Reporters' Daily Transcript (May 24, 1984)

Armstrong 1





No. C 420153


Thursday, May 24, 1984


Pages 3000 - 3194, incl.

(See Volume 15)
Official Reporters

INDEX FOR VOLUME 19 Pages 3000 - 3194, incl.


3000-F   3013-L
(Resumed) 3014-F    
(Resumed) 3111-F   3136-H
(Resumed) 3137-F 3151-H  


76 - Laurel Sullivan Application 3156
77 - Laurel Sullivan Contract 3159




THE COURT: All right, in the case on trial let the record reflect that counsel are present.

LAUREL SULLIVAN, the witness on the stand at the time of the adjournment, having been previously duly sworn, resumed the stand and testified further as follows:

THE COURT: The witness has retaken the stand. Just state your name again for the record, ma’am. You are still under oath.

THE WITNESS: Laurel Sullivan.

THE COURT: You may continue, Mr. Flynn.

MR. FLYNN: Thank you, Your Honor.


Q Miss Sullivan, in 1970 what was your post?

A I was the LRH Comm and the Supercargo Secretary.

Q What is a Supercargo?

A It is a Sea Organization title for the Hubbard communication office executive secretary.


Q And after you held that post what, if any, post did you hold?

A In 1971 I returned to the ship and was the director of processing for the Flag administrative organization. From there I became the LRH communicator Flag.

After that I returned to Los Angeles for four months and was again the super cargo and senior to the LRH communicator.

Q On board the ship were you the director of processing?

A Yes.

Q What is a director of processing?

A It is the head of the department of processing in the technical division. And it supervises the auditors and auditing processing. And it liaises between the auditors and the case supervisor and takes care of the administration of the files.

Q When you say “the administration of the files,” what files are you referring to?

A The pre-clear folders.

Q And that was in 1971 that you held that post?

A That was — yes, the summer of 1971.

Q Now, did you have an understanding from the time you joined Scientology up until the time you began director of processing as to what processing files were?

A Yes.

Q what are they?

A They are auditing folders.


Q And throughout your period in Scientology up until 1981 was there any question in your mind as to what processing files were?

A No.

Q Never?

A No.

Q To your knowledge is it common knowledge among Scientologists that processing files are auditing files?

A Yes.

Q And between — in the year 1969 was that common knowledge?

A Yes.

Q Now, did you become aware that processing files were being culled to get persons’ crimes?

A Yes.


Q And when did you become aware of that?

A In 1971.

Q And under what circumstances did you become aware of that?

A Well, while I was the Director of Processing in the Flag administrative organization, which was the onboard personal staff organization, there were two executives, John Horwich and Amos Jessup who apparently were not doing a good job. The LRH personal PRO at the time, Sylvia Calhoun, came and interviewed me and asked me if I would take the position of the LRH Communicator Flag and said I would do so.

When I went for my first briefing with L. Ron Hubbard, he told me that John and Amos were not in very good condition, and I was present when he said to one of the technical staff, “Get his crimes.”

Q And what did that mean?

A It meant go through his folders or his confessional and find out what he had done to transgress against the organization or him.

Q For the rest of the years that you were involved in Scientology did you know it was a common practice to cull folders to get people’s crimes?

A Yes. I also participated in that at times.

Q And when did you participate in it?

A In 1977.

Q And under what circumstances did you participate in it?

A When staff wanted to leave the organization and


were being asked to sign their crimes, at times there was an overload and the public relations person, who was my husband at the time was overloaded, and I assisted him in going through folders and preparing the documents for people to sign.

Q And were people required to sign these documents?

A Yes.

Q And what documents were they required to sign before they could leave?

A A list of their transgressions against the organization or any embarrassing or illegal activities that they might have been involved in, in or out of the organization.

Q And to your knowledge were other documents such as promissory notes, releases and nondisclosure bonds
also required to be signed?

A Yes.

Q And was there a practice of retaining a person’s belongings if they tried to leave the organization?

A Yes I have seen that, but not in every case.

MR. FLYNN: Now, for Your Honor’s information, we have an affidavit coming in, so before I get into some of the financial transactions I am going to wait until the affidavit arrives so the court can see it.

THE COURT: All right.

Q BY MR. FLYNN: Now, Miss Sullivan, on board the ship was there a practice of drilling to tell lies which euphemistically was called the Shore Story?

A Yes.


Q And what was that?

A Well, they were PR drills that were done on every incoming student or staff member, and there was a PR pack in the port captain’s office, and as one traveled through the routing form to become situated as a staff member, there were checkouts done on the materials in that pack, and that was like a hat pack or an orientation pack for an incoming student or staff member which explained what you said and what you did not say and one was drilled according to the story at the time.

Q Now, with regard to your period on board the ship, how long did you remain on board the ship?

A Well, off and on from 1967 until 1975.

Q And at various points during that time period were you sent out on missions by L. Ron Hubbard?

A Yes.

Q And you described one of them yesterday. What other missions did L. Ron Hubbard send you out on?

A Well, I did the one to AOUK which was a long-term mission called the Garrison mission.


I did the one to Los Angeles and then a repeat one to Los Angeles.

I did some local ones. I am not familiar with them all from the ship. I have done them. I have done probably 16 or 18 over the whole time I was in Scientology.

Q And who sent you on these missions?

A Well, there would be a briefing officer who briefed you and sometimes you would get a chance to talk to L. Ron Hubbard or sometimes you would not. Sometimes he would send notes down; sometimes he would do an evaluation and you would read that evaluation if you were the one selected to go.

Q And, for example, the LA mission was to rejuvenate — bring up the gross income of a LA organization?

A That was basically it.

In that particular case that was one mission which was briefed, written by him, briefed by him and monitored by him for a number of months.

Q Now, without going through all of the posts and all of the missions that you held, at one point you became the senior Pers PRO of L, Ron Hubbard?

A Yes.

Q When was that?

A That was in November, 1973.

Q Just prior to that time had you held a post in the Hubbard communications office?

A Yes.


Q And who was your senior in that office?

A Kima Douglas.

Q At some point in 1972 did you have a briefing session with Kima Douglas as to a mission she was going on?

A Yes, I did.

Q What was that, Miss Sullivan?

A I was requested by her to fill in on some of her duties when she went on a confidential mission.

She said she was going to Liberia to set up the Religious Research Foundation; that she had been briefed on it by LRH and that she would be back within the week.

Q And did she tell you what the purpose of setting up the Religious Research Foundation was?

A Yes. She did on her return. And that was to make sure that LRH got paid.

Q Now, thereafter did you meet with many Scientologists on board the ship who were receiving courses at what was called Flag on board the ship?

A Yes.

Q And did you learn at that time what corporations those individuals were paying money to?

A Yes.

Q And what did you learn?

A Foreign Scientologists were paying money to Religious Research Foundation.

Q Now, what corporation, if any, was delivering the services on board the ship that these people were paying for?


A Well, that seemed to shift. But the final story was that the Church of Scientology of California was delivering services on board and had chartered a portion of the vessel from OTC.

Q When you say, “it seemed to shift,” what do you mean by that?

A Well, it wasn’t clear to me all of that time whether it was OTC or the Church of Scientology of California.

Q Why is that, Miss Sullivan?

A Because there wasn’t any emphasis on it.

Q What was the shore story with regard to who was running the ship?

A Operation Transport Corporation.

Q Who was actually running the ship?

A L. Ron Hubbard.

Q And were there drills while you were on board the ship to conceal the fact that the ship was connected at all to Scientology?

A Yes.

Q And was that a regular — a routine thing?

A Yes.

Q Scientologists coming on board the ship, what were they drilled on as to their involvement in receiving courses on board the ship?

A Well, they were drilled that they were executives and they could tell about their backgrounds and tell the truth. But they weren’t to mention Scientology. So they


were creating an image that they were really corporate executives from wherever they were from; that they were there receiving business management training from Operation Transport Corporation, which was a business management consulting firm.

Q Was that a shore story?

A That was it in a nutshell.

Q Was that the truth?

A No.

Q What was going on?

A In fact they were staff members from the Churches of Scientology around the world. And in fact, they were there receiving religious counseling and training.

Q When you say “counseling and training,” these were courses prepared by L. Ron Hubbard; is that correct?

A Yes.

Q And what, if any, understanding did they have as to where there — the monies that they were paying was going?

MR. HARRIS: I’ll object to that, Your Honor.

THE COURT: I’ll sustain the objection to the form of the question, what they were told.

If she knows, she may testify. But what they personally understood would be a conclusion.

Q BY MR. FLYNN: Yesterday Mr. Harris marked an exhibit from “The Auditor” which is exhibit 74; with specific reference to the third Xeroxed page, “What your fees buy,” do you recall that, Miss Sullivan?


A Yes.

Q When did you first see “What your fees buy”?

A Probably in 1970 or ‘71. I think I remember the first issue of it.

Q Do you know who wrote it?

A L. Ron Hubbard.

Q And when you became the senior Pers PRO was there a public relations line about whether L. Ron Hubbard was receiving any money from the church?

A Yes.

Q What was that?

A That he never drew a salary.

Q And was there any other public relations line with regard to whether he had forgiven debts?

A Yes, there were several.

Q What were they?

A That he had forgiven a debt of thirteen and a half million dollars of monies owed to him, as it says here; that essentially, he had not collected monies that were due from the church and that he didn’t collect any money due him for research and that he had paid for it all himself.

And during my time it was that he only collected off his author’s royalties.

Q Now, is there even a suggestion in “What your fees buy” that he never even collected royalties?

MR. LITT: I object. The document speaks for itself.

THE COURT: I’ll sustain the objection as to her interpretation of the document.


Q BY MR. FLYNN: Now, was there a public relations line about whether he was receiving less funds than an Org staff member from any Churches of Scientology?

A Yes.

Q And when was the first time — was it in 1970-1971 that you first heard about this public relations line?

A Yes.


Q And was that public relations line true, Miss Sullivan?

A No.

Q And was he receiving funds from Churches of Scientology?

A Apparently so. From 1972 is from when I am most familiar with him receiving funds.

Q And was that when Religious Research Foundation was created?

A Yes.

Q New these people coming on board, to your knowledge they were making their checks payable to Religious Research Foundation?

A Either that or they were making checks payable to someone who transferred them to the RRF account.

Q Now, did the Religious Research Foundation deliver any goods or services of any nature or description on board the ship?

A No.

Q And what was the Religious Research Foundation?

A Essentially it was a bank account.

Q And who were actually delivering the goods and services on board the ship that these people were paying for?

A Church of Scientology of California.

Q Or the people on board the ship; is that correct?

A True.


MR. LITT: Your Honor, if I may, I would like to establish the foundation of her knowledge. So far, other than asking –

THE COURT: Well, you can take the witness on voir dire.

MR. LITT: Thank you, Your Honor.


Q Miss Sullivan, the testimony that you have just given, what contact in the year 1973 did you have with RRF accounts?

A I spoke to Vicky Livingston who was L. Ron Hubbard’s accountant at the time.

Q So your knowledge is what someone else told you?

A Yes.

Q Did you ever handle the account yourself?

A No.

Q Did you review the books?

A No.

Q Did you write any checks?

A No.

Q Did you bank any checks?

A No.

Q Is the same true for the remaining years on the ship?

A Yes.

Q What you know is what someone else advised you?


A Yes, and information that I supplied that person.

Q And is the same true for the following years?

A No. We get past 1980 there.

MR. LITT: Your Honor, it is quite clear that whatever information which is being stated as facts is the result of hearsay statements made by someone else, who by the way is under subpoena in this case apparently, and this witness is not competent to be answering questions did RRF do that, do this? Did it do that? what did it do with money. She has no personal knowledge by her own testimony. This is strictly which she was told by someone else.

THE COURT: Well it appears to me that she’s being told these things by agents of L. Ron Hubbard or of the Church of Scientology who apparently appear to have knowledge of what they were talking about or talking in the course of their business, and were presumably authorized to discuss these things with her because it was part of their business operation, so the objection is overruled.


Q Now, Miss Sullivan, just to wrap this area up or cure this problem in this area.

Did you liase [liaise] with this person Vicky Livingston in your capacity as Senior Personal PRO and in her capacity as LRH accounts?

A Yes, and it should be mentioned also that L. Ron Hubbard, himself, told me he was paid from there.


Q He told you that directly?

A Yes.

Q And at some point did a reorganization in the senior personnel public relations office take place?

A Yes.

Q And when was that?

A That was in November and December 1973.

Q And you were the head of the office at that time?

A Yes.

Q And what was that reorganization?

A It was a reorganization of the personal PRO bureau done in liaison with LRH accounts and his personal secretary, and it was an establishment of what his publics or his audiences were, and they were prioritized according to his income sources.

Q Now, when you say what his publics were, does that mean where his income sources were?

A Essentially, yes.

Q And did you yourself prioritize, as you put it, those income sources?

A Yes, in liaison with Vicky Livingston.

Q And did you obtain from Vicky where his sources of income were in order to prioritize those income sources to promote them in the public relations office?

A Yes.

Q And how did you do that?

A Well I was instructed on the central office of


LRH ED No. 2 to liase with her in collecting the categories of income and to name them as publics as a market segmenting or as a grouping and categorizing people who received information from him and from which income was generated and how he was remunerated from those publics, and we came up with five basic categories, and from there we were instructed to put them specifically on cards, after which when I had them in sequence, I was to send them to L. Ron Hubbard and he would approve them.

Q And did that occur?

A Yes.

Q What were those five categories?

A Staff internal.

Q What did that mean?

A That meant aboard the ship.

Q Meaning that is how L. Ron Hubbard was deriving income from people on board the ship?

A Well, their activities in the long run remunerated him.


Q Okay. And what was the next category?

A Staff External.

Q And what did that mean?

A That meant anyone not on board the ship that was a staff member.

Q And what was the next category?

A Scientologists International.

Q What was that?

A That was anyone taking training or processing in an organization or buying books.

Q And did you categorize that as public paying Orgs?

A Yes.

Q And what did that mean?

A It meant people getting a service from the organization and paying into organizations or buying books.

Q And this was categorized as a source of L. Ron Hubbard’s income; is that correct?

A Yes.

Q And what was the next category?

A Professional people.

Q And what did that mean?

A That meant it was a category No. 4, an income priority No. 4 where he might have an association with a non-Scientologist professional person who may or may not generate income for him or with him such as a movie director or someone that he might collaborate with on business affairs.


Q What is the next category?

A Personal acquaintances and friends and family.

Q How did he derive income from that category?

A Not much directly; on the personal acquaintances, some of them were old friends; some of them he had
written articles for.

That was category No. 5, the lowest priority.

Q The first category was Staff Internal; is that correct?

A Yes.

Q Now, when you — and you received information from Vickie Livingstone from LRH accounts as that being the primary source of potential income for Mr. Hubbard?

A Yes. We worked that out together.

Q Now, at that period of time did you have a briefing session with Vickie Livingstone with regard to retroactive billing to RRF for L. Ron Hubbard’s income?

A Yes.

Q And what was that?

A I asked her how she was managing to keep his income flowing while he was away during the previous year. And she told me that there were retroactive billings, meaning billings for services done prior to the creation of RRF.

Q Now, when you say a period of time that he was away, do you know where he was?

A In New York.

Q And in terms of people actually coming on board,


did you have personal knowledge that people were making checks out to RRF?

A Yes.

Q And let’s focus now on who was providing the goods and services on board the ship to these people who were paying this Religious Research Foundation.

They were crew — people who signed on as crew members on board the ship?

A No. They were public people arriving for services.

Q Those are the people who were paying for them?

A Yes.

Q Who was delivering the services?

A staff and crew there.

Q And who did the staff and crew work for?

A L. Ron Hubbard.

Q And what was the shore story as to who they worked for?

A Operation Transport Corporation.

Q And in the overall structure of things, were they in a general sense staff members of Churches of Scientology?

A Yes.

Q And were they being paid wages?

A Yes.

Q And who was paying their wages?

A I think it shifted from time to time. But for the most part, OTC.


Q And when you were on board the ship did OTC pay your wages?

A Yes.

Q And you received wage payment vouchers that said OTC on them?

A Yes, for a time.

Q And you also received blank wage payment vouchers; is that correct?

A Yes.

Q Now, from that time up to 1980 did you have an ongoing liaison, as long as you were senior personal PRO with the LRH accounts office?

A Yes.

Q And from 1972-’73 up until 1980 did you understand that it was an ongoing practice for foreign Scientologists to pay money directly into RRF accounts?

A Yes.

Q And was there a shore story with respect to RRF, or was that a hidden account to the public and other staff members on board the ship?

A It was considered confidential; not everyone knew about RRF.

Q Did people who were paying the checks ask what Religious Research Foundation was?

MR. HARRIS: Ask this witness, Your Honor?

THE WITNESS: I don’t know.

THE COURT: Let’s let the answer stand.

THE WITNESS: May I take a break, Your Honor.


THE COURT: Certainly.

THE WITNESS: For five minutes?

THE COURT: Okay. We’ll take a five-minute break. (Recess.)


THE COURT: All right, let the record reflect that counsel are present. The witness has retaken the stand. Just state your name again for the record.

THE WITNESS: Laurel Sullivan.

THE COURT: You are still under oath and you may continue, Mr. Flynn.

MR. FLYNN: Thank you, Your Honor.

Q Now you testified, Miss Sullivan, that prior to 1980 you were aware of the purposes and connection of RRF to L. Ron Hubbard; is that correct?

A Yes.

Q Just yes or no, after 1980 did you learn the amounts in the RRF accounts and where these accounts were located?

A Yes.


Q Now, what essentially were your duties as a senior personal public relations officer of L. Ron Hubbard?

A My first duty was to assist LRH in his activities in production. And that was stressed routinely as my first duty.

Q What does that mean?

A What that meant was if he went ashore or if he conducted any kind of personal or management business at all, I was to assist him with public relations. We called it flanking, flanking his production with PR.

That meant preparing people for his activities; sometimes assisting him with his production directly; anything from management to photography to film scripts to public surveys to writing promotions, writing dust jackets for books, editing his books or any such. There is a long list of different types of activities.

I also had as a duty to stay briefed on all of his activities so that I could flank those either directly or indirectly.

Q So as long as you were senior personal public relations officer you had personal knowledge of what L. Ron Hubbard was doing in connection with the management of Scientology organizations?

A Yes.

Q Was there a shore story in connection with whether he was managing Scientology organizations?

THE COURT: At what point in time, counsel?

MR. FLYNN: Let’s take on board the ship first.


THE COURT: That is up to 1975 per the witness’ previous testimony. Okay.

Q BY MR. FLYNN: Up to 1975, Miss Sullivan.

A Yes. There was a shore story that he was consultant for OTC. And as such, gave advice and directives to officers of the corporation to carry out their duties.


Q And was there a public relations line to the outside as to whether or not he was involved in the management of Scientology organizations?

A Yes.

Q And what was that?

A That he was very much on the management lines; that he was doing data evaluations; that he was in regular communications with Scientology executives; that, in fact, there were several pictures of him taken and posted with those people to promote that.

Q This is to Scientologists?

A Yes.

Q Now when I say that was within the organization, that was the public relations line?

A And to the public.

Q Now, with regard to government and officials of various ports you went to, was there a public relations line or shore story with respect to what he was doing?

A Yes.

Q And what was that?

A That was that he resigned from all directorships in 1966. Had no direct contact with Scientology organizations and often wrote books or engaged in his hobbies of photography, and that was very much played down, his relationship, but that he still retained his position as founder and, of course, gave advice from time to time.

Q Was that latter public relations story true?

A No.


Q And how long did you remain senior personal public relations officer from 1973 forward?

A All together about eight years.

Q And there were periods of time when you were removed from that post?

A Yes. The longest removal for an eight month period.

Q And when was that?

A That was in 1978 and through to ‘79.

Q And what happened then?

A I was sent to the RPF on the List 1 project.

Q what was the List 1 project?

A That was a culling of folders for List 1 rock slams, the meter read and sec checking to determine if you had a List 1 rock slam.

Q What was a List 1 rock slam?

A Well, it is an agitated motion on the E meter which indicates that one has crimes against the subject which is being discussed.

My particular List 1 rock slam was on myself, which was later found to be not so, but –

Q who were the subjects on List 1?

A LRH, MSH, Scientology, Orgs, the E meter, preclears, auditors, Scientology-related subjects. I think there were about 20 things on the list.

Q Now was this in the middle of the Department of Justice investigation, if you know, that this project took place?


A Pardon me?

Q Do you recall that there was a raid of church premises in 1977 by the Federal Bureau of Investigation?

A Yes.

Q And did the List 1 project take place during the investigation by the Federal Bureau of Investigation of the church if you know?

A I don’t know of any direct relationship between that.

Q Do you know whether or not there were governmental investigations going on at the time that this List 1 project took place?

A Oh, yes.

Q And one of the purposes of the list, one project was to find any bad intentions or activities toward L. Ron Hubbard; is that correct?

A Yes.

Q And was he the first person on the List 1?

A Yes.

Q Now, throughout the period of time that you were Senior Personal Public Relations Officer, which as I understand it is up until November 1981?

A No, July 1981.

Q July 1931, was there any change in the shore story or public relations line to government and officials as to L. Ron Hubbard’s control and management over Scientology organizations about which you have already testified?

A Well there were shifts in emphasis.


Q What were the shifts?

A They had to do with shifting emphasis towards activities that he was engaged in to divert attention from and play down any management activities he was engaged in.


Q And throughout that period of time per your observation, at least until L. Ron Hubbard disappeared in early 1980, was he managing Scientology organizations throughout the world?

A Yes.

Q Now, at some point in time did you become — strike that.

What was the personal office of L. Ron Hubbard in 1973 when you became personal public relations officer?

A It was — at that time it was called a unit because it didn’t have the formal seven divisions. But it did have a household unit; it had the messengers; it had the LRH accounts office which was in Mary Sue’s office, but part of the personal office, part of her personal office. It had the personal secretary’s office which consisted of photography, the answering of mail and book compilations, audio-visuals which means video tape, and so on. And the personal public relations office.

It also had the staff aides included in that.

Q Who staffed these positions in the personal office?

A Do you mean what individuals?

Q Were these people working for OTC while you were on board the ship, for example?

A Yes.

Q And did you have any conversations with L. Ron Hubbard as to the association or relationship of his personal office to Scientology organizations?


A Yes.

Q And when did you have those conversations?

A I had many conversations. In my initial first year was a time when I spent a great deal of my time in his office discussing that relationship.

Q And what was the relationship as he briefed you on it between his office and Scientology

A That we worked for him; that we didn’t take orders from anyone else; that we didn’t get disciplined by anyone else; that I should treat him as a client in that I was retained by him or servicing him; that I represented no church and was not to represent a church.

If I was requested to answer questions about church affairs, I was to refer it to the Guardian’s Office and not as a representative take a stand to represent the church and to keep those representations particularly separate.


Q And how often did L. Ron Hubbard brief you and emphasize this to you about what you just testified?

A Well, very often in different ways.

Q Are you familiar with a policy of L. Ron Hubbard called “The Founder”?

A Yes.

Q Now let me show you exhibit L, 500-L under seal; is that the policy that you are familiar with, Miss Sullivan?

A Yes.

Q And is this widely published in Scientology publications?

A Yes.

Q Do you know which publication it is published in?

A It is published in the Green volumes. It is published individually on a reprint basis from the publications organizations. It was published by me a number of times in the public relations packs which we mailed to people to let them have information about LRH relationship to the church and the other affairs.

Q Now, there is a clause in there that, “My office of LRH as founder remains mine as the public … ” et cetera, et cetera.

A That’s correct.

Q Now, was that your understanding throughout the period of time you were in the public relations office that it was directly L. Ron Hubbard’s?

A Yes. The public — the “mine” that he is


referring to as far as my office in this particular policy letter in 1966 is the Hubbard communication office, and that later grew into the personal office and took care of his communications, so at this time it is of a different name.

Q Now, at various times while you were Senior Personal Public Relations officer with publications issued such as exhibit 500-S, executive directive SOED 489 INT were items of that nature created with regard to what relationship, if any, the office of L. Ron Hubbard had to various churches of Scientology?

A Yes.

Q And how many such executive directives related to the subject of the relationship between the personal office and Scientology organizations to your knowledge were issued?

A Well the particular issue category for personal office was the central office of LRH executive directive. We have a copy here, I think, and when I left there were, the number was somewhere around 800, and then there were other directives published which went more broadly such as this Sea Org ED which went to every Sea Organization organization, and I believe there were probably, they covered various subjects, but I would say 200, 300, 400, something like that.

Q So was it understood within the structure of Scientology that the central office of L. Ron Hubbard belonged to him?

A Yes.


Q And based on your observations and his conducting of Scientology Organizations throughout the world, throughout the period of time that you were involved, Miss Sullivan, did you conduct those organizations as if they were his?

A Yes.

Q Let me show you what has been marked as plaintiff’s exhibit No. 24, Executive Directive COLRHED 824; is that one of the COLRHED’s that you were referring to of that type?

A Yes.

Q Did you write that COLRHED?

A I wrote it in conjunction with Gerry.

Q That is on the biography project; is that correct?

A Yes.

Q And with respect to the biography project, that was coming from the — the management of the biography project was coming from the central office of L. Ron Hubbard; is that correct?

A Yes.

Q And if the biography project was a church project, what office would it have come from. Miss Sullivan?

A The Guardian’s office public relations bureau.

Q Now at some point in time in connection with your duties as Senior Personal Public Relations Officer, did you become involved in an effort to begin a biography project?

A Yes.


Q And when was that?

A well, when I first took over the post of LRH Personal PRO I interned as an expediter for a month. During that time I went through the files and sorted out the biography project files, so I was aware of its existence.

Then within that month I took over as in charge of the bureau and shortly thereafter I received a manuscript from an author, Peter Tompkins, which was the first half of the first draft of a biography, and I reviewed it at that time.

Q And approximately when was that?

A That was either late ‘73 or very early ‘74.


Q All right. And what happened to that effort to do a biography about L. Ron Hubbard?

A Well, it fizzled from time to time. And it would get started up again. And I think that what caused it to fizzle was the lack of data and documents to back up what was being said or to be written.

What caused it to go back on board again, was usually myself or Sue Anderson and sometimes LRH.

Q When you say “sometimes LRH,” what do you mean by that?

A He would ask me whatever happened to the biography project.

So I would get it into a rebirth cycle.

Q This was with regard to the Tomkins biography subject?

A It started with Tomkins and then it went — there was a letter that he wrote to a publisher in England himself instigating a new biography project after he decided he didn’t want Peter Tomkins to write it.

I got a copy of that letter and followed up on that.

Q With regard to the lack of documentation, did you ever have any conversations with L. Ron Hubbard as to whether his personal records had been stolen prior to 1953?

A Yes.

Q What was that?

A Well, I told him that I was going to start a collection of documents.


And he said, “Well, you way have a great deal of trouble because my ledgers and the logs of my writing and a number of my documents were stolen in 1953.”

And he seemed to think that there was an editing project of his Naval records that had been done by the government.

He essentially told me that it would be difficult and that we would collect them, but they might be altered or whatever.

Q Did he tell you who he thought had stolen his records prior to 1953?

A He thought that it could have been his second wife Sarah or government agents.

Q Did you eventually find that in fact those records had never been stolen?

A Some of them, yes.

Q And this is bringing us up to 19 — early 1980; is that correct, when Mr. Armstrong brought documents to you?

A Yes.

Q Now, before we get there, at some point in time in connection with an effort to get a biography project off the ground, was a survey done which has been marked as exhibit 500-P in connection with the biography project?

A Yes.

Q And who initiated that survey?

A I did.

Q Did you write 500-P which is “Sea Org Executive


Directive LRH Biography Survey ED 7230 Flag”?

A No. Tom Atlee did.

But these are my questions on the survey.

Q Who is Tom Atlee?

A He is the survey person in the Flag Management Bureau who had a network who could execute an international survey such as this.

Q You were basically trying to find out what people were interested in with regard to the subject of. L. Ron Hubbard and his background?

A Yes.

Q Let me show you 500-O, “Sea Org Executive Directive Flag Confidential Flag LRH Image Survey Preliminary Tabulation” dated 23 May, 1975.

Did you play any role in the creation of that document?

A Yes.

Q what was that role?

A Well, I — the first issue that covers a LRH image survey is an L. Ron Hubbard executive directive COLRHED which he wrote which assigned me to execute this. It is about an eight-step program to do what was called the “really find out survey” about his image. And that is the result.

Q Do you recall getting the results of that in 1975?

A Yes.

Q The public image survey?


A Yes.

Q And what was the item that people considered to be most vital with regard to a biography?

A Honesty.

Q And what was that percentage?

A 66 percent.

Q Now, with regard to exhibit 500-S and the third page of that, it starts at the top, “Sea Org Flag Bureau dated letter 564 LRH personal PRO Functions and Publics.” Are you familiar with that document?

A Yes.

Q And what connection, if any, did you have with the preparation or dissemination of that document?

A well, I wrote it, but there is another issue which I basically wrote it from. And I updated it with this one.

“Functions and Publics” came from, I believe it is, a Flag order. It is definitely a white and black ink issue which LRU wrote himself about the personal office and his activities and his products.

And from there we wrote this. And this is Sue Anderson and myself distinguishing our two positions so that people wouldn’t get confused.

Q When you say “a white and black ink issue,” what does that mean?

A It is similar to this. It could have been a Flag order.

In other words, they are all color coded. And


this is a Flag Bureau data letter. And I think another one was a FO or maybe even a CBO. I aw not sure. It was earlier.

Q FO was a Flag order; CBO is what?

A Central Bureau order.

Q And the different issues were color coded differently?

A Yes.

Q In this particular document it shows the structure of the LRH personal office under L. Ron Hubbard; is that correct?

A Yes.

Q And then down to “GO Publics,” what are GO Publics?

A They are people that the Guardian’s Office mainly deal with which are the press, government officials, legal matters, any kind of official traffic.

Q Now, throughout the period of time when you were in the personal office, Miss Sullivan, was there any question in your mind but that you were working for L. Ron Hubbard?

A No.

Q At any point in time did the biography project pick-up again after it fizzled, as you put it? Is that correct?

A Yes, several times.


Q And in the several times what basically occurred?

A Well, the first time it fizzed was with Peter Tompkins where a biography was being done and then a book arrived and was sent into LRH called “The Secret Life of the Plants” written by Peter Tompkins, and at that time it credited LRH, and he was very upset and said that, in fact, this biographer had used the right to go through his documents in the Guardian’s office to steal material and to base his book and had actually stolen his research. So he didn’t want Peter Tomkins involved at all in any biography. That was the first thing. The next thing that happened was that I think a man by the name of George Hart or something wrote to LRH personally through his secretary, Irene Thrupp, at Worldwide and said that he had a publishing company and would like to do a biography of him. LRH answered the letter personally, sent me a carbon copy, sent David Gaiman a carbon copy, and because David was in England, asked him to interview the guy.

David did so and said, “No, he is kind of a two-bit operation. Let’s not do it with that guy.” So that tended to fizz it there, and we were back to finding an author.

I felt we were approaching it from the wrong way, too. we talked about getting publishers and authors and so on, but I felt we needed to get documents, then authors, then publishers, and so I began a collection of documents in the US and on board, and so on to begin the biography project again.


During photography in 1975 I discussed it at length again on the shoot lot in Curacao, and there were several conversations with him about the resurrection of the biography project and the more exposure internationally LRH got and the more successful we were in public relations, raised more questions about who is this man, all of these things that he apparently has done, and so the need for a book became more apparent, and when we would have problems, it would be a common comment like, “Oh, if only we had a biography done, all this could be handed to a person in a book.”

In 1975 when WA came, ashore in Daytona Beach, I spent all day from about 9:00 in the morning until 8:30 at night discussing biographical details with L. Ron Hubbard in our apartment in Daytona, and I said I would get it going again.

Q Now during the years 1975 to 1980 did questions arise in the public relations office as to past biographical sketches of L. Ron Hubbard that had been published were accurate?

A Yes.

Q And did you handle those?

A Yes, I did.

Q And what questions arose?

A Oh, many questions.

Where did he go to school? Was he really a nuclear physicist? Questions about his trips to Asia. Questions about his parents. Questions about his background.

[Missing pages 3042, 3043]

Q And did you become involved in that project?

A Yes.

Q Now, did you have conversations with L. Ron Hubbard about his background?

A Yes.

Q And what conversations did you have with him about that fact?

A Well, I asked him — when I had a chance to talk to him personally on that subject, I would sometimes ask him things, maybe a single question or two for some reason that I wanted to clear up something. I would have something sort of pending or sitting that I didn’t know the answer to.

And then when the moment was opportune, I would ask him, “now, back in 1953 or whenever it was, what really happened there?”

And he would tell me or not tell me in detail.

And sometimes I would write to him for clarification on specific points; sometimes I would just go to my files and see if it was there or not.

Q Now, did he basically affirm to you, without going through all of the aspects of his background, what had been previously stated in various biographic sketches of him as being true?

A Yes.

MR. LITT: I object. That is over broad, Your Honor.

THE COURT: I suppose if you go through the litany. But we can generalize it at this time.

If you want to cross-examine on it, you can


do so.

Q BY MR. FLYNN: Did he basically say that what had been published about him was true, Miss Sullivan?

A Yes.

And I want to say also at times he told me there were certain things that were true, but he didn’t really want it out in the public.

Q Like what?

A Well, in the ’60’s there was a biographical sketch published about him in different Auditor magazines or, I think, the Ability magazine. And it was all about his tour of duty on the USS Algol and Mr. Roberts and so on.

The story I got from him was a different story than what that said which was that someone had stolen a story from him at a dinner party where he was telling the tale and they went off and wrote the Mr. Roberts story.

So I had these disjointed facts. And from time to time we would issue these little summarizes [summaries] of his biographical background for a dust jacket or for a general issue for a publication of some sort.

It would go to him for current approval and then the emphasis would shift.

If I made the error of including that in it, he would say, “well” — he would cross it out or say, “I don’t really want to talk about that,” or, “let’s not put any emphasis on that. Let’s focus on something else.”

And it would just shift.

Q But he would affirm that it was true?


A Yes, but we weren’t going to discuss it or we weren’t going to publish that part at that time.

Q And did you in fact find that over a period of many years and many different biographical sketches some of which have been marked as exhibits under seal here, that there were different stories about L, Ron Hubbard?

A Yes. That was motivating force in getting a biography done.

Q In 1980 did you have a conversation with Gerry Armstrong about the Dive Bomber incident?

A Yes.

Q And basically, at the end of that — we’ll get into it in a little bit — but at the end of that conversation did you tell Mr. Armstrong that if L. Ron Hubbard said it is true, it is true?

A Yes.

Q Was that the view that you took up until the time that you left the organization basically?

A Well, until the last year or two.

Q What happened in the last year or two?

A There were just too many facts contrary.

To begin with, my rationale was kind of simplistic. It was he must have changed his mind or I would just file it in my mind somehow as he must have forgot or what about this. And it didn’t add up. But I would always think that I was the one with the missing information; so therefore, what he said was true, but I didn’t have all the facts.


But as I gathered the facts, I knew I had the facts. And Gerry would present them to me sometimes incredulous and sometimes he thought he didn’t have all the facts. And he would ask me, “Is there something else to this?”

And it became overwhelmingly evident that we had the facts and L. Ron Hubbard did not.

Q Now, let’s go up to 1980; where were you at that time?

A Up to 1980?

Q Yes, the beginning of 1980; where were you actually, physically located?

A Okay. In January I was living at Gilman Hot Springs.

In February I took a trip for three weeks to Clearwater.

In the interim I began the MCCS project in February, 1980 in Los Angeles and was given about a five-day grace period to move my belongings, to move my clothes and things to Los Angeles and set up another office and room there.

Q In January, 1980 you were at Gilman Hot Springs; is that correct?

A Yes.

Q What was your post there?

A LRH senior personal PRO.

Q And where was L. Hon Hubbard at that time?

A He was at a location called X in Hemet.


Q And did you have routine communications with him during that period?

A Yes.

Q And prior to that had he been at La Quinta with you?

A Yes.

Q And how long were you at La Quinta?

A I arrived in April, ‘77 and left in November, ‘78 or December, ‘78.

Q And incidentally, while you were at La Quinta were there shore stories as to who you were working for and what your involvement was at La Quinta?

A Yes.

Q And what briefly were those shore stories?

A It was the Friends of Norton Karno shore story.

And then when we were making films, it became evident that Norton Karno wouldn’t be making films.

There were various and sundry variations which were rather hard to stick to, but –

Q All of this period of time who were you working for?

A I was working for L. Ron Hubbard.

Q And was Mr. Armstrong in the household unit during at least part of this period of time?

A Yes.

Q And was the household unit in the central office of L. Ron Hubbard?

A Yes. He was in the personal office with him.


The central office of L. Ron Hubbard stayed at the Flag base in Florida. So we were personal office again with him.

In other words, we were with SU personal office,

Q With regard to these movies that were being made, was the purpose for L. Ron Hubbard to make money on these movies?

MR. HARRIS: By way of a conversation this witness had with Mr. Hubbard or –

It calls for a conclusion, Your Honor.

THE COURT: What kinds of movies were these?

THE WITNESS: There were 36 films. They were — some of them were promotional films and some of them training films which would be seen only by counselors in their training sessions.

Q BY MR. FLYNN: Did you acquire any information as to whether it was L. Ron Hubbard’s purpose to make money on these films?

MR. LITT: At what time, Your Honor?

MR. FLYNN: We’ll find that out, Your Honor.

THE COURT: Contemporaneously with the movies.

THE WITNESS: In November, ‘79 it was very clear to me that he wanted to be paid. And his account checked with me on what activities he actually performed so that they could be billed.

Q BY MR. FLYNN: And were there bills created?

A Yes.


Q And were people like Mr. Armstrong working on these movies?

A Yes.


Q And were you working on the movies?

A Yes, I am in a couple of them.

Q And how much were you getting paid at the time?

A Let’s see. Well, during the time I worked on them while I was an RFF member, I guess I got about four bucks a week, and then I guess I went to a base pay of probably around $20 a week, and then when I was Senior Personal PRO I was paid about $34.40, I think.

Q Now, when you were at La Quinta with Mr. Hubbard, was he continuing to manage Scientology Organizations worldwide?

A Yes.

Q And just briefly how was he doing that?

A By Telex.

Q Issuing daily dispatches on the Telex line?

A Yes, either to the management office in Florida or directly or sending out broad messages

Q And was there a group called the Commodore’s Messenger Org?

A Yes.

Q And basically how did they function during this period of time in 1978?

A They were with him 24 hours a day on a watch basis, and they were messengers delivering messages directly from him while on duty. They also performed secretarial functions for him because he didn’t have his secretary with him. There was a secretary at Flag in Florida,


and they by now were growing up and they were writing their own programs which he would approve and issuing those to management.

Q And during that period of time were there programs or operations to prevent any process servers from serving L. Ron Hubbard?

A Yes.

Q And what were those?

A They were essentially issued to my husband at the time, Fred Rock, who was the port captain or the PR person representing the Friends of Norton Karno, and we did drills on the staff, how to handle subpoena service and how to answer that he wasn’t there and that sort of thing.

Q And, for example, did Mr. Hubbard have a get-away car on the premises?

A Yes.

Q Now, in early 1980 do you recall the threat of a governmental raid?

A Yes.

Q And what was that?

A Well there had been a raid and it seemed that the Guardian’s office had information from somewhere that there was another raid imminent, and their concern was that the Gilman Hot Springs property would be raided because at that time our security in our location was getting to be pretty well known, and what was going on there was getting to be pretty well known, and so they suspected that a target for an attack or a raid would be Gilman Hot Springs.


At that time as an executive, I was briefed with other heads of the organizations at Gilman Hot Springs that that looked like it was going to occur and that we were going to go on kind of an all-hands alert to handle that situation.

Q And what was done to handle it?

A Well the major thing that was done was to get rid of extraneous material that might be taken in the shredding project.

Q And how massive a shredding project took place?

A Well, in the garage there was a top of the line shredder that we used to call Jaws which was a massive machine that went 24 hours a day.

There were also teams which buried material under the floorboards and in the grounds of the property which is about a square mile, an ex-golf course, 27 hole golf course. So they were out digging and that sort of thing.

Q What types of material was buried?

A Valuable documents that we didn’t want to shred but which were so sensitive that they couldn’t be found or seen.

Q Such as the Commodore’s Messenger logs; were they buried?

A Yes.

Q What were they?

A They were a record of every order he ever gave


on the ship and the person’s response to it on a 24-hour basis.

Q And the orders while he was a La Quinta and Gilman Hot Springs, et cetera?

A Yes.

Q And those Commodore Messenger orders reflected the control mechanism of L. Ron Hubbard throughout
that period of time of Scientology organizations?

A Yes, in two ways, by substance and by pure volume.

Q What was the volume of it?

A Many ledgers, stacks of ledgers.

Q Approximately how many people were involved in the shredding process?

A Well, everyone on the property was involved, and at that time I believe there was about 180 people, but people who were engaged in the motor pool and grounds were, of course, didn’t have very much material to go through, so they weren’t involved for the entire time, maybe a couple of hours.

Q What were the ground rules or the criteria by which documents were selected to be shredded?

A Well, anything that indicated that L. Ron Hubbard controlled the church or was engaged in management was to be shredded.

Q Do you know why that was, Miss Sullivan?

A Yeah. It was so that if there was a raid, that no information about his control of the church would be


in the hands of the opposition.

Q And do you know whether that had to do with inurement issues and money issues as to who controlled Scientology moneys?

MR. HARRIS: Objection; compound and leading.

THE COURT: Overruled.

Q BY MR. FLYNN: And incidentally at that time were you familiar with the practice of the board of directors giving undated letters of resignation?

A Yes.

Q And over how long of a period had you been familiar with that practice?

A Since approximately 1974 on the ship. I knew about OTC and I had heard comments about it earlier.

Q Do you know whether Kima Douglas was the director of RRF, Religious Research Foundation?

A That has to do with –

THE COURT: All right then the privilege will be sustained at this point.

Q BY MR. FLYNN: Now, Miss Sullivan, based on your observations in the personal office of L. Ron Hubbard between 1973 and 1980, did you observe as to whether there was any corporate integrity to the various Scientology organizations?

A Well I did observe it, yes.


Q And what did you observe?

A I observed that there was basically none.

Q And had Mr. Hubbard issued a publication on corporate integrity?

A Yes. And there were publications from the Guardian’s Office.

Q And were those essentially shore stories?

A Yes.

Q Did all organizations do whatever Mr. Hubbard told them to do during the period of time that you were involved?

MR. HARRIS: How in the world, Your Honor, could she –

THE COURT: To the extent you have knowledge, you may answer; to the extent you don’t have knowledge you should so state.

THE WITNESS: In my experience every person in every organization made their best efforts to follow his
instructions to the letter.

There was, of course, dissension from time to time and that person didn’t usually last very long.

Q Now, I believe you — did you give both criteria that were used to determine what documents were going to be shredded or just one criteria?

A I didn’t give all of them.

Q What were the other criteria?

A Any evidence that LRU had been on that property; involvement in international affairs. From time to time there were independent judgments made. Some of the things


I felt were actually advantageous to keep around. And I spoke to Doreen Gillam about it.

Q Who was Doreen Gillam?

A She was the Commodore’s Messenger Executive Director or Commanding Officer for the Special Unit. And she was in charge of the burying and so on. And the various sensitive things were being put into trunks.

I had some very sensitive things, some of them I rewrote as though they were notes to myself because I had to have them in hand to get my job done.

So when these questions came up, I asked, you know, some of these things don’t seem to be all that serious. And if you are going to make a judgment such as, for example, if L. Ron Hubbard said the marketing position for this product is a Rolls Royce so everything you talk about with this product is Rolls Royce, I didn’t see any harm in that.

And yet, these things were being taken as strictly management decisions which they were, but my misunderstanding was how in the world could we get rid of the entire volume of these things and still carry on our work?

So there were independent judgments wade in that regard.

Q And you yourself were making those types of independent judgments?

A Yes, I was.

Q Now, if the criteria was strictly followed, is it your understanding that virtually all the documentation


would have been shredded?

A Well, everything that had his name or signature on it probably would have.

Q Do you know approximately how many documents were shredded?

A I know by concept, I don’t know by numbers.

Q What is your concept?

A My concept — with that size of shredder running 24 hours for a couple of days and that much burying going on, I would say 30, 40,000 copies.

Q Okay. Now, among the more sensitive materials that you rewrote, was, for example, one of them a Nobel Peace Prize project?

A Yes.

Q What was the Nobel Prize project?

A Well, it was a project that came from the purification project which was a detoxification program which had been issued internationally by LRH and which he wanted full credit for.

He wanted it issued to Scientology, but essentially wanted it in the broad public use in detoxification centers.

He wanted to be known as the original researcher and discoverer of this detoxification program.

He said that part of that program was to get him the Nobel Prize.

He also said that I had an unlimited budget to do so.


Q From what funds?

A It was nonspecific. It was from any funds.

The funds that I got were from Scientology.

Q For this project for him?

A Yes.

THE COURT: We are going to take a 15-minute recess.



THE COURT: All right in the case on trial let the record reflect that counsel are present and the witness has retaken the stand — all counsel except Mr. Litt and Ms. Dragojevic. I assume they are out in combat somewhere else, and the witness has retaken the stand.

State your name again for the record, ma’am. You are still under oath.

THE WITNESS: Laurel Sullivan.

THE COURT: You may continue, Mr. Flynn.

Q BY MR. FLYNN: Miss Sullivan, you had mentioned you thought the shredding operation was going on for two days. If I suggest it was two weeks, does that refresh your memory at all?

MR. HARRIS: I will object to that, Your Honor; improper question.

THE WITNESS: Well, the shredding –

THE COURT: Well I will sustain the objection to the form of the question.

Q BY MR. FLYNN: what is your understanding as to how long the shredding operation was?

MR. HARRIS: We will object to her understanding. Your Honor. It is not relevant.

THE COURT: Oh, overruled. I assume it is based to some extent on personal observation.

THE WITNESS: Well in my office it went on for about two days and it could have gone on for longer because I didn’t have that much. Most of my materials were public materials anyway, so if anybody raided, I really didn’t care.


But there were some sensitive directives, and those things were taken care of, but I didn’t have to do the personal shredding and I didn’t have to do the digging. I just turned then over.

Q BY MR. FLYNN: Okay, just very briefly, you mentioned this detoxification program in which Scientology funds were used to get a Nobel prize or attempt to get a Nobel prize for Mr. Hubbard.

Essentially what is the detoxification program?

A It is a regimen or sauna, vitamin intake and physical exercise designed to sweat out the toxic chemicals that a body might retain in its fatty tissue.

Q And was there a doctor who worked on this project with anyone?

MR. HARRIS: Objection; irrelevant.

THE COURT: Oh, overruled.


Q BY MR. FLYNN: Who was that?

A Dr. Denk. I paid him $10,000 to do a research program on it.

Q Where did those funds come from?

A They came from Sea Org reserves.

[Missing page 3062]

A Well, they were ledgers and journals, diaries; they were old letters; they were some receipts; they were personal materials having to do with LRH’s background. There may have been some current materials also.

I didn’t go through them all in detail except to just sort of inspect piece by piece what it was.

Q And at that time did you make a decision as to what was going to be done with them?

A Yes, I did.

Q What decision did you make?

A I made an independent decision that not only were these documents not to be shredded, but that I would copy them with Gerry’s help and the assistance of one of my staff to send them out of the country so that if in face there was a raid, that I would have access to another source.

Q How many copies were made?

A I think there were five.

Q And where did these copies go to?

A I sent one copy to David Gaiman in the Guardian’s Office because he also has an archive of LRH documents.

I sent one copy to Irene Thrupp, LRH’s personal secretary Worldwide.

I sent one copy to Europe to my public relations junior there, Janet Whelan [Wieland], for safekeeping. And I retained a copy.

Q And did you hide the original somewhere?

A Well, they were put in Gerry’s care. And then they were in my office in a file cabinet.


Q At some point did they get hidden under a bed or something to that effect?

A Some of them may have been taken to the living quarters of individuals so they would be the last place to look for a raid.

I had some things like that in my bedroom.

Q Now, under the — prior to the documents being brought to you would it have been Mr. Armstrong’s decision as to what was to have been done with the documents in the midst of the shredding process in his capacity as the head of the Household Unit?

A Yes. He made a decision.

Q But at one point in time do you have any understanding as to whether or not the only person that stood between the shredder and the documents was Gerald Armstrong?

A Yes.


Q And then he brought them to you; is that correct?

A Yes.

Q And under the criteria that you set forth as to whether these documents should have been shredded, what should have happened to them?

A Well they would have been shredded. Gerry brought them to me for a decision about it, so I said, “No, we won’t.”

And because we had discovered these, I informed the people who were running the shredding project that I wasn’t going to shred them, that they had been found and what we were doing with them.

Q And did you subsequently learn in a little more detail the contents of not only these initial materials that were brought to you but other materials that Mr. Armstrong found and brought to you?

A Yes.

Q And under the criteria that had been established, should these materials have been shredded?

A Yes.

Q Now when you received these materials, did you make any decisions as to what to do with them in connection with resurrecting the biography project?

A Oh yes.

Q What did you do?

A I went, “Oh, boy, this is everything I have ever wanted.”


Q You thought the truth about L. Ron Hubbard’s background was in these materials?

A Yeah. I thought, “Wow, let’s begin.”

Q And so what did you do?

A Well my first concern was preserving them because some of them were fairly flimsy and written on kind of an airmail paper that was now about 20 years old or 30 years and some of it on newsprint, and these things had been left open to the weather and I was concerned about them and the exposure that they had.

Some of them were dusty and dirty, and I knew that they were valuable as collector’s items. I knew they were valuable from the informational content, so my first action was to get them organized so that we knew what we had and to preserve them and to keep them secure.

Q All right, you know at some point that Mr. Armstrong petitioned L. Ron Hubbard to become the archivist to work on the biography; is that correct?

A Yes.

Q And what, if any, involvement did you have with that petition?

A Well, we discussed it. Gerry at the time wasn’t really being used to his full abilities, just managing the household unit for a household that LRH didn’t arrive to very much. He had finished his renovations project of the house and he was a good store man, but also a very good man with documents because I knew him from the ship, and so we discussed it and how we could actually extricate him out of


the household unit, keep that going and get him over to the PR bureau and at that time I had very specific instructions from LRH to man up, beef up my office because I was going right into an international area and I had not been on that position, I only returned to it in June, and it had been sadly neglected before that. The bureau had almost been destroyed, people transferred, and we had time to make up for.

So I was very enthusiastic about getting Gerry on it and I talked to him and he was enthusiastic and he said he didn’t really want to do PR front lines. He didn’t want me to throw him into any press handling, but he sure wanted to get this biography done. So we decided that the best thing for him to do would be to start the archives and let’s petition to do that. So he did that from his household unit position.

Q You actually received an order from L. Ron Hubbard to beef up his own personal office; is that correct?

A Yeah.

Q And in connection with that order, you were making an effort to bring Mr. Armstrong into the personal office?

A Yes.

Q Now, throughout the period of time that Mr. Armstrong was in the archives project, was he in the personal office of L. Ron Hubbard?

A During the time when now?

Q When he was in the archives project.


A Yes.

Q And you knew that the petition had gone into Mr. Hubbard from Mr. Armstrong? is that correct?

A Yes.

Q Did you learn if Mr. Hubbard had approved the petition?

A Yes.

Q How did you learn that?

A I got a copy of it.

Q From whom?

A Well, there was one coming to me on the lines, but my first knowledge that it was in fact approved was when Gerry brought it in. He brought in his original approval.

Q Did you receive any confirmation from L. Ron Hubbard yourself as to whether or not it had been approved by him?

A Well, I did receive confirmation that he knew about it and I didn’t have any reason to doubt that he would approve it or that it was him that approved it, so when I sent in my weekly reports, now my weekly report was a briefing, and in the briefing one of the categories was the biography project.


And he commented at that time that Garry was going to get started on that; that we were going to go to work on Omar Garrison to be the author, but first we had to do the collection.

Q These weekly reports went to who, Miss Sullivan?

A They went to the messenger on duty to L. Ron Hubbard.

Q For how long a period of time did you continue to file these weekly reports with Gerald Armstrong working on the project?

A There was one main mention of it. And after that I went to Clearwater probably during January. And then there was the first week of January and then we got going on it. And then I left for Clearwater in early February and was back again by February 23rd to begin the legal project.

Q The legal project being the MCCS Mission?

A Yes.

Q How, in connection with these weekly reports, exactly now did they go to L. Ron Hubbard?

A Well, I would type them up; keep a copy for myself; the original would go — sometimes I would pass it through an administrative senior or attach a copy to my weekly report. Usually though I would just address them to the MOD, the messenger on duty and LRH. And they would just go.

Q And for years had that been the routine method of transmitting communications to L. Ron Hubbard?

A Yes; either that — in earlier years it was to


his personal communicator who was at that time my direct senior but now there was no personal communicator except for the messenger.

Q Where was there not a personal communicator?

A There was one at Flag, but not where we were. The messengers had taken over that functions [function].

Q Now, did you also provide reports to Mary Sue Hubbard?

A Yes. Later.

Q When did you first begin providing reports to Mary Sue Hubbard?

A On the MCCS project.

Q With respect to the biography project, did you provide any reports to Mary Sue Hubbard?

A Yes.

Q And what did you provide?

A I sent an inventory of archives materials.

I spoke to her on the telephone a number of times about the biography project. I asked her permission for some LRH funds to be used for the attorneys to negotiate the contract. And that was approved.

I sent the Telexes from Gerry when he was in England negotiating with Omar Garrison on my behalf, since I couldn’t go. I sent those to her with my recommendations for the framework for the negotiations.

Q Now, when did these communications to Mrs. Hubbard begin?

A Well, for the most part, in the fall of 1980.


But before that time when Gerry was collecting documents, he was really working very hard. And we were starting to get an idea of the vast amount that we could collect plus we had other people out collecting. And we were getting taped interviews. I think we ended up with something like 50 or something, 70 taped interviews. And I was starting to get very excited that we could actually do this project. It was time to engage an author.

But Omar Garrison was still working on his book “Playing Dirty” and I was in regular communications with Mary Sue through Worldwide through David Gaiman, I was saying hey, we are going to do it. We have got the documents.

“When is Omar going to be done?”

Since David Gaiman was the liaison personally for Omar and had been for a number of years, I was going through David to engage Omar even though David was in England and Omar was in Utah.

There were numerous conversations back and forth of whether or not it would be all right for Gerry and I to contact Omar directly.

And finally it was decided that, really, I should go to England and meet with Omar when he was there with David and Sheila Gaiman and we would discuss this biography project and negotiate.

Unfortunately, because of my PR duties and being involved in the legal problems, I couldn’t leave. And I certainly couldn’t leave for a week.

And so Omar was going to be there and I asked


would it be all right with him if I sent Gerry along, since that would be the person that Omar would be working with and he would need to know who he was going to be working with. And I wanted to make sure from the outset that it was okay with Omar.

So I sent Gerry as my representative for L. Ron Hubbard, that sort of thing, to begin the negotiations. And I knew I could count on him to be real precise. And he sent Telexes back on a daily basis and asked me questions about the framework.

I sent them to Mary Sue. And all the time the Telexes were going on the Guardian’s Office communication lines and back to the personal office communication lines through the Controller’s Office. And that is basically how it occurred.

Q When L. Ron Hubbard approved the petition did you need to get any approval from Mary Sue Hubbard for the biography project to go forward after L. Ron Hubbard’s approval?

A No.

Q And you mentioned you requested funds for lawyers from Mary Sue Hubbard?

A Yes.

Q And in connection with negotiating the contract, why is that, Miss Sullivan?

A Well, L. Ron Hubbard was the subject; he stood to make some money. And I was negotiating on his behalf.

[Missing page 3073]

rights to publish had a relationship with L. Ron Hubbard and essentially how the funds were to be handled. Put in that perspective that some documents were owned by the church and had been purchased and paid for by the church and would contribute to it didn’t make him working for the church, just because he used those things.

Q Well, so for that reason were there tax considerations at the time?

A Yes.

MR. HARRIS: Well, I will object, Your Honor. This is very clearly MCCS mission material.

THE COURT: Well I will permit her to give her opinion as to who he was working for. If the reasons have to do with these tax considerations or these conversations with the lawyers, then we won’t go into the reasons, but they will stand as unrebutted as far as the court is concerned.

So, you can give your opinion as to who he is working for.

MR. HARRIS: I understood that. I didn’t object to that.

I objected to Mr. Flynn leading the witness; did this have something to do with tax considerations?

THE COURT: Well, let the witness give her opinion as to who he was working for, and I guess she has.

Q BY MR. FLYNN: What if any tax considerations were there, Miss Sullivan?

MR. HARRIS: Well, I will object to that, Your Honor.

THE COURT: I will sustain the objection.


Q BY MR. FLYNN: Well at this time in 1980-1981 did issues begin as to who had control of Scientology funds?

MR. HARRIS: Well, objection; vague.

THE COURT: Sustained.

Q BY MR. FLYNN: With regard to the contract negotiations, was an agreement made between Omar Garrison and PDK, a written agreement to your knowledge?

A Yes, it was.

Q And did you attend the contract negotiation sessions?

A Yes.

Q And who did you represent?

A L. Ron Hubbard.

Q And were you in charge of the biography project for L. Ron Hubbard?

A Yes, and I believe I am mentioned in the contract.

Q And did you participate in writing the contract?

A Yes, I did.

Q What were the benefits for L. Ron Hubbard pursuant to the contract that you negotiated on his behalf?

MR. HARRIS: The contract speaks for itself, Your Honor.

THE COURT: I will sustain the objection.

Well, the contract that we have seen, I think, is the contract between PUBS DK and Omar Garrison. I don’t know that we have actually seen any contract, have we, in evidence as between Hubbard or the church other than maybe a letter. There’s been some discussion about the royalties


and various things. I can’t recall.

MR. FLYNN: No, that contract has not been produced. Your Honor.

Q There was a contract between Omar Garrison and PUBS DK; is that correct?

A That is correct.

Q And you were involved in the writing of that contract?

A Yes.

Q And incidentally later on you found out that PUBS DK knew nothing about the contract?

A Yes. As a matter of fact, I knew that from the beginning.

Q And how did you know that from the beginning?

A Because the agent representing PDK was Larry Brennan who was the Legal Branch 1 Director Worldwide and was appointed by Telex by someone at PDK that the Guardian there authorized as the agent for PDK.


So if someone queried the PDK directors, they really didn’t have much to do. It was orchestrated from Worldwide which is where Gerry was.

Q And Worldwide is the Guardian’s Office?

A Yes.

Q And who controlled the Guardian’s Office?

A It was Charles Purcell in charge of the legal; Jane Kember and Mary Sue Hubbard.

Q And who above Mary Sue Hubbard controlled Mary Sue Hubbard?

A Well, L. Ron Hubbard.

Q Now, so PUBS DK was essentially the Guardian’s Office; is that correct?

THE COURT: If you know.

THE WITNESS: Well, PUBS DK was a for-profit publishing company. But some of the directors and officers were the same.

So some members of the Guardian’s Office were also PDK.

So in a sense, this transaction, they are one and the same. That does not mean that everyone in the GO was everyone in the PDK.

Q BY MR. FLYNN: I understand that. But was PDK, to your knowledge, basically controlled by the Guardian’s Office?

A Yes.

Q And is this in line with your previous testimony that there was really no corporate integrity to any of these



I had to get certain funds out of PDK. I couldn’t get those funds out without Herbie who was in the Guardian’s Office to authorize the release of those funds. And no one there would give me any money until Herbie approved it anyway.

So I went over to the Guardian’s Office.

Q Herbie who?

A Herbie Parkhouse.

Q He was the Guardian’s Finance Worldwide?

A Yes.

Q He had been Guardian’s — he had been in control of finances of the organization back to the 1950’s?

A Well, he had been on finance for a number of years. He was in dissemination. I worked for him personally in ‘67 in dissemination and promotion.

In 1968, I think, he was Deputy Guardian Finance.

Q We have the contract between Omar Garrison and PUBS DK; was there another contract, a secret contract between L. Ron Hubbard and PUBS DK?

A Well, there was an existing contract between L. Ron Hubbard and PUBS DK. And it was to be amended to
include him as the subject of the biography.

And that was approved by Mary Sue on the framework of the overall negotiations which occurred.

Q Did letters go back and forth between


Alan Wertheimer and Larry Brennan from the Guardian’s Office or PUBS DK relative to the second contract, the secret contract?

A Yes.

Q And are these the letters, Miss Sullivan, marked as exhibit EE and FF from Alan Wertheimer to Larry Brennan?

A Yes, This one is dated November 17, 1980. It looks like the first one. But it starts off saying,
“. . .thank you for your November 10th letter.”

So one is missing.

Q There were other letters?

A It appears that there is another letter missing.

Q What role, if any, did you play in the preparation of the contents or these letters?

Do you need to take a minute to review them?

A Yes.

Q Why don’t you do that?

Were there other letters in addition to exhibits EE and FF?

A Well, there is another letter from Larry dated November 10th.

There is also Telexes which begin the correspondence. And then this is the initial correspondence.

My participation was in this letter.

Q “This letter” being exhibit EE dated November 17, 1980?

A Yes. I provided the attorney with the lists of


things that Mr. Hubbard was going to contribute and what Gerry’s activities would be worked out to be. And this letter was written.

Q Who hired Alan Wertheimer?

A Well, he was originally hired by Cary Gleason who had a POA from L. Ron Hubbard to negotiate a film contract.

Q And which film contract was that?

A It was a contract on “Revolt in the Stars,” a science fiction film. And Cary Gleason and Elizabeth Gablehouse negotiated with Alan Wertheimer.

Q And then did you retain him as L. Ron Hubbard’s representative in the biography project?

A Well, he was his attorney for all matters; although he was the copyright expert.

Q Now, with regard to exhibit EE, paragraph 3 — I am sorry — paragraph 2, “. . .I am further advised that Mr. Hubbard is willing to make his personal files and records available to PDK and Mr. Garrison.”

Do you recall that being a subject of discussion at that time in October, November, 1980?

A Yes. And schedule A to the contract was a note from L. Ron Hubbard saying basically that — discussing that Omar Garrison would be the biographer and that these materials were available and that –

He didn’t envy anybody the task of collecting them all together, but there they were.


And so that was attached as part of the contract. So we are discussing this.


He also verbally approved it from many years that these files be provided, so there wasn’t really any question.

Q And those files were his files; is that correct, his personal records?

A Oh, yeah.

Q And that is what Mr. Armstrong was collecting?

A That is right.

Q And was it understood at that time that Mr. Armstrong was working for Mr. Hubbard in doing this?

A Yes.

Q And was it understood that the files were as stated there the vital part of the project?

A Oh, yeah, couldn’t have been done without them.

Q And did Omar Garrison insist on having them?

A Yes.

Q Now with regard to the second page of exhibit double E in reference to the paragraph that starts off, “First while Mr. Hubbard may be willing to waive an up-front or advance, he must be reimbursed for his out-of-pocket expenses in connection with the compilation of the archives, including without limitation salaries paid to employees hired by him in connection with said compilation.”

Who was the employee that is contemplated in that paragraph?

A Well it is Gerry and it also was to include part of my time, and I was to keep a log of all of the time that I spent on the biography, and I did keep that log. I


don’t have it.

Q Where is that log?

A Well that would be in the biography files.

Q So it was understood that –

MR. LITT: Your Honor, I am going to object to this line of questioning, and the reason is that this apparently is based upon advice which was advice given and from what I can determine never implemented by Mr. Wertheimer, and Miss Sullivan’s testimony about what was to happen was that there was certain advice apparently which was given by an attorney as to how to handle certain matters. Those letters may reflect that attorney’s understanding of what he thot might happen. There is no indication that it ever did happen, and for Miss Sullivan to be testifying in this generalized language of what is to happen is in reality saying that she received certain advice from attorneys which presumably she recommended be followed, but it appears was not implemented.

MR. FLYNN: If Your Honor please, if you look at exhibit double G, which you don’t have in front of you, this is a confirmation of the proposals in the two letters by Mr. Brinkman purportedly acting on behalf of PUBS DK, and the first item referred to in exhibit double E is this salary and compilation of the archives issue which Mr. Brennan agrees to, so it becomes part of a contractual arrangement.

THE COURT: I am not sure what the objection is.

MR. LITT: The objection –

THE COURT: Was there a question that you are objecting to?


MR. LITT: The last few questions that have been posed to Miss Sullivan have been what was supposed to happen and what did this mean, and Miss Sullivan’s answer was well, Gerry was to have this happen; not what did happen, and the was-to-happen apparently refers to the fact that certain advice was given which she, I gather, assumed would be followed and implemented but which it appears was not, in fact, implemented, and that therefore statements that she is making at this point are not factual statements of what occurred but are rather indirect recitations of advice that was provided to her.

THE COURT: Well, whatever is in the record will remain. You can ask your next question. If there is an objection, I will rule on it then.

Q BY MR. FLYNN: Miss Sullivan, did, in fact, Mr. Armstrong begin the biography project and compile the documents as Mr. Hubbard’s employee?

A Yes.

Q To be paid by Mr. Hubbard?

A Yes.

Q And did Mr. Brennan in what is, I believe, exhibit double G agree to that fact on behalf of PUBS DK?

A Yes. This is confirmation. This isn’t so much what is to be. This is confirmation of an agreement which Mary Sue approved as the holder of the POA for L. Ron Hubbard.

THE COURT: By POA you mean Power of Attorney?


Q BY MR. FLYNN; Now, at that time is that, in


fact what occurred to get the biography project off the ground?

A Yes.

MR, HARRIS: Well, is what, in fact?

Q BY MR. FLYNN: Gerald Armstrong would compile the archives as Mr. Hubbard’s employee?

A Yes.

Q And did he do that?

A Yes.

Q Now, you negotiated this contract with Omar Garrison; is that correct?

A Yes.

Q And as an essential part of the contract with Omar Garrison, was it a fact that L. Ron Hubbard was to receive certain moneys from this biography project?

A Yes.

Q And what was he to receive?

A He was supposed to receive 50 percent of the profits and then a 5 percent royalty as I understand.

Q He was to receive not only five percent royalties on a biography on his own life –

A Right.

Q — but also 50 percent of the profits from PUBS DK; is that correct?

MR. LITT: Your Honor, I am going to object to the question.


MR. LITT: Is there an agreement that Miss Sullivan is


referring to that was entered into? I have inquired of this. I can find no agreement that was ever entered into to reflect this and I don’t believe it was ever entered into, and she is apparently referring, and the question is being asked as to what advice was given or plans that were made, not things that occurred.

MR. FLYNN: If Your Honor please –

THE COURT: Well, I am going to overrule the objection. The documents speak for themselves, and that is essentially what we are talking about.

We all know the biography was never published so that nothing was ever paid obviously. There was never any sales, never any royalties, and so I don’t think that we have to dwell a whole lot longer on this particular nit, so let’s go onto the next nit.

Q BY MR. FLYNN: The biography was never published?

A Right.

Q And that is because of what was discovered in the documents?

MR. LITT: Objection; calls for a conclusion.

THE COURT: All right. I will sustain the objection.

Q BY MR. FLYNN: Just with regard to exhibit double P on the second page there is a notation, “Mr. Hubbard has ownership and possession of the archives.”

Was that the understanding among everyone involved in these contract negotiations at the time. Miss Sullivan, that you dealt with?

A Yes.


Q Did L. Ron Hubbard know what Gerald Armstrong was collecting?

A Yes.

Q And did Gerald Armstrong, in having possession of them, have possession of them as L. Ron Hubbard’s representative?

A That is correct.

There were other things in the office that belonged to the church, we clearly had those separate.

Q Now, at this time that this was being done were there discussions between you and Mr. Armstrong about whether these documents would go into a trust that he was collecting?

A Yes.

Q And what were those conversations between you and Mr. Armstrong?

MR. HARRIS: I’ll object to that, Your Honor. That is, again — we are right in the middle of the MCCS Mission. Her discussions with Mr. Armstrong about what was to be –

THE COURT: I’ll sustain the objection at this point.

MR. FLYNN: We have an affidavit that we’ll give you at the break, Your Honor, that Miss Sullivan needs to sign with respect to the MCCS Mission.

THE COURT: All right.

Q BY MR. FLYNN: Now, as a result of these agreements that were entered into with Omar Garrison and the
letters from Alan Wertheimer that you testified about, did you observe Gerald Armstrong working collecting documents?


A Yes.

Q And his physical location was moved from Gilman Hot Springs to downtown Los Angeles because of the MCCS Mission; is that correct?

A Well, it was because of my location and also because of security.

Q Now, your location was moved to Los Angeles because you became the head of the MCCS?

A Yes. And he became part of that for a brief time.

Q He became MCCS second?

A Yes.

Q What other people were involved in MCCS?

A Well, there was a Guardian’s office person, Rick Klingler, who was the church representative. And he didn’t last very long. Then they got a new Guardian’s Office representative who was Lisa Britowich. And she became MCCS Second.

I got Gerry off the project to go to the archives full time.

And then as problems on MCCS arose, a new person was added. And they represented the church side of that problem.

Q Okay. During the period of time that Mr. Armstrong was collecting these documents, did you have conversations with him about the contents of the documents?

A Yes.


Q Starting, just quickly, with an incident involving “The Dive Bomber,” do you recall Mr. Armstrong coming to you in early 1980 with reference to the Dive Bomber?

A Yes. As a matter of fact, I returned early from Clearwater to do an event on Dive Bomber.

Q Were you in charge of the event?

A No, The Safe Environment Fund people were involved in the event. They promoted it. And they had promoted a film which was supposedly written by L. Ron Hubbard. And we were busily trying to verify that fact.

They had written to L. Ron Hubbard asking for details of it. He had answered them and given me some information on it.

I returned from Clearwater in order to go to the event to represent him at the event and to tell the story.

Q Now, when you say it had been promoted, this event had been promoted on the basis that L. Ron Hubbard had written the screen play for the Dive Bomber; what type of promotional activity took place?

A There were telephone campaigns and there was a flyer that had been mailed out. And there were posters around the organizations and people who were on the Safe Environment Fund Donor List were being contacted to attend this event at the Hollywood Palatium [Palladium].

Q Was it for the purpose of raising money?

A Yes.

Q And was it for the purpose of raising money to defend the individuals who had been indicted, including


Mary Sue Hubbard?

A Yes. As I understand it, that was the purpose of the Safe Environment Fund.

Q Do you recall approximately how many people attended?

A I would say about 2,000.

Q And do you recall approximately how much they paid per ticket?

A Well, I would — I think about $20. But I didn’t pay; so I really didn’t pay that much attention to it.

Q So you don’t have a real precise recollection; you have a general recollection?

A Yes. I think it was about $20.


Q Did you ask Mr. Armstrong to verify that Mr. Hubbard had written the screenplay for the “Dive Bomber”?

A Yeah. I had to do a speech on the subject, and I really couldn’t add it up.

Q And so what did you do? You asked him to go find out, and what happened?

A Well, he came out with no leads. In fact, we found out that chances were probably that he didn’t write it, and this promotion had gone out and I was scheduled to speak. So I went up there and I read what L. Ron Hubbard wrote.

Q Did you tell Mr. Armstrong, “Well, if L. Ron Hubbard says it, it is true”; regardless of what the facts were that he had found?

A Well I mentioned — I said that to Gerry a number of times because of where my frame of mind was at, and I was divided and Gerry — I always knew that Gerry was very thorough, and I asked Gerry many times to be very thorough, and I checked his sources. I checked the places he checked, and there was no place else to check, but I always had in the back of my mind L. Ron Hubbard saying these things had been lost or stolen or there are not records or whatever.

So, I always thought that maybe we were the ones with the missing data and that particular time I assumed that that was the case because we were just beginning the document collection. But I don’t think it was the case.

Q Now, thousands of dollars were promoted, were raised on the promotional activity that took place on the basis that he had written it; is that correct?


A I think so, yes.

Q And similarly in the prior 20 years millions of dollars had been generated in income on the basis of Mr. Hubbard’s claims to be, for example, a nuclear physicist; is that basically true?

MR. HARRIS: Well that clearly calls for speculation. Your Honor.

THE COURT: I will sustain the objection.

Q BY MR. FLYNN: Well, in your position as personal PRO, were you selling the imagine [image] and background and character of L. Ron Hubbard, Miss Sullivan?

A Yes.

Q And in your duties in connection with prioritizing income aspects for Mr. Hubbard, was it based upon his background, character, et cetera?

A Yes.

MR. HARRIS: Object; vague and compound as well.

THE COURT: Well, I think the “et cetera” probably can be stricken.

MR. FLYNN: All right, strike the et cetera.

Q Is that essentially what had gone on for several years selling L. Ron Hubbard?

A Yes.

Q Was a communication sent off to L. Ron Hubbard about whether or not facts had been found to indicate that he had not written the “Dive Bomber” and did you receive a reply?

MR. HARRIS: Objection; compound.


THE COURT: Well, it is sort of directing her attention to something, probably an exhibit in front of her at the moment.

MR. HARRIS: Well then it also assumes a fact not in evidence, Your Honor.

Q BY MR. FLYNN: Was a communication sent to L. Ron Hubbard about this problem, Miss Sullivan?

A Well a communication went from the Safe Environment Fund and I got a copy of the reply.

Q The reply from who?

A From L. Ron Hubbard, and this is it.

Q Do you remember seeing that at the time back then?

A Oh, yeah. I just read this. I read this to the whole audience pretty much.

Q That is what you read in front of these 2,000 people?

A Yeah. I figured I better just tell it from him.

Q Now, later on did you have the opportunity to examine a lot of the documents that Mr. Armstrong had collected?

A Yes.

Q And were you able to reach a conclusion in your own mind as to whether the statements in Mr. Hubbard’s dispatch of 11 February, 1980 marked as exhibit double D were accurate?

A Well, the conclusion I reached was that it was



Q And that he had not written the “Dive Bomber”?

A Yes, and there was another book which — there was a specific book that mentioned plays or movies that he had written on for those years, and it didn’t mention the “Dive Bomber” and so I was curious about that since it was conspicuously absent to me.

Q And did you look into any documents that indicated whether Mr. Hubbard had $10,000 after World War II that he had put in a safe deposit box or what his financial condition was in the 1940-41 area?

A Well, I read the letters from that period, and it didn’t sound like he had $10,000. Sounded like he was living at the Knickerbocker Hotel in New York. Was sick a lot of the time and couldn’t get the fare to go visit his kids and wife.

Q After World War II, Mr. Hubbard had claimed he was crippled and blinded and ha had cured himself by 1947; is that correct?

A Yes.

Q And did you look at documents that indicated that he was constantly making claims to the Veterans Administration to get a pension, among other things expressing that he had no money?

A Yes, I saw those.

Q And that was when he supposedly had the $10,000 in the bank account after World War II?

MR. HARRIS: From what is this witness being asked a


question, an exhibit she has in front of her?

THE COURT: I will sustain the objection.

Q BY MR. FLYNN: You found out that the communication marked as exhibit 500 double D was false; is that correct, Miss Sullivan?

A Yes.

Q Now, during the period of 1980-1981 did you have regular ongoing conversations with Mr. Armstrong about what he was finding in the documents?

A Yes.

Q And what, in general, was the nature of those conversations?

A Well I would ask Gerry, “Well, how is it going?”

And he would do weekly reports and I’d ask. him questions about that.


Q And he sent in weekly reports, incidentally?

A Yes.

Q Written?

A Written weekly reports, what was done and what was to be done.

Q And to your knowledge all of those are in the possession of the organization?

A Yes. I would think they were.

Q Go ahead.

A I kept the file for awhile that I was there. I would go in and when Omar would be there, I would ask him how it was going, if he needed anything. And he always said Gerry was keeping him supplied. And sometimes they would ask me questions about my knowledge or anything that LRH might have told me about certain time periods that would give them some more information about certain documents.

I would leave the documents and they would make reference to various things like where he was or names of boats or names of wives or children or who they were. And so I would give to the best of my knowledge from the discussions I had with LRH personally any more information that I had.

Sometimes they would come up with some real gems that would open up a whole area of his life. And I would — I was fascinated. I probably was the more curious one of all because I had been on the longest. I didn’t have time to spend a lot of time in there. And I –

So it was mainly to answer questions to help them


in their work.

Q Did Mr. Armstrong begin to express to you all of the things that he was finding?

A Not always. I think Gerry kept it to himself a lot of times because he was upset that these things were not adding up. And he always just gave me the documents.

One time, at least, it was really significant for me, was when the biographical sketch appeared to be entirely false and he had all the documented evidence that it was entirely false except for the birth date. And what he didn’t know at the time was that LRH wrote it himself and told me that was the only authorized biography; no other was to be out. And that was the only one we used.

And Gerry brought all of this in and put it in my in-tray and I say, “My God. Come on, Gerry, sit down. What you are telling me is that this man is a liar. You are telling me right — this was something I have been putting out for awhile now. And you are telling me that he is a lier [liar].”

He said, “I am not telling you anything. Just read the documents.”

Q And at some point in time did Mr. Armstrong become concerned because of what he was finding about his own personal security in the organization?

A Oh, yes, we both did.

Q And in what way did you become concerned?

A Well, our job of creating a biography that was positive was getting increasingly difficult; although that


was still our intention. And there are — it is my opinion that within the organization a lot of people weren’t really concerned with the facts; they were concerned with the fiction. They weren’t really willing to hear the bad part.

I felt that it was important to give an overview and correct the emphasis without all the bad part and without all the good parts, but to show that — to tell the truth and to emphasize the truth and to tell a story about this man who, obviously, was colorful, charismatic, a leader and pretty impressive. And we didn’t really have to embellish facts. There was more than enough to put in a book. And we didn’t really have to put all the gory details of a person’s past in a book.

So we were trying to be selective and I was trying to use good judgment.

I was very concerned that if anyone did hear about the gory details, that we would become the targets. And I think that is what happened.

Q What do you mean when you say you would become the targets?

A Well, we would be stopped from doing the project.

I was removed; Gerry was Sec Checked and my fears came true.

Q And based on your experiences and history in the organization did you find this to be true in general; that when anyone questioned what the ordered program was, that they became targets?

A Yes.


Q And, for example, the story about L, Hon Hubbard not receiving any monies from the organization, you knew throughout the years that that was false; is that correct?

A Oh, yes.

Q And because of the amounts you learned about in MCCS, did you become fearful that you were going to become a target?

A I knew I would. I knew far too much.

Q Now, let me show you what has been marked as exhibit J for the defense and exhibit 26 for plaintiff.

Do you remember a period in the fall of 1980 when you had conversations with Mr. Armstrong about having him communicate to Mary Sue Hubbard what was going on with respect to the biography project?

A Yes.


Q And what were those conversations between you and Mr. Armstrong?

A Well, I asked Gerry to brief Mary Sue. The subject was coming up. The negotiations were going on and Mary Sue –

Q This is just prior to the contract?

A Right. Mary Sue had really not been informed before that and now she was the holder of the POA. She was the person who was going to authorize me to negotiate this thing, and she also had — she was a prospective interviewee of the biographer. I wanted her participation.

So I asked Gerry to compile an inventory and also I had spoken to Mary Sue on the phone, and usually our conversations were about legal matters, but sometimes they’d get personal and I would try to give her some good news because she was pretty down and out about her own legal situation and upset at times, and I’d say, “Hey, guess what? Guess what we found? Gerry found this in the archives and we thought it was lost.”

And she would say, “My goodness,” and be quite enthusiastic that, in fact, these things were being recovered and restored.

In fact we discussed the “D.C.” documents which were a lot of materials from early days which she thought Sarah Northrup had taken from Washington, D.C., but which had been transferred from the Washington, D.C. office and ended up in Del Sol and Gerry had recovered these things, and a lot of the things that had been thought lost were there,


and so I was giving her good news. There was personal memorabilia. There were things from her children. There were things, you know, things from her babies and she was delighted and obviously hadn’t seen these things in a while. So I was even willing to send some of them to her to let her see it for old time’s sake.

A When you say she had not been kept abreast, you mean she wasn’t kept informed on a weekly report basis between the beginning of the petition in October 1980?

A Right. She knew what was going on. She knew the kind of activity I did, but I asked Gerry –

Q You had had communications with her at the beginning of the project, but there was not an intense line of communication up to the fall of 1980?

A Right, and I didn’t mention specific documents until I asked Gerry to please compile an inventory and let’s give Mary Sue an idea, and then I also wanted to give her an idea of the value of things and prior to the archives being added to MCCS, I had to collect enough material to get her approval to add archives to MCCS. So I gave her an inventory of values.

Q When you say add archives to MCCS, what does that mean?

A Well, there were several legal projects which MCCS was going to sort out, and they had very specific categories and archives was not part of that. However, ongoing adjacent MCCS and not part of MCCS was L. Ron Hubbard’s estate planning, so I was liasing on that. The archives was


obviously personal possession and therefore part of the estate. As part of the estate planning, it looked like we better get the archives sorted out to assist so that those three things could get done.

When it became apparent to me that it was a pretty big project, I then requested it be added to the MCCS project, and it was. It was approved.

Q Now, did you request Mr. Armstrong to write a full report to Mrs. Hubbard in the fall of 1980 just prior to the signing of the contract?

A Yes.

Q And you were his senior at the time?

A Yes.

Q And did he prepare a report which is marked exhibit J and send it to you?

A Yes.

Q And do you recognize that as having received that in the fall of 1980, Miss Sullivan?

A Yes.

Q And your skills at the time were public relations skills; is that correct?

A Yes.

Q And what was your feeling at the time with regard to whether Mr. Armstrong had public relations or diplomacy skills?

A Well I felt that Gerry was pretty direct and sometimes a little abrasive, and I really didn’t want to upset the apple cart too much or draw too much attention


to this because I didn’t want other people to start getting scared of where we were at.

Q When you say “other people getting scared,” did you mean people in the Guardian’s office?

A I mostly meant messengers.

Q Why did you mean that?

A Well I didn’t consider that they had very good judgment as far as L. Ron Hubbard and his personal affairs were concerned.

Q Were these mostly younger kids in the 18, 19-year-old range?

A Well they were in their early 20’s, and they had been around since their early teens.

Q And who was really the messenger in control at that time? Was it David Miscavige?

A Well, Dede Reisdorf and David Miscavige were the two key people there.

Q And they were only what, 19 or 20 years old at that time?

A Yeah, early 20’s maybe.

Q And so after you received exhibit J, what did you do?

A I asked Gerry to rewrite it a little bit.

Q Ana in what respect did you ask him to rewrite it?

A Well I asked him to be a little more diplomatic on some of the stronger points. I asked him to leave out some of the points that she didn’t really need to hear, the whole


history of everything.

Q Like what?

A Well –

Q Do you recall without having to go through it?

A I didn’t think the details about where things were in this lower hold No. 1 in 1971 were relevant points for 1980.

Q Did you send it back to him suggesting he be a little more diplomatic?

A Yes.

Q And in the second version marked exhibit 26, was it added in that, “I am sending this to you because you are the most knowledgeable on the subject”?

A Yes. I also didn’t want it to be a big surprise to Mary Sue like, “How come I am receiving this? How come I have to receive this?”

I wanted her to get it so I had some kind of words in there as to why we were sending it because what I was doing, I was preparing my ground so I can ask her if I could go ahead and add it to the project.


Q Add it to what project?

A The MCCS project.

Q And she was in charge of the MCCS project?

A Well, she was a technical supervisor or on legal matters and coordinator of it. And I have to say that during the MCCS project I respected her advice a lot more than the messengers who were really just administrative and who got their legal expertise from me and my experience.

Q So as the legal problems began to arise in connection with the biography project, you began to feel that they more and more should be merged into MCCS?

A Could you tell me that one again?

Q Did you think that there should be, as time went on, a merger of the legal problems in the biography project with the legal problems in MCCS?

A I knew that they would be sorted out by MCCS because there was a revision of the agreement between PDK going on.

Q Now, another change from exhibit J to exhibit 26 is what is called a COLRHED; is that correct?

A Yes. Right.

Q Now, did you request what Mr. Armstrong had attached as just a list of the items and actions to be taken at the end of the letter be actually transformed into a COLRHED?

A Yes, I think so.

Q And do you recall why you did that?

A Well, why I put them in a COLRHED?


Q Yes. Do you remember?

A Well, I was trying to officiate what we were doing.

Q When you say “officiate what you were doing,” what does that mean?

A well, there were a couple reasons.

I wanted people to know what was going on in the archives so that if they had those materials, to send them to us.

I was also preparing for approval to do this archives project. And there were also MCCS implications as to why this should be done.

Q Now, did you receive a response from Mrs. Hubbard to exhibit 25?

A Yes, I believe I did.

I think Gerry did and it came back through me.

Q What is your memory of what that response was, Miss Sullivan?

A My instant response to that was that it was “Thank you. Very good.”

Q Did you have any communications with Mary Sue, oral communications with reference to that response?

A Yes.

Q And when did you have those?

A On the telephone during that period of time.

Q And what were those communications?

A They were just enthusiastic encouragement to carry on.


I told her also that we had another guy out doing interviews on the East Coast and that her son had contacted some people on his leave of absence and sort of healed some wounds between family relations; that people said hello to her when we interviewed them; they always remembered her and LRH and send their best regards.

It was basically good news. And sometimes it had to do with specific documents like written works. And I believe I told her about a compilation of some science fiction work that was going on.

I generally was quite open about the kinds of things I was doing in the PR Bureau because I was excited about them and it was about the only good news I had at the time.

Q Were you very close to Mary Sue Hubbard at the time?

A Yes. I have known her since 1967.

Q And were you a personal friend of hers?

A Yes, I was.

Q And did you receive — were you aware at some point that she was removed from her post?

A Yes.

Q And after she was removed from her post did you have communications with her about who had done it, who had removed her?

A Yes.

Q And do you remember approximately when that was?

A It was after I had left the organization in 1982.


Q Did she invite you to come and stay at her apartment?

A Yes.

Q And what communications did you have with her with regard to who removed her?

A Well, David Miscavige removed her. And she said she was tricked.

He also removed me and didn’t lift a finger. Other people executed it. So I considered that he removed us both. And she told me that she felt it was grossly unjust and that she didn’t say the things that he said she said.

And she wrote a report to the people in the organization to correct those things, but nothing was done about it. And she felt exasperated and that they wouldn’t do anything about it and that here I was, out in Canada; she was out. The Guardian’s Office was destroyed and our project had been taken over.

We were feeling kind of rough about it. And, certainly, it didn’t harm our friendship.


Q Could Mary Sue Hubbard have been removed from her post by a 22-year-old boy, David Miscavige, without the approval of L. Ron Hubbard in your experience?

A No.

MR. HARRIS: Object to that; calls for speculation and conclusion.

THE COURT: Overruled.

THE WITNESS: Well, you want to hear about her removal?

Q BY MR. FLYNN: I’d like to.

THE COURT: I am sorry?

Q BY MR. FLYNN: What were the circumstances?

THE COURT: There was an objection to the question, your opinion.

Q BY MR. FLYNN: You answered yes?

THE COURT: Was that your answer?


Q BY MR. FLYNN: She couldn’t have been removed without L. Ron Hubbard’s approval; is that correct?

A No.

Q What were the circumstances surrounding her removal?

THE COURT: This is what she told you.

THE WITNESS: Yeah, and also what David Miscavige told me.

David Miscavige had told me that LRH wanted her to step down and resign and also a number of other things which were not very complimentary about her that apparently


LRH said, including some written dispatches from him about it and about the Guardian’s office, and David Miscavige was also objecting to Mary Sue’s hand in MCCS, and her close communication with me.

He was supposedly my administrative senior and yet she was calling me and we were collaborators, and this apparently was threatening to him and he questioned me about it at length and warned me that I better not side with her and I said, “What side?”

But he said that LRH was against her and wanted her out. And she asked me and knew that somebody wanted her out, and asked who it was and I never told her name. I knew it was him, but what do you do? You don’t tell her it is her husband, so I spared her that, and then David Miscavige apparently, according to him — according to him went to see her and said that, “You are a threat to LRH and these affairs by being in this position and for that reason, you must step down.”

And so she stepped down, and also apparently named me as the big trouble maker and he says that she said it and she said that she never said any such thing, and that is in the letters.

So, I believe her.

THE COURT: We will take a recess at this time. Reconvene at 1:30.

(The noon recess was taken until 1:30 p.m. of the same day.)




THE COURT: In the case on trial, let the record reflect that counsel are present, two of them; the witness has retaken the stand.

State your name for the record, please. You are still under oath.

THE WITNESS: Laurel Sullivan.

LAUREL SULLIVAN, the witness on the stand at the time of the noon recess, having been previously duly sworn, resumed the stand and testified further as follows:


Q Miss Sullivan, you testified this morning about a communication that you saw from Mary Sue Hubbard in response to the document that Mr. Armstrong sent to her which has been marked as exhibit 26; are you certain that you saw a response from Mary Sue Hubbard?

A Yes.

Q Now, you had testified earlier about the frequency of communication to Mary Sue Hubbard up until the fall of 1980; did weekly reports begin to be sent to Mary Sue Hubbard concerning, among other things, what was happening in the biography project?

A Yes.


Q And when did that begin?

A Well, probably more frequently and regularly from July ‘80 if not before.

Q From July 1980?

A Yes.

Q And what was the reason that weekly report began to go to Mary Sue Hubbard?

A So that she could stay abreast of the activities that were going on, what was to be done and what was done.

Q Now did the weekly reports only concern the biography project?

A No.

Q What else did they concern?

A They concerned the MCCS mission.

Q And I believe you testified earlier that there actually was a merger of aspects of the biography project with the MCCS mission; is that correct?

A Yes.

Q And approximately when did that merger begin and then become a full merger?

A Well, late 1980. We were sending copies of the letters. First of all, all legal documents and letters from attorneys were always attached to the weekly reports, and so the first part of the report was what was done and what was to be done and the second part of the report was in a reference letters and in a communication from attorneys from that week, and so when those — when the contract was finalized and when the letters were finalized, they went up


whichever week they fall in.

Q Now, based on the communications that you had with Mary Sue Hubbard, did she know what documents Mr. Armstrong was compiling for the project?

A Yes I think so. Should have been pretty clear.

Q And on what basis do you say that it was pretty clear?

A Well if she didn’t know the exact documents, she would know categories of the types of things that were being collected.

She knew a biography was being done and that covers a person’s lifetime.

Q Did she know that Mr. Armstrong had, for example, the documents from the Del Sol Hotel?

MR. LITT: Objection; calls for a conclusion.

THE COURT; I will sustain the objection. In other words, this witness can’t read the state of mind of somebody else but certainly if she submitted information to her, you can ask her whether it appeared she had that knowledge.

Q BY MR. FLYNN: Did you ever have any communication with Mary Sue Hubbard in connection with the fact that documents had come from the Del Sol Hotel?

A Well it was in Gerry’s submission to her, and so she responded to that. So I assume that she read that.


Q Now, as the senior person in charge of the biography project for L. Ron Hubbard did you keep abreast of all of the types of documents that Mr. Armstrong was compiling?

A Well, I did my best. I didn’t see all of them.

Q But he kept you informed of the categories; is that correct?

A Yes. He did his weekly reports. So I reviewed his weekly reports.

Q And all of those weekly reports were left with the organization to your knowledge?

A Yes.

Q Now, let me show you what has been marked as Plaintiff’s exhibit 7 and ask you if you recognize that.

A Yes, I do.

Q And when did you first see that, Miss Sullivan?

A Well, it would have been late 1980.

Q And do you know whether or not this document went to Mary Sue Hubbard?

A Well, yes, I think so.

Q And why is that?

A Because everyone did. Every single document that — any official document that was completed went up on a weekly report.

Q That had to do with the biography contract?

A Yes.

Q Now, on page 2, paragraph No. 2 of exhibit 7 is a reference to “. . .providing Mr. Garrison with complete


access to our archives and records on LRH including FOI documents, private papers, letters, photographs, logs, legal papers, and the like”; do you see that?

A Yes.

Q Did you know at that time as the person in charge of the biography project that that is the type of documentation that Mr. Armstrong was compiling and giving to Mr. Garrison?

A Yes.

Q Including legal papers of Mr. Hubbard?

A I think that Gerry would have selected appropriate ones. I don’t think he would assume that he could give all legal papers. But I think that, yes, that was included.

Q Were there any restrictions placed on Mr. Armstrong, express verbal restrictions, on what he should collect or not collect?

A No. Rather, I impressed upon him that he — I said, “I want documents. I want dates. I want figures. I want times. I want names. I want places. And that is what you are doing.”

I very specifically told Gerry that that was the kind of documentation that I wanted.

Q And Mr. Armstrong fulfilled that request; is that correct?

A Yes.

Q Was there any question in your mind after the fall of 1980 that Mary Sue Hubbard knew that that was being done?


MR. LlTT: Objection. Calls for speculation, Your Honor.

THE COURT: Sustained.

Q BY MR. FLYNN: In any event, you believe that Mary Sue Hubbard received what has been marked as exhibit 7; is that correct?

MR. LITT: Objection. Asked and answered.

THE COURT: Sustained.

Q BY MR. FLYNN: Now, at some point did you — did you tour the archives with Mr. Garrison?

A Yes, I did.

Q When did you do that?

A On a few occasions.

Q And when was the first occasion that you did that?

A Well, when he first arrived from Utah and we were going to do our negotiations, we went into the area and he had been given a brief description of the kinds of things we had collected.

After the negotiations, he moved to Los Angeles and we went through the archives area and what was in each cabinet. And we set up an office for him in that area so he had frequent access to those files.

Q Did Mary Sue Hubbard know that — strike that. Did you have any communications with Mary Sue Hubbard with regard to the fact that Omar Garrison had free access to those files?

A Yes, I did.


Q When did you have those communications?

A Late in the fall.

Q Of 1980?

A Yes.

That was on the telephone.


Q And what did you say to her and what did she say to you if you recall?

A I told her that Omar was there and he didn’t always come in. Sometimes he left then went back and forth to Utah, so I just mentioned that he was there and there was one point I was curious about which I didn’t ask her, but I was saying other things to elicit a response, which was why she refused to be interviewed personally which was kind of a problem for Garry and kind of a surprise to us that she would refuse such a thing when she knew what was going on and she knew so much and could authenticate things which we were trying to get accurate.

So I was discussing it in that vein, letting her know that people were being interviewed and so on, and she did not volunteer further or anything else, but I told her that he was there.

Q Now, were you familiar with a thing called Controller archives?

A Yes.

Q And did you know that there was an agreement between Mr. Armstrong and Mr. Vorm for Mr. Armstrong to give Mr. Vorm technical materials and for Mr. Vorm to give Mr. Armstrong personal materials?

A Yes.

MR. HARRIS: Well I will object to “agreement,” Your Honor. There was apparently some exchange per both witnesses.

MR. FLYNN: I will withdraw it, Your Honor.

THE COURT: All right.


Q BY MR. FLYNN: What was your understanding, if any, Miss Sullivan, as to what the practice was between Mr. Vorm and Mr. Armstrong with regard to exchanging documents between Controller archives and the archives that Mr. Armstrong was collecting?

A Well both of them had a responsibility to their respective seniors to create a complete archive for which they had a purpose.

That Gerry had some materials that Tom needed, it would be understood that Gerry would turn them over at least copies; that Tom had things that we needed, it would be understood that he would turn them over and there was no withholding of materials when their jobs are to make sure that each has a complete file.

Q And was, in fact, that the practice?

A As I understood it, yes.

Q That personal materials were going from Controller archives to Mr. Armstrong’s archives?

A Yes.

Q Now did you have any communication with Mary Sue Hubbard about that?

A I didn’t personally.

Q Did you –

A As I understood it, Gerry organized that and reported on it.

Q when you reported on it, how do you know that he reported on it?

A Well I think he sent a communication through


the lines up on his own to Tom. It wasn’t just a direct thing. They both had to get authorization to do it.

Q And to your knowledge was it approved that Mr. Armstrong could get access to those materials from Controller archives?

MR. LITT: Objection. Are we talking about to all the materials or what materials? It is vague; or are we talking about materials –

THE COURT: Well, whatever knowledge you had on that subject, you can tell us.

THE WITNESS: Well, to be honest with you, it wasn’t really significant that Gerry would have to clear such a thing with me. This was routine activity on his job, so he was just going about his business and liasing with Tom. However, that they were liasing directly, I think, was cleared through their seniors.

Q Now you, as Mr. Armstrong’s senior, did you ever receive any orders from L. Ron Hubbard or from Mary
Sue Hubbard restricting Mr. Armstrong’s access to Controller archives?

A No.

Q And was there ever any communication of any nature or description that suggested to your knowledge, that went out, that Mr. Armstrong could not have access to Controller archives?

A No, but he would go through Tom for what he needed.

Q Now, Mrs. Hubbard has testified in this case


that she believes she last saw you in 1977, I think it was.

When did you last see Mary Sue Hubbard?

A Late May 1981.

Q And where did you see her?

A At the New Otani Hotel in Los Angeles.

Q And what were the circumstances under which you saw her at that time. Miss Sullivan?

A I arranged a conference room for her and Mulligan, Henning Heldt, Dede Reisdorf, David Miscavige, Bill Franks and possibly one other to discuss some disagreement over the MCCS mission.


Q And who attended?

A Those people and possibly one other.

Q And at that time what was Bill Franks’ position?

A Executive director international.

Q Theoretically, was he the highest official in the Church of Scientology?

A Yes.

Q In fact was he?

A No; in fact, he sat with me in the lobby in the last half of the thing while these other guys hashed it out.

Q The other guys being who?

A Mary Sue, Henning Heldt, Ann Mulligan, Diane Reisdorf, David Miscavige, possibly Gale Irwin. That is all I recall.

Q And they were hashing out aspects of MCCS?

A Yes.

Q Now, what was Henning Heldt’s position at the time?

A He was management liaison for the office of Controller. And so communications to management were going through him and to CMO and so on.

Q And in your experience were these people the people who were running the organizations under L. Ron Hubbard?

A Yes.

Q And David Miscavige was there; is that correct?

A Yes.

Q What was his position at that time?


A He was chief officer of the CMO.

Q Was it understood by the people present that he was the communications link to L. Ron Hubbard at the time?

MR. HARRIS: Understood by this witness, Your Honor?

THE COURT: To the extent of your knowledge of the subject, you may answer it.

MR. LITT: Your Honor, may I say that it appears that Miss Sullivan herself did not attend this conference.

THE COURT: She was part of it. Apparently they were outside when other things were happening.

The question is whether or not Mr. Miscavige was the missing link.

MR. LITT: As the people at the meeting understood. But it wasn’t understood that she was at the meeting.

THE COURT: I got the impression that she was there during part of it.

THE WITNESS: That is so.

THE COURT: To the extent that you have knowledge, what was your knowledge on that subject?

THE WITNESS: About the link to L. Ron Hubbard?


THE WITNESS: David Miscavige told me that there was a line to him, but that it wasn’t something that he could originate and make sure that communication got to him, but that if materials were called for, he could arrange for materials to go to him and requested documents of me and communications from me and even briefing reports from me so that if in fact these things wore called for, that they would


be ready to go.

And I did this a number of times. Sometimes it appeared that there had been a response because of authorization to plans. I didn’t actually see a response, but it seemed to me that confirmations were received.

Q BY MR. FLYNN: Now, was there at that time a reason why the location of L. Ron Hubbard, to your knowledge, was being kept secret?

THE COURT: Assuming that this had nothing to do with information that you acquired in this MCCS program. If it involves that, then you tell us that it does and we won’t go any further.

THE WITNESS: There was one reason. And that was — well, there were a number of reasons. Some of them involved MCCS.

One of them was to avoid subpoena in a lawsuit.

Q BY MR. FLYNN: To your knowledge were there lawsuits going on at the time in which Mr. Hubbard was the defendant?

A Yes.

Q Do you receive communications from Mr. Hubbard in 1980 or 1981?

A Yes, I did.

Q And this was after he had left and supposedly gone into seclusion?

A Yes.

Q What communications did you receive?


A I received the manuscript for “Battlefield Earth.”

I received the manuscript for “The Way to Happiness.”

I received taped messages for Scientologists to be played at events.

I received instructions about what to do with those tapes and messages to send.

I received publishing instructions on the manuscripts and I received instructions on Christmas gifts and the amounts to be spent on people.

My last communication was in May, 1981.

Q Now, just yes or no, do you have any personal knowledge of the fact that the organization was representing throughout 1980, 1981, and 1982 that no communications had been received from L. Ron Hubbard since February, 1980?

A Yes.

Q And was that true?

A No.

Q And was that another shore story?

A Yes.

Q Now, just yes or no, in your office in Los Angeles did you have charts all over your walls showing the money flows of various corporations in connection with RRF?

MR. HARRIS: Well –

Q BY MR. FLYMN: after February, 1980?

MR. HARRIS: I’ll object to the question.


THE COURT: I’ll sustain the objection.

Q BY MR. FLYNN: Let me show you, Miss Sullivan, what has been marked as exhibit 28. It is a dispatch or a letter dated 15 June, 1981 from Gerald Armstrong to yourself re the archives trust; do you recall that?

A Yes.


Q And this is plaintiff’s exhibit 28.

Now do you recall receiving this dispatch?

A Yes.

Q And it starts off, “With the termination of MCCS can you tell me where the archives trust plan is at?”

Do you see that?

A Yes.

Q (Reading):

“Who is handling? What is the general plan? How are my actions regarding artifacts, museum affected?”

Now, when did MCCS terminate?

A The last part of June we wrapped up over a period of a week or two.

Q And while Mr. Armstrong was working on the biography project, were you trying to determine what organization he should be connected to for purposes of the biography project?

A Yes.

Q And how were you determining that?

MR. LITT: Objection, Your Honor. The determination obviously is interrelated with MCCS and how the various corporations or entities were going to be organized.

THE COURT: Well I am going to sustain the objection to that question, but it seems to me that you put into evidence this exhibit 28, and certainly since this witness, I guess, put the words down here, she certainly should have an opportunity to explain what she is talking about because


it appears to be in contradiction to some of the other testimony in the case.

Q BY MR. FLYNN: You responded to Mr. Armstrong’s inquiry on exhibit 28?

A Right.

Q And your response was, “The archives trust is being turned over to R accounts whose hat it is to handle.” What do you mean by that?

A Well, if LRH owned it and they were valuable, then it would be part of the estate and the estate planning was going on, and so LRH accounts was handling that so they would handle the archives trust.

Q And this was part of the sort out that was going on?

A Yes.

Q And the IRS case was proceeding at that time, too; is that correct?

A Yes, but that sort out wasn’t — the estate planning sort out wasn’t part of MCCS.

Q In connection with the IRS case, just yes or no, were you brought in by Mr. Harris to be a witness in that case?

THE COURT: Well what do you mean by “brought in”? Was she called as a witness to testify or was she –

Q BY MR. FLYNN: Did you have a meeting with Mr. Harris with regard to testifying; just yes or no?

A It is hard to answer yes or no.

Q Did you go through a thing called “witness



A Yes.

Q And what was witness school?

A Preparation for witnesses for the IRS case.

Q And was it explained to you that you knew too much to testify?

MR. HARRIS: By whom?

THE COURT: I am going to sustain the objection. It seems to me that what nay or may not have happened in that case creates a lot of collateral issues, and I don’t want to get involved in that.

MR. FLYNN: Fine, Your Honor.

Q You then say, “after that is done” — meaning the turning over the archives trust to R account to inventory and who determines what, “After that is done, then legal can take on the business of setting up a trust.” what did that mean?

A What that meant was that the setup of the new LRH legal office could take on the business of setting up the archives trust and take care of it from there.

Q What was the new LRH legal office?

A That was Terri Gamboa and Norman Starkey, Becky Pook, Maria Starkey, and some new attorneys brought in.

Q And that became Authors Services Incorporated?

A Yes.

MR. LITT: Objection, that is a conclusion. Your Honor. Move to strike.


THE COURT: Well I will deny that motion. Let it stand.

Q BY MR. FLYNN: Now the central office of L. Ron Hubbard, when this was taking place in the summer of 1971; namely –

THE COURT: 1981.

MR. FLYNN: Thank you, Your Honor. 1981.

Q Determining who owns what and turning over R accounts, with regard to the central office — was R accounts in the central office of L. Ron Hubbard?

A It had been moved out of there into a private office.

Q And what was the name of the private office?

A LRH accounts.

Q And did the central office of L. Ron Hubbard become Author Services Incorporated?

A No.


MR. HARRIS: What has that to do, Your Honor, with the exhibit?

THE COURT: I’ll sustain the objection.

Q BY MR. FLYNN: Did the personal office of L. Ron Hubbard become Author Services Inc.?

A Yes.

Q And prior to the time that the personal office of L. Ron Hubbard became Author Service Inc. did you and Mr. Armstrong leave the organization or about that time?

THE COURT: It is a compound question. You can ask about before she left.

Q BY MR. FLYNN: With regard to you, Miss Sullivan –

A It is hard to tell because I took a month off just before I left.

Q You left in November, ‘81?

A Yes. I was gone throughout October. So give me that question again.

Q Do you know when Author Services Inc. began?

A I know that it began when they took over from MCCS. But whether it was official, the paperwork, I am not exactly certain.

Q But in any event you are certain that the personal office became Author Services Inc.; is that correct?

A Yes.

Q And to your knowledge is that a for-profit organization handling all of L. Ron Hubbard’s affairs?

MR. HARRIS: I’ll object to that, Your Honor.


THE COURT: I’ll sustain the objection.

Q BY MR, FLYNN: Then you say, “right now it doesn’t affect what you are doing.”

What does that mean?

A Well, what it meant was that Gerry was going about his business, performing his duties and supplying Omar. He was taking care of the documents. They were in safekeeping. He kept excellent receipts. So if there was aver to be any reimbursement for funds spent and then to sort out that, this wouldn’t be a problem. So he could just carry on with his job and let the legal work catch up to him.

Q And this legal was all ongoing to determine who worked for who and where the monies were coming from and who owned what; is that correct?

A Yes.

Q Then you say, “You are working for the CSC and supported by SOR belonging to CSC.” What did that mean?

A Well, that is kind of a shore story.

What it means is that the money that Gerry was getting was coming from the Church of Scientology of California reserves.

Q Who controlled those reserves, to your knowledge?

A A number of people had access to them. L. Ron Hubbard had control.

Q Now, you say it was a shore story; was it a


shore story similar to the Friends of Norton Karno shore story?

A Well, in a sense. But there is also some aspects to it that are part of MCCS.

It makes it difficult for me to answer.

Q What are those aspects?

MR. HARRIS: Well –

THE COURT: I’ll sustain the objection.

MR. FLYNN: Your Honor, they introduced the exhibit.

THE COURT: Well, that is true. But I don’t know that that would necessary work a waiver of the whole kit and kaboodle here.

Q BY MR. FLYNN: You say, “. . .when the new corps get set up, you’ll be paid by the new corp. But very likely will receive your project funds by CSC.” What does that mean?

A Well, CSC had a responsibility to supply and cooperate with the biography project and so that they would do so, as the new corporation ASI would get set up or some similar named corporation.

Q ASI being Author Services Inc.?

A Yes.

Q The management company for L. Ron Hubbard?

MR. HARRIS: Objection, Your Honor.

THE COURT: You don’t have to keep repeating things. I’ll sustain the objection.

THE WITNESS: That it was evidence to me that is where Gerry would go. But in the meantime, that is where he got


his money from, from Sea Org Reserves. And if there was any reimbursement to be done, then that would be done.

But the church was cooperating anyway. So it didn’t really affect him is what I was telling him in the overall.

Q BY MR. FLYNN: Now, is there any question in your mind but that that is a shore story that he was working for CSC?

A No, none.

Q And why is that, Miss Sullivan?

A Well, he was performing duties and responsibility to L. Hon Hubbard. And he wasn’t responsible to anybody else for his duties.

He was coordinating between church people. And he was using church monies. But he wasn’t responsible to them except perhaps for receipts and accounting.

Q He was using church monies for L. Ron Hubbard’s biography?

A Well, yes.

There was Xeroxing to be done and paper supplies and documents to be collected up and that sort of thing.


Q Now then you say, “We will cross that bridge when we come to it”; and what does that mean?

A Well I was trying to just let Gerry know that he wasn’t really affected by all this sort out. I was leading the project. I didn’t know exactly how it was going to turn out.

I had made my recommendations and I couldn’t really give him a stable answer other than what I saw as the imminent thing that would occur.

Q And what was the imminent thing that you saw occurring?

A Well I considered that he would be personal office staff and he would be moved out with the rest into a corporation that were acting as an agent for L. Ron Hubbard.

Q Well you had previously testified that there was no corporate integrity to any of these corporations; is that correct?

A Yes.

Q And did you include the Church of Scientology of California in that, that there was no corporate integrity?

A In my experience, yes.

THE COURT: Well, the word has been used in different ways, and as I gather the directive or that bulletin that Mr. Hubbard apparently issued had to do with integrity in the sense of maintaining separate identifies.

Integrity, of course, has other meanings and I am not sure whether you are meaning it in a more general sense; traits of character or honesty and things of that nature


or you are talking in terms of whether there was a separate corporate entity that was separate and distinct and existed separate and apart front these other corporate entities or Mr. Hubbard. I am not sure.

Q BY MR. FLYNN: When you say there was no corporate integrity, Miss Sullivan, what do you mean?

MR. HARRIS: And not based on MCCS.


Q BY MR, FLYNN: Basing your observations from 1966 when you joined the organization up until 1980.

A Well, who was really in charge and who was really in control was L. Ron Hubbard.

The people who were on the boards of directors in the Church of Scientology of California, or other churches that I knew were not really performing either managerial functions or controlling functions. I saw minutes, board minutes passed around, prepared for them by legal people just for signature, and the rest belongs to a later time.

THE COURT: Al [All] right.

Q BY MR. FLYNN: And does that include the practice of procuring undated resignations from members of the Boards of Directors?

A For OTC, yes.

Q And well to your knowledge was that done for other corporations?

A Yes.

Q Now, in your experience if any board of directors of any Scientology organization issued any paper of an order


or command that was contrary to the command or order of L. Ron Hubbard, which would have been obeyed?

MR. HARRIS: Well, I am not sure how a board member issues an order and a command, Your Honor.

THE COURT: Well, sustained. It is rather ambiguous.

Q BY MR. FLYNN: Well, do you know what corporate resolutions are, Miss Sullivan?

A Yes.

Q And do you have a general idea of what boards of directors of corporations do?

A Yes.

Q And what is that understanding?

A Well they manage the affairs of the corporation and decide on appropriation of funds and record their meetings in minutes and those are legal documents, and that the corporation has a single identity.

Q And in your experience prior to 1980, did corporations act within the Scientology structure –

MR. HARRIS: Well –

MR. FLYNN: — with corporate resolutions?

MR. HARRIS: I will object, Your Honor. May I voir dire the witness?



Q Were you on any boards of directors of any Scientology organizations, Miss Sullivan, prior to 1980?


A No, I was signatory on bank accounts for a time.

DIRECT examination (Resumed) BY MR. FLYNN:

Q Well, prior to 1980, Miss Sullivan, did you become aware of what the corporate relationship of Scientology organizations was to Mr. Hubbard?

A Yes.

Q And how did you become aware of that?

A Well I worked closely with him, so I knew what his activities were. I saw minutes passed around. I know how corporate resolutions were done.

Q And how were they done?

A Well the legal branch prepared the documentation, something for signature to the board of directors. That happened in Los Angeles. It happened in the United Kingdom when we purchased the building for AOUK, and although I wasn’t personally getting signatures like that, I did see it from time to time.

Q And where did the order come from to your knowledge to create those resolutions and minutes?

A Well, they were originated from, the routine ones, were originated from the legal bureau.

As far as major purchases or major setups, they were often directed by LRH.

Q Let me show you a declaration.

We just had this typed, Your Honor, so we


are just going to have to have it signed on the witness stand.


MR. LITT: Your Honor, before there is any inquiry on this, can we finish reviewing it?

THE COURT: I guess all he wants to do is ask her to sign it.

MR. HARRIS: It is all right.

Q BY MR. FLYNN: Would you review that, Miss Sullivan, and if it is accurate, execute it?

A There is one thing here I want to ask about.

Q Is there a correction you want to make, Miss Sullivan?

A Yes, I think so.

Q Why don’t you write it in and initial the correction.

A There is another correction here.

MR. FLYNN: May I show Your Honor the correction? And I’ll show the corrections to counsel.

THE COURT: Let counsel see it first.

MR. LlTT: Your Honor, we have substantial objections to this. Initially, we ask that it be filed under seal. And after the court reviews it –

THE COURT: Well, I don’t at this point –

MR. LITT: It violates the privilege, Your Honor.


THE COURT: Well, I don’t at this point –

MR. LITT: It violates the privilege, Your Honor.

THE COURT: Well I was saying something, Mr. Litt.

MR. LITT: I am sorry. I apologize.

THE COURT: I think that the witness has already testified to enough here to keep the plaintiffs’ lawyers busy in cross-examination, and in the meantime, the court will have an opportunity to review this and think about.

One time it was mentioned that Mr. Harris had some documents he wanted to submit in camera.

MR. HARRIS: Yes, Your Honor.

MR. LITT: Yes, we do.

THE COURT: And if you want to do that, you may do so and I will not have this filed at this point, just maintained by the court. The court is going to review these things and we will think about it.

MR. FLYNN: Am I going to have the opportunity to see these documents?

MR. HARRIS: Not unless the court orders it. This is for in camera submission.

THE COURT: Okay. I will look at them.

MR. FLYNN: May I just inquire, I see roughly perhaps that half inch of documents.

May ask the witness, Your Honor, how many documents exist in the MCCS files?

MR. HARRIS: Your Honor, I can tell you that there is two, at least two large boxes of MCCS files, and as I indicated on the record before, I went through and pulled items.


Some are transcripts of tapes as there is a tape under seal. There are memos to counsel. There are memos back from counsel. There are communications by this witness.

THE COURT: Well I will review it.

MR. HARRIS: If the court desires the whole two boxes, though, I am certainly willing.

THE COURT: No, I didn’t say that.

Do you know whether any of these documents were provided to Mr. Garrison that counsel has referred to, these boxes at MCCS?

THE WITNESS: I don’t think so.

Q BY MR. FLYNN: Do you know whether tapes were provided to Mr. Garrison of some of the MCCS meetings?

A Well I do know that Gerry had one. I don’t know if Garrison got it.

THE COURT: Well I don’t see any reason why we can’t go ahead.

Do you have any further questions aside from MCCS? This would be the time to do it and counsel could cross-examine.

MR. FLYNN: I do have some.

MR. LITT: May I make one point which I guess we will address this more, but we just want to make clear that one of the things when the court reviews it we’d ask the court to look at, that any efforts to pierce the privilege must be done by extrinsic evidence, and to the extent that this appears to contain information that comes from MCCS, itself, there is a question to moving to strike that.


THE COURT: We will deal with that in due course if we get to it.

Q BY MR. FLYNN: Let me ask you this, Miss Sullivan: With regard to what has been marked as exhibit 28, wherein you state that you are working for the CSC and later on, “We will cross that bridge when we come to it.”

Was that statement made by you in that way because of the fact that the MCCS mission was sorting out who was working for Mr. Hubbard and who would be goig [going] to the new corporation?

A Yes.

Q And this was prior to the new corporation being created? is that correct?

A Yes.

Q And were there issues relating to Mr. Armstrong receiving $4 per week — or strike that — receiving approximately 17 to $20 per week while he was working on the biography project?

MR. LITT: I am going to object to that, Your Honor. I think to the extent they can ask a general subject matter, but as to issues, they are issues that were raised in consultation with attorneys about various legal requirements.

THE COURT: Well I will sustain the objection. It is over broad.

Q BY MR. FLYNN: You know that Mr. Armstrong and you were working for L. Ron Hubbard; is that correct?

A That is right.


Q And Mr. Hubbard — you knew that Mr. Hubbard was receiving or was going to receive the money from the biography project; is that correct?

A Yes.

Q And you knew that Mr. Hubbard owned the archive; is that correct?

A Yes.

Q And you knew that Mr. Hubbard was going to place the archives in a trust for tax deductions; is that correct?

MR. LITT: Objection; that calls for speculation.

MR. HARRIS: It calls for a legal –

MR, LITT: Calls for a legal conclusion that is speculative.

THE COURT: She can testify whether she believed they were going to be placed in a trust. The purpose of that was irrelevant at this point.

THE WITNESS: That was my plan.

Q BY MR. FLYNN: Was there a problem that arose with regard to the amount of compensation that Mr. Armstrong was receiving in connection with the biography project when he was doing this work for Mr. Hubbard?

MR. LITT: Same objection, Your Honor. The problem, if there is a problem –

THE COURT: Well I don’t know what the question might be. If it is involved in this legal arena, then, of course, it would be privileged at this point. I haven’t concluded that it isn’t privileged, so I will sustain the objection.


Q BY MR. FLYNN: Let me ask you this, Miss Sullivan: Was it because of legal problems that you wrote what you did on exhibit 28?

A Yes.

Q And in actual fact and practice was Mr. Armstrong working for the Church of Scientology of California at that time?

A No.

Q Now at some time were you held under guard?

A Yes.


Q And when was that?

A It was twice; once in 1978 and once at the Cedars Complex in 1981.

Q And what were the circumstances under which you were held under guard on those two occasions?

A In 1978 it was when I was sent to the RPF. And I said, “I want to speak to my husband.”

And I wanted to leave. So I was held under guard and kept apart.

THE COURT: What do you mean by “held under guard’? Can you describe what you mean?

THE WITNESS: Well, there was a person posted at the door which I couldn’t leave unless I got past that person. As I understood it, it was a 24-hour guard. And my meals were delivered to me.

I was escorted to the bathroom. And I felt under guard.

And in 1981 I had a guard posted at my bedroom. And I was in a locked area where I couldn’t leave.

When I needed to purchase some things at a store, I was escorted against my will.

I was escorted to and from meals and I had to ask permission to go to the restroom.

Q BY MR. FLYNN: Now, Miss Sullivan, do you recall while you were in the RPP or at other times whether you were requested to sign nondisclosure and release bonds?

A I don’t really recall signing anything like that, but I know it was customary.


Q Now, do you know what corporate name is was customary to put on these bonds?

A Church of Scientology of California.

Q And in your experience when people were signing these bonds did they understand what they were signing?

MR. HARRIS; I’ll object to that, Your Honor.

THE COURT: Sustained.

Q BY MR. FLYNN: Do you have a present recollection of even having signed one?

MR. HARRIS: She just stated she didn’t.

THE COURT: Overruled.

THE WITNESS: I do remember signing one. I may have signed more. It didn’t really seem all that significant to me.

I know I refused to sign one.

Q BY MR. PLYNN: Did you read it when you signed it?

A Oh, yes.

Q Do you recall what was in it now?

A Well, the one that I signed was a nondisclosure bond about activities within the Commodore’s Messenger Org and their connections, their business.

Q Now, what was the one that you wouldn’t sign?

A It was the one that said that I hadn’t been held or incarcerated.

So I told them we could cross that part out and I would initial it or they could retype it.

They said they would retype it, but they never


came back with it. So I never signed it.

Q When was that?

A After I left and came back to sign their bonds. It was in February, 1982.

Q Now, did you –

A It could have been December, ‘81, I’m not sure. I came down a couple of times.

Q Did you come back and do that to prevent them from thereafter harassing you?

MR. LITT: Objection. Leading.

THE COURT: What was your purpose in coming back and doing that if you had a purpose?

THE WITNESS: I figured if I didn’t do that I would be harassed and declared and Fair Gamed. And so I did it.

And I was Fair Gamed anyway.

Q BY MR. FLYNN: At some point did private investigators start going to where you were living and your parents and that type of thing?

A They represented themselves as from my parents to one former employer. And one person from the church called my father and told him that he was a friend of mine and that he should give him my address which my father did not do. That was also a misrepresentation.

Q Prior to your testifying here today were you fearful of the repercussions of your testimony, of coming in and testifying?

A Yes.

Q And when did you first meet me, Miss Sullivan?


A In February, 1984.

Q February, 1984?

A Yes.

Q And thereafter — just yes or no — did you give testimony before several governmental agencies from Canada and the United States in Florida several months ago?

A Yes.

Q And were you given promises at that time that you would not be prosecuted in connection with any of your activities in Scientology when you testified?

A Yes.

Q And have you been asked by the Canadian government to testify in an upcoming legal proceeding involving a pending criminal investigation in Toronto, Canada?

MR. HARRIS: What is the relevance of that, Your Honor?

THE COURT: Maybe he is anticipating what you are going to be asking to show bias, motive, or interest.

MR. HARRIS: Please, Your Honor, instruct him not to anticipate what I am going to do,

THE COURTi I’ll sustain the objection.


Q Now are familiar with a practice of the organization called Freeloader Debts?

A Yes.

Q And what is that practice?

A That is a practice of retroactive billing for services rendered to Sea Org members or staff members after breakage of contract.

Q Breakage of what contract. Miss Sullivan?

A Either the Sea Org member contract or an organization contract.

Q How when you say a Sea Org member contract, are you talking about the billion year contract?

A Yes, and there was a policy that I revived with Lyman Spurlock in, I guess it finally came out in 1980 or ‘81. I guess it is the current thing on Freeloaders, and whereby we revised some of the documents and everybody signed new contracts as well as the billion year thing.

Q Who is Lyman Spurlock?

A He is the investments officer.

Q International in the Church of Scientology?

A Yes.

Q And he is currently the head of ASI if you know?

A I suppose so.

Q And he works with you in the MCCS mission?

A He wasn’t on the mission, but I consulted him.

Q Did you consult him to get amounts in bank accounts?


A Yes.

Q And with regard to the Freeloader Debt practice that you knew about during your years of Scientology, what was it?

A It was a billing practice whereby staff members were billed the full price and sometimes not even the price at the time they received the service, but rather just the full price at current rates, and sometimes the debts were upwards of a hundred thousand dollars.

Q When an individual tried to leave?

A Yes.

Q And were those individuals made to understand that those were legally enforceable debts?

A Yes.

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

THE COURT: We will take a 15-minute recess. (Recess.)


THE COURT: Let the record show that counsel are all present; the witness has retaken the stand.

State your name again for the record. You are still under oath.

THE WITNESS: Laurel Sullivan.

THE COURT: Mr. Harris, you may proceed.

MR. HARRIS: Do you mind if we switch and I go first and Mr. Litt goes second, Your Honor?


MR. HARRIS: Thank you.


Q Miss Sullivan, did I teach a witness school?

A No, not personally.

Q And you did not testify in the IRS case?

A That is correct.

Q When was the first time that you met Mr. Hubbard?

A November, 1967.

Q And you were on a clearing course at that time?

A Yes, I was.

Q And were you offered a chance by some group called the OT Committee to go aboard a ship; is that correct?

A Yes.

Q And you leapt at the chance to do that; right?

A Yes, I did.

Q And at the time you knew what Scientology was?

A I hadn’t experienced all of it, but I was getting


up there.

Q And was it your understanding that Scientology was a religion?

A No, not really.

Q So if you would have written things about spiritual gains in those days, you wouldn’t have been talking about anything religious in your opinion?

A Well, I’m sure that I did write things about spiritual gains. And I’m sure I considered them personal enlightenment. I didn’t consider then a form of worship or traditional religion.


Q Such as Christianity?

A Such as Christianity or anything I had been U3ed to in my upbringing.

Q It was different in that respect that people didn’t go into a chapel and hear somebody preaching?

A Right.

Q But you had received auditing at the time that you were approached by the OT committee?

A Yes. Actually I wasn’t approached. I went and applied.

Q You volunteered to do that?

A Um-hmm.

Q Just so the court reporter can get it, uh-huh means yes?

A Yes.

Q And at the time that you volunteered to do this; that is, go aboard the ship, did you know what the purpose of the going aboard the ship was?

A It was to help Ron set up an OT base. Other than that it wasn’t real clear until you got aboard the ship. Then you got briefed.

Q It was the ship’s mission to find a safe OT base; is that correct?

A That is right.

Q And had you yourself experienced what you considered harassment in East Grinstead prior to getting aboard the ship?

A No.


Q You were the receptionist; were you not?

A Yes.

Q And you would talk to other people who were at St. Hill about what was happening to them; right?

A Yes.

Q And you understood that at least in their minds there was some harassment going on; is that correct?

A I didn’t look at it that way at all.

Q Have you made contrary statements in the past?

A I may have. That was the PR line.

Q Well when you went aboard the ship, you knew that you were refused admittance to Gibraltar; right?

A Yes.

Q And you knew by that time about some Parliamentary action in Australia; right?

A Yes, vaguely at the time.

Q And the vague understanding that you had was that Scientology had been banned in Victoria, is that correct?

A Yes.

Q Prior to the time that you went aboard the ship, you actually applied voluntarily as you said; right?

A Yes, I did.

Q Now to whom did you apply?

A Well, a lady by the name of Janet Gilford called the house where I was working — or living and asked for someone else who was a friend of mine, and I intercepted the call and said, “Hey I want to come. These guys are leaving.


I want to go.”

I had heard the taped lecture “Ron’s Journal 67? that September or October where he, himself, said that he needed help, so I said, “Okay, I will go.”

I was under age, and so they didn’t really want to take me, but I talked my way under the wire.


MR. HARRIS: Your Honor, I have an item that is addressed to “OT activity volunteer.”

May that be marked plaintiff’s next in order?

THE COURT: All right. 76.

THE WITNESS; My old application.

Q BY MR. HARRIS: I ask you if you recognize that.

A Yes. I do. My handwriting sure has changed, though.

Q And you were hoping to be accepted by filing that application; right?

A Yes, I was.

Q And you were in fact accepted?

A Yes.

Q Now, when you aboard the ship, that was in Southampton Harbor?

A Yes.

Q And your first job on the ship was as a cook?

A No. It was a steward.

Q Did you at some point become a cook?

A Yes, later in 1968.

Q Now, when did you join the Sea Org?

A Well, I think I signed my Sea Org contract somewhere around the end of February.

Q The end of February of what year?

A Of ‘68.

Q Now, about that time you knew how the Sea Org had started; right?

A Yes, pretty much.


Q And it happened one evening aboard a boat or a ship called the Avon River?

A Well, I have told that story. And I have heard that story. But I wasn’t there.

Q You heard the story from the people who were there?

A Yes, I have — well, yes, from one of them.

Q And then you told it to others?

A Yes, I did.

Q And the story that you told, I take it you believed; correct?

A I figured it was a good story.

Q Did you believe it?

A I didn’t know.

Q The story that you told was that people who were with Mr. Hubbard at the time decided to do this on their own; is that right?

A Yes, sir. I did.

Q And they told Mr. Hubbard that they wanted to pledge themselves to him; is that correct?

A That is the story.

Q And the group suggested a life time contract?

A Well, as I understand it, it was — that is not quite how I understand the story,

Q Tell me how you understand it.

A The story goes that Ron Pook and John O’Keefe and LRH were talking one night. And they were saying that, really, “we ought to firm this thing up.”


And it looked awfully good, these people around and helping LRH.

“We ought to firm these things up and make a group out of it.”

And one suggested a contract and LRH apparently said — this is according to Ron Pook — apparently he said at that time, “Well, do you really think we could do that?”

And he said, “Well, yes. We could do it.”

And somebody said, “Well, for how long?”

And somebody else said, “For 10 years.”

And somebody else said, “For 20 years.”

And LRH said something, “Well, maybe that is too long. Maybe we’ll be done by then.”

And that is as far as clearing the planet and all that jazz.

And somebody else said — I think it was John O’Keefe — “Well, 10, 20, a billion, what is the difference?”

So it became a joke.

I like the story because it got LRH off the hook PR-wise for dreaming up a billion year contract.

Q And you said that the adventure that they were in was to help Ron clear the planet; right?

A Yes.

Q And that is what you wanted to do when you joined the Sea Org?

A No. Actually, when I joined the Sea Org the mission of the Sea Org was to get ethics into [in on] the planet.


I didn’t think they would be able to do it; so I was just really having a good time.

Q So at least as far as you were concerned, it didn’t make any difference what the overall purpose of the group was; you were having a good time and wanted to continue having a good time?

A Yes. I was on an adventure. And I think those people there were on an adventure. And I was willing to follow the rules to have some adventure. If that was the rule, then I went along with it and agreed to it and did it and supported it.

MR. HARRIS: I have a document, Your Honor; may it be marked Plaintiff’s next in order?


Q BY MR. HARRIS: Let me ask you if you recognize exhibit 77.

A Boy, you guys are good on your records.

Q Yes.

A Even I couldn’t find this one.

Yes, I do recognize it.


Q And that is the contract you signed?

A Yes it is.

Q Now when you were on the ship and held these various positions in the beginning were the people aboard the ship Scientologists?

A Well for the most part. Some were not.

Q You had a couple of people who were not?

A Well most of the engine room was not and the boatswain and the carpenter were not, and shortly after we arrived in Valencia, the galley crew was not.

Q And you learned to be a crew member?

A Essentially, yes.

Q What did you learn?

A Well in the beginning I learned how to clean decks and how to make up beds, ship’s style. How to cook and how to serve while you are at sea. How to walk on a rocking deck, and I learned how to tie knots and how to stand a watch on Condition 1.

I learned how to climb up the forward mast and rig up a light, and after that I got some more formal training up to quatermaster [quartermaster] and a little bit of celestial navigation.

Q On board the ship, which at that time was the Royal Scotsman?

A Royal Scotman.

Q Scotman?

A There is a distinction.

Q All right, on board the Royal Scotman, the


first port in which you were able to stop was what?

A Well, we anchored off Monte Carlo to take on some emergency stores, and then we docked at Caliari in Sardinia.

Q And when was the first time that you saw Mr. Hubbard aboard the Royal Scotman?

A About the second night — the first night.

Q And he came down to the galley area?

A Yeah, actually the first time I saw him was when he was — when he divvied up the watches, but in the galley area was where I first spoke to him myself.

Q And at that time you thought he was a warm, nice human being; right?

A Yeah. I also thought he was pretty formidable.

Q When you went off to England from the ship, when was that?

A Off to England?

Q You did go to England from the ship?

A Yeah, that was May 4, 1968.

Q And at that time what was your post?

A It was as the mission in charge to assist in procuring the building, the old YMCA at 20 Southbridge in Edinburgh and thereafter to set up a household unit which would then accommodate about 27 people.

Q What was the purpose of that mission?

A I think I just stated that.

Q No, I mean you were going someplace to set up something; what was the purpose of the something? That is


what I meant to say.

A We were setting up an AO.

Q And an AO was an Advanced Organization?

A Yes.

Q Where upper level Scientology materials would be delivered?

A Yes.

Q What was your post prior to going on that mission?

A Well I had been on the liability cruise as cook, and before that there was some administrative posts on the ship itself.

Q Well let me ask you this: Miss Sullivan, were you at the time that you were aboard the ship taking any kind of courses?

A Well, I was enrolled in a clearing course already. I went clear on February 14, ‘68, and then I didn’t enroll in anymore until we got selected as a team to go off on this mission and then I did a couple of OT levels, one in a hotel room while I was on the job, and then as a member of the selected team, I went first to sort of set up in advance of the rest and it was a Flag mission. The whole team was part of the same mission.

Q Now when you say “it was a Flag mission,” what was Flag?

A It was the ship where the Commodore was and so it was considered a Flag mission.

Q And by that time Mr. Hubbard had been named the



A Yes.

Q When you went to England, you left from what port?

A Valencia.

Q And there was a functioning land base in Valencia?

A Yes, Alicante.

Q And at Alicante students and preclears were coming in from around the world?

A So I understand. I was never there.

Q You didn’t go to the actual place where the activities were going on?

A No, I was in a hotel transporting communication and sending messages back and forth at that time.

Q Now, at the time you knew that you were or at least you told people that you were Operation Transport Corporation; is that correct?

A Well I think at that time we were Operation Transport Services, so we might have changed early on there.

Q But you were fairly openly Scientologists at that time; right? In other words, you didn’t try to hide the fact that you were Scientologists?

A No, we didn’t try to hide it, but we weren’t out in the street disseminating to anyone particularly. I only know of one business contact where I got some materials printed in Spanish. I mean it was in English and the Spaniards didn’t understand it, so the security angle wasn’t an issue.


Q At least as far as the people with whom you dealt, they didn’t — strike that.

The people with whom you dealt as far as supplies and so on, nobody told you to tell them that you weren’t Scientologists?

A I didn’t deal with people on supplies. I just picked the Telexes, went to the agent.

Q Other than this one item of Spanish –

A Printing.

Q Right.

Now, when you went to England you stayed in England for a short time and then went to Scotland?

A Yes. It was just a day or two to pick up some funds from Herbie and go on up to Edinburgh.

Q And there to open another advanced organization similar to what was going on in Valencia or that was your understanding?

A Yes, to set up an AO base there.

Q And did you set it up?

A Yes.

Q And then you had people coming in from various places in the world in order to take Scientology services there?

A That is correct.

Q Did there come a time when the UK government stopped Americans from coming for Scientology services?

A Yes.

Q When was that?


A I believe the date is July 28, 1968.

Q That was after you had established the AO in Scotland?

A Yes, May, June, whatever.

Q And I take it that that ban applied as well to the Scottish organization?

A Well, it didn’t at first. But then the — then it seemed to later. We were worried that it would.

Q And so a plan was developed to set up an advanced Org back in the United states?

A Right.

Q And you went back to the ship for purposes of firing on a mission to come to Los Angeles to set up an advanced Org here?

A No, not correct.

What happened was I was there in the UK and they split the crew down the middle; the Americans would go to America and the British would stay.

As a Canadian I was supposed to go with the Americans. And I chose to stay there.

So I kind of had to get a special okay to stay in England with the English because I was Flag crew. I wanted to get back to the ship.

So I got the okay as a Canadian to stay in the UK.

And then I worked there until May of ‘69 when I returned to the ship.

And then after that in October of ‘69, late.


October, I went to Los Angeles. And by that time the original AO in Loa Angeles was already set up functioning. And I just took over at a low period.

Q when you took over your post was what?

A Super cargo –

Do you mean in AO LA?

Q Yes.

A Super cargo LRH communicator.

Q You were there to see the AO survive?

A Yes, to boom the AO.

Q And also to do something with the American Saint Hill Organization?

A Yes, that came later.

Q Which you understood to be a part of the Church of Scientology of California?

A Yes.

Q At that time?

A Yes.

Q You understood that?

A Uh-huh.

Q And the Advanced Organization that was existing there was part of the Church of Scientology of California? right?

A Yes.

Q And the American Saint Hill Organization and the Advanced Organization were both delivering Scientology services?

A Right.


Q Separate churches within a corporation Church of Scientology of California so far as you understood it at that time?

A Yes.

Q Now, did you have any finance posts while you were in Scotland or in the United States?

A Yes, I did.

Q What were those?

A In Scotland I was a cashier. And then I was the LRH communicator; so I had access to financial reports.

And then in the United States I was the super cargo and in charge of division 3 which is the treasury division and a member of the executive council doing the financial planning.

Q And as cashier, I take it you banked all the monies that came in?

A I invoiced them and turned over receipts to be banked.

Q And as super cargo in Los Angeles you made sure that the monies that you received were banked by your treasury division?

A Yes. Sometimes I banked it myself.

Q And the account in which you banked the monies in Los Angeles was a Church of Scientology of California account?

A Yes, it was.

Q And you made sure that the money was banked before it was spent?


A Yes.

Q In other words, you didn’t take cash out; you were very careful about making sure that it got into the bank before you did any financial planning; right?

A Well, I don’t remember taking any cash out.

Q Now, the accounting system that you had at that time required that you write an invoice for all funds received; is that right?

A Yes.

Q And a disbursement voucher for all funds dispersed?

A Yes.

Q And the Advanced Organization in Los Angeles was supposed to send some support money to the ship; right?

A Yes.

Q And where was the money sent?

A As I understood it, it was sent to Switzerland.

Q Did you understand the name of the account in which the money went?

A I probably knew the name once, but I don’t recall it now.

Q And when you were in Scotland with the Advanced Organization there that organization was also supposed to send support money to the ship; is that correct?

A As I understand it, the money from the UK didn’t actually leave the country.


Q So no support money went from the Advanced Organization in Scotland to the ship?

A I am not sure about that. I think it was retained in the country or in England.

Q The money that went for the support of the ship at that time which went to the Swiss account, did you know what was happening with that money?

A My instructions were these and this is what I knew: What I knew was that our mission was to support the Sea Org from one organization to make enough funds to take care of every Sea Org expense and every eventuality that the Sea Organization would have, and that crossed corporate boundaries and that is what I did and I don’t really have details beyond that.

Q Well in 1969 when you were at the Advanced Organization, did you send any money to L. Ron Hubbard?

A To his account, you mean?

Q Yes.

A No, I did not.

Q In the advanced organization in Scotland were you aware of any money going to L. Ron Hubbard personally?

A No, I don’t think so.

Q And after your post at the Advanced Organization in Los Angeles, you then returned to the ship?

A Yes.

Q And what year was that?

A 1971.

Q You were aware through reports, I take it, that


the ship had to leave the Spanish ports?

A Yes.

Q And you were aware through reports that the ship had to leave Corfu?

A Yes, I found that out after I returned.

Q You talked to the people aboard?

A Yes, We weren’t permitted to have any information about the location of the ships while we were on Garrison mission.

Q But you did manage to communicate with the ship; did you not?

A Yes, but as far as locations and their local business, that was top security.

Q In other words, the people who were in the United States couldn’t know the location of the ship but still could communicate with it?

A Pretty much. I think at different times the security was completely off and then it was back on again.

Q When you went back to the ship in 1971, was Mr. Armstrong aboard?

A I don’t specifically recall, but I think he probably was there then.

Q What is the post that you had when you arrived back to the ship?

A Director of Processing for the Class 12’s.

Q And for how long did you hold that post?

A About two or three weeks and then I got promoted


to LRH Comm.

Q Before becoming LRH Comm, which is LRH Communicator; right?

A Yes.

Q What did you observe about what L. Ron Hubbard was doing on the ship?

A Before I became LRH Comm, Flag, you mean?


Q Yes.

A Well –

Q I am talking about the period from the time you left Southampton to the point where you became LRH Com, understanding that you were in Scotland and also in the United States.

A Okay. So what did I understand about his activities?

Q No; what did you observe.

A What did I see him do?

Q Yes.

A I saw him command the ship in all phases and instruct people as to what to do with the ship.

I saw him instructing officers and the captain of the ship.

I saw him instructing technical personnel.

Q When you say, “instructing technical personnel,” what do you mean by “technical personnel”?

A I mean telling them to set up sessions and to get this person under session; get then audited; get them trained; reorganize that office; this goes here; that goes there.

Let’s see. I saw him briefing people on our sailing plan.

I saw him brief the crew on international activities, management activities, ship activities, ship movements, local customs.

I saw him attend parties.


I saw him case supervise folders.

Q “Case supervise folders”?

A Yes, review processing folders.

Q For what purpose?

A For the purpose of supervising of auditing going on.

Q Okay.

A Okay, I saw him in his office. Anybody could walk by his office and look in the window and see him at his desk working. Sometimes you could see what he was doing; sometimes you couldn’t.

I saw him on his own boat.

Q Which was?

A Chris-craft.

Q As opposed to the Royal Scotman?

A As opposed to the Royal Scotman.

I saw him go ashore a couple of times.

Q You saw him — you also saw products that he was producing; right?

A Oh, yes.

Q Issues?

A Yes. I saw policy letters and bulletins and Flag orders and the whole works.

Q And also the command section of the orders of the day?

A Yes.

Q Now, during the period that you were observing him was it the case that he was — strike that.


Did you see him performing any outside activities, that is, for anything other than Scientology, whether it be management or technology?

A I don’t understand your question.

Outside Scientology?

Q Well, outside activities like a business ashore selling shoes or anything like that.

A He didn’t sell any shoes.

Q All right. Do you know if he sold anything prior to your becoming LRH Com?

A I never saw him sell anything.

Q At the time that you became LRH communicator, this was aboard the ship?

A That time was in ‘71, yes.

Q Yes. And what was your job then?

A At the time I was LRH communicator?

Q Yes.

A LRH communicator.

Q What did you do?

A What was my job then?

Q What were your duties?

A Okay. To insure that his orders were carried out.

Q And that was it?

A In the Org where I was, LRH Com which was the Flag Administrative Org.

Q Were there more than one organization aboard the ship?


A Well, there was what we called the ship’s Org that ran the ship.

Then there was the Flag Admin Org which trained students.

And then there was the personal office which was the aides and a few other people.

You see, we had all these little groups around. And my Org was the Flag Admin Org at the time. And I was the LRH Com Flag, so it was called at that time, I think, because there wasn’t any other LRH communicator.

Q Well, in 1971 when you came back to the ship there were no aides, right?

A There were no aides?

Q Hadn’t the Executive Council at Worldwide been disbanded at that time?

A The Executive Council Worldwide?

Q Yes.

A No. I think they were disbanded in ‘68.

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


Q BY MR. HARRIS: By the way, when you went back to England prior to going to Scotland for those couple of days, were you aware of an entity called The Executive Council Worldwide?

A Yes. I was aware of them before that too.

Q I show you what has been marked exhibit 75 and ask you if you recognize that.

A I may have seen this, but I don’t actually recall it as familiar.


Q All right. In any event, you knew that at some point some of the executives from England came to the ship in 1971?

A Well, not specifically. I remember executives from all over the world coming to the ship in 1971, so who was who, I wasn’t really familiar with because I had just come back from the US.

Q If this doesn’t refresh your recollection, I will take it from you.

A Okay.

Q When was the Flag bureau developed aboard the ship?

A I am not exactly sure of the date. I don’t think I was there.

Q Well let’s do it this way: When there were aides, they were called Commodore Staff something; right?

A Um-hmm.

Q Just so the reporter gets it; yes?

A Yes.

Q And there was a Commodore Staff 1, Commodore Staff 2, et cetera?

A Um-hmm.

Q There were seven aides; is that correct?

A There was more than that.

Q Well eight if you count Mary Sue Hubbard, CSG.

A And then there was Commodore Staff F for finance. There was also Commodore Staff PA, and Commodore Staff Estates.


Q Wasn’t Commodore Staff F, in fact, Commodore Staff 3?

A No.

Q Did it change at some point?

A Commodore Staff F evolved out of Commodore Staff 3 and Commodore Dissemination of Books, and then there became a Commodore Staff Publications Organization, also.

Q Now, these aides had juniors under them; is that correct?

A Well, no, they didn’t have any immediate juniors. Some of them had secretaries.

Q Well they were responsible for long-range planning for their respective division; correct?

A Yes. However, they had what was called an opposite number system where they are responsible for their opposite number division and activity, but they didn’t order directly into that activity. It went through what was called a filter, so they didn’t actually have direct juniors. Some of them had secretarial assistants, but they weren’t directing right into divisions.

Q Well, the setup was supposed to be that Mr. Hubbard would give orders to the aides and they, in turn, would order down into the various organizations across the world; right?

A Well, they did that, but he ordered me to filter it because he thought that their orders were a little nuts.

Q Their orders were what?


A A little bit nuts, and he said that they were overloading the divisions and that I should filter them and that was my job, and when I took over my organization that was his first order to me. He said every order into that organization goes through me.

Q And so you received all the orders into all the organizations across the world?

A No, into my organization.

Q Only your organization which was the Flag Administrative Organization?

A That is correct.

Q And that was the place where the executives were coming for training?

A That is correct.

Q All right, now, your area was not where the aides were; is that correct?

A My area?

Q Your area; Flag Admin Org, as it was called.

A I don’t understand my area. You mean by zone of control or my physical location.

Q Yes, your zone of control.

A That is true.

Q When do you first recall seeing Mr. Armstrong?

A In the early ’70’s in the port captain’s office.

Q And was he in the port captain’s post at that time?

A Well I remember him in the early ’70’s in the port captain’s office doing ship’s rep, and I think I signed


the ship’s articles with him, went through my shore story pack with him or saw him there.

Q You had seen him before in Canada?

A Yes.

Q Before he was in Scientology?

A Well he was in Scientology, but I saw him on a tour there in Vancouver.

Q Was that a Sea Org recruitment tour?

A It was probably a regs tour, probably did Sea Org recruitment also.

Q Did you recruit Mr. Armstrong into the Sea Org?

A I didn’t personally sign him up, no.

Q Do you feel that you aided in getting Mr. Armstrong into the Sea Org?

A Yes, I think I did.

Q And did you make any representations at the time that you aided in getting him into the Sea Org?

A I don’t know what you are suggesting. Could you give me an example?


Q Well, what did you tell Mr. Armstrong which, in your opinion, aided him in getting into the Sea Org?

A I don’t recall what my speech was at that particular event. But it probably had to do with the news services and how great the Sea Org was and how great it was to work with Ron and kind of a pep talk.

Q A pep talk to get people to — who were Scientologists to commit themselves to the Sea Org?

A Either to the Sea Org or to send money off to the next step in processing.

Q It was a combination tour?

A Yes, it was a good will-sign-up tour.

Q And who was with you on that tour?

A I think probably Richard Daneen [Dineen].

Q And you went from Los Angeles to Canada?

A Yes; not directly, but started from there.

Q All right. Then after your tour to Canada the next time you saw Mr. Armstrong was aboard the ship in the port captain’s office?

A I think so.

Q And what year was that?

A I am not sure of the exact year.

Q Well, when you went back on the ship in 1971 for how long were you aboard the ship?

A From late June to about September 12.

Q And then where did you go?

A Back to Los Angeles until January 4th.

Q Now, do you recall seeing Mr. Armstrong on the


ship in that small period of time?

A Well, I am really not sure. And if he was there, he probably wasn’t in my Org.

I don’t recall him specifically, but I do remember seeing him in the early ’70’s there.

Q When you went back or came back to Los Angeles, what was your post?

A Super cargo and LRH communicator AO LA.


A Yes.

Q And for how long did you hold that post?

A Until January 4th.

Q Of?

A ‘72.

Q January 4, ‘72.

Now, all right. You also had finance responsibilities in that post; did you not?

A Yes, pretty much the same one. I was basically returned to the same job.

Q And it was basically done the same way; that means that monies came in were banked, invoiced, monies spent, disbursement vouchers written?

A Except it was vastly different as far as the volume of cash.

Q But other than that, the system remained intact?

A Yes.

Q And I take it you didn’t send any money to LRH



A No, I didn’t.

Q Nor did your juniors; right?

A Nobody under my supervision did.

Q And you were still supporting the Sea Org operations aboard the ship with reserve money of AO?

A That’s right.

Q Now, where did that support money go in 1971?

A Well, as I understood it, it went to Switzerland.

Some of it probably stayed in local accounts because we sent crew to the ship and financed their plane fares.

There ware also local expenses in the area. So I am not sure that all of it went to overseas accounts, but some of it probably did.

Q When you say “all of it,” do you mean in excess of expenses that were being incurred at the Advanced Organization Los Angeles?

A Right. And at different times the income levels were vastly changed from 3,000 a week to 100,000 a week to 350,000 a week.

So how much went and how much stayed, it was sort of a questionable thing.

Q Well, as being on the finance planning committee, you had the responsibility of determining how much went and how much stayed; right?

A No.


Q Did you participate in decisions about what things should be bought?

A Yes, I did.

Q And people would submit requests to get a particular item, whether it be a stapler, a typewriter, whatever, even a building; right?

A Yes, I did.

Q And you would make decisions along with the rest of the people on the finance committee as to how the money should be spent?

A I reviewed the finance committee work. And I made decisions as part of the Exec Council how our budget would be spent.

Q Again, you banked the monies in Church of Scientology of California accounts?

A Yes.

Q All right.

In January, 1972 you went back to the ship; is that right?

A Yes.

Q And what post did you assume at that point?

A For a couple of weeks I was a work [word] clearer. And then I was assigned as establishment officer.

Then I was senior establishment officer establishing the technical division and supervising the other establishment officers.

Q When you went back to the ship was there an Org


called the Flag Bureau?

A Yes.

Q Which consisted of the aides?

A No.


Q Okay, where were the aides and in what organization?

A Personal office.

Q And you are quite certain of that; right, Miss Sullivan?

A Yeah. That is what they were. Commodore Staff Aides.

Q And hence they were in the personal office of L. Ron Hubbard?

A That is as I understood it, yes.

Q At the time that you were aboard in 1972, what was the personal office of L. Ron Hubbard? What did you understand it to be?

A Well, it was people who were working directly for him to facilitate him in his activities, and I wasn’t real familiar with him at that time because I had my hands full in my own organization, my own group of people, and there was a research project going on with LRH in charge of it, so I was answerable right to him, too, so I didn’t know exactly how the structure was working.

I just did my own thing. I wasn’t particularly affected by them.

Q Well you say there was a research project going on. Who was doing research?

A L. Ron Hubbard was and he asked me to write down my research, also.

Q And this was Scientology research?

A Yes, it was administrative research.


Q On how a church should operate?

A No, how to motivate personnel and get them more productive.

Q Well, the products that Mr. Hubbard was producing in 1972 were Scientology products; right?

A I am not familiar with it. I am only familiar with the project I was on, which was a Scientology project, and it was a research project. He didn’t discuss with me his other affairs at that time.

Q In 1972 he didn’t discuss his –

A His other activities with me.

Q The activities which you observed in 1972, were they different than what you had observed when you first went on the ship?

A Oh, yes, a lot more duress.

Q A lot more duress. That is something that you felt?

A Oh, yes.

Q But you didn’t leave; is that right?

A No, I didn’t.

Q You stuck it out?

A That is right.

Q And in fact, you stuck it out until in July 1981?

A Until November 1981.

Q Well you actually left in July 1981; didn’t you?

A I actually left in November 1981. I got busted in July 1981.


Q In what year did you become LRH Pers PRO?

A 1973.

Q And what month was that?

A I believe it was November 4th, but before that I was an intern in the PR bureau expediting and doing small projects.

Q And how is it that you got this post?

A Well, I had been familiar with LRH. I got along with him pretty well and I had done what was considered a spectacular mission to Los Angeles in the month of August, and I had returned after my quick trip home to Canada, and my position in the Hubbard communication office was covered by the person that was covering for me while I was doing these other projects.

So, I was sort of considered available, and it kind of was by accident. One person had gotten approval from LRH to send me back to Los Angeles again permanently to run the whole of the Continental United States, and I said, “Yeah, but you guys didn’t ask me, so I am not going, and I am also not technically trained to that degree, so I am not going to go be senior over the whole Continental United States.”

And I wrote to LRH and I said, “I don’t think this is fair.”

So he sent his communicator down to talk to me for a minute, and Wally Burgess at the time got wind that I was kind of not really posted. I spent three days without a job.


So he put up a proposal to make me a PR.

Q When you say “he put up a proposal,” what does that mean?

A He wrote up a personnel submission to LRH to post me in the personal office under himself as a trainee.

Q What was his post?

A LRH personal PRO.

Q So in other words, you were going to train on the job with Wally Burgess?

A Yes. Right.

Q And you did that?

A I did it for three weeks, yes.

Q Then what happened?

A Then Wally got busted and I got promoted.

Q Now, was there a Hat Pack that you used to train for your post?

A Well, there are a couple of issues. It wasn’t a Full Hat Pack, no, not the way it was supposed to be for policy at all.

Q There were just two issues?

A Yes.

Q What was your Hat?

A It had — it was called LRH personal PRO written by LRH and had to do with the duties. And then it had to do with — then there was one called my functions and responsibilities, or something on the personal office that had to do with LRH’s activities.

So I had that one. Then as soon as I got the


job, I had COLRHED No. 2 to reorganize the Bureau. And that was my instruction.

So I didn’t have a Hat because we were under a reorganization.

Q Now, prior to taking over this job of LRH Pers PRO, PRO, did you think you were working for Mr. Hubbard?

A Sure, I did.

Q And it is the case that all aboard the ship thought that they were working for Mr. Hubbard; right?

A Well, I didn’t ask them all, but they all wrote daily reports and they all took directions from him. They all felt intimately connected and administrated by him. I considered it kind o£ an honor to be up in the personal office of L. Ron Hubbard.

Q Other than the duties of the posts and the personal office of L. Ron Hubbard — strike that.
When you took over as LRH Pers PRO did you have a talk with Mr. Hubbard?

A Yes, I did.

Q He told you what your duties were?

A Yes, he did.

Q And I take it that you did a nonexistence formula?

A Yes, I did that, I think.

Q You wrote up what the products of your post were?

A No, I didn’t, not right away.

He wrote COLRHED No. 2 which was the


reorganization of the PR Bureau. And I didn’t get to the products of that until I got to that stage in the program.

So that COLRHED is what put me on the job. And it started when I was — it just names me on there; Laurel Watson is all it says.

Each target, my name, what I was supposed to do. And I did that.

In the meantime, I got promoted to the position. I had already been out on photo shoots with him. I had already been pretty well grouped [grooved] in.

I had worked with him before when I was LRH communicator; I used to have dinner with him. So it was all pretty familiar.

So just for him to tell me what to do day to day to get me started was pretty commonplace.

Q What were the products of LRH at the point that you became Pers PRO? What sort of things was he producing?

A Well, he was right back on the management lines after his New York trip.

He did some photography in the daytime.

Q Photography for what?

A For Cindusta, which was some operation ashore, a company he had set up there, a magazine he was taking pictures for.

And he did data evaluations and was reviewing the international management situation.

He was reviewing the technical quality of the auditing going on. And I think there is an issue that he


wrote on all of his products that appeared many times.

Q I was just looking at what you observed him producing; he produced photographs; right?

A Yes. He took them.

Q He produced writings?

A Yes, he did.

Q Did these appear to be non-Scientology matters to you?

A Just the photography seemed more like an outing to me.

Q And how long was he out on this outing?

A About four hours.

Q Other than that, the work that you saw him performing and the products that he was producing were, as you understood it, Scientology products; right?

A Not all of them.


Q Well, the research was Scientology related; right?

A Yeah, he had memberships in different clubs that he was interested in, and he was doing other research.

He had an enormous quantity of books that he used to read that weren’t Scientology, so it wasn’t only Scientology.

Q Well, he read other than Scientology books, you are saying?

A Well, he did research on other activities.

Q Yes.

A He also was writing a book.

Q And what book was that?

A Well, he said the working title was “The Raw Red Revolution.”

Q In 1973?

A Right.

Q Did he do photographs for promotional materials used in Scientology?

A Not at that time.

Q Well, let me ask you this: Did you ever republish any of his writings that had been written earlier; you, Miss Sullivan?

A Did I publish any of his writings?

Q Yes, republish writings that had been written earlier.

A When?

Q At any time.


A Oh, often.

Q And you would put, for example, something that had been written in 1970 might be reproduced in 1975?

A Well, yeah, but I don’t know that I would always do it directly or only me.

Q But you have seen such things?

A Yes.

Q In other words, though something was written and may have reference to a particular period, you would republish it in a later period; correct?

A Sometimes.

Q Have you ever seen the LRH writing, “What Your Fees Buy”?

A Yes.

Q When is the first time that you saw that?

A I think it was in 1970 or ‘71.

Q And how was it that you saw that?

A Well, there was a very heavy regging campaign going on in 1971, which is to solicit funds for Scientologists for the upper levels.


Q Did you see it when it first came out as far as you know?

A Yes, I think I did. That first Auditor, that first Auditor had pictures that I took in it; so I think I probably would have seen it.

THE COURT: We’ll take our recess at this time. We’ll reconvene tomorrow morning at 9 o’clock.

MR. FLYNN: Your Honor, I have Mr. Wertheimer coming in tomorrow just to authenticate those two letters.

MR. HARRIS: We can certainly take him out of order. There’s no problem.

THE COURT: Very well.

(At 4:02 p.m., an adjournment was taken until Friday, May 25, 1984; at 9:00 a.m.)