A I don't recall his name. I remember what he 12 looked like. I don't recall his name. I followed that 13 press conference up with a number of radio interviews over 14 the phone. Then that evening, me, Matt -- 15 Q All this happened the same day of the meeting? 16 A That's correct. 17 Q At OSA, after you slept the night in the pigs 18 berth? 19 A Yes, correct. Then that evening I was told 20 that me, Matt Bratschi, Mark, Lipscum -- Mr. Lippman, who 21 is a Jewish Scientologist, was going to go to the Jewish 22 Federation Council and disrupt the ceremony, and with us 23 would be a gentleman from the OSA that had a videotape 24 camera, and he was going to videotape the disruption. That 25 is basically what we tried to do. 168 1 Mr. Lippman -- Bob Lippman, I think his name 2 is -- and Mark tried to make their way into the Jewish 3 Federation Council Building, but were observed and known to 4 be Scientology and kicked out. 5 I was confronted by a security officer of the 6 Jewish Federation Council who ordered me to leave, and I 7 threatened to kick the shit out of him if he didn't back 8 off. 9 And we basically objected to the presence of 10 Patricia Ryan being in the building, and talked one media 11 person from leaving the area. 12 And after that, we went back to the OSA, and 13 we were debriefed, and everyone was celebrating because we 14 did such a wonderful job of disrupting it. 15 I recounted my approaching Priscilla Coates, 16 C-o-a-t-e-s, and Jolly West, W-e-s-t. 17 Q Who are they? 18 A Priscilla Coates is a member of the Cult 19 Awareness Network, one of the long-time members of CAN. 20 She was a founder of the CFF -- 21 Q What is CFF? 22 A Citizens Freedom Foundation. 23 -- and is currently a defendant in many 24 Scientology-based slap suits. 25 Q And Dr. West? 169 1 A Dr. Jolly West is a professor of psychiatry at 2 UCLA that has talked about Scientology in a very critical 3 way openly. 4 Q So what happened next? 5 A We went back to the Church and was told by 6 Mr. Butterworth that there was a special meeting going to 7 be held that evening in the OSA, and that -- 8 Q By going back to the Church, what do you mean? 9 A Went back to the OSA at the Saint Hill 10 Organization Building. 11 Q Was that when you recounted your -- when you 12 told them about Priscilla Coates -- 13 A Priscilla Coates and Jolly West, yes. 14 Q Then David Butterworth -- 15 A David Butterworth informed me there was 16 another special meeting. I told him I was tired and wanted 17 to go back to the motel. He said, "Well, this is something 18 that cannot wait, and it is a very special meeting." 19 And later after dinner we went back into the 20 OSA office. It was simply me, Eugene Ingram, David 21 Butterworth and Matt Bratschi. 22 And then there was a woman there that came in 23 later by the name of Linda, who I assume was an assistant 24 of David Butterworth. I don't know her last name. I have 25 had conversations with her later on the phone in the OSA 170 1 office. 2 And it was a plan to -- first of all, it came 3 out -- 4 Q Let me back up a moment. Where was this 5 meeting? 6 A In the OSA office. 7 Q Do you remember whose office it was in? 8 A There was a series of offices there, and it 9 wasn't just one of the offices. I don't know whose office 10 it was. It was like a conference room. It was adjacent to 11 the Public Affairs office. 12 Q This is the evening of November 17th, is it? 13 A It is either the 17th or the 18th. It was on 14 a Saturday. 15 Q About what time? 16 A Approximately midnight. 17 Q So what happened at the meeting? 18 A It was at that meeting when they stated that 19 they were going to go into another area of activity which 20 they felt could really end the Cult Awareness Network once 21 and for all. 22 David Butterworth stated that he felt that the 23 Cult Awareness Network was already on shakey ground; that 24 there was one person who was the glue to keeping the Cult 25 Awareness Network together, and that was Cynthia Kisser, 171 1 and that if we could get rid of Cynthia Kisser once and for 2 all, then the Cult Awareness Network would fall apart. 3 Eugene Ingram then stated that Cynthia Kisser 4 was a bitch who did not deserve to live, and wouldn't it be 5 wonderful if we could get her out of the picture once and 6 for all. 7 And they were talking about how the OSA had 8 been successful in the past, particularly with Gabe 9 Cazzeras. He is a former mayor of Clearwater, Florida, who 10 was involved in a car accident. 11 And there was a conversation asking me how 12 committed I was, how far would I go to prove my commitment. 13 And I was asked by Mr. Ingram what I would do if someone -- 14 he said, "This is just a hypothesis. What would you do if 15 someone came up and asked you to kill somebody?" 16 And I put on this front of commitment, and I 17 said, "I will do anything you ask me to do." And they said 18 that they wanted to get rid of Cynthia Kisser; that one 19 very easy way of getting rid of somebody is cutting the 20 brake lines on their car or releasing brake fluid. 21 And they talked about the fact that people 22 have had brake lines cut in their cars before and that 23 people haven't died from it. 24 And other follow-up suggestions were taking a 25 pillow once Cynthia Kisser was knocked over the edge of the 172 1 road, hit a tree, went into a ditch or something, shoving a 2 pillow in her face, suffocating her dead. 3 Eugene Ingram said, "That is a possibility." 4 An option that I might have is taking a .357 and blowing 5 her away if she did not die in the accident, or possibly 6 dragging her body to a nearby lake and putting her under 7 the water and drowning her. 8 Quite frankly, I was very stunned and thought 9 that this was a joke, but I also knew that it wasn't. And 10 I was very concerned about the implications of that. And I 11 was assured that Bowles & Moxon would protect me no matter 12 what the situation was. 13 And if need be, Eugene Ingram knew of safe 14 houses in Mexico City or Canada, that he had a son going to 15 a college in Denver, and that there are a lot of places in 16 the Denver/Boulder, Colorado area he could hide me if 17 people started asking questions. But that until this whole 18 thing blew over, that Bowles & Moxon would be able to step 19 in and discount if anyone decided to come after me. 20 Q How did Bowles & Moxon come to get mentioned 21 as providing protection for you if they came after you in 22 relation to killing Cynthia Kisser? 23 A Because I was very concerned that if somehow 24 they linked me to killing this woman, who was going to 25 protect me. I had no one to go to except them. 173 1 Q Did they say what Bowles & Moxon would do? 2 A I just was told they would protect me, and if 3 there was any type of law enforcement coming after me, they 4 would step in, and they would protect me. 5 And then he said, "If necessary, we will get 6 you to a safe house outside the country." Eugene also said 7 he had relatives in Brazil, and if need be, he would get me 8 a passport and fly me to Brazil, put me into hiding there. 9 Q Did he say how he would get you a passport? 10 A Not specifically. He just said he had that 11 access. But the idea of running her off the road and 12 cutting her brake lines did not alarm me as much as when he 13 suggested the possibility of taking a .357 and blowing her 14 brains out. 15 And when I questioned that, he laughed and in 16 a very kind of a sneering way, he said, "Well, the bitch 17 deserves nothing better." 18 Q So what was said next? 19 A Eugene talked about how to further make an 20 impact because if Cynthia Kisser died in this, what would 21 prevent Priscilla Coates from stepping in and taking over. 22 And then Eugene brought up the possibility of 23 taking her daughter with her, killing off her young 24 daughter. That's all. 25 Q Then was anything else said at this meeting? 174 1 A Only they asked me if I was committed enough 2 to do it, and I said, "Yes." And they said they would get 3 in touch with me, and that they wanted it done fairly soon. 4 And I received a phone call that the plan was 5 going to go into action on Thanksgiving holidays, and they 6 booked me airfare to Chicago, where I was instructed to get 7 a rental car and get in contact with Randy Kretchmar, 8 K-r-e-t-c-h-m-a-r, and Allen Brooks, who are staff members 9 with the OSA in Chicago, and they would provide me routes, 10 the know how to cut a brake line, the route that Cynthia 11 Kisser took from her home in Wonderlake, Illinois, to 12 Barrington, what other routes to take once I did this, and 13 how I could get out of the area, who to contact, and that 14 once it was done, Mr. Kretchmar would help me get out of 15 the area, and they said it would all be taken care of. 16 I need to take a break, please. 17 (Brief recess.) 18 Q BY MR. BERRY: The discussion about killing 19 Cynthia Kisser took place at the OSA late on the evening of 20 November 17 or 18; correct? 21 A Correct. 22 Q There was no one present from Bowles & Moxon 23 at that meeting, was there? 24 A No. 25 Q Was there discussion about anything other than 175 1 the elimination of Cynthia Kisser? 2 A Only when I told Eugene that I was very scared 3 about being caught, and he told me one other option that I 4 had was to TKO. 5 Q What does "TKO" mean? 6 A And he told me that I could talk to David 7 Butterworth about what TKO was. And Mr. Butterworth 8 informed me that TKO meant "total key out." 9 "Key out" in the Church of Scientology is a 10 term to describe keying out of a reactive mind, becoming 11 more rational, becoming more focused in the thinking 12 process. A total key out would be total elimination of the 13 reactive mind or suicide. 14 Q What do you think he meant when he told you 15 about TKO? 16 A He was suggesting that one option I had was to 17 kill myself after I did this. And he, Eugene, specifically 18 told me that there were very painless, easy ways to kill 19 yourself; that in his experience as a Los Angeles police 20 officer, he saw numerous ways where people kill themselves 21 or were killed. 22 And I remember commenting that, "Well, like on 23 all the TV shows, a person sticks a gun in his mouth and 24 pulls a trigger." 25 He said, "You don't want to do that because 176 1 there is a possibility it might not sever your spinal cord. 2 An easier way was to stick your" -- this is really hard to 3 talk about. I'm sorry. 4 "The easier way was to stick the barrel of the 5 gun in your mouth, up through the gum so not only it would 6 shoot up, it would sever the brain stem. And although you 7 may not die immediately, at least the brain is dead, and 8 you would not feel pain." 9 Q Who else was present when he was talking about 10 this? 11 A David Butterworth himself. 12 Q Anyone else? 13 A No, sir. 14 Q Was anything else discussed at that meeting 15 that night? 16 A No. I was just really fazed because not only 17 with the idea of trying to -- I mean, what I saw was a 18 commitment, but they were also talking about the 19 possibility of my killing myself. 20 And I had started having a lot of questions 21 about just how committed they were towards me, and why I 22 was selected to do this. 23 Q Did you ask? 24 A Why I was so special. 25 Q Did you raise any of those questions with 177 1 them? 2 A I did with Eugene Ingram. 3 Q At that meeting or -- 4 A At that meeting. 5 Q What did he say? 6 A And Eugene said from the time that I started 7 in Scientology, I had always been wishy-washy; that I was 8 always back and forth, and here I was trying to prove 9 myself. This would be one way to really prove myself, and 10 that I had absolutely nothing to worry about in terms of 11 being caught or anything because there were always ways to 12 get out of it, and this was one way I could prove myself 13 with something that they truly wanted done. 14 And then Butterworth gloated, "Just think, if 15 you were the one responsible for destroying the Cult 16 Awareness Network, you would be a hero, and L. Ron Hubbard 17 would be honored to have you by his side." 18 Q What do you think they meant by "to have you 19 by his side"? 20 A Well, I figured what they were saying is that 21 I would have left my body and be dead just like L. Ron 22 Hubbard was. 23 Q Was that the first time you had heard of TKO? 24 A That was the very first time. 25 Q Have you spoken about TKO with anyone since 178 1 then? 2 A I asked when I -- after I left the Church, I 3 asked Gerry Armstrong what TKO was, and he said he had 4 never heard of it. I asked Gerry Whitfield; he had never 5 heard of it. Hannah said that she heard of it, but wasn't 6 specific as to what it meant. 7 I had also heard of EOC, and a number of 8 ex-members I asked about EOC, and they didn't know what it 9 was either until one member, Gerry Whitfield, said he 10 pulled it out of a Scientology text and defined what EOC 11 was. 12 Q What does "EOC" stand for? 13 A "End of cycle." Suicide. 14 I really had questions about what they really 15 wanted, whether they wanted me out of the way, too, or 16 why -- 17 Q Did you raise those questions? 18 A I just wanted -- I did. And I asked them why 19 I was the one, and they said they knew I could do it. 20 And David Butterworth said that from what he 21 knew of my experience, that I was a very angry person, and 22 that I could utilize that anger in a very positive and 23 constructive way, and this was one way of doing it. 24 And I remember asking him why the Cult 25 Awareness Network -- why they were so threatened by the 179 1 Cult Awareness Network, and they were very, very angry at 2 Cynthia Kisser, and that Cynthia Kisser was one of the 3 reasons that Scientology was suffering so much, and to get 4 rid of her and the Cult Awareness Network, none of these 5 deprogrammers out there would have a resource to go to, and 6 they would fall by the wayside, and we would be able to get 7 on with our work and not be bothered. 8 Q What was the work they wanted to get on with? 9 A Scientology. 10 Q Anything else at that meeting that you can 11 recall? 12 A Not that I recall. 13 Q So what happened after the meeting finished? 14 A The next day I was preparing to leave. They 15 said they would get in contact with me. Eugene Ingram said 16 that he had had some contacts with a syndicated television 17 show, Inside Edition; that he wanted me to interview with 18 the producer for Inside Edition in Los Angeles. 19 So we drove to their offices in West L.A., and 20 went to their offices, and I interviewed with the producer, 21 and it was basically a slam Cynthia Kisser/Cult Awareness 22 Network project, and they didn't seem real interested in 23 the project. 24 And then afterwards, Eugene and I went to 25 lunch, and he said that the Church had great plans for me, 180 1 and that everyone, when they heard how committed I was, was 2 very happy; that David Miscavige was sorry that he could 3 not meet with me, but that he had other things going on, 4 but he knows about me and is very happy with me, and that I 5 was seen as a hero. 6 And then we just started talking about other 7 issues, like the sea org, and he told me that, in his 8 experience, that he had some problems with the 9 para-militaristic element of Scientology, but they were 10 very nice people, and they had only good intentions. And I 11 asked him if he ever felt betrayed by Scientology, whether 12 they could come against him, because in my own experiences, 13 I felt that I was praised and abused, and it was a 14 rollercoaster of praise and abuse. 15 And he said that they would never dare come 16 against him because of everything that he has done. And he 17 said that he learned this as a police officer, that you 18 record, you write down everything, and everything he has 19 written and submitted to the Church of Scientology, he has 20 reproduced; that he has a rental storage unit in the 21 Mt. Washington area near his home, and that he has kept 22 everything that he has ever provided to Scientology. 23 And if the Church of Scientology ever did 24 anything against him, he would, "Fuck them up the ass 25 royally." Those were his exact words; that they knew 181 1 better not to ever screw him. 2 Q When was this conversation? 3 A This was on the morning -- it was Sunday 4 morning -- I'm sorry. Monday morning. And I believe it 5 was November 20th. I could be wrong on the date, but it 6 was a Monday morning of that weekend when I flew back to 7 Portland. 8 Q Was it the day after or the day after the day 9 after the evening conversation about Cynthia Kisser? 10 A It would have been Saturday -- it would have 11 been the Monday after because the conversation occurred on 12 Saturday night, and then there was Sunday where I had 13 planned to go back, but they wanted to keep me an extra day 14 just to talk and to do radio station interviews, which I 15 did. 16 Q What happened during these radio station 17 interviews? 18 A Well, Gayle Armstrong was the one that set it 19 up. It was basically to attack the Cult Awareness Network 20 and to symbolize that the reason that the Jonestown tragedy 21 happened was that people were being unfairly persecuted for 22 their religion and not being left alone, and that people 23 that were opposed to diverse religious beliefs were being 24 attacked, and that is why they felt compelled to kill 25 themselves, and that the Cult Awareness Network were the 182 1 ones responsible for leading these witch hunts against 2 religious organizations. 3 So that was the scope of my interviews on 4 radio. I have to admit that several of the interviews 5 didn't go real well, and I was viciously attacked in 6 response by the hosts who said that, "If you have anything 7 to do with the Church of Scientology, we know in basis you 8 are a liar." 9 Q Did you have any meetings that day with 10 Scientology representatives? 11 A No. I hung around with David Butterworth 12 throughout the day. That afternoon, I was in the OSA 13 office, and David Butterworth told me that he wanted me to 14 step out into the hallway to introduce me to his staff, and 15 I went out to the hallway with him and Eugene, and the 16 entire staff of the OSA, Legal Affairs for OSA, and Public 17 Affairs were all standing outside at parade resting in 18 military type of -- they were standing out there in a 19 military troop. I don't know how you would describe it. 20 They are standing out there at attention, except everyone 21 was at parade rest in rows of three. 22 And I was told that they were members of the 23 sea org, and that is why they were acting very militaristic 24 and at parade rest. 25 David Butterworth talked about the Cult 183 1 Awareness Network and their endeavors to end the Cult 2 Awareness Network, and he said that, "Due to some very 3 positive things that happened this weekend, I can honestly 4 say that the Cult Awareness Network will totally be out of 5 existence within one year, and that Garry Sharff has agreed 6 to help us in that endeavor." 7 And I was applauded by the staff and asked to 8 talk to the staff. 9 Q And did you? 10 A Yes, I did. 11 Q What did you talk to them about? 12 A I said that Cynthia Kisser and the Cult 13 Awareness Network within one year will be history. That 14 was it. 15 Q So did you have any other conversations of 16 consequence with David Butterworth that Sunday? 17 A Well, I was with David Butterworth throughout 18 that evening, but there was no specific conversations. I 19 spent a lot of time in the war room. He was showing me 20 what they do with the computer systems. 21 He did suggest that I pay a visit that evening 22 to Priscilla Coates and to harass Priscilla, but Eugene 23 Ingram put a stop to it, saying that it would interfere 24 with what we wanted to accomplish in the future. 25 Q Who was Priscilla Coates? 184 1 A Priscilla Coates is a founding member of the 2 CFF, a long-time member of the Cult Awareness Network. She 3 is the director of the Cult Awareness Network's affiliate 4 for Southern California, Los Angeles, and is a defendant in 5 a number of legal actions filed by the Church of 6 Scientology. 7 Q And what did he explain to you with regards to 8 the computers? 9 A He told me that everything that they had ever 10 retained on anyone with connection to any adversary of the 11 Church of Scientology was in the computer -- names, 12 addresses, personal information, everything was entered. 13 All data was inside the computer banks, and 14 that was the main computer center, the main computer hub 15 for the Church of Scientology International. 16 Q What else did you learn about the war room? 17 A Well, I just know that all the different 18 intelligence banks throughout the United States, the 19 different OSA offices, communicate through that war room, 20 that computer room. 21 And off to the far right there were just huge, 22 metal shelves full of faxes, and that every OSA office in 23 the country will fax reports to this room, and this room 24 inputs it into the main computer. 25 Q Now, the Office of Special Affairs is part of 185 1 Church of Scientology International; correct? 2 A Yes, it is a division; it is the Guardian's 3 Office. 4 Q How do you know that? Does it seem common 5 knowledge in Scientology? 6 A Yes, it is common knowledge. Sue Taylor told 7 me. In fact, because Sue Taylor was one of the original 8 members of the Guardian's Office at the time that the 9 Church of Scientology was served with a search warrant by 10 the FBI, and that following the conviction and sentencing 11 of the four leaders of Scientology who were sent to prison, 12 that the Church of Scientology decided to do a major 13 reorganization, and that they got rid of the Guardian's 14 Office, and they kicked out all the bad apples in the 15 organization, replaced them with good, ethical people, when 16 in fact what they did was simply redub the Guardian's 17 Office and named it the Office of Special Affairs. 18 Sue Taylor, who is working directly with OSA, 19 is the former Guardian's Office. By no means was she 20 kicked out or penalized for her activities in the 21 Guardian's Office. She is very effective, and a very 22 effective voice now working with David Butterworth in OSA 23 activities. 24 And David Butterworth himself told me that the 25 Special Affairs used to be called the Guardian's Office, 186 1 but because of the conviction of the Scientology leaders, 2 and because of the bad public image it received, that they 3 were on an endeavor to promote and improve their public 4 image, and the Guardian's Office had a very bad stigma 5 attached to it. So it was simply renamed the Office of 6 Special Affairs, and basically does the same things. 7 However, it has been changed, so there is no 8 unethical or criminal activity involved. That is the 9 public side of it. Realistically, it is all lies. 10 // 11 // 12 // 13 // 14 // 15 // 16 // 17 // 18 // 19 // 20 // 21 // 22 // 23 // 24 // 25 // 187 188 ================================================================= 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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