|
§ What's New || Search || Legal Archive || Wog Media || Cult Media || CoW ® || Writings || Fun || Disclaimer || Contact § |
|
|
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF MARIN
---o0o---
DEPOSITION OF: LYNN R. FARNY Tuesday, July 26, 1994 VOLUME III
|
|||||
|
|||||||||||||||||||||||||||||||
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
I N D E X
|
||||||||||||||||||||||||||||||
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
1994, commencing at 9:55 a.m. thereof, at the Law Office of William R. Benz, 900 Larkspur Landing Circle, Suite 185, Larkspur, California, before me, SUSAN M. LYON, Certified Shorthand Reporter #5829, personally appeared
LYNN R. FARNY,
called as a witness, who having been first duly sworn, was examined and interrogated as hereinafter set forth.
A P P E A R A N C E S
Landing Circle, Suite 185, Larkspur, California, appeared as the referee.
Boulevard, Suite 2000, Hollywood, California 90028, represented by TIMOTHY BOWLES, ATTORNEY AT LAW, appeared as counsel on behalf of the Plaintiff Church of Scientology.
Drake Boulevard, San Anselmo, California 94960, represented by FORD GREENE, ATTORNEY AT LAW, appeared as counsel on behalf of the Defendants Gerald Armstrong, |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
et al.
Landing Circle, Larkspur, California 94939, represented by MICHAEL WALTON, ATTORNEY AT LAW, appeared as counsel on behalf of DEFENDANT MICHEAL WALTON.
---o0o---
|
|
|||
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
---o0o--- (Defendant's Exhibit Nos. 14-17 marked.) RESUMED BY MR. GREENE
first one is marked as Exhibit No. 14, which is a SEA Organization Flag Conditions Order 6664, dated 18 February 1982.
before?
before. I've seen one or more documents bearing the title Suppressive Person Declare Gerry Armstrong.
person declare issued for Gerry Armstrong in and around February 1982?
what the purpose of this inquiry as it appears to |
||
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
be part of the cross-complaint that you filed in this
action, which has already been stricken by the court. MR. GREENE: No, this is -- we've been through this before, last time, Mr. Bowles.
defenses of unclean hands, of defense based on first amendment, based on duress, and undue influence.
complained specifically alleged that Mr. Armstrong had two suppressive person declares naming him as such, and goes on from there to relate other events following that.
going off into discovery in the other action, which apparently has already encompassed such allegations.
generally the line of objections here, we are allowing it to progress on the cross-complaint, which is abuse of process, which goes to malice, and also on the affirmative defenses that Mr. Greene has mentioned.
any extensive discovery, then, it's obviously just going to be used in another case.
we're going to do it here, too. To the extent it doesn't |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
overlap with this case, we have no interest in going into the other case.
cross-complaint and the affirmative defenses raised, in my opinion, are sufficient to encompass this from a discovery standpoint in this case.
MR. GREENE: I think I have -- our side is neglectful but I guess you should look at my copy here.
general objection rather than specific.
document and any testimony regarding it.
knowledge was a suppressive person declare issued for or having to do with Gerald Armstrong in and around February of 1982?
I recall it being in 1982.
a document that looks similar at least to that document |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
before?
other suppressive person declares.
officer for CSI; right?
do with Gerald Armstrong since the Church of Scientology of California originally sued him in 1982; right?
declares that were issued on him memorized.
that appears to be a true and correct copy of the suppressive person declare on Gerald Armstrong you see before us now; right?
given you the best I can.
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
that
you've produced authenticated, I would guess the
normal procedure would be to send it to us to admit that that's an authentic copy of it, then I could go check the files, or whatever. But insofar as there was no designation of subject matter here, and insofar as any discussion of cross-complaints was stricken from the cross-complaint, I have Mr. Benz's comments in mind, I am answering your question, I didn't go back and look. It's been many years since I've read one or the other, or both.
suppressive person --
decision that you were the person who was most appropriate for CSI to put forward to testify about the matters pertaining to the lawsuit against Gerald Armstrong that we're here for that's been filed in Marin?
decision insofar as you were concerned in your participation?
and going back to 1982, do you have any recollection as to |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
why a suppressive person declare was issued with respect to Gerald Armstrong?
evidence.
knowledge whatsoever.
question, Mr. Bowles. The question was --
any recollection.
Mr. Farny?
reasons why Armstrong was declared because he left Scientology without going through the proper procedures?
position in the SEA organization without going through the proper procedures.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
designated by the term routing out; correct?
organization; right?
declared a suppressive person because he spread destructive rumors about senior Scientologists?
spread.
mind.
the time that Armstrong had been reported, at least, to have been spreading destructive rumors about senior Scientologists; right?
around Christmas time of 1981, wasn't it? Or rather, excuse me, strike that.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
around
December of 1981, wasn't it?
statements that he no longer was a Scientologist; right?
technology did not work, as well; is that true?
the end of 1981 and beginning of 1982, is there anything set forth in Exhibit 14 that you believe to be inaccurate?
Special Affairs, is there not, wherein the suppressive person declares relating to Gerald Armstrong are maintained?
file?
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
which is a two-page document entitled Executive Directive, dated 20 September, 1984.
working in the legal division of CSI, weren't you?
Greene?
Affairs International purporting to be issued on or about 20 September, 1984.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
before?
International executive directive 19 before, yes.
or --
with it. So if you would tell me what the meaning of the document is.
summer or early fall of 1984 to provide information for Scientologists concerning the ecclesiastical status of certain individuals discussed therein.
individuals set forth in Exhibit 15 is that their actions were destructive and aimed at the enslavement rather than the freedom of man; right?
Greene or --
and four.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
which transpired in the fall of 1984 within CSI, it's true, is it not, that it was generally known that Gerald Armstrong had been designated as a squirrel; right?
where?
was within CSI.
squirreling. He was obviously included in this issue because of his involvement with Lipkin and Ristuccia in the plot that was revealed in Griffith Park.
process of being revealed, if I remember right. But it was around that time period that that went down as well.
did, but he certainly earned inclusion in this with the rest of these individuals through that activity.
that's set forth in Exhibit 15 that's false, is there?
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
opinion and purely ecclesiastical communications meant for distribution only within a defined ecclesiastical community and all sorts of things like that. But in any event, within those parameters, I'm not aware of anything within this that's --
faith belief and opinion on the part of the church.
it not?
left-hand corner of Exhibit 15, at the three lines under OSA INT ED 19 where is says, "All Scientologists Public Notice Board and Staff Notice Board"; do you see that?
particular document, does it not?
have been mailed a copy. That would have been a physical impossibility.
Scientologists to read. And the way public parishioners, |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
non-staff would read it, would be on the notice boards designated for public parishioners of the church at their local church. The staff would read it on the staff notice boards.
directive would be distributed to all Scientology organizations for posting; right?
asking him if he actually knows this document was distributed in that way?
know, I don't know if this one was or not.
procedure.
can see what it says in the upper left-hand corner.
than all of the churches of Scientology.
of this, right, because you were in CSI?
within CSI legal; right?
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
housed within the Office of Special Affairs; right?
Office of Special Affairs; right?
executive directive issued from the Office of Special Affairs, to your knowledge, did OSA have a procedure for the distribution of an executive directive which is designated such as this?
Special Affairs had any type of procedure for the distribution of a document that was labeled all Scientologists, public notice board and staff notice board; correct?
It's asked and answered. He just told you that.
He didn't answer the question, Mr. Bowles.
was distributed within the office of Special Affairs I International. As far as beyond that, I don't remember. I really don't. |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
there executive directives which issue from OSA today from time to time?
Affairs.
that are not -- today, currently, that are not limited in the scope of distribution to the staff of OSA?
International, but I'm not aware of any beyond that in recent years.
knowledge, when an executive directive issues from OSA currently its distribution does not go beyond units within CSI; is that what you're saying?
I'm trying to think of an instance in recent years where it went beyond that and I can't think of one as I sit here.
he has one."
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
before, although we don't have them yet from the other court reporter.
suppressive groups list that we looked at last time; right?
Affairs International.
talking about flag orders now rather than flag executive directives.
that to my attention.
calling that to my attention.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
is unlimited within the realm of Scientology, isn't it?
The distribution would generally be noted in the upper left-hand corner.
organizations and missions.
placed in all organizations and missions would receive a copy of a flag executive directive; right?
Whether as a matter of practicality and sheer logistics and mechanics whether they would, one would hope so, but I can't say that obviously.
Scientology procedure by having access to such an order; right?
15, which is an OSA International executive directive, the distribution of an OSA International executive directive, at least as to 1984, was much broader --
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
terms of this specific issue, it would seem so from what's noted on the upper left-hand corner.
actually effectuated that the public notice boards and staff notice boards in the churches and missions all got a copy.
existed in 1984 and frankly, I would doubt it, but I'm not here to guess. I'm just saying what my understanding is.
distribution practices of OSA ED's, was there a procedure in effect whereby there was accountability whether the distribution was accomplished?
what you mean by accountability, please?
ED's generally, because as I said, they're mostly internal documents and it would be very easy to see if they were distributed in the Office of Special Affairs International, which at that time occupied one floor of a building, you could look and see if the -- however many staff we had at the time -- |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
usual for an issue such as this from the Office of Special Affairs to be issued with a designation public notice board/staff notice boards. So I don't know what procedures existed to make sure that they all got one, if indeed there were such procedures.
it have been a violation of any procedures for this to have appeared on any staff notice boards, no, it would not have.
answer it from this direction that we've been going on for some time about.
the persons enumerated there were considered to be among the worst enemies of Scientology?
it important for all church members to know what occurred.
the most important enemies, no.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
that right?
squirrels.
settlement which took place in 1986 with respect to a number of clients who were represented by Michael Flynn; right?
such settlement were included Kima Douglas; right?
developing and drafting those settlement agreements; right?
settlement agreements in consequence, aren't you?
as to both of them, their settlement agreements included non-assistance provisions; right? |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
not to disclose any of their knowledge about Scientology, its practices, or anything about its founder L. Ron Hubbard; right?
brief --
settlement agreements. Number one, it's irrelevant. Number two, it may violate the terms of those agreements.
have spoke out of turn by answering your first question. I'm afraid I can't answer your second question because the terms of the agreements are confidential.
witness to answer the question and the reason is this. One of the affirmative defenses alleged by Armstrong is that the settlement agreement is a violation of public policy.
policy is because it's not only Armstrong that |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
signed one of these agreements whereby former
knowledgeable, highly placed officials of Scientology were, by virtue of provisions of the agreement, to maintain silence with respect to their knowledge and were required not to testify unless subject to service of subpoena and were required not to make themselves "amenable to the service of subpoena" in a spirit that was contrary to the agreement.
circumstance whereby it was not only Armstrong who was required to keep his mouth shut and not help anybody who had been hurt by Scientology, but other people as well, that in total that that constitutes a violation of public policy.
existence of such provisions to this witness are relevant to this lawsuit and would overcome any kind of concern that they may be confidential.
may be confidential, but that does not mean that a court is precluded from inquiring into whether or not such terms exist, and that's why it's relevant.
position.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
on for the morning so far into areas that are covered by portions of the cross-complaint that have been stricken from this case that are being litigated down in Los Angeles. He's taking discovery in the other case at this point.
settlements which are clearly beyond even the scope of that litigation.
by the terms of the contract from discussing terms of the other agreements.
limited strictly to the particular terms of the settlement agreements with Kima Douglas, and who else?
public policy. That argument he's already lost in the Court of Appeals by the decision that was issued last month.
appeal of a preliminary injunction. And as you know, Mr. Bowles, a preliminary injunction is, in fact, what it says it is, preliminary.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
don't interrupt you.
has a likelihood of success on the merits and that, of course, upholds the soundness of the contract.
about that. I don't think there's been a decision about that.
think at this point the question as to the content of the other settlement agreements is going beyond the scope of where we are here, so I'll sustain the objection as to the particular content of the agreement, of the other settlement agreements --
Are Kima Douglas or Laurel Sullivan engaged in any present litigation --
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
individuals who entered into settlement agreements that were represented by Flynn or in that group of individuals was Edward Walters; right?
individuals in Los Angeles, but there was also a block of individuals in Boston, as well, that were represented by Flynn, the Garretys, they entered into settlement agreements, didn't they?
agreement.
recollection.
was where the litigation was centered?
Peter Graves.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
in the calendar year 1986.
included Marjorie Wakefield; right? --
who had not been declared suppressive persons in the -- referring to the Florida people that I just enumerated?
relevance of this? You're going off into other former parishioners who have settled cases. |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
same lawyer, it was all part of the same general plan to eliminate from any kind of litigation and from the marketplace of ideas in public persons who were familiar with and willing to testify about what they saw as the truth regarding the beliefs and practices of Scientology.
He's going to be asking questions about Wakefield, McLean, Cazares and these others, what their experiences were with the church, what they may have be-en doing outside and since then.
asking whether they were included also. He's jumping the gun. I haven't gone there.
where you're going --
getting close to the edge.
I've gone over it.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
suppressive persons, and that signals to me that you're going off into irrelevant areas.
please.
question as to whether these people were declared suppressive persons.
find out, though, don't you?
set, sir?
don't you stop interrupting.
answer, if he wishes. If there's an objection, please |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
make it in the form of an objection. We can rule on it.
answering the questions for him.
it within your ability to ascertain whether or not the Florida settling individuals were declared suppressive persons, don't you?
individuals was Howard Schomer; right?
Angeles global agreement; isn't that right?
agreement, Mr. Greene? It's vague. That's your term. Can you define it, please? |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
about. THE WITNESS: Actually, I had a problem with the words global agreement because it presupposes one agreement that everybody signed on to one document. We settled with him in December of 1986, yes. MR. GREENE: Q. And that was in conjunction with a number of other people, including Armstrong?
we're talking about, do you?
for the record. I'm not intentionally trying to be obtuse with you.
Now, Michael Flynn also had pending litigation against the Church of Scientology; right?
conjunction with Armstrong and the others in L.A., as well; right?
|
321 |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
at, wasn't it?
that you, meaning CSI, did not provide money separately to Armstrong; right?
terms.
litigation on the record that what we did was provided a pool and had the individual parties and Micheal Flynn decide among themselves who got what part of that pool of money.
participants.
and equitable, they did, as opposed to us arbitrarily putting a value on it.
Flynn, was it not?
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
it here.
objection. It goes to the content of the settlement agreements.
that Michael Flynn had a conflict of interest in representing approximately 20 people, including himself, in one settlement. And that that conflict of interest invalidates the efficacy of his representation of Armstrong with respect to the settlement and to the settlement itself. It's directly relevant.
question, Mr. Benz, how much was the total settlement amount given to Mr. Flynn.
Mr. Flynn had a conflict of interest or not.
terms which, by contract, my client is constrained from revealing. It's also irrelevant.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
rights, do not and cannot supersede a judicial inquiry.
protective orders and we certainly would be willing to enter into an appropriate protective order.
that has been brought against him by Scientology. He hasn't -raised the issue. That issue is joined. He is entitled pursuant to discovery to get information that's relevant to that issue.
were settled out by Michael Flynn including, Michael Flynn himself, it sure as heck is relevant what the pool of money was that was given to Flynn, which has been admitted here, that that amount is relevant. MR. BENZ: Well -- MR. BOWLES: He's taking issue with something that Michael Flynn may have done. He might have just as well sued Mr. Flynn if he wants the information.
decided to give others out of a total settlement and the total amount are irrelevant to this matter. My client again is constrained. That's our position.
should be considered a party to this contract that's considered so confidential. And if he's a party to the |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
contract, then certainly telling him what the terms are doesn't violate any confidentiality.
and Mr. Flynn. And if Mr. Flynn, if he has a problem with Mr. Flynn, he should sue Mr. Flynn.
We're not talking about --
conflict of interest. That's your position relative to Mr. Flynn.
client that your client participated-in setting up, Mr. Bowles, by setting up a procedure whereby Michael Flynn, which your client knew represented 20 people, including himself, was given a big pot of money, and he was told to go settle the cases. That's relevant to whether or not Flynn had a conflict of interest. And it's also relevant to whether or not there's unclean hands here, both of which have been asserted as affirmative defenses in this case.
fraudulently conveyed his assets, are we not? Because we haven't discussed it in, so far, the three days that I've been being deposed. |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
I just want to glance at this thing.
grounds of relevance, primarily. We know the fact that Mr. Flynn was involved in this. We know the fact that he was representing others. And we know the fact that he was representing Mr. Armstrong in this when the agreement or whatever it was.
amounts and details would add anything to the defenses. So I am going to sustain it.
recognize that to the extent that it doesn't jeopardize the parties' case here, but I will not hesitate to pierce the confidentiality if it becomes otherwise important or relevant.
point that this is a suit for fraudulent conveyance alleging that Mr. Armstrong has given away his assets defrauding my client. How the terms of a confidential settlement agreement with other parties comes to play on that is remote, at best. |
|
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
these specific allegations were stricken from his cross-complaint already.
is the third time we've talked about the cross-complaint and the affirmative defenses in Mr. Armstrong's complaint, so let's move on with it.
take -- respectfully take exception to your ruling --
amount of money, particularly that which would accrue to the benefit of Michael Flynn is directly related and directly relevant to the extent of the conflict.
Scientology has represented that there was a lump sum and, that was given to Flynn, that Flynn used to settle his and other cases.
to be made but not to allow any inquiry as to what that amount is. So I respectfully disagree with your ruling based on those grounds and the others stated.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
Exhibit 15.
engaging in some actions that were destructive and aimed at the enslavement and not the freedom of man. And I would ask you now to tell me specifically what were those actions, to your knowledge?
question?
A. All right. To the best of my knowledge, making misrepresentations concerning the background of Mr. Hubbard, the founder of the religion; the actions he took to -- in stealing the personal archive documents; his work with agents of the criminal investigation division of the IRS to subvert or to undermine the church, specifically, those actions I referred to earlier. I would think that they would all be encompassed within that.
destroy the representation of the religion's founder. That if one believes, as I do, that Scientology frees people, the attempted destruction of that indicates an intention to enslave people.
opinion. |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
of this issue.
to that.
referred to; right?
that Scientology was engaged in the freedom of man, or freeing --
paths aside from that offered by Scientology that free people?
official church position?
that is a workable solution. |
|
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
directing your attention on 15 to the second paragraph under the list of names with Scientology, deliberately held policy up to scorn that you recall?
recall how he did?
recollection is that Armstrong, in fact, did hold policy up to scorn; right?
fit within this paragraph. What it is specifically a decade later beyond the general categories of conduct that I've articulated in response to a couple of questions ago, I don't remember.
enumerated on shortly ago, would it be the -- what you say are the misrepresentations regarding Hubbard that would fall within the scope of deliberately holding policy up to |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
scorn?
principles so.
in which Armstrong deliberately held policy up to scorn?
that were in his declarations through this time period and the lies that he used in order to obtain a judgment he didn't even expect from Judge Breckenridge.
Flynn regarding Armstrong, included in that was an agreement if a reversal of Breckenridge's decision was obtained, to limit damages upon retrial to $25,001; right?
damages to nominal damage, yes --
time around.
more than the jurisdictional maximum that then existed for superior court, right, of $25,000? |
|
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
other than damages, were the more important issues.
important were Judge Breckenridge's characterizations of Scientology; right?
injunctive relief that was sought.
asked, wasn't this the important thing. I told you what was the important thing.
absolutely, without question. I'm not going to sit here and tell you it wasn't.
the judicial process was very important because that was the relief we were seeking.
very important was, would be obtaining a reversal of Judge Breckenridge's characterizations of L. Ron Hubbard; right?
characterizations of Hubbard were mistaken and erroneously based upon his crediting Armstrong's misrepresentations; right? |
|
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
Flynn dog and pony show, yes.
Laurel Sullivan; right?
but as a general proposition, sure.
litigation Wollersheim versus Church of Scientology; right?
included Sullivan; right?
didn't she?
generally bad things about the religion, but she had no relevant testimony whatsoever to give to that case because she had never met him, and that's part of the misrepresentations that have been flying around here over the years, is that witnesses to torts were removed from |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
the legal process. That's garbage and you know it.
say bad things just because they were being paid to do so were removed from the marketplace forcing you guys to deal with facts, and that appears to be something you can't tolerate, and that's why you got a problem with it, just so we're clear.
in Wollersheim, wasn't he?
he had nothing relevant to say to any issue and forbade him from opening his mouth in front of the jury.
well?
mistreatment of Wollersheim but on the manner in which Scientology operated; right? A. No. They made up their schtick and just, you know, flapped their gums just like they were being paid to do.
|
334 |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
characterization of them making up their schtick and flapping their gums, you would apply the same type of characterization to Gerald Armstrong, wouldn't you?
Q. In the context of his participation in litigation and his phony declarations?
phony and that they contain lies.
Scientology and its founder, as was Sullivan and Walters; right?
lies, yes.
decision was reversed by Scientology's unopposed appeal thereof --
because the appeal at that stage had already been fully briefed, there was no further need for an appeal brief -- now just let me finish.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
sent the case back because the cross-complaint, in their view, hadn't been disposed of. In reality, it had been disposed of by way of the settlement.
that Mr. Armstrong felt compelled to communicate to the court, you'll notice he's not been sued for breaching the settlement agreement -- by communicating to the court concerning that appeal, because that was a change in circumstance neither side anticipated. In fact, we've gone out of our way to point that out on a number of occasions and it keeps being raised.
You're familiar with the fact then that Armstrong sought permission from the Court of Appeal to participate in the appeal of his own action; right?
appeal with a copy of the settlement agreement under seal; right?
consider such action by Armstrong in any way to constitute I a violation of the settlement agreement; is that right?
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
Armstrong, because of the change of circumstance seeking
leave from the court of appeals to file papers, merely that fact, not necessarily anything he said in them or public disclosures he may have made beyond that, but seeking to participate in the appeal is not and was not considered by CSI to be a breach that became part of the Los Angeles action because of the change-in circumstance.
that the manner in which Armstrong participated in the appeal constituted a violation of the agreement?
not part of the Los Angeles action.
Armstrong participated in his own appeal was or is considered by CSI to be a breach of the agreement.
position on that.
appeal, you know, to.participate in the appeal would not be the subject of the breach action.
was granted by the Court of Appeal; right?
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
position that Armstrong's participation in his own appeal in any way constituted a violation of the agreement?
needed to. It's not a subject that's under current litigation.
sought to assist Bent Corydon's effort in unsealing the court file, which I would have considered certainly not in the spirit of how the settlement had been arrived at, or the term -- or what resulted from it.
the breach action. The precise reasons for it not being part of the breach action, well, it's kind of difficult to talk about because it goes into communications with lawyers.
such a big deal was made out of the agreement Gerry made in December '86 not to further participate in the appeal and what actually happened, because circumstances changed --
but what the Court of Appeals did necessitating a slightly different operating climate. |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
there was a retrial of Armstrong One was considered to be part of the settlement with Gerald Armstrong, wasn't it? A. Well, I don't know what you mean by -- well, I don't want to phrase it that way. I don't know what you're referring to when you say settlement. It is not within the four corners of-the settlement agreement signed between the churches and Gerry.
it at the same time.
an agreement whereby CSI agreed to indemnify Flynn in the event that there was a judgment for $25,001 against Armstrong; right?
document.
a signatory if not CSI; is that right?
Scientology organizations from time to time; right?
|
|
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
package; right --
I didn't mean $25,001, I meant $1.
injunctive claim.
Armstrong silent; right?
there had been a lot of litigation about restraining Armstrong from talking about what he had claimed to be his knowledge of Scientology; right?
involving that issue; right?
Armstrong case.
you worked on, didn't you?
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
Gerald Armstrong's circumstances;
would prevent Armstrong from disclosing knowledge that he obtained from the documents that he received from Omar Garrison; isn't that right?
was employed to write a biography about L. Ron Hubbard; correct?
biography --
the --
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
employed to write about Hubbard was to act as an archivist; right?
provide documents having to do with Mr. Hubbard's past to Omar Garrison; right?
he?
routing out, he at some point thereafter went to Garrison and obtained copies of those historical documents regarding Mr. Hubbard; right?
the way out, as well as obtaining some from Mr. -- that Mr. Garrison was holding temporarily, but which were still bound within the entire ambit of what the authorization of possessing them was, which was for the creation of the authorized biography.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
say, took and ones that he obtained from Garrison were considered by CSC to be within the scope of the fiduciary duty that Armstrong owed to CSC; right?
unauthorized manner --
keep his mouth shut about; right?
were not the only area that CSC wanted Armstrong to keep his mouth shut about; isn't that right?
1982.
hairs.
for? |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
want Armstrong to keep his mouth shut about what was in the Hubbard documents, but also with respect to his knowledge of Scientology operations, generally speaking.
than spreading lies about the church. Of course, you're not going to be interested in someone who continues to spread lies about one. I mean, that's kind of natural.
clear about what we're talking about here in the lie department, the lies that he spread were the same lies that were erroneously, in, your view, adopted by Breckenridge in his decision, in part -
so-called defense yet. So that took a few years to think of.
resulted in the Breckenridge decision, that's what we're talking about.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
to Armstrong's what you said were lies, CSC made efforts to obtain court orders keeping Armstrong silent; right?
temporary restraining order and preliminary injunction covered anything beyond the documents themselves and their contents.
I've drawn a blank right now. Cole was one of them, yes. So I just don't remember the precise terms of the order that we sought and obtained.
lawsuit in terms of injunctive relief were the continuation of such orders; right?
the documents back.
court. |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
Waddington, that's the TRO judge, Waddington.
injunctive relief compelling Armstrong to keep his mouth shut about the contents of the documents to be permanent; right?
continuing to utter lies about the church?
included or not.
time, what has stuck with me as being the focus were the documents themselves because, obviously, for the last dozen years, the documents, of course, received further attention in litigation.
package pertaining to nominal damages --
stipulation or the indemnity agreement; right?
it, but I don't think his signature appeared on those two |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
documents.
on it is based upon what facts?
talking directly with Michael Flynn.
but the substance of it was that, I mean, I just came away with the understanding that what Mike was telling Mike was getting to Gerry; what Hertzberg and Heller were telling Mike Flynn was getting to Gerry, because throughout the entire several months that the settlement negotiations went on, it was apparent that -- and if this is something Flynn did and didn't tell his clients, well, I can't help taht, but it was apparent to us that when Flynn would come back with a position, he was speaking for his clients. It seemed like he had discussed things with one or more of his clients. Q. Were there discussions between Flynn and Heller and/or Hertzberg pertaining to the non-assistance provisions some time in advance of the December signing date, to your knowledge?
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
transpired between Flynn and/or Heller on one hand and the Hertzberg and/or Heller on one hand and Flynn on the other directed toward the non-assistance provisions in advance of this signing?
are you talking about non-assistance provisions?
what I'm talking about, how Armstrong -- I think, it's 7G and 7H.
those discussions occur?
the get go. So it would have been for many weeks, I'm thinking into the summer when the negotiations first started.
know if it was post-verdict or not. Because I remember |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
most of our own internal discussions took place in the apartment that Earl had, so we were still doing the Wollersheim trial. My sense is it was pre-verdict. So that would be prior to July of ' 86.
totalled $30 million; right?
of Appeal?
Flynn's clients started prior to that verdict, is your best recollection?
and we were talking about in the winter, but I don't think so. I think it started sometime shortly before that, within weeks or whatever.
period of time before they were consummated in December.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
question. And I'm getting a little bit more of an estimation from you.
and on from 1979 on with Flynn on settlement so --
not, to preclude Armstrong from, if possible, from continuing to lie about Hubbard and the church?
objective that there be peace. And it was our objective that problems would not continue to be generated which flowed from the lies he was telling. But there was also conduct that would be involved, active assistance to adverse litigants, that sort of thing. It was our intention that there be a clean slate.
his lies to deal with, which I think is where you're going, but that's a different question.
Operation Clean Slate? |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
Heavens no. No, it didn't.
of the settlement agreement?
agreement.
discussions with Flynn, with respect to Armstrong and his other clients, we covered that base, when did the -- settlement discussions with Flynn started in the summer of 1986. Was the scope inclusive of many, if not all of Flynn's clients?
thereafter.
complete break with no assistance came up, and I know I said earlier from the get go. It was certainly right near the get go.
it wouldn't make any sense, for example, to get a commitment from Armstrong not to talk or not to assist but not to get one from Sullivan or Walters, it would just be like sticking a finger in the dike if you didn't get all of the ones that were uttering the lies about Scientology and Hubbard; right? |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
CSI was saying to Flynn, we want confidentiality; right?
the settlement group.
to obtain commitments of non-assistance; right?
sought was to not have the signing individuals executing declarations for other litigants voluntarily, among other things; right?
they had been doing, which was going out of their way to hire themselves out as hired guns concerning the church. If they were compelled to testified by lawful process, fine. |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
as hired guns.
show to rest?
lawful process. There was no need for it, in any case, in any event. It was just created solely to destroy the church. And we didn't think that destroying the church was very pro-survival, to use the Scientology phrase, thing to do.
Scientology's primary objective is is the freeing of human beings; right?
service of process meant, according to CSI, that Armstrong was just what it said, not to make himself amenable to service; right?
to go out of his way to voluntarily accept subpoenas just to cover the fact of voluntarily complying, cooperating, rendering his active assistance. For example, arranging to be at a courthouse at a certain time just so that someone could hand you a subpoena. |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
participation on his own, so be it. He would need to, you know, comport his behavior.
Scientology -- ordered Gerald Armstrong to appear and testify?
for protective order, that sort of thing. But once the court said the day is done, the man needs to testify, the day is done, the man needs to testify.
Armstrong's violations, I believe, was having to do with the first Yanny trial when he appeared and was served with a subpoena; right?
this is all part of the cross-complaint that we had stricken on motion in this case. And all you're really doing here is try to litigation and gain discovery in non-overlapping matters for the other matter.
mean to interrupt you.
now.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
agreement is the basis for the lawsuit here?
cross-complaint -- well, the basis for the plaintiff's complaint here is fraudulent conveyance, which, if we win this, will become a tool for collecting on successful action in Los Angeles.
circumstances of it are not directly relevant to this litigation. Now, he's already pled in a cross-complaint all of his alleged circumstances surrounding events after the settlement agreements were entered, and that's what he's getting into now, this so-called Yanny matter.
talking about now intended to be a violation of the agreement, and as such, the basis upon which you're claiming potential indebtedness?
breach action.
independent recollection.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
you sit here today whether or not Armstrong's appearance at the Yanny trial and accepting the subpoena was considered by CSI to be a breach of the agreement?
suit. Whether a breach --
included in the suit, whether it was a breach that we sued him for. And I said let's look at the document.
that a breach of the agreement?
answer to your question?
helping me clarify it.
Armstrong's appearance at Yanny's trial in Los Angeles and receipt of service of a subpoena to testify to be a violation of the agreement?
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
received the subpoena seemed to have been a sham just to assist his voluntary cooperation, yes.
look, we've got copies.
of context, he was a former lawyer for Scientology; right?
Scientology entities, yes.
are not certain whether included in CSI's complaint in Los Angeles against Armstrong as a cause of action is the receipt of the subpoena, right, in Yanny?
look at it.
do lunch, or do you want to do his question first? |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
Q. Why don't we do lunch. A. Okay. Q. Can we do it in 45 minutes?
lunch recess.)
approximately 1:30.
agreement and the stipulation that we discussed, as well as the indemnity agreement, as being part of a -- I believe your term was package. I don't mean to mischaracterize you.
the same transaction; is that fair to say?
affidavit or declaration signed by Armstrong; isn't that right?
remember which it was. I tend to think it was a declaration. Q. A sworn statement in writing? |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
of that in the files of CSC, to your knowledge?
Special Affairs?
maintained a copy, but I'm reasonable certain that we still retained the original. I'm not 100 percent certain.
circumstances that written sworn statement would be filed in conjunction with the settlement discussions pertaining to Armstrong?
recall specifics.
filing that at some point, but I'm not certain.
Internal Revenue Service?
document was filed by CSI or some other Scientology |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
related entity?
filed by one of the Scientology entities that were a party to this settlement, which was CSC, CSI, and perhaps others.
party to that settlement, too, wasn't it?
against Author Services Incorporated that Flynn had that were part of that overall settlement.
knowledge, is the corporate entity which handles, at least in part, Hubbard's writings; isn't that right, Mr. Hubbard's writings?
yes.
lawyers, on behalf of Scientology related groups that participated in the settlement negotiations was Lawrence Heller; right?
A.-- yes. |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
where Armstrong signed his settlement agreement; isn't that right?
to Armstrong, was an agreement with Flynn whereby Flynn would not represent people against Scientology in the future included, to your knowledge?
package with Gerald Armstrong.
Flynn?
unilaterally that he wanted to do something else with his life. So I wouldn't characterize it as a term of any of the agreements.
representation, namely, that he would not in the future represent individuals in litigation against Scientology?
he wished to pursue other activities.
related individuals or entities state to Flynn the desire |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
that
he no longer represent individuals in litigation
against Scientology?
activities, as well.
discussions with Flynn?
included yourself; right?
our side of the table, as well as people who directly interfaced with Flynn?
during those negotiations.
In addition to those individuals already enumerated, who else participated on your side of the |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
table?
Marty Ratbin and David Miscavige for ASI and for Mr. Hubbard's interests, insofar as he was a named defendant in any of the suits.
for the interfacing with Michael Flynn was Lawrence Heller; right?
Religious Technology Center was involved to a certain degree.
objection to Michael Flynn assisting Armstrong, if Flynn so decided?
I'm just asking you for the position of the corporation that you're here representing whether or not, as I said, CSI has any objection against Flynn assisting Armstrong should Flynn so decide.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
things down early on before this blew up completely. He indicated that he had been unable to make any progress in that regard. So I don't know if he'd have the ability to do anything.
ability. But my question is directed toward whether or not CSI would have any objections to Flynn so representing Armstrong should Flynn make that decision.
on that beyond what I've said. I'm sorry. I just don't know.
know. I haven't formulated a position. I said I didn't know.
speculation.
to make that speculation. MR. BENZ: So I will sustain on the ground of speculation, at least. |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
twice to intervene and calm things down before everything really hit the fan, or that's my paraphrasing --
incorporate the questions when, who called Flynn, and what did the person say, to your knowledge.
attorney-client privileged information, there is an objection raised here.
information appearing that had originated in the universe of data that was associated with the Armstrong litigation.
there was litigation contemplated, actually, initiated concerning that. I did not participate in that one directly. I heard that one after the fact. There was an indication that nothing could be done, wasn't able to do anything. The second time was later, '88, '89 period. And, again, I believe that time Michael Hertzberg called Mike Flynn. And then there was a third instance where Harry Heller called Gerry directly. But that was the two times I recalled with Flynn, because things were heating up in |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
the late '89 period.
Now, when you're referring to Miller's book, that's the book -- first of all, you're referring to Russell Miller; is that right?
believe it's L. Ron Hubbard, Bald Faced Messiah?
And that was litigation that was transpiring in Great Britian; right?
Miller had access to information which, in your Scientology -- generally, if you can, if you can't, I know you'll tell me -- view only could have been derived from documents sealed in the Armstrong litigation; right?
information could have been derived from documents that made their way over there prior to the initial temporary restraining order. But there were other documents that appeared to have resulted from the trial that couldn't |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
have gotten out any other way. It was our perception that they originated prior to the December '86 settlement. We didn't have a sense that they had originated post-December '86 in terms of new communications.
really get anything in response to our request that, hey, how do we deal with this stuff, what do we do.
terms of the settlement agreement to say anything, it was our desire at least some information go along that channel of communication prior to having to jump in with both feet over there.
could be done, it would appear, we made an effort to express things in just the purest form we could without added aggravation.
could possibly express the facts that he was trying to express. He could have gone on a serious roll. He didn't.
those false reports that were in that book in that |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
particular case.
made to confine the remarks just to what was needed at the time.
kind of a term of art, isn't it?
or is it fair to say that what you're referring to is an inaccurate statement of fact?
litigation, while posted within CSC --
case that was ultimately tried in front of Judge Breckenridge?
I think, four declarations in the litigation in Great Britian involving Russell Miller's book.
definitely more than one, certainly. |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
you consult with Long prior to him drafting or him signing that?
paralegal within OSA, doesn't he?
with matters that are pre-litigation matters.
is to try to prevent it from turning into a fire.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
Michael Flynn -- actually, let me back up.
litigation, do you know who it was that endeavored to contact Flynn?
universe would be either Heller, Hertzberg or Cooley?
candidate that you could estimate would be the one?
second contact to Flynn, that was Hertzberg that made that effort, to your knowledge; right?
minutes ago.
but I'm pretty sure it was Michael.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
litigation; right?
at least he published a book.
Greene.
Ron Hubbard, Madman or Messiah; right?
up, which I understand to be in connection with the court litigation, was more specifically what you were referring to was the service of a deposition subpoena on Corydon's behalf on Armstrong?
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
Joe Yanny said he was going to do if we didn't resolve matters was do everything we can to undo all the Flynn settlements.
rumblings about them from Corydon's lawyers about efforts they intended to make to unseal the files, to undo the settlement agreements and such.
yet when the effort was made to communicate with Mike Flynn. Because subsequent to its service Larry Heller spoke with Gerry Armstrong directly. So I'm not exactly sure where it fits in sequence.
us work together on this, let us not allow what we made in December of '86 to blowup because of somebody else. We've got a beef and he was just trying to create trouble.
Morantz, M-o-r-a-n-t-z.
trying to stir it up and was having some effect because all of a sudden then after that Morantz and Plebin started making motions to unseal the file?
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
Yanny having gotten Corydon to do it, yes.
Hertzberg called Flynn was so as to seek Flynn's assistance not to -- to prevent Yanny from being able to screw up the benefits of the settlement?
essentially on behalf of all of the Scientology entities that were the beneficiaries of the settlement; right?
who asked him to.
to call Gerry directly later on down the line?
Gerald Armstrong, one action which preceded said call was the service of a deposition subpoena on Armstrong by Corydon's lawyers; right? A. Yeah, I guess so. Q. Okay. A. That's a long way around that question, though. |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
subpoena? Yes.
recognition, was there not, within CSI that the benefits of the settlement were jeopardized?
reaction to it. If it was used as an excuse to get on a soapbox and start launching on us, so to speak, yes.
the questions relevant to the issues legally obligated to answer, then no.
was served with a deposition subpoena, too;-right?
that was of difference. There was basically three of them, there was Gerry's, there was Laurel Sullivan's and there was Homer's.
circumstances with each.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
so that he could insure of confining his remarks to that which was legally proper, relevant, felt that he would be compelled to answer. His was a viewpoint of open cooperation with us.
have anybody else to represent him. Sullivan wasn't friendly, but in my view she just -- she answered the questions. It was not necessarily favorable testimony, no one particularly enjoyed it, but she didn't go out of her way to start a war again.
on the other extreme.
which started a war again?
manner in which he was around to be served with a subpoena, which I believe I covered earlier. Q. That was basically making himself available; right? A. Going out of his way to travel from Northern California to Los Angeles and be there at the courthouse and have the other lawyer come and meet him there. And it was beyond that which he would legally be required to do. He was going out of his way to start things. I'm sure he had his reasons for doing so, but that's what occurred. |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
direct knowledge of Corydon's case, which was the whole point.
to Los Angeles so as to be available for service of process to testify, or was it once? Did he do so both in Yanny and Corydon?
the Yanny case, I'm sorry.
If that was the subject of his note, he got it right. No, that was the Yanny case; that's correct.
Corydon, come to think of it. I mixed the two up. Sorry.
think it was at the hearing concerning his deposition in the Corydon case that Rick Wing showed up with the Yanny case subpoena. That's why I got the two muddled.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
you considered the two instances wherein he was available for service of process to be similar, that he was making himself available?
himself available or not. It was more his reaction to it and his reaction to Laurie's call that indicated that all was not well on the home front. It certainly didn't rise to the level of us running down to the court to sue him.
we finally said, okay, this isn't something we're going to resolve, we've got to enforce.
with Armstrong?
Objection.
acting as counsel for CSI; right?
yes.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
case for ASI.
pertaining to what was going on with Armstrong; right?
content of his conversations with Heller.
problem.
as to Armstrong didn't pan out; right?
as, I think it's Defendant's 18.
things out with Armstrong in the Corydon litigation didn't pan out, he moved for protective order; right?
Incorporated, yes.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
be, certainly.
Homer Schomer's subpoena. I don't see a reference to Gerry's, unless I'm just going totally blind here. I see a reference in the beginning that says certain third party depositions, but I don't see the reference to Gerry.
be right.
who was subpoenaed in the Corydon litigation; right?
orders as to Schomer, not as to Armstrong, you're right, I stand corrected.
to delay or prevent the taking of certain third party depositions.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
involved in the Corydon litigation, as you said, were Sullivan, Armstrong and Schomer?
which one of -- which one or more of them would have been in play.
depositions of those three individuals was generally the same, wasn't it, namely, all of them had signed settlement agreements; right?
what time we're talking about in the process. I'd say our concerns with respect to Mr. Armstrong's were heightened --
to Homer Schomer's --
the process.
description.
|
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
they had signed settlement agreements in December of '86, at least; right?
common was that each of them had been signatories in the December '86 settlement agreements with Flynn?
none of them knew buckus about Ben Corydon.
right, they also shared that in common?
seeking a protective order to delay or prevent the taking of third party depositions; right?
that before the actual motion was filed and served, weren't you?
post within OSA legal, weren't you?
Services Incorporated. |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
occasion.
motion brought by Mr. Heller on behalf of Author Services?
the knowledge and consent of CSI, was it not?
know whether it required our consent.
was there?
planning and negotiation, the two primary attorneys involved were Michael Hertzberg and Lawrence Heller; right?
paramount because he was the major interface with Michael |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
Flynn up until the very end. As far as input into the decision making process, I'd say the three lawyers I mentioned before were all, all of them, involved, each on behalf of their respective clients, et cetera.
universal settlements was to resolve all Wollersheim like cases; right?
"Wollersheim like cases"?
in Mr. Heller's papers --
it. And it was probably an accurate description if you take into account the entire description of what is meant by that, the tremendous time and financial burden which litigation of this nature placed not only upon the litigants and their attorneys but the courts involved, as well. So I would say yes.
Scientology staff members or parishioners instituted litigation against Scientology; right?
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
isn't that right?
would change the definition.
stable of professional witnesses, without regard to the merits of a particular case or even the facts, go around try to trash the church from courtroom to courtroom to courtroom. It was one of those types of cases.
the suit gets resolve -- having a dispute, the suit gets filed, the dispute gets resolved, the suit gets resolved, I wouldn't describe as a Wollersheim like case.
disparate, they're really to the exclusion of each other, they both would fit within what you said. So that's why I can't adopt that characterization.
the characterization of Gerald Armstrong as a squirrel, included as a basis for such characterization was the assertion that he offered false testimony to the IRS. I'm looking at the third paragraph below the list of names. Right?
have offered false testimony to the IRS in order to |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
protect their overts against mankind and their only way out of this universe."
about that paragraph, if I may, as it relates to Gerald Armstrong. Is that all right?
whether he had given such testimony. It does say some of them. If he had, fine. I'm pretty sure he had, so we can proceed and I'll do the best I can.
information.
knowledge, used in the legal sense or in a more generic sense?
implies perjurious conduct rather than merely lies. And I think if it was merely lies, we would have said lies or false statements.
testified falsely in the course of Armstrong One, isn't |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
it?
yes, this paragraph would apply to him.
understanding is of the meaning of the phrase "in order to protect their overts against mankind"?
trust with regard to the religion of Scientology.
personal archives of the founder of the religion.
David Mayo all had positions of trust, some quite senior to the position Armstrong had.
individuals committed harmful acts, an overt is a harmful act, against Scientology in violation of that trust, rather serious harmful acts to wind them up in the position that they were in as of the 20th of September, 1984.
palatable if one can get the IRS to come down on the church, and that's what's meant by that.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
the IRS in order to make less of or destroy that which they had committed serious harmful acts concerning. Because, otherwise, the severity of their acts if viewed in the cold light of day would have been very difficult for them to face. This made it easier for them to face.
an argument with a guy, you punch him in the mouth, ah, he was a bum anyway, makes it easier than if it was a 70-year-old woman who was hobbling in a cane and you knocked her out.
make it a little bit less than human, it's a heck of a lot easier to abuse it; right?
that being the harmful acts you have committed against that which you are trying to dehumanize. It's -- the dehumanization is to excuse and make less of the severity of your harmful destructive acts.
hurt somebody else and I say to -- I come up with some demeaning label that makes that person less than a full |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
human being, then it's, aw, didn't really hurt them anyway because they weren't really human, something like that?
to that paragraph on the phrase "overts against mankind," is it correct to say that since part of the affect of Scientology is the freeing of mankind, that acts that are harmful to Scientology are harmful to mankind? What my question is, is that what this phrase means, essentially?
"overts against mankind" mean?
individuals committed were of such severity because of the importance of their positions, some less than others, that it was an overt against mankind, it was a harmful act against mankind.
mankind is connected with the good that Scientology does for mankind; isn't that right?
concern; isn't it?
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
of that sentence where it says, "Their only road out of this universe."
to a certain level of spirituality and awareness where one is no longer confined to the laws, trials and tribulations connected with the physical universe. It is our belief that we provide a road out of the trap where the physical universe is.
here, but what this sentence means is that they were committing overts, harmful acts against not only mankind but their own spiritual progress, their own spirituality, their own peace of mind on a cosmic scale, I guess.
cut-off like their spiritual nose -- no, that's the wrong way to put it. That by their overts, not only did they hurt Scientology and mankind, but they hurt themselves, too?
me, still on this paragraph.
written declarations that then went to the IRS? |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
Actually --
That's a lousy question.
answer.
Armstrong went to the IRS and therefore that was offering of false testimony which caused Armstrong to fall within the scope of this paragraph that we're discussing.
me?
something, I mean, for a minute, the term overts against mankind, that's overts as used -- this would be the same thing as what's referred to in the Scientology Technical Dictionary as an overt act, wouldn't it be?
hardbound dictionary to the witness.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
Dictionary?
one and, to a lesser degree three would apply as well.
definitions set forth in the technical dictionary more or less would apply; right?
would probably apply most.
record, please? All three.
someone or something, an overt act is an act of omission or commission which does the least good for the least number of dynamics or the most harm to the greatest number of dynamics," and there's a citation for that. You don't want me to read the citations, do you?
committed in an effort to resolve a problem," and another citation.
willing to have happen to you," and another citation.
|
|
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
paragraph of Exhibit 15 where in a full sentence it says, "Several of them have misrepresented Scientology practices to the FBI or justice department in a futile attempt to taint the minds of the government and the courts against the Church Scientology."
Armstrong engaged in fall within the scope of the definition of that sentence?
time specifically was some specific false testimony some of these others gave which was used in the CSC v. Linberg case by the justice department.
declarations were submitted to the FBI or justice?
futile attempt to taint the minds of the government and the courts against the Church of Scientology," would it be fair to say that inclusive in such efforts were allegations that have commonly come to be known as Scientology's so-called practice of fair game?
within the specific misrepresentations referred to in this |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
paragraph?
question first.
it better.
of practicing something called fair game as being included as an attempt to taint the minds of government and the courts against Scientology?
when.
that's it, okay?
purporting to bear a date of 18 October 1967.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
document before, haven't you?
as well?
policy; right?
fair game law that during the brief window of time that the term fair game was used in the church, not as you people define it --
conditions; right?
1967; right?
not a policy letter that's church policy or that has been church policy since the '60's, if indeed this particular document ever was.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
direct your attention to Exhibit 17.
entitled HCO policy letter of 21 October, 1968; right?
game; correct?
of Exhibit 16, the one that says, "Enemy" -- where it says, "SP order, fair game" -- "may be deprived of property or injured by any means by any Scientologist without any discipline of the Scientologist, may be tricked, sued or lied to or destroyed."
necessarily talking about the same thing in the cancellation of fair game. There was a specific policy letter called the fair game law and there was another policy letter issued at the same time in 1965 explaining what it was and its genesis. This is not that. This being Exhibit 16.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
Now, the condition that is labeled liability, do you see that?
within the doctrine of ethics used within Scientology, is it not?
described in our ethics system.
never been able, by the way, to verify the accuracy of this particular document, but in any event, it would have become a nullity in October of 1968.
Scientology at all, if I remember correctly.
questions.
something that isn't. Why don't you ask me questions about something that is.
take words and try and twist them around with |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
ancient writings that have nothing whatsoever to do with, one, the fraudulent conveyance at issue in this case, which we still haven't mentioned today, or, two, the litigation involving Gerry Armstrong.
described what fair game was during its brief, brief incarnation, all of which occurred prior to Gerry Armstrong's involvement in Scientology, I'd be happy to discuss that with you, and the cancellation, and the reasons for the cancellation.
pieces of paper that neither you, nor I, nor anybody can even verify was authentic 30 years ago when it purports to have been written and have you make statements about my church on the basis of that. I'm just not going to do that.
you've used that in such ominous tones throughout the deposition, I'd be more than happy to. This is not that. So I don't know what you want.
the doctrine of Scientology ethics, isn't it true that |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
there's a condition that's known as treason?
liability and several others. This is not the formula one applies in order to deal with those conditions.
syllogism. You're asking me A, B, C and D and then jumping to Z as the conclusion.
one time a doctrine called fair game. Yes, there is such a thing as an suppressive person disclaimer. That doesn't make this church policy.
can play them all day if you want. It's just going to make the court reporter tired.
you feel defensive.
want you to waste your time trying to construct a house of cards that evaporates at the first -- actually, the sensible question is, is this or has this at any time in the last 20 years been a policy of the Church of |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
Scientology. The answer to which is no, then it doesn't allow you to build your little house of cards.
was Exhibit 16 ever submitted in evidence in Armstrong One?
suppressive person; isn't that right?
them used and they're generally used in that manner, yes.
sentence.
does it not?
this. You say this policy letter does not cancel any policy on the treatment or handling of an SP, so you get magical and you whip out this penalty for lower conditions and you say, aha, this is the treatment and handling of an SP, it was never cancelled, ergo, you guys are bad people. |
| 400 | |
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
It's nonsense. That isn't how it goes.
this tactic, which you tried in the Azoran case and you try here and he tried in Armstrong One, to take advantage and use as a litigation ploy. It's built on lies.
Scientology has never had anything that is like what Exhibit 16 purports to be?
And isn't it true that part of the reason why you believe Gerald Armstrong to be a suppressive person is because he has asserted that Scientology practices fair game within the meaning of Exhibit 16?
greatest man who ever walked the face of this earth, that makes him a suppressive person. The rest is just litigation games, as far as I'm concerned.
Armstrong sought to destroy the representation of L. Ron |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
Hubbard was because Armstrong really couldn't cut the
mustard so far as Scientology is concerned; isn't that right?
the first --
researcher. He had no idea what he was doing. He gets to the first hurdle and gives up. And rather than actually putting his nose to the grindstone and pulling the string the entire way and finding out what the truth is, he left, and then he realized what he did. And his only hope of keeping his sanity was to try and destroy that which he had abandoned.
abandoned was allegiance to L. Ron Hubbard; right?
philosophies and a way of living his life and the spiritual progress one can make in Scientology, certainly.
of this physical universe; isn't that right?
him and his progress as a spiritual being, that's a |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
decision that's entirely his own to make. If he chooses not to believe that Scientology is that path, that's his decision to make.
entrusted, which to try and reap financial gain in order to excuse the fact that he cannot come to grips with the fact that he has abandoned that. If he doesn't want to be a Scientologist, I could care not a wit, I don't even really care.
is that he can't stomach not being a Scientologist and be accountable for that all by himself and he has to take it out by painting Scientology with a black brush; isn't that right?
is pretty obvious. I won't make that characterization. In my view, probably, but that's something only he can answer.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
Exhibit 15,
didn't it?
covered that.
about, Mr. Farny.
view what's wrong with Armstrong is that he did not have and does not have this spiritual wherewithal to cut the mustard according to Scientology technology and therefore has got to basically discredit Scientology in order to keep his own sanity?
his conduct that CSI objects to. His making of an agreement in good faith on both sides and then keeping the money and violating that agreement, and while at the same time making himself judgment proof. Those are the parameters of the current dispute.
his state of mind or my personal opinion about his state of mind really doesn't matter in the litigation.
conduct that violated the terms of the agreement, and that |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
he sought to make himself judgment proof concerning, that are at issue in both of cases. That's the only parameters of the dispute, you see.
I expressed is that which CSI holds towards Gerald Armstrong, that's the question.
that view. I can't speak for the other officers and directors what view they hold. I just -- it's not a question.
just not a question that can be answered.
to answer it.
please.
phrased what I described as the specific conduct on his part that's at issue in the litigation is probably the only view that CSI as a corporation has because that's the view we've expressed through our communications filed in the lawsuit. |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
to matters which have been expressed in the course of the lawsuit, though; isn't that right?
in-house communications, haven't you?
1984 isn't necessarily the view in 1994.
Farny. Gerald Armstrong's overts have not gotten any better from 1984 to 1994, have they?
better? Can you explain what you're talking about?
because he has an audience.
but his motivations are just as evil as they were before; is that right?
declarations. I can't speak for his motivations.
with falsehood; isn't that right?
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
does it not?
category, yeah. We're not talking about General Motors here.
organization.
Come on man. What we have --
getting to be badgering. Philosophical.
Greene.
purity of Scientology technology, is it not?
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
Technology center's purpose but that is among one of the things we do, yes.
so is addressing false reports regarding Scientology; isn't that true?
Armstrong; isn't that right?
rectify those false reports that have come from Armstrong about Scientology; isn't that right?
one else would be doing it.
isn't it?
that we're in here is to freeze the fraudulent conveyances so when we win in L.A. we can collect them.
right?
back that which we bargained for and paid dearly for in 1986.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
1986 was the ability to stop false reports coming from Armstrong; isn't that right?
have an objection to the truth?
get into arguments with the witness. Just ask the next question.
much for your comments.
starts, "They have turned."
record, please.
Scientology principles by demanding no ethics be applied |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
to them or by them."
fall within the scope of this paragraph?
he?
as well, hadn't he?
stuff applied on me, didn't he?
instance that came to mind that would fit within that paragraph but, yes, I would suppose so.
the past credentials and accomplishments of L. Ron Hubbard would fall within the scope of this paragraph, wouldn't it?
than this one.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
old. I don't know. I would guess it would seem so.
the commanding officer of OSA International?
the settlement agreement --
what I was going to say -- ask you whether or not this is all right with you, I want to ask you questions about the meaning of people adverse to or aligned against Scientology.
front of me --
refresh.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
"Plaintiff agrees that he will not voluntarily assist or cooperate with any person adverse to Scientology in any proceeding against any of the Scientology organizations, individuals or entities listed in paragraph one above."
understood that you already went through all this before on prior days; is that right?
person, adverse to Scientology," was it the intent of CSI to include within the scope of that someone who was not in agreement with Scientology's aims?
answer it the other way.
they just don't happen to agree with us, no, it would not fit. |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
sentence of paragraph G is, "Any person who is either a plaintiff or defendant or intending to become one," like in actively proceed toward becoming one in litigation or arbitration.
agreement?
conclusion.
why or why not --
way it was written.
Scientology in any proceedings against any of the Scientology organizations."
parties is with respect to one of the central provisions of the agreement.
the intent, but you're not asking intent, you're asking |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
the witness why he didn't put some language in there. I'm not certain that he was the only author of this. And it is a document that apparently was drafted in collaboration and is an end to litigation. And so why someone didn't do something else I don't believe is an appropriate question. You can certainly ask what the meaning was.
litigation where Armstrong testified as a witness, he was adverse to Scientology, was he not?
this first sentence of paragraph 7-G.
was that no person -- that Armstrong should not cooperate with any person who was a party to litigation with Scientology; is that right?
Greene, so don't put words in his mouth.
Bowles. That's hardly --
You've already got an answer to that question.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
posited that hypothetical I could think of an instance where it could apply more broadly, such as if you have someone like Margaret Singer who for a short time made her living testifying in certain Scientology cases, were he to actively assist her to do so, I think it would actually fit within the parameters of this. Although it is largely intended to cover plaintiffs and defendants -- future plaintiffs and defendants, those who are proceedings in that direction.
to that, was it?
assistance then in that circumstance requires amendment because it's not -- if he changes Margaret Singer's flat tire on the road, that would not violate the settlement agreement, but that would be assistance.
further her testimony, hypothetically, that would have.
be modified.
activities as would be specific to the provision of information that Armstrong derived in connection with his experience in Scientology; right?
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
derived it from. It also encompasses acts which aid the person in the proceeding against Scientology, as is modified later in the sentence.
paragraph 7-G is that the intent of that paragraph is not strictly limited to precluding Armstrong from assisting thosewho are parties to litigation with Scientology; is that right?
broader than that.
the extent of their anti-Scientology activities; right?
proceedings against, so it would have to be in that context in this --
practices, would that person be adverse?
would, I think, view themselves as being adverse, but adverse as it applies to this paragraph, I don't know because it requires other factors. |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
to take a general proposition try and shoehorn it into this paragraph when it has clearly a different definition in this paragraph than it would as a general proposition because "any person adverse to Scientology" is modified by "in any proceedings against any of the Scientology organizations," blah, blah, blah.
a proceeding. And is a person who is critical of Scientology considered to be adverse thereto?
litigation?
an intelligent answer.
I think what you're asking me is would they fit within paragraph G of the first sentence. It would require additional factors to be able to determine that.
to determine that? A. They would have to be taking some act, either as a |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
hostile reporter, and then there would be the provision concerning media, or as a party to the litigation, or even as an expert witness to the litigation on the side opposing whatever Scientology organization was, by way of examples.
hypothetical. It's more easily dealt with in the concrete. And it's also more easily dealt with, if I may say, from the conceptual viewpoint of separating one's self from having anything to do with Scientology whatsoever. Then the hair-splitting and the walking the edge of the line just don't come into play because the subject of aiding an adverse litigant just doesn't come up, or, gee, does it count if I help this witness but not the plaintiff, is that really helping the plaintiff. That kind of hair-splitting just doesn't come into play. So it's more easily interpreting within the overall spirit of what this was intended to be to begin with.
in any kind of litigation having to do with Scientology, in part; right?
to the beginning of time.
in any kind of public discourse or debate with respect to |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
the conduct or beliefs of Scientology; right?
respond to a request for help?
paragraph 7-G.
in.
contractual provision?
cooperate is.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
application to any drafting or draft or construction of contractual provisions.
question.
I'm not going to have a general definition shoe horned in to a word that is used with precision in this subparagraph in a slightly different manner. Just as you're not going to do that, I'm not going to allow you to play word games because we'll get an incorrect record here. It will be misleading, and you wouldn't want that:
questions, Mr. Greene.
whole lot of speeches by your client, Mr. Bowles.
question and get on with the litigation.
that's your problem.
MR. WALTON: If you have an objection, why don't you make your objection and let's have a rule on it instead of pitter-patter. |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
cooperate presuppose a request for help?
Q. Mr. Farny, the last sentence of paragraph G does not restrict plaintiff with respect only to litigation, does it?
agreement?
against Scientology.
any practice of Scientology, would such organization be considered to be aligned against Scientology?
to be on the opposite side, opposed to, seeking to destroy.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
declares itself to be opposed to Scientology openly and vociferously, that means that it seeks Scientology's demise, is that what you mean?
explaining in expansive terms here that we're not just talking about some mild ill will, we're talking organizations aligned against Scientology.
consider to be mild ill will.
consider to be mild ill will.
things and comes to an interview with a negative view but responds to the truth, comes away with an objective view, that sort of thing.
to Scientology, would you consider such organization not to be aligned against Scientology?
which is the equivalent of such an open declaration, obviously.
view would bring an organization into the scope of the language of it being aligned against Scientology be |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
included in the definitions of what is suppressive organizations?
paragraph 7-G, is it required that such organization be formally established?
sentence as -- were you talking about the last sentence, Ford, just to clarify?
sentence. The sentence doesn't seem to express such a requirement.
participated in the creation of this document to not require the definition of organization to necessarily apply to something that's formally organized?
unincorporated associations, partnerships, companies, and to a large degree, to some degree, certain governmental agencies of different -- different countries, which have from time to time acted in this manner.
that out? |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
group involved in compiling the papers.
organizations that were considered to be aligned against Scientology be spelled out?
that we didn't want to limit it in that manner and we wanted it to be as clear and comprehensive as possible.
agreement to be as clear and as comprehensive as possible, was that also part of the basis why the language was picked otherwise in paragraph G of the prior sentence about non-cooperation with any person adverse to Scientology?
rest of the sentence there.
encompassed with sufficient clarity and as clearly as it could be expressed at that time.
that which we were at that time in the process of coming to an agreement on, which was a cessation of participation on Gerry's part in the litigation wars as they were ongoing at the time and the attendant fallout activity |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
thereto.
defined terms so that it would be perfectly clear what that agreement was, you see.
encompass as many situations as possible, some of which you recognized you probably could not foresee?
want it to be susceptible to hair-splitting which would circumvent the intention of the agreement. And the breadth allows for a sufficient degree of comfort so that it wouldn't be that hair-splitting, or at least so we thought at the time.
was communicated at the outset to Flynn when serious settlement negotiations commenced in the summer of '86; right?
thereafter, it certainly was an important consideration from as close to the get go as my recollection allows it to be.
paragraph 7-H where plaintiff agrees not to testify or otherwise participate in any judicial, administrative or legislative proceeding adverse to Scientology?
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
sufficiently clear and sufficiently broad so as to correctly reflect that he's getting out of the business, quote unquote.
thereafter of settlement negotiations in the summer of 1986?
against us anymore; right?
know, to agree to something like that. I mean, the courts have their own say in it and if a court orders somebody to testify, of course they have to testify. But insofar as the career that they all embarked on of being professional witnesses against the church without regard to the facts of the case, yes, we wanted them to seek another career that did not involve being professional witnesses against Scientology --
to the immediate dispute at hand, they had bigotry and prejudice to spread from eons past, as it were.
listened to that, didn't it? |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
Fortunately some others did not.
reference to was Sullivan; right?
him.
cases as some of the others.
in this dog and pony show. But we wanted as clean a break as possible so as that they wouldn't want to become active participants in the dog and pony show.
anything other than the litigation he was involved in in |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
Boston.
settlement negotiations with Michael-Flynn in the summer of '86, was the objective communicated to Flynn that Scientology did not want any of the members of his dog and pony show to go into some jurisdiction so as to make themselves able to be served and then consequently compelled to testify?
not. What was expressed at the outset was we wanted them to make a clean break.
came. And that concept entered in somewhere along the path that, all right, they've made a clean break, they would, of course, have to be subpoenaed. However, but we don't want them going out of their way traveling into jurisdictions to be subpoenaed because that defeats the |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
clean break concept. So how do we come up with some language that expresses that?
the process that was definitely brought up.
the process when that concept was brought up, was it the beginning, middle or end?
towards more the particular expressions more towards the middle, but are closer to the beginning, I think.
turn, conveying this idea of non-amenability to service of process to his clients; right?
to the other contents of 7-H about not agreeing to testify in any judicial, legislative or administrative proceeding unless subpoenaed; right?
provisions with respect to non-assistance to his clients, as well; right?
communicating all of these provisions to his clients.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
and said with respect to any of them, no way, my clients won't do it?
Gerry would have a hard time with we can say whatever is needful and he can't say anything. And that was the subject of some serious discussion towards the latter few weeks.
to is the notion that Scientology related organizations would be free to characterize Armstrong according to the truth and Armstrong would not be free to so respond to whatever such characterization might be; right?
his statements had gone out there and the need for communicating on that, you know, so yes.
confidentiality provisions were not mutual; right?
the terms of the agreement, as to any amounts of money that exchanged hands and such. But in terms of Gerry not speaking of Gerry's experiences in Scientology, that last term was not mutual. We could speak of Gerry and his experience with Scientology. And that was important at the time, considering the use to which his statements had been made. |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
litigation, Department of Justice, IRS, et cetera?
provisions were mutual; right?
our part on making statements, because most of the statements that were out and about that other people were using concerned past activity, so we could say that.
in any future proceedings. What would be relevant and at issue which would be just post settlement conduct.
is the post settlement conduct.
talking about the current litigation brought by CSI against Armstrong; right?
an hour and I notice the court reporter is getting tired.
settlement agreement, part of the intention of that |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
settlement agreement was to dispose of Armstrong's pending cross-complaint against CSC; right?
sometime within the first two months of 1987, wasn't it?
matters which pertained to the cross-complaint; right?
Cazares.
right?
with Scientology setting him up with a lawyer that they actually controlled, wasn't it?
Benz, we are going far afield here with other litigants, other circumstances that do not concern this case. MR. BENZ: At this point I would agree. What's --
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
before I do that.
and to the motion for protective order brought by Lawrence Heller.
Armstrong was served with the civil subpoena to testify in the Yanny trial; right?
I believed concerned, in part, Gerry's deposition.
motion for protective order. This was the hearing on that motion, wasn't it?
representing Armstrong adverse to CSI?
circumstances.
you go back and talk to your superiors and they tell you |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
what to say?
and looking at the fifth paragraph under the list of names on page one, would you read that paragraph into the record.
principles over Scientology principles in their misrepresentations to Department of Justice representatives, as well as Boston lawyer Michael Flyyn."
scope of the assertion that you just read would be the claim that Scientology was psychologically harmful to some people?
that.
written on the page.
paragraph applied to Gerald Armstrong; right?
paragraph that starts, "Several of them have spoken out."
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
record.
Scientologists in good standing to the IRS in a hope that they might escape from their own destructive acts and shift attention from themselves and their crimes."
paragraph; right?
own destructive acts and s hift attention from himself and his crimes?
about overts and overts against mankind and their only road out of this universe as set forth in the third paragraph?
paragraph that we're talking about here, the one that starts with "several of them have spoken out" is another way of describing what is set forth in the paragraph that mentions the overts; is that right?
wouldn't be able to separate them apart as I sit here.
and assisted in the alteration of tech in an attempt to |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
seal off the bridge to those who have fallen prey to their destructive intentions."
certain how much active squirreling he was involved in. This, of course, directly applies to Mayo and Vogerdeen and Nelson because of their activities at the Advanced Ability Center.
anything specifically by Armstrong that would fit in this one.
Scientology technology to other people in an unauthorized manner, such assertions do not apply to Armstrong as a general matter, do they?
the circumstances in September of '84 whether that would fit with him.
that, I don't think so. I don't think he is. He's just, from what I know, gone either farther -- I've lost the word -- apart from what would be Scientological |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
principles. You know, he's -- I've seen a letter from him with either Buddism or yoga type concepts in it. So I actually don't think he's involved in this at the present. I don't know if I'm wrong or not.
adoption of Buddism precepts takes him even further away from Scientology than he was before, is that what you meant to say?
squirreling of Scientology, which this is referring to, it's just a different subject matter. Roman Catholicism, Hinduism, Judism, it's just a different subject matter. And he's entitled to pursue whichever religion he believes in. I wouldn't call it squirreling because it's not an alternation of Scientology.
least in part is intended to describe those who, without authorization utilize Scientology technology; right?
round and round there for about ten minutes at a time, as well. Squirreling is the alteration and/or attempted |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
rip-off of Scientologist's technology.
Scientology, though; right?
courses; right?
correct, because he's not in good standing with the church.
starts, "Their continued harmful acts," would you read that in the record, please.
their continued desire to drive others to the level of beasts and animals devoid of spiritual qualities places them in the psychiatric camp of those who manufacture madness for profit."
means?
record also.
spiritual destruction and cries for no ethics, no morals and no policy have separated them from the body of the |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
ethical and practicing Scientologists of this planet."
just read drew a strict line whereby the persons who were the subject of this directive were placed on one side and Scientologists on the other?
drawn --
had renounced and sought to destroy. Of course they were on the outside of that group. They were no longer part of it. They had renounced it. They had taken acts seeking to destroy it. So of course they weren't part of it anymore.
Exhibit 3.
yourself the Scientology creed.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
section there where it says, "And we of the church believe that the laws of God forbid man to destroy his own kind, to destroy the sanity of another, to destroy or enslave another soul, to destroy or reduce the survival of one's companions or one's group."
destroy or reduce the survival of one's companions or one's group, that includes the definition of an overt that you gave to us earlier, doesn't it?
definitions?
technical dictionary that you read into the record earlier comport with the tenant of the creed that says that those in the church believe that the laws of God forbid man to destroy or reduce the survival of one's companions or one's group? |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
to this, Mr. Benz, because I think we're a little far afield, to say the least, of this lawsuit.
discussion with the witness, on the meaning of now the Scientology creed, which is a part of the ecclesiastical writings and teaches along with the definitions and in another published volume. I think we're far afield. I think it's a waste of time and I don't think it's relevant.
motive. These are the very bylaws of CSI that's a party to this lawsuit.
nothing in this section of bylaws, having heard the definitions in the technical dictionary before, that are going to have much relevance in connection with this particular suit, as far as I can see.
specifically.
offer of proof or connection?
Exhibit 15, which is the executive directive having to do |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
with squirrels and what the conduct was of Armstrong, that fell within the definition of the third paragraph underneath the list of names. The witness testified as to the meaning of overts, confirmed that the overts as used in Exhibit 15 comported with the definition of an overt or definitions of an overt act as set forth in the technical dictionary. And depending -- which are all relevant to Armstong's affirmative defense of unclean hands and affirmative defense of duress and undue influence. And directly relate to the pending question which is focused on specifics of the creed as set forth in the bylaws of CSI, which is the plaintiff in this lawsuit, and which this witness has been designated to represent. And it 's right on and relevant.
church believes that the laws of God forbid man to destroy or reduce the survival of one's companions or one's group, so I don't see that that goes to any motive of malice or anything else.
he believed that what Armstrong's acts have done is to do
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
directed at the destruction of Scientology, that Armstrong's repeated, often repeated falsehoods and misrepresentations about Scientology and about its founder are all directed at the destruction of Scientology, and that's -- Scientology is the group that's referred to here. It's directly relevant.
discussing that, it's okay, but I don't think going into a generalized language of a creed adds anything to it, so I'll sustain the objection.
forth in the bylaws of the very organization that's prosecuting this lawsuit? It's not a generalized question about Scientology, it's specific to the plaintiff in this lawsuit and to its bylaws that it has produced in discovery. MR. BENZ: I don't see the connection, this portion of the creed with what you're talking about on these other items.
creed, "We of the church believe," are there -- starting on page 17 where it says "We of the church believe" and |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
going through to page 18, up to the point where there's the next capitalized sentence or phrase, and looking at the subject matter in between those two, my question to you is on whether or not there are any tenants which are not adopted by CSI currently?
set forth in our bylaws?
expression of the bylaws?
question, the answer to your first question is no. The first question, was there anything in there that we haven't, and then you, rephrased it to is this the current expression.
says, "We of the church believe that the laws of God forbid man," and then there are those items that are enumerated. In your view is it, or in the view of CSI somebody destroys his own kind or destroys the sanity of another or enslaves another's soul or reduces the survival of their companions, does that put the person beyond the law of God?
It would be an act which would be in violation and -- not even in violation, that's not the right word. It would be |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
inconsistent with the creed of the church, which is something one would try to live by.
happening to do something that was inconsistent with that, the act would not be correct, the act would not be good, but the individual wouldn't necessarily have renounced the creed because he screwed up, basically.
that. Nobody's perfect.
line of questioning. I think he's droning on with philosophical discourse that hate nothing to do with the lawsuit.
deliberate and intentional course of conduct, then would the view be that such person would be beyond the laws of God?
merely mean he would have renounced this as a creed to live by. |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
have renounced would have been the inalienable right to think freely, talk freely, write freely on their own opinions, or to utter, or to counter or utter or write upon the opinions of others; right?
which is the squirrel document --
Q. -- where would all of the information supporting the assertions in Exhibit 15 that apply to Gerald Armstrong be stored?
old. I have no idea.
have an accurate idea?
collection of documents that was compiled to support this, rather than information existing within the general body of information that has grown up over the years concerning the Armstrong litigation.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
several of the cases and find instances to support the statements that apply to him. Whether such a body of compiled knowledge exists or even existed at one time, I have no idea, and that's what I meant by I have no idea.
document originated, is it that it originated based on a generalized opinion of Armstrong within CSI or was it based upon documents?
part of Gerry Armstrong and the others mentioned here. I don't know if there was a specific package of information compiled annotated to each line or whether it was taken from the general body of knowledge and specific acts that Armstrong engaged in that gave rise to this. I just don't know.
that this document originated whether or not there was any kind of body of written material supporting the claims set forth in Exhibit 15?
own body of documents as opposed to whether there existed at all documentary to support for any of these? I think you're referring to the former, aren't you?
|
| 447 | |
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
version of this issue? I have no recollection of having done such.
collection of documents in support of a declaration such as is manifested in Exhibit 15?
to offering a threat to Scientology, the greater the documentation as a general rule of thumb; is that right?
more important?
course of conduct that was -- strike that.
determined whether or not to support claims made about an individual who was designated as a squirrel?
written materials that were correlated together that supported a claim such as are made in Exhibit 15; right? |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
directives specifically, would have annotated packages that go with them, with the documentary support.
eight-page document, which is entitled HCO policy letter of 21 November, 1972.
something in particular?
you not?
does that appear, to your knowledge, to be an accurate definition of black propaganda?
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
a campaign of black propaganda against Scientology?
portions of that, yes.
December '81 and his first act and the time after December '86 up until his first act after that.
sometime, late '89.
making reference?
days.
sequence.
Armstrong, what did he do?
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
believe, he was spreading black propaganda, spreading lies.
that he spread were given under penalty of perjury in the course of the legal proceeding?
in this country and abroad.
to Handle Black Propaganda. I haven't read this one word for word to make a comparison.
need to tell me, at least generally, it comports with the policy letter with which you are familiar?
authentication.
you've got time to do just the word by word comparison.
letter, yes.
|
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
entitled HCO policy letter of 11 May, 1970.
familiar with it; two, whether or not it generally appears to be an accurate copy of that with which you are familiar.
copy of this policy letter, yes.
at the middle of the page where it says, "Intelligence is covert," and then, oh, I don't know, about five, six lines down where it says "Black propaganda is in its technical accuracy a covert operation where unknown authors publicly affect a derogatory reaction and then remain unknown."
in the other policy letter that you've had me read of black propaganda.
Armstrong, would it?
that I just read and I am directing your attention to, that would not include Armstrong, would it? |
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
last decade since he left?
hidden from us, and his desire at that point to infiltrate into the organization and to quote him at that time, "to spread chaos and destruction."
to be a black propaganda campaign. That's what he was attempting to do, including the phonying up of forged issues that would be planted in our files. So yes, I would say that's one example, certainly.
issue, Exhibit 2 would be characterizable as an issue, wouldn't it?
here you've gone through Exhibits 1 through 20. And would |
|
453
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
you tell me which Exhibits of 1 through 20 do not constitute issues?
using.
colloquialism so that we're clear in the sense that you were using it.
communication of the church on paper that would exclude books.
data as -- in one of the official forms of communication. HCO policy letter, HCO bulletin, ethics orders, executive directives and such.
there are less of them, which of Exhibits 1 through 20 are not issues.
taken, although the individual documents within, in which case I think there's only one here, would be an issue.
five-minute break.
|
|
454
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
conclude today's session and resume tomorrow morning at 9:30.
stipulation for these transcripts that the original is coming to the witness?
put on the record.
before.
I'm fine with that. I don't care.
---o0o---
thereof.)
|
|
455
|
|
|
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 |
and for the State of California, do hereby certify:
was present and duly sworn to testify the truth in the within-entitled action on the day and date and at the time and place therein specified;
me in shorthand and was thereafter transcribed under my direction into typewriting;
correct transcript of said deposition and of the proceedings which took place;
and, if necessary, correct said deposition and to subscribe the same;
action;
hand this 8th day of August 1994.
|
|
§ What's New || Search || Legal Archive || Wog Media || Cult Media || CoW ® || Writings || Fun || Disclaimer || Contact § |