Gerry Armstrong--Reporters Transcript of Proceedings 05-17-1984 LASC 420153

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

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

CHURCH OF SCIENTOLOGY OF CALIFORNIA,

Plaintiff,

vs.

GERALD ARMSTRONG,

Defendant.

MARY SUE HUBBARD,

Intervenor.

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No. C 420153

REPORTERS' DAILY TRANSCRIPT

Thursday, May 17, 1984

APPEARANCES:
(See Appearances Page)

VOLUME 14

Pages 2174 - 2344, incl.

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

APPEARANCES:

For the Plaintiff:	PETERSON & BRYNAN BY: JOHN G. PETERSON 8530 Wilshire Boulevard Suite 407 Beverly Hills, California 90211 (213) 659-9965 -and- ROBERT N. HARRIS The Oviatt Building 617 South Olive Street Suite 915 Los Angeles, California 90014 (213) 623-7511
For the Intervenor:	LITT & STORMER BY: BARRETT S. LITT Paramount Plaza 3550 Wilshire Boulevard Suite 1200 Los Angeles, California 90010 (213) 386-4303 -and- BARRETT S. LITT BY: MICHAEL S. MAGNUSON The Oviatt Building 617 South Olive Street Suite 1000 Los Angeles, California 90014 (213) 623-7511
For the Defendant:	CONTOS & BUNCH BY: MICHAEL J. FLYNN - and- JULIA DRAGOJEVIC 5855 Topanga Canyon Boulevard Suite 400 Woodland Hills, California 91367 (213) 716-9400
For Dr. Denk:	OVERLAND, BERKE, WESLEY, GITS, RANDOLPH & LEVANAS BY: ROBERT BERKE 10951 West Pico Boulevard Suite 300 Los Angeles, California 90064 (213) 474-6020

I

INDEX FOR VOLUME 14		Pages 2174-2344, incl.

DAY	DATE		PAGE

Thursday	May 17, 1984	A.M.	2174
		P.M.	2263

WITNESS

DEFENSE:			CROSS

ARMSTRONG, Gerald
(resumed)			2178-L
(resumed)			2269-L

EXHIBITS

PLAINTIFF'S:

FOR
IDENTIFICATION

24 - 3-page document 8-17-80 "LRH Biography Plan"

25 - 3-page letter 6-16-80 from Sheila to Omar

26 - 7-page letter 10-30-80 & 3-page document 11-2-80

27 - 1-page letter 5-25-80 Gerry to Rick

28 - l-page letter 6-15-81 to Laurel from Gerry

29 - 8-page document 12-10-81, staff contract

30 - 2-page letter 12-12-81 Gerry to Barbara

31 - 2-page letter 5-7-80 Gerry to "Dear Sirs"

32 - 2 letters 5-14-80 & 5-7-80, 4 pages

33 - 1-page letter 10-13-80 Gerry to Ted

34 - front & back copy of cancelled check #854

35 - 1-page document 4-27-69 Flag Order 196OR

36 - 5-page handwritten document 2-22-80 & copy
of 2 handwritten letters

2192

2199

2213

2232

2234

2237

2242

2251

2252

2256

2271

2282

2291

2174

LOS ANGELES, CALIFORNIA; THURSDAY, MAY 17, 1984; 9:05 A.M.

-o0o-

THE COURT: All right, in the case on trial let the

record reflect that counsel are present.

GERALD ARMSTRONG,

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

having been previously duly sworn, resumed the stand and

testified further as follows:

THE COURT: The witness has retaken the stand. Please

state your name again for the record, sir. You are still

under oath.

THE WITNESS: Gerald Armstrong.

THE COURT: You may continue, Mr. Litt.

MR. LITT: Thank you, Your Honor.

Your Honor, before we proceed, perhaps we

could finish up the matter of the discovery of the materials

that were going to be given to us.

THE COURT: All right. Mr. Flynn?

2175

MR. FLYNN: Your Honor, the chronology was sent to me.

And it is attorney-client privileged. I am getting it from my

office.

I don't think we have any objection to it anyway,

but I want to read it first.

The notes, we have collected and Mr. Armstrong

has brought them in here this morning. I haven't had a chance

to look them over.

Financial bills, I have got to get from my

office and they are on their way. I'll estimate by tomorrow

morning we'll have it here and we'll have everything sorted

out.

THE COURT: You are getting them from Boston?

MR. FLYNN: Federal Express, Your Honor.

I have piles and piles of files here, Your

Honor.

THE COURT: Miles of piles of files?

MR. LITT: With respect to what Mr. Flynn referred

to as "the notes," can we have an agreement that they will

be reviewed by the end of the lunch hour? I mean --

MR. FLYNN: I would think so.

MR. LITT: We are in cross-examination. If we are

going to make use of them, we have to get them.

MR. FLYNN: I'll get that to you.

THE COURT: He'll try to accommodate you.

MR. LITT: The other matter was there was something

that Mr. Armstrong had written, a story, that we had discussed,

that was on the subject of Scientology. I think it was,

2176

but not using the name which you didn't make reference to,

Mr. Flynn.

I was curious about the status of that.

MR. FLYNN: I have the records of experiences with

the private investigators which we are going to Xerox; the

chronology of positions; that is what he sent to me. And

notes on his state of mind.

Is that what you are referring to?

MR. LITT: No. I thought --

THE COURT: What was it that you had made reference

to in general relating to what Mr. Litt is asking?

2177

THE WITNESS: Your Honor, in May 1982 I started to write

down what was going on in my mind regarding the paranoia and

the steps that I was going through at that time, and that

is what it is.

I gave it some time ago to Miss Dragojevic and

it is in her office somewhere, and I think she hasn't been

able to locate it as yet, but that is the one we are talking

about, Your Honor.

MR. FLYNN: Apparently Miss Dragojevic does have that,

Your Honor. We will seek to locate that.

THE COURT: Was there something else about a book that

you were writing?

THE WITNESS: No, I wasn't writing a book.

MR. LITT: I asked him -- my recollection is I asked

a question whether he had written anything that was possibly

for publication, whether it had been published or not, and

I thought he said that he had.

Is that the thing that he gave to Miss Dragojevic?

THE WITNESS: I mentioned there was a short thing which

I never completed. So, I never completed it. I never

intended it for publication.

MR. LITT: But it was, whether by name or not, dealing

with your view of your experience in Scientology?

THE WITNESS: It was the part that I had written at

that time I recall was only dealing with what was going on

at that time in my mind.

THE COURT: This is the same thing that you were talking

about that Miss Dragojevic has?

2178

THE WITNESS: Yes.

MS. DRAGOJEVIC: I will look for it, Your Honor.

THE COURT: Okay.

MR. LITT: Are we ready to proceed?

THE COURT: Yes, you may.

MR. LITT: Thank you, Your Honor.

CROSS-EXAMINATION (Resumed)

BY MR. LITT:

Q Mr. Armstrong, with respect to, I'm not sure of

the exhibit number, but the last exhibit, the book

"Scientology, A World Religion Emerges in the Space Age,"

I don't recall for sure whether you actually had a chance

to a look at the book before we broke yesterday.

THE COURT: It is exhibit 23.

THE WITNESS: No, I didn't.

Q BY MR. LITT: Can you take a look at that and

just tell me if that is the book that you had reviewed and

had given to your parents and to the chief of police in your

home town?

A This is the book that I gave to them.

Q That is fine. You don't have to read it at the

moment. I just wanted to confirm that that was the book.

Now, Mr. Armstrong, as I understand it, it is

your testimony that you worked directly for L. Ron Hubbard

during all of your years in Scientology; is that right?

A Basically that is correct. He was the --

Q That is all.

2179

A Well, let me explain it more so that you get it

in the proper context.

Q Okay.

A You may be using "directly" in the sense that

there was nobody between him and me. I am using in the sense

that he was the person who could order anyone above me. No

one could order him.

There were times in which there were people

between us, but he was -- he was my senior, yes.

Q Well, perhaps I am confused. I thought your

testimony was more than that he was your senior. I thought

your testimony was that you worked for him and not the church;

isn't that right?

MR. FLYNN: Well --

THE COURT: You are talking about 13 years, counsel.

MR. LITT: Well, I think his testimony was that that

was the case throughout all the 13 years. That is what I

am trying clarify.

THE COURT: Your use of the word "directly" is

ambiguous. That is the problem.

2180

MR. LITT: Well, I'll rephrase the question.

Q Correct me if I am wrong, Mr. Armstrong, but is

it your view that you worked for Mr. Hubbard as opposed to

working for the church throughout all your years in

Scientology?

THE COURT: The Church of California, do you mean, or

an amorphous body of the church?

MR. LITT: Any Church of Scientology.

THE WITNESS: Yes.

Q BY MR. LITT: So as far as you were aware, you

were never employed by any church; correct?

A What I knew regarding the employment was that

there were certain steps necessary in order to cover up the

fact of Mr. Hubbard's control. So I played along with that.

But I knew at all times that I was working for him and that

he controlled and that I -- the same as the Scottish Highland

Club; I really did not work for them, although on paper you

could say I did. A similar situation was what you called

"The Church."

Q So as far as you knew, in reality you never

worked for the church; correct?

A I worked for Mr. Hubbard; correct.

Q Now, let's take your first working experience

after leaving Canada which was the ship; as far as you knew

did the ship have any relationship to the Church of

Scientology of California or any other church?

A The only connection that I knew throughout the

time that I was on board was that we were in the Sea

2181

organization and that all Scientology was controlled from

on board the ship.

I did not know at that point of the subsequent

plan to make the ship a mission of the Church of Scientology

of California. I only learned of that connection in 1982.

Q Okay. So at some subsequent point you learned

information about the connection, but at the time your

testimony is that you didn't know about the connection?

A That is correct.

Q All right. Now, when you petitioned Mr. Hubbard

in January, 1980, can you take a look at exhibit F.

MR. FLYNN: Do you want me to use our copies of the

exhibits, or do you want to get each one out as we go through

it?

THE COURT: We can find it.

Here is exhibit F.

Are there any other exhibits you are going to

refer to so that the clerk can pull them?

MR. LITT: In the next sequence it would be exhibit f,

exhibit Y, exhibit AA.

THE COURT: All right.

Q BY MR. LITT: now, this petition is addressed

to Mr. Hubbard; is that correct?

A Yes.

Q And was it your intention at the time that you

wrote this petition to enter into a personal employment

contract with L. Ron Hubbard?

MR. FLYNN: I'll object, Your Honor.

2182

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

ambiguous. Personal employment contract? I am not sure.

Like when you're in the movies and you have a personal

employment contract or what?

MR. LITT: No.

Was it your intention in writing this petition

to ask that Mr. Hubbard hire you personally to engage in this

activity?

A I never articulated it like that in my mind.

The way I perceived it was that I was requesting

to be able to do certain things which required his agreement.

And he was to do certain things.

I never articulated, as I said, that it was a

personal employment contract, but that I expected to do

those things if my petition was approved.

Q Well, what things did you say in your petition

to him that he was supposed to do other than to approve your

doing what you asked?

A That he was to be the line for verification of

data and approvals.

Q That was his obligation under this agreement that

you entered into with him?

A Yes.

And as he later stated in later communications,

"I did pursue that for awhile and I did send him information;

however he dropped out of sight and we could not then admit

to a line of communications. So it did not continue."

MR. LITT: I move to strike as nonresponsive.

2183

THE COURT: The letter is stricken as nonresponsive.

Q BY MR. LITT: In the second paragraph you say

to Mr. Hubbard, ". . .I feel it warrants a petition to you

because it entails research of your personal time track and

the person doing such would have to have your trust."

I take it from that that there are other things

that you did in your 13 years that didn't require such a

petition to Mr. Hubbard personally; is that right?

A Well, as I stated in here, this is the first time

that I had petitioned for a position, that I petitioned

Mr. Hubbard for anything. I did a number of things from my

first time on board the ship. I drove his cars and I assumed

that I --

MR. LITT: Move to strike as nonresponsive.

THE WITNESS: Well, I didn't petition any other time.

Q BY MR. LITT: That was not my question,

Mr. Armstrong.

A I am sorry.

2184

Q My question is I take it from the way that

you phrased that "I feel it warrants a petition to you,"

that there were a variety of other things that you did that

did not require any petition to Mr. Hubbard in your prior

11 years prior to writing this petition; right?

A That's correct.

Q And they didn't require Mr. Hubbard's trust;

correct?

A No, that is not correct.

Q Well, here, you say, don't you, that "The

person doing this would have to have your trust"?

A As opposed to, for example, someone who did

not already have Hr. Hubbard's trust.

Q Well, did you already not have his trust?

A I did have it.

Q Now on page 3 of the petition you say, "I

am requesting your approval on creating this post"; right?

A Yes.

Q Now isn't it a fact that all you were doing

was writing within Scientology to Mr. Hubbard getting his

approval for something that you wanted to do because it

affected him and that is all this petition was about?

MR. FLYNN: Your Honor, object to "within Scientology."

I think it is ambiguous.

THE COURT: Well, I will sustain the objection.

I assume the letter speaks for itself.

MR. LITT: We are going to his state of mind. He's

testified, Your Honor --

2185

THE COURT: Now, you don't need to argue with me.

If you want to read a clause, that is what he wrote. That

is there in black and white.

Q BY MR. LITT: All right. Now the response

that you got to this petition, Mr. Armstrong, basically

said, "This sounds like an excellent idea. Get with your

senior."

Did you at the time interpret this response

to be a contract between you -- to form a contract between

you and Mr. Hubbard; is that how you viewed it at the time?

A I never used in my mind that word, but I knew

in my mind that he had agreed to the points which I had

laid out.

2186

Q Yes, but you didn't think, did you, that you

had entered into a contract with him at the time?

MR. FLYNN: I am going to object. Calls for a legal

conclusion.

THE COURT: Argumentative; sustain the objection.

Q BY MR. LITT: Exhibit double A, Mr. Armstrong,

this is a document which if I recall your testimony correctly

referred to the fact that -- I am sorry, you were going

to send this document to a whole number of people, correct,

and that is why the two parts at the beginning is blank?

A Yes.

Q And it discusses your new position; correct?

A Yes.

Q Did you send it to a variety of people?

A Yes.

Q Do you recall who you sent it to?

A I... Sue Anderson in Clearwater, Ken

Urquhart in Clearwater, Jim Isaacson in Los Angeles.

Sue Anderson was the LRH pers PRO international.

Ken Urquhart was the former personal communicator. Jim

Isaacson was then pers sec US -- or pers sec PAC, the Pacific

area.

I sent it to, I believe, David Gaiman and

Sheila Gaiman who were the Guardian Worldwide and the Deputy

Guardian for public relations worldwide.

There were a number of other people whose

names and posts I don't recall at this time.

Q First let me ask you a question. Guardian

2187

Worldwide, was the Guardian Worldwide an employee of

Mr. Hubbard's, too, as you understood it?

A When you say "employee of Mr. Hubbard's,"

do you mean was he working as I was working specifically

for Mr. Hubbard and directly working for him personally?

Q Is that what you mean when you say that you

were an employee of Mr. Hubbard?

A Right. I tried to explain this.

Q Well, then, --

A During --

Q Was the Guardian Worldwide an employee of

Mr. Hubbard?

A I would say less than I was.

Q But also the Guardian Worldwide was an employee

of Mr. Hubbard as you understood it?

A The Guardian Worldwide was under Mr. Hubbard,

subject to his orders.

Q And therefore in your mind as you see it,

an employee of Mr. Hubbard but not as direct an employee

as you?

A Right, ultimately, yes.

Q And the Deputy Guardian of Public Relations

Worldwide, he was also an employee?

A Ultimately --

Q She, Mr. Harris says she. I am not sure,

but whatever.

A They considered themselves employed by, I

don't know. They were subject to his orders.

2188

Q But you considered them. We are going to

know how you understand this.

As you understand it, they were employees

of Mr. Hubbard?

A I understand that there was a distinct

differentiation between the degree of employment and the

fact that I was working on his personal matters.

2189

A I was not having anything whatsoever to do with

the organization. I used organizational communication lines

just like Mr. Hubbard did, but I worked only for him and only

on his personal matters.

So there was in my mind a differentiation between

the types of duties that I had when I was in his household

unit and when I was in the personal office of L. Ron Hubbard

as opposed to the types of duties that a Guardian's office

personnel may have who didn't even see Mr. Hubbard.

Q Was everybody who was in the Sea organization

an employee of Mr. Hubbard?

MR. FLYNN: When, Your Honor?

THE COURT: Well, I assume at the time they were in

Sea Orgs.

MR. LITT: Right.

THE WITNESS: Do you mean were they subject to his

orders? Did they work for him? Did they think they were

working for him? Then, yes.

Q BY MR. LITT: So it is your testimony that

everybody that was in the Sea Org thought that they were

employees of Mr. Hubbard, at least as you understood it?

A Again, there are degrees of this. And there are

degrees of the whole fraud.

But those who are closest to Mr. Hubbard,

obviously, were his employees; those who were further away,

I don't know what they thought. They were subject to his

orders; they thought they worked for him.

Q They didn't think they worked for any church,

2190

any of these people, as far as in your experience; right?

A They may have also thought that. But no one was

senior to L. Ron Hubbard within what you call the church.

If Mr. Hubbard was not a part of the church and

they took orders from him, then they worked for L. Ron

Hubbard.

Q Do you have something that says that L. Ron

Hubbard is not connected to the Church of Scientology? Were

you told that L. Ron Hubbard had no connection to the church?

A No. I was --

Q You have answered my question.

Now, at some point, Mr. Armstrong, while you

were holding your archivist position you worked on something

called a "LRH biography plan"; is that right?

A Yes.

Q And this was something to be issued that would

describe this plan and what it was to do; is that right?

A Yes.

Q And it was to be issued as an executive directive

or, at least, that was the plan; that it would be issued as

an executive directive from the central office of LRH?

A Yes.

Q And did you draft the initial version of that

petition -- I'm sorry -- that directive?

A My recollection is that I had some input into

it.

Laurel also was a major contributor to that

executive directive.

2191

Q It was written by you and Laurel jointly?

A Yes.

Q In that directive you set some targets; is that

right?

A Yes.

Q And these were targets as to what the biography

plan was supposed to do; is that right?

A At least part of it, yes.

Q I'm trying to get a copy so I can show it to

Mr. Armstrong. But we seem to be having some difficulty

here.

MR. FLYNN: I was going to mark this and I overlooked

it.

MR. HARRIS: Good. Then it served everybody's purpose.

2192

MR. FLYNN: That is our only copy, too.

MR. LITT: That is what, Mr. Flynn?

MR. FLYNN: Apparently what you gave me in the middle

of the examination.

MR. LITT: Let me just make sure that is a copy of

that. Let me make sure you are getting the right thing.

May this be marked as plaintiff's next in

order?

THE COURT: 24 for identification.

Q BY MR. LITT: Now, Mr. Armstrong, the worthwhile

purpose that is listed on this document which is on the

first page under primary targets to is, "To bring about

greatly increased acceptances of LRH and demand for his products

and create goodwill with all LRH, GO and Scientology

publications"; is that correct?

A Yes.

Q Now that was a target that was primarily aimed

at Scientology; isn't that right?

A This -- the whole document here is -- what

was written and included the various parts of the Scientology

network who would be involved, and all the targets directly

concerned these people in addition to the LRH personnel

who were involved.

The other part of this thing, of the whole

overall project did not have to be included because here

we are issuing targets to people within the whole Scientology

network.

Q Well, the Scientology network, as you say,

2193

that is the various churches and other Scientology organizations;

correct?

A Right.

Q And this document sets up targets for and

activities for a variety of Church of Scientology posts

as to what they should be doing with respect to this biography

claim; correct?

A That is correct.

Q And it makes reference to the -- on page 2

in discussing who has responsibility for what, makes reference

to the LRH pers PRO International. That is Laurel; is that

correct?

A No.

Q That was somebody under Laurel?

A Yes.

Q And that person's job, according to this,

was "to coordinate source missions and PR exploitation to

staff."

Is that Scientology staff, Church of Scientology

staff?

A I think -- did you leave out an earlier part;

"coordinate source missions and PR exploitations to staff"?

Q No, I read that, but I am asking you about

the word "staff."

A Right.

Q That is Church of Scientology staff; right?

A Probably is Church of Scientology.

Q Okay.

2194

A Church of Scientology staff, Scientology Missions

International staff, missions staff, Guardian's office staff,

that sort of thing.

Q And "to reach Scientologists in general";

right?

A That is what comes after "staff," yes.

Q And "new public" meaning new people to be

attracted to Scientology; correct?

A It could mean that. It could mean Mr. Hubbard's

public. Within the LRH pers PRO International Bureau, there

was a pers PRO for staff. In other words, the person who

represented Mr. Hubbard to the staff of Scientology organizations

and they -- that person was in charge of coordinating the

source missions. Source missions were briefings on Mr. Hubbard.

Those were continually given and that would be the action in

the use of the book to staff.

Mr. Hubbard would be PR'd through this new

biography to staff and Scientologists.

Q And it was always considered within Scientology

that whatever promoted Mr. Hubbard's public image, promoted

Scientology; is that correct?

A I guess -- the two were continually linked, so,

yes.

Q Now, this document that you drafted, I don't

notice that it has Mr. Hubbard's name on it at the end; can you

look at the last page?

A Yes.

Q It says "Senior Pers PRO Researcher and Senior

2195

Pers PRO"; that is you and Laurel; right?

A Yes.

Q "Authorized by AVC INT."

A Yes.

Q And AVC INT, what is that?

A AVC INT was -- my recollection is that that was

Julia Watson at that time.

A I am not asking who it is. What does it stand for

first?

A It is Authorizations and Verifications, and I am

not sure what the C is, but in any case they were Authori-

zation and Verification Unit, and were in the personal office

of L. Ron Hubbard, and I believe then it was Julia Watson but I

am not sure.

2196

Q And then the Watch Dog Committee, was that in

the personal office of L. Ron Hubbard?

A Well, the Watch Dog Committee was in the --

Q You didn't answer my question.

Right now I am just asking you if it was in the

personal office of L. Ron Hubbard.

A I need to explain the personal office of L. Ron

Hubbard for you to realize that there are two separate

sections to it. And it is -- I can't answer it with a yes

or no.

Q Are the boards of directors of the Churches of

Scientology in California that is the last at the bottom of

this document, are they part of the personal office of

L. Ron Hubbard?

MR. FLYNN: Does this call for a legal conclusion?

MR. LITT: I'm asking him his understanding.

THE WITNESS: No.

THE COURT: He has answered.

Q BY MR. LITT: So this was a document written

ultimately on behalf of various boards of directors of the

Churches of Scientology; is that what you understood it to

be? Is that correct?

A No.

Q But you and Laurel did write it up this way for

the boards of directors of the Churches of Scientology, did

you?

A When you say "for the boards of directors," it

is likely that we put this in here that we wrote for the

2197

boards of directors for the Churches of Scientology.

If you mean did we write it for the boards, no.

These documents did not go to any boards of directors

anywhere.

We all knew that this was a standard step which

went to the bottom, standard statement to remove --

Q Go on.

A -- the control from Mr. Hubbard. The document

was, in fact, approved by Mary Sue Hubbard because it involved

the Guardian's office and it was approved by WDC, Watch Dog

Committee.

Watch Dog Committee was the body who acted for

Mr. Hubbard and who had been in control of Scientology under

Mr. Hubbard since 1978.

Q Okay. Now, in carrying out your post of

researcher -- that is what it was called at this time, right,

researcher?

A It was called at various times various things,

archivist, researcher. Those were the main two designations.

Q When you sent your February 3rd letter to the

controller, do you recall that? That is already into

evidence.

A Yes.

Q That is addressed -- the controller was a

Scientology post; is that correct?

A She was a Scientologist. She had control of

Scientology organizations. You could call it a Scientology

post.

2198

Q So were all of the people who worked in the

Guardian's office, as you understood it, Mary Sue Hubbard

and L. Ron Hubbard's employees?

A I think that you have to go back to what I said

before. And it depended to the degree they were their

employees, the degree that they worked directly for them.

Ultimately, yes, they were.

Q So the people, all of the people who --

There was a Controller's office; right? Do you

know anything about that?

A Yes.

Q And there were various Controller assistants for

different areas; correct?

A Yes.

Q And those -- there were communicators and

secretaries and the Controller assistants had aides; correct?

A Yes.

Q And all of these people were the -- as you

understood it, were the personal employees of L. Ron and

Mary Sue Hubbard or just Mary Sue Hubbard?

A Let me explain. Ultimately they were the

employees of L. Ron Hubbard.

The further you got away from L. Ron Hubbard,

the less they became the personal employees; how far those

people were removed from that, I don't know; how far they

were in their own minds, I don't know.

Q Now, in your capacity as a researcher did you

have contact with a variety of people who were, as you

2199

understood it, Church of Scientology staff as opposed to what

you say you were?

A I had contact with Scientologists on all levels

in many, many organizations.

Q Okay. Did you have any contact with the

Guardian's office at Worldwide in connection with the

biography?

A Yes.

Q And showing you --

May this be marked next in order, Your Honor?

THE COURT: All right. 25.

MR. FLYNN: Your Honor, for the record, we had requested

the production of all correspondence with Omar Garrison.

This was never produced.

MR. LITT: This was not between Mr. Armstrong and Omar

Garrison.

THE COURT: Let's go forward.

2200

Q BY MR. LITT: Mr. Armstrong, do you recognize

this document?

A It could be one that I received from -- a copy

of it, at least, I received from Sheila Gaiman. If this is

not it, I received something which contained similar

information.

Q Okay. Now, on page 2 -- this is a letter

between Sheila Gaiman -- what post did she hold?

A I believe she was a deputy guardian or at least

the temporary deputy guardian for PR Worldwide at that time

in the Guardian's office.

Q And this is a letter between -- well, from her

to Mr. Garrison in reference to he biography; correct?

A Yes.

Q Now, Ms. Gaiman was -- she had a Church of

Scientology of California position at that time; right?

A I didn't think of her in terms of Church of

Scientology of California.

Q Well, you thought of her in terms of Church of

Scientology Worldwide?

A I thought of her in terms of the Guardian's

office Worldwide.

Q Well, you thought that the Guardian's office was

a part of one church or another; didn't you?

A I thought it was part of the overall network of

Scientology. Some years later I learned that they were a

part corporately of the Church of Scientology of California,

but then I had no idea.

2201

Q In April 1980 you had no idea?

A Right.

Q June 1980.

Now, on page 2 in discussing with Mr. Garrison

how he will receive research materials she says, "There is a

particular research terminal assigned to this biography."

That is you; right?

A Okay.

Q Is that right? Was that your understanding of

what she meant?

A Yes, uh-huh.

Q And, in fact, she said that she would arrange

for Garrison to meet you; isn't that right, on page 3?

A Yes.

Q So your first meeting with Mr. Garrison was

arranged and coordinated by Sheila Gaiman, Deputy Guardian

of Public Relations Worldwide; correct? That is how it came

about?

A Well, I don't quite understand what you mean by

that, that overall picture.

Sheila never made any arrangements for me.

Sheila knew Garrison. Garrison was going to be there at a

certain time.

I made all the arrangements at my end. I sent a

communication to Mary Sue and had the CMO on SU approve all

the money. Sheila never made those arrangements.

Q Sheila was the one who was dealing at that point

with Mr. Garrison and she arranged -- she was the one who

2202

said to Mr. Garrison, "I will arrange for you to meet with

this research terminal"; right?

A I guess she wrote it in the letter.

Q All right, that's all.

Now, let's take a look at the agreement,

exhibit G.

MR. FLYNN: Was that marked, Your Honor?

THE COURT: Yes, 25.

MR. LITT: This is your exhibit -- that one is

marked 25.

Q Now, Mr. Armstrong, you recognize this document.

This is an agreement between Mr. Garrison and HUBS-DK;

correct?

A Yes.

Q And at paragraph 10-B, take a look at that.

That is on page 3.

A Okay.

Q It says, "The publisher shall use its best

efforts to provide author with an office, an office

assistant and/or research assistant" et cetera; correct?

A Yes.

Q Were you as you understood it the research

assistant to be provided by the publisher?

THE COURT: Well, are you asking him now or are you

asking if he knew at that time or if he had any knowledge

about what this contract was at that time?

Q BY MR. LITT: Well, you saw this contract at the

time; didn't you?

2203

A Yes. Q And you were the archivist at the time; right?

A Yes.

Q And did you review the contract at the time?

A I believe that I saw it at the time. I did not

at that point have a copy and I did not read it over in

depth.

Q Well, was there ever any in the year 1980 other

research assistant for Mr. Garrison provided to Mr. Garrison

in connection with the biography project other than you?

A No.

Q All right, and was it your understanding that

this contract which had been entered into called for the

fact that Mr. Garrison would be given research help and you

were that research help?

A Well, what my understanding was was that there

was a second contract and the second contract was between

PDK and Mr. Hubbard.

2204

MR. LITT: I object and move to strike. This is

completely nonresponsive.

Q I'm asking you about your understanding.

THE COURT: He is explaining what his understanding

is.

Let's have the question read back.

(The question was read.)

THE COURT: Well, it is a compound question. I guess

that is the problem; it is a compound question.

Q BY MR. LITT: Was it your understanding that

under this contract Mr. Garrison was to get an assistant in

researching the biography?

MR. FLYNN: This contract, or the overall contractual

picture?

THE COURT: Exhibit G.

Did you have such an understanding at the time?

THE WITNESS: Your Honor, the understanding that I had

was that this was a part of it and that there's another

contract and another set of agreements between PDK and

Mr. Hubbard which include the provision of the researcher

which I was. And that this referred to that. But that there

was going to be a second agreement; that is what I understood

from Laurel and Mr. Wertheimer at that time.

Q BY MR. LITT: You understood there were some

proposals for a second agreement; is that correct?

A I understood --

Q You didn't think that there had been any signed

2205

second agreement when you saw this agreement, did you?

A Well, I knew there couldn't be because we

couldn't admit to any communications with Mr. Hubbard. So

I had been the researcher even prior to this contract. I

had been performing the same function.

In fact, prior to the signing of the contract

I had already prepared an office for Mr. Garrison.

Q I know, I'm just -- really, I'm just --

Did you understand that the contract, this

contract, called for providing research help to Mr. Garrison?

A Yes.

MR. FLYNN: Your Honor, it has also been our contention

that this contract," to use Mr. Litt's language, includes

within it the contractual proposals that are set forth in

the Wertheimer letter and that Mr. Hubbard was the most

essential party to that contract.

THE COURT: It is obvious that this person had no

direct communications with PDK or whatever. We all know

contracts which say things that are not necessarily accurate.

The document speaks for itself, for whatever it

is worth.

Q BY MR. LITT: And you were to -- and you in fact

were the researcher who assisted Mr. Garrison; correct?

A Up to a particular point at which time there was

another person who became involved.

Q When was that?

A In the fall of 1981.

Q Okay. So up to the fall of 1981 you were the

2206

person; correct?

A Yes.

Q Now, did --

Could the witness be handed exhibits 7 and 8?

THE COURT: Very well.

Q BY MR. LITT: Now, this document, exhibit No. 7,

Mr. Armstrong, at page 2 it discusses the fact that CSC is

willing to provide certain things to Mr. Garrison including

an office space for him to work in the Cedars Complex;

complete access to archives and records of Mr. Hubbard and

an assistant to assist Mr. Garrison; do you see those

references?

A Okay.

Q Now, all of those things were done; is that

correct?

Mr. Garrison was provided an office in the Cedars

Complex?

A Yes, up to a certain point he had an office.

After a particular point, he no longer had one.

Q And a variety of archival materials and records

were provided to Mr. Garrison?

A No. This isn't quite true.

The CSC archives and records on LRH were not

provided and some were provided sometime later.

Mr. Vaughn Young was able to obtain access to

those, but the CSC archives were never made available. I

did not have access to them; Mr. Garrison did not have access

to them. And we were able to obtain a small bit of

2207

information which included the FOI documents mentioned here

from Vaughn Young.

Q We'll come back to more discussion of that.

An assistant, you, was provided to Mr. Garrison?

A It mentions an assistant. I never received or

was told about this communication or plan.

I knew about the other information which was that

Mr. Hubbard was to provide research help.

Q All right. But, again, there was no other

assistant provided other than you; is that right?

A Mr. Young was provided in the fall of 1981.

Q All right. And this board minute, which is

exhibit No. 8, which --

A You left off No. 4.

Q That's all right. I'm not asking you any

questions about No. 4 at the moment. It is not relevant to

what I'm asking about.

A Okay.

Q And this board minute, adopting it, you never

saw that or, did you see that?

A I never saw it at the time. I saw it sometime

later.

It was produced in a deposition by the

organization.

Q Now, let's turn to exhibit J.

Do you recognize this document?

A Yes.

Q This is this October 15, 1980 communication

2208

addressed to Controller that you have testified about

before?

A Yes.

Q And the copy, again, that you had, you obtained

that from Mr. Garrison?

A I am not sure. My recollection is that it was

produced by the organization at a deposition, but --

Q We have checked our records and that appears not

to be the case.

Does that help to refresh your recollection?

A Okay. If that is not the case, then, it was

amongst the materials given to me by Mr. Garrison.

2209

Q All right, and when would you have given this to

Mr. Garrison at the time?

A Sometime in -- probably in 1981, later in the

year 1981.

Q At some point in 1981 did you copy up a whole

set of your files that were International files and give

them to Mr. Garrison?

A No, just when the subject -- we were trying to

sort out the biography contract and the problems that we

were having because we ran into a real bug, you'd call it,

when we found out that PUBS-DK, with whom I was in

communication, did not know of the existence of the

contract, and I couldn't find anyone who knew anything about

it who was on what you call "on-line" at that time because

the people had been -- the hierarchy of the Guardian's

office had been removed by the CMO in the summer of 1981,

and we ran into a great deal of problem.

So, in trying to sort this out, in trying to

assist Mr. Garrison to prepare the contract and even to get

him the money which was owed him at that time, $2,500, I

gave him a lot of materials so that we could understand what

had gone on through that period.

Q All right, and this document is the document

that you --

A That which?

Q This is the one that you say that you sent on

October 15, 1980; is that correct?

A Yes.

2210

Q And you said you got an answer but you don't

have the answer; was that your testimony?

A Yes. My recollection is that I got an answer

and I don't believe it was very long. It was just an

acknowledgement of it. It certainly would have registered

in my mind if I had not gotten an answer. I would have

written again and asked her again if she had received it

because it was such a massive letter and contained so many

things. I am very positive that I got an answer.

Q Now in this document on page 4 it says, you are

discussing the fact that you have been traveling around,

finding various materials and actually you start the

discussion on page 3.

You say, "Situation A. It appears the various

churches around are either doing nothing about it or are

giving away their valuable artifacts."

Do you see that on page 3?

A Yes.

Q And then you have a long discussion that goes

through page 4. Aren't these proposals that you are making

about the church and what the churches should do with

respect to these materials?

A Yes.

Q And you are making a variety of recommendations

about how the various church organizations should handle

these materials; correct?

A Okay.

Q And you are making them to Mrs. Hubbard who was

2211

the controller, but you are making them actually to the

controller post; right? It wasn't a personal communication

to Mary Sue; right? It was a communication to her post?

A Well, I think you will find that part of the

communication could only have been made to her. If it had

been to someone else and not her on the post, I think I

wouldn't have written what I did, especially in the

beginning.

Q Okay, but in this section you would have written

it; wouldn't you?

A Perhaps. I'd have to really think of that one.

While I was traveling around doing the biography

project, I came across other situations which I alerted

people within the organization about, and this was part of

it. There is no way that I could from where I was take care

of all the situations in the organization, but at least at

that point had become aware of the existence of some of this

early material which I considered then had historical value,

and I tried to inform the proper people of that.

Additionally, I picked up materials which I did

not need for the biography, but which in liaison with Tom

Vorm, who had possession of the technical or policy

materials and the tapes which were technical materials, I

picked those up.

It was because I was there. It wasn't because

it was my job.

Q In any event, you were writing about

various churches should do; correct?

2212

A Yes.

Q And let me just go back to clear up one thing.

Do you have any idea when you would have

received a response to this communication? I take it it

would have been somewhat close to the date?

A It would have been, yes, shortly after that.

Q Let me show you a document --

Your Honor, I'm going to use the original on

this and then ask to substitute.

I have a document here which seems to be an

identical copy of this exhibit except that it is dated

October 31. It has white-out on it. It has some other

white-out on it.

Do you recognize that document, Mr. Armstrong?

A Yes.

2213

Q It is -- comparing it --

Could this be marked next in order, Your Honor?

THE COURT: 26 for identification.

Q BY MR. LITT: Comparing it to exhibit 26 -- I'm

sorry -- comparing exhibit 26 to exhibit J, there is white out

at the top of the first paragraph; is that correct?

A Yes.

Q And there is white out next to the date after

the 15; is that correct?

A Yes.

Q And could you look at the back? Can you see a

15?

A Yes.

Q On the back?

A Yes.

Q Mr. Armstrong, did you do this white out?

A Probably did.

Q Okay.

MR. FLYNN: Your Honor, for the record, this was never

produced either. And it was requested; nor was it listed

on the exhibit list.

MR. LITT: Exhibits in examination don't have to be

listed, Mr. Flynn.

THE COURT: What was the comment?

MR. LITT: Well, Mr. Armstrong is still examining it.

THE COURT: No; your comment that something doesn't

have to be listed.

MR. LITT: Exhibits that may have to come up in the

2214

cross-examination of defense, we don't know what we may have

to use until the testimony is in.

THE COURT: What is this document anyway?

MR. LITT: This is a document that was an identical

copy that was recently located in the files after

Mr. Armstrong had testified about this October 15th letter.

That is an identical copy of that, apparently, an original

that was still in his file with a changed -- different date

than this copy. And it appears that it remained in his

file.

THE COURT: Well, let's go ahead and see what happens.

Q BY MR. LITT: You made this change, is that

correct, Mr. Armstrong?

A My recollection that this was sent to Laurel;

whatever date. And Laurel requested that I put these

materials in.

The reason -- this is something that I often

did was -- I did not have a correcting typewriter. And my

copies were often very messy like this. So I wouldn't have

sent --

Down here you can see by the back thing here,

which in fact it is a paste-up. And I would not have sent

Mrs. Hubbard this sort of a paste-up. I would have Xeroxed

this and sent her a good Xeroxed copy.

Q So you would have sent this to her --

Is it now your testimony that it is the

October 31 version that you sent to her?

A Now I am more positive than ever that I did get

2215

a response and that this, at the beginning -- I sent this;

Laurel sent it back to me.

THE COURT: You say "I sent this"; refer to the letter

or number, please.

Q BY MR. LITT: This is No. 26 --

THE COURT: He also has an exhibit J?

MR. LITT: Yes.

THE WITNESS: Okay. This is routed --

THE COURT: Not "this."

THE WITNESS: -- Exhibit J is routed by the Senior Pers

PRO.

Laurel asked me to change it and say why I was

sending it. Hence, I added these -- I changed the

introduction at Laurel's request.

This doesn't have --

Q BY MR. LITT: "This" being what?

A Exhibit J does not have on the back of it this

proposed archives issue which I was proposing. And by the

state of it, I would not have sent this this way because it

was a paste-up. I would have made a good Xerox and sent it

in in that manner.

Q So it is now your testimony that this October 15th

document which is exhibit J was sent on October 15th to Laurel

who sent it back to you and said, "Redo it"?

A That is correct. That is my best recollection.

I am very positive.

Q And you took the original of that, correct?

Because this is, presumably, the original, "this" being

2216

exhibit 26, since it has the whited out 15 that you can see

on the back and is now dated 31 October?

A Yes.

2217

Q You took the original and you changed it after

Laurel returned it to you?

A Yes.

Q Correct?

A Yes, and then I Xeroxed that and sent her the

Xerox which would be nice and neat and not a whited-out

mess.

Q And it is now your testimony that it is to the

October 31, document that you got a response?

A Yes.

MR. FLYNN: Your Honor, if there are any more

documents that haven't been produced, you are dealing with

years of documentation in this organization and obviously

transfer of documents and command lines in the organization,

if there are any such documents that Mr. Litt intends to use

in this examination, I think he should produce them.

MR. LITT: Your Honor, with respect to production,

there was a lot of discovery back and forth in this case.

There were things produced. There were things that the

church took the position were not relevant to the case if

there were not motions to compel made and rulings that they

should be produced.

I mean you can't say as an abstract, "Produce."

There is no order of this court with respect to discovery

what was not obeyed. I was not involved in most of that

because I was not representing the church at that time, and

we have tried to find what we can after hearing

Mr. Armstrong's testimony. I don't see that there is

2218

anything the least bit wrong with what is going on.

We have received a lot of things that we had no

idea that Mr. Armstrong had that were not on the exhibit

list and that we had no idea of.

THE COURT: Okay. Well, the court has tried to permit

both parties to have the benefit of in-trial discovery

production, so you can produce whatever else you have got,

Mr. Litt and Mr. Harris, too, of what you are going to use

and that is the order of the court.

MR. LITT: I just want to understand the order.

Is this anything that we are presently

planning --

THE COURT: Yes, in the cross-examination of this

witness.

MR. LITT: Okay. We can get that together at the

break.

THE COURT: All right. We will take a break now for

15 minutes.

(Recess.)

2219

THE COURT: We are back in session.

MR. HARRIS: Could I address the court before the

witness resumes the stand, Your Honor?

THE COURT: Certainly.

MR. HARRIS: As you know from my belated appearance,

I don't have a great familiarity with the files; however,

I did check the discovery requests briefly.

On September 8, 1983, at least the date that is

stamped at the top the defendant and cross-complainant

request for production of documents item No. 20 -- I don't

know if I want to read it all, but, essentially, it asks

for originals and copies of any and all correspondence

concerning the biography project and/or the L. Ron Hubbard

archives to or from any of the following individuals, and

then there is a whole list of people, apparently:

Then counsel objected which is Mr. Peterson on

a date, 8 November, 1983 to No. 20:

"Object. This request is overly

broad, burdensome, and to a great extent

irrelevant; however, plaintiff has located

and is prepared to provide for inspection

certain materials which are relevant to the

suit and would constitute correspondence of

the nature requested."

2220

There was no inspection by the other side.

However, we will have Mr. Peterson here at 1:30

if the court desires.

THE COURT: No. All I want to do is see that they get

these exhibits so they can prepare. We don't have to spend

a lot of time spinning our wheels and wasting time so we can

go forward.

I have been here a couple of weeks already. As

I indicated yesterday, I am not going to spend the rest of

my life on this case. In fact, I don't expect to spend that

much more time although you are going to have an adequate

time to cross-examine, and I don't know how many more

witnesses the defense will present. But the point is I

don't see any reason to get bogged down in things which are

going to come out anyway, and that is the purpose of the

trial is to determine, try to find out what the truth was or

is, and not a game, and that is my approach to this.

MR. HARRIS: That is mine as well, Your Honor.

We will do all that we can.

THE COURT: Okay, fine. Let's continue with

Mr. Armstrong.

Please retake the stand, sir.

MR. LITT: While Mr. Armstrong is taking the stand, we

have provided a set of documents to Mr. Flynn. I am not yet

certain because I didn't have a chance to go through

everything that it is everything, but we will at the lunch

break try to continue a review and bring additional

materials.

2221

THE COURT: Fine. I appreciate that, Mr. Litt.

Please state your name again for the record,

sir. You are still under oath.

THE WITNESS: Gerald Armstrong.

Q BY MR. LITT: Now, Mr. Armstrong, when you were

in Scientology, was it considered a matter of prestige to be

connected to Mr. Hubbard?

A I think that it probably depended on the

individual, the degree, but I think that it was an asset

being connected with him, yes.

Q In fact, people would, if anything, tend to use

his name in a variety of contexts as sort of authority

because his name carried a great deal of weight; correct?

A If you mean would they say that they had orders

from him when they didn't or he had told them something when

he hadn't, I think not because to fake an order was a very

serious offense in Scientology and to later be found out by

Mr. Hubbard would be deemed to be a serious offense.

I can't recall someone faking such a thing other

than pursuant to Mr. Hubbard's orders.

Q I am not asking you about faking a thing. All I

am asking you is people would, where the conditions allowed,

use his name because if it was associated with Mr. Hubbard,

it would get done faster and people would sort of snap to,

so to speak; right?

THE COURT: If you know.

THE WITNESS: Right. By association, where I was in

the organization --

2222

Q BY MR. LITT: I am not asking about you in

particular. I am just asking about your general impression

overall.

A Right. I am trying to explain that.

By association was not enough. An order from

Mr. Hubbard was sufficient to get something done on a very

speedy basis, but not just by saying that you were

associated in some way. I hope that answers it.

2223

Q Well, you got a lot of things done because of

the post that you held that dealt with Mr. Hubbard's archives;

right?

A Well, I was able to do what I did throughout

those two years because of the approval of Mr. Hubbard of

my petition.

Q Well, how many people in the organization had

seen to that? Did all of the people that you have sent all

of these communications to, had they seen that, or did they

just know that you were a researcher collecting LRH materials

and that was important? Wasn't that what you understood

what their knowledge pretty much was?

A Each person who was in a position of power that

I had to deal with knew that Mr. Hubbard had approved the

position.

Q I'm not talking about just positions of power.

THE COURT: The whole thing is a compound question the

way you have phrased it. You can get any kind of an answer.

MR. LITT: I'll rephrase it, Your Honor.

Q You had communications throughout the organization;

correct?

A Yes.

Q At many different levels where you needed to get

something, needed help with something in the course of these

two years; right?

A Yes.

Q And many of these people, as far as you knew,

hadn't been sent a copy of your petition or directly informed

2224

of your petition; right?

A I --

MR. FLYNN: Again, Your Honor, it is compound, but I

hate to keep making needless objections.

THE COURT: Well, if the witness can answer it, he may

do so.

THE WITNESS: I'm trying to think of any particular

person who would be in a position like that with whom I had

communications who I would not have had to tell that sort

of thing.

When I was dealing with, for example, the people

who assisted in the setting up of the office for Mr. Garrison,

there I liaised with organization people doing -- who

installed the carpet and painted the walls, that sort of

thing. And I was able to do that simply because of the

altitude that I had as a result of working for Mr. Hubbard.

I never had to explain that he had approved my

petition.

Q Okay. Fine. Now, in doing your work did you

get a car at some point?

A I did get a car at some point.

Q When you say in doing my work, it is not quite

that way. I was able to obtain the car not directly in

connection with the biography project, but as a result of

Mr. Hubbard's order regarding the Nobel Prize project; that

unlimited Scientology funds were to be allocated for that

project.

It was on the basis of that order from Mr. Hubbard

2225

that I submitted a proposal for the purchase of the car which

was also used on the biography project which was used by

MCCS.

But the initial order which paved the way for

the purchase of the car was the unlimited funds allocated

to get the Nobel Prize. I was also working on that project

at the time. So that is how I got the car.

Q Now, the car that you used in connection with

the biography work, had that been paid for by the Church

of Scientology of California as far as you knew?

A I don't know. It came from -- the way I

understood the finances worked, was the special unit, which

then was in Gilman Hot Springs, received a lump sum per month

from what it called SOR, Sea Org Reserves. And it was from

those Sea Org Reserves monies that I obtained the car.

Q And the Sea org Reserves monies, did you know

what they were? Did you know whether they were Church of

Scientology of California, or Mr. Hubbard's, or something

else's?

A My understanding was Sea Org Reserves contained

the monies from all Scientology sources internationally

except for those that were designated RRF or except for those

that were maintained in the local organizations' accounts.

So they had operating expenses. There was --

this was GO accounts in addition to Sea Org Reserves. Sea

Org Reserves was the biggest.

Q Did you think Sea Org Reserves was Mr. Hubbard's

personal money?

2226

A Well --

MR. FLYNN: At what point in time, Your Honor?

MR. LITT: During the archives period.

THE COURT: What is meant by "personal money"?

MR. LITT: Did he think it was Mr. Hubbard's money as

opposed to money that belonged to one or another church.

THE WITNESS: My understanding was that Mr. Hubbard

could order whatever he wanted done with that money; whether

or not that made it his personal money, that is really hard

to say.

I think that he acted as if it was his personal

money. It probably wasn't his personal money.

2227

Q And the funds that came to set up your archives

project you knew came from Sea Org Reserves?

A Yes. Well, let me say that was my

understanding. Sea Org Reserves simply sent an amount of

money monthly to the Special Unit which was controlled by

WDC, Watchdog Committee, which was the committee under

Mr. Hubbard who controlled Scientology internationally.

The disbursements at the outset of the biography

project simply came to me from the treasury in what was

called the HKU, the Housekeeping Unit, and the person who

disbursed them was Gary Press, and Gary -- and the

Housekeeping Unit was the service unit attached to the CMO

International CMO International, then the smaller body

within CMO International, WDC, was the group which under

Hubbard controlled Scientology.

Later on I was asked to shift the --

Q I am going to -- you are not answering my

question, Mr. Armstrong.

A Well, you asked me about Sea Org Reserve.

Q There is no question pending.

A I don't know if I completely answered your

question, Mr. Litt.

Q That's all right.

Now, did you know or did you believe at the time

that Sea Org Reserves belonged to the Church of Scientology

of California?

MR. FLYNN: Your Honor, the last question was similar

to this one with regard to what the witness believed and he

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