Sworn Statement of Marcus Quirino

Date:May 27, 1997




DATE:                      May 27, 1997.

BEFORE:                    Donna M. Kanabay, RPR, RMR
                           Notary Public, Court Reporter. 

PLACE:                     State Attorney's Office
                           Criminal Justice Center
                           Clearwater, Florida

                           Assistant State Attorney
                           Attorney for State of Florida.

                           Agent Lee Strope

                           Sergeant Wayne Andrews
                           Clearwater PD.

                           MR. ROBERT POLLI
                           101 E. Kennedy Blvd.
                           Tampa, FL 33602
                           Attorney for Mr. Houghton

    TAMPA AIRPORT MARRIOTT, (813) 224-9500
   ST. PETERSBURG, CLEARWATER, (813) 821-3320

page 2

              INDEX TO PROCEEDINGS  
                                        PAGE LINE

EXAMINATION - Mr. McGarry                  3    4
EXAMINATION - Sergeant Andrews            71    2
EXAMINATION - Agent Strope                93   12
Reporter's Certificate                   106    1

page 3

MARCUS QUIRINO, the witness herein, being first duly sworn, was examined and testified as follows:



Q. Please state your name, or the record.

A. Marcus Quirino. Spell it?

Q. If you would.

A. It's M A R C U S, Q U I R I N O.

Q. And your attorney's going to place something on the record, and we'll begin.

MR. POLLI: We're here today --

My name is Bob Polli. I represent Mr. Quirino.

We're here today pursuant to a State Attorney investigation subpoena. I've discussed with Mr. Quirino his responsibilities and obligations and protections that are given to him by Florida statute 914.04. Mr. Quirino understands those protections and his responsibilities, and are (sic) prepared to start answering questions.


Q. All right. My name's Mark McGarry. I'm going to ask you some questions that pertain to the circumstances surrounding the death of Lisa McPherson, back in November and December of 1995. What's your birthdate?

page 4

A. X, 1964.

Q. And where do you live?

A. At the Hacienda Garden Apartments.

Q. How long have you lived there?

A. About six or seven years.

Q. All right. And how long have you lived in Clearwater?

A. Since 79, May 9th.

Q. All right. And where did you live prior to that?

A. England.

Q. England?

A. Yes.

Q. So you're not a US citizen, is that true?

A. No.

Q. And is 79 when you came over from England?

A. Yes.

Q. And why did you come? Did you come to Clearwater in 79?

A. Yeah. I came to Clearwater with my mom, who worked for the Church and was transferred --

Q. Okay.

A. -- to Clearwater.

Q. So how long have you been a member of the Church of Scientology?

page 5

A. My parents were Scientologists when I was born, so I was basically - -

Q. Born into it.

A. Yeah. Born into it.

Q. All right. Does your mom still live here in Clearwater?

A. Yes, she does.

Q. Did your status change from being a public person to a staff person sometime after you moved to Clearwater, or were you staff prior to moving here?

A. Staff.

Q. Staff?

A. I was fourteen -- thirteen or fourteen when I first came here. You know, I went to school, and the rest of the time, I worked, you know, in the Church.

Q. Okay. So you've been a staff member of the Church ever since you moved to Clearwater.

A. Yes.

Q. Okay. Were you a staff member while you were in England?

A. For a short while, yeah.

Q. All right. What did your duties originally start out as, in 1979?

A. Clerical-type duties: Typing dispatches, collect data, that kind of thing.

page 6

Q. Collecting data?

A. Yeah. Like, you know, talking to people on the base, you know, at Flag, getting data from them,' collecting stats, statistics and that kind of thing.

Q. So who trained you in that period of time?

A. Mostly a guy called Rick Kemmon (phonetic).

Q. Mm-hmm.

A. And I had various supervisors. I don't really remember their name. They're not around here now. Did various courses and stuff.

Q. The Church is pretty organized about data and statistics - -

A. Mm-hmm.

Q. -- is that a correct --

A. Yes.

Q. - - statement? Moving On from 79 and your clerical duties, can you tell me what other posts you've held while you were at the Flag organization here?

A. I've been what's called an "expediter" for a number of years, which is just a person that works on handling any kind of backlogs. I've been what is called a "staff section officer," who is a person in charge of getting the staff trained and processed.

Q. Mm-hmm.

page 7

A. I've been a scheduling ward in charge, who is the person who lines up parishioners for their auditing sessions.

Q. All right.

A. I've been a page -- I'm sorry -- a tech. page, who's someone that gets parishioners for their sessions. I have been deputy chief officer, who is basically an executive over the treasury tech. qual. division of the Church. (Whereupon the reporter asked for a clarification).

THE WITNESS: It's short for "qualifications."

A. And also, the chief officer's org. officer, which is a post that executes programs, gets programs done, like you write a program out that lays out a series of steps and things to do. BY


Q. Is that what you're doing now?

A. No. Now I'm what's called a "director of processing," and I actually direct parishioners' processing.

Q. Let's talk about that last job you held before director of processing. Explain that to me again.

A. Deputy chief officer.

Q. No, the one after that.

page 8

A. Chief officer's org. officer?

Q. Yes.

A. That is a person that executes programs. I guess you could say, like, expansion plans or handling for something. And then you write out a series of targets or a series of steps to get that overall product done. And then that's laid out in what's called a "program." And the chief officer's org. officer would execute that program.

Q. All right. And your new job, now, is director of processing?

A. Yes.

Q. Explain that to me, please.

A. Basically, it's the person that is in charge of what's called the Hubbard Garden Center, which -- HGC -- which is where parishioners get their auditing sessions. And I would be the one that finds out what service the person has come for, work out the best auditor for them. to go with, and then ensure that they're actually getting their auditing. And any -- any things that come up, get handled with their CS and their auditor.

Q. All right. The position that you -- post or position that you held in November of 85 was deputy chief officer?

A. Yes.

page 9

Q. Do you remember the periods that you held that particular post? ,

A. It was from, I think, September, 92 -- September, 93 until September, 96.

Q. All right. Did you ever meet Lisa McPherson?

A. Yes.

Q. And when is the first time you met her?

A. Probably the beginning of 95. Like March, April, somewhere around there.

Q. March or April of 95?

A. Yeah.

Q. And what were those circumstances?

A. She was a parishioner getting auditing in one of the HGC's. One of my duties, you know, included me going through the various HGC's, seeing, you know, that people were producing, you know, in production. And occasionally, she would be at what's called tithe scheduling board," talking to the board IC. I would see her there, say, "Hello," ask her how she was doing.

Q. You kind of lost me for a second, there. You're following up on her production?

A. No, no, no.

Q. On--

A. On the various staff members.

page 10

Q. Okay. Their production.

A. Yes.

Q. In what respect? They're producing what?

A. Well, like an auditor audits PC's.

Q. Mm-hmm.

A. They do so many hours a day./

Q. Mm-hmm.

A. 'Cause PC's, you know, pay for intensives of auditing. Just check out how much they've done. Then they have seniors, like directors of processing, and they have an overall statistic, see how much of that they have done for the day;

Q. Okay. Was Lisa - - in that period, there, was she going through some auditing sessions?

A. Yes.

Q. She was?

A. Mm-hmm.

Q. Who was doing that auditing, remember?

A. No.

Q. All right. Would it have been Alain Kartuzinski? He doesn't do that. He was supervising, though.

A. Right.

Q. Somebody other than him?

A. Yes. She had -- she had numerous different

page 11

auditors, because she did different auditing actions, required different class auditors.

Q. All right. And are these auditing sessions associated with various courses that she was taking? Is that how that works?

A. No. We have a grade -- what's called a "grade chart." One side is training, one side is processing. The auditing sessions deal with the processing side. Courses would deal with the training side.

Q. I got you. Well, auditing isn't free, right?

A. Right.

Q. That -- you pay for auditing.

A. Right.

Q. What does an auditing session cost?

A. It varies.

Q. Give me a ballpark..

A. Well, it's usually based on -- an intensive -- an intensive can carry from about three thousand dollars to ten thousand dollars.

Q. For --

A. An intensive is twelve and a half hours.

Q. Okay. So twelve -- ten thousand dollars gets you twelve hours. Is that what you're saying?

A. Twelve and a half hours.

page 12

Q. Twelve and a half hours?

A. But that's the utmost auditing that you can get.

Q. All right. Are there records around, somewhere, that show all of that?

A. In terms of what?

Q. Lisa's auditing, what she paid for.

A. There should be a -- there's -- each parishioner has an account file, what they pay to the Church.

Q. And there's full records of everything she spent in the Church in that file?

A. There should be. I haven't seen it, so I wouldn't know, but it should be in there.

Q. You haven't seen it? You ever been audited, yourself?

A. Have I ever been audited?

Q. Yes.

A. Yes.

Q. Now, if you wanted to go look in your file and see how much money you've got into that, you can do that?

A. Like an account file?

Q. Yeah. Your file.

A. Yeah, I can look at my account file.

Q. Can you look at your account file?

A. Yeah.

Q. Can you look at all your files?

page 13

A. Can't look at my PC folder.

Q. That's somebody else's business?

A. That is the folder that has all of your auditing records in it. I can't look at that.

Q. Who looks at that?

A. The CS and the auditor and the DFP.

Q. What's -- what, exactly, is the file called, that's got all the financial records in it? If I wanted to look at that, what would I ask for? What's it called?

A. The treasury account folder.

Q. Treasury account folder?

A. Mm-hmm.

Q. Are those maintained in the Church?

A. Yes.

Q. Here in Clearwater or elsewhere?

A. Maintained here.

Q. In Clearwater?

A. Mm-hmm.

Q. Now, are they maintained on into -- forever and ever, even after somebody leaves the Church or after they expire, as in "die," or do you know?

A. Well, what usually happens, if someone, like, leaves or die (sic) or whatever, is that they get put into the archives. I mean, I don't -- they don't destroy or get rid of those files, because we're required by the IRS

page 14

to keep accurate financial records.

MR. McGARRY: Gentlemen, do we have that file?


SERGEANT ANDREWS: The treasury file?

MR. McGARRY: Yeah.

SERGEANT ANDREWS: I think so. We have some parts of it.

AGENT STROPE: Yeah. We have --

SERGEANT ANDREWS: We have accounts -- It would be, like, "Flag Service" on the top of the page?

THE WITNESS: Yeah. Exactly.

SERGEANT ANDREWS: And then a billing for different account numbers?


AGENT STROPE: I think what you're talking about is the -- is the records of her stay, mostly; the records of her stay at the --

SERGEANT ANDREWS: No, I think I have the account folder.

MR. McGARRY: Okay.


AGENT STROPE: I don't think so.

THE WITNESS: Well, there are two accounts.

page 15



Q. Let's talk about the other one.

A. One will be for her training and processing, and one will be for any kind of accommodations she has, because they're two different --

Q. What's that file called?

A. I would assume it would be "accommodations accounts folders."

Q. "Accommodations accounts folder"?

A. Because there are two different orgs. I think their financial records are kept separate.

Q. You know a follow named Glen Stillow?

A. Yes.

Q. What's his position in the Church?

A. He is -- Actually, I don't know. He works in OSA.

Q. In OSA?

A. OSA. Office of Special Affairs.

Q. You ever met him?

A. Yes..

Q. Recently?

A. Yeah. I see him -- I mean, you know, we go to briefings. I see him all the time.

Q. Okay. Do you know what a custodian of records is?

page 16

A. No.

Q. Okay. This accommodations account folder, does that go to archives, also, after somebody leaves the Church and/or dies, or do you know?

A. I don't know

Q. That's also kept in the Flag Building, down in Clearwater, off Fort Harrison?

A. Yes.

Q. Would there be any reason you could think of that either of these two folders you just named to me would be transferred out of Clearwater, to any other branch or geographical location that the Church has an office in, like LA or Dallas or something like that?

A. Unless someone requested them.

Q. Okay. If you wanted to see your treasury account folder, who would you go see?

A. There is a person in Treasury who's in charge of the files.

Q. And that person's name is --

A. That person -- I actually don't know who handles that. It would be the credit/debit files in charge. don't know who's on that post right now. That's what the post title would be.

Q. All right. Credit/debit -- what --

A. Files in charge.

page 17

Q. All right. So we got a little sidetracked in there, but this is -- Basically, you met Lisa in March of' 95 while she was obtaining some auditing.

A. Mm-hmm.

MR. POLLI: You have to answer "yes" or "no," so she can take it down.



Q. When you go "mm-hmm," you never know whether that's "yes" or "no" on these things, so that's why you have to say "yes," specifically. Were you aware of where Lisa worked?

A. I -- I heard it in passing, but I don't know, like, what they do exactly. I know she worked for Bennetta Slaughter at -- I think it's called AMC --

Q. Publishing?

A. Yeah. I didn't know -- actually, I only ever heard the initials "AMC." I didn't know, actually, what it was they did.

Q. Did you know Bennetta Slaughter?

A. I've talked to her. I've been her board AC years ago. ,

Q. What's that?

page 18


A. That's the scheduling board in charge. That's the person who arranges when the person goes in session with their auditor.

Q. You're not aware of what, exactly, AMC does?

A. No. ~.

Q. Following up from March of 95, did you ever have any conversations, specifically, with Lisa, about how she was doing, or anything with AMC? Were you friends with her or just acquaintances?

A. Just acquaintances.

Q. Knew who she was?

A. Yes.

Q. Were you aware that there was a time, back in the summer, prior to this incident where she ended up dying, where she also had a episode where she went a little bit, maybe -- not quite Type III, but maybe Type II?

A. Yes.

Q. You were aware of that?

A. Yes.

Q. How did you become aware of that?

A. I believe I heard, from Alain Karduzinski, at the time.

Q. What was the circumstances surrounding that deal with Lisa?

page 19

A. She was on an auditing cycle, which she had -- something had come up where she - - I was told from him that she was overly stimulated.

Q. Mm-hmm.

A. And so, therefore, she was being, one, kept - - being observed, kept an eye on by - - I think, at the time, it was Susan Greenwood - - and her folders were reviewed, and she was gotten onto an auditing program to get her --

Q. Straightened out a little bit?

A. Yes.

Q. And was that accomplished?

A. Yes.

Q. So you knew about Lisa McPherson's, for lack of a better term, "mental instability," prior to her stay at the Cabana in November of 95.

A. Yes.

Q. And you gained that information from talking with her senior case supervisor, Mr. Karduzinski?

A. Yes.

Q. And it was - - do you remember what period of time, during the summer, that was?

A. Not exactly.

Q. So there would be a record within this treasury account folder showing that she took some auditing to fix her up in the summertime, more than likely, right?

page 20

A. I don't know.

Q. Well, you pay for the auditing. It isn't free, right?

A. That's right. But if you bought five intensives in January, and debited them all out, they then go into the PC folder, and then the auditor keeps track of how much is used of that, until those hours get low, at which point you would get sent back to see the bridge consultant about needing more hours. So if she had a large number of hours in the folder, it wouldn't show up again on the -- on the treasury account until those hours were used and she had to go back. So I don't know if anything would show in the treasury account during the summertime. I mean, it would have to be looked at. I don't know.

Q. I see what you're saying. You really couldn't correspond a particular course to hours used, using the treasury account folder, without corresponding it with the PC folder.

A. Right.

Q. And the PC folder, of course, is hands-off to Lisa.

A. Yes.

Q. And us, more than likely.

page 21

A. (Nods head).

Q. All right. So Mr. Karduzinski was in charge of her auditing during that period of time - - supervisor of the auditing?

A. Right. Q.' But you're not exactly sure who the actual auditer was, during that period.

A. No.

Q. How do I find that out? Who tells me that? Where's the records for that?

A. The records would be in her PC folder.

Q. All right. So I can't get that. Who do I ask to get that?

A. Probably - -

Q. Mr. Karduzinski?

A. Yeah. Or one of the OSA terminals, like the CO OSA, and Bennetta Slaughter - -

Q. Maybe Bennetta Slaughter would know --

A. -- know --

Q. -- who was the auditor for Lisa during that period of time?

A. She may.

MR. McGARRY: Do we know who that is? We don't know who that person is.

page 22

AGENT STROPE: Not during that time, no.

SERGEANT ANDREWS: I think Mr. Karduzinski said he couldn't remember. BY


Q. All right. Lisa goes Type III in November of 95. When did you become aware of that?

A. I think the day -- like, later that night, after it happened, or the next day.

Q. All right. You've seen the schedule, here, from your lawyer, right?

A. Mm-hmm.

Q. Okay. And we begin this whole thing on -- is it --

MR. McGARRY: Correct me if I'm wrong fellows - - Is that six - - 18th of November?



Q. All right. So you gained information about her little automobile accident on the 18th, that evening?

A. I actually didn't know that she had an automobile accident. What I was told that was that she had had -- it was called a "spin" -- and she was brought into the base.

page 23

Q. "Spin" meaning - -

A. Going Type III.

Q. -- psychotic break?

A. Right.

Q. Same thing? Mean the same thing?

A. (Nods head).

Q. Who told you that?

A. Alain Karduzinski.

Q. Why does he tell you that?

A. Because I am, like, a senior executive, at the time, over qual., which is where he works.

Q. So you're Alain's boss?

A. Not directly.

Q. No, but --

A. Indirectly, I was a senior to him.

Q. All right. So, among other people, he reported this to you?

A. Yes.

Q. Who else does this get reported to?

A. He would have reported it to the qual. sec...

Q. What's that?

A. That is the - - the person who is, basically, the in-charge of the area that he works in. Like, he's in the qualifications division, and then it has, like, someone who's in charge of that, who runs that division.

page 24

Q. Do you know who that was?

A. I don't actually remember.

Q. Who is it now?

A. Now it is Kay Curly.

Q. Curly? Kay Curly? So the equivalent to Kay Curly would have been Alain Karduzinski's boss, at the time., in November of 95,. her predecessor, or somebody that held that position?

A. His direct boss would be the dir. of direction. I don't remember who that was at the time. Then his direct boss or her direct boss would be the qual. Sec. Qualifications secretary.

Q. So Mr. Karduzinski calls you and says, what? "We've got a problem with a person that's a member of the Church," right?

A. Yes.

Q. And did you discuss with him what your course of procedure was going to be?

A. No. He just told me that she was under watch in the Cabanas, and that the folders were being FES'ed for what's called an introspection run-down.

Q. All right. I know what introspection run-down is, but what is -- the folders is going to be - - FES. What's that mean?

A. It's called a "folder error summary." It's

page 25

where someone goes through the folder and, for the introspection run-down, finds various points where someone has indicated some point of introspection to the PC.

Q. That's the PC folder we're taking about?

A. Yes.

Q. Now, why does he tell you this?

A. Because I'm senior to that area.

Q. And you're monitoring the situation, so to speak?

A. He just -- just infoed me, as a matter of needing to know.

Q. Now, would he do this by telephone, face-to-face, or by written response?

A. I believe -- let me see -- it was face-to-face.

Q. Face-to-face? Now, she's a public person, right?

A. Yes.

Q. Is it not unusual that a public person would be treated in this manner, or is it - - is this a usual course of business?

A. Well, what - -

Q. She's not a member of staff --

A. Right.

Q. - - and yet she was brought in, in a Cabana, given a room --

page 26

A. Right.

Q. - - and provided a watch, a very expensive watch, with twenty, thirty people involved here - -

A. Right.

Q. -- in addition to - I don't know. Did she pay for that room?

A. Don't know.

Q. Food?

A. I don't know.

Q. Who knows that answer?

A. It would have to be checked in the accommodations account. That would show.

Q. She'd get billed for it?

A. Yeah. Or - - I mean, it would show whether she was billed for it or not.

Q. That's in the accommodations account folder.

A. Right.

Q. All right. My question was -- I probably never got to it -- she's public.

A. Right.

Q. Is it the usual course of business, in the Church, if - - to have a public member get treatment like this, to bring them around --

A. If they go Type III --.

Q. Right.

page 27

A. - - they are usually put under a watch.

Q. Public?

A. Yes.

Q. How many times have you seen that occur?

A. Three.

Q. Three times?

A. Mm-hmm.

Q. Since you've been in Clearwater?

A. Yes.

Q. All right. When were those other times?

A. Oh, I think one was 86 or 87 --

Q. Mm-hmm.

A. -- and one was probably mid-'88.

Q. Women or men?

A. One was a man and the other one was -- both of them were men.

Q. Did those individuals eventually get the introspective run-down after the watch was - - isolation watch was, apparently, successful?

A. That, I don't know,.

Q. Do you know if the procedures were generally considered as successful or not, for those other two?

A. I don't know.

Q. Were you in a position, in the Church, to be made aware of those introspective run-downs --

page 28

A. No.

Q. -- as well?

A. No.

Q. You weren't, at that time?

A. Not at that time, no.

Q. You just knew about them.

A. Yeah.

Q. In your conversation,, your face-to-face conversation with Mr. Karduzinski, did you guys discuss a plan or procedure for Lisa McPherson?

A. Only that she would be put under watch, you know, gotten stabilized out, and then gone on to introspective run-down when she was able to be audited.

Q. All right. There's -- there's written procedures, I presume, that were penultimately written by Mr. Hubbard --

A. Mm-hmm.

Q. - - on this procedure, right - -

A. Right.

Q. -- for the watch and for the introspective run-down.

A. Right.

Q. Now, are you familiar with those procedures?

A. No.

Q. Who is?

page 29

A. Alain Karduzinski would be familiar with them.

Q. So you're not versed in those?

A. I'm not --

Q. You're not well-versed in those procedures?

A. No, I'm not.

Q. If I wanted to see where that is written, where is that - - where do I - - how do I get that information?

A. You could check with OSA. The information on how to do them or how they're done is covered in the technical volumes, which are the red volumes that we have.

Q. OSA has that?..

A. Yeah. I think OSA -- we have a qual. library. I think some of these may even be in the public library.

Q. Okay. Mr. Karduzinski's familiar with the procedure?

A. Yes.

Q. Was he in charge of implementing that procedure?

A. He would have been in charge, as far as the auditing. As far as the setting up of a watch, that would normally be handled by HCO or security, which I think would come under Paul Kellerhouse.

Q. Okay. Do you know, personally, on this particular case, here, with Lisa, who handled that isolation watch?

A. I talked to a number of the people that were on

page 30

the watch. I don't know who actually set it up or who arranged it.

Q. Okay. We're going to get to that. Apparently, you talked to some people on December 5th - -

A. Right.

Q. -- but you're not aware at -- while it was being set up, who was setting it up.

A. No. It would have been coordinated between Alain and Paul.

Q. All right. Let's talk about how the information circulates between you and Mr. Karduzinski and everybody else that was involved in this isolation watch. And I say that broadly, because I've talked to probably twenty people, maybe more.

A. Mm-hmm.

Q. Some of them are just rank and file staff members, and some of them are people that seem to know a lot about the circulation of paperwork, being Mr. Baxter and Mr. Kellerhouse. Circulation of - - would you agree with this statement: Circulation of paperwork through the office of the Church is pretty complicated.

A. No.

Q. It's not?

page 31

A. It's a very simple system.

Q. Is it? Are you well-versed in it? Are you pretty familiar with where everything goes?

A. Pretty much.

Q. Well, you've been in it in this general area since 79 --

A. Right.

Q. -- almost all the way, right?

A. Right.

Q. Okay. Did you and Mr. Karduzinski have a routing system for information between the two of you and what all these people here were doing with Lisa McPherson?

A. No.

Q. You did not?

A. No.

Q. Did he?

A. From them to him, yes.

Q. You weren't involved?

A. No.

Q. You did not read anything?

A. No.

Q. You read no documents at all, from any of these people, during the ongoing of this isolation watch?

A. Nope.

page 32

Q. And that's because it wasn't designed to go to you, right?

A. Right.

Q. So it was -- all reports were designed to go to him.

A. Right.

Q. And the reason for that is because he's in charge.

A. Right.

Q. So the system of reports between Mr. Karduzinski and all of these individuals, some of which don't speak English so good, so their reports, of course, I'm sure, are a little bit weak - - how would these reports, from these twenty-some people, get to him?

A. They would be written up, and then either his page or one of them would take them up to his office.

Q. His page is Lacey Spencer?

A. At the time, it was, yes.

Q. Was it ever anybody else - - I mean, during this period -- or was it just her?

A. I think it was just her.

Q. All right. So if Rita Boykins wrote a report -- You know Rita?

A. Yeah, I know Rita. ,

Q. -- and she wanted that report to get to

page 33

Mr. Karduzinski, how would that be achieved?

A. Well, normally, I think they would either - - the normal dispatch system in this charge is, you write it, you put it in an "out" basket, and someone takes it and delivers it where it's supposed to go.

Q. All right. Where are these --

A. With something like this, it would probably be hand-routed, because it's case Beta.

Q. All right. Let's back up and talk about your basket thing. Where's this basket, if you were to do it that way?

A. Every staff member has what's called a three-basket system: An "in" basket, a "pending" basket, and "out" basket. Traffic coming to them goes in their "in" basket. They read it, they handle it right away. Goes in the "out" basket. If they can't handle it right away, requires them to do more work on it, goes in their "pending" basket. Every day, they go to take what's in the "out" basket and go to the comm. station, where they have one basket for them, along with everybody else in their division or department, so all the people they work with would have one basket in the same system. That's where

page 34

the incoming traffic goes. So they take that, and the stuff they're bringing out goes into an "out" basket.

MR. POLLI: Slow down.

A. The stuff they're bringing out goes into an "out" basket. BY


Q. I see. And you're saying that, more than likely, to the best of your knowledge, that system was not employed by these people; it was more likely, more or less, employed by courier, correct?

A. That would be an assumption.

Q. Who knows the answer to that?

A. The watch members would have to say how they got them there.

Q. Would -- well, maybe Lacey Spencer will know some of that.

A. Possibly.

Q. And maybe the security people, too, right?

A. Yeah.

Q. After those reports go to Mr. Karduzinski, what does he do with them?

A. He would read them, put them in her PC folder. And then, if, based on reading them, he sees that

page 35

something needs to be done, he would give instructions back to the watch.

Q. All right. I'm confused about those folders. Now, why in the world would somebody stick a report written by Rita Boykins about her watch of Lisa McPherson, and put that in her PC folder"

A. Because it generally is considered that what the watch is doing is case-related.

Q. With auditing?

A. Yeah.

Q. All right. So to the best of your knowledge, all of the reports would end up in the PC folder?

A. Yes.

Q. All of them.

A. To the best of my knowledge, yes, that's where they would go.

Q. Is this somebody that would look at that PC folder -- I guess it would be Mr. Karduzinski, but -- and determine that some of these are more deserving of a PC folder or another folder? I mean, was there any way that they could get split up and route different ways?

A. That, I don't know. I mean, he -- maybe he makes a decision to keep them in another file. I don't know.

Q. All right. Back to Mr. Karduzinski. You had

page 36

that original conversation with him. How many conversations would you have with him during the course of this November-December episode with Lisa?

A. I think I had one or two. Q More"

A. More.

Q. So for this whole period of time, you only talked to him three times, about Lisa?

A. Yeah.

Q. Well, let's talk about those conversations. Do you remember when they were, the second one?

A. When, no, I don't.. I know it was like --

Q. Towards the end of her stay or towards the beginning of her stay?

A. I think one of them was within a couple days of her being there, and the other one would have been, probably, towards the middle of it.

Q. All right. Let's talk about the occasions themselves. What exactly did you guys talk about?

A. I just asked him how she was doing, if she was sleeping and if she was coming out of the spin at all.

Q. And his response was?

A. That she was eating. She was still very agitated. On the first one, it was, like, eating, but

page 37

still very agitated. Aggressive towards watch members. And on the second one, that she was now sleeping more and, you know, looks like, within a few days if she kept at that way, we'd be able to start auditing her.

Q. Did you ever speak to any of these caretakers, directly or through the telephone?

A. The- Q.. Caretakers. Janice, Laura, Silvia, Rita --

A. During the watch?

Q. Yeah.

A. No.

Q. You've spoken to them since then, on December 5th -- and we're going to get to that -- right?

A. Yeah... Actually, I -- No, that's not true. I did talk to Heather once, after Janet -- after -- what's her name -- Joan got punched in the eye, cause Joan had a black eye, and I asked Heather how she got a black eye, and Heather told me.

Q. Okay. Did you take that information or did you follow-up that information with Mr. Karduzinski?

A. No.

Q. Did you ever go down there to the Cabana area and see for yourself what was going on?

page 38

A. No.

Q. Where was your office at the time?

A. Coachman.

Q. Of f of Coachman?

A. No. It's in the Coachman Building.

Q. Coachman Building?

A. Yeah. Although I spent the majority of my time, during that time period, at the Sandcastle, which is my other building.

Q. Right. Do you know Janice Johnson?

A. Yes.

Q. Did you have any conversation with her during this period of time?

A. Nope.

Q. How about Lacey Spencer? Did you ever talk to her?

A. Sometimes.

Q. In reference to Lisa McPherson?

A. No.

Q. All right. Let's go to December 5th. That's the day that Lisa died. What was the first thing you found out about Lisa on December 5th, and from who?.

page 39

A. I got beeped by, I think, Brian, in OSA, who was --

Q. Brian Anderson?

A. Yeah. I think it was about nine-thirty, ten o'clock at night. Went over to OSA, which was in the CB; briefly got told what was happening; that she had died on the way to the hospital. I asked him, you know, why; what had happened, and he didn't really have the data at the time. And then he was on the phone to Minkoff or Janice, at the hospital.

Q. Was that in your presence?

A. Yeah. He was on the phone when I was there.

Q. And that was at ten-thirty at night?

A. I don't remember the exact time, but it was late at -- late at night.

Q. Who was in the room with you? Just you and him?

A. No. There was me; Brian; I think Annie was there -- Annie Mora was there --

Q. Annie Marrow?

A. "Mora." She works for OSA.


MR. POLLI: I think it's M 0 R


page 40




Q. M 0 R

A. Oh, "Mora."

A. Judy -- Judy Fontana was there. I think PK was there and I think maybe Arthur was there, too. And there were some other OSA people there. I don't really remember who they were.

Q. And that was in the evening hours of December 5th somewhere between, let's say, ten and midnight?

A. Yeah.

Q. And you - - when you arrived in that office, these people were already there?

A. Yes.

Q. And Mr. Anderson was on the telephone with Dr. Minkoff?

A. He was on the phone. I don't know for sure that it was Dr. Minkoff or if he was talking to Janice at the hospital. But I know he was on the phone to someone at the hospital, either one of those two.

Q. Okay. Did you - - were you made aware of the conversation that he'd had with somebody at the hospital, after he hung up?

A. Yes.

Q. And what information was that?

A. That she had died, and it looked like she had an

page 41

infection, and that it was possibly spinal meningitis.

Q. And you think that that information came from either Janice and/or Dr. Minkoff.

A. Right.

Q. Was there a conversation among this group, then, as to what procedure, and what should take place at that point?

A. Yes.

Q. And what occurred, and who said it?

A. I don't remember exactly who said it, whether it would have been PK, myself or Brian, but what was gone over was the fact that we had people on watch with her, and that if she had had spinal meningitis, it's contagious, so we needed to list out who was on watch, find out when they were on watch with her, and then those people that had been on watch with her, I think, within the last week, would have to go into isolation until we knew what it was.

Q. Was Mr. Karduzinski at that meeting?

A. Don't remember.

Q. Might have been?

A. He might have been. He was not there the whole time. He did get called over at one point, but he got sent back to, you know, get the folder, look at the folder, see -- give us -- you know, what was happening

page 42

from the folder. And I don't know if he was there before, during or after other conversations.

Q. All right. The folder. He went to get the folder. And that folder is which folder?

A. The PC folder.

Q. PC folder. Did you see that folder?

A. No.

Q. You didn't.

A. No.

Q. So he didn't come back with a folder for your --

A. He might have brought it back, and he may have gone over it with OSA, but he didn't -- I didn't go over it with him.

Q. All right. Where exactly in this building is this meeting taking place? And this is in -- is this in Brian Anderson's office?

A. Yes.

Q. And what building is that?

A. The CB -- the Clearwater Building.

Q. Oh, the bank building? And the PC folder would have been located in which building?

A. Fort Harrison.

page 43

Q. So at ten -- between ten-thirty and midnight, you're saying Mr. Karduzinski had gone to get the file, PC file, folder, that had all this information in it?

A. The folder was sent for. Whether it was him or someone else that went to get it, it was sent for.

Q. All right. Who sent for the folder? Who wanted to see it?

A. Brian or PK.

Q. Who was the highest ranking guy in this office?

A. Probably Brian. No, at the time, it would have been --

Q. Judy?

A. No. It would have either been Brian or PK.

Q. In the hierarchy of the organization, it was either one of those two?

A. I'm not sure which one of them, at the time -- like, Brian was a CO OSA, but PK was the -- what's called the senior inspection reports officer, which is in a senior org. to the one I'm in. So I don't know which of those two would be considered the senior of them.

Q. Do you remember which -- which one of these people in this office is the one that said, "Look, Karduzinski, go get that PC folder, will you? We'll have a look at it;" which one of them said that?

A. Don't remember.

page 44

Q. And you're saying that the folder never showed up before you left.

A. No. I'm not saying that. I didn't see it. It may have come there before I left, but I didn't see it.

Q. Did you ever have a conversation or learn any information that the folder made it to these people, and they looked at all of it, looked it all over? Do you know that?

A. No.

Q. Did you ever look at it?

A. No.

Q. What else occurred at this meeting?

A. That was basically it. And then it was decided to go up and interview the watch members.

Q. Who decided that?

A. I think PK, cause he had the guards rounding the people up and getting them there for me to see.

Q. Getting them where?

A. To the Coachman, up to the fifth floor, where my office is.

Q. Late at night?

A. Yeah.

Q. And the purpose of this procedure was what?

A. To find out when they had been on watch; what

page 45

they observed; if they'd been on watch in the last few days; to see, basically, if we could isolate whether it was spinal meningitis, and also isolate who had been with her within a certain amount of time -- which I don't remember how much time we had talked about - - but certain people would have to go into isolation, because they were with her, like, in the last few days, or something like that.

Q. What else was discussed at the meeting?

A. I think that was basically it.

Q. Anybody mention whether this was a potential screw-up for the Church?

A. Brian might have said something, like - - not "screw-up," but you know, "This is a flap. Needs to

Q. "It ain't going to look good," right?

A. "It's never going to look good."

Q. Certainly, if somebody died in the Church. Was anybody at this meeting discussing who, possibly, to blame for this - - A..No.

Q. - - going a little awry? Anybody say, "Karduzinski did this"?

A. No.

Q. Karduzinski's position with the Church, now, is what, right now?

page 46

A. He's on training.

Q. Training for what?

A. He's an auditor, so he's just doing more training, increasing his

Q. He went from the position that he had, being up here on the top floor, with - - meeting with PK and Brian and Judy, to being an auditor?

A. Well, he wasn't at the meeting, initially. I think he came over there after the meeting was going. I mean, it was -- it was going. He wasn't, like, brought to the meeting right off. He got called for at one point. But he was, then, still on post, I think, until several months later. I mean, he didn't go from this to being an auditor, no.

Q. Well, the point I'm getting at is, it looks like he got busted down to private from whatever it was he did before. He's now not doing it in the same way --

A. Right.

Q. Looks like he got punished.

A. I don't know, cause I haven't seen the issue that took him off post. But it was several months later, before he came up for post.

Q. So you're telling me now that you're not aware of him getting a reassignment based on the way this Lisa

page 47

McPherson thing went down?

A. Right.

Q. You don't know?

A. I don't know.

Q. Who knows the answer to that?

A. Possibly PK.

Q. How about Brian Anderson? Does he know the answer to that?

A. He might. I mean, he had -- at the time, he was a CO OSA, so he may have more information.

Q. Let me ask you this. Who is the person that makes that change?

A. It's done -- it would be done based on the justice system. He would get what is called a committee of evidence.

Q. Mm-hmm. I'm familiar with that.

A. And then a committee would decide what needs to be done with him.

Q. All right. And was that, in fact, taking place during that period of time?

A. No.

Q. There was no justice committee of evidence?

A. He had a committee of evidence which removed him from post, but this was like, I think, three or four months later.

page 48

Q. Well, my question --

A. And I wasn't -- I don't think that committee of evidence was on Lisa McPherson's cycle.

Q. So you're saying he screwed up something else?

A. I don't know what -- I don't knew, cause I haven't read it. I don't know, cause I haven't read it.

Q. Well, how did you find out about it?

A. I was told by my senior, which is a tech. sec., because Alain was then auditing in his HGC's.

Q. So your statement here today is that you don't think that committee of evidence discussed Lisa McPherson in their removal of his - -

A. I'm not saying that. I don't know, cause I haven't read it. It may well have. I don't know.

Q. Who's in that committee of evidence?

A. I don't know.

Q. Who's in charge of deciding whether or not there's going to be a committee of evidence?

A. They usually get called by HCO. They go through a justice chief.

Q. Who's that?

A. We didn't have one at the time, so it would have gone to our justice chief in LA.

Q. Who's that?

A. That, I don't know.

page 49

Q. Well, you know there's a committee of evidence that occurred two or three months after Lisa McPherson died, and you know the subject of the committee of evidence was Mr. Karduzinski.

A. Mm-hmm.

Q. You told me that.

A. Mm-hmm.

MR. POLLI: "Yes"?



Q. So you don't know who was on that committee --

A. No.

Q. -- and you don't know who called the committee.

A. No.

Q. Who do I ask to find that information out?

A. You could check with Brian, Bennetta - -

Q. Bennetta?

A. -- Slaughter, Brian Anderson, or possibly PK.

Q. Okay.

A. Because they come out in an issue form. But depending on the nature of what's in it or whatever, you know, whatever it's about, it's not unusual to go out to every staff member. Sometimes they're limited distribution, they only go to certain terminals. The

page 50

people on the committee would know who they - -

Q. Well, the committee of evidence, my understanding is it's a little tribunal that makes a decision on whether or not somebody didn't do good. Is that an accurate rendition of what that - -

A. Committee of evidence is a fact-finding body which would review all of the evidence, any reports, any data, with regards to whatever they're being charged on -- charged with.

Q. Well, that's what I'm -- somebody's being charged with - -

A. Right.

Q. -- doing something not good --

A. Right.

Q. -- wrong, bad.

A. Right.

Q. So there's a little group of people that review all of the facts and review the evidence and then make a finding - -

A. Right.

Q. -- and then act on that.

A. Well, then they submit. And if it gets approved, then it gets acted on.

Q. Who's that submitted to?

A. It gets submitted to the justice chief or the

page 51

cont. justice chief.

Q. Who are those people?

A. The cont. justice chief, now, is Heather Hough. She just started that post.

Q. Who was in 95?

A. I don't think we had one, so it would have gone to INT justice chief.

Q. Who's that?

A. That, I don't know.

Q. How do I find that out?

A. From one of these people, PK, Brian or Bennetta.

Q. They'll know the answer to that?

A. Yeah.

Q. How many either -- committee of evidence hearings were held in reference to Lisa McPherson's situation -- not that you've admitted that this one was for Lisa. I know you've said it was for Karduzinski, but we're not exactly sure what the subject matter was.

A. Right.

Q. Anybody else go through a committee of evidence, in reference to the way this was handled?

A. Not that I know of.

Q. Janice Johnson?

A. I don't know.

Q. Same line of questioning: Janice Johnson didn't

page 52

hold an MLO office after this situation with Lisa? You're aware of that, right?

A. She's not on the MLO now. I don't know' when she came off that post. I know she's not now. I know she's a word-clearer.

Q. Which, among us guys here in this office, is -- sounds like a demotion, too. Would you agree with that?

A. No.

Q. No?

A. No. See, when she came to the Church, she wanted to become an auditor. So this is just a step in that direction.

Q. Okay. So she didn't -- you're not aware of anything about a committee of evidence in addressing her situation and her responsibilities with Lisa McPherson?

A. No.

Q. Are you saying no, you're not aware of anything or no, you don't know --

A. I'm not aware of anything.

Q. You're saying one could have existed, but you don't --

A. Exactly. ,

Q. Who do I talk to to find that out? Same person, Brian, Bennetta - -

page 53

A. Brian, Bennetta - -

Q. -- PK?

A. Yeah..

Q. PK sounds like he knows a lot for being in charge of security. I mean, he's -- he knows --

A. Right.

Q. He's in all these high-level meetings, right?

A. Well, at the time -- at the time of this cycle, he was on a different post than security chief.

Q. Right. I've talked to him. I might have to talk to him again. Back to this meeting, now, so now we've got a decision to be made about isolation, and we're gathering up people, and you speak to some of these people. And this is on the late hours of December 5th, correct?

A. Right.

Q. Who participated in this information-gathering procedure with you, anybody?

A. It was me, the -- he had -- PK had security guards getting the people there for me --

Q. Mm-hmm.

A. And I think he might have had a guard giving them paper when they arrived - -

Q. Mm-hmm.

A. - - telling them to write down what they had

page 54

observed - -

Q. Mm-hmm.

A. - - until I could see them.

Q. So they got a little head start with their note-taking, and then you'd interview them, and then what would they do with their notes?

A. Give them to me.

Q. Hand them directly to you?

A. Yeah.

Q. And what would you do with them?

A. I took all of the notes, typed up the summary, which you have, and then I gave them all to Brian when I was done.

Q. Brian Anderson was - -

A. Yes.

Q. - - handed all of those?

A. Yes.

Q. Did you do that personally?

A. Give them to Brian?

Q. Mm-hmm?

A. No. I gave them to PK to give to Brian.

Q. PK gave them to Brian. I know this occurred sometime ago, but all these people that you spoke to here --

A. Mm-hmm.

page 55

MR. POLLI: "Yes"?



Q. -- that's not everybody; just some of them, right?

A. Right.

Q. And why is it not everybody?

A. I think these were the ones that we thought were on the watch later, so the ones, like, that were on the watch later were the ones that we mainly looked at. I mean, we did interview a lot of them - - I think it was about -- I don't know -- two, three, maybe four o'clock. We just had to call it quits and just put them into isolation until we knew back from Minkoff exactly what it was.

Q. Okay. The first page of your debriefing here is a call to Dr. Minkoff.

A. No. That first page, if you look the next -- that's a write-up from Brian Anderson. And then mine starts on the first page.

Q. Oh, this is Brian Anderson's --

A. Right. And mine's the third page.

Q. Right. I knew that. I'm sorry. So how did you go about dictating this stuff?

page 56

You just pick up the dictating machine or did you - -

A. I took notes.

Q. You took notes? Well, how did it become typed like this?

A. I typed it up on a computer when I was done.

Q. This is your typing?

A. Mm-hmm.

Q. You didn't have a secretary do this?

A. No.

Q. And you did this right after you took the notes on December 5th/6th?

A. Right.

Q. And these were all given to Brian Anderson?

A. Right.

Q. Do you know what Brian Anderson did with them?

A. No, I don't.

Q. Did you give these summations to Brian Anderson also?

A. Yeah. It was given to him as, like, a little pack of stuff.

Q. In addition to the handwritten ones?

A. Right. All my notes, all the write-ups from the watch, and then the summary was all turned over to him.

Q. All right. So when I go and take all these people, here, and go through all these people, here, that

page 57

I've talked to, and figure out who said that they were at this meeting with you, is that going to correspond? I mean, all these people said they had a meeting with you. Was there a meeting with you where everybody said, "Hey, I'm here. I was there," and you gave a little speech or something, about what's going on"

A. No. I just saw them individually.

Q. Individually?

A. Mm-hmm.

Q. So if some of these people say that they went to a meeting on December 5th, there might have been another meeting where they were all gathered together and told what occurred or anything like that?

A. Possibly.

Q. All right. I haven't taken the time to do this correlation thing, so I don't know. I'm just asking. Cause seems to me like I remember a bunch of people saying they went to a meeting, and I'm not so sure that all of the summaries are here. My question, then, is, would there be some people that would show up and you say, "Hey, this is what happened. I'm not going to take your summary, because you were at the beginning of the watch, so I don't need to do that. Thanks for coming. See you later"? , Could that have occurred?

page 58

A. I don't remember saying that to anyone. Possibly a security guard or something could have told them that when they got there, cause --

Q. All right. "We're just doing the last-week people," or something like that. A Right

Q. That was your intention?

A. Yes.

Q. And your concern was because of infectious disease?

A. Yeah. Because it had been in the paper two - - one or two articles on people with spinal meningitis within the local area, and this looked - - or per the report to me from either Janice or Dave Minkoff, that it might have been spinal meningitis. And just take that precaution to make sure if these guys were exposed to it they're not still walking around.

Q. Okay. So the purpose of these summaries that you dictated here was for you to find out their contact with Lisa?

A. Right.

Q. Not what Lisa was exhibiting, doing, behaving, any of that.

A. No.

page 59

Q. So you weren't thinking, "Lawsuit. Problem. We've got a liability problem. Document. Records," et cetera?

A. No.

Q. It's strictly, "When and where were you in contact with Lisa, and why?"

A. Cause --

Q. There's much more information than that in these summaries, though.

A. Yeah. Just like, "When did you first start the watch? What were you doing? How was she? Did you notice, you know, how she was in the last few days," that kind of thing, to get the - - you know, to see what they had seen on it. But the main -- the main concern was that some of these guys had already finished their watch with her, and we have over fifteen hundred parishioners, you know, at Flag at one time.

Q. Yeah. And you gave this to Mr. Anderson.

A. Right. I gave it to PK - -

Q. PK, who gave it to Mr. Anderson.

A. Right.

Q. And this -- I'm just guessing because of the way

page 60

your attorney got a copy and went and showed you, was the first time you've seen this --

A. This.

Q. Yeah. When's the last time you saw that, right there?

A. I don't know.

Q. Well, let me ask you this: After you gave it to PK, who gave it to Brian Anderson, when was the next time you saw that document? Was it -- I mean, back then. Did you have a meeting with --

A. No. I saw this, maybe, five weeks ago, four weeks ago.

Q. Four or five weeks ago --

A. Mm-hmm.

Q. -- you saw that document? And who showed you that?

A. Bennetta.

Q. Bennetta Slaughter?

A. Bennetta. Because they had it -- they didn't know what it -- they didn't know who wrote it, so he showed it to me to find out if this is something I had written from that -- from that, written --

Q. Who was present with you and Bennetta? Anybody?

page 61

A. No.

Q. And did you acknowledge to Bennetta that you had dictated this on December 5th, late night?

A. I told him who wrote it.

Q. Wrote it, typed it.

A. Right.

Q. See, the cover letter -- this is what threw me a little bit -- the cover letter that -- addressed to this, is -- it's signed by Laura Vaughn, and she says it's a two-part thing. She says -- Did you ever have a conversation with Laura Vaughn? Never? A.. I don' t know who she is.

Q. Okay. How about Sandy Weinberg or Lee Fugate?

A. Who's -- Sandy --

Q. The lawyers that represent the Church.

A. I talked to Sandy.

Q. Okay. When was that?

A. It's probably two weeks before I talked to Bob.

Q. Okay. Well, her cover letter, she says, in here -- and they sent me this stuff gratuitously, I might add -- that it's, one, as a part of an internal investigation; and two, to address the problems raised by what you're talking -- what you were talking about in reference to infectious diseases.

page 62

So as far as you know, it's just for infectious disease reference.

A. Right.

Q. But there was not a - - this summation here that you've got was not part of an internal investigation, as far as you're concerned, back on December 5th.

A. Right.

Q. Now, I'm going to go back and ask a few more questions about this paper-routing thing. And the only reason why -- I'm not trying to pick on you -- it's because you seem to be pretty knowledgeable about that situation, and how things go. I subpoenaed -- we subpoenaed, the police and I, a whole bunch of these notes --

A. Right.

Q. -- from -- from all these people I talked to --

A. Mm-hmm.

Q. -- and I obtained a lot of stuff. I mean, it's -- I don't know how many pages are here, but quite a few pages. And they're all marked with FSU numbers, and -- By the way, do you know how this works this, FSO numbering system here?

A. No. It's probably something the OSA puts on there.

page 63

Q. I mean, have you ever seen this is on papers or - -

A. No.

Q. -- or is that just stuff that goes out to document what they know is being released?

A. When I saw that on the documents the other day, I thought it maybe something you guys put on the papers, so--

Q. Well, that answers my question. Now, I got a bunch of reports from a bunch of people, and then I've come to find, after interviewing -- and Bob's been present for many of them -- I talked to six, seven, other people, and they say, "Oh, yeah. I wrote a report." Arid some of them aren't clear. Those aren't the ones I will be referring to. Some of them are very clear. "I wrote a report. I gave it to PK. I gave it to Lacey. Or I routed it to Mr. Karduzinski." And now I've come to find out -- and this is information I've received from the lawyers that I previously referred to, Sandy and Lee - - that those -~ reports aren't available any more. Can't find them. Let me give you some examples of some people: Patricia Strasener (phonetic) says she wrote a report on 11-26 and on 12-5. I assume this 12-5 one is one that went to you.

page 64

A. Right.

Q. And that's in her own handwriting. And she thinks that they went to Karduzinski. She doesn't know that because, of course, she didn't hand them to him directly, but she had the route go to -- I guess that's called CS?

A. Yeah.

Q. Joan Stevens. She recalls a report on 11-23 and another one on 12-5. And she specifically said, in her deposition, she handed you one of those pieces of paper. She said, "Marcus Quirino. I handed -- gave it to him." Is that one of the people you interviewed here?

A. Yes.

Q. It is?

A. Mm-hmm.

Q. Okay. All right. So she remembers that. Barbara Weinberg, November 23rd, report to security. And then she also remembers, at the end, another one to you. Handwritten. Heather Petzold. She wrote three reports. She says one of them went to Karduzinski, and then she thinks, on December 1st or December 2nd, she wrote another one to Karduzinski, and then, December 5th, she remembers another one to you.

A. Right.

page 65

.Q. And she even said what was in those reports. Emma Schamehorn, December 5th, report to you.

A. Mm-hmm.

Q. Wrote another report. Can't remember what day she did them, though. Sam, the security guy --

A. Mm-hmm.

Q. -- three to four reports. Went to a fellow named Toss or Toff Attila. Toff. You know him?

A. No. I think he might be a security guard.

Q. Alice Van Rondell (phonetic), one report. One of them to Karduzinski, one of them to Woodcraft and one of them to security. And then this woman that was just in here before you - - do you know Haydee?

A. Mm-hmm.

Q. Two reports sent to CS. Now, I've painstakingly went through that just because I want to demonstrate to you that there's a lot of paper out there - -

A. Right.

Q. -- that I've been told doesn't exist any more. Do you have any -- do you have any idea where that might be?

page 66

A. Huh-uh.

Q. Who I should talk to next?

MR. POLLI: "Yes" or "no"?


A. The only thing, I could -- sitting -- the only person that would know would be Alain. I would assume they went to the PC folder. If they've given them to you, then -- BY


Q. Well, my question is, if I have reports relating to these caretakers watching after Lisa, like this one, here, that would be from her PC folder, right; there's no reason - - I mean, as far as you know, this went to the PC folder?

A. Well, if you have it then, no, I would say it wouldn't have gone to her PC folder.

Q. Oh. Where would it have gone to?

A. That, I don't know. See, if anything goes into the PC folder, I don't know that it would be given to you. If it was kept in another file, which this -- possibly, this was, then --

Q. Well, a couple lawyers have told me they don't exist, so let's start with that premise. And they represent the Church.

page 67

Who do I find out - - who is the person that I talk to in that Church that tells me where and what happened to that stuff? I don't care if it's a record custodian, if it is Brian Anderson.-- who is in charge of keeping these records?

A. It would be Alain, or possibly Brian Anderson would know. I mean, they were routed to Alain, as the CS. I don't know what happened to them after they went to him.

Q. All right. So you don't know.

A. No.

Q. How about this fellow that I've been offered up here -- guy's name is Glen Stillo (phonetic). He's the custodian of records, now. He's been told to me that he's custodian of records for the Church. He's been assigned to that post, now, by the Church and the lawyers.

A. Mm-hmm. Okay.

Q. Do you know him?

A. Yes.

Q. Okay. So he might have some answers.

A. Possibly, yes.

Q. All right. Did you have any meetings with any of the people that we previously discussed, after December 5th?

A. The watchers and stuff?

page 68

Q. No. Well, back to Brian Anderson and Judy and that -- that bunch, there.

A. No.

Q. No? No meetings?

A. No.

Q. Were you ever interviewed by the police, back when this occurred?

A. No.

Q. Just out of curiosity, what -- what reason would you give to why I can't see these -- these reports if, in fact, they exist, in the PC folder? I mean, is there a priest-penitant privilege, or is there something that you think that there's -- you know, what is -- what's up with that?

A. The only thing I -- if it's in the PC folder, it's just privileged data. I mean, that's not --

Q. Let me ask you this: You've been in the organization for a long time.

A. Yeah.

Q. Is there something about those reports that would make you think that there's a priest-penitent privilege?

A. Just because it's about her, while she was under watch, being directed by the case supervisor. So in

page 69

theory, it should have gone into her folder. Any reports on a PC is supposed to go into the PC folder, unless it's a matter of, like, ethics, in which case it goes to an - -

Q. Ethics folder.

A. Right.

Q. Are all these folders located in the same place, treasury account folders, ethics folders?

A. They're all kept in different buildings, because they belong to different divisions in the Church.

Q. Okay. So different people in charge of different folders.

A. Right.

Q. And the guy that is currently in charge of PC folders is who?

A. Would be, I think, Steve Harlan.

Q. Steve Harlan?

A. He's in charge of the actual filing of the folders, where they get placed in the archives.

Q. He is? This committee of evidence -- would that have , been a different committee of evidence - - Were you aware of an internal investigation --

A. No.

Q. -- other than that one we mentioned, a couple months after Lisa's death?

page 70

A. Right.

Q. What we have here is a semantics problem that some of the lawyers that I'm dealing with, and maybe what you're used to dealing with, in terms in the course of the Church - - your lawyer, here, calls this an internal investigation.

MR. POLLI: She's doing an internal investigation?

MR. McGARRY: No. This is the cover letter, and she calls what he was doing an internal investigation. Sounds like it -- just trying to see whether it needs a "sic" or not. BY


Q. You meet with any lawyers, during December 5th or the week or two after that reference, to possible litigation that might occur out of this situation?

A. No. First time I was approached on it or anything was the meeting with Sandy.

Q. Well, I've drug on long enough. Would you like to take a break? Because I know these guys want to ask you some questions. So would you like to plunge ahead or get a break and get a glass of water?

A. I don't mind. We can just go ahead and get it over with.

page 71

MR. McGARRY: All right. Thank you. EXAMINATION BY


Q. Marcus, the deputy chief officer --

A. Yeah.

Q. -- trying to look at some of the chain of command, there, at the Church. It looked like it was, like, the third man in charge of the -- Flag. Is that -- is that wrong or is that correct?

A. Of that org., yeah.

Q. Of that organization.

A. Of that section of the org., yes.

Q. So Brian Anderson's in a different section of the org.--

A. Right.

Q. -- and Alain Karduzinski's in another different section of the org.

A. Well, Alain is below me. It goes -- me, and then he has a division head, and then a department head, and then he's in the section --

Q. And they all answer to -- you were their senior at that time.

A. Right.

Q. And who did you answer to?

A. The chief officer or the captain.

page 72

Q. The chief officer being - -

A. Don.

Q. Jason?

A. Yeah. And the captain being Debbie Cook.

Q. Are they still in the same position? A Captain is, yeah Don isn't

Q. Where's Don now?

A. I think he's -- I think he's on the "Freewinds," which is the boat that we have.

Q. Does he still hold a pretty high position in the Church?

A. I don't know, because I'm on a different post. I haven't talked to him, probably, in about six or eight months.

Q. Your new post --

A. Yes.

Q. -- are you down the ladder in your chain of command, now, than you were?

A. Yes.

Q. Any reason for that?

A. It was a reorganization done last year, in September, to better organize the place for production. We added a bunch of new positions, and I was used to replace someone to get a new position, and my position - - the org. board no longer exists.

page 73

Q. So no one is a deputy chief officer - -

A. , No.

Q. -- in your position any more.

A. Right.

Q. Okay. How computerized is the Church in their recordkeeping?

A. Pretty --

Q. Let me just stop. This way, it'll limit your answer. Everything I've seen so far is in handwritten reports. You know, all of these things -- I think most of my research on the Church shows a lot of handwritten reports, you know, usually a legal-sized paper like this stuff --

A. Mm-hmm.

Q. -- and written. Your report, even though it's typed, probably just word processing. It's not in any kind of computer program.

A. Right.

Q. Has that changed? What I'm looking at is, if we're looking for information in 95, about Lisa, would that be in computer programs, or are we looking in the right place for all these handwritten notes?

page 74

A. As far as I know, it would be in handwritten notes. I mean, some people, like myself, people senior to me, have access to computers. But usually, people lower on the org. boards, unless they have a PC of their own, don't usually have a computer. Some have typewriters. But mainly they write their dispatches and stuff by hand.

Q. In July or August of 95 -- and I've been able to pin that down somewheres in the middle of July to the middle of August -- Lisa was having her other PTS episode.

A. Mm-hmm.

Q. In the accounts folder, would the auditing for that PTS be different, the names of the courses be different than what her normal studies would be? If you were -- if you were studying or getting audited to be clear, and you had a psychotic break, would not the PTS - - or would not the auditing be different than your clear auditing?

A. No. Certain -- the accounts computer has certain categories of auditing, like "L's" auditing is a certain category. And then most of the other thing in class is "regular." And then "regular," which is what she would have probably been debited under covers, like anything for her case level. If she did "power," then

page 75

maybe a debit for "power," which is a type of process.

Q. Okay. This report that you made up, who told you to -- to do this -- I don't want to say "investigation," because of the semantics problem, but who -- where did that come from, that you were supposed to talk to these people?

A. When I was -- Brian and PK, because of what was said by -- whoever it was on the phone, either Dave or' Janice -- I don't remember if it was PK or Brian says, "Okay. We need to interview these guys, you know, find out if there's any possibility of these guys being, you know, exposed to the infection. We have to know who was there at what times, that kind of thing.".

Q. And just to touch on Prosecutor McGarry's statements, I started to look into the organization a little bit, and I found it kind of strange -- and I know, probably, maybe - - I hope you can answer this -- but he hit upon it - - Alain was a senior case supervisor, no longer is; Janice Johnson was an MLO, no longer is; Arthur was the senior to the -- to the security chief, which is Arthur Baxter. Now Arthur Baxter's not a security chief no longer, and PK's no longer in that other position he was in. He's now the security chief. So everybody in this organization, similar to the police department, and

page 76

me being a sergeant, next week I'm a patrolman. That's one step down. And everyone I look at that had any type of dealings or control with Lisa has received a demotion. Now, in your opinion that's -- those aren't demotions, is that - - was that your testimony?

A. No. I don't think -- I don't think Janice's is a demotion. Alain, he was removed by a Com. F. But I don't know -- I don't know about the Com. F to say whether it was regarding Lisa's cycle or something else. And my post was done away with, and I replaced someone who went to do another post. There's a lot of reorg. that gets done, because one thing we do in the Church is we continuously evaluate how we're doing, and we will adjust things to increase our production, increase the amount of service that we do.

Q. I read an article in the Source magazine, and the article was done on Alain Karduzinski. And I'm not sure when it was done, but it was a pretty big article. In fact, I had two copies, one in English and one in German. And in reading the article, it -- it really, to me, as an outsider of the Church, it really came off as Alain Karduzinski as being a very big deal in this Church, as a senior case supervisor.

page 77

A. Mm-hmm.

Q. Was it normal Church procedure for him, as a senior case supervisor, to also do the auditing on Lisa McPherson?

A. It's not normal, no.

Q. It's not --

A. But it also depends what they're being audited on. Because certain things, like the introspection run-down, for instance, you have to be specifically trained on that. And I don't know how many auditors we have actually trained to actually deliver that run-down. We're limited in that. We have a few, and he is one of them that can do it.

Q. Okay. Those attendance reports -- and let me just show a couple of them -- Have you seen these at all, any of these?

A. Yeah. I've glanced at them. I haven't read them all.

Q. These attendance reports -- of course, we're missing a lot of days and different things -- would -- and you only can say church policy, because you've been in clerical -- so long I'm kind of counting you as a clerical Scientology expert, because you are the most knowledgeable person we've talked to, clerical --

page 78

A. Right.

Q. Would those reports be destroyed?

A. I don't think so.

Q. Everything I've read about the Church, they're very organized, and their documentation is kept.

A. Right.

Q. So I just -- that was -- that was actually the question (sic) I expected to get. Thank you. Now, did you see the folder -- I know you didn't get a chance to ,look in the folder, the PC folder, but this folder that was brought over from the Church, did you see it brought in at all? Did you ever see it?

A. No.

Q. The--

A. I've seen it in his office prior to that, and I haven't seen it since -- since this.

Q. Okay. Now -- and the only thing you can do is volume --

A. Mm-hmm.

Q. The only thing you can show me is volume, by inches, here, on the table, but I'm going to ask to you try to do that for me, okay --

A. In terms of what'?

Q. Well, you saw the folder on his desk. Was it this thick or was it this thick or this thick, or could

page 79

you put a thickness on it?

A. Well, the one that's on his desk was probably this thick. But she has, as far as PC folders, a lot more than just one.

Q. Okay.

A. I mean, I don't remember the number/of folders that she has, but - -

Q. All right. So the folder you saw on his desk for Lisa McPherson, that was her PC folder, was how thick?

A. It was probably about, you know, two and a half, maybe three inches.

Q. Okay. But you don't know if that just dealt with her isolation - -

A. Right.

Q. -- or that's her entire PC folder.

A. Well, see, the way a PC folder goes is, you write a program for the person, in terms of auditing steps, and the person goes through and does those sessions. And then, when that program's done, they get another program. So you can have, you know, as much an as an inch worth of programs at the front, which is just a running record of what she's been doing, and then, you know, various invoices forms, routing forms and that kind of thing in the back of the folder, which can take up two inches, and you only have an inch worth of auditing in it.

page 80

I mean, I don't know how that is with hers, but that's what can generally happen with folders.

Q. Did you get -- you got a chance to look at this?

A. Yeah.

Q. The first two are not yours, so I'll move those over. Is this your entire report?

A. Yeah. I mean, the only -- I don't -- I don't have a signature on it, so maybe -- I don't know.

Q. Okay. The thing that I found strange about looking at it is, after -- and I've been in this since September -- after looking at all of the Scientology documents, and even the ones that are rough-written - - and I call that "rough-written," by just scribbling down -- every one of them are pretty specific, as far as having someone they're going to and a signature or some type of a --

A. Routing.

Q. -- a routing, like.

A. Yeah.

Q. If you take Brian Anderson's report, okay, he puts in "Debrief of Dr. Minkoff." But on the bottom -- I guess that's him --

A. Yeah.

Q. -- "CO of OSA Flag." And that would be the

page 81

commanding officer of the Office of Special. Affairs, Flag, right?

A. Right.

Q. Now, I noticed, in your report, and considering you the clerical expert, you have no heading on your report, you have mo finish on your report, you have no signature on your report. Is that normal for you?

A. If I'm doing a summary, yes. All I did was, like, take the interviews. I'd done the notes. I had just wrote it into a summary. So it's easier for someone to read, rather than have to read through all the notes and various write-ups on people.

Q. All right. The documents you used to build this report, if we were to put them in this folder -- and we're back to inches again - -

A. Mm-hmm.

Q. -- if we were to put them back into the folder, how thick would they be?

A. Probably a little bit less than what's in there already.

Q. Just a little bit less?

A. Yeah. Probably like -- probably like that much. Q Okay Now, that would be the reports that these people were instructed to write to you on December 5th that they're all telling us about.

page 82

A. Right. And then each person I saw, I took a separate piece of paper and took my notes on them.

Q. On that? Now, did you keep those notes? A No, I turned it all over to security

Q. Okay. I guess my better question would be, are they -- are they usually kept, those notes?

A. I don't know, because I -- I mean, I would assume they would be, but I don't know.

Q. Okay. Let me go, real quickly, to -- in your report, I think you just testified a little bit ago -- the question, I think, was, why is it only these people in the report, and your answer was that, "We felt --" "We --" and I think you termed it that way - - "We felt that these were the people who took care of her at the end." Yet when I look at page 2 real quickly, Leslie Woodcraft is on November 24th --

A. Right.

Q. -- which is only four days into the watch. There's a lot of people in here, that didn't see her at the end, that you wrote about. So apparent -- I find that in opposition to your testimony, that, you wrote this report because these were the people who saw her at the end." But these are not all

page 83

the people who saw her at the end.

A. Well, anyone that was on the watch was brought over. We just started -- I just started interviewing the people. But the main ones was to find out who, mostly, was on at the watch, because at the time we were doing this, I don't know who was on at the end. So it was just interview people.

Q. Okay.

A. And I think, by the time I got to the end of this, these are the ones that were on it for the last few days. And by the time we were done with it, it was probably two, three, four o'clock in the morning.

Q. All right. I find it interesting here, on the second - - under "Heather Hough" - -

A. Mm-hmm.

Q. -- you wrote the paragraph -- third paragraph down - - that says, "Heather was then off until three days ago, when she was put back on. Once she returned to the room, she found that Lisa was pale, comma, weak and slept more."

A. Mm-hmm.

Q. "Per Heather, Lisa has not been active in the last three days." Now, since we don't have the benefit of Heather's report, because the Church is telling us that

page 84

they can't find it, can you tell me where this -- and I want to take it almost as a quote, because that's a very specific paragraph, I think, as far as describing Lisa -- where that would have come from?

A. Well, that would have come from my interviewing her, and her note - - her write-up, and then my notes on that interview.

Q. So it would come from three things: Talking to her, probably her - -

A. Write-up.

Q. - - write-up on December 5th -- Now, you didn't have, at that time, any benefit to these caretaker reports.

A. No.

Q. You didn't get to see these.

A. No.

Q. And I just want to go down -- jump a paragraph, and I want to go down to the next one. And it says, "Today, most of the day, Lisa was in bed, to -- saying --" and I'm just thinking that maybe that says, "not saying anything or not moving, comma," and then, "she was breathing." I find that an unusual comment. You know what, I'm saying? We're talking about human beings, here, and a woman, and it says, "she was breathing," like it was

page 85

something extra-important.

A. Yeah. I mean, I don't --

Q. Would that be another kind of a quote Or -- from Heather Hough, or statement from Heather Hough to you, that she was breathing? I mean, you know, if she wasn't breathing -- if she wasn't breathing, you know, I would be hoping that - -

A. Right. Yeah. I don't know why I would have put that down like that. I mean -- other than that, you know, she died on the way to the hospital. So just to make sure that she was actually, you know, alive before they even took her to the hospital.

Q. Okay. Down at the bottom of that page, under "Rita Boykin" --

A. Mm-hmm.

Q. -- it says, "Last twenty-four hours, Lisa had a swollen jaw on the left side of the face, and when attempting to feed her, a complaint about pain on the I'm just correcting the typos --

A. Right.

Q. -- but, "complained about pain in the throat."

A. Mm-hmm.

Q. "Rita did administer magnesium shots to Lisa, including today."

page 86

I'd like to know if you remember where that information came from, and did you do any questioning as far as the swollen jaw and the shots?

A. Not about the swollen jaw. The shots, she said she had given her a couple or three shots of magnesium, including that day; magnesium, to calm her down.

Q. Okay. And that's what you were understanding the magnesium shots were, is a -- a -- I don't know -- sedative, I guess?

A. I guess you could call it a sedative. I mean, we have a drink that we have, which is covered under the purification run-down, called "Cal-Mag," which is calcium magnesium, which is mixed together. Actually gives the body calcium-magnesium, to calm it down.

Q. And to your knowledge, since you have that knowledge, on that -- on the other run-down, was it normal church policy to be giving intramuscular shots or intra -- shots with needles? Is that a regular practice of the. Church?

A. No.

Q. Did you question that at all, on Boykin, when she said, "we were giving her shots"?

A. I asked her how many, and she said she'd given

page 87

her a few. Three, or something like that. I think she said ,that it started with -- Janice had given her one.

Q. Okay. That was my next question: As the deputy chief, at the time, and you're trying to figure out what happened here, who saw her, who would be responsible for ordering these shots I mean, you didn't order them.

A. It would either -- it would -- you'd have to ask them, but it would either be Alain or Janice.

Q. Johnson?

A. Yeah.

Q. I just want to skip back up to that paragraph above that, where it says Rita was, then, off for a few days, and then came back onto it last Thursday, November 3rd. And I'm assuming that she was off for a couple days from the watch and then came back on November 30th. Is that what that means?

A. Yes.

Q. "At that time, she noticed that Lisa was not walking around much, and sat on the bed quite a bit. She reported that she was weak and not eating much at all. A couple of days ago, she seemed to be doing better. However, in the last twenty-four hours she has noticeably dropped weight."

A. Mm-hmm.

page 88

Q. Now, my question is, that twenty-four hours that she has noticeably dropped weight, is that the last twenty-four hours from November 30th?

A. No. "Last twenty-four hours, noticeably dropped weight," was up to DecÁmber 5th.

Q. Okay. So that would have been, like, the last day of --

A. Last day.

Q. -- that she -- that she was alive?

A. Right.

Q. Okay. How about the "noticeably" -- "not walking much, and sat on the bed quite a bit"? Can you -- do you know, from your report, when that was?

A. That was about the 30th, when she came back on. She said she was not walking around as much.

Q. All right. So on the 30th, she's reporting to you that she's not walking around much, and she's on the bed quite a bit --

A. Mm-hmm.

Q. -- which would not be, like, the last two days.

A. Right. Like, I got this data from her on the 5th,so she's telling me, on the 30th, "When I went back on, she wasn't walking around as much; sitting on the bed a lot." You know, "quite a bit more."

page 89

Q. And she reported, "She was weak and not eating much at all." Do you remember what reference that would be? And the only reason I'm asking you this is, we don't have the benefits of Rita's report, again.

A. Well, this is what she told me that night when I interviewed her.

Q. Okay. So it would be safe to say, from November 30th to December 5th, is what this paragraph's about --

A. Right.

Q. -- which Rita's reporting she comes back November 30th, she's with her until she dies, and this is what Rita's reporting to you.

A. Right.

Q. Okay. Now, there was some testimony earlier, by some people -- Paul Greenwood, I think, specifically, and Laura Arrunnada, as, specifically, that they were ordered,, when they came back from the hospital, of taking Lisa to the hospital, that they were ordered and they sat in a security room inside the garage. Now, does that security room exist, and do you know where it's at?

A. Mm-hmm.

Q. Okay. They were ordered to sit in there, along with Janice Johnson, the three of them who had transported

page 90

Lisa to the hospital, and ordered to write a report on what happened. Now, is that report ones that were provided to you?

A. No.

Q. That's a different report?

A. I mean, anything that they brought to me was just handwritten, right at the time They came upstairs They were told what to write I didn't get any other report, that I know of, from these guys.

Q. Okay. So you have Janice Johnson in here, you have Laura Arrunnada in here, and you have Paul Greenwood in here.

A. Mm-hmm.

Q. Okay. Now, how did you gather the data for your report, here, on those three people?

A. It was given -- I didn't interview Janice or Paul. I was given a write-up on what they had said or what they had done, I think, whatever they wrote up --

Q. Okay.

A. -- when they came upstairs.

Q. Did they write it upstairs in front of you --

A. No.

Q. -- or was this prewritten?

A. They didn't write it in front of me. They may

page 91

have written it upstairs. They may have written it before they got there. But these are some of the last people I got around to seeing. And by the time I got around to seeing them, I didn't actually see them. I was getting their reports to put into a summary.

Q. Here's what I'm trying to get to -- Laura Arrunnada -- I haven't talked to Janice, but Laura Arrunnada and Paul Greenwood testified under oath that they were reported (sic) to write reports when they returned to (sic) the hospital.

MR. POLLI: I don't think Laura did. She didn't write any reports.

SERGEANT ANDREWS: She didn't write any reports.

MR. POLLI: I don't think she did, because she's Spanish.

SERGEANT ANDREWS: But apparently he had read her report.

A. No. Janice and Paul, I didn't interview -- BY


Q. You never read --

A. I never interviewed them; I think I interviewed Laura Arrunnada.

Q. How do we know that, from here? We don't.

page 92

A. We don't, really.

Q. All right. So you did see reports from Janice Johnson and Paul Greenwood - -

A. Mm-hmm.

Q. - - in reference to --

A. This --

Q. -- this? And so the information you have for Paul Greenwood came from that report.

A. Right.

Q. Okay. And those reports that were just a little thinner - -

A. The stuff I got, I gave to OSA.

Q. Yeah. Who did you give to in OSA?

A. Actually, one of the security guards -- I think' it was PK or Arthur -- and they took it over there --

Q. Okay..

A. -- to Brian.

Q. All right. And I just wanted to clear this up:, You were not - - your testimony today under oath is you are not positive this is your entire report, or you are?

A. I'm not -- I couldn't swear to it. I mean, I did do this, and I do recognize writing all this you have, but like I said, you know, this is like a year and a half

page 93

ago, and there may have been more to it. I mean, like maybe there's a page 6 or something. That I don't know.

Q. Do you remember signing it?

A. No. I definitely didn't sign it. I just printed it off and attached it to the front of everything.

SERGEANT ANDREWS: Okay. I don't have I anything further.

AGENT STROPE: I just have a couple questions.




Q. We've got some reports, we don't have others. And we know that you were collecting the data for this report. But when this was all over, did you write some type of report? Did you have to do some type of report?

A. The only thing -- no. The only thing I had to do was just type up this summary and turn it in.

Q. But you never had to do anything on your own.

A. No.

Q. Nobody asked you to write a report concerning this whole Lisa McPherson incident?

A. No.

Q. Were you ever briefed by someone, concerning the

page 94

incident, afterwards?

A. (Shakes head)

Q. Never sat down with anybody and said, "This is what happened, I think," and, "This is what happened," or--

A. (Shakes head).

Q. No? Okay. I'm just going to touch on this for a minute: We interviewed Heather -- which is now Petzold, right?

A. Yes.

Q. And she had told us, under oath, that she had went to someone -- and I don't know if she said it was you or Alain Karduzinski -- and said, basically, "Listen, this girl is getting worse. Things are not good here. We need to do something different for this girl. I don't like the way things are going." Are you familiar with that statement? Did she ever come to you and say that?

A. No.

Q. Were you familiar with her attitude concerning the care of Lisa?

A. No.

Q. Alain never bothered to talk to you about that?

A. No.

page 95

Q. Would it have made a difference?,

A. Well, if I had known that it was something - - she felt like something was "off" with it -- or Patrick, I think, also made a similar statement - - we could have done something with it. But, like, in interviewing, even, the -- interviewing Rita afterwards the last couple days, Rita thought she was actually improving, until the last twenty-four hours.

Q. Mm-hmm. And you also made a statement earlier that the reason for your reports - - basically, your reason for these interviews was to protect the people you were interviewing from or -- the people you were interviewing or the people that were with Lisa, from whatever disease it was that Lisa had, right? Is that what you --

A. It wasn't to protect them. If they had -- if she had spinal meningitis, the thought behind it was that they needed to be isolated, one, so if they have it, they're not walking around the base, because we have fifteen hundred other people there, and it's a contagious disease.

Q. So basically, that was the sole reason for your report?

A. Right.

page 96

Q. And then - - Sergeant Andrews touched on this earlier, where you made. a reference in the reports to, "She was breathing." "She was given a bath." That really has no relationship to spreading disease, does it?

A. No.

Q. Is that just -- Okay. And I'd went over this with Dr. Minkoff, too. I believe you mentioned in your report that Rita Boykin said that, the last twenty-four hours, Lisa had a swollen jaw on the left side of the face. Did she say how that became swollen?

A. (Shakes head).

Q. Anybody ever mention to you about Lisa being struck?

A. Struck?

Q. Mm-hmm.

A. No.

Q. No?.

A. I did hear from them, her hitting them.

Q. Mm-hmm.

A. Her doing things like banging her head on the floor, kicking the bed, breaking glass, that kind of thing.

page 97

Q. Well, we went over, with Dr. Minkoff, a mark that was on the left side of her face, that I believe was the result of a strike, and - - and there is indication here there was swelling on the right side. I thought maybe somebody had mentioned how that swelling took place.

A. No.

Q. You don't have any medical background?

A. Myself?

Q. Yeah.

A. No.

Q. You'll have to excuse me, here. I agreed to go last, so I just have to kind of go through and see that I don't cover things that have already been covered. And. you never went to the Cabanas to visit Lisa?

A. No.

Q. As far as you know, was Lisa held all the time at the Cabanas or was there some place else that she was held?

A. As far as I know, she was in the Cabanas the whole time.

Q. She never left, in all the days she was there? She was never taken anywhere, for whatever?

A. I don't know.

Q. You don't know or she wasn't?

A. I don't know.

page 98

Q. Okay. You said that you're required by the IRS to keep certain folders. Which folders are you talking about?

A. No. The Church is required by the IRS to keep accurate financial records, so any - - any donations made by parishioners, we have to keep track of those. We're required every year to give them a statement of their account. So --

Q. So all those folders -- are they accessible to us, all those folders having to do with your financial records, as far as you know?

A. I don't know what the normal legal proceedings are to get them. But as far as I know, there wouldn't be any reason you couldn't get them. But you'd have to check that with - -

Q. How do your records request relate to someone who is deceased? What happens to a person's files after they're deceased?

A. They go to archives.

Q. And where is that? Los Angeles?

A. No. Well, I don't know how far back we're required to keep files. I know that, last year, we had a bunch of our financial records from, like, you know, ten years or so ago, go out to Los Angeles. But as far as I know --

page 99

Q. Do a person's entire file, including their counseling file and their auditing file and everything, go, when they're deceased, to a particular place?

A. No. They would get marked "Deceased," and they get filed in the archives.

Q. Now, are they open to us after they're deceased? There's no longer a privilege there, is there?

A. That, I don't know. You'd have to check with the - - have to check with OSA.

Q. But after they're marked "Deceased," they're marked "Deceased" and go somewhere, is that it?

A. Yeah.

Q. Did you ever discuss this case with Lyn Farney (phonetic)? You know who Lyn is?

A. Huh-uh.

Q. You don't know who he is?

A. Who is he?

Q. He works for OSA in Los Angeles. Never met him?

I don't think so.

Q. Okay. You've used the word "production" a lot. What do you mean by "production"? It sounds like General Motors, here.

A. We keep statistics on how much counseling, how much training we do, and we, you know -- from an

page 100

administrative point of view, work out ways to get more counseling, more training done. And you know, it's, you know, referred to as "production," because, like, what various people produce. It's a product that they produce. And how much of that product.

Q. For a fee.,

A. Hmm?

Q. For a fee, right?

A. Well, we get, you know - - we get an allowance, church members..

Q. No. I mean the Church. The production benefits the Church.

A. Right.

Q. The organization. Does Bennetta Slaughter hold any kind of post at the Church --

A. Any kind of post?

Q. - - or is she strictly public?

A. She's public, but I think she, like, heads up a number of the different community activity - - you know, community relation groups and stuff like that. You know, I think she's in charge of the Women's Auxiliary or something like that.

Q. So she's actually, maybe, part-time staff?

A. It's not staff. It's, like, a volunteer.. It's,

page 101

like, you know, someone would, you know, in a - -

Q. We've spent some time around, and I see her attending meetings with the likes of Ableson and Rinder and some of these people. Is there a possibility she may be staff and you don't know it?

A. Who? Ableson?

Q. Attorney Ableson, from Los Angeles.

A. No.

Q. Brian --

A. She's not staff. She's definitely public. She does things like, you know, sponsors Way To Happiness, works out with Way to Happiness, out in the community. Does a lot of community-type work. But it's on a voluntary-type basis.

Q. Is it unusual to have someone like Lisa, who is public, given so much attention?

A. Not in her condition, no.

Q. Is that something she would have questioned or that is something somebody can say, "We're going to do that, whether you like it or not," or is that totally voluntary?

A. Well, someone in her condition, when she came in, if she was, like, in a Type III spin, we would just automatically do it. I mean, if it wasn't us, if she was out on the street, she'd be put in the psychiatric ward

page 102

involuntarily or whatever.

Q. Now, on November l8th, when Lisa went to Morton Plant, were you -- were you aware of anybody within your organization that was looking for Lisa at that time?

A. No. Q Was she in auditing before that time, do you know, on that day, on November 18th?

A. I don't think so.

Q. Was she free to leave whenever she wanted to? Are people under auditing or under watch, like she was, free to just get up and leave?

A. No. I mean, if she --

Q. No?

A. - - was, like, coherent and, you know, had regained, you know -- was able to function on her own, she would have been free to leave, but she wasn't in that condition.

Q. Was she allowed visitors?

A. I don't know.. I don't think anyone came to visit her.

Q. Is it acceptable for members of the organization to lie to the police or anybody to protect the Church? Is that acceptable?

A. No.

page 103

Q. Under no conditions?

A. Huh-uh. No. There's a policy from LRH to abide by the laws of the land. Whichever land, you know, whichever place we happen to be at, we have to abide by those laws.

Q. When did you first realize that this was going to be a criminal investigation by the police department?

A. I think, the next day, when I heard that the police department had come down to interview people on the watch.

Q. You weren't interviewed at that time?

A. No. I wasn't actually on the watch at that time. Any contact I had, really, with it, other than, you know, a few passing comments, and talking to Alain a couple times, was the debrief at the end.

Q. Mm-hmm. Were you aware that Janice Johnson was a doctor, medical doctor?

A. Mm-hmm.

Q. Was that the reason she was appointed medical liaison? Did that have something to do with it or --

A. (Shakes head).

Q. You don't know?

A. That, I don't know.

page 104

Q. Is it usual procedure, in a watch, to have someone with medical training there?

A. No.

Q. It's not usual procedure? Is this an exception to that rule or - -

A. She was -- she was the MLO, so that's why she was connected with it. I mean, normally, if -- even if she wasn't trained medically, the MLO would be keeping an eye on it.

Q. Did you ever go over, in their entirety, the caretakers' notes?

A. No, just the ones that were given to me that night.

Q. If those notes -- and I'm not saying they were, but if those notes were gleaned through and decided which ones would come to us and which ones weren't, who would do that?


Q. OSA? There was some -- I'll ask you this question, and then I'll wrap it up. There was some indication, early on, that, before the 18th of November, that Lisa had inferred to people that she knows in Texas that she wanted to leave the Church.

page 105

If a person -- what would you -- how would you deal, or how would the organization deal with a person that wants to leave? Is that okay to do?

A. There's a routing form, which is a form that takes you through various steps to do - - get your money to - -

Q. Are they discouraged to --

A. They get seen -- on the routing form, there's various different handlings that would done with them, such as fixing any outnesses (phonetic) that may be on their auditing, or if they're on training, making sure they didn't misunderstood (sic) words.

Once they're done with that routing form, they get their money back and they're free to go.

Q. They get their money back and they're free to go?

A. Absolutely.

AGENT STROPE: Okay. I don't have any further questions. Thank you, sir.

MR. McGARRY: That's it. Thank you sir.


page 106




          I, the undersigned authority, certify that
MARCUS QUIRINO personally appeared before me and was
duly sworn.

          WITNESS my hand and officia1 seal this 2nd day 
of June, 1997.

                        [notary seal]

                      DONNA M. KANABAY, RPR, RMR
                      Notary Public - State of Florida

page 107




          I, DONNA M. KANABAY, Registered Professional
Reporter, certify that I was authorized to and did
stenographically report the deposition of MARCUS QUIRINO,
and that the transcript is a true and complete record of
my stenographic notes.

          I further certify that I am not a relative,
employee, attorney or counsel of any of the parties, nor 
am I a relative or employee of any of the parties' 
attorney or counsel connected-with the action, nor am I
financially interested in the action. 

          DATED this 2nd day of June, 1997.

                      DONNA M. KANABAY
                      RPR, RMR