Gerry Armstrong--Deposition Lynn R. Farny Volume II 07-12-1994

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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF MARIN

---o0o---

CHURCH OF SCIENTOLOGY
INTERNATIONAL, a California
not-for-profit religious
corporation,

Plaintiff,

vs.

GERALD ARMSTRONG; MICHALE
WALTON; THE GERALD ARMSTRONG
CORPORATION, a California for
profit corporation; DOES 1 through 100, inclusive,

Defendants.

AND RELATED CROSS-ACTION.

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NO. 157-680

DEPOSITION OF:

LYNN R. FARNY

Tuesday, July 12, 1994

VOLUME II

Reported by:
PENNY L. GILMORE CSR NO. 4724

PENNY L. GILMORE & ASSOCIATES
DEPOSITION REPORTERS
P.O. BOX 862
ROSS, CALIFORNIA 94957
(415) 457-7899

I N D E X

Witness: LYNN R. FARNY, Volume II
Examination by:		PAGE
Mr. Greene		138
E X H I B I T S
DEFENDANT'S		PAGE
2	Notice of Taking Deposition	137
3	Revised Bylaws of Church of Scientology International	139
4	HCO Policy Letter of 5-1-65	201
5	HCO Policy Letter of 2-9-79	202
6	HCO Policy Letter of February 1979	208
7	HCO Policy Letter of 3-5-65	210
8	HCO Policy Letter of 8-9-72	213
9	HCO Policy Letter of 11-25-70	224
10	Document entitled Suppressive Person Declare [Revised Version 04-22-1982]	240
11	Document entitled Introduction to Scientology Ethics	242
12	Document entitled The Organization Executive Course	244
13	Document entitled Suppressive Persons and Suppressive Groups List	249

134

BE IT REMEMBERED that pursuant to Notice and on

Tuesday, the 12th day of July 1994, commencing at the hour

of 10:15 o'clock a.m. thereof, at the conference room of

900 Larkspur Landing Circle, Larkspur, California, before

me, PENNY L. GILMORE, a Certified Shorthand Reporter

licensed by the State of California, personally appeared:

LYNN R. FARNY

a witness herein, who, being by me previously duly sworn,

was thereupon examined and interrogated as is hereinafter

set forth.

---o0o---

LAURIE J. BARTILSON, Esq., representing the Law

Offices of Bowles & Moxon, 6255 Sunset Boulevard, Suite

2000, Hollywood, California 90028, appeared as counsel on

behalf of Plaintiff.

MICHAEL L. WALTON, Esq., representing the Law

Offices of Michael L. Walton, 700 Larkspur Landing Circle,

Suite 120, Larkspur, California 94939, a defendant,

appeared in pro per.

FORD GREENE, Esq., representing the Law Offices

of Ford Greene, 711 Sir Francis Drake Boulevard, San

Anselmo, California 94960, appeared as counsel on behalf

of Defendant Gerald Armstrong.

135

WILLIAM R. BENZ, Esq., 900 Larkspur Landing

Circle, Suite 185, Larkspur, California 94939, appeared as

the referee in said action.

ALSO PRESENT: Gerald Armstrong, Defendant.

---o0o---

136

(Whereupon Defendant's Exhibit 2
was marked for identification.)

MR. BENZ: On the record.

When we adjourned yesterday I think there was a

request for a ruling regarding whether or not we would

allow questions going into the general area of the

motivation of the plaintiff in bringing the lawsuit, if

that's the proper word. In that area, anyway.

I have reviewed the Appellate Court decision and

the Complaint and the Cross-complaint and in my opinion the

motivation in bringing the lawsuit itself is probably

governed by the laws of malicious prosecution which

requires, and, therefore, would not normally be

admissible. Nonetheless the Cross-complaint does allege

and it has allowed in abusive process and basic

ingredients of abusive process is ulterior motive.

In addition to that, there is the affirmative

defense of unclean hands, which is a very broad

affirmative defense, and, therefore, because it may lead

to the discovery of admissible evidence I am ruling that

defense is entitled to go into the motive.

MS. BARTILSON: Can I ask one question for

clarification? I guess I had considered that the question

before Your Honor was whether, the more narrow question,

whether Mr. Greene may inquire into the personal religious

137

practices of the witness. Is it your ruling here today

that he may do so, because that was the exact question

that was before the witness when we did our little

divergence into argument.

MR. BENZ: I had thought I ruled on the personal

religious practices earlier, and subject to changing my

mind if there is a brief on that. So I am not ruling that

the personal religious practices are involved except as it

may go, since I don't know what the religious practices

are, to the motive of the plaintiff would be admissible

but the witness's personal religious practices are not.

By admissible, I mean you may inquire into. There is

certainly no ruling on evidence.

MR. GREENE: Okay, then we will proceed.

---o0o---

EXAMINATION RESUMED BY:

MR. GREENE: Q. Good morning, Mr. Farny.

A. Good morning, Mr. Greene.

Q. Is there any reason why you are unable to

proceed and give your best testimony today?

A. No.

Q. I've showed you what's been marked as Defendant's

number two, which is a Notice of Taking Deposition.

Actually it's plural, depositions, a three-

page document. Have you seen that document before?

138

A. Yes, I have.

Q. Is it pursuant to that document that you

appeared here yesterday and continue to be here today?

A. Yes, it is.

MR. GREENE: I would like to mark as Defendant's

three the Revised Bylaws of the Church of Scientology

International, which have been Bates-stamped 200012

through 200043 and ask the Court Reporter to please mark

it.

(Whereupon Defendant's Exhibit 3
was marked for identification.)

MR. GREENE: Back on the record.

Q. Mr. Farny, I've shown you what's been marked as

Defendant's Exhibit three, which is a copy of the Revised

Bylaws of CSI. Do you recognize that document?

A. Yes.

Q. Turning to the last page, 43, that's your

signature there, isn't it?

A. Yes, it is.

Q. As the bylaws of CSI presently exist, isn't it

correct that Exhibit three is a true and correct copy

thereof?

A. Including the addendum on the last page, yes.

Q. So as things currently exist with respect to CSI

there aren't any other bylaws which are in effect aside

139

from Exhibit three; is that an accurate statement?

A. Yes.

Q. Turning your attention to -- I'm going to use

the last two numbers of the Bates stamp mark instead of

referring to the different pages of this exhibit.

On page 12 where it says, "The Church is the

ecclesiastical Mother Church of the many churches within

and without the United States which have been and will be

organized for the purposes of Scientology..." and the

sentence goes on, "...all bound together as elements of

one international and hierarchical church by voluntary and

self-determined agreement and upon adherence to the

following." Then there's a list of things. What I want

to address you to is the term "ecclesiastical Mother

Church." The term -- First of all, let me lay a little

foundation. You are familiar, are you not, with these

bylaws?

A. Yes.

Q. You are familiar with the bylaws in your

capacity as secretary of CSI; is that right?

A. That's right.

Q. You have been secretary of CSI since 1988?

A. Also correct.

Q. Did you act in any official capacity within CSI

prior to 1988?

140

A. Certainly.

Q. What was that?

A. I had an ecclesiastical position; I didn't have

any corporate position. I worked in the legal department

since 1984.

Q. When you refer to your working in the legal

department from '84 to '88 as holding an ecclesiastical

position, would you define for me what you mean by your use

of the term "ecclesiastic"?

A. A position that derives from -- sorry, that

derives its authority, if you will, from the ecclesiastic

organization of the Church as opposed to the corporate

organization of the Church. The corporation as a

corporation is organized with directors and officers;

ecclesiastically we're organized otherwise.

Q. So the ecclesiastical organization is separate

and distinct and apart from the corporate organization?

A. Except to the degree --

Q. First if you can agree give me a yes-or-no

answer?

MS. BARTILSON: I'm going to object and ask you to

let him finish answering the question before you interrupt.

I think that was the ground rules yesterday.

THE WITNESS: Except to the degree of this --

and the answer is not going to offend you -- the people

141

that occupy the corporate positions occupy similar

ecclesiastic positions, so there's some relationship to

it.

MR. GREENE: Q. Again, my question is that the

ecclesiastical organization exists separate and apart from

the corporate organization?

MS. BARTILSON: Objection, asked and answered.

Answer it again.

THE WITNESS: Obviously you are dealing with the

same group of people. There are parallel -- I think a

better way of expressing it, there are parallel

ecclesiastical and corporate organizations that are

separate, but the part in the question I'm having

difficulty with is "distinct." You are talking about the

same Church. In other words, the Church of Scientology

International is organized in an ecclesiastical fashion,

and within those ecclesiastical positions certain

individuals occupy corporate positions. To that degree

they are separate, yes, but you are talking about the same

entity.

Q. We're talking about CSI.

A. That's right.

Q. That's the corporation.

A. Mm-hmm.

Q. That's one subject matter that we're discussing.

142

A. Right.

Q. The other subject matter we're discussing is the

subject matter of ecclesiastical authority.

A. Right.

Q. And there's commonalities between CSI and

ecclesiasticalness but they're not identical, are they?

MS. BARTILSON: Objection, vague and ambiguous.

THE WITNESS: I don't exactly understand your

question.

MR. GREENE: Q. Let me try to make it more

clear.

A. Try it again.

Q. Yesterday, if my recollection is right, your

testimony was that there are approximately 1400

Scientology-related organizations, right?

A. Yes, churches, missions and groups.

MR. WALTON: What?

THE WITNESS: Churches, missions and groups.

MR. WALTON: Am I the only one down here not

hearing well?

MR. BENZ: I missed it the first time. I heard it

the second time.

MR. GREENE: Q. So of those 1400 churches,

missions and groups, CSI is one, correct?

A. That's also correct.

143

Q. Now isn't it true that there is ecclesiastical

authority in place in each of those 1400 groups, if you

know?

A. Yes.

Q. Ecclesiastical authority in place in each?

A. Each as its own separate unit or among them?

That's what I don't understand about your question. I think

it's largely irrelevant, though, because the answer is yes

to both questions. I want to make sure which of those two

questions you are asking.

Q. I'll keep asking my questions and we'll do our

best to wend our way through this.

Where officers, directors and trustees of CSI

have authority, that's defined according to the articles

in the bylaws of CSI?

A. Right.

Q. They are also subject to authority that's derived

from an ecclesiastical source, right?

A. Okay, I'll go along with that. All right.

Q. And the ecclesiastical source is the scripture of

the Scientology religion; isn't that right?

A. That's also correct.

Q. And the scripture of the Scientology religion in

part is derived from the writings of L. Ron Hubbard?

A. Correct. I would object to your

144

characterization of "in part." It is derived from the

written and recorded spoken words of L. Ron Hubbard on the

subjects of Dianetics and Scientology.

Q. Entirely?

A. Yes.

Q. So then is an accurate definition of your

understanding of the use of the term scripture as used in

Scientology, to define scripture as being the totality of

the written -- of the writings and recordings of L. Ron

Hubbard?

MS. BARTILSON: Objection, misstates the

witness's testimony.

MR. GREENE: I'm asking if that's accurate.

THE WITNESS: No, that's not accurate.

MR. GREENE: Q. Then I misunderstood what you

said. Tell me again. I'm sorry.

A. Scriptures of the Scientology religion are

comprised of written and recorded words of L. Ron Hubbard

on the subject of Dianetics and Scientology with the

allowance that theym may have been cancelled over the years

or revised or modified, or whatever. On the subject of

Dianetics and Scientology, what I had told you in the first

answer was given allowances for any cancellations or

revisions that may have been done over the years.

Q. That's part of -- Let me get a bigger picture

145

first before I go more narrowly.

When you make the qualification on the subjects

of Scientology and Dianetics, does that include writings

on organizational administration?

A. That would not be included in the exception.

Q. I'm not focused on the exception; I'm focused on

the scope of the meaning of scripture. So my question is

is it included within the scope of the meaning of

scripture L. Ron Hubbard's writings on administrative

management?

A. Certainly, as it's used in the Church and as

it's used in the organization Executive Courses, First

Volume, certainly that's considered scripture.

Q. You are a Scientology executive yourself; is

that right?

A. That's correct.

Q. So you have gone through and received some

amount of training in the organization executive courses,

right?

A. Yes.

Q. Would you tell me what the extent of your

training in that regard has been?

A. I've done the entire Organization Executive

Course, which is the study of the encyclopedic volumes of

Church policy as well as the Flag Executive Briefing

146

Course.

Q. And the OEC, Organization Executive Course

books, those are the green ones?

A. That's correct.

Q. Now directing your attention to what's Bates

stamped as page 13 there's the enumeration of what the

Mother Church has got to adhere to and there's a list of

three items.

A. Yes.

Q. So part of what CSI's corporate mandate is is to

adhere to the goals, tenets, doctrines, codes, creed,

policies and practices set forth in the Scientology

scriptures, right?

A. That's correct.

Q. And you yourself as an individual Scientology

executive are bound by such things as well, correct?

A. Certainly in the performance of my duties, yes,

of course.

Q. And also in the performance of -- I mean, you

have given your life to Scientology, essentially, haven't

you?

A. I've devoted my life to it, yeah. I think we're

getting into the area of personal religious experience

that's been excluded, but, yes, of course I have.

Q. That's been roughly since 1976, right?

147

A. Roughly.

Q. Now item two talks about recognition of the

ecclesiastical authority of the hierarchy of the Mother

Church, right?

A. That is what it says.

Q. Now making reference to the ecclesiastical

authority that means, if I have understood you -- and I may

not and I know you will correct me if I haven't --

that recognition is of the Scientology scriptures, right?

A. To be precise, the recognition is of the

ecclesiastical authority of the hierarchy of the Mother

Church but it flows, that authority flows from the

scriptures, if that's what you are asking.

Q. That's a good starting point. Then the next point

I want to go to is the phrase "hierarchy of the Mother

Church." My first question is: The hierarchy to which that

phrase makes reference, is that hierarchy contained

within CSI?

A. That appears to be the most logical reading of

point two, yeah.

Q. Let me ask you -- I know that it appears to be

the reading --

A. It would --

Q. It appears that way to me, too.

A. It would match the way things work. So the

148

answer to your question would be yes.

Q. Let me ask you about ecclesiastical authority.

You're familiar with the Sea Organization, right?

A. Yes.

Q. You are a member of the Sea, aren't you?

A. Yes.

Q. You have been a member of the Sea Org since

when?

A. 1981.

Q. Now the Sea Organization -- that's spelled S-E-A,

for the record -- is an organization that's governed by

ecclesiastical authority, is it not?

A. In the general sense, yes.

Q. You know the president of CSI, Hebert Jentzsch?

A. Right.

Q. He's a member of the Sea Org, isn't he?

A. Yes.

Q. The vice-presidents, Leisa Goodman and Janet they

are also Sea Org members, aren't they?

A. Yes.

Q. And your assistant, Leslie Browning, she's Sea

Org, too?

A. Yep.

Q. As is the treasurer Jonathan Epstein?

A. That's also correct.

149

Q. Then the directors Mark Yager, Mike Rinder, Curt

Weiland, Guillaume Leserve and Katherine Rinder are all Sea

Orgs, as well?

A. That's correct.

Q. What we didn't talk about yesterday is who are

the trustees. Actually, that's preliminary. There are

trustees of CSI, aren't there?

A. Yes.

Q. The trustees are those individuals who, among

other things, have the responsibility of appointing the

directors at CSI right?

A. Yes.

Q. Who are the trustees?

A. Mark Yager is one of the trustees; Mark Ebert;

Michael Sutter; Warren McShane, Louise Stuckenbrack.

Q. Would you spell that last one?

A. S-T-U-C-K-E-N-B-R-A-C-K.

Q. All of those individuals are Sea Org members,

aren't they?

A. That's correct.

Q. Now going back to item two on page 13 of Exhibit

three, when you answered the question I asked you with

respect to the meaning about the hierarchy of the Mother

Church there's also a Sea Org hierarchy, too, isn't there?

A. Not necessarily in the sense that it's used

150

here.

Q. Let's escape from the document, just speak

generally for a minute.

There's a hierarchy of authority within the Sea

Orgs, isn't there?

A. Not as the Sea Organization. It's quite

loosely -- I would say probably, but not in the sense it's

used here.

Q. What's your understanding of the sense it's used

here so I make sure I'm on the same wave length?

A. In the sense it's used here there is a

recognition that the Mother Church of the Scientology

religion is at the place that it occupies in the hierarchy

of that religion and there are definite lines of authority

that stem from CSI's position as CSI.

In the Sea Organization there is no authority

that derives from an individual's rank or position or

whatever in the Sea Organization as the Sea Organization

that's independent of their corporate or ecclesiastical

position. You have a Sea Organization member; if you take

away their ecclesiastical position and you take away their

corporate position they are still a Sea Organization member

with a certain status within the Sea Organization but they

have no authority. The authority doesn't flow from the

position in the Sea Organization which is why I

151

say in a loose sense when I refer to hierarchy, because

hierarchy has a concept of authority flowing.

Q. Let's talk about hierarchy just generally so we

can see whether or not we can have a meeting of the minds

here.

There is a hierarchy of authority with respect to

corporations that have a place in the overall constellation

of Scientology, isn't there?

A. Yeah, I believe so, if I'm understanding your

question.

Q. In other words, some corporate organizations

exercise authority over other corporations.

A. Within certain precisely defined limits, yes.

Q. RTC, for example, is charged with maintaining

the purity of Scientology technology -- is that right?

A. That's correct.

Q. And CSI is charged with the propagation,

ensuring and maintaining the purity and

of the religion of Scientology, page 15, "...as

has been developed and may be further developed

by L. Ron Hubbard."

A. That's correct.

Q. Now in the Sea Organization do you have a rank?

A. Yes.

Q. What's your rank?

152

A. Petty officer second class.

Q. Who's your senior?

A. I don't have one in the Sea Organization, if

we're still on the Sea Organization as the Sea

Organization.

Q. Who designated you to have the classification of

petty officer second class?

A. Officers Council of the Flag Command Bureau.

Q. Who is on the Officers Council of the Flag

Command Bureau?

A. I'm not really certain.

Q. Do you know anybody who's on it?

MS. BARTILSON: I'm going to object at this

point because we're diving into religious practices. The

Sea Organization is a paternal religious order. We're

diving into Mr. Farny's connection to this order and

asking for names of individuals as part of it. He already

testified that it doesn't have any particular authority as

a group; it's simply part of this religious order. I

think we're going really far afield here.

MR. BENZ: What connection does this have to the

lawsuit?

MR. GREENE: The connection it has, this witness

has testified, number one, there's been testimony about how

part of what the job of CSI is and his job as

153

secretary in CSI is to comply with the scriptures of

Scientology and to recognize ecclesiastical authority.

He has also stated that ecclesiastical authority,

that the Sea organization is subject to that, as well. And

I am endeavoring to find out exactly what that means

because that will in turn go to the issue of motive as is

relevant to the matters which bring us here later on in

terms of what Mr. Farny's requirements are and what CSI's

requirements are in following the writings of L. Ron

Hubbard and the policy letters that flow down from some

higher authority. That's what I'm trying to find out is

what is the flow of authority.

This witness has testified, one, that gee, there's

really no flow of authority in the Sea Organization but on

the other hand he stated that he's got a particular rank or

at least classification. So I'm simply endeavoring to find

out how it was that he got such classification and who gave

it to him because he didn't give it to himself. And it's

relevant to finding out who calls the shots and how those

shots are executed.

MR. BENZ: The problem I have at the moment I

don't see what the shots are.

MR. GREENE: I know. This is preliminary to

that.

MS. BARTILSON: But we don't have any foundation

154

that anybody other than the corporate authority for CSI

has called any shots anyplace. There's been no testimony

to the contrary by anybody. I don't think you are getting

that.

MR. GREENE: I'll tell you what, I'll approach it

a different way and --

MR. BENZ: If you can tie it in and go

backwards.

MR. GREENE: That's exactly what I'm going to

do.

MR. BENZ: That will be helpful.

MR. GREENE: Q. There are corporations in

Scientology that are known as Sea Org organizations,

right?

A. There are organizations within Scientology that

are Sea Org organizations and they are housed within

corporations, yes.

Q. What's the Sea Org organization that's housed

within CSI?

A. There's several.

Q. What are they?

A. Watchdog Committee, Commodore's Messenger

Organization International; Golden Era Productions;

Commodore's Messenger Service for Golden Era Productions.

MR. BENZ: Excuse me, that's Golden what?

155

THE WITNESS: Golden Era Productions.

Planetary Dissemination Organization;

International Network of Computer-organized Management,

I-N-C-O-M-M for short; Office of Special Affairs

International and Flag Bureaus, and the Flag Command

Bureau; International Finance Office; L. Ron Hubbard

Personal Public Relations Office; Senior Case Supervisor

International Office. I don't think I've forgotten any.

How many is that?

Q. Twelve.

A. That's what I remember. I think that's all.

Q. Just in terms of numbers, is it your

recollection that there may be other Sea Org units housed

within CSI in addition to the 12 that you enumerated for

us today?

A. Yes. International Training Organization, 13.

I think the list now encompasses all.

Q. Excuse me?

A. I think the list now encompasses them.

Q. Is complete?

A. Yes, I think so.

Q. Now within the Office of Special Affairs

International is housed a legal bureau; isn't that right?

A. That's right.

Q. You have a role within OSA legal, don't you?

156

A. Yes.

Q. What is that?

A. I'm responsible for CSI litigation; also my post

as corporate secretary requires me to do other legal things

from that position.

Q. What's the title of your post in legal?

A. CSI litigation handling officer.

Q. What's the scope of your authority as CSI

litigation handling officer?

A. I'm responsible for the successful resolution of

litigation matters involving CSI as a party or any other

litigation matter concerning the trademarks which CSI has

an obligation to participate in.

Q. Those would be trademarks that CSI has been

licensed by RTC to use?

A. That's correct.

Q. I just wanted to clarify. I didn't mean to stop

you.

A. That's fine.

Q. Are there any other areas of activity that you

are authorized to participate in in addition to those two?

A. To the degree that situations may exist that

might result in litigation that embroil CSI I do have

authority to step in and see to it that they're resolved

prior to it becoming litigation if it's possible to

157

resolve that. That, I think, generally describes it.

Q. Were you hatted on being CSI's litigation

handling officer?

A. Yes.

Q. Who provided you with the hatting materials?

A. I compiled them myself.

Q. Are you telling me that there was no preset

hatting procedure for being CSI's litigation handling

officer?

A. That's correct.

MR. BENZ: What's the term, hatting?

THE WITNESS: Hatting.

MR. GREENE: Q. Hatting means -- Strike that.

In the practice of Scientology very specific definitions

are given to particular words, right?

A. Sure.

Q. In fact, part of being a Scientologist is having

a command of the particular meanings that Scientology gives

to specific words, right?

A. It certainly helps to understand the subject if

you do, yes, of course.

Q. In fact, that understanding of language of --

Well, I don't want to put words in your mouth.

A. Shall we define the term Mr. Benz asked about?

Q. I'll get there.

158

A. It was what is the definition of the word

hatting.

Q. I understand that, but I have my own way and I

like to do it my way. I'm the one asking the question.

A. You and Frank Sinatra.

Q. Thank you.

Isn't it fair to say that Scientology really has

its own language in a sense? It's English, but it's got

its own language, right?

MS. BARTILSON: I'm going to object to this line

of questioning. We're really far afield in delving into

Scientology as a general subject. I think it's

unnecessary and a waste of time and it's harassing the

witness.

THE WITNESS: There's a terminology that's grown

up with the subject that's unique to the subject, and

that, like any other subject, has its own unique

terminology. I wouldn't describe it as another language.

MR. GREENE: Q. That's fair enough. There's a

terminology that's specific to the practice of

Scientology, right?

A. Yes.

Q. In fact, the terminology is so specific that

Scientology has caused to be published a technical

dictionary that people can refer to in order to ascertain

159

the meanings of specific words if they're not clear about

it, right?

A. I don't know if that was the result of it being

so specific. It certainly is helpful, yes.

Q. But there is such a technical dictionary, right?

A. Yes, there is.

Q. And the technical dictionary contains within it

words that have particularized uses and meanings within

Scientology with definitions attached to those words,

right?

A. That's correct.

Q. Now hatting means to train for a particular post,

doesn't it, among other meanings?

A. That's correct.

Q. The term "post" means the job to which one is

assigned in Scientology, right?

A. That's correct, like the word position.

Q. Like the word position or like in the military

someone being posted, right?

A. Right, although I think the military uses it for

the base to which an individual is assigned. I think they

use billeted for the specific job duty.

Q. I shouldn't make the comparison. Okay.

Did you assign yourself to the post of

litigation handling officer?

160

A. No.

Q. Who assigned you?

A. Michael Rinder.

Q. Do you know what Rinder's -- Strike that.

What is Rinder's position in OSA legal?

A. His position is outside of OSA legal.

Q. So Rinder is not posted within OSA legal at all,

right?

A. He's the Watchdog Committee member for the Office

of Special Affairs and holds the position as head of the

Office of Special Affairs.

Q. Within OSA, Office of Special Affairs, what other

bureaus are contained in addition to legal?

A. Public relations. There's an Investigative

Support Branch for legal, which is a separate bureau;

there's an Executive Bureau; Hubbard Communications Office

Bureau.

Q. What was the one you said right before Hubbard

Communications Bureau?

A. Executive. Enhancement Bureau, Treasury, Action,

Social Reform.

Q. Any others? No, right?

A. That's right, no.

Q. Now all of these -- I need your help. When you

gave me the list of Officers Council, Flag Command Bureau,

161

Watchdog Committee, CMO International -- that means

Commodore Messenger Organization International, right?

A. Commodore Messenger Organization International

is the correct word for that.

Just, before you go on, I didn't put Officers

Council as one of the organizations under CSI. It meets

yearly to decide on promotions, so I wouldn't consider it

a formal organization. It's made up of individuals within

these other organizations.

Q. So these are the organizations within CSI; they

are Sea Organization organizations?

A. Right, meaning all of the staff members of those

organizations also happen to be members of the Sea

Organization.

Q. Now you know David Miscavige, don't you?

A. Yes.

Q. And David Miscavige is a Sea Organization

correct?

A. Yes.

Q. What is his label?

A. Label? Human being.

Q. I know he's a human being. Thank you for

reminding me.

A. You are welcome.

Q. What's his post?

162

A. Chairman of the Board of Directors of Religious

Technology Center.

Q. To your knowledge, is there any individual in the

religion of Scientology who is alive that holds more

authority than David Miscavige?

MS. BARTILSON: Objection, vague and ambiguous.

Alive to do what?

THE WITNESS: Authority is such an often misused

word, especially in Gerry's counter-claim. I would like to

define the parameters of that question a little bit before

I answer it.

MR. GREENE: Q. Actually, since I am asking the

questions and you are answering, let me try to assist you.

A. Okay.

Q. You have an understanding of the term authority,

right?

A. I do.

Q. Is it fair to say that within your understanding

of that term is included the meaning of one person issuing

an order and another person complying with it?

A. Yes.

Q. Limiting your answer to that understanding, is

there anyone in Scientology who, to your knowledge, gives

orders to David Miscavige?

A. No.

163

Q. To your knowledge, is there any post in the Sea

Organization senior to that of Chairman of the Board of

RTC?

A. There aren't any posts in the Sea Organization as

the Sea Organization. There are posts within the churches

that make up the Sea Organization.

Q. Let me ask it this way: In the overall

Scientology religion is there any post senior to Chairman

of the Board of RTC?

A. No.

Q. So overall in Scientology worldwide the highest

position is Chairman of the Board of RTC?

A. It's the senior position in the religion, yes.

MS. BARTILSON: Is this a convenient time to

request a break? Whenever you have a convenient moment.

(Discussion off the record.).

MR. GREENE: Q. Now, is it fair to say that part

of what OSA legal is charged with doing is handling

ecclesiastical matters?

A. What?

Q. Let me --

A. Vague and ambiguous.

Q. You don't understand? I know your deposition has

been taken before. It's a really difficult subject matter.

If you don't understand me, I know you will tell

164

me. Feel absolutely free to tell me to do it better, do it

again.

A. Do it better, do it again.

Q. Now in referring to the ecclesiastical authority

of CSI as set forth in item two Bates-stamped page 13

Exhibit three, the ecclesiastical authority that's being

recognized as stated in the bylaws is that which you have

enumerated to be the 13 Sea Organization organizations

within CSI, right?

A. Each within their sphere of influence, yes.

Q. Each within their sphere of influence are

charged with handling whatever matters are within their

sphere of influence, right?

A. That's correct, although the ultimate

ecclesiastical authority within CSI is the Watchdog

Committee. It's at the top.

Q. The buck stops at the Watchdog Committee?

A. That's right.

Q. Who are the members of the Watchdog Committee

besides Rinder?

A. Mark Yager, he's the chairman; Mark Ingbert; Greg

Hughs; Pablo Lobato.

Q. Would you spell that?

A. L-0-B-A-T-0. Elizabeth Miscavige. I'm drawing a

blank on the others but there are four or five others.

165

Q. That's fine. Elizabeth Miscavige being the wife

of David Miscavige?

A. No.

Q. Sister?

A. Sister-in-law. She's goes by the name Bitty.

Q. Since 1976 you've worked within other Scientology

corporations in addition to CSI, right?

A. Yes.

Q. CSI, in fact, wasn't even originated until 1981

or so?

A. That's correct, 1981.

Q. You work within Church of Scientology of

California, for example, right?

A. Right.

Q. What other organizations have you worked in

during the time you have been a Scientologist?

A. Church of Scientology, Mission of Riverside; and

I briefly held a position in Cincinatti.

Q. What organization there?

A. Church of Scientology of South Hamilton County,

Ohio. Hamilton County -- no, Columbus, not Cincinatti,

sorry.

Q. Since 1981 you have had occasion to interact with

other -- That's all right, let's break.

Off the record.

166

(Brief recess.)

MR. GREENE: Back on the record.

Q. Mr. Farny, is Michael Rinder your senior?

A. Not directly.

Q. Who is your direct senior?

MS. BARTILSON: Objection, asked and answered.

THE WITNESS: Ed Parkin.

MS. BARTILSON: How many times do we have to have

the same question?

MR. GREENE: Excuse me, counsel. Q. Who is Mr.

Partkin's senior?

A. Neil Levin.

MS. BARTILSON: Same objection.

MR. GREENE: Q. Who, is Levin's senior?

A. Jacqueline Kavenaar, K-A-V-E-N-A-A-R.

Q. Who is Ms. Kavenaar's senior?

A. Michael Rinder.

Q. And who is Michael Rinder's senior?

A. Mark Yager.

Q. And who is Mark Yager's senior?

A. Doesn't have one.

Q. What is Ed Parkin's post?

A. Legal activities chief.

MS. BARTILSON: Same objection, asked and

answered.

167

MR. GREENE: Q. And Neil Levin's post?

MS. BARTILSON: Objection, asked and answered

yesterday.

THE WITNESS: Legal aide, A-I-D-E.

MR. GREENE: Q. And Kavenaar?

A. Deputy commanding officer for production.

Q. And Rinder's post?

A. He holds two: He is Watchdog Committee member

to OSA as well as being commanding officer of office of

Special Affairs International.

Q. And Mr. Yager's post?

A. He's the Watchdog Committee chairman as well as

being the commanding officer of Commodore's Messenger

Organization International.

Q. So one way that an order coming from Yager might

be labeled would be COCMO, Int.?

A. Would be labeled COCMO, Int.

Q. Now who is Yager's senior?

A. He doesn't have one.

MS. BARTILSON: Objection, asked and answered.

MR. GREENE: Q. Do you know how Yager was assigned

his post of WDC chairman?

A. No.

Q. Now within OSA, then, the command lines run from

Yager at the top down through the other people that you

168

enumerated?

A. Mr. Yager is not in OSA.

Q. Excuse me, you are right. In CSI?

A. Run that by me again.

Q. The command lines in CSI as they pertain to OSA

run from Yager down through the other individuals that you

enumerated, right?

MS. BARTILSON: Objection, vague and ambiguous.

If you understand it -- feel free to answer it.

MR. BENZ: Are you asking for a ruling on that?

MS. BARTILSON: Is it vague and ambiguous to

you, too?

THE WITNESS: I'm thinking if I can answer it. The

command lines in OSA run from Mr. Rinder. I think that's

the best answer.

MR: GREENE: Q. When you use the term "command

lines," what you are making reference to is the activity of

giving an order and getting compliance?

A. That's one small part of it, yeah. There is also

coordination among activities and receiving of reports from

activity originated at a lower level on the command lines

such as mine.

Q. So if you receive a command, part of what you

have to do is, one, do whatever the command instructs you

to do, right?

169

A. No, not in the absolute sense, of course not.

Q. I'm not talking in an absolute sense. First of

all -- Wait a minute, I'm sorry. I don't mean to argue

with you.

When you are talking about an absolute sense

what do you mean?

A. You just said if I receive a command I

automatically have an obligation to follow it merely

because I received it.

Q. No, no, I'm sorry if that's what I conveyed. I

wasn't meaning to do that.

A. That would be inaccurate.

Q. Is it fair to say when you receive some sort of

directive from somebody who is senior to you to call that

a command? What would you call that?

A. A communication like that received from the

people who I've listed here on the command channel within

the office of Special Affairs can be a suggestion, an

observation, a request, or it can be an order.

Q. Okay. Is there a hierarchy among suggestion,

observation and order?

A. Suggestions and observations would be merely

that. Those are regular English definitions. An order is

also a regular English definition. An order presumes

there's an expectation of compliance if the order is

170

within the duties of the position receiving it, the

authority of the position issuing it and within general

policy. If it's not within all those, the obligation to

comply with it disappears.

Q. When you say "general policy," you are making

reference to the policy as set forth in the scriptures of

L. Ron Hubbard, right?

A. That CSI officially adopts as its governing

policy, yes.

Q. Going back to my question, let's say you receive

an order from someone senior to you.

A. Anyone in particular?

Q. Not anyone in particular; it's generic and I'm

trying to get a generic understanding.

A. The problem with a generic description, keeping

in mind the statements that are made in the

Cross-complaint, I can't adopt some sort of generic

hypothetical that's then twisted into something that Oh,

here, this applies to the Cross-complaint. I'm a little

better with specifics.

Q. Let me just try and make sure we're on the same

wave length. I'm not trying to twist you up; I'm trying to

get a clear understanding here.

You said that you would comply with an order if

it was within the scope of your duties, right?

171

A. That's correct.

Q. And if it was pursuant to policy, right?

A. That's correct.

Q. And then there was one other condition.

A. There were two other conditions: It was within

my job duties to perform that request and task and it was

within the authority of the individual requesting it to

issue such an order. Of course, if it was legal.

Q. Let's say those four conditions were satisfied.

A. I get five, but that's fine. The fifth one went

without saying, but generally, fine.

Q. That's fine, five is fine.

Then would you comply with the order?

A. Insofar as I was able to do so I would do so,

yeah.

Q. After you complied with the order would you then

give a report on how you complied with the order?

A. Either verbally or in writing I would let the

individual know I had done it.

Q. Frequently such reports are done in writing,

correct?

A. I don't know about frequently.

Q. In your experience.

A. My experience it's verbal and in writing.

Q. What is the scope of -- what are your job duties

172

as litigation handling officer?

MS. BARTILSON: Objection, asked and answered.

Go ahead.

THE WITNESS: Gee, I guess I won the opportunity

to list them all.

Duties are to see to it that legal situations

that affect, potentially affect CSI or the trademarks and

service marks CSI is authorized to use are resolved

through insuring that competent counsel is obtained to

deal with the situation; that that counsel receives

adequate backup of staff resources necessary to provide

the information that counsel needs to solve the situation;

that adequate planning exists to resolve the situation and

that that planning is executed. And it would be my

responsibility to originate the plan.

MR. GREENE: Q. So part of your job would be to

come up with a game plan on how to approach any given legal

problem; is that fair?

A. It's more counsel's job. It's my job to see to

it that counsel would do such a thing.

Q. In the backup that's provided for counsel, that

would involve, if necessary, paralegal support?

A. That's correct.

Q. It would involve investigatory support as well

if required, right?

173

A. Yes.

Q. And the investigatory support would come from the

OSA Bureau of Investigative Support for legal, right?

A. Yes, or from myself or from the paralegals or

from the attorney's office himself.

Q. Included within investigative support for legal

are private investigators, right?

A. Not within that bureau itself. Any

investigators that are hired would be hired by counsel and

the personnel in that bureau would provide whatever

briefing materials and assistance the investigator would

need much the same way that we would provide paralegal

support for the attorneys.

Q. The particular investigators are recommended by

OSA to counsel employed by OSA, right?

A. Recommends whom? We would agree or not of an

investigator selected by a lawyer, yes.

Q. One of the investigators who has been employed in

the past by OSA is Eugene Ingram, right?

A. No, he's been employed by counsel.

Q. Ingram has been employed by counsel who's been

employed by OSA, right?

A. Represented OSA. Well, represented CSI,

whatever.

Q. Aside from making sure that legal situations

174

that affect or could affect CSI or the trademarks or

service marks that CSI is licensed to use through obtaining

competent counsel –

A. Wait a minute, you left something out.

Q. What was that?

A. I think I said something after "or potentially

affects CSI." Before I said "through," the word " through."

I think I said "competently handled." If not, I should

have.

Q. Part of your job is -- what I'm going to ask you

is aside from what you have told me are components of your

job duties are there any others?

A. I think those are the major components, yeah.

Q. So when you execute the planning then you provide

a written or verbal report to your senior, right?

A. Usually verbal or a copy of the paper that's

filed or the order that results, court order that results

from the action taken, yes.

Q. How long have you held your current post?

A. This post came into existence in the spring of

this year.

Q. And prior to that what was your post?

A. Civil litigation officer. It had essentially the

same duties.

Q. What can you tell me about how the post was

175

changed from civil litigation officer to your current one?

MS. BARTILSON: Objection.

MR. GREENE: Litigation handling officer.

MS. BARTILSON: Requesting a narrative. Improper

question.

MR. GREENE: Is that an instruction?

MS. BARTILSON: It's a request.

MR. GREENE: Q. Do you understand what I am

asking?

A. It's broad. I can go on awhile.

Q. Why don't you give me a few preliminary

comments?

MS. BARTILSON: The objection stands and I'll

ask him not to answer.

MR. GREENE: Then instruct him and we'll

proceed.

MS. BARTILSON: I have.

MR. GREENE: Can we have a ruling?

MR. BENZ: Can I have the question read back

again?

(Record read back.).

MR. BENZ: Objection is sustained.

MR. GREENE: Q. When did you first learn that your

post of civil litigation officer was going to be changed to

litigation handling officer?

176

A. Shortly before it changed.

Q. Which was approximately when?

A. Approximately in the spring.

Q. Of '94?

A. Yes. Maybe a few weeks before spring.

Q. So we're talking March?

A. February-ish, March-ish, with a real big ish.

Q. Late February, early March?

A. Around that general area.

Q. Who told you first?

A. Michael Rinder.

Q. Where were you?

A. In his office.

Q. Which is located where?

A. 6331 Hollywood Boulevard. Now we were in a

different office at the time.

Q. Where were you then?

A. We were in the Cedar's complex.

Q. The blue buildings?

A. Yes.

Q. In Hollywood?

A. Yes.

Q. What did Rinder tell you?

A. That in the at that time upcoming reorganization

that I would be continuing to do the same thing I was

177

doing although the name of the post changed.

Q. Did you ask him how the reorganization had come

about?

A. No.

Q. Did it cross your mind to ask him that question?

A. Not in that conversation, no.

Q. In a later conversation did you ask him?

A. No.

Q. Did it cross your mind -- at any time later to

ask?

A. No.

Q. Now when you receive an order that order comes to

you from a post senior to the post that you hold,

right?

A. It's not going to come from one junior to me, no.

Q. But how the order comes to you is a matter of

policy, isn't it?

A. As in the physical mechanics of what it will do?

Q. Yes.

A. That and a function of the physical universe

there are certain ways one has to communicate.

Q. Orally?

A. Orally is one of them.

Q. In writing?

A. Writing is another.

178

Q. And in some cases physically?

A. I don't recall receiving a physical order, but

you are correct that orders can be issued that way.

Q. That's the scope of my universe. Is that the same

as yours?

A. Ditto.

Q. So, then, when you receive an order, for such an

order to be pursuant to policy that order has got to be in

writing, doesn't it?

A. Policy contemplates the existence of verbal

orders, so the answer to your question is no.

Q. Was the entire legal division of OSA affected by

the reorganization?

A. Yes.

Q. How many people was that, approximately?

A. Thirty to 40.

Q. Now the action bureau of OSA contemplates the

performance of what type of activities?

A. Sending representatives to local areas to assist

them to resolve situations in that area either internally

within the local Office of Special Affairs or Department of

Special Affairs or externally.

Q. When such persons were sent out would that be

called a mission?

A. It would.

179

Q. Would such persons performing such missions

generally be members of the CMO?

A. No.

Q. Did you hold the post of civil litigation officer

within OSA during the original Armstrong

litigation?

A. You mean in 1984?

Q. That was when --

A. 1982 to 1984?

Q. Yes, '82 to '84.

A. No, I did not.

Q. Were you involved in the Armstrong litigation --

Actually, strike that.

What post did you hold in the '82 to '84 time

period, post or posts?

A. It's plural. When the case was first filed and

we obtained the temporary restraining order --

Q. Wait, wait, wait, I want --

A. I have to do it by what was happening. Do you

want to do it by date?

Q. No, you can give me activity and sequence.

A. When the litigation was first filed I was in

supercargo of the Office of Special Affairs, U.S.

MR. WALTON: I'm sorry, what?

THE WITNESS: Supercargo.

180

MR. GREENE: Q. That was your post?

A. Yes.

Q. So then what post next did you have?

A. Then August '82, August '82 I was on that

position. I'm not sure -- no, it wasn't OCS; that was

before the reorg was completed. It was U.S. Guardian's

Office.

Q. So you were supercargo of the U.S. Guardian's

Office in approximately August of '82?

A. That's correct. Then after the reorg I went into

legal. That would have been January of '83 I went into

legal in the mission all clear, and I held various

positions within that until I moved up to the Office of

Special Affairs International in approximately April of

'84. My position was called litigation secretary. I was

the head of what is now the Legal Bureau. At that time it

was the Litigation Bureau.

Q. So you were litigation secretary up through June

of '84 when Breckenridge's decision came out?

A. Yes.

Q. Then were you civil litigation officer?

A. No.

Q. What was next?

A. Next was deputy litigation chief for the United

States; then was litigation chief. I'm not sure it was

181

chief. No, it wasn't chief, it was director of both of

those. Then I was the All Clear legal secretary. My next

post in legal was litigation chief, legal aide.

Q. Legal aide is a different post?

A. It's different.

Q. I just want to make sure I'm clear.

A. Legal quality control officer and then civil

litigation officer.

Q. And all of these positions were all positions

ecclesiastical authority of CSI, right?

A. Not all that I listed.

Q. Let me go through them and check them off and

then you can tell me.

A. You want me just to tell you where the ones

within CSI start?

Q. Sure.

A. Litigation secretary, all the ones thereafter.

Q. Those were the ecclesiastical positions?

A. No, all the ones from that one onward was within

CSI. The ones previously were CSC, Church of Scientology

California.

Q. So when you were supercargo USGO, that was within

CSC?

A. That's right.

Q. Then you made reference to the reorganization

182

and that's what has been called in the past "mission

corporate category sort-out"?

A. No.

Q. That's a different reorganization?

A. Mission corporate sort-out didn't result in a

reorganization; it was abandoned. It was a complete

failure.

Q. The reorganization, then, to which you were

making reference was the reorganization that resulted, at

least in part, with the origination of CSI, RTC, Religious

Technology Center, and CST, Church of Spiritual

Technology, right?

A. In part. It began approximately in the summer of

1981 and was complete with a total disbandment of the

Guardian's Office by October of '83.

Q. Now the list that you gave me of litigation

secretary on, those all were within OSA, right?

A. That's correct.

Q. And OSA is an ecclesiastical organization,

right?

A. The Office of Special Affairs International.

Q. Right.

A. What we've been calling OSA.

Q. Yes. Just so we're clear, there's a difference

between the Office of Special Affairs and Office of

183

Special Affairs International, isn't there?

A. Yes.

Q. So when you and I have been talking here saying

the words or the letters OSA, what my understanding has

been is we've been referring to the international

organization; is that the same as what yours has been?

A. I don't think I've used it any other way.

Q. I don't think you have either. I just want to

make sure we're clear.

A. Yes.

Q. So with all that in mind, going back to Bates-

stamped page l3 of Exhibit three, when you are talking

about items two and three there and references made to

ecclesiastical authority and governance in ecclesiastical

matters by said hierarchy, what we're talking about is OSA

International, right?

A. Not exclusively, no.

Q. But in part?

A. Small part certainly, but we're not the main line

of ecclesiastical management of the religion; we're a small

portion of that that deals with external matters such as

this lawsuit. So we're not by any stretch of the

imagination the mainline of activity of the Church.

Q. Right. I'm not meaning to suggest that you are.

A. Within those confines, fine.

184

Q. Because indeed something, to use your term

mainline, the Watchdog Committee would be much more

mainline than OSA; is that right?

A. That's correct.

Q. And the Flag Command Bureau, as well?

A. That's right.

Q. And in fact --

A. And the Flag Bureaus.

Q. And the Flag Bureaus.

Now earlier when you described the Flag Command

Bureau, Watchdog Committee, CMO, Int., and on down the

list, was that in order of hierarchy?

A. No, it was in order of how they came to my mind.

Q. Let's look at those in terms of hierarchy, if we

may.

A. All right.

Q. What is primary? What is at the top of the

hierarchy, and I can review them.

A. I just thought of another one that should go in

there, which is the International Executive Strata, rather

a major one to have forgotten. Doing it this way is easier.

So at the top of the hierarchy is the Watchdog

Committee.

Q. Then what's junior to that?

A. Junior to that within what is described as

185

International Management is the Commodore's Messenger

Organization International.

Q. And then junior to that?

A. Well, still at the same echelon, we're still at

the same echelon of international management. You have the

Senior Case Supervisor's Office, International Finance

Office, Golden Era Productions, although they don't have

any management functions; they produce dissemination

materials: Films, video tapes.

Q. Advertisements?

A. Audio tapes and advertisements for Dianetics and

Scientology.

Q. Some of which we see on television?

A. I hope so. They're still at that same echelon

of International Management as is the Commodore's

Messenger Organization, Golden Era Productions and

Planetary Dissemination Organization. And immediately

below the level of the Watchdog Committee, still in

International Management, is the International Executive

Strata.

Q. Is International Finance Office included there,

too?

A. No, they are in the International Management.

Q. So International Finance Office is on par with

International Executive Strata, right?

186

MS. BARTILSON: Objection, misstates.

THE WITNESS: Yes. Generally.

MS. BARTILSON: Sorry.

THE WITNESS: Generally, yes. Now still answering

your question --

MR. GREENE: Q. Okay, go ahead.

A. Next echelon down is the upper middle management

echelon, which contains the Flag Command Bureau and the

organizations within it all of which are of a similar level

in terms of hierarchy. Now that completes the list.

Q. In your knowledge does the Watchdog Committee

have a member who is in RTC?

A. No.

Q. You know that there is not such?

A. I know that there is not such.

Q. Now within the Watchdog Committee there is --

Strike that.

Do you know who the members of the Watchdog

Committee are?

A. I don't have anything to add to my previous

answer.

MS. BARTILSON: Objection. Asked and answered.

MR. GREENE: Q. To make sure I've got my

understanding correct, the Watchdog Committee is contained

entirely within CSI?

187

A. That's right.

Q. Directing your attention now to page 14 of

Exhibit three, and under item C where reference is made to

the "Religion of Scientology and Scientology shall mean the

religious doctrines, beliefs, tenets, practices, applied

religious philosophy and technology for its application as

developed by L. Ron Hubbard and as the same may hereafter

be developed by L. Ron Hubbard," is your personal

definition of Scientology the equivalent of what's set

forth in what I just read?

A. Yes.

Q. Does your personal definition of Scientology

include anything more than what is set forth there in

paragraph C?

A. I've used the terms to also include the

individuals who adhere to these beliefs. When I speak of

"in Scientology we do blah blah blah," I would include the

individuals who adhere to these beliefs as well as the

philosophy and religion and stuff.

Q. Directing your attention to paragraph D where

"Scriptures" is in quotes and is defined as "Shall mean the

writings and recorded spoken words of L. Ron Hubbard with

respect to Scientology and organizations formed for the

purposes thereof," we spoke about that briefly earlier and

you adopt that definition personally as well, don't

188

you?

A. Yes, I do.

Q. And your own personal use of the term scriptures

with reference to Scientology does not include anything in

addition to what's set forth in paragraph D, does it?

A. No.

Q. Now turning to the next page and directing your

attention to the first paragraph, would you take a moment

to read that paragraph to yourself?

A. Subparagraph (g) or the first article under

three?

Q. I apologize, it's following section one. Let me

know when you have had a chance to do that.

A: I've read the first paragraph.

Q. Where reference is made to maintaining the purity

and integrity of the religion of Scientology, what does

that refer to in your understanding?

A. As it's set forth here with reference to CSI's

duties or the Church of Scientology's duties it means to

ensure that the technology developed by Mr. Hubbard for

improving an individual's spiritual awareness is applied in

exactly the manner that LRH said to apply it. It ensures

the organizational structure of the Church is in such a way

that it doesn't lessen the integrity of that technology,

pervert it in any fashion, or use it in such a

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way that's harmful.

Q. Within Scientology isn't it true that what you

are referring to is encapsulated in the phras that goes

something like: Standard technology standardly applied?

A. Yes, that would be accurate. That would refer to

the audio technology and Mr. Hubbard's philosophy.

Q. Now there are some individuals who have used

Scientology technology without authorization or permission,

right?

A. Yes.

Q. Part of what CSI's responsibility would be --

Well, strike that.

A person who is engaged in the unauthorized use

of such technology would compromise the purity and

integrity of Scientology; is that fair to say?

A. Not in all cases because some use of the

technology is not requiring an authorization. You can buy

a Dianetics book or a self-analysis book at the book store

and use it and that's fine, that's what it's there for,

it's to be used. You can give a touch assist or something

to someone. You can use it, read one of the books, adopt

the principles and use them in your life. So none of that

sort of thing requires any organization.

Q. Any kind of metered activities would, however,

right?

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