Gerry Armstrong--Reporter's Transcript Scientology v. Armstrong 05-04-1984 LASC No. C 420153

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

DEPARTMENT NO. 57 HON. PAUL G. BRECKENRIDGE, JR., JUDGE

CHURCH OF SCIENTOLOGY OF CALIFORNIA,

Plaintiff,

vs.

GERALD ARMSTRONG,

Defendant.

MARY SUE HUBBARD,

Intervenor.

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NO. C 420153

REPORTERS' TRANSCRIPT OF PROCEEDINGS

Friday, May 4, 1984

APPEARANCES:

(See Appearances page.)

VOLUME 5

Pages 598 - 812

NANCY L. HARRIS, CSR #644
HERB CANNON, CSR #1923
Official Reporters

APPEARANCES:

For the Plaintiff:

PETERSON & BRYNAN
BY: JOHN G. PETERSON
8530 Wilshire Boulevard
Suite 407
Beverly Hills, California 90211
(213) 659-9965

-and-

ROBERT N. HARRIS
The Oviatt Building
617 South Olive Street
Suite 915
Los Angeles, California 90014
(213) 623-7511

For the Intervenor:

LITT & STORMER
BY: BARRETT S. LITT
Paramount Plaza
3550 Wilshire Boulevard
Suite 1200
Los Angeles, California 90010
(213) 386-4303

-and-

BARRETT S. LITT
BY: MICHAEL S. MAGNUSON
The Oviatt Building
617 South Olive Street
Suite 1000
Los Angeles, California 90014
(213) 623-7511

For the Defendant:

CONTOS & BUNCH
BY: MICHAEL J. FLYNN

- and-

JULIA DRAGOJEVIC
5855 Topanga Canyon Boulevard
Suite 400
Woodland Hills, California 91367
(213) 716-9400

VOLUME 5

I N D E X

Day	Date	Session	Page

Friday	May 4, 1984	A.M.	598
		P.M.	714

W I T N E S S E S

PLAINTIFF'S WITNESSES:	DIRECT	CROSS	REDIRECT	RECROSS

VORM, Tom (Resumed)	608	665	673
ARMSTRONG, Gerald
(Excerpts from the depositions of Gerald Armstrong were read into the record verbatim starting at page 691.)

E X H I B I T S

DEFENDANT'S	IDENTIFIED	RECEIVED

C - Declaration by Mr. Vorm	610	610

598

LOS ANGELES, CALIFORNIA; FRIDAY, MAY 4, 1984; 9:07 A.M.

-o0o-

MR. HARRIS: Before resumption of cross-examination,

Your Honor, pursuant to Your Honor's order, I am producing

to the court for in camera inspection, and there are some

privileges that will he asserted with respect to these three

inventories; one dated 24 September, 1982, inventory of

materials turned over to the court by Attorney Michael Flynn;

one dated 3 September, 1982, inventory of material turned over

to the court by Contos & Bunch; and one undated, summary of

materials returned by Omar Garrison.

599

THE COURT: All right. Hand them to the clerk.

MR. FLYNN: Your Honor, what I am looking for is the

inventories prepared by the church.

MR. HARRIS: The problem, Your Honor, is that these

inventories were prepared pursuant and in some cases prepared

by an attorney. But those where the church people participated,

it was at the direction of attorneys with attorneys present

with the sealed documents in the case of the sealed documents.

And in the case of the other items, at the direction of an

attorney.

In any event, I think we can argue it when the

time comes. But for right now, at least, I have complied

with the court's order.

THE COURT: I am not sure I understand where there is

a disagreement.

MR. FLYNN: There has been, I am informed, an extensive

inventory on computer prepared by the church with regard to

almost every single piece of paper that is downstairs. In

addition to that, there has been an inventory prepared of

the Omar Garrison materials by the church as a well as an

inventory of the controller archives prepared by the church.

That is what we are looking for.

MR. HARRIS: Your Honor, I have no knowledge of any

computer items. I do have knowledge of these three inventories

which is what the court ordered and which I have produced

for the court.

The court specifically asked us to bring --

I can actually probably find the court's words --

600

MR. FLYNN: With the church inventories, Your Honor,

I submit that we would be able to prove that all the documents

under seal are also in possession of the church.

MR. HARRIS: That simply isn't true and he can't

prove it.

THE COURT: There has not been any testimony yet that

there is such an inventory of materials that -- all of the

materials relating to these different archives have ever

been inventoried.

601

MR. FLYNN: The individual who apparently is most

familiar with it is Kenneth Long. On the current state of

the record if the church and the intervenor go no further

and introduce no further evidence with regard to specific

documents that they claim are not in their possession, either

copies or originals, then I would submit they probably wouldn't

have made out their case and I wouldn't need the inventories,

but if they are going to persist in the allegations that there

are 2- to 3,000 pages of originals that they don't have

copies of, and are unable to submit one document, I submit

the only way I can prove that they do is through their own

inventories.

MR. HARRIS: Your Honor, requested, you asked Mr. Flynn:

"What is it you want inventories

of, materials which are downstairs or files

under seal?

"MR. FLYNN: Yes, Your Honor.

"THE COURT: If you have such an inventory,

you are ordered to produce it."

I said, "We will produce it tomorrow."

I have. That was one inventory requested.

The next inventory requested:

"MR. FLYNN: Your Honor, may that be

produced also if an inventory has been done of

Omar Garrison's documents?

"THE COURT: If there is such an inventory,

then the church will be ordered to produce it."

I have.

602

THE COURT: Well it appears to be in compliance with

the court's order.

MR. FLYNN: At this state of the record, Your Honor,

maybe I will let the issue rest.

THE COURT: Okay. We will let it rest. Put it to

sleep.

Now, what about these particular inventories?

I assume that there is nothing here that in a sense is

confidential because these documents, other than -- as to

what is in the court's files under seal, either side could

have made an inventory.

You have got stamped on here "confidential

attorney-client privileges."

MR. HARRIS: That, Your Honor, was prepared by

Mr. Peterson who is here specifically in connection with the

litigation in this case.

THE COURT: True, I can understand why you might

contend it was work product.

MR. HARRIS: I do. I contend it is both work product

and attorney-client privileged, both.

MR. FLYNN: If I could be heard, Your Honor.

THE COURT: Don't interrupt my thinking at the moment.

Just relax.

603

THE COURT: I have rather hurriedly scanned through

this document, the series of documents that deal with the

inventory materials turned over to the court by Contos & Bunch.

I don't see anything here that would be characterised as

attorney-client privileged.

I don't see anything that would be absolutely

privileged on their work product other than possibly some of

the characterizations of the attorney which, I presume would

be his interpretation of some of these documents. That,

presumably, would be absolutely privileged such as reference

to whether something is an original or a carbon copy of

what it might be. That would be interpretation and would be

absolutely privileged.

But certainly, his description of what is there

can't be privileged because it is down there. It is in the

court's possession. It came from the attorneys Contos &

Bunch.

I can't see anything other than possibly some

interpretation which I could cross out.

MR. HARRIS: The problem is, Your Honor, when you

are describing documents, you cannot help but put your own

thoughts in respect to it; in other words, there is no such

thing as as objective inventory of the items because it was

being prepared by an attorney in respect to litigation which

is in litigation.

As far as the privilege aspect, the communication

from the attorney to the client, originally only the attorneys

were allowed, as you may recall, in to see the documents.

604

Now, I don't particularly wish to press the issue

of attorney-client privilege. But I would press the issue

of work product which it is fairly clear to me it is. And

I don't think that we should have to give it to Mr. Flynn.

He has had access to the documents. He could have secured

his own inventory.

THE COURT: Well, do you need any of these in your

cross-examination of this witness? Because my disposition

is to review these more carefully and block out anything which

might prove to be an interpretation.

MR. HARRIS: Might I suggest, your Honor, that you

might have to look at the documents in order to do that?

THE COURT: You may make that suggestion, but I don't

think I have to.

MR. HARRIS: Well, I tried.

I think in order to determine if it is an

interpretation, you must have some objective standard on

which to base the determination which is the document itself.

THE COURT: I don't think I have to get that essentially

involved. It is not that super secret. We have got the

documents here.

MR. FLYNN: I think we are missing the issue a little

bit, Your Honor.

THE COURT: I know what you are saying in a sense;

in other words, if something is missing, you want to know what

is missing and what isn't there.

MR. FLYNN: And they are the only ones who have got

access to what isn't there. They have got all the access.

605

They are walking into court and saying there are materials,

even though the witness could not name one document, down-

stairs that they don't have copies of. And they are the

only ones I can elicit evidence from since it is in their

exclusive possession and control.

THE COURT: It is their burden of proof. So if they

want to prove something that is not there, I guess other than

the 2- to 3,000 pages which are down there which are originals

that we don't have, if they can't either with this witness

or other witnesses identify specifically at least some of

these items, I shouldn't think they would be going through

identifying page by page; we could spend years on the case

doing that.

I can understand how a witness might not be

able to say something without having an inventory, but if he

is shown an inventory and then asked to identify items --

MR. HARRIS: The problem, Your Honor, is that, of

course, that can be done. But we are trying to do this case

without getting into the contents of the documents under

seal. And even an inventory describes to some extent the

contents of the documents which we have contended all along

simply should remain under seal.

We are not trying to produce any original

documents in our case-in-chief or any inventories or copies.

MR. FLYNN: If they are going to stipulate that they

are not going to try to prove that any particular original

is down there or any particular original they don't have

possession of in other archives, I would submit that they

606

haven't met their burden of proof if that is what is going

on here.

MR. HARRIS: Your Honor, if at the time we get through

with our case-in-chief we have not done it, met our burden

of proof, I an sure Your Honor will do the right and correct

thing. But as far as I have anything to do with it, we'll

try to do it without producing any of the documents under

seal so as to maintain their privacy interest.

607

THE COURT: All right, well, let's do it this way:

We are going to proceed at this time with the examination

of these witnesses. I will look these natters over when I

have a chance and anything which I conclude might be an

interpretation of counsel, I will delete from it and counsel

will have the right to call any witnesses back for further

cross-examination as it relates to any of these inventories

if I conclude they should be released or returned to defense

counsel for examination.

MR. HARRIS: All right, Your Honor.

THE COURT: I'd like to get off the dime here this

morning.

MR. HARRIS: Sure, I understand that.

the only thing I wanted to assure the court is

that one of the documents, at least, is an internal church

summary of items which are not under seal and that is the

Omar Garrison one.

THE COURT: I realize that.

Let's get the record stated.

In the case on trial, let the record reflect

that all counsel are here and have been here and the witness

has retaken the stand.

TOM VORM,

the witness on the stand at the time of the adjournment,

having been previously duly sworn, resumed the stand and

testified further as follows:

THE COURT: Just state your name again for the record,

608

sir. You are still under oath.

THE WITNESS: My name is Tom Vorm.

THE COURT: You may continue.

MR. FLYNN: Just before I do that, I have one other

witness who is a high church official who came to the court-

house named Lyman Spurlock here today. We are going to

call him as part of our case, but we have found that we are

unable to subpoena anyone from the organization because they

won't let you beyond the front door and they won't tell you

whether anyone is there, so if the court could simply issue

an order that Mr. Spurlock is to return at the beginning of

the defendant's case. He is in the court room now.

THE COURT: You can put him on call if he will agree

to be on call. Otherwise, he will have to remain here until

his testimony is required.

MR. FLYNN: I have one other problem with this

Andrew Lenarcic who filed this original affidavit.

THE COURT: Let's do one thing at a time here.

MR. PETERSON: Your Honor, I have discussed Mr. Flynn's

proposal with the witness. He has to be out of town a

couple of days the mid part of next week. We would agree that

he would be on call. Whether we can produce him on the

first day of Mr. Flynn's defense or some time thereafter, I

am not sure. But we will place him on call and at some

time during the defense we can make him available.

MR. FLYNN: That is fine.

THE COURT: As long as he agrees to be on call through

counsel.

609

MR. PETERSON: We would like 24 hours' notice.

THE COURT: All right, 24 hours' notice.

MR. FLYNN: And the second problem is with this

Andrew M. Lenarcic. We are going to deliver a subpoena over

to the organization, but as I say we can't get by the front

door.

MR. HARRIS: That is not true, Your Honor, really.

THE COURT: I am not going to worry --

MR. HARRIS: I agree.

MR. FLYNN: When we get into the issue of Mr. Hubbard's

availability, you will hear a little more testimony on that

point. But in any event, we are unable to find Mr. Lenarcic

and he is a critical witness to the defense because he says

precisely the opposite of what this witness says that I am

now going to go into.

MR. HARRIS: That is a wrongful characterization,

Your Honor.

THE COURT: Well, people are entitled to characterize

things as they want to characterize than. It is not evidence

and I don't take it as evidence. For whatever it is worth,

I think we ought to proceed with the cross-examination of

this witness.

MR. FLYNN: Fine, Your Honor.

CROSS-EXAMINATION (Resumed)

BY MR. FLYNN:

Q Mr. Vorm, you filed a declaration in this case?

A Yes.

610

THE COURT: And is that a copy of the declaration?

A It looks like it, yes.

Q Is your signature on it, sir?

A Yes, a copy of it.

MR. FLYNN: May that be marked as an exhibit, Your

Honor?

THE COURT: Okay.

THE CLERK: C.

THE COURT: All right, C for identification.

Let me see it.

MR. FLYNN: And I would offer it, too.

THE COURT: Any objection?

MR. HARRIS: No, Your Honor.

THE COURT: All right, be received.

Q BY MR. FLYNN: Mr. Vorm, you testified yesterday

that you received from Mary Sue Hubbard a memorandum dated

11 December, '79; is that correct?

Q That is true.

Q Did that go to you personally, sir?

A Yes, it did.

Q And was it signed by Mary Sue Hubbard?

A It was in her handwriting, the whole thing.

Q Well, there was a phrase that said "much love"

with a place for a signature underneath that; is that

correct?

A Could I see the document?

THE COURT: Certainly.

MR. FLYNN: It is either 10 or 11, I believe.

611

Miss Dragojevic has our copy. She is not here yet.

Q She didn't sign that; did she?

THE COURT: Well there are two different documents.

MR. FLYNN: I am referring to exhibit 10.

THE COURT: Do you have 10, sir?

Okay, fine.

612

Q BY MR. FLYNN: Referring to exhibit 10,

Mr. Vorm, Mary Sue Hubbard did not sign that; did she?

A I don't believe she had her name written on the

bottom, no.

Q Now, in the Guardian's Office was it a practice

for people to transmit one document to another without

signing them?

A Transmit one document --

Q From one person to another without signing them?

A Yes, it was. Yes.

Q And with regard to communications from L. Ron

Hubbard was that also a practice?

MR. HARRIS: If he knows.

Q BY MR. FLYNN: If you know.

A I don't know.

Actually, I would take that back. I think it

was not the case because I received communications from at a

certain point.

Q You received communications from whom?

A Signed "R" at the bottom.

Q Typewritten or handwritten?

A Typewritten.

Q And did you accept that as a communication from

L. Ron Hubbard?

A I assumed it to be, yes.

Q So that was a practice within the organization,

to have a typewritten "R" to signify that it came from

Hubbard; is that correct?

613

A Well, in this particular case. The document

that came to me was that way. So I assumed it was in that

case.

Q The question is was that the practice.

A I don't know about the practice in general, the

organization as a whole.

Q In your declaration, which has been marked as

exhibit 12 --

THE COURT: C.

MR. FLYNN: I offered it -- Oh, exhibit C.

Q You state that these materials that you gave to

Gerald Armstrong belonged and were the personal property of

Mr. and Mrs. Hubbard; is that correct?

A That is true.

Q Now, did all of the materials that you gave to

Gerald Armstrong belong to Mr. and Mrs. Hubbard?

A Well, they all came from Mary Sue's trunks;

do --

Q Throughout the period of the biography project

when you were giving materials to Gerald Armstrong, were

there any materials that you gave him that did not belong to

L. Ron Hubbard or Mary Sue Hubbard?

A I gave him materials on two occasions. Both of

them came from the Mary Sue trunks.

Q So your testimony is that they belonged to

L. Ron Hubbard and Mary Sue Hubbard?

MR. HARRIS: Calls for a legal conclusion, Your Honor.

THE COURT: I'll sustain the objection.

614

Q BY MR. FLYNN: In your declaration you state

that they were the personal property of L. Ron and Mary Sue

Hubbard; is that correct?

A What number?

Q Paragraph No. 3.

A That is true.

Q Now, your testimony, as I understand it, there

were no materials that you gave to Gerald Armstrong that

were not the personal property of L. Ron Hubbard and Mary

Sue Hubbard?

A Well, aside from the legal definition, they came

from Mary Sue's trunks; so therefore --

Q When you prepared this declaration --

Did you prepare it?

A Yes. I didn't type it up, no.

Q You did put in the declaration, did you not,

that they belonged to the Hubbards?

A Right.

Q It was your testimony on direct examination that

they belonged to the Hubbards; is that correct?

A I believe so.

Q Now, you also testified on cross-examination

yesterday that on two occasions you petitioned for and

received approval from the controller; one being Mary Sue

Hubbard and the other being Gordon Cook to give the

materials to Gerald Armstrong; is that correct?

A That is correct.

Q And you stated in those petitions that those

615

materials should be rightfully in his possession because he

was doing the biography project; is that correct?

A From the post function, yes.

Q Now, in your declaration you state in

paragraph 6 that at no time did Mr. or Mrs. Hubbard give you

permission to give those documents to Gerald Armstrong; is

that correct?

A Which document is it referring to?

Q Which document were you referring to, Mr. Vorm?

A Well, let me read this.

That was concerning the documents after

Mrs. Hubbard had gone off post.

Q So if I understand your testimony correctly,

with regard to the materials you gave before Mrs. Hubbard

went off post you did have permission from her to give those

materials to Gerald Armstrong?

A That is true.

Q What materials were those?

A It was the ones that I listed out in this

document here.

Q What are they?

MR. HARRIS: Referring to exhibit --

THE WITNESS: It is exhibit 11, "Comply re LRH

Historical Items."

Q BY MR. FLYNN: What documents are they,

Mr. Vorm?

Take one document at a time, if you would, then

I'll ask you a question.

616

A The yearbook, 1928.

Q Is that document under seal in this court?

A I don't believe so, no.

Q In whose possession is it?

A I am not sure at the moment.

Q Have you seen it in the possession of the

church?

THE COURT: At what time, counsel?

MR. FLYNN: At any time after the beginning of this

lawsuit which is August 1982.

THE WITNESS: No, I haven't.

Q BY MR. FLYNN: Do you know where it is?

A No.

617

Q Well you don't know whether is under seal?

A I don't think it is under seal. I don't recall

seeing it there.

Q What is the next document?

A Book of photos, gray cloth cover.

Q Do you know where those are presently?

A No I don't.

Q Are they under seal?

A I don't believe so, no.

Q What is the next item?

A Brown mounted photos.

Q Do you know where those items are?

A No I don't. I am not exactly sure what that

is referring to.

Q Are they under seal?

A I don't know about that one.

Q What is the next item?

A Brown engraved leather photo binder.

Q Do you know where that item presently is?

A No I don't.

Q Do you know whether it is under seal?

A I don't believe so, no.

Q What is the next item?

A Boy Scout's diary, 1924.

Q Do you know where that item is?

A I believe that is in the Garrison stuff.

Q Is it under seal?

A I don't think so, no.

618

Q Is there any material in this list that is

presently under seal?

A There is one item I am not positive on. Letter

from Thomas J. Kelly.

Q Letter from Thomas J. Kelly?

A Right.

Q Do you recall what that item is?

A What it is about or what it is concerning?

A What it concerns.

A No I don't.

Q Now, does that basically represent the first

group of items that you gave to Gerald Armstrong with Mary

Sue Hubbard's permission?

A Yes.

Q What was in the second group of items that you

gave to Gerald Armstrong with the permission of the

controller?

A Well it was several boxes full. I don't recall

each one individually.

Q Can you recall any document?

A There were quite a few files concerning

Rhodesia. There were some telexes. There were various

files, some typewritten, some handwritten communications.

Q Relating to what?

A To LRH's time when he was in Rhodesia.

Q So the telex is the sub-category of your first

answer to documents relating to Rhodesia?

A Yes.

619

Q Other than the telexes, are there any other

items that you recall?

A There were a lot of, I will say at least

five or six files concerning HEC, which is the Hubbard

Exploration Company.

Q Any other items?

A There were some files relating to LRH's

horticultural experiments.

Q Any other items?

A There were some mortgage papers regarding the

St. Hill property in England.

Q Any other items?

A There were various letters. I recall one

letter to Richard Nixon. There way have been one to Kennedy,

and there were several files of that nature to prominent

people.

Q Do you recall any other items?

A There was a file called Cit, C-i-t, -Wash, stood

for Citizen's of Washington. I believe that was taken.

Q Any other items?

A There was a file or two concerning legal FDA.

These weren't individual documents. These were like files

of documents, a file with about 30 or 50 pages or documents

in the file itself.

Q Any other items?

A If I had the inventory to go through. We

checked them off as we took them. That is all I can recall

offhand, though I could probably think of more if I had more

time.

620

Q Which inventory?

A That is the inventory I kept of the trunks

that we checked off as we --

Q At the time you gave them to Gerald Armstrong?

A That's right.

Q Where is that inventory?

A It is in my file.

Q Was that an inventory that was prepared at

the time you gave them to Gerald Armstrong?

A No.

Q Was it prepared prior to the time you gave

them to Gerald Armstrong; that is, in the trunk?

A Yes.

Q Do you know whether there was a lawyer present

when it was prepared?

A I don't believe so.

Q Where is that inventory?

A It is in my files.

Q Do you have it with you?

A No, I don't.

Q How many pages is it?

A Thirty, forty, something like that.

Q Now, that is 30 to 40 pages of inventory that

just covers the material in the trunk for the second group of

materials you gave to Gerald Armstrong, is that correct?

A No.

Q It covers the contents of the entire trunk?

A Did you say "trunk"?

621

Q Did you find that inventory in the trunk?

A No.

Q Where did you find that inventory?

A It was given by me.

Q By whom?

A By, I think it was, the controller transcriptionist.

Q At the time you received the trunk?

A Yes.

Q Was the inventory done at that time?

A No.

Q It had been done in a prior point in time?

A Evidently, yes.

Q And you went through and you checked off the

materials you gave to Gerald Armstrong; is that correct?

A That's right.

Q When you got the documents back from Omar Garrison,

did you compare that inventory to the materials you got

from Omar Garrison?

A No.

Q Has anyone done that?

A I don't know for sure. It could have been

done. It might not have been done. I don't know.

Q Did you compare it to the materials that were

in the guardian's office archives?

MR. HILL: Well --

MR. FLYNN: All right, I will withdraw it, Your

Honor.

Q Let's get the number of archives that exist

622

in the organization. There is controller archives; is that

correct?

A Which time period are you referring to?

Q Between 1979 and 1981.

A Okay.

Q There are controller archives?

A Right.

Q And then there were what we call biographical

archives; is that correct?

A Right.

623

Q And you testified yesterday that you believed

that in biographical archives there were four filing

cabinets?

A Of -- Well, like original materials. I am not

sure exactly how many materials had been copied.

Q If I suggested to you that biographical archives

would fill almost an entire room that were in the possession

of Mr. Armstrong and they were not in the possession of your

organization, does that refresh your memory?

A Refresh my memory of what size they are?

Q Right.

A No. I would stick to my testimony.

Q The four filing cabinets?

A That's right.

Q Now, the 50,000 documents that came from Omar

Garrison, did those come in filing cabinets or boxes?

A Boxes.

Q How many boxes were there?

A Approximately 15, 20.

Q Has anyone done an inventory since receiving

those documents from Omar Garrison as to what is in those

documents?

A I believe so, yes.

THE COURT: We have got that here, counsel, I believe.

One of these purports to be a summary of materials returned

by Omar Garrison.

MR. FLYNN: Perhaps Your Honor can state in camera,

but I can identify it is the inventory that this witness has

624

seen.

THE COURT: It refers to some 20 boxes.

MR. HARRIS: There has been no establishment --

THE COURT: Have you ever seen this before, sir?

THE WITNESS: I think I recall seeing a copy of it. I

am not sure.

THE COURT: Does that appear to be the inventory of

the material returned from Garrison?

THE WITNESS: It would appear to be, yes.

Q BY MR. FLYNN: In addition to the biographical

archives which were in the possession of Mr. Armstrong and

Mr. Garrison and in addition to controller archives which

are the technical materials you testified about yesterday,

there are also Guardian's Office archives; is that correct?

A Yes. They were called Guardian's archives.

Q And there are Guardian's archives at Worldwide;

is that correct?

A That is true.

Q And have you checked the Guardian's Office World

Wide archives to determine whether any of the materials that

are downstairs under seal are also in those archives?

A Yes. I have.

Q Did you do an inventory?

A An inventory was done.

Q Where is that inventory?

A It is in my file or in my office.

Q Where did you do that inventory?

A I didn't do it.

625

Q Who did it?

A It was done by someone over at Worldwide.

Q And Worldwide is over in England; is that

correct?

A That's right.

Q But you have that inventory in your possession?

A That's right.

MR. FLYNN: Your Honor, may that inventory be produced

together with the inventory relating to the contents of the

trunks?

THE COURT: I'll make such an order -- apparently

these are in this witness' possession and he can deliver

them to his attorney and his attorney can review them and

provide them to the court and we'll do the same thing with

that that we are doing with this.

MR. HARRIS: Very well, Your Honor.

Q BY MR. FLYNN: In your testimony you related --

you testified about documents relating to Rhodesia; in the

biographical archives that were either returned by

Mr. Garrison or in what you say is the four filing cabinets,

are there documents relating to Rhodesia?

A Yes.

Q How many, if you know?

A Several file folders.

Q Either in the biographical archives or in the

documents returned by Mr. Garrison are there documents

relating to the Hubbard Explorational Company?

MR. HARRIS: Just so I get this straight, Your Honor,

626

is he talking about the biographical archives presently in

the possession of the church and this witness as opposed to

the biographical archives taken by Mr. Armstrong which are

under seal in this court?

MR. FLYNN: Correct, Your Honor.

MR. HARRIS: Which is correct, Mr. Flynn?

Q BY MR. FLYNN: Mr. Vorm, we'll call the

biographical archives under seal as the sealed documents and

the biographical archives in general are the biographical

archives in the possession of the organization.

A Okay.

627

Q Now the biographical archives that are in

the possession of the organization, together with the

documents from Omar Garrison, do they contain materials

relating to the Hubbard Explorational Company?

A There may be a few in there.

Q Have you checked both places?

A I haven't checked specifically for those

documents. I have been through most of the materials.

Q Did you do a comparative analysis with inventories?

A No.

Q With regard to the horticultural experiments,

are those in the biographical archives in the possession of.

the church?

A I think they are, yes.

Q With regard to the St. Hill property in

England, are there are any documents relating to that issue,

the St. Hill property in the biographical archives in the

possession of the church or the materials returned from

Omar Garrison?

A I think there may be.

Q With regard to the letters to Richard Nixon,

are they in the biographical archives in the possession

of the church or the materials returned from Omar Garrison?

A I haven't seen those.

Q Did you check?

A Not specifically for those documents, no.

Q Did you do a comparative analysis inventory

to inventory?

628

A No.

Q And same question with regard to letters to

Kennedy?

A Same answer.

Q And letters to other people?

A Same thing.

Q And the file that says "Cit-Wash"?

A I don't recall seeing that.

Q You don't recall seeing it where?

A In the biographical archives or the Garrison

archives.

Q Now is that presently under seal?

A I don't recall seeing it down there either.

Q And the FDA files, have you seen files relating

to the FDA lawsuit in the biographical archives in the

possession of the organization or in the materials returned

from Omar Garrison?

A I have seen some documents relating to it in

the sealed documents. I don't know that they were the exact

file.

If I recall, there were two or three files

that were taken from the trunks originally. I have seen at

least one or two documents, individual documents, and then

sealed documents downstairs.

Q Now do you know whether those one or two

documents are in the biographical archives or the materials

returned from Omar Garrison?

A I don't recall seeing them in those archives,

629

no.

Q Did you do a comparative analysis?

A No I didn't.

Q When you gave the materials to Mr. Armstrong,

was it your understanding that the materials belonged to

Ron and Mary Sue Hubbard?

A Well I understood they were under Mary Sue's

control, and in that respect they were her documents to do

with what she wanted to do.

Q So it was your understanding at that time

that they did not belong to the church?

A Right.

Q Were you involved in any consultations, just

yes or no, with any attorneys for the church at the outset

of this lawsuit, beginning of the lawsuit in August 1982?

A I became in communication with some attorneys.

I am not sure of the exact date that you are referring to.

Q Now, are there any materials presently under

seal that you have an understanding of as belonging to the

church?

THE COURT: Well I think you have got an ambiguous

word. You have used it several times. It is the word

"belonging."

A person might have ownership. He might have

a right of possession. I don't know what you really mean

when you say "belonging."

MR. FLYNN: The problem I have got, Your Honor, is

they are using ownership and belonging in their affidavits

630

to get legal relief, which they did, and the witness is now

coming in and saying that he doesn't know what the legal

connotations of these words are, so I am kind of in a never,

never land with regard to trying to prove who owned or had

possession.

THE COURT: Well they are going to have to prove

either possession or some right to relief here, and this

other business, of course, goes to, I suppose, credibility.

But we all know that when affidavits are drafted, they are

using lawyer's language. I think now that we are in trial

and we are being more specific, you ought to try to be more

specific. When you use the word "belong" if you use that

word, you can ask him what he meant.

MR. LITT: This affidavit was before Mr. Armstrong,

who is the only one who knows the documents, testified and

the situation was somewhat confused, and Mr. Armstrong has

testified they are the Hubbards' documents. There has been

no contrary testimony.

I don't understand what this has to do with

any of the issues that have been presented in our case.

THE COURT: Well, you don't need to get involved in

rhetorical excesses at this point. The witness is

on the stand. He signed a declaration.

MR. LITT: He didn't sign this declaration.

MR. HARRIS: That is what I wanted to clear up in

the record. He pointed to the declaration of Andrew M. Lenarcic.

THE COURT: I thought we had exhibit C which is this

witness' declaration.

631

MR.FLYNN: We do, Your Honor.

Mr. Litt has interjected something foreign

to what we were discussing.

THE COURT: Didn't you sign this declaration, exhibit C?

THE WITNESS: Yes, sir.

THE COURT: Well I assume that is what we are talking

about, Counsel.

MR. LITT: That is my misstatement.

THE COURT: He is entitled to cross-examine as to

what he meant or what his words were and so forth, but I

think using the word "belonging" in this context -- in that

part of a question is a little ambiguous.

MR. FLYNN: I will narrow it, Your Honor.

Q You stated in your declaration, Mr. Vorm,

"I was aware at all times that these trunks were considered

to be personal property of Mr. and Mrs. Hubbard."

Is that correct?

A That is true.

Q Where did you get that awareness from?

A By the fact that these were Mary Sue's trunks

and that she had given me instructions on how to handle

them and she was the authority as far as where the material --

where they could go or if they could go anywhere.

632

Q Now, that was your awareness with regard to the

first trunk or first group of materials you gave to

Mr. Armstrong?

A That is true.

Q With regard to the second group of materials you

gave to Mr. Armstrong, what was your awareness with regard

to that group as to whether they were the personal property

of Mr. and Mrs. Hubbard?

A It would be the same

Q And where did you give the authority to give

those documents to Mr. Armstrong?

A From the new controller Gordon Cook.

Q During the period of -- between 1979 and 1981 do

you know what the line of authority was in the church

hierarchy from L. Ron Hubbard down?

A No.

Q If L. Ron Hubbard authorized Gerald Armstrong to

have the documents that you gave per Mr. Cook's order to

Omar Garrison, would that be authority in your awareness

superior to any other authority within the organization?

MR. HARRIS: I'll object to that, Your Honor. It is

compound; it also calls for speculation and is hypothetical

in form.

THE COURT: Well, it was hypothetical, certainly.

People can ask questions that are hypothetical.

I think it is somewhat ambiguous. And I think

you can reframe it and make it less compound.

Q BY MR. FLYNN: Was Mr. Hubbard the supreme

633

authority within the Church of Scientology between 1979 and

1981?

MR. HARRIS: To this witness' personal knowledge, or

is he asking him as an expert?

THE COURT: I think the question now becomes ambiguous

because we have had testimony that about his writings and

how he might be the philosophical underpinning or the

theological underpinning of the church.

I think you ought to -- as to what matters? Are

we talking about control of these documents, or as to other

matters, spiritual matters, or what?

Q BY MR. FLYNN: With regard to your disposition

of materials from the controller archives you testified you

received one order from L. Ron Hubbard; is that correct?

A I assumed it to be from L. Ron Hubbard, yes.

Q Did you receive any other orders other than the

one that you recall from L. Ron Hubbard?

A They weren't really orders.

Q What were they?

A They were dispatches concerning the tape project

that was going on; various thoughts that he had about it and

how it was going, that type of thing.

Q Did he give you any instructions?

A Well, he said -- I believe he said I would

suggest something or another, that you do this, that type of

thing.

Q Did you consider that to be -- did you consider

L. Ron Hubbard, when you received that order, to be the

634

highest authority within the organization?

MR. HARRIS: That mischaracterizes --

THE COURT: I'll sustain the objection. It hasn't

been established that he treated that as an order.

Q BY MR. FLYNN: Is it your testimony, Mr. Vorm,

that you never received any other orders from L. Ron

Hubbard?

MR. HARRIS: Asked and answered, Your Honor.

THE COURT: It also characterizes what has not been

established yet.

I'll sustain the objection.

Q BY MR. FLYNN: Is there any document presently

under seal that in your awareness is the property of the

Church of Scientology?

A I think there is a corporate resolution or a

corporate establishment original down there. I am not sure

what corporation it is from. If I recall, it was CSC. But

I'm not positive about that.

Q Can you give me the date?

A No, I can't.

Q Can you give me any other information so we can

find it among the sealed documents?

A Well, it seemed -- if I recall it seemed to be

on legal-type paper, like it had the numbers down the side

type thing.

Q Do you know what it related to?

A I don't recall. It was like a corporate --

original corporate document.

635

Q And in your understanding or awareness that

belongs to the Church of Scientology; is that correct?

MR. HARRIS: He is using "belongs" again, Your Honor.

THE COURT: I'll sustain the objection.

Q BY MR. FLYNN: Is that the personal property of

the Church of Scientology?

MR. HARRIS: Corporate property of the Church of

Scientology or ecclesiastical property of the Church of

Scientology?

The problem is it is very ambiguous at this

point.

Q BY MR. FLYNN: Where did it come from, Mr. Vorm?

A I don't know, sir.

Q Did it come from controller archives?

A It could have.

Q Could it have come from Guardian Office

archives?

A No.

Q Could it have come from the biographical

archives?

A It could have.

Q Can you name one other document?

A Which --

Q That, according to your understanding, is the

personal property of the Church of Scientology.

MR. HARRIS: Are we talking about the Church of

Scientology of California, the plaintiff here?

THE COURT: I assume we are talking about the

636

plaintiff.

MR. HARRIS: Very well. So modified, then, I would

have no objection.

BY MR. FLYNN: Can you name one other document,

Mr. Vorm?

A Not offhand; just from recall.

Also, would have a question about the legality

of ownership. I am not sure who owned legally some of the

documents here.

Q BY MR. FLYNN: The controller archives, is it

your understanding that the church owns the controller

archives?

A No.

Q Who owns those?

A I am not really sure. I don't think it is the

church.

637

Q Is it Mary Sue Hubbard or L. Ron Hubbard?

A Could be.

Q Well, whose possession have they been in?

A They have been in my possession.

Q Who do you work for?

A I work for a corporation called CST.

Q CST?

A That is right.

Q What corporation is that?

A Church of Spiritual Technology.

Q. Who gave the Church of Spiritual Technology

authorization for you to hold these documents?

A I don't know.

MR. HARRIS: If --

THE COURT: Are we talking about now or talking about

'77 to '81?

Were you working for CST at that time, too?

THE WITNESS: No, I wasn't.

THE COURT: Who were you working for at that time?

THE WITNESS: I believe it was Church of Scientology

of California.

THE COURT: When did you leave Church of Scientology

of California and become an employee of CST, if you did?

THE COURT: Approximately November '83.

THE COURT: You may continue, Counsel.

BY MR. FLYNN: So, is it your testimony that

in November 1983 CST was the possessor of the controller

archives?

638

A Well, I am not sure of the legal things on

it. All I know was I started getting paid another corporation

Q When you say you started getting paid, did you

get a disbursement voucher?

A Yes.

Q What did it say on it?

A Didn't say anything an it.

Q It was blank?

A Yes.

Q How do you know you started getting paid by

another corporation?

A that is what I was told, and also the checks

that -- our weekly checks that came in had CST written on

it.

Q You received checks?

A Yes.

Q Do you know whether Mr. Armstrong throughout

the period he was involved in the organization received cash?

A Well, I happen to handle finances for the

archives, so, therefore, I received one check in which I

disbursed to the staff. That is how I saw the check.

Q How long have you been involved with the

Church of Scientology.

A About eight years or so.

Q When did you first start receiving checks as

opposed to cash?

A For what?

Q For your pay.

639

A For my individual pay?

Q Correct.

A I never received checks for my individual

pay.

Q Well, you are now getting checks from CST?

A At the treasury terminal or person for the

area I work in.

Q Is that your pay?

A It is a combined pay of all the staff which I

then disburse to the staff.

THE COURT: Including yourself; is that what you are

saying?

THE WITNESS: Yes.

Q BY MR. FLYNN: And when you pay yourself,

do you pay yourself by check or cash?

A Cash.

Q Where do those funds come from?

THE COURT: If you know.

MR. HARRIS: I will stipulate they come from a bank

account, Your Honor.

THE COURT: Well --

MR. FLYNN: I will withdraw it, Your Honor.

Q Is it your testimony that the controller

archives are now in the possession of a corporation called

CST?

A I believe so. I don't have personal knowledge

of the agreement and that type of thing.

Q And is it your awareness that these documents

640

do not belong to CST?

MR. HARRIS: "Belong"; Your Honor?

THE COURT: Well, which documents.

Q BY MR. FLYNN: The controller archives that are

currently in the possession of the CST who, according to your

understanding, owns these documents?

A I don't know what to say to that. They are

still in my possession. As far as who owns them, it could

be Mr. Hubbard. I don't know for sure.

Q Who gives you orders with respect to the

documents, if anybody?

A What kind of orders? Like day-to-day orders

type things?

Q First, day-to-day orders.

A My immediate senior.

Q Who does he work for?

A I am not sure of his exact command lines. I

think it might be Mr. Spurlock.

Q Well does he work for Author Services Incorporated?

A Who?

Q Mr. Spurlock?

A Yes.

Q Is Author Services Incorporated a for profit

corporation?

A I don't know.

Q Does it handle all the business affairs of

L. Ron Hubbard?

A I don't have any personal knowledge about that.

641

Q But you do get day-to-day orders from

Lyman Spurlock; is that correct?

A No.

Q You got routine orders from Lyman Spurlock?

A No, I get no orders from Lyman Spurlock except

maybe very, very occasionally suggestions or something.

Q Did you just testify a few moments ago that

you get regular orders from Lyman Spurlock?

A No.

Q Do you know anything about Author Services Inc.?

MR. HARRIS: Know by personal knowledqe, Your Honor,

or hearsay?

MR. FLYNN: I will withdraw it, Your Honor.

THE COURT: Okay.

Q BY MR. FLYNN: Have you done any work for

Author Services Inc.?

THE COURT: If you know.

THE WITNESS: That I was paid for?

Q BY MR. FLYNN: With or without pay.

A I have gotten phone calls now and then from

them if I had certain things in the archives, which I would

go cheek and let them know.

Q Is there anyone between the command lines between

you and Lyman Spurlock?

A Yes.

Q Who?

A A person named Dan Pryzbilski.

Q How do you spell that?

642

A I am not sure. It is P-r-y-z-b-i-l-s-k-i,

something like that.

643

Q What is his position?

A He is the CO, LRH archives.

Q What does "CO" stand for?

A Stands for "commanding officer," the same as

executive director.

Q "LRH" stands for L. Ron Hubbard?

A That's right.

Q Where are those archives?

A They are with me.

Q Approximately how many pages of materials are in

those archives? A It is the same archives.

Q The same as the archives that Mr. Armstrong had?

A It is the same everything we are talking about.

The archives Mr. Armstrong had came into my

possession.

The controller archives are still in my

possession and the whole thing is called the LRH archives

now.

Q Meaning that they belong to L. Ron Hubbard?

MR. HARRIS: Your Honor, I'll object to the form of

the question.

THE COURT: Well --

MR. HARRIS: That is the title.

THE COURT: I suppose if that is a question, you can

answer that if that is what it means.

THE WITNESS: My understanding is that it means that

it contains materials pertaining to LRH, primarily his

644

writings and his published works.

Q BY MR. FLYNN: Does it have his personal

materials also?

MR. HARRIS: The writings and published works may be

personal materials, Your Honor.

I object to the form of the question.

Q BY MR. FLYNN: Describe, if you can, Mr. Vorm,

what is in LRH archives by categories.

A There is the original Dianetics Scientology

lectures; the written published materials, what you would

call the technical materials; what was described earlier in

the controller archives.

There is the Mary Sue trunks; there are the

materials that used to be in Mr. Armstrong's possession.

Q If I can stop you right there, that if the four

filing cabinets, you say?

A Well, I am a little bit confused on the four

filing cabinets. I am not sure if my answer yesterday --

what I was answering exactly on, on the four filing

cabinets. That is what I meant to be original materials.

As far as the other materials in there, I am not

sure whether they were copies or exactly what they were.

Q There were more than four filing cabinets that

came from Mr. Armstrong?

A Yes, there were.

Q Approximately how much more?

A Maybe three, four, five more filing cabinets and

some boxes, that type of thing.

645

Q How many boxes?

A Eight, ten, maybe more.

Q So in addition to the four filing cabinets you

testified about yesterday, there are now three to five more

filing cabinets and eight to ten, maybe, more boxes from

Mr. Armstrong's materials?

A Of things from there, yes.

Q Have those been inventoried?

A Not that I know of.

Q To your knowledge no person has inventoried

those materials?

A It is possible they have been. I am not sure.

It could have been done right at the start of this whole

thing.

Q Do you know of anyone who would have done it?

A Possibly Ken Long.

THE COURT: Can you say of your own personal knowledge

that of those two to three thousand pages that you described

of original materials under seal that there are no copies of

these within these other four to five filing cabinets and

eight to ten other bones?

THE WITNESS: I would be fairly certain of it. I have

been through it myself.

Q BY MR. FLYNN: You have been through it?

A Yes.

Q But you didn't inventory it?

A No.

Q Can you name one document in the two to three

646

thousand that may not be in those materials you just

described?

A Not without looking at the documents.

Q Was there any other materials that are now in

LRH archives other than what you have already described?

A I think that pretty well covers it.

Q Did the Omar Garrison documents go in there?

A Yes.

Q Now, approximately how many pages of material

you estimate are now in LRH archives?

A I have trouble estimating on the pages, exact

number of pages. I mean there are 15, 20 file cabinets,

30 -- maybe 50 file cabinets worth of materials plus 5,000

tape lectures.

Q How many boxes?

A Oh, boy. Probably 20, 30, something like that.

Q How big are the boxes?

A Standard, maybe banker's box-type.

Q A foot-and-a-half by two feet?

A Yes, something like that.

Q Have all of those materials been inventoried?

A No.

Q Would you estimate that the number of pages of

materials is in excess of 500,000?

A That might be a good figure.

Q Have you ever seen, in connection with your

duties, any orders stating who those materials belong

to, who owns them?

647

A Well --

MR. HARRIS: "Orders," Your Honor? I have an

objection to that characterization.

How about "communications"?

MR. FLYNN: I'll accept that.

Q Have you ever seen any communications from

anyone as to who owns those materials?

A Yes, I have.

Q What have you seen?

A I saw a paragraph that evidently came from a

dispatch that I was told was by Mr. Hubbard, saying that he

owned the materials, the technical materials.

Q What about the other materials?

A I haven't seen anything on that.

Q When did the dispatch come from Hubbard?

A I don't know.

Q Within the last year?

A No.

Q Two years?

A It would have to have been before 1980.

Q Before 1980?

A June 1980, yes.

Q Were these materials all collected in that

location in June 1980?

648

MR. HARRIS: "These materials"; ambiguous.

THE COURT: I will sustain it.

Q BY MR. FLYNN: What was your position in June

1980?

A Controller archives, IC.

Q So, the dispatch you say you saw in June 1980--

THE COURT: I think he said before, some time before

June 1980.

THE WITNESS: Right.

THE COURT: It had to be some time before June of

1980.

Q BY MR. FLYNN: Your best memory was that it

was some time before June of 1980?

A Yes, that's correct.

Q Was it signed?

A No.

Q Was it in typewritten form?

A Yes.

Q What was on it?

A What was on --

Q Was there as R on it?

A No.

Q Were there any initials on it or was

L. Ron Hubbard's name on it?

A No.

Q It was just a typewritten form?

A Right.

Q And it was your understanding it came from

649

Hubbard?

A Yes, it was dated when I saw it that it came

from Mr. Hubbard,

Q And you accepted it as such as coming from him?

A I had no reason to question it.

Q Well, that was the routine, the command line;

is that correct?

MR. HARRIS: Well, what was -- "that" --

THE COURT: Sustained.

Q BY MR. FLYNN: When you received communications

of that nature where there was no signature or initials on

it and you were told that it came from Hubbard, you accepted

it as such; is that correct?

A No, I wouldn't say that is correct.

Q You didn't accept it?

A Well I never received any communications

from Mr. Hubbard that were in the way you just described.

Q Well this communication you just testified

about was in addition to the other communication you received

in connection with the tapes?

A No.

Q The same communication?

A Well it wasn't a communication that I received.

Q Did you testify about a communication you

received where the letter R was on it?

A Yes.

Q This communication you just testified about

a moment ago where the communication said that these materials

650

belonged to L. Ron Hubbard, you testified, I believe, that

that did not have an R on it; is that correct?

A That is right.

Q So now there are communications which in

your understanding came from L. Ron Hubbard?

A That is right.

Q Did you testify earlier that there was only

that you have received from L. Ron Hubbard?

A Yes.

Q All right. Are there any additional ones that

you haven't told us about yet?

A No.

Q Who showed you that communication, the one that

came some time prior to June 1980?

A It was written in on the top of the program that

I received a copy of.

Q What was the program?

A I think it was a program to inventory the

materials in the archives or something like that.

Q In controller archives or all the archives?

A I think it was all the archives.

Q And do you know whether it went to someone else

besides you?

A The program or --

MR. HARRIS: Well that assumes facts not in evidence.

The witness has stated about three times, Your Honor, he only

received one that went to him. He saw this --

MR. FLYNN: I will withdraw it, Your Honor.

651

THE COURT: All right.

Q BY MR. FLYNN: This communication, did it have

a routing form up in the upper left-hand corner?

A Of the program?

Q Right.

A Yes, it did.

Q Tell the court what a routing form is.

A Well at the top of a dispatch, it is like this,

where you want the dispatch to go so you just put the person's

post title and draw and arrow to it or something like that.

Q And do you recall what the routing was on that

program?

A I think it was to C from a post title entitled

R Account.

Q To the controller from R Account?

A Yes.

Q R meaning L. Ron Hubbard?

A I believe so, yes.

Q Do you know what that office was, R Account?

A No, I don't.

Q Do you know where it existed within the

organization, physically?

MR. HARRIS: It assumes a fact not in evidence that

it was an office.

THE COURT: Well I believe he said it was an office.

MR. HARRIS: He said it was a post.

THE WITNESS: It was a post.

THE COURT: Not a post office?

652

THE WITNESS: No.

Q BY MR. FLYNN: You know that it was a post?

A Yes.

Q And do you know how many people worked on the

duties related to this post?

A Not exactly, no.

Q Do you know where the post was located?

A No.

Q At that time did you do an inventory?

A Not at that time, no.

Q When did you do one?

A A little bit later.

Q Approximately how long after that?

A Year and a half, maybe something like that.

Q Now when you did that inventory, did you do

it in connection with any lawyers?

A No.

Q Where is that inventory?

A It should be in my files, my post files.

MR. FLYNN: Your Honor, may that be produced?

THE COURT: Well, let's see. Is this of materials

that were in existence before the materials that you gave to

Mr. Armstrong or was this something that was done after

the materials -- when in point of time to the event we are

talking about here did this inventory occur?

THE WITNESS: I think it was done after.

653

THE COURT: Was that after -- before the materials

came back from Garrison?

THE WITNESS: Yes.

THE COURT: Was it before Mr. Armstrong left the

church, or after?

THE WITNESS: I think it was after.

THE COURT: And did this incorporate all the materials

that you had under your control in your job there at that

time?

THE WITNESS: Yes. But it was very general. It was

like -- almost like a number of pages, number of files for

the type of inventory as opposed to a specific item-by-item

inventory.

THE COURT: What would be the relevance of this? I am

having a little trouble putting it into perspective.

Q BY MR. FLYNN: Was this inventory designed to

inventory all the materials that Gerald Armstrong left in

the biographical archives?

A No.

Q What was it designed to inventory?

THE COURT: If you know.

THE WITNESS: It was basically an inventory of

controller materials primarily.

Q BY MR. FLYNN: What color paper was it on?

A White.

Q Was it a Guardian Office program?

A No, it wasn't.

Q Do you know whether LRH accounts was a Church of

654

Scientology post?

A No, I don't.

Q You don't know?

A I don't know.

Q Your recollection is that the program was to