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FOR THE COUNTY OF LOS ANGELES

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

  (See Appearances page.)

VOLUME 7

Pages 996 - 1177

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APPEARANCES:

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I N D E X

W I T N E S S E S

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I N D E X

E X H I B I T S

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-o0o-

MR. LITT: Good morning, Your Honor.

THE COURT: Good morning.

MR. FLYNN: Good morning, Your Honor.

THE COURT: All right, we are back in session.

Is Mrs. Hubbard available?

MR. LITT: Your Honor, what we would like to do is

have Mr. Vorm testify. After court yesterday Mrs. Hubbard

came to our office and we worked until about 10:00 reviewing

these articles, and she will be here around 10:00 and we

are prepared to proceed with Mr. Vorm.

THE COURT: All right.

TOM VORM,

recalled as a witness by the plaintiff, having been previously

duly sworn, resumed the witness stand and testified further

as follows:

THE COURT: Mr. Vorm, you have already been sworn, so

just have a seat. State your name again for the record. You

are still under oath.

THE WITNESS: My name is Tom Vorm.

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MR. HARRIS: Your Honor, I gave you a copy of the

item which I said was an evidentiary item which contains the

marks of Mr. Armstrong. I have a copy for Mr. Vorm; I gave

a copy to Mr. Flynn. I would like the court's copy to be

marked Plaintiff's next in order.

THE COURT: Okay. 13; so marked for identification.

 

DIRECT EXAMINATION,

BY MR. HARRIS:

Q Mr. Vorm, you previously made reference to

Mr. Armstrong marking certain sections of an inventory in

your testimony previously as I recall; is that right?

A That is correct.

Q Now, at my request did you obtain the entirety

of the inventory of the trunks from your files?

A Yes, I did.

Q Actually, it was pursuant to the court's order,

but at my request.

Now, When you obtained that inventory of the

trunks, what did you do with it?

A I pulled out the pages that had Gerry's check

marks on them and put them together and put the others

together separately.

Q And exhibit 13 which you have before you,

are those the pages that you pulled out that had Gerry's

markings on them?

A That is correct.

Q Prior to pulling them out did you number the

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A Yes, I did.

Q That is, the entirety of the inventory?

A The whole thing, yes.

Q From 1 to whatever it was?

A Yes.

Q After that was done you pulled out the pages?

A Right.

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Q Directing your attention to the small 12 on the

first page which is circled, is that your writing?

A Yes.

Q And is that the numbering system that you used

throughout?

A Yes. I put a circle around all my numbers in

the bottom right-hand corner.

Q All right. Other than that 12 on the first

page, is anything there your writing?

A No it is not.

Q When you received the trunks, did you use

exhibit 13 in going through the trunks?

A Yes, I used the original of exhibit 13, right.

Q On the front that is on the first page of

exhibit 13 there is what appears to be trunk 8.

By your observation of the trunk, what did that

mean?

A Well, each trunk had a designating letter

that was marked on the trunk. Trunk 8 had the number 8 mark

on the trunk, and that was the contents of the trunk.

Q All right, directing your attention to page 14,

your numbering of exhibit 13 on the left-hand side appears

to be the word "envelope" the number 1 and then a bracket

which extends down toward the bottom of the page; do you

see that?

A Yes, I do.

Q All right, when you opened the trunks and

used the inventory, part of which is now exhibit 13, were

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that is in the middle of page 14 of exhibit 13, were in fact

contained in envelopes?

A Yes.

Q And did the inventory that is page 14, for

example, exhibit 13 contain an envelope No. 1 which contained

the items that are on page 14?

A Yes, it did.

Q Down about three-quarters of the way down the

page there appears to be some dark writing in the left-hand

column.

Do you recognize that?

A Yes, it looks like Nikki Friedman's handwriting.

Q And when you went through envelope No. 1 in

trunk 8, did you find a packet re Pontiac papers, certificates,

et cetera?

A No, I didn't. It wasn't there.

Q Was everything else that is indicated on the

inventory page 14 of exhibit 13 in an envelope which had a

designation 1?

A As far as I recall, yes.

Q Now, the check mark over on the right-hand

side of page 14 of exhibit 13, whose marks are those?

A Those were made by Gerry.

Q And what time were these done?

A They were done as part of the procedure for the

transfer of materials to Gerry in approximately October of '81.

Q In respect to the items that are checked off,

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A He received the original item.

Q I am now looking at the top. There were two

LRH wallets, one full of membership cards that would have

just been given to him at the time?

A That's right.

Q With no copies retained by you?

A No.

Q And that would have been true of the remainder

of the envelope 1 which has check marks on the right-hand

side?

A That is correct, yes.

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Q Envelope 2, envelope 3, at the time you

opened the trunks using the inventory, did those appear to

contain the contents as designated in the middle of page 14?

A Yes. They appeared to be accurate.

Q Please, turn to page 15.

Again, on the left-hand side there appear to

be various envelopes. And so we can clear this up for the

rest of it, in each of the cases where there was an envelope

for file designated on the left-hand side, when you opened

the trunks and looked in there was there an envelope which

contained the items that are in the inventory, that is, the

middle part?

A Yes.

Q Directing your attention to the top of page 15

there is what appears to be a bracket of some sort on the

right-hand side with a check mark; do you see that?

A Yes.

Q What does that designate?

A What that meant was instead of checking off

every single item, all the items in that category were

bracketed and a check mark was put beside it, meaning all of

those items were given to Gerry.

Q And, again, these were originals and no copies

kept by you?

A Well, the items in the trunk were Xeroxed

copies. Those originals of those Xeroxed copies were given,

and no copies were kept by me.

Q Fine. Down about three-quarters of the way

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the right-hand side near where other checks are which says

"Missing."

Whose writing is that, if you know?

A That would have been Gerry's.

Q And there was something that was missing from

envelope 11, to your recollection?

A Yes.

Q All right. Directing your attention to

page 16 on the right-hand side, mid page, there appear to

be M's underlined, some with question marks; what do those

designate, if you know?

A Well, as far as I can tell, the M in this

inventory indicated there was a manuscript, meaning it was

several pages of handwritten, usually handwritten, sometimes

typed, either an article or something that could be con-

sidered a manuscript as opposed to just a single note or

something like that.

Q And, again, the check marks are Mr. Armstrong's

check marks on the right-right side?

A That is correct.

Q What is that X that is below the two check marks

mid page, right-hand side, page 16, Exhibit 13?

A What happened on that particular item was I

was going to give it to Gerry. And after looking at it,

decided that it was something that actually should be in my

archives. And so the check mark was crossed off, and I kept

that particular item.

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Q In Mr. Armstrong's presence?

A Yes.

Q Now, with respect to the check marks at the

bottom of the page on the right-hand side, were these

envelope 22, envelope 23, with various categories, were these

individual documents or multiple documents? What is it?

A Those particular items were files containing

several articles, some of the pages stapled together because

they are series, correspondence, or whatever that particular

file contained. But there is definitely more than one item

in those files.

Q Directing your attention to page 17 of

Exhibit 13, again, each of the check marks on the right-hand

side designated that these were items given to Mr. Armstrong

and these were his check marks?

A That's right.

Q And not to be duplicative, but again, are we

talking about single pages, files, or a mixture, when you are

looking at page 17?

A Page 17 is actually a mixture, I believe.

For instance, the letter from Karl Marx was

either one or two pages, wasn't very big, as I recall. Some

of the others, like folder, legal receipts, I recall that it

had quite a few receipts in the file itself. So it is a

mixture.

Q Turning to page 18, it appears to be just one

check mark, "Correspondent Home of this"; was that an indi-

vidual document or a file?

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A That was a file. If I recall, there were

several pages of correspondence in that.

Q Directing your attention to page 24, up on

this --

By the way, this is trunk No. 12-1 up at the

right-hand corners what does that designate?

A That was the designation on the outside of the

trunk that was marked 12-1, and this inventory would corres-

pond to that trunk.

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Q Okay. Now, when you received the trunks,

approximately how many were there?

A As I recall, there were around 20, something

like that when I first got them.

Q And the numbering system on the trunks were not,

I take it, 1 to 20 judging from this?

A Right.

Q Could you explain to the court what the

numbering system was if you could figure it out?

A They just had various numbers on them, 12-1,

12-3, 12-5, 12-6. I don't know why they started with 12,

but that is what the trunks were marked and that is what

the pages were marked so that is what corresponded.

Q Now there is on the left-hand side an underlined

phrase "Pack HWD-1."

By your observation of the contents of the

trunks, what did HM mean?

A Well, this particular trunk contained mostly

HWD packs. HWD evidently stood for hand-written dispatches

per the note on the top and also, I believe, the files

themselves are labeled LRH handwritten dispatches or

handwritten dispatches or something like that.

Q Now, when it says "pack HWD-1" what was the

difference between a pack and an envelope by your observation?

A Well, in the earlier trunk the envelopes were

actually like legal manila-sized brown envelopes with a

flap on the front. They had numbers on the outside of the

envelopes.

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When he talks about pack here, what it was is

it looked like someone had gone into a file drawer and just

taken out a section of files, wrapped them in cardboard and

tied them with a string and then written on the outside of

the cardboard the pack number of that particular pack.

Q All right, now, up in the center of the first

inventory item appears to be ACC notes and then 16th and 17th

have a circle around them, as does 20th and there is some

handwriting; what is that?

A Those were notes that I made when I was going

through the trunks originally.

Q And what does that indicate?

A Well on the 16th and 17th it says "Booklet

filed MSS" which is my indication of manuscripts, so what

that means is that there was a booklet pertaining to the

16th and 17th ACC's which I considered should have been

filed with the manuscripts, and I took it out and filed it

in another file.

Q All right, and the circle around the 20th,

what does that designate?

A That would just be my notation that I had

pulled it out and filed it somewhere else. Those are my

initials.

Q And when we see those throughout the remaining

pages, those are indications that you took an item out of

the trunk and filed it in some sort of file?

A Right.

Q And again the check marks that go down page 24

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A That is correct.

Q In respect to these, are we talking about

multiple documents or single documents?

A In most of these cases there are multiple

documents. Some of the files had hundreds of pages in

them. Some of them had just a few.

Q And down at the -- it looks like mid-way

there is some writing. Appears to be "two folders."

Whose writing is that?

A That looks like Gerry's writing. I can't be

sure exactly.

Q Directing your attention to page 25 appears to

be only two items designated by check mark; Cuba and deceased

Scientologists.

These were items that were given to Mr. Armstrong?

A They were files that were given, yes.

Q And again with any of this so far did you

make copies or did he make copies to return to archives?

A No, these were the original files and I was

just transferring them to him.

Q All right. Directing your attention to page 27

pack HWD-3, there is a notation, there is an item FDA Legal

scratched out, and then there is some writing; whose writing

is that?

A That as Gerry's writing.

Q What did that indicate?

A What if I recall when we went through this

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it was written "missing" and as we went through, then later

on we found it in one of the other packs under a different

heading. So we ca$er back and wrote that in, crossed out

the "missing" and wrote in where to find it.

Q Direcing your attention to the bottom of page

27 of exhibit 13 there is what appears to be handwritten

"all HEC files" with a check mark; whose writing is that?

A That is Gerry's writing.

Q And what files were included in all HEC

files?

A That included the entirety of pack HWD-4(a).

If you look right underneath on page 27 where it says

pack HWD-4(a), it says HEC. There was a file divider there

labeled "HEC" which included all the files evidently in the

file drawer. That is what was used and these files were HEC

files and they were all given to Gerry except for the two

items that I had taken out earlier on page 28.

Q Two items -- oh, I see, the RSF orders and

ships org book?

A That is correct.

Q All right. Now, so what you are saying is

the check mark that is on page 27 which is next to "all

HEC files" encompassed the first part of page 28 through

Tangiers?

A That is right.

Q Bottom of page 28 appears to be the designation

"Legal" and then there is "AMA" and "FDA" with check marks;

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A That indicates that those were two files that

were taken and they were both checked off.

Q Do you recall the size of these files? Were

they single documents or multiple?

A Those particular files were pretty thick.

I think they were an inch or more/of correspondence, various

things having to do with legal.

Q Now, this FDA I noted earlier on page 27 was

looked to be missing, and then there was this notation

"See Legal FDA"; has that word showed up?

A That's right.

Q And what is the designations of the dates at

the bottom of page 28; 9-'53-'60 et cetera; what was it?

I don't assume it was just dates sitting in the file.

A No, that was, if I recall the file said Legal,

and then afterwards it said whatever these designations

were from 1953 to 1960. That would have been legal materials

like correspondence with attorneys back and forth from that

period of time, meaning 1953 to 1960, inclusive.

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Q All right. Page 29 appears to have check

marks throughout and then some writing about two-thirds of

the page down, "Legal AMA, Legal FDA"; whose writing is

that?

A That is Gerry's writing.

Q What does that indicate at the time that that

was put there?

A I don't recall exactly on that.

I think what happened is that these items were

missing earlier, at least this one, this "FDA Legal." And

either there was two additional files labeled "Legal AMA" or

it was just written in on the wrong page. I am not sure.

Gerry was handling the check marks as we went through on

that particular item.

Q Up at the top of page 29, the third entry,

"Dear Fellows," there is an X; what does that indicate?

A I don't recall what that particular X meant.

Q And with respect to the items on page 29 of

Exhibit 13, are they single documents or multiple?

A These were all file folders. These were the

labels on the file folders. In some cases, some of them were

single pages. As I recall, for the most part they had more

than one page. In some cases, they had a lot more pages.

Q Turn to page 30, the bracket with the check

that is up at the top and the category "Membership Cards";

what does that indicate?

A It indicated that those three items were all

taken.

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Q And with respect to the items on page 30

which contain check marks, again, I take it it is a

potpourri, some individual documents, some files?

A Well, they were all files. There weren't any

individual documents.

As far as what the files contained, you are

correct; some were single: some were more than one.

Q All right. Quickly going through, 31 appears

to be a lot of check marks.

32, there is one, Excalibur. This is an item

that Mr. Armstrong took?

A That is correct.

Q Going to page 34, there is one check mark,

"Ships and Boats, 1957-68," and then an indication, seven

folders; that was given to Mr. Armstrong?

A Yes.

Q And what does -- from your recollection of what

it looked like, what are the seven folders? Are we talking

about big items, small? What is the best you can describe

it?

A As I recall, those particular folders were all

at least an inch thick. There was just a lot of

miscellaneous files and correspondence, that sort of thing.

Q Turning to page 37, there appears to be some

writing about two-thirds of the way down the page, "Pack

HWD 13"; do you recognize that writing?

A Yes.

Q That is whose writing?

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A That would have been Gerry's.

Q Directing your attention to page 42, at the

bottom -- well, it is actually mid page. But at the bottom

of the typing appears to be some handwriting, "MSH Letter

1973 one pack LRH" -- I can't make that out -- "Certs"

and then "(Photos) two packs"; what was that and what did

it indicate?

A What that indicated was the -- the letters

that Mrs. Hubbard wrote to Mr. Hubbard in the 1973 period.

He was away for a while.

What those included also, there were some

certificates that were actual photos of the certificates as

opposed to original certificates. There was two packs of

those. Those were given to Gerry.

Q Those two items is handwriting, whose hand-

writing is that?

A That is Gerry's handwriting.

Q And the letters, 1973 MSH, did Mr. Armstrong

get the originals or copies?

A Well, per our agreement, he was given the

originals to Xerox only, which he then brought back to me.

Q So you maintained the MSH letters in 1973 in

original form in your archives right now?

A That is right.

Q And as far as you know, he made copies?

A Correct.

Q Directing your attention to page 43 of

Exhibit 13, there appears to be an arrow of some sort about

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A Yes.

Q And what does that designate?

A What that is, the -- there were two packs

labeled RHOD; that stood for Rhodesia 1 and 2.

Then it says, "See following inventory for

details, contents of Rhodesia drawer and top study."

There are two pages following, page 44 and

page 45, which was basically a breakdown of those two packs

as far as the files that they contained. And my notation

just says, "To Senior PTR Researcher Both Packs," with my

initials.

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Q And when was that written?

A I am not sure exactly. If I recall, it was

written slightly later than or slightly before. I think it

was later. It had to have been later than this other

transfer with the checks.

Q A11 right. And how did that happen?

A I can't recall specifics on it. I can't

recall specifics on that.

Q In any event, pages 44 and 45 --

THE COURT: Before you leave 43, what is all this

crossed-out material supposed to be?

THE WITNESS: I don't know what that was, Your Honor.

That was crossed out in a heavy black pen.

THE COURT: Before you had access to it?

THE WITNESS: Before I received the inventory.

THE COURT: Did Mr. Armstrong have anything to do

with that, to your knowledge?

THE WITNESS: No.

THE COURT: All right.

Q BY MR. HARRIS: Pages 44 and 45, then, are the

two packs that are under Rhodesia 1 and 2 just broken down?

A That's right.

Q And you gave the entirety of the packages

Rhodesia 1 and 2 to Mr. Armstrong?

A That's correct.

Q Directing your attention to page 48 of

Exhibit 13, about halfway down the page, "Some handwriting

folder containing MSH letters, et cetera"; do you see that?

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A Yes.

Q Whose handwriting is that?

A I don't know whose handwriting that was.

That was on the inventory when I received it.

Q And was there, in fact, such a folder in the

trunks?

A Yes, there was. If I recall, what happened

was we came across these letters, but we couldn't find the

notation on the inventory as to where they were. So on

page 42, Gerry just wrote them in, "MSH letters 1973, one

pack."

Q Page 42?

A Right.

Q Oh, I see.

A Then later I saw that notation, and if you

will see on page 42 I wrote down at the bottom, "See 12-3

page 6," just as an indication.

Q Oh, I see. In other words, back on page 42

there is some writing below the word "packs"?

A Right.

Q Which is your writing?

A Right.

Q Making reference to what is now page 48?

A That's right.

Q All right. Page 50 of Exhibit 13, there is a

notation up at the top which appears to be the title of the

page as well as the date. There is a date 8 February 1969,

then LRH per sec WW files to LRH.

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You received page 50 along with the rest of

the inventory at the time you received the trunks?

A That's right.

Q And the items from your observation of the

trunks -- in this case, trunk 12-4, contained all of these

items?

A That's correct.

Q And a great many of them appear to be checked

off. Were these files or individual documents?

A These were all file folders. They appeared

to be primary correspondence files.

Q Originals?

A Original documents.

Q And that extends over to page 51?

A Yes.

Q Page 52, about a third of the way down, the

page there is on the left-hand side, something pack number

LRH PS3, et cetera; whose writing is that, if you know?

A I am not sure whose writing it is.

Q All right. As far as the contents of the

packs, does the inventory reflect what was in those packs?

A As far as I recall, yes. There were packs

labeled LRH PS3. I believe that stood for per sec with a

number after it, and those particular files matched up.

Q And the LRH Correspondence Files, which has a

check mark next to it, two parcels, about how big were these,

if you recall?

A I don't recall exactly. I know they had more

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Q All right. Now, over on the left-hand side of

page 52 there appears to be little dashes in the left

margin; what are those?

A I don't believe they signify anything other

than maybe we just looked at the files. I don't think they

have any significance.

Q Again on page 56, title "Contents of Large

Double Doored Safe WW," with a date, that was all on there

when you received this?

A Yes.

 

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Q Now, I want to direct your attention to

page 58. I'd like to describe it in geometric terms, but I

won't.

There is a line running from "LRH Personal

Records" down to "Sunburst Cross Pin plus Ornamental

Ribbon." And there appears to be some writing on the right-

hand side. What does that designate, if you know?

A These particular items were all the ones that

I gave to Gerry after I had sent the request to Mary Sue in

January of '81.

MR. HARRIS: May I have just a moment, Your Honor?

THE COURT: Yes.

Q BY MR. HARRIS: I am going to show you

Plaintiff's Exhibit No. 11. Is that the approval that you

are talking about?

A Yes.

Q And you listed the items that you wanted to

turn over to Mr. Armstrong --

A Right.

Q -- in box 1 and box 2. Now, I don't see any paperbacks -- approxi-

mately 30 assorted science fiction paperbacks; where were

those from?

A I think those were in trunk 8, but I couldn't

find them on the inventory when I first picked up the

trunks.

Q So these are the items that were approved by

Mrs. Hubbard to be given to Mr. Armstrong, which are on

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A Right.

What I did was I just went down the inventory.

And you'll see, it matches almost exactly with what is on

the request.

Q In any event, throughout the remainder of

Exhibit 13 the check marks indicate that Mr. Armstrong

received the items after which the check marks appear?

A Yes.

Q Now, did you also, at my request, this weekend,

from your memory of what was under seal here in the court,

check all of the archives under your control with respect to

items that you remembered being under seal?

A Yes, I did.

Q And for what purpose?

A To be able to determine whether we had copies

of certain items that I remembered being under seal in

court.

Q And the items under seal you are talking about

are originals?

A Right.

Q So you compared your archives with your memory

of what was under seal as originals to determine if you had

copies?

A That's right.

Q All right. Using Exhibit 13 and pointing to

the page number on Exhibit 13, could you tell the Court some

of the items that are originals under seal and no copies in

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MR. FLYNN: Which archives are we referring to, Your

Honor?

THE COURT: The one under his control.

You are the controller archives?

THE WITNESS: That's right.

THE COURT: Is that the same as the G.O. archives?

MR. HARRIS: I think we'll straighten that out with

the chart, Your Honor.

THE COURT: Okay. Charts are always helpful.

THE WITNESS: Page 25 of the inventory, my numbering

system, there is a file under "Pack HWD-3" called

"Deceased Scientologists."

If I recall, when I was downstairs in the

court, that file contained a funeral oration and handwriting

by Mr. Hubbard for a lady named Peggy Conway, who had died

at a certain time in the '60s or late '50s, something like

that.

There also was some other correspondence

relating to a couple other Scientologists who had passed

away. I could not find any copy of those particular

original documents in the archives.

Q BY MR. HARRIS: All right.

A On page 27, under the HEC Files that were all

taken by Gerry, there was a file called Norton Rose 1966,

which, as I recall, contained at least 75 pages of original

documents, probably more, could have been in the hundreds of

legal correspondence and that type of thing between --

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any of those documents or copies of them in the archives.

Also the file called "Catterall 1966"; those

particular items, those particular files, I am sure -- on

some of these others I have a pretty good idea that they are

missing. I am just not going to say for certain.

Q Only ones where you are certain.

A Right.

Q And only a few. If you could, just designate

as you go through, name the page and the file. We'll under-

stand that there is an original by your memory under seal

which you do not have copies of in your archives.

A Right.

The next page, page 28, again, is part of the

HEC Files. It is a file called Constantine Diamontides,

something like that. It is a Greek name. I don't recall

those documents in the file.

If I recall, there are several big corres-

pondences, handwritten, between Mr. Hubbard and this par-

ticular person in Greece at the time.

At the bottom of page 28, under "Legal," those

two files, Legal AMA and Legal FDA.

Also, the file Legal 1962 to 1967. As I recall,

in court, there were a lot of pages in those files. Some of

them had like over 100 pages of legal correspondence, that

type of thing, from that period of time. And I could find no

copies in the archives concerning those.

Q Let me stop you for a minute.

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What archives did you look through to determine

if you had copies so that the Court understands what you did?

A I went through Gerry's archives, the ones that

had been turned over to me. I went through the material,

the files that had been returned by Omar Garrison and also I

went through my own files, the controller archives' files

plus files that were listed as the G.O. Archives' files

that had been given to me in '83.

Q So we don't extend this out, was there more

items on the inventory that you could name where the

originals are under seal and you do not have copies?

A I don't have any more that I could name from

memory.

If I had a complete inventory, I am sure --

MR. HARRIS: I have a chart which I showed to

Mr. Flynn this morning, Your Honor, and indicated that I

would use.

May this chart be marked Plaintiff's next in

order?

THE COURT: 14.

MR. FLYNN: We object and contend that it is

inaccurate, Your Honor.

MR. HARRIS: Any inaccuracies can be handled by

Mr. Armstrong, Your Honor, or others.

Q Showing you Exhibit 14, let me ask you a few

questions first.

Are you familiar with the contents of what is

called Guardian Archives WW?

A Right now?

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Q Yes.

A Yes.

Q And were you ever at Guardian Archives WW?

A Yes.

Q And when was that?

A That was January 1982.

Q And are the contents of Guardian Archives WW

now under your control?

A Well when you say was called Guardian Archives

WW, there's been a lot of materials that have been called

that at various times. Certain materials that I consider

to be archive materials are now in my control that were

called Guardian Archives WW?

Q All right. The inventory which I turned over

to the court the other day, what is that an inventory of?

A That is an inventory of the materials that I

received when the Guardian Archives WW was broken up

basically.

Q All right. From your knowledge of archives

generally, did you prepare rough drafts from which exhibit

14 was prepared?

A Yes.

Q Ail right, could you explain to the court

what the designations on item 14 mean and you have got to

hold it up go the court could see it at the same time.

A Do you want me to go through the whole chart?

Q Yes.

A Okay.

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Well, from what I know of the various archives

and my own research into what they were pursuant to trying

to sort out the confusion that existed when I came on the

post, this is basically a delineation of the Guardian Archives

and how that differs between the Controller Archives and

what the various terms mean because some terms were used

yesterday that kind of confused me as far as what was being

referred to.

Anyway this is basically a drawing of how I

understood the archives to have occurred and how it came

together. In 1966 there were the original materials of

Dianetics, of Scientology, including original LRH dispatches

of matters, that type of thing, plus the reference, the

Dianetics and Scientology materials, magazines that the

various organizations were asked to send in so that they

could be on file as a historical reference plus other

historical files. Those were all termed the Guardian

Archives. Mrs. Hubbard was the guardian, and that is where

they all were in England.

In 1969 Mary Sue Hubbard was made the

controller. There was some concern about the materials

and the project was sent to England to bring some materials,

the original materials of Dianetics and Scientology to the

ship, leaving at England the reference files of Dianetics

and Scientology materials, magazines, that type of thing,

plus any other historical files.

So, this is where the trunks were created.

The result of the project that did that just went through

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concern LRH and Mary Sue, and that is why you have a lot of

personal materials and that type of thing in the trunks. So,

the controller trunks then continue down the side.

Around 1975-1976 they were moved to California.

They were kept in storage for a while. Some time around

this period, at various times through this period the

tape trunks were separated, the trunks containing the tape

lectures for this project to preserve the tapes. They were

kept in Clearwater, Florida in 1975 or 1976. A project

was being done.

They were moved in 1977 to Los Angeles as a

separate matter, then these other trunks containing the

written materials and the personal materials.

In 1977 I came on post over the tapes. My

post title was Guardian's Office Archives Librarian. There

was a little confusion as to what archives. There was no

Controller Archives at that time.

In 1979 I received these trunks to add to

the tape trunks that I had, and that was when the Controller

Archives came into being. That included the original

Dianetics and Scientology materials, original LRH dispatches,

personal materials that were in the trunks plus all the tapes,

and that was the Controller Archives.

In 1981 the transfer occurred of some of these

materials to Gerry which was this archives here. After

Gerry left in October 1982 all these archives then came

back to me. The name was changed to LRH Archives.

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In February '83 what was left was at GO

Archives Worldwide. During this period they got a bit

confused as to what they were supposed to be doing, too. It

was under the public relations bureau and they had put all

kinds of public relations operational files, various programs

that we were working on, that type of thing into the archives

which weren't archives material. That was -- it was kind

of a confused mess all the way down here.

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In February, '83 there was a project that was

done basically at my request. They sorted out all of this

other material; anything that was archives material, they

shipped to me in packs. And that is the inventory that

you have on your desk, the GO Archives Worldwide. That is

basically the chart.

Q All right. Now, there have been mention of

Bureau of Information Archives; is there such a thing?

A Not that I know about.

Q Those are called Bureau of

Information what?

A Files.

Q There has been a mention of Per Sec files;

what are those?

A Those were -- basically, those were files of

correspondence, that type of thing which the personal

secretaries would keep; also a valuable documents file,

which I believe is supposed to include insurance policies,

legal things like that.

Q Is there a Pers Sec file in Los Angeles to

which you have access?

A Yes.

Q And do you know generally the nature of the

materials in that file?

A Yes.

Q Is there any Pers Sec file with which you

are not familiar?

A Yes.

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Q Which one is that?

A Pers Sec files at Worldwide.

Q Now, the term R Storage has also come in.

A Uh-huh.

Q What is that?

A Well, the way I understand it is in relationship

to this chart, in 1966 is where this chart started. Prior

to that, prior to 1959, prior to Hubbard going to England,

there were these other materials. Ana they were being

stored in Washington DC.

Q Where did they wind up?

A R Storage at Gilman Hot Springs.

Q When you visited the archives area that

Mr. Armstrong was putting together did he ever tell you that

items that he was collecting were from R Storage?

A I wondered where he got them.

There was some mention of it, yes.

Q All right.

Q No further questions, Your Honor.

THE COURT: You may cross-examine.

MR. FLYNN: Thank you, Your Honor.

 

CROSS-EXAMINATION

BY MR. FLYNN:

Q Would you turn to page 32 of exhibit 13,

the inventory, please?

Do you have that in front of you, Mr. Vorm?

A Yes.

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Q In response to a question of Mr. Harris did you

state that the Excalibur transcript was among the documents

that are listed on page 30 to which Mr. Armstrong check marked

as being given to him?

A I don't think I mentioned the word "transcript."

Q Did you state that it was a manuscript?

A No.

Q Do you recall what it was?

A Yes.

Q What was it?

A It was a file containing various notes or

letters about the book "Excalibur."

Q And do you know where the original manuscript

of Excalibur was at the time that this inventory was created?

A No. I don't.

Q Do you know whether it ever came into

Mr. Armstrong's possession?

A Yes.

Q Do you know where it came from?

A No.

Q In any event, it didn't come from anything

in this inventory; is that correct?

A That is correct.

Q Now, were you in the courtroom yesterday

when Mrs. Hubbard testified that Gerald Armstrong stole these

materials from her?

A I don't recall her exact testimony; something

to that effect.

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Q Well, would you agree with me, Mr. Vorm,

that you and Mr. Armstrong went through a fairly elaborate

procedure to list every item that Mr. Armstrong received

possession of?

A Would I agree with you?

Q Would you agree with me that that is what the

two of you did?

A Yes. We went through and checked the materials

off.

Q In fact, you even listed what was missing?

A In some cases, yes.

Q And you cross-referenced to other areas of

the inventory where you found it in other locations; is that

correct?

A In one or two cases, yes.

Q And you gave all of this material to

Mr. Armstrong with your permission; is that correct?

A Well, if you mean I did it willingly or

unwillingly, I --

Q Did he steal the materials from you?

MR. HARRIS: May the witness finish the answer, Your

Honor?

MR. FLYNN: I'll withdraw the last question, Your

Honor.

Q Did he steal the materials from you, Mr. Vorm?

A I am not sure.

THE COURT: Of course, the word "steal" in legal

concept, there are a variety of ways a theft can be committed.

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We are dealing with a lay person here. I am not sure -- I

realize how this came up yesterday, but I think it begs the

issue to say something was stolen from him. It is calling

for a legal conclusion.

MR. FLYNN: I'll withdraw it, Your Honor.

Q You and Mr. Armstrong agreed together and

listed the materials that he could have; is that correct?

A Agreed together about what?

Q About what he could have.

A As we went through, yes.

Q And you received permission from your supervisor

or Mr. Cook who was then the controller to do that; didn't

you?

A That's right.

Q Now, is there anyone -- strike that.

In October of 1981 when you did this was

there anyone in the Church of Scientology of California

of higher ranking authority than the controller?

A Yes.

Q Who?

A A post called ED Int. There was some

particular -- there was a thing called WEC which was a committee.

There were other terminals, other people.

Q Did you ask Mr. Cook whether or not he

received permission from any of these other higher authorities?

A No.

Q Is Mr. Cook still a member of the church?

A I have no idea.

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Q I take it, then, Mr. Vorm, you just followed

the command lines of -- based on the orders or authority

of your immediate senior; is that correct?

A I followed the command lines to put my request,

do you mean?

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Q To give the materials to Mr. Armstrong.

A That is right.

Q Now, you testified that over the years there

was a great deal of confusion as to what materials should

go in what archives; is that correct?

A Yes.

Q And I believe you testified that in 1966

there was a project where everyone, quote, grabbed anything

and everything, end quote, and that is why, quote, there

were personal materials of L. Ron Hubbard and Mary Sue

Hubbard in the trunks.

MR. LITT: That is not the testimony. That misstates

the testimony.

THE COURT: Well, we have all heard his testimony.

Why don't you ask him a direct question?

Q BY MR. FLYNN: was there a project in 1966 to

grab materials at Worldwide and place them in trunks?

A I don't know if they were grabbing things.

What you mean by that particular word, I don't

know. But as far as I know there was a project to pack

materials up and put them in trunks.

Q On direct examination, did you state that

they were grabbing anything and everything?

A I don't recall.

Q And did you give a reason to the court as to

why there were personal materials of L. Ron Hubbard and

Mary Sue Hubbard in these trunks? Do you recall giving a

reason?

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A I don't recall. I think I recall saying that

they did that. I -- I don't know if I gave a reason.

Q Well, is there a reason why personal materials

of L. Ron Hubbard and Mary Sue Hubbard were in the trunks

that you received?

A Probably.

Q What is it?

A Do you want my opinion? I don't have any

real first-hand knowledge of it.

Q Do you have any first-hand knowledge of

anything to do with the project in 1966?

A No.

Q Where did you get your information?

A From talking to various people, writing to

people, trying to find out what had happened at that time.

Q When did the chart that has been marked as

exhibit 14 -- any of that prior to 1980 predicated on your

first-hand knowledge?

A Part of it is, yes.

Q What is?

A The fact that these materials were in the trunks

and I saw them in the trunks; the fact that the tapes were

separate from the trunks; that they had been moved separately

to Los Angeles.

Q What is the sum total of your knowledge about

the project in 1966, Mr. Vorm?

A Sum total?

Q Right.

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A Do you mean personal first-hand knowledge?

Q Any type of knowledge, first-hand, hearsay.

What do you know about the project in 1966?

A Basically what I testified; that there was a

project to collect up materials; that they were going to

bring these materials from England to the ship. There were,

evidently, more than one person on it. one of the persons

was named Wally Burgess.

They -- per the materials and the inventory

that I have, they went through practically every place they

could find that contained materials that pertained to

Mr. and Mrs. Hubbard. They packed them into cardboard boxes;

tied them up with string; made up this inventory; sent them

to the ship.

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Q Now, do you know whose permission they did that

with?

A I don't know exactly, no.

Q When they made the inventory, would you agree

with me that they had to see that there were letters from

Mary Sue Hubbard and L. Ron Hubbard in order to list them as

such in the inventory?

MR. HARRIS: I will stipulate to that, Your Honor.

That is self-evident.

Q BY MR. FLYNN: Didn't they do the same thing in

1966 that Mr. Armstrong was doing in 1980 and 1981, Mr. Vorm?

A I don't think so.

Q Do you have Exhibit 11 in front of you?

A No.

MR. HARRIS: I took it away.

Q BY MR. FLYNN: Would you turn to the last page

of Exhibit 11?

A Yes.

Q In the last sentence in the first paragraph,

the sentence reads, does it not, "These are currently being

gathered up by RH Pers Sec PRO Research Unit"?

A Yes.

Q And that refers to personal materials of a

founder which would be of historical interest; is that

correct?

A That is correct.

Q And that is the basis upon which you gave all of

the materials in the inventory to Mr. Armstrong: isn't that

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A No, that is not correct.

Q Didn't you believe that this letter of Mary

Sue Hubbard dated August 26, 1980 authorized that?

A No.

Q Didn't you testify on cross-examination

several days ago that that was the basis of your belief?

A That it was an authorization?

Q Didn't you testify that you believed that

Mary Sue Hubbard authorized personal materials of the

founder of historical interest to be delivered to the

LRH Per Sec PRO Research Unit?

A By this particular document?

Q The question is, Mr. Vorm, didn't you testify

that based on Exhibit 11, you believed that personal

materials of the founder of historical interest could

rightfully be delivered to Gerald Armstrong?

A Well, I am a little confused per this par-

ticular first page.

Yes, materials were authorized. They were

historical items, and they were approved by Mrs. Hubbard.

Q In October 1981, when you delivered more

materials, did you believe that the August 26, 1980 letter of

Mary Sue Hubbard authorized the types of materials that are

set forth in the inventory that you delivered to Gerald

Armstrong?

A No, I didn't.

Q And you did that solely on the authority of

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A Right.

Q Now, in your chart, you have laid out what

GO WW was at the top; is that correct?

A My understanding of it, yes.

Q And that is as of 1976, Mr. Vorm?

MR. LITT: Is that referring to GO WW Archives or

GO WW itself?

THE WITNESS: It is referring to archives.

Q BY MR. FLYNN: All these questions relate to

archives, Mr. Vorm, if there is any confusion in your mind.

A Okay.

Q When did you visit GO WW Archives?

A In January of '82.

Q And would you describe the physical premises

in which GO WW Archives were located in January of '82?

A It was a building down the road from the main

Saint Hill Manor. It was a cement -- it is a cement floor.

I am not sure what the walls were made of.

Q It was an entire building?

MR. HARRIS: Could the witness be allowed to finish

his answer, Your Honor, once the question is asked? He is

trying to describe the building.

THE COURT: All right. Well, let the witness finish

his answer.

THE WITNESS: It had a locked door on it.

Q BY MR. FLYNN: It was an entire building,

wasn't it, Mr. Vorm?

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A I don't think the entire building was the

entirety of the archives. I think there were other things in

a room or whatever.

Q How many divisions of GO WW Archives were

there in January of 1982, if you know?

MR. HARRIS: "Divisions"? It is ambiguous, Your

Honor. I will object to the question.

THE COURT: Well, overruled.

If he doesn't know, he can state.

THE WITNESS: I didn't know of any divisions.

Q BY MR. FLYNN: Well, do you know whether there

was PR Archives within GO WW in January 1982?

A It looked to me that it was pretty well messed

up, mixed together, as far as what I considered to be

archives material and PR files.

Q And do you know whether there were B-1 Archives

at GO WW Archives in January 1982?

A I didn't get part of your question.

Q Do you know whether there were B-1 Archives at

GO WW Archives in January 1982?

A No.

Q Isn't it a fact that between 1980 and October

1981, when Mr. Armstrong was working on this project, that

there was one entire building at GO WW Archives solely

relating to PR Archives?

A I am not sure. I don't know what that is.

Q You don't have any firsthand knowledge of that?

A That there was an entire building?

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Q That was just PR Archives as part of GO WW

Archives?

A Well, it was my understanding that the PR

Archives were the GO Archives. The GO Archives were

placed under the PR bureau sometime in the mid '70s.

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Q Do you know whether Mr. Armstrong ever visited

those archives before you did?

A I believe he did, yes.

Q Did you find any separate section of GOWW

Archives when you visited there which comprised B-1 Archives?

A No.

Q You testified that in the inventory there was

Xeroxed copies of many of these materials that were in the

trunks; is that correct?

A I don't recall saying that.

Q Well, were there Xerox copies which you called

Xerox originals in the trunks?

A In the trunks?

Q In the trunks that you had possession of in

October, 1981 when you looked at this inventory.

A I am sorry. I am confused.

Q Could you give me the first question?

Q You understand the difference between an

original and a copy?

A That's right.

Q When you opened the trunk and you went through

what has been marked as exhibit 13, did some of the items

in exhibit 13 constitute originals and some constitute

copies?

A Yes.

Q Do you know where the originals were of the

copies that you saw?

A Well, the copies, I recall, were -- there were

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But if I recall, I also had the original in another file

of the ones I remember.

Q Were there any copies in the trunks that you

didn't have possession of the originals?

A I can't say one way or the other.

Q You don't know?

A I don't recall any specific ones, no.

Q Do you know whether there are originals at

GO -- whether there were originals at the GO Worldwide

Archives between October -- strike that -- in October of 1981

where you only had copies?

A I don't know that, no.

Q Now, do you recall testifying in your

prior testimony that you never went to all of the documents

in the LRH Archives collected by Gerald Armstrong?

A I couldn't have said that. I don't recall

specifically exactly what the words were.

Q This past weekend did you go through all of

the documents that were collected by Gerald Armstrong?

A In general, yes.

Q Approximately how many documents did you go

through, Mr. Vorm?

A That is hard for me to say. There were quite

a few.

Q Well, do you recall testifying that there were

approximately 16 to 18 file cabinets?

A I don't recall saying that number, no.

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Q Do you recall how many file cabinets there are

that comprise the documents that were collected by Gerald

Armstrong?

A Well, there is approximately -- there is around

four or five that contain original documents. There are

other files that contain other types of materials like

there was a working file that contained magazines and that

type of thing.

There was a file that contained some letter from

someone else that they had written that weren't even LRH's.

It may have been, but the whole file was like a Xeroxed

copy of that. Some of the file drawers were empty.

Q Do you recall how many boxes of materials

there were?

MR. HARRIS: Originals, or copies, Your Honor?

MR. FLYNN: Originals or copies.

THE WITNESS: Fifteen or twenty.

Q BY MR. FLYNN: Is it your testimony that you

went through all of that material this weekend?

A Yes.

Q Can you give me an estimate as to the number

of pages that you went through?

THE COURT: Well, the witness di say that he went

through these things generally. I don't know what that

meant. Nobody asked him.

But as distinguished from specifically, what

did you mean when you said you went through them generally?

THE WITNESS: Well, what I was looking for was copies

 

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there were a lot of files that just contained originals. And

those particular files, I just went through and made sure

they weren't copies.

In one case it was easy to tell because the

original was a different colored paper or older age, that

type of thing. Some of the boxes, some of the files, I

just went through generally. Whatever the whole file of

magazines, I could see in the files that there were no

copies of the particular documents that I was looking for.

Then I didn't go into the magazines page by

page.

In many cases, boxes contained books and that

type of thing which just, by looking at the books, I could

tell that there weren't files or loose copies of the

documents I was looking for. So that is what I mean by

generally.

THE COURT: We'll take a 15-minute recess.

(Recess.)

 

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THE COURT: All right. In the case on trial let the

record reflect that parties and counsel are all present.

The witness has retaken the stand.

Just state your name again for the record, sir.

You are still under oath.

THE WITNESS: My name is Tom Vorm.

THE COURT: You may continue, counsel.

Q BY MR. FLYNN: Mr. Vorm, when you were going

through Exhibit 13 and checking over the items you were

giving to Mr. Armstrong --

THE COURT: Are you talking about when it happened or

yesterday or today or what?

Q BY MR. FLYNN: At the time that you actually

gave him the materials when Mr. Armstrong was in your

presence checking off the items, did you know that Omar

Garrison was writing a biography on the life of

L. Ron Hubbard?

A I think so, yes.

Q And at that time did you know that Mr. Armstrong

was giving these materials to Omar Garrison?

A Original materials?

Q Any of the materials that are checked, did you

know that he was giving them to Omar Garrison?

A I was not aware that he was giving him original

materials.

Q Did you give him original materials?

A Yes.

Q For what purpose?

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A For use in the biography and for his archives.

Q You gave him original materials for use in the

biography; is that your testimony?

A Uh-huh.

MR. LITT: Objection; his testimony is what he just

said.

THE COURT: There was an "and," also.

Q BY MR. FLYNN: When you gave him the original

materials, you knew that they were being used in the

biography; is that correct?

THE COURT: Or in his archives. That is what he said.

THE WITNESS: Right.

Q BY MR. FLYNN: Well, was it your understanding,

Mr. Vorm, that all of those original materials had to be used

for both of those purposes?

A It was my understanding that copies may be

given to Mr. Garrison.

Q In whose discretion?

A I don't know.

Q In Mr. Armstrong's discretion?

A I don't know. I didn't have any particular

consideration about that.

Q Now, when you knew that the materials were

being given to Mr. Armstrong for use in the biography or for

Mr. Armstrong's archives, you knew that there were at least

two groups of letters from Mary Sue Hubbard to L. Ron Hubbard;

isn't that correct?

A That is true.

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MR. FLYNN: That is all I have, Your Honor.

THE COURT: Redirect.

MR. HARRIS: Just briefly, Your Honor.

 

REDIRECT EXAMINATION

BY MR. HARRIS:

Q Mr. Vorm, again Mr. Flynn mentioned B-1

Archives; is there such a thing, to your knowledge?

A I have never heard that term until it was

mentioned here.

Q And the project which resulted in the trunks

which came into your custody, what was the year of that

project?

A It would have been 1969.

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Q The letters from Mary Sue Hubbard to Mr. Hubbard

and vice versa that Mr. Armstrong asked for, please, state

the conversation at the time that he asked for those and

what you did.

A The particular letters in question, the ones

from 1966 and '67 and also the ones from 1973, I was not

originally going to give them to Mr. Armstrong.

He basically insisted that he needed them;

that the data in those letters was needed as background

material to verify dates, names, places, that type of thing

where Mr. Hubbard/was at a certain time, but that the contents

of the letters would not be used, which was my concern because

I considered them very private.

Q Did you give him the originals or copies?

A Based on his assurance that they would just

be used as background data, I allowed him to make copies

of them and kept the originals for the archives.

MR. HARRIS: No further questions.

 

RECROSS-EXAMINATION

BY MR. FLYNN:

Q Prior to giving those letters to Mr. Armstrong,

did you consult with anyone?

A What do you mean by &qu