1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

FOR THE COUNTY OF LOS ANGELES

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

  (See Appearances page.)

VOLUME 6

Pages 813 - 995

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

APPEARANCES:

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

I N D E X

W I T N E S S E S

E X H I B I T S

[Missing Pages 813 - 844]

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

BY MR. FLYNN:

Q Mrs. Hubbard, did you understand that Omar

Garrison was going to write a biography about your husband?

A I did.

Q When did you first learn that such a biography

was going to be written?

A You'll have to clarify your question because

there were different times that there were biographies going

to be done.

Q When did you first learn that a biography was

going to be written by Omar Garrison?

A It was proposed some time in the late '70's,

that we would -- in the Guardian's office that we would have

him write a biography at some point, yes.

Q Could you be more specific with regard to a

particular year?

A No, I can't. Late '70's.

Q Is there any particular date that you have in

mind when you feel that Omar Garrison was the one that

was chosen to do the biography?

A Well, I think as far as like a date in -- when

he was chosen, I am not exactly certain. But I feel it was

resolved when he did sign the contract that he would write

the book.

Q Your memory is that the contract was October,

1980, some time about there?

A Yes.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q Was it your understanding that it was going to

be a truthful biography?

A Yes.

Q And that the facts about your husband's life

recited in the biography would be accurate; was that your

understanding?

A Yes, without any invasion of privacy or that

sort of thing, yes.

Q What do you consider to be an invasion of

privacy?

A Personal matters that -- when people are

currently living that one doesn't go into, doesn't invade

their privacy.

Q What do you consider to be personal matters?

A I would consider the death of my son and the

autopsy report and the private detective investigation of

that to be a personal matter.

Q And in your view that would not be the proper

subject of biographical interest by Mr. Garrison; is that

correct?

A That is correct.

Q Did you tell Mr. Garrison that?

A I never had a communication. He never asked

me anything. I never had any communications except one

letter from him saying he would like to interview me.

I told him I am sorry, but I am busy. But

put any questions on tape and I would be glad to hear from

him. But I never heard from him.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q So you never placed any restriction on

Omar Garrison about putting materials in the biography

relating to the death of your son Quentin; is that correct?

A I didn't know he had the materials about the

death of my son Quentin. I didn't know anybody had gone

into storage and given these things out.

Q Do you know approximately how many pages of

material Omar Garrison had to write the biography of your

husband?

A I don't know, but there are thousands and

thousands of pages in these boxes that are over there.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q You have looked through those boxes?

A I have.

Q Did you ever obtain any understanding as to how

many pages of material Mr. Garrison had in addition to

what is in the boxes under seal?

A No.

Q If I suggest to you that the boxes under seal

represent less than two percent of the materials in the

possession of Omar Garrison about your husband, do you have

any knowledge of that type of percentage?

MR. LITT: Objection; calls for speculation. There

is no foundation. The witness said she doesn't know how

much.

THE COURT: Well, as phrased, it assumes facts not

in evidence. You can pose it as a hypothetical and it is

a proper question.

Q BY MR. FLYNN: Let me ask you this, Mrs. Hubbard:

You knew that Gerald Armstrong was collecting materials,

did you not, to write the biography?

A Yes.

Q And you knew that Omar Garrison was using

the materials to write the biography; is that correct?

A I presume so, yes.

Q Did you ever communicate to Gerald Armstrong

any restrictions with regard to the collection of the

materials to write the biography?

A Yes.

Q When?

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

A In a letter. I forget exactly when it was.

I asked him to ask me for any materials that he wished or

wanted to know about and then I would have to authorize them

to send them to him.

Q Do you recall the date of that letter?

A That was some time in February 1980.

Q And do you recall what restrictions you put on

Mr. Armstrong?

A Well he would have to request -- anyone wanting

to go into my personal storage would have to request me for

materials or anyone wanting materials from me would have to

request me first.

Q If I suggest to you that that letter was

dated February 11, 1980, does that refresh your memory at

all?

MR. LITT: Why can't the letter be shown to Mrs. Hubbard

and then we will not have to suggest.

Are you marking that, Mr. Flynn, or are you

just showing it to her?

MR. FLYNN: I am going to offer it.

MR. LITT: Perhaps it should be marked as an exhibit,

Your Honor.

THE COURT: What are we up to?

THE CLERK: D as in David.

THE COURT: All right, mark it as D for identification.

THE WITNESS: Yes.

MR. FLYNN: My understanding that has been marked in

evidence?

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

THE COURT: Marked for identification.

Are you offering it in evidence?

MR. FLYNN: I am, Your Honor.

THE COURT: Any objection?

MR. LITT: Let me just take another look at it, Your

Honor. I don't think so.

No objection, Your Honor.

THE COURT: All right, be received.

Q BY MR. FLYNN: And that letter was in response

to a letter dated 5 February, 1980; is that correct,

Mrs. Hubbard?

A Yes, that is correct.

Q And you received that, did you not, at

some point prior to February 11, 1980?

A Yes, I did.

MR. HARRIS: Just so we can keep the record straight,

Your Honor, do you intend to mark the exhibit that she is

referring to as a piece of evidence, Mr. Flynn?

MR. FLYNN: I do, Mr. Harris.

MR. HARRIS: May it be marked defendant's next in

order?

THE COURT: Are you talking about this two-page

letter of February 5?

MR. FLYNN: May that be marked as defendant's D.

THE CLERK: Is that a different one?

THE COURT: It is a different -- E as in easy.

MR. FLYNN: It is now my understanding they are both

marked, the 5th February --

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

THE WITNESS: This one is marked D.

THE COURT: It is marked for identification. I

haven't received it in evidence.

MR. FLYNN: I am offering that, also.

THE COURT: Any objection?

MR. LITT: No objection.

THE COURT: All right then they are both received in

evidence.

Q BY MR. FLYNN: Now, do you have any understanding

as to whether your husband authorized Mr. Armstrong to

collect materials?

A I don't believe my husband did.

Let me say I don't believe my husband authorized

Gerry Armstrong to go into our personal information storage

to collect materials or the Guardian Archives trunks, no.

Q Now the Guardian Archives trunks were located

at Gilman Hot Springs; is that correct?

A No.

Q Where were they located?

A They were located at the church facilities in

Los Angeles known as the Cedars Complex.

THE COURT: Let me just so we don't get confused

here, the Guardian Archive trunks and the Controller Archive

trunks are the same trunks.

Otherwise, we are going to start using

different terms and everybody is going to be asking questions

at cross purposes.

MR. FLYNN: Thank you, Mr. Litt.

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q Now, R Storage is located where, Mrs. Hubbard?

A In Gilman Hot Springs.

Q And is it your contention that your personal

materials were located there?

A Yes, some of them, a great deal of them.

Q Do you have any understanding as to whether

Mr. Armstrong petitioned your husband to use materials

collected from Gilman Hot Springs to assist in the biography

project?

A No, I do not.

Q Do you know whether such a petition was sent

to your husband?

A I know that a petition was sent to my husband

in relationship to being appointed to the post.

Q When did you learn that?

A I learned that in the -- in my deposition in

this case.

Q So you learned that after the date of

5 February, 1980 is that correct?

A Yes.

Q And the date of 5 February, 1980 is the date

of Mr. Armstrong's petition which has been marked as

exhibit E; is that correct?

A Yes.

Q And your testimony today is you first learned

that he had petitioned your husband when your deposition

was taken?

A No, no. I first saw the petition, the actual

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

was sent to me, the original petition that he had done to my

husband was not attached to what I received.

MR. HARRIS: "This" for the record, Mrs. Hubbard, is

what exhibit?

THE WITNESS: This is E.

Q BY MR. FLYNN: Your deposition was taken on

January 11, 1983; is that correct?

A It was taken in January '83, yes.

Q Now the question is when did you first learn

that Mr. Armstrong petitioned your husband to collect

materials for the biography?

A I learned that my -- that he was appointed to

the post in this petition and that he was intending to

collect materials for the biography.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q All right. So you knew --

MR. LITT: That this, again, refers to exhibit E.

Q BY MR. FLYNN: Do you have any memory as to when

you received exhibit E?

A Well, I usually answered something

when I actually saw it which would be like my answer

which is exhibit D which is February 11th.

Q So your memory is that you received exhibit E

on February 11th and responded that day; is that correct?

A Yes, that is correct.

Q And your testimony now is that you knew as of

February 11 that Mr. Armstrong was commissioned to write --

to collect materials for the biography; is that correct?

A That is correct.

Q And you knew on that date that -- quoting from

exhibit E, " ... petitioned R --

" R is your husband?

A That is correct.

Q -- "to do this post"; is that correct?

A Right.

Q And the paragraph before that --

MR. LITT: Just to clarify, based on that question,

she knew that that is what Mr. Armstrong said?

THE COURT: Let's let the witness answer the question.

If you have an objection, object.

We'll take a 15-minute recess.

(Recess.)

THE COURT: In the case on trial, let the record reflect

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

You may retake the stand. State your name

again for the record.

You are still under oath.

THE WITNESS: Mary Sue Hubbard.

THE COURT: Have a seat.

You may continue with your cross-examination.

Q BY MR. FLYNN: Mrs. Hubbard, I believe you

testified on direct examination that Mr. Armstrong stole

materials relating to the death of your son Quentin; is that

correct?

A I don't know if I alleged specifically to those,

but I consider he did steal materials of mine.

Q Relating to Quentin?

A As -- I am not sure. I think he got those from

the GO. And they were not supposed to give the materials

to him without my permission.

Q When do you -- the GO is the Guardian's Office?

A Yes, that's right.

Q When do you think he got those from the

GO?

A I have no idea.

Q What made you think he got those from the GO?

A Because I know they have the records there.

And I also know that in our agreement with the police in

Las Vegas, that those documents were under seal there.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q That they were under seal in the records of

the GO?

A No, that they were under seal -- the original

documents of those are under seal in Las Vegas and that those

materials then could have only come from the GO files.

Q I believe you testified that what Mr. Armstrong

stole were reports of private investigators that the Guardian's

Office had hired?

A That is correct.

Q What makes you think he stole those?

A Well, why does he have them in his possession?

I mean, he is not working on any biography.

Q Do you consider those to be personal materials

that shouldn't have gone to Mr. Garrison?

A I do.

Q And so you don't know whether Mr. Armstrong

stole those and kept them on his own or whether he gave them

to Mr. Garrison?

A No, all I know is that they are right there

in the court records.

Q In fact, you don't even know who gave them to

Mr. Garrison; do you?

A No. I don't.

Q And who is Vaughn Young?

A He is an employee, I believe, of the church at

one time that I knew.

Q Do you know whether he is now?

A I don't know.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q Do you know whether he's been named as a

witness in your case?

A I didn't review the witness list, no.

Q Do you know whether he's been reviewing the

documents downstairs that are under seal?

A No, I was never there when he was doing any

reviewing of documents.

Q Did you ever give him permission to do that?

A No, I have never given him permission to do

that.

Q And you don't know whether he is currently

working for the church or for you?

MR. HARRIS: Asked and answered.

THE COURT: Sustained.

Q BY MR. FLYNN: Well, if I suggest to you,

Mrs. Hubbard, that it was Vaughn Young who gave the

materials relating to Quentin to Mr. Garrison and not

Gerald Armstrong, does that surprise you?

A I -- MR. HARRIS: Object to the form of the

question.

THE COURT: Sustained.

Q BY MR. FLYNN: Do you know whether Vaughn Young

gave the materials to Omar Garrison relating to Quentin?'

A I don't know.

Q And you don't know whether Vaughn Young has

been working in the employ of the church right up to the

present time?

MR. HARRIS: Asked and answered, Your Honor, three

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

THE COURT: I will sustain the objection.

Q BY MR. FLYNN: In any event, your testimony

is that those materials relating to Quentin are personal

and shouldn't have gone to Omar Garrison; is that correct?

A That is correct.

Q Do you know whether Mr. Young received permission

from anyone in the Guardian's Office to collect those

materials?

A Collect them for what purpose?

Q For the biography.

A No, I don't know that.

Q You were removed from your post as controller

at some point in tine?

A I resigned from my post at some point in

time.

Q When was that?

A That was in May 1981.

Q Did you resign because of your conviction of

a felony?

A Partially. That was part of the reason, yes.

Q And what felony were you convicted of,

Mrs. Hubbard?

A I was convicted of a violation of 18 USC 371.

Q What is that?

A Committing a conspiracy --

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

MR. LITT: Objection. Any further inquiry is improper.

THE COURT: It is permissible to bring out what the

common name of it is. The number is meaningless in

itself.

Q BY MR. FLYNN: Was it a conspiracy to obstruct

juctice?

A It was a conspiracy to commit an offense

against the United States Government.

Q Was it your understanding that you committed

a conspiracy to obstruct justice?

MR. HARRIS: Her understanding is irrelevant. She has

given the code section. This is clearly improper.

THE COURT: I'll sustain the objection. It is

argumentative.

Q BY MR. FLYNN: Mrs. Hubbard, when you were

controller did you impose tight security over Guardian Office

documents and materials?

A There was tight security on Guardian Office

documents and materials, yes.

Q Who had access to Guardian Office type materials

when you were controller?

A Only Guardian Office personnel were authorized.

Q If someone outside of the Guardian's Office --

strike that.

Anyone outside the Guardian's Office who

wanted to see the materials had to get permission; is that

correct?

A That was the way it was supposed to have been,

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

A Yes.

Q Was there any changes in that procedure?

A Not that I am aware of, no.

Q And was Mr. Armstrong, to your knowledge,

ever a member of the Guardian's Office?

A He attempted to be on many occasions, but he

never was permitted to be, no.

Q So the answer was he was not?

A That is correct.

Q So if he ever had to get Guardian Office

material, he would have to get permission; is that correct?

A Hypothetically, yes. He would have to.

Q Well, can you describe where the Guardian's

Office Archives were located in Los Angeles.

A I simply know they exist. I have never been

to the church facility there.

Q Did you testify on direct that you were

basically the head of the Guardian's Office?

A No.

Q Were you?

A No, I wasn't.

Q In your post as controller did you have overall

supervisory authority over the Guardian's Office?

A Yes, I did. The head of the Guardian's Office.

Q What was her name?

A Jane Kember.

Q You had authority over her?

A I had general supervision over her, yes.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q You can't tell us any of the security measures

that were in existence in Los Angeles with regard to

Guardian's Office Archives; is that your testimony?

A There were security arrangements that were

made in relationship to the Guardian files there.

Q Do you know what it is or was during 1980 and

1982?

A I know that only authorized people could go to

the Guardian's Office space. And I know that only certain

people were allowed into various files in the Guardian's

Office.

Q Okay. Are you familiar in general with

the files of the Guardian's Office?

A No.

Q Do you know whether any documents existed

in Guardian's Office files in 1980, 1981 that related to you

and your husband?

A Yes, by inference.

Q Were there any files that directly related to

you and your husband?

A Yes.

Q Were there any personal materials in the Guardian's

Office relating to you and your husband?

A Yes.

My son and what I have already testified, the

matter of Alexis.

Q So the Guardian Office had possession of

personal material relating to you and your husband; is that

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

A Certain materials. Yes.

Q You were removed from the post of controller

when?

MR. LITT: I object. The testimony was that she

resigned. It assumes facts not in evidence.

THE COURT: Reframe the question.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q BY MR. FLYNN: You resigned when, Mrs. Hubbard?

A In May 1981.

Q Thereafter did you have any authority or

access to Guardian's office files after your resignation?

A No, I did not.

Q So, whoever succeeded you, according to the

routine policy of the church in the position of controller,

could give permission to someone like Mr. Armstrong to obtain

access to those files; is that correct?

A They could, yes.

Q And what is the name of the individual who

succeeded you?

A I think his name was Gordon Cook.

Q Do you know whether Mr. Cook gave permission

to Mr. Armstrong to review Guardian's office files?

A No, I don't know.

Q And your testimony is that there were personal

materials in the Guardian's office files relating to you and

your husband; is that correct?

MR. LITT: Objection; asked and answered.

THE COURT: Sustained.

Q BY MR. FLYNN; Do you know what personal

materials exist in the Guardian office archives relating to

you and your husband?

A Are we talking about the controller's archives

now, the ones that were under my -- in the trunks?

Q Well, your attorney suggested there is no

difference between Guardian office archives and controller

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

A Yes.

Q Now, other than the contacts of the trunks

that you have testified about, can you tell me what personal

materials were in the possession of the Guardian office

archives relating to you and your husband?

THE COURT: At what point in time, counse1?

MR. FLYNN: In 1980-81.

MR. LITT: Your Honor, I think the question is

ambiguous.

Mrs. Hubbard has testified as to what the

personal materials were is the controller's archives. Then

Mr. Flynn said: Can you tell us what other materials were

in the controller's archives.

I don't understand the question. I don't see

how Mrs. Hubbard can understand the question.

THE COURT: Well, I am not really sure what you are

really after.

We have got some inventory. I don't think you

want to try to identify each and every item that was in any

particular --

MR. FLYNN: I will withdraw the question, Your Honor.

Q Mrs. Hubbard, you listed the materials in

direct examination that were in the trunks that were in

controller archives; is that correct?

A I did.

Q Now, other than those materials that you listed,

were there any other materials in controller or Guardian

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

to personal materials of you and your husband in 1980-1981?

A I don't understand what you are asking about.

You mean other than what I said?

Q Other than what you have testified.

A Oh, there were many other things. You just

named off a few of the things that were in the archive

trunks.

Q And there were many other things of a personal

nature; is that your testimony, in the Guardian office

archives?

A No.

MR. LITT: Your Honor, can we get some ground rules?

Can the phrase "controller's archives" be used

to refer to that?

THE COURT: Well, I don't know. It's been off and on.

MR. LITT: It has been used by Mrs. Hubbard, and

Mr. Flynn is starting to interchange.

THE COURT: I have been given here an inventory of

G.O. archives.

MR. LITT: But that is a different archive than

controller's archive.

THE COURT: Maybe we better find out. You said before

they were the same thing.

MR. LITT: Let's get it cleared up because I am

getting confused by Mr. Flynn's questions.

THE COURT: Okay.

BY MR. FLYNN: Mrs. Hubbard, is it your

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

archives are the same thing?

A Well, I can take that -- yes, we can consider

they are the same thing.

Q Okay. Do you know where the Guardian office

archives wore located in 1980-1981?

A Yes.

Q Where?

A At the Cedars Complex, the church facilities

there.

Q In addition to the materials in the trunk or

the trunks that you have testified about, can you give us

some estimate as to how big the Guardian office archives

were in 1980-1981?

A Well, when I am referring to the Guardian

archives, I am referring to those materials that are in those

trunks, and there isn't, to my knowledge, other than for like

tapes and so on, there isn't anything that I knew of that was

in the Guardian archives.

Q Where were the Quentin materials?

A The Quentin materials, I think, were taken

from the Guardian office, but the Guardian office is

separate, you see. There is a Guardian office, U S Guardian

Office, and then there is the controller's office, and the

U S Guardian Office, which was a local Guardian office

which also had facilities there at the complex. They had

their own files.

Q Were there any group or collection of documents

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

denominated Guardian office archives?

A Not to my knowledge. There were just the

tapes and the HCOB's and that sort of thing.

Q There was no such denomination Guardian

office archive; is that correct?

A No. There just was really the controller's

archives.

Q Now, other than the trunks in the controller's

archive, were there any other documents and materials?

MR. LITT: Objection.

THE WITNESS: I don't know what he is talking about.

MR. LITT: The question is ambiguous. Were there any

other materials where?

MR. FLYNN: In the controller's archives. That is

what I said, Mr. Litt.

Q Other than the trunks, were there any docu-

ments or materials in the controller's archives?

A Yes.

Q Can you give the Court an estimate of how big

they were?

A Well, most of them had come from the archive

trunks and they had been put into file cabinets by Tom Vorm

and they were also doing tape projects and they were taking

out all the tapes and were making master recordings of the

tapes, and they had taken out transcriptions of the tapes.

In other words, the tapes were being transcribed for use in

publishing books and so they were -- those materials were

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q Let's start here.

How many trunks were there in the controller

archives, if you remember?

A There were approximately 27 trunks.

Q And those were placed into filing cabinets?

A No. The trunks still remained there.

Materials were taken from those trunks and placed into

filing cabinets within the controller archives.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q Approximately how many filing cabinets in

1980-81 were there in the controller's archives, if you know?

A I don't know.

Q Now, what about the Guardian office archives

worldwide? Where were they located?

A Those were located at Saint Hill, Sussex.

Q Did they contain the same materials or copies

thereof of what was contained in the controller's archives

in the United States?

A What do you mean copies of?

Q Well, were these basically the same materials,

only one was originals and one was copies?

A I don't know what they had at Guardian archives

at Saint Hill.

Q Had you ever been there?

A No. I had never been there to see those after

they had been established.

Q Can you give the Court some estimate of how big

those archives were?

A No, I can't. I have never been there.

Q What about the B-1 archives? Have you ever

heard that term?

A No. I have never heard that one term.

Q Have you ever heard the term B-1 files"?

A I have heard of the Information Bureau files.

Q The Information Bureau was the bureau of the

Guardian's office that collected information?

A Yes, it was.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q And is that the bureau that collected

information on Quentin?

A Yes.

Q And were Quentin's files in the B-1 bureau

files?

A I can't testify directly to that. But I

presume they were.

Q They were?

A I presume so.

Q Now, was there different types of permission

procedures required to get into B-1 files as opposed to

getting into controller's archives?

A Yes.

Q What was the difference?

A In getting into Information Bureau files, they

would have to go through Guardian personnel to get authority.

And to get into the controller's archives, they had to go

through myself to get authority.

Q After you resigned, permission would reside in

the new controller; is that correct?

A Yes.

Q Now, when did you first know that Gerald

Armstrong had possession of documents and materials from

Gilman Hot Springs relating to you or your husband?

A I think that -- after I had consulted with my

attorney, I had received a registered letter from

Mr. Armstrong and a mailing service which I employed. And I

wondered what was Mr. Armstrong sending me a registered

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

I then contacted my attorney and asked him --

I knew that Mr. Armstrong had already been giving

depositions or affidavits or something in court cases, civil

cases, against the church.

So I undertook to ask my attorney about this

matter. And he was to make inquiries on my behalf to the

church.

Q So the first time you learned about the fact

that Mr. Armstrong had possession of personal materials

relating to you and your husband which you say he stole was

in the summer of 1982 shortly before the beginning of this

lawsuit in August of 1982; is that correct?

A Yes, other than the specific things that I

had already authorized which were those materials.

And then in one of his dispatches here he

mentions certain little things about -- like some -- a

diary about my husband's Orient trip, some poems, essays, a

few other things which I knew I had seen at our house at

Gilman Hot Springs. And I knew what those materials

involved.

Q Your testimony now is that you knew in

February of 1980 that he had access to some materials at

Gilman Hot Springs relating to you sad your husband; is

that correct?

A I am testifying that these things I knew about,

I authorized, and felt that they were all right for him to

have, yes.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

But I did not think that he had actually gone

into my storage at the time because these materials were not

stored in my storage there and materials that I authorized

from the Guardian -- controller's archives, I had actually

seen. They were boxes that had been sent over to me and I

had personally authorized them. And that is simply my testi-

mony.

Q What materials that are currently under seal

came from Gilman Hot Springs that you say you didn't know

about in February, 1980 that he had possession of?

A There are all the things that I have said, but

I'll repeat them again.

There were letters to and from my husband to

his mother; this was practically his whole lifetime of

letters, letters to and from my husband to his father which

were all of his collection of letters over his lifetime;

letters to and from my husband to and from his first wife

Polly which covered their entire marriage period.

There were letters to and from my husband to

his second wife Sarah that covered their entire marriage

period; letters to and from my husband in relationship to his

son.

There were certain manuscripts of my husband;

a book, called "Positive Mental Therapy."

There were numerous documentations of materials

from a Porto Rican minerals company; numerous documents from

something called Allied something or another which was a

company that he had.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

There were materials in relationship to my

husband's Dianetics Research Foundation; legal memos from

Mr. Weiskirk; legal memos from my husband to Mr. Struckmeyer;

materials about my husband's Alaskan expedition and the

volumes of books that he had done of "The Magician," the

ship that he had gone on; just all sorts of things.

Q Now, those materials, you didn't know that he

had?

A No. I never knew he had those.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q Did you know that he had any personal letters?

A There were a few things that I had seen at the

house, that were letters that were mentioned there that I had

seen in the house at Gilman Hot Springs.

Q If you will look at the fifth paragraph of

Exhibit E.

A Yes.

Q Incidentally, where were you living in February

1980?

A I was living in Los Angeles.

Q So you received this in Los Angeles?

A I did.

Q And did you go out to Gilman Hot Springs to see

what Mr. Armstrong had possession of?

A No, I did not. I also know that Mr. Armstrong

never wrote me and said, "Hey, Mary Sue, I am going into

your storage and I am taking things out of your storage,

and you don't know anything about it. And I am taking 25 or

30 or 40 boxes of your things."

And, I mean, he could have asked, you know.

Q You never knew about that?

A I never knew about that. He never asked me in

any letter.

I asked him, "Please ask me what you want for

this biography."

He never wrote me a letter asking me for any-

thing.

Q Mrs. Hubbard, would you look at the fifth

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

A Yes, I will.

Q Do you see the phrase, "Right now I am

assembling whatever data, docs, et cetera, we already have

at SU"?

A Right.

Q What is "SU"?

A SU is the summer headquarters out at Gilman

Hot Springs.

Q Was it called the special unit?

A It might have been.

Q So he is telling you in the first sentence he

is assembling whatever data, docs we already have at Gilman

Hot Springs; is that correct?

A Right.

Q (Reading:)

"In so doing I have made a

number of finds, one of which is an

uninventoried, beat-up box containing R's

diary from his orient trip."

You see that?

A Yes, I see that.

Q So you knew that in 1980?

A I did.

Q Poems?

A Yes.

Q Essays?

A Yes.

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q (Reading:)

"And several personal letters

and other things"?

A Yes.

Q Do you see that?

A Yes, I do.

Q Now, would you agree this was right at the

beginning of Mr. Armstrong's beginning this project?

A Yes.

Q So right at the very outset he told you that he

had personal letters; is that correct?

A That is correct. I knew because I had seen

these boxed materials out there, so I knew what he had.

Q When did you see those?

A I saw them on a visit when I was there to

Gilman Hot Springs.

Q When was that?

A That was late 1979.

Q And you had gone through all these materials?

A No, there were some of them out there. My

husband had them, and they were on the -- like diary of the

Orient trip. That was on the coffee table.

Q You have a specific memory of that being on the

coffee table and not in some boxes?

A Yes, they were on the coffee table and not in

some box. I presume somebody else later put than in a box.

Q Did you go through any box when you were out

there in late 1979?

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

A No, I did not.

Q You didn't know what was in the boxes?

A What box? There was only one box referred to.

Q Were there any other boxes?

A No, there were just these materials which I

recognized as having seen from the Gilman Hot Springs

house.

Q So you don't know what materials he was

collecting out there; is that your testimony?

A Yes. I didn't know what other materials.

Q You didn't know?

A I didn't know. I assumed that he would ask me

if he wanted to go through my personal storage, he would ask.

But there were other materials out there. People had been

living at Gilman Hot Springs and my husband since 1976, so I

assumed he was collecting some materials there.

Q Well, these several personal letters that are

referred to, were those in your personal storage?

A At that particular time, no.

Q Where were they located?

A They were located at that time, as I say, in

the house at Gilman Hot Springs.

Q They weren't located in the beat-up box?

A No.

Q Well, does the letter say that they were

located in the beat-up box?

A (Reading:)

"In doing so, I have made a

number of finds, one of which is an

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

uninventoried, beat-up box containing

Ron's diary from his Orient trips, poems,

essays, et cetera from his youth and

several personal letters and other things."

And I assume from reading that, that means

they were in the beat-up box.

Q So they weren't on the coffee table?

A No, not at that time.

Q Now, how many boxes of personal letters were

out at Gilman Hot Springs, if you recall?

A I don't recall.

Q And that storage out there is called R

storage?

A Yes.

Q Did you ever go through that storage?

A I packed up that storage and I saw the storage

in this innumerable number of boxes when I was at La Quinta.

Q When it was at Gilman Hot Springs, did you ever

go through that storage?

A No.

Q Now, in 1979, early 1980, were you at Gilman

Hot Springs when shredding was occurring, shredding of

documents?

A No, I was not there at that time.

Q Do you know anything about the shredding of

documents during that period of time?

A No, I don't.

Q Would a shredding operation have come under the

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

MR. LITT: Objection; calls for speculation.

THE COURT: Well, if you know, you could state. If

you don't, you can so state.

THE WITNESS: No, I don't know.

Q BY MR. FLYNN: It wouldn't have?

MR. LITT: The witness just answered the question and

said she didn't know.

THE COURT: I will sustain the objection. She said

she didn't know.

Q BY MR. FLYNN: Your testimony is you don't

know whether a shredding operation in 1979, early 1980,

would have come under the domain of the Guardian's office?

MR. LITT: Objection; asked and answered.

THE COURT: Well, it is clarification; overruled.

You can answer.

THE WITNESS: At the time -- I think you are asking

me about shredding at Gilman Hot Springs.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q Right. I am asking you whether that would

have come under the domain of the Guardian's office to engage

in such an operation.

A No.

Q It wouldn't have?

A No.

Q In early 1981, was there any agency within the

Church of Scientology which would have had control over

shredding of documents?

A I never heard of anybody having control over

shredding of documents.

Q Did you know anything about something called

shredding of church documents?

A I know that -- you know, like at some point

within the G.O., like if they were finished with files, old

files, materials, that they shred them. And they shredded

old files that were no longer --

Q Did you ever hear of a procedure called

"a vetting hat write-up"?

MR. LITT: Your Honor, in the motion in limine the

Court ruled that there was not going to be a wide open dis-

cussion of all of this.

Mrs. Hubbard has been asked about shredding at

Gilman Hot Springs. She says she knows nothing about it.

This is beyond the scope. If it is impeachment,

I don't know what of. This is improper examination.

THE COURT: Well, she has testified about giving

consent and what she gave consent to and what she didn't give

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

didn't believe to be somewhere else.

This is cross-examination. Her credibility is

in issue. We did talk about some of those motions, but they

were primarily in the context of a jury trial. And we

wouldn't be doing any of these things in the presence of a

jury.

There is no jury here.

I don't know what this is leading to. It may

lead nowhere. But I think he can ask the question.

Overrule the objection.

Q BY MR. FLYNN:Do you know what "vetting hat

write-up" is, Mrs. Hubbard?

A I have never seen a vetting hat write-up.

Q Do you have any idea what the term means?

A I have heard of vetting, yes.

Q What is your understanding of what that term

means?

A I think it is removing from the files any of

the headings that say to and from, the signatures of dis-

patchers.

Q Is that something that the Guardian's office

did?

A I believe at one time the Guardian's office

did do some of that, yes.

Q Were you the controller when the Guardian's

office was doing that?

A I heard about it, yes.

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q What was the purpose of vetting, if you know?

MR. HARRIS: Could we have a time frame, Your Honor?

MR. FLYNN: 1980-81, Your Honor.

Q What was the purpose of vetting?

A '80 and '81, I am not sure I heard about

vetting in '80 and '81 within the Guardian's office.

Q Did you know what the term meant in 1980 and '81?

A Yes, I did.

Q Was the purpose of vetting to prevent -- well,

like the government might seize documents and find out

certain things about the operation of the church?

A At one time there was a sort of -- well, like

after the raid upon the church and when the government took

so many documents, they took about 200,000 documents of

materials and only used about 200 at trial.

I know that the church sort of -- well, like

within the G.O. there was like a paranoia that developed;

that everyone was afraid of writing anything within the

Guardian's office because by some -- that the FBI might come

in and raid and so on.

So I knew it very early before we clarified

exactly what the law was all about and what -- like the law

of conspiracy was about. And so there was some vetting

done that I was aware of within the G.O.

Q Did that paranoia that you just described

exist in early 1980 at Gilman Hot Springs with regard to

the government seizing documents of the church, if you know?

A I didn't know that at the time, no.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q Do you know whether a shredding operation

took place in early 1980 at Gilman Hot Springs?

A I don't know.

Q You don't know anything about it?

A No.

Q Now, do you know or have you learned that in

connection with any shredding operation certain materials or

documents from R Storage were collected by a person named

Brenda Black and brought to Gerald Armstrong?

MR. LITT: I object to the question of has she

learned.

What is the relevance, Your Honor?

THE COURT: It is preliminary to some other question.

I'll overrule it.

You can answer.

THE WITNESS: Subsequently in the course of -- in the

course of this legal case, I learned that Brenda Black had

asked Gerry about some materials, yes, at one point.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q Have you talked to Brenda Black about that?

A No, I have never talked to Brenda Black about

it.

Q Was that the first time you learned anything

about shredding?

A That was the first time I learned anything

about shredding, yes.

Q And when did you acquire that knowledge?

A That must have been at some point in late

'82, something like that.

Q Now do you have any understanding as to the

fact that Mr. Armstrong came into possession of documents

and materials from R Storage during a shredding operation

in early 1980?

MR. LITT: Your Honor, Mr. Flynn is trying to

establish what Mrs. Hubbard's assessment of basically

evidence in this case is. In Mr. Armstrong's testimony he

can put on testimony as to that. The question is what she

knew during the relevant time period, all of which is prior

to August 1982.

If she's heard what Mr. Armstrong may have

testified to, what does that have to do with any of the

issues in this case if she didn't have personal knowledge

of it.

THE COURT: Of course, it is irrelevant unless it

is preliminary to some other question.

MR. FLYNN: It is preliminary, Your Honor.

MR. LITT: Well, can we have an offer as to what

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

THE COURT: We could have had the answer long ago.

Would you read the question, please, if you

can find it.

(Record read.)

Q BY MR. FLYNN: Do you have any understanding

about that?

A No, only what has been alleged in the case.

I don't know the facts of it at all.

Q After you learned that Mr. Armstrong came into

possession of what he says is in exhibit E from R Storage

at the special unit at Gilman Hot Springs --

A Yes.

Q -- did you at any time thereafter go out and

examine any of the documents and materials out at Gilman

Hot Springs that he had come into possession of?

A I didn't know he had come into any possession

of them other than what is stated there.

Q Well you knew he had a beat up, uninventoried

box; is that correct?

A That is correct.

Q And you knew that there was material relating

to you and your husband in R Storage; is that correct?

A Yes.

Q Did you ask him where he got the box?

A No I made an assumption.

Q What assumption did you make?

A I made the assumption that after my husband

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

box from what I had seen in the Gilman Hot Springs house and

that that was the beat up box that was ing talked about.

Q When was your understanding as to when your husband

left the area?

A My understanding was my husband left the area

in early February 1980.

Q Did you ever have the understanding that he

left in March 1980?

A No, I didn't.

Q Now you filed various declarations in various

courts in the United States; have you not?

A Yes.

Q And those declarations relate in part to the

fact that you haven't seen your husband since 1979?

A Yes.

Q And do you have a specific memory today that

your husband left in early February 1980?

A Just that it seemed that was about the time

that he left, yes.

Q Could it have been March?

A In reviewing various data and so on to refresh

my memory, I think it was in February of 1980.

Q Let me show you a 28-page declaration you

executed on September 28, 1983.

A Right.

Q Is that your signature?

A Yes, that is.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

Q And would you read the first sentence in

paragraph 12 of that declaration?

A (Reading:)

"Somewhere around March 1980 my husband

again went into complete seclusion."

Q Now does that refresh your memory, Mrs. Hubbard,

as to when your husband left Gilman Hot Springs?

A No I still believe I am more correct in the

February 1980.

Q Well you signed this under pain and penalty

of perjury; did you not?

A I did,

Q So this affidavit is wrong?

A That affidavit is not as correct, no.

Q Is it false?

MR. LITT: Objection; it is argumentative.

THE COURT: Sustained; it is argumentative.

Q BY MR. FLYNN: You testified in direct that

your husband is in seclusion; is that correct?

A That is correct.

Q What do you mean by seclusion?

A I mean that he is living privately and personally

and by himself.

Q When was the last time you saw your husband?

A I have already said late 1979.

Q And after that period of time did you ever

appear before a notary public with your husband and execute

any documents?

A No, I did not.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q Have you communicated with your husband since

late 1979?

A Yes, I have.

Q How have you done that?

A I have written him personal letters which I

have addressed in envelopes and put them into my out basket

in my office.

Q Is your husband receiving those letters?

THE COURT: If you know.

THE WITNESS: I don't know, sir.

Q BY MR. FLYNN: Did you testify in your

deposition that you don't believe your husband is receiving

those letters?

A Yes.

Q Is that your belief here in the courtroom?

A That is my belief in the courtroom.

Q Do you know who is receiving the letters,

Mrs. Hubbard?

A No, I don't.

Q Do you know whether those personal letters

are read by members of the church?

A No, I don't.

Q Do you of anyone that is communication with your

husband?

A No, I don't.

Q Since late 1979 have you been in communication

with any person who has told you that he is in communication

with your husband?

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

A No, I have not.

Q Well, you have been in communication with your

lawyer; is that correct?

A Yes. I have been in communication with my

lawyer.

Q You are aware that a declaration of your husband

was filed in the DeWolfe probate proceeding; is that

correct?

A Yes. That is correct.

MR. FLYNN: May I have exhibits 1 and 2 of the plaintiff,

please?

Q Have you seen this handwritten letter of your

husband marked exhibit 1 and dated February 3rd, 1983?

A No. I have never seen the original of this.

Q You have seen a copy?

A I have seen a copy, yes.

Q Now, do you know the circumstances under which

that letter came into the possession of your attorney?

A No, I do not.

THE COURT: I don't think there has been any testimony

that it was ever in the possession of her attorney.

MR. FLYNN: To date there has not been, Your Honor.

Q Now, do you know whether that handwritten --

do you know who Mr. Lenske is?

A Yes.

Q Do you know who Mr. Brunell is?

A No.

Q Do you know that special ink was sent to your

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

A I didn't know at the time. I heard about it

later in the case.

Q You knew that special ink was sent?

A I just heard about it.

Q Do you know whether the special ink was prepared

the day before that letter is dated?

A No, I don't.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q Now, do you know of any way that anyone in the

Church of Scientology communicates with your husband?

A No, I don't.

Q Are you familiar with a corporation called

Author Services, Incorporated?

A Yes, I am.

Q And what is your understanding as to what that

corporation is?

A That that is a business management firm that

my husband has conduct personal business for him.

Q And do you know whether they are in weekly

communication with your husband?

A I believe that they must be, that they might

be in communication with him. I know they send him reports

because of affidavits that were filed in this case.

Q So your belief is that Author Services,

Incorporated is in weekly communication with your husband?

A I don't know weekly and I don't really know.

I have never asked them. I just know what they said in

the affidavit.

Q When you write these letters to your husband,

describe how you deliver them or mail them to him?

A I write my letter. I put it in an envelope.

I put it in my out basket on my desk.

There is a man and his wife who live with

me. He picks it up, the communication from my out-basket,

and then he takes it and he delivers it, as far as I know,

to a mail service.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q What type of a mail service?

A One of the public type mailing service where

you can -- you know, that receives mails and telephone

messages for people.

Q You mean like Federal Express?

A No, like an address -- like a place that performs

services for people. We have them in Los Angeles. I

don't know if you have them in Boston or not, but they

are just a mailing service.

People can call them. They leave messages

and they relay messages for people. They will hold your

mail for you and you go and pick up your mail, and that

sort of thing.

Q Do you know the name of it?

A No, I don't know the name of it.

Q What do you put on the envelope that you address to

your husband?

A I put on the envelope to R.

Q With no address?

A No address, no.

Q What is the name of the person who delivers

this to the mail service?

A His name is Mr. Potter, Neville Potter.

Q And where is Mr. Potter located?

A Mr. Potter is located here in Los Angeles.

Q Can you give me his address?

MR. LITT: Objection, your Honor. Mr. Potter lives

with Mrs. Hubbard and we don't want Mrs. Hubbard's address

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

cases. We have had rulings that it not be disclosed.

MR. FLYNN: If they produce Mr. Potter, it will

be fine.

MR. LITT: Are we going to spend time on that in

this case? Does the court want to hear Mr. Potter?

MR. FLYNN: It goes to the issue of availability

of Mr. Hubbard.

MR. LITT: If the court wants Mr. Potter in --

THE COURT: It isn't a question of what I want.

It is a question of what you want to do to avoid disclosing

the address if he wants to raise this issue.

MR. LITT: If the court finds that Mr. Potter is

a proper witness and that therefore Mr. Flynn is entitled

to his address, then subject to confirming it with

Mr. Potter, I will represent to the court that we will

make him available in the event that the court permits

the inquiry.

THE COURT: Well, at this point that will be the

status of the record.

Let's go on to the next question.

Q BY MR. FLYNN: Now, Mrs. Hubbard, you don't

believe that your letters are getting to your husband,

but you believe that Author Services, Incorporated is

in communication with him; is that correct?

A I can only say what they said, what I know

from what they said in the affidavit, Mr. Flynn, and I

have never spoken to people or Author Services. I have

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q Did you, testify earlier in cross-examination

that you don't believe that your husband authorized

Mr. Armstrong to collect the documents to prepare the

biography?

A Yes, I did.

Q Do you know where Mr. Armstrong's communication

came from in early 1980 relative to that subject?

A I am not sure I understand your question.

Q Do you know the circumstances under which

your husband may have communicated to Mr. Armstrong that

he was authorized to collect what you say is your personal

documents and letters?

A I don't think there was any communication

that authorized him to go into my personal storage. If

there is such a document that says Mr. Armstrong could

go into our personal storage, I haven't seen it.

Q Do you know when Mr. Armstrong first petitioned

to collect materials for the biography?

A I understand that he did petition and I have

seen subsequently such petition, but I don't have the

petition before me.

Q Well, let me show you exhibit 11 in this case.

Q Have you seen exhibit 11 before?

A Yes, I have.

Q And in the upper right-hand corner, is that

your notation, "Very good. Approved. Mary Sue"?

A Yes, that is correct.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q And what is exhibit 11?

A Exhibit 11 is a dispatch from the controller

archives to myself requesting that I go through the contents

of these two boxes and authorize whether or not they are

going to go to Mr. Jerry Armstrong.

Q And did you do so?

A Yes, I did.

Q And what is the date of exhibit 11?

A January 1981.

Q And what was the purpose of Mr. Armstrong

obtaining authority at that time to have materials from

controller archives?

A I don't see any reference to Mr. Armstrong

requesting materials. I only see reference that Mr. Vorm

is requesting of me whether these materials that are my

personal possessions are authorized by me to be given

to Mr. Armstrong for a museum and for use in a biography.

Q And you approved that?

A Yes, I did. I looked through the materials

myself. I have the two boxes there. I went through them

all and I said yes, that those could go to Mr. Armstrong.

Q That is dated January 5, 1980; is that correct?

A It is dated that, but the date is incorrect

on this.

Q Well, do you know when Mr. Armstrong first

petitioned to gain access to your materials?

A He might have petitioned to gain access to

my materials, Mr. Flynn. If there is such a petition

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

the case. I am sorry. I have not seen anything requesting

permission for Mr. Armstrong to enter my storage to obtain

things without my knowledge.

Q You haven't seen anything, Mrs. Hubbard?

A I told you I haven't seen any request from

him requesting authority to go into my storage. I haven't

seen it and at no time throughout the whole time he was

working on it, I never received any request saying, "Dear

Mary Sue: I would like to go into your storage and I

would like to obtain for use possibly with your permission the

following articles" and so on.

He never sent me any materials from my storage

saying, "Dear Mary Sue: Could I please use these for

the biography?"

I never had anything like that, so I am not

sure I understand what in the world you are talking about,

Mr. Flynn.

Q Well, Mrs. Hubbard, you did see exhibit E

where he said he was going through personal letters on

February 5, 1980?

MR. LITT: Objection; that has been asked and answered

about three times now, your Honor.

THE COURT: Sustained.

Q BY MR. FLYNN: What is your best memory as

to when your husband left to go into seclusion?

A My best memory is in February of 1980.

Q Did you ever see a petition of Jerry Armstrong

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

A I did see one, yes, in the deposition.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q In 1980 before your husband left did you see

this petition?

A I never saw this petition.

MR. LITT: Is that being marked as an exhibit, your

Honor?

MR. FLYNN: It is, your Honor.

THE COURT: Mark it next in order, F.

Q BY MR. FLYNN: Have you had an opportunity

to read that petition, Mrs. Hubbard, prior to today in

the courtrom?

A I only briefly glanced at it in my deposition

earlier in, I guess it was, '83.

Q What is the date of that document?

A It says January 8, 1980.

Q That was a petition to your husband; is that

correct?

A Yes. That is what it says.

MR. LTTT: Your Honor, may I request that if

Mr. Flynn intends to ask Mrs. Hubbard questions concerning

the document, that she be given the opportunity to read

it before she is asked about it?

THE COURT: All right.

MR. FLYNN: Yes.

Q Go ahead.

Q Have you read that, Mrs. Hubbard?

A Yes, I have.

Q What is the date on that?

A The date of that is January 8, 1980.

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Q Now, that is before the date that you say

your husband left the Gilman Hot Springs area; is that

correct?

A I said I thought my husband left in January,

1980. I don't know if it was before or after the date.

I don't know when he left the area.

Q Did you testify earlier that he left in early

February, 1980?

A Yes.

Q Are you changing your testimony now to make

it January, 1980?

A I am saying -- yes, January, 1980 is