Sworn Statement of Annie Mora

Date:August 21, 1997



      IN RE:



      DATE:               August 21, 1997

      TIME:               Began: 10:35 a.m.
                          Ended:  2:00 p.m.

      PLACE:              Criminal Justice Center
                          Office of the State Attorney
                          Room 1000
                          Clearwater, Florida

      REPORTED BY:        Ruth N. Martin, CSR, CP, RNR
                          Registered Merit Reporter
                          Notary Public
                          State of Florida at Large

                    KANABAY COURT REPORTERS
              TAMPA AIRPORT MARRIOTT - (813) 224-9500
            ST. PETERSBURG/CLEARWATER - (813) 821-3320



            Office of the State Attorney
            Criminal Justice Complex, Room 1000
            Clearwater, Florida 33760
                 Attorney for State of Florida

            JOHN F. LAURO, ESQUIRE
            John F. Lauro, P.A.
            Barnett Bank Plaza, Suite 3950
            101 East Kennedy Boulevard
            Tampa, Florida 33602
                 Attorney for the Witness


            LEE STROPE, Special Agent
            Florida Department of Law Enforcement
            WAYNE C. ANDREWS, Detective Sergeant
            City of Clearwater Police Department

           BY MR. McGARRY                                 3
           BY DETECTIVE SERGEANT ANDREWS                 97
           BY SPECIAL AGENT STROPE                      119
           BY MR. McGARRY                               135
           BY DETECTIVE SERGEANT ANDREWS                138

      CERTIFICATE OF OATH                               141


      1             The deponent herein,
      2                  ANNIE MORA,
      3          being first duly sworn to tell the truth, the
      4          whole truth, and nothing but the truth, was
      5          examined and testified as follows:
      6                  MR. LAURO: Let me put on the record that my
      7          name is John Lauro, and I represent Miss Mora. She is
      8          testifying today pursuant to a subpoena issued by the
      9          State Attorney's Office for Pinellas County,
      10         Pasco County. And as a result, she's testifying with
      11         full protection of Florida law in connection with that
      12         subpoena.
      13                           EXAMINATION
      14   BY MR. McGARRY:
      15         Q.   Okay. Your name, please?
      16         A.   Annie Mora.
      17         Q.   And your date of birth?
      18         A.   X '61.
      19         Q.   All right. And where do you reside?
      20         A.   At the Hacienda X
      21         Q.   I know where it is.
      22         A.   Okay.
      23         Q.   Do you have a roommate? Are you married?
      24         A.   I'm married.
      25         Q.   Okay. How long have you been a member of the


      1    Church of Scientology?
      2          A.   Since 1982.
      3          Q.   Okay. And how long have you resided in
      4    Clearwater, Florida?
      5          A.   Three and a half years.
      6          Q.   Okay. And where did you live before you lived
      7       here?
      8          A.   Los Angeles.
      9          Q.   Okay. And obviously, you were a member of the
      10   Scientology religion out there?
      11         A.   Uh-huh.
      12         Q.   Okay. And how did you become a member of
      13   Scientology?
      14         A.   My mother introduced me.
      15         Q.   Okay. Did you meet your husband through the
      16   Church or were you married prior to you getting into the
      17   Church yourself?
      18         A.   I met him in the Church.
      19         Q.   Okay. What caused you to move to Clearwater?
      20         A.   He -- he and I were living and working in
      21   Los Angeles, and he came to Clearwater to do a specific job,
      22   and he ended up getting posted in Clearwater, so then I
      23   transferred.
      24         Q.   Okay. What's his position?
      25         A.   He's the Chaplain at the Flag Service


      1    organization.
      2          Q.   Okay. And were you -- is there an OSA out in
      3    L.A.?
      4          A.   Uh-huh.
      5          Q.   There is?
      6          A.   Yes.
      7          Q.   And were you with them out there?
      8          A.   Uh-huh.
      9          Q.   So you were able to find a post in Clearwater in
      10   OSA?
      11         A.   Right.
      12         Q.   When you moved here -- which would have been what,
      13   '94?
      14         A.   Yeah.
      15         Q.   What was your position then?
      16         A.   Before I moved here?
      17         Q.   No, when you moved here. When you moved here in
      18   '94, what position did you get with Clearwater Flag?
      19         A.   I was in the research -- same area where I work
      20   now.
      21         Q.   So you haven't changed anything since you moved
      22   from L.A.?
      23         A.   Unh-unh.
      24         Q.   So how would you describe your job description?
      25         A.   I research, I collect information that I think


      1    others need to know in order to give direction on how to
      2    handle situations for --
      3          Q.   What kind of situations?
      4          A.   Situations that may present public relations or
      5    legal situations for the Church.
      6          Q.   So you must be working pretty closing then with
      7    Brian Anderson. It seems like he does a lot of that.
      8          A.   Yeah, uh-huh.
      9          Q.   Who else does what you do? Anybody else?
      10         A.   Nobody at the moment.
      11              Who else did in December of '95, anybody else?
      12         A.   Nobody at that time.
      13         Q.   Okay. But within your office also worked -- I'm
      14    sure they probably had various responsibilities, but
      15    Humberto Fontana and Judy, right?
      16         A.   Uh-huh.
      17         Q.   Lynn Farney, was he in that office?
      18         A.   No. He's from Los Angeles, always been there.
      19         Q.   Oh, he's from L.A.?
      20         A.   Yeah.
      21         Q.   Do you know him?
      22         A.   Uh-huh.
      23         Q.   Do you work with him?
      24         A.   No.
      25         Q.   I mean, was he here for the Lisa McPherson thing


      1    for a period?
      2          A.   Yeah.
      3          Q.   Okay. Ben Shaw is now in there, right?
      4          A.   Uh-huh.
      5          Q.   Ben Shaw took Brian Anderson's position?
      6          A.   Uh-huh.
      7          Q.   Okay. Let me start by asking you, did you know
      8    Lisa McPherson prior to any of this occurring back in
      9    December of '95?
      10         A.   Never met her.
      11         Q.   Never met her?
      12         A.   Unh-unh.
      13         Q.   Did you know -- did you know Benetta Slaughter?
      14         A.   Never met her.
      15         Q.   No?
      16         A.   Unh-unh.
      17         Q.   Okay. When did you first hear her name,
      18   Lisa Mcpherson's name?
      19         A.   The day that she went to the hospital,
      20   Morton Plant, after the car accident.
      21         Q.   All right. Who told you that that occurred?
      22         A.   I don't remember exactly. It may have been Brian.
      23         Q.   Brian Anderson?
      24         A.   Yeah.
      25         Q.   And do you remember what was told to you?


      1          A.   That a parishioner of ours was at Morton Plant
      2    Hospital. I don't remember anything more than that.
      3          Q.   All right. What action did you take when you
      4    heard that information?
      5          A.   Well, I went to the hospital.
      6          Q.   You were one of the people that went to the
      7    hospital?
      8          A.   Uh-huh.
      9          Q.   Why was that?
      10         A.   That was with the purpose of finding out what was
      11   going on, to see if there was a situation there that the
      12   Church should be concerned about, get what information about
      13   that that I could, so that handling could be done that would
      14   help her and protect us as well.
      15         Q.   Okay. So you -- you were given enough information
      16   to realize that this was a Type III situation, possibly?
      17         A.   Uh-huh.
      18         Q.   Agreed?
      19         A.   Yeah.
      20         Q.   And that potentially a psychiatrist might get
      21   involved here, which is against you guys, being the Church's
      22   philosophy, so that is why members from the organization
      23   might have shown up there. Would you describe that as your
      24   position?
      25         A.   That was a concern, yeah.


      1          Q.   Okay. Who took you to the hospital?
      2          A.   I think I drove it in my car.
      3          Q.   By yourself?
      4          A.   Uh-huh.
      5          Q.   Who else from the Office of Special Affairs also
      6    went, if you can remember?
      7          A.   Humberto went.
      8          Q.   Humberto?
      9          A.   Uh-huh. He was the only other person from my
      10   office that went.
      11         Q.   All right. And when you arrived there, you
      12   discovered there were other members from the Church that
      13   were there also, correct?
      14         A.   Uh-huh.
      15         Q.   And who were they?
      16         A. Well, there was a parishioner there, not a Staff
      17   member. Do you want --
      18         Q.   Who was that?
      19         A.   That was David Slaughter, Benetta Slaughter's
      20   husband.
      21         Q.   Okay. And why was he there?
      22         A.   From what he relayed to me, he had gotten a call
      23   from Lisa at home, from the hospital, and so he went.
      24              Another gal went who was a resident in their
      25   household at the time. Her name is Mary Damass.


      1          Q.   Mary Damass?
      2          A.   Uh-huh.
      3          Q.   She came with  --
      4          A.   So she was there.
      5          Q.   -- David Slaughter?
      6          A.   I don't know.  Perhaps, but I don't know for sure.
      7          Q.   All right. You gained that information from
      8    Mr. Slaughter himself?
      9          A.   Uh-huh.
      10         Q.   Was that at the time or recently?
      11         A.   At the time at the hospital.
      12         Q.   All right. Who else from the Church was there?
      13         A.   Another parishioner named Jeanne Decuypere.
      14         Q.   And she's a chiropractor?
      15         A.   Uh-huh.
      16         Q.   And how did she come to be there?
      17         A.   I'm not sure. I don't know.
      18         Q.   You don't know how she arrived or what her purpose
      19   was?
      20         A.   From what I understood later, she had treated Lisa
      21   priorly as a professional.
      22         Q.   Okay. Anybody else?
      23         A.   After I arrived there was -- either after I
      24   arrived or when I arrived, I believe Emma Schamehorn was
      25   there, and then after I arrived Judy Goldsberry-Weber came,


      1    Alain Kartuzinski came, and I think that's it.
      2          Q.   That's quite a lot of people for a situation like
      3    this.
      4          A.   That's true.
      5          Q.   Has this ever happened before?
      6          A.   Not in my experience, no.
      7          Q.   Why did she attract so much attention?
      8          A.   Well, it's not -- it's not very usual that this
      9    kind of thing happens to somebody. And when it happens to a
      10   Scientologist who, you know, has been a parishioner for a
      11   long time, and should by this time be in such a -- a good
      12   frame of mind, you know, it's like why does this happen.
      13   It's a tragic thing to go crazy.
      14         Q.   Okay. Let's -- let's touch upon your study level
      15   so I'll know. Obviously, you've been with the Church for
      16   some time, but your level of study is how far on that side
      17   of the board, not the training side?
      18         A.   Are you familiar with the --
      19         Q.   Pretty familiar.
      20         A.   -- different levels?
      21              Okay. So I am -- I have the basic administrative
      22   training that any Staff member does. It's called
      23   Staff Status II.
      24         Q.   Let's go to the other side of the board. Let's go
      25   to the spiritual side.


      1          A.   The technical side?
      2          Q.   The technical side.
      3          A.   So there I've done the Hubbard Qualified
      4    Scientology Course; and there's a little bit of auditing
      5    involved in that course as well.
      6          Q.   Are you clear?
      7          A.   Unh-unh.
      8          Q.   You have not reached Clear?
      9          A.   No.
      10         Q.   That was my main question.
      11         A.   Okay.
      12         Q.   Back to the hospital: So what role did -- did you
      13   play at the hospital? Did you speak to anybody that was
      14   from Morton Plant?
      15         A.   No.
      16         Q.   Who did?
      17         A.   Humberto did.
      18         Q.   And were you present to hear him speak to
      19   somebody?
      20         A.   No.
      21         Q.   Okay. Do you know who he spoke to?
      22         A.   No.
      23         Q.   Do you know what the basic context of his purpose
      24   was? I mean, what was he talking to the doctors about?
      25         A.   His -- his purpose at the time was to do what he


      1    could to inform the authorities in the hospital that she is
      2    a Scientologist and that she, based on her religious
      3    beliefs, wouldn't want to end up in -- in the hands of
      4    psychiatry. She doesn't want to get drugs, she doesn't want
      5    to get put away. And so he was making that known --
      6          Q.   Okay.
      7          A.   -- to them as best he could. I don't know how --
      8    how well he did himself. But he wanted that known and ...
      9          Q.   You say that you don't know how well he did
      10   because of what?
      11         A.   I don't know who he talked to, I don't know what
      12   reaction he got, but that was his purpose.
      13         Q.   All right. And let's go to Judy Goldsberry-Weber,
      14   what was her purpose?
      15         A.   Judy had -- she came because she knows people in
      16   the hospital from having come there before with parishioners
      17   and Staff for emergency care, you know, accidents.
      18         Q.   What position did she have with the Church?
      19         A.   She was the Medical Liaison -- she was one of the
      20   Medical Liaison Office staff.
      21         Q.   Office staff, okay.
      22         A.   I think she was the --
      23         Q.   Did anybody else in the MLO Office show up there?
      24   Was it just her?
      25         A.   I think Emma was there too.


      1          Q.   Emma, that's right.
      2          A.   She was there.
      3          Q.   Out of the people that you've named that were
      4    there -- did you leave anybody out that you can recall?
      5    know this has been a while.
      6          A.   Unh-unh.
      7          Q.   Okay. That pretty much covers it.
      8               Out of those people, who actually spoke personally
      9    with Lisa McPherson?
      10         A.   I know in the -- in the back, in the emergency
      11   room area, there was Debbie -- Mary Damass and
      12   Jeanne Decuypere, and then later on Alain Kartuzinski was
      13   able to see her.
      14         Q.   All right. How about Judy Goldsberry-Weber, was
      15   she back there too?
      16         A.   She did go back. I don't know if she actually saw
      17   Lisa.
      18         Q.   And you didn't?
      19         A.   No.
      20         Q.   So you don't know what was said out there, or did
      21   you gain that information later?
      22         A.   Yeah, anything I -- I got about what happened came
      23   later.
      24         Q.   Occurred later?
      25         A.   Yeah, uh-huh.


      1          Q.   Okay. After they were in there, those people you
      2    just mentioned were in there talking to Lisa, they came out,
      3    did y'all have an assembly together and decide what would
      4    best be the course of action, plan of action for Lisa?
      5          A.   No. Before she came out I recall, you know, being
      6    concerned about this, where she was going to go, how is she
      7    going to be cared for, did she even need somebody to help
      8    her, was she able to get around. These are the kinds of
      9    things I was trying to decipher. And there was some talk
      10   about where she might be able to stay, you know. It was
      11   adjudicated she probably shouldn't stay by herself, because
      12   she was obviously unstable.
      13         Q.   What do you mean, "adjudicated"?
      14         A.   Decided. Figured out.
      15         Q.   Okay.
      16         A.   And while there I remember Alain was on the
      17   telephone, I don't know who with particularly, but, you
      18   know, he was -- he as well was working on that, you know,
      19   where -- where was she going to go, how was she going to be
      20   cared for.
      21              And before she came out it was decided, not by
      22   myself or not by Alain, but whoever he was talking with on
      23   the phone, it was coordinated with whoever was at, the Church
      24   at the time, not at the hospital, that she should just go to
      25   the Fort Harrison.


      1          Q.   All right. Whose decision was that?
      2          A.   I don't --
      3          Q.   Who makes the final call on that out of that group
      4    of people?
      5          A.   I don't know who that was.
      6          Q.   Who's the highest ranking individual out of those
      7    people you mentioned?
      8          A.   Perhaps the Security Chief.
      9          Q.   Was he there to?
      10         A.   Not at the hospital.
      11         Q.   Oh.
      12         A.   Oh, out of us in the hospital?
      13         Q.   Yeah. Out of the people in the hospital, it might
      14   have been you?
      15         A.   Yeah, well, it might have been if it were -- if it
      16   were -- if it were up to me, but it wasn't.
      17         Q.   Okay. That decision was made -- obviously, that
      18   decision, the care of her spiritually, wouldn't have fallen
      19   under your purview of authority anyway?
      20         A.   No.
      21         Q.   That would have been Mr. Kartuzinski, correct?
      22         A.   Yes.
      23         Q.   And why was that?
      24         A.   Because he's in a technical position where he
      25   would, you know, know what to do with a person to help a


      1    person in that condition.
      2          Q.   Okay. Had he -- had he had experience with
      3    Lisa McPherson prior to this incident?
      4          A.   I don't know.
      5          Q.   Who knows the answer to that?
      6          A.   He would know.
      7          Q.   Okay. Do you know who her Auditor was at the time
      8    prior to her being pre-Clear?
      9          A.   No.
      10         Q.   His title is Senior Case Supervisor, correct?
      11         A.   At that time, yeah.
      12         Q.   Okay. So she fell -- her situation fell under his
      13   responsibility?
      14         A.   Yeah. It didn't have to be that way, there are
      15   other Case Supervisors, but he --
      16         Q.   He happened to draw the lot on that one?
      17         A.   Yeah.
      18         Q.   Okay. So are you aware then -- how long did this
      19   last down there at the hospital? How long were you guys
      20   there, do you remember?
      21         A.   I don't know. Maybe an hour.
      22              MR. McGARRY: Fill me in, Detectives, what
      23   time was the accident?
      24              DETECTIVE SERGEANT ANDREWS: About six
      25   o'clock at night.


      1          Q.   Six o'clock at night. So what time do you think
      2    she checked out, best of your recollection? Was it the wee
      3    hours sometime, morning hours?
      4          A.   Oh, no, it was still in the evening I'm sure.
      5          Q.   Evening hours?
      6          A.   Yeah.
      7          Q.   And how did that process go? How did Lisa get out
      8    of the hospital? Who did she leave with?
      9          A.   She walked out of the hospital with
      10   Jeanne Decuypere and Emma and Alain.
      11         Q.   All right. And whose car did she get into?
      12         A.   Alain's.
      13         Q.   All right. And who got in the car with her, just
      14   the  two of them or more than the two of them?
      15         A.   Emma and Jeanne.
      16         Q.   At the time they got in that automobile, was it
      17   known to you what the course of action was going to be?
      18         A.   That she was going to the Fort Harrison, yes.
      19         Q.   For rest and relaxation, that was the decision
      20   that was made?
      21         A.   Yeah.
      22         Q.   And you knew that?
      23         A.   Uh-huh.
      24         Q.   And that decision was made by Mr. Kartuzinski in
      25   consultation with whoever else he had on the telephone from


      1    the other end of the Church?
      2          A.   Yeah.
      3          Q.   Okay. Do you know if she went straight to the
      4    Fort Harrison at that time?
      5          A.   I assume so. I didn't follow them, but I don't
      6    know what else they would --
      7          Q.   The reason why I'm asking, there's always been a
      8    missing gap here, how she got all of her things. She ended
      9    up with a bunch of clothes and personal effects at the
      10   Fort Harrison. I never did figure that out. Do you know
      11   how she got all that stuff?
      12         A.   (Witness shakes head negatively.)
      13         Q.   Have no idea?
      14         A.   I can guess, but I don't --
      15         Q.   Take a guess. I won't hold you to it.
      16         A.   Probably one of her friends brought it.
      17         Q.   Brought it to the Church?
      18         A.   Yeah.
      19         Q.   You don't know if they went to her house first or
      20   went straight to the Fort Harrison?
      21         A.   I don't think they would have gone to her house
      22   first.
      23         Q.   Okay. Now, what did you do?
      24         A.   At that point?
      25         Q.   Yes.


      1          A.   Well, I would have left and gone back to my
      2    office, started gathering whatever information was available
      3    on her. You know, there are various kinds of information we
      4    have there. Like there is a central file, file, which is a
      5    file of correspondence between her and the Church.
      6          Q.   You started pulling all the files?
      7          A.   Yeah.
      8          Q.   Would you characterize yourself as somewhat of a
      9    Custodian of Records there or are you just -- you gather
      10   information when a situation like this comes up?
      11              MR. LAURO: That's kind of a legal term, but
      12   aside from the legal issue, how would you describe your
      13   function in terms of records?
      14         A.   The latter that you mentioned, when something
      15   happens.
      16         Q.   You gather the information so that action can be
      17   taken on it and the right people get the information
      18         A.   Right.
      19         Q.   -- to act upon it?
      20         A.   Exactly.
      21         Q.   So this gathering of folders, I assume, various
      22   folders --
      23         A.   Uh-huh.
      24         Q.   -- was for ultimately who to look at, you or
      25   somebody else?


      1          A.   Well, I would compile the information and give it
      2    to my Seniors, Brian at the time, you know. That would be
      3    something of use to the Legal Department as well.
      4          Q.   Okay. So you compiled this information, and that
      5    included a central file folder?
      6          A.   Uh-huh.
      7          Q.   Account folders? No?
      8          A.   I wouldn't have cared about that at the time.
      9          Q.   Ethics folders?
      10         A.   Yeah.
      11         Q.   Okay. Personal folder?
      12         A.   She wouldn't had -- she didn't have one. She
      13   wasn't --
      14         Q.   Okay. PC folders?
      15         A.   I would have gotten information from the PC folder
      16   that would be of use to us, but I'm not -- that's not a
      17   folder I myself would go through.
      18         Q.   Why?
      19         A.   'Cause I'm not of that same level in Scientology
      20   that she was.
      21         Q.   Okay. So you're not Clear, so you can't go
      22   through them?
      23         A.   Uh-huh.
      24         Q.   You can physically handle the folder. How would
      25   you go through it to pick something out if you can't look at


      1    it?
      2          A.   I wouldn't. I would have somebody else do that
      3    for me.
      4          Q.   Okay. And who was that somebody else?
      5          A.   Alain, I think. I don't know who else I would
      6    have had do that...
      7          Q.   Well, let's see here and think about that for a
      8    second.
      9          A.   Okay.
      10         Q.   'Cause that's a burning question I have.
      11         A.   Okay.
      12         Q.   I want to know who was the person that went
      13   through the PC folder or gathered -- you gathered the PC
      14   folders, you actually got them?
      15         A.   No.
      16         Q.   You didn't --
      17         A.   Didn't have any reason to have them in my office.
      18         Q.   All right. But you gathered folders?
      19         A.   Uh-huh.
      20         Q.   All the folders but the PC folders?
      21         A.   Right. Which is two folders.
      22         Q.   There's just two PC folders that she had?
      23         A.   No, the central file folder and the ethics folder
      24    are the two that I got.
      25         Q.   You gathered those?


      1          A.   Yeah.
      2          Q.   And you can look at those, right?
      3          A.   Yeah.
      4          Q.   Let's keep with those two folders then. Who did
      5    you give those folders to?
      6          A.   Well, eventually they were sent to Los Angeles.
      7    Up to that point they didn't go anywhere.
      8          Q.   You didn't let Brian Anderson look at them?
      9'         A.   I didn't hand them to him.
      10         Q.   All right. Did he call for them?
      11         A.   I don't -- I don't think so.
      12         Q.   So you just had them on your desk?
      13         A.   Uh-huh.
      14         Q.   Who looked at them -- is that where they stopped?
      15         A.   Huh?
      16         Q.   Your desk was the last stop for those two folders?
      17         A.   There may have been people come to look at them or
      18   take them from my desk to --
      19         Q.   Do you know who any of those people would have
      20   been?
      21         A.   People in our office.
      22         Q.   Okay. Is there a procedure where they would come
      23   see you and take them or they would take them without your
      24   knowledge or would they check them out or is there some
      25   situation that keeps track of these things so they don't end


      1    up being misplaced or end up on somebody's desk where they
      2    don't know where they are?
      3          A.   Normally when we go into somebody else's area when
      4    they're not there, and we need something, we'll take it,
      5    borrow it, leave a note saying, I have blah, blah folder
      6'   with me. They rarely go outside of the office.
      7          Q.   You gathered the ethics and the central file
      8    folder. Now, what did you do with those folders?
      9          A.   I used a lot of information to make this report.
      10         Q.   To make this document here?
      11         A.   Uh-huh.
      12         Q.   And you did this at whose suggestion, or was it
      13   initiated by yourself?
      14         A.   By myself.
      15         Q.   Totally?
      16         A.   This is my job.
      17         Q.   All right. You initiated this whole procedure?
      18   Nobody said, Annie, give us a summary of the ethics and the
      19   central file folder, please?
      20         A.   I don't think so. It's just that's something that
      21   I would normally do.
      22         Q.   All right. But most of the people that have
      23   testified in reference to the Lisa McPherson situation have
      24   indicated it's not a normal situation. Would you agree with
      25   that?


      1          A.   Definitely.
      2          Q.   Okay. So my question is, is this a normal
      3    situation?
      4          A.   The writing of a report?
      5          Q.   What's this called, a Knowledge Report?
      6          A.   This is a report.
      7          Q.   Just a report?
      8          A.   Yeah.
      9          Q.   But you would characterize this as a summary of
      10   the ethics file and central file folders that you read,
      11   correct?
      12         A.   It's a report that has information from those
      13   files in there.
      14         Q.   Okay.
      15         A.   It has other data too.
      16         Q.   From what other sources?
      17         A.   From -- from David Slaughter, you know, how this
      18   came to be.
      19              Well, this -- this report here was done when she
      20   died. But I remember a lot of this information that's in
      21   this report came from the earlier data collection done when
      22   she first went to the hospital.
      23         Q.   We're going to have to back up and ask about that.
      24              When she first went --
      25         A.   I mean, when she came out of the hospital, then I


      1    got--
      2          Q.   I gotcha. The data -- that's where I thought we
      3    were.
      4               I know this was created, right, this was created
      5    after she died?
      6          A.   Uh-huh.
      7          Q.   And I'm still talking about your pulling the file
      8    folders when she went to the Cabana, that day. We're still
      9    on that.
      10              MR. LAURO: I think what she means, some of
      11   the information contained in that report had been
      12   assembled in some form prior to the --
      13         Q.   Prior, three weeks before or so?
      14         A.   Yeah.
      15              MR. LAURO: Just so the record is clear,
      16   we're talking about a report that's dated December 5, I
      17   believe, 1995, that I've handed to Mr. McGarry, which
      18   based on my discussions with Miss Mora I've concluded
      19   is not privileged in any way. And I believe that the
      20   Church concurs in that view; And without waiving any
      21   of their privileges, they've authorized me to turn that
      22   over to you this morning.
      23              MR. McGARRY: Okay. Any questions as to this
      24   specific document I'm sure are going to have to be
      25   handled by Wayne Andrews, who is now furiously reading


      1    over it. I haven't had that opportunity. But I'm sure
      2    he will ask specific questions about the content of
      3    this document.
      4    BY MR. McGARRY:
      5          Q.   But going back to, so we know where we are in the
      6    frame of time, when Lisa first gets placed in the Cabana,
      7    that's when you're first gathering your information --
      8          A.   Right.
      9          Q.   -- and gathering folders and files?
      10         A.   Right.
      11         Q.   So your testimony here today is that you got the
      12   ethics folder and the central file folder, and the purpose
      13   of those two folders, you gathering those, is for whose
      14   benefit, yours or somebody else's? Mr. Kartuzinski's?
      15         A.   Well, anyone who would -- who would need to have
      16   the information to help them -- to help them, you know, in
      17   various ways. Like, one, how could -- how could she have
      18   gotten to this condition, you know. Well, there -- there's
      19   something there to handle, obviously because --
      20         Q.   Right. You've got work to be done, no question
      21   about it.
      22         A.   Yeah. So you find out what -- what the errors
      23   were or what -- what went wrong with this girl that she got
      24   to that point.
      25         Q.   Yes.


      1          A.   So you gather the information with that purpose in
      2    mind.
      3          Q.   All right.
      4          A.   As well as to, you know, get a picture of what we
      5    have here and, you know, what to do to handle it.
      6          Q.   All right. And is the area of the PC folders --
      7    those folders contain auditing, correct?
      8          A.   Uh-huh.
      9          Q.   At a level of which you're not capable of reading,
      10   correct?
      11         A.   Right.
      12         Q.   Were those files gathered or pulled by any
      13   individual in your office?
      14         A.   No, not in my office.
      15         Q.   By anybody in any office?
      16         A.   Well, I'm sure in the -- the technical area that
      17   was pulled, yeah.
      18         Q.   Okay. And ultimately, that file would fall in the
      19   hands of, let me take a stab, Alain Kartuzinski?
      20         A.   Right.
      21         Q.   Okay. And so he had the benefit of those.
      22              Are you specifically aware of that or is that
      23   something you would say, well, that would be the normal
      24   course of business to take care of Lisa?
      25         A.   That would be the normal course.


      1               I'm -- since you asked, I've been trying to
      2    remember, you know, did -- did he actually that night get
      3    the folder and did he go through it and did he give me
      4    information that night from the folder. I mean, I -- I
      5    think he did, but it's like a long time ago, I don't --
      6          Q.   I understand. I won't hold you to it. I know
      7    it's been a couple of years.
      8          A.   Yeah.
      9          Q.   What else did you do that night when you got to
      10   the Church hotel? You're back to your office, I guess?
      11         A.   Actually, I didn't go back to my office first.
      12   First I -- I went to the hotel and went to the room where
      13   she was, where Lisa was taken. She had gotten there
      14   already. And Emma was there. And Lisa was pretty calm. I
      15   just saw her briefly. Emma was with her. And I left. Then
      16   I went to my office.
      17         Q.   All right. And that's when you gathered the two
      18   other folders?
      19         A.   Yeah.
      20         Q.   Okay. Did you have a conversation with anybody in
      21   your office about what the course of procedure was going to
      22   be with Lisa McPherson at that point?
      23         A.   I don't remember a specific -- a specific
      24   conversation, but it's the thing that we would do, yeah.
      25         Q.   All right. And what was your -- what was your


      1    next involvement with Lisa?
      2          A.   Well, our concern at that time was to -- you know,
      3    that she would sleep and she would rest and she would eat
      4    and she would calm -- calm down and, you know, come back to
      5    herself.
      6          Q.   Okay. That sounds like a good plan.
      7               Who was in charge of implementing that?
      8          A.   I don't remember exactly. I mean it's covered --
      9    as you know now, it's covered in -- in LRH written material
      10   on what to do with someone who's in that state.
      11         Q.   Right.
      12              Maybe you missed my question. She's there to --
      13   it's been testified before, it's no mystery to me, that she
      14   was there to be calmed down in order to get more auditing
      15   for what may be called an Introspection Rundown or further
      16   auditing to bring her back to normal. Were you aware of
      17   that?
      18         A.   Uh-huh.
      19         Q.   Okay. Who's in charge of that? Who's in charge
      20   of her being in the hospital -- being in the Cabana? Who's
      21   overseeing this thing?
      22         A.   Well, there's two -- there's two points of view or
      23   two concern terminals. One is Alain Kartuzinski, because he
      24   was at that time the Case Supervisor --
      25         Q.   Correct.


      1          A.   -- for her. And Security on the other hand,
      2    because here we have a person who is a security concern.
      3    You know, we don't know If she's going to hurt herself,
      4    break a window, alarm neighbors --
      5          Q.   I understand.
      6          A.   -- attract police. You know, this is a security
      7    concern. It's -- it was very unusual to have someone in her
      8    condition there.
      9          Q.   All right. For the implementation of the watch,
      10   Mr. Kartuzinski is in charge of that. And anything further
      11   that would happen after the watch was completed and she was
      12   calmed enough to receive training or auditing would have
      13   been Mr. Kartuzinski's concern?
      14         A.   Uh-huh.
      15         Q.   Correct?
      16         A.   Uh-huh.
      17         Q.   All right. Were you aware then that -- how were
      18   you involved in the implementation of the watch, if you were
      19   at all, of the people that took care of her around the clock
      20   and/or the Security? I guess they helped in reference to
      21   that as well. Were you involved in any of that?
      22         A.   No. The -- the closest I got to that was checking
      23   with Security and checking with Alain on occasion, like
      24   every couple days or so, to see how she was doing, was she
      25   getting better.


      1          Q.   Okay. You checked with Kartuzinski?
      2          A.   Uh-huh.
      3          Q.   On a pretty regular basis?
      4          A.   Yeah.
      5          Q.   Okay. And your reason for doing that is what?
      6          A.   Because from -- from our position in the
      7    Office of Special Affairs, we're concerned that, you know,
      8    the Church -- you know, we don't want the Church being in a
      9    position of where we might get in trouble for something.
      10         Q.   Right.
      11         A.   We don't want bad press, we don't want trouble.
      12         Q.   Obviously, things went bad?
      13         A.   Yes.
      14         Q.   Okay. So how did Mr. Kartuzinski keep track of
      15   this whole thing?
      16         A.   Well, the -- the gals who were taking care of her
      17   in the day would write reports at the end of their shifts,
      18   you may call, and those reports would normally go into the
      19   person's PC folder.
      20         Q.   All right. And who told those gals to do that?
      21         A.   I don't know.
      22         Q.   All right. Was it done, as far as you know?
      23         A.   I think so, yeah.
      24         Q.   Okay.
      25         A.   I don't know why it wouldn't be done.


      1          Q.   Not a trick question, I've got a bunch of reports.
      2               But as far as you know, Mr. Kartuzinski got those
      3    reports as well?
      4          A.   Yeah.
      5          Q.   Is that fair?
      6          A.   Yeah, uh-huh.
      7          Q.   And consequently, he would tell you how she was
      8    doing based on what he read from caretakers' reports?
      9          A.   Right.
      10         Q.   Okay. Can you -- do you know, you might not know
      11   the answer to this, but do you know how actually physically
      12   those reports would work their way up to Kartuzinski's
      13   office?
      14         A.   I don't know.
      15         Q.   Okay. You don't know if it was a runner or
      16   Security or hand delivered or none of that?
      17         A.   No, I don't.
      18         Q.   That was handled by Security or whatever other
      19   areas dealt with that aspect?
      20         A.   Yeah.
      21         Q.   Okay. Well, tell me what Mr. Kartuzinski was
      22   telling you in reference to Lisa McPherson's progress.
      23         A.   Our -- my conversations with him were always
      24   brief. I mean, I didn't need to know and wasn't even
      25   curious about the details of her psychotic behavior. I


      1    mean, if it was psychotic, it was psychotic. And I -- you
      2    know, I just -- I wanted to know if she was getting better,
      3    if she was calming down, if she was eating, sleeping, you
      4    know, is she getting to a point yet where she can have a
      5    conversation with somebody.
      6          Q.   And what would you do with the information?
      7          A.   Nothing.
      8          Q.   Okay. Would you pass the information on to
      9    anybody else in your office?
      10         A.   Probably. I don't remember exactly.
      11         Q.   All right. Brian Anderson's in charge of the
      12   whole place at that time, correct?
      13         A.   Yeah.
      14         Q.   And --
      15              MR. LAURO: The OSA?
      16              MR. McGARRY: The whole schmeer, right?
      17              MR. LAURO: The whole Flag operation?
      18              MR. McGARRY: Flag.
      19         A.   No, he's not in charge of that.
      20         Q.   Was?
      21         A.   No.
      22         Q.   Who was?
      23         A.   There's a whole structure above him.
      24         Q.   Who's that?
      25         A.   Well, there's -- you have -- I wish I had --


      1          Q.   We've got paper, we've got pens. We've done this
      2    before. Why don't you give her a piece of paper, here's a
      3    pen.
      4          A.   You have the Flag Service Organization, which is
      5    there to service parishioners and get them up the gradation
      6    chart or the bridge. Then you have Flag Crew, which is the
      7    organization that cares for the hotels and the restaurants
      8    and transportation of Staff and parishioners about the area.
      9               Then you have -- this is the Flag Land Base
      10   offices, which our office is one of these.
      11         Q.   All right. OSA.
      12         A.   You have also, you know, Senior Personnel Office
      13   that oversees personnel matters in both these organizations.
      14   Senior Qualifications Area that oversees technical matters
      15   in the FSO. You have World Institute of Scientology
      16   Enterprises, the WISE Office it's called, and they -- they
      17   have a membership for parishioners who are in business. And
      18   we're not too close to them, but they're -- they're a
      19   service for parishioners.
      20         Q.   Where was Mr. Kartuzinski's office at the time?
      21         A.   Here.
      22         Q.   Down there?
      23         A.   It's in -- it's in the same row of various other
      24   offices. He's not like senior to any of these.
      25         Q.   Right.


      1          A.   You know, he can -- he can issue orders into these
      2    organizations here, because he is senior to them.
      3          Q.   Okay.
      4          A.   And then there's -- to the side, but they don't
      5    really run us, they're just a higher up organization, is the
      6    Commodore's Messenger Org, Organization.
      7          Q.   Who runs that?
      8          A.   At the time it's a gal named Angie -- no. Yeah,
      9    Angie Quirino.
      10         Q.   Marcus Quirino's wife?
      11         A.   Yeah. She wasn't there at the time --
      12         Q.   Where is Marcus Quirino here?
      13         A.   Here's here. He's here in the FSO.
      14         Q.   All right.
      15         A.   And then there's also -- Security is in this same
      16   level, same level as us.
      17              And then you have a higher up organization, which
      18   they -- they're not based in Clearwater particularly, but
      19   they have representatives from Los Angeles in Clearwater.
      20         Q.   And that is?
      21         A.   This is the Religious Technology Center.
      22         Q.   RTC, we talked about that earlier today. Who's in
      23   charge of that?
      24         A.   Right now it's a gal named Sue Gentry. So she --
      25   she runs that.


      1               Now, this -- this organization doesn't have a
      2    purpose of running things, they're not a management body,
      3    but they're here to ensure that --
      4          Q.   Hubbard tech is followed?
      5          A.   Yeah, exactly.
      6               And Commodore's Message Organization also doesn't
      7    have a job of management, but they have programs from the
      8'   main office in Los Angeles that they execute in the
      9    organization.
      10         Q.   All right. Where is Ben Shaw in that now?
      11         A.   He's at the top of the Office of Special Affairs.
      12         Q.   He wasn't at the time?
      13         A.   No.
      14         Q.   Who was at the time?
      15         A.   Brian Anderson.
      16         Q.   All right. That's kind of my question.
      17              So he -- Brian Anderson's at the top of the
      18   management of the Flag organization here at the time' in '95?
      19         A.   He-- he was heading the
      20   Office of Special Affairs.
      21         Q.   Right. But there wasn't anybody -- not counting
      22   these people, there wasn't anybody here that could tell
      23   Brian Anderson what to do, correct?
      24         A.   Well, there is a Senior -- she's not like above
      25   him particularly, but she -- I'm not sure how --


      1          Q.   Cook?
      2          A.   No.
      3          Q.   Who's that?
      4               Where is she?
      5          A.   Cook is down here.
      6          Q.   All right.
      7          A.   Actually, this person doesn't -- doesn't really,
      8    run him. I mean, they're -- they're equal. They don't tell
      9    each other what to do.
      10         Q.   Who is that person?
      11         A.   This is -- this is Monica Quirino. But she was
      12   like nowhere on this cycle.
      13         Q.   Okay. All right. That's helpful. Thank you.
      14         A.   Okay.
      15         Q.   And the Fontanas, where are the Fontanas? Where
      16     are they in this thing?
      17         A.   They're here.
      18         Q.   They're in OSA also, right?
      19         A.   Yeah.
      20         Q.   All right. So how was Brian Anderson receiving
      21   his information on this cycle?
      22         A.   I don't remember. He may have gotten some from
      23   me, he may have kept himself informed by others.
      24         Q.   Would he have kept himself informed or would he
      25   have been isolated from this thing so as not to know too


      1    much in reference to his media releases on whatever
      2    happened?
      3          A.   I don't know.
      4          Q.   Okay. So you're --
      5          A.   I don't know.
      6          Q.   It's a touchy question, I know, but ...
      7          A.   I mean, I didn't, like, observe how he was doing
      8    his job at the time. I'm a junior person to him.
      9          Q.   Well, the reason why I ask that, because whenever
      10   a question is asked to the Church in reference to
      11   Lisa McPherson, he's the spokesperson, or he was at the time
      12   at least, he was until a little time ago.
      13         A.   Yeah.
      14         Q.   He was the guy that was providing the answers, was
      15   to be the spokesperson, that was his job.
      16         A.   From his position. That would have been his
      17   position, yeah.
      18         Q.   Any time there's cameras running, he's the guy?
      19         A.   Right.
      20         Q.   And he's saddled with the information, and
      21   whatever information is given to him is disseminated through
      22   the media?
      23         A.   Yeah.
      24         Q.   He was the Church spokesman at the time?
      25         A.   Yeah.


      1          Q.   I don't think he is anymore. He's got a new
      2    position now, correct?
      3          A.   He still is the Church spokesman.
      4          Q.   Is he?
      5          A.   Uh-huh.
      6          Q.   But his position somewhat changed here since this
      7    Lisa McPherson thing, correct?
      8          A.   Since that time, yeah.
      9          Q.   All right. Did you go down and see Lisa yourself
      10   in the Cabana?
      11         A.   I did.
      12         Q.   After the first day?
      13         A.   I did one time.
      14         Q.   You did?
      15         A.   After she was there about a week.
      16         Q.   All right. And explain that to me. How did that
      17   go? What caused you to do that?
      18         A.   I was -- I was in the area. I checked in with
      19   Security, the Security Chief was there and -- you know, to
      20   see how -- how Lisa was doing today, is she getting any
      21   better, is she sleeping at all. And he was at the time
      22   arranging for a change of -- of personnel to take care of
      23   her. So he was kind of in a hurry to get that done and I
      24   just walked with him back to the room. And he asked if I
      25   could stay in the room for a moment while he had one of the


      1    gals in there come out to turn the -- the shift over to this
      2    new gal.
      3          Q.   Right.
      4          A.   He says, can you just stay in the room for a
      5    minute? There was -- Valerie Demange stayed in there with
      6    me.
      7          Q.   Yes.
      8          A.   And I was just in there maybe five minutes or
      9    less.
      10              And at the time she was -- when I first walked in
      11   she was at the -- there's an adjoining door in the -- in the
      12   room. It was locked, but there was a door there just the
      13   same. And so she was licking the doorknob there. And once
      14   in a while she would take a break and talk to an imaginary
      15   person on the other side of door. So she did that for a
      16   while. And then she -- she was talking all the time. I
      17   couldn't even tell you what she said, just complete
      18   nonsense. She walked around the room, very agitated.
      19              She came close to me. She called me by another
      20   name of a gal that I kind of look like. And she sat down on
      21   the bed near me and she cried and she sang and she crossed
      22   her legs. And with her leg that was extended she was
      23   kicking, and she was close enough to the window where she
      24   was kicking the -- the big window near the door, the exit
      25   door. And that's about it.


      1          Q.   Okay. Did you write this up? Did you write a
      2    report about that?
      3          A.   (Witness shakes head negatively.)
      4          Q.   No? Somebody else probably would have had to
      5    anyway, one of the girls on watch?
      6          A.   I don't know. I don't -- it wasn't significant
      7    enough, it doesn't seem to me.
      8          Q.   Right.
      9               What -- what period were we in on this? Do you
      10   remember how far along we were?
      11         A.   I think she was there about a week.
      12         Q.   Okay.
      13         A.   Or under a week, I don't know.
      14         Q.   Was there somebody from the MLO Office that was in
      15   charge or saddled with extra, responsibilities in reference
      16   to Lisa McPherson that you're aware of?
      17         A.   I don't know. I mean, at the time -- at the time
      18   it was happening, I don't remember that specifically.
      19         Q.   All right.
      20         A.   Well, I know Judy Goldsberry-Weber's in that
      21   office. I know that Janice Johnson is. Laura Arrunada, I
      22   know that. Who else? Emma Schamehorn. Who am I missing?
      23   Suzanne Green Schnurremberger at the time. They were all in
      24   that office.
      25         Q.   Do you know if any of those people were seeing


      1    Lisa?
      2          A.   I know Suzanne was with her for a while,
      3    Suzanne Green. Laura. Emma was at the hospital and on the
      4    evening when she came to the Fort Harrison. At the
      5    hospital, Morton Plant, and then that evening at the
      6    Fort Harrison. But I don't know how -- how long she stayed
      7    with her, if she stayed the night there or what. Judy, I
      8    don't know.
      9          Q.   Well, let me ask you this: When you were at the
      10   Morton Plant Hospital, were you around when somebody had to
      11   actually sign Lisa out? Were you aware that
      12   Judy Goldsberry-Weber is the person that signed her name
      13   with --
      14              MR. McGARRY: What's his name, Logan?
      15              DETECTIVE SERGEANT ANDREWS: Lovett.
      16         Q.   -- Dr. Lovett?
      17         A.   Yeah. After that was done I heard about that.
      18         Q.   Okay. How did you hear about that?
      19         A.   From Judy.
      20         Q.   Okay. You had a conversation with Judy after
      21   that?
      22         A.   Yeah.
      23         Q.   How long after?
      24         A.   Just briefly. I mean, she -- Lisa McPherson,
      25   Jeanne Decuypere, Emma and Alain were walking out of the


      1    hospital, and Judy Goldsberry-Weber came out from the back
      2    and she said, I signed -- I signed for her.
      3          Q.   Signed her out?
      4          A.   I said okay.
      5          Q.   She basically put herself on the hook -- I
      6,   interviewed her so I know this. I'm telling you stuff that
      7    came from her -- she put herself on the hook with
      8    Dr. Lovett, saying she would be responsible for her care.
      9    Were you aware of that?
      10         A.   After, yeah.
      11         Q.   Don't get me wrong, Lisa signed the thing too.
      12         A.   Uh-huh.
      13         Q.   But Judy didn't get to participate in any of the
      14   care of Lisa McPherson for some reason. Are you aware of
      15   that?
      16         A.   I don't know. Not aware of that. I don't know
      17   why that would be, particularly.
      18         Q.   All right. Who calls the shots on that?
      19         A.   I don't know how -- I don't know who or how the
      20   people caring for her were picked, particularly.
      21         Q.   All right. Who would know that?
      22         A.   Security Chief maybe. I mean, he -- he wasn't
      23   really -- I don't know.
      24         Q.   Would Kartuzinski know some of that?
      25         A.   As far as why -- what the qualifications would be


      1    for a person?
      2          Q.   Yeah, who would be selected over who to be in
      3    charge of, from the Medical Liaison Office, in charge of the
      4    health and well-being of Lisa McPherson.
      5          A.   I don't know. I don't know that there was
      6    someone. I don't have any knowledge of someone from that
      7    office being in charge of her medically or overseeing that
      8    specific aspect.
      '9         Q.   I don't want to use the word "medical." I mean,
      10   that makes it sounds like -- well, I know all those people
      11   at one time or another had contact with Lisa, and my
      12   understanding is Janice Johnson was the point person from
      13   the MLO Office that was in charge of feeding her and giving
      14   her medicine or giving her -- she got a couple
      15   prescriptions. So you don't have any knowledge of that?
      16         A.   No.
      17         Q.   Okay. All right. After that first visit you had
      18   down the Cabana, what did you do next in reference to
      19   Lisa McPherson's stay at the Church's hotel?
      20         A.   That day I -- I saw her after she was there for a
      21   week?
      22         Q.   Yes.
      23         A.   I don't remember.
      24         Q.   You don't remember doing anything specifically?
      25   mean, did you do any other tasks that were asked of you in


      1    reference to her stay there?
      2          A.   I don't think so.
      3          Q.   Next thing you did probably was this summary here
      4    after she'd passed away, died?
      5          A.   Oh, like you're asking my next contact with the
      6    cycle?
      7          Q.   Yes.
      8          A.   There was one day after I saw her where I remember
      9    I asked the Security Chief how she was doing, and he -- he
      10   said she's -- she's actually calming down, sleeping and so
      11   forth. And I said, Really? I was like happy, you know,
      12   finally. I don't know how much longer she could last, you
      13   know, being that active without any sleep. So I was -- I
      14   was very happy to hear that she was calming down.
      15              I asked, What worked? What changed? What is she
      16   responding to? He says, Well, she was given some aspirin.
      17   Said, Okay. And then I took some -- some of my own concern
      18   off and my attention off of it at that point, knowing that
      19   she seemed to be now recovering.
      20              And then my next contact after that was when I
      21   was -- I was up in Alain's office when another gal came in
      22   and said, that she died.
      23         Q.   Who was the other gal that came in?
      24         A.   This is Kate Curley, is her name.
      25         Q.   What does she do with the Church?


      1          A.   She is the Qualifications Secretary in the
      2    Flag Service Organization.
      3          Q.   Okay. How did -- who did she get the information
      4    from, do you know?
      5          A.   I don't know. I think she got a call -- I'm not
      6    sure. I don't know how else she would have gotten it
      7    besides the phone call.
      8          Q.   Did you get that information before -- who was
      9    with you when you got that information?
      10         A.   Alain.
      11         Q.   Alain.
      12              Did Brian Anderson get that information after you
      13   did or before you did?
      14         A.   I don't know.
      15         Q.   All right.
      16         A.   Normally it would be like either right before or
      17   right after.
      18         Q.   Right.
      19         A.   I don't know who the person at the hospital chose
      20   to notify first.
      21         Q.   Right.
      22              The person from the hospital you're referring to
      23   is a Church member or a person that works at the hospital?
      24         A.   Janice Johnson.
      25         Q.   It would have been Janice that made the call?


      1          A.   Yeah.
      2          Q.   She called?
      3          A.   I think so.
      4          Q.   Okay. What did you do when you heard that
      5    information?
      6          A.   I asked who died. I was like, Who died? It's
      7    like, I've never heard someone walk into an office and talk
      8    about someone dying, you know what I mean. Like, Who died?
      9    Lisa I said, Lisa who? McPherson. Lisa McPherson, where?
      10   I mean, I had no knowledge that she was taken to the
      11   hospital, which was something that normally we would -- we
      12   in OSA would be notified of, 'cause it presents a possible
      13   situation that we would have to deal with, obviously. So
      14   I'm like, you know, Where?
      15         Q.   So now OSA had to investigate the scenario here,
      16   right?
      17         A.   Yeah.
      18         Q.   And who did that? Who led that charge from OSA?
      19         A.   Well, I -- I got whatever hysterical information
      20   was coming out of Kate's mouth. She was very, like, upset.
      21   And so I got whatever she knew.
      22         Q.   Right.
      23         A.   And either I said call OSA or something. And I'm
      24   sure she would -- I don't know what she would have said.
      25   I'm not going to guess. Anyway, I got whatever information


      1    she had, which wasn't much, and I went over to my office.
      2    And by the time I got there, there were several other people
      3    there who had gotten word of this.
      4          Q.   All right. And did -- was there, I don't want to
      5    use the word "investigation," but was there a fact gathering
      6    operation instilled then in OSA into finding out exactly
      7    what occurred? I say that because this looks like what this
      8    is.
      9          A.   Most -- okay.
      10         Q.   I mean, this is December 5th.
      11         A.   Most of that is files information.
      12              I mean, there wasn't like a meeting called with
      13   the purpose of doing some kind of organized or uniform data
      14   gathering type things. Just, you know, we really didn't
      15   know what to do. It's, like, not a usual situation at all.
      16   And a lot of people came into OSA to -- I don't know, maybe
      17   different people had different purposes; not really knowing
      18   what else to do, you know.
      19         Q.   Okay. Did -- who told you to do this?
      20         A.   I -- I don't recall that anybody did.
      21         Q.   You generated this on your own?
      22         A.   Somebody may have told me, I don't know. I don't
      23   remember specifically. But it is a normal thing that I
      24   would do. I mean, I wouldn't normally have to be told to
      25   write a report out for something like -- any -- if any


      1    situation occurs.
      2          Q.   Okay. Out of all of OSA, you're the only one that
      3    did one of these or were there more of these created from
      4    other people in OSA?
      5          A.   I think I'm the only one.
      6          Q.   Would you know that or are you --
      7          A.   Well, I don't remember seeing anything else, and
      8    it wouldn't be another person's job to do that.
      9          Q.   Okay. It would be your job?
      10         A.   Yeah.
      11         Q.   What's the purpose of doing this?
      12         A.   To inform those who need to know of what occurred
      13   so that a coordinated handling could be worked out and done.
      14         Q.   All right. And those people are who?
      15         A.   That would have been Brian Anderson, Judy Fontana,
      16   our -- our Senior office in Los Angeles, Counsel. I mean, I
      17   didn't write this for counsel particularly, there's a lot of
      18   stuff in there I wouldn't put in something just for counsel,
      19   but --
      20         Q.   Right.
      21         A.   -- knowing that the Legal Department would --
      22         Q.   There's some technical stuff in here?
      23         A.   Yeah, and they wouldn't know.
      24              Anyway, that's who it would be written for.
      25         Q.   All right. Who were the people that came from


      1    L.A. in reference to Lisa McPherson's case? I know a
      2    couple, but I'm 'missing some people, I'm sure. I'm talking
      3    about right after she died, who came from L.A. following
      4    December 5th? Steilo, I know, came later.
      5          A.   Yeah. Ben Shaw came later as well.
      6          Q.   Ben Shaw came later. But they sent some people, I
      7    think they sent some people over from L.A.
      8          A.   I don't remember that.
      9          Q.   You don't?
      10         A.   Unh-unh. It's not to say that nobody came.
      11         Q.   Lawyers maybe? Any lawyers? Elliott, did he show
      12   up?
      13         A.   Elliott has come, but I don't know that it was --
      14         Q.   Right after?
      15         A.   It wasn't right after, it was later.
      16         Q.   Okay. Anybody else from L.A. that you can recall
      17   that showed up there?
      18         A.   At that time, no.
      19         Q.   All right. This -- when did you --
      20              MR. McGARRY: Fellows, when did the
      21   Clearwater investigation begin? Right off the bat?
      22              DETECTIVE SERGEANT ANDREWS: Yeah, the night
      23   of the 5th and then into -- actually, the morning of
      24   the 6th, early morning of the 6th.
      25         Q.   So was there a -- did you gather any folders after


      1    she died? I guess to create this, correct?
      2          A.   Well, I already had the folders.
      3          Q.   You had them?
      4          A.   I had the CF and the ethics folder.
      5          Q.   Right. So this was solely created from those
      6    files?
      7          A.   No.
      8          Q.   You used other information that you had gained
      9    either from communication with all the parties involved --
      10         A.   Yeah.
      11         Q.   All right. Where did the PC folders go after she
      12   died?
      13         A.   Well, there was a time period I don't know where
      14   they were particularly, probably in the place where they
      15   belong on the -- on the base, and eventually they did come
      16   to my office and were packaged up and --
      17         Q.   And how many of them were there, do you remember?
      18         A.   Oh, I don't remember.
      19         Q.   More than one?
      20         A.   Yeah.
      21         Q.   Pile of them?
      22         A.   Yeah.
      23         Q.   Maybe seven?
      24         A.   I think more.
      25         Q.   More?


      1          A.   (The witness nods affirmatively.)
      2          Q.   Okay. And who ordered them from your office in
      3    OSA?
      4          A.   I don't remember if it was Judy or if it was
      5    Brian.
      6          Q.   All right. And what was the purpose of them being
      7    ordered to OSA?
      8               They're kept in a different place from your
      9    office, correct?
      10         A.   Normally, yeah.
      11         Q.   Right.
      12              Okay. So they ended up on your desk?
      13         A.   No, on the -- on the floor.
      14         Q.   Okay.
      15         A.   There's a space there.
      16         Q.   All right. But you saw all of Lisa McPherson's
      17   folders, PC folders on the floor there?
      18         A.   Uh-huh.
      19         Q.   And what period of time are we talking about here?
      20         A.   Some months later.
      21         Q.   Okay.
      22         A.   May. I think it was May that we shipped them and
      23   I know they didn't stay in my office very long at all.
      24         Q.   She died in December. So it would have been four
      25   months later they end up in OSA, correct?


      1          A.   Uh-huh. Uh-huh.
      2          Q.   Now, to the best of your knowledge, those PC
      3    folders also contained the daily reports from the caregivers
      4    that were looking after Lisa for a period of time at the
      5    Cabana, correct?
      6          A.   Well, I don't know. I didn't see them.
      7          Q.   All right. Where else --
      8          A.   It seems that that's where they should be, yeah.
      9          Q.   All right. So you're thinking that Brian or one
      10   of the Fontanas ordered those?
      11         A.   Yeah. Well, not -- not Humberto, it would have
      12   been Judy.
      13         Q.   Judy.
      14              All right. Why her?
      15         A.   She was the Legal Officer at that time.
      16         Q.   All right. And you said they were packaged up?
      17         A.   Uh-huh.
      18         Q.   And who did that?
      19         A.   Myself and, another gal that worked with me. She
      20    wasn't in the office at the time of the death, she was out
      21    on a medical leave.
      22         Q.   Just out of curiosity, how many people in your
      23    office are Clear?
      24         A.   Out of curiosity?
      25         Q.   Right.


      1               Well, you know why I bring that up?
      2          A.   No.
      3          Q.   I mean, 'cause you guys can't look in those
      4    folders, right?
      5          A.   Right. Right.
      6          Q.   That's kind of funny.
      7          A.   Well, we weren't looking in the folders.
      8          Q.   I know you weren't. But there wasn't anybody in
      9    your office that could.
      10         A.   No, there are people in my office that could.
      11         Q.   Who's that?
      12         A.   Brian.
      13         Q.   He's Clear?
      14         A.   Yeah.
      15         Q.   Okay.
      16         A.   Mary Story.
      17         Q.   Story?
      18         A.   Uh-huh.
      19         Q.   Okay.
      20         A.   Judy Mercy.
      21         Q.   All right.
      22         A.   Judy Fontana.
      23         Q.   Okay.
      24         A.   Humberto.
      25         Q.   All right. Did any of those people look in those


      1    files?
      2          A.   Not that I saw.
      3          Q.   Okay. Did Brian look in those files?
      4          A.   I didn't see anybody look in the files.
      5          Q.   All right. So you just packaged them all up?
      6          A.   Yes.
      7          Q.   And why were they packaged up?
      8          A.   I didn't ask.
      9          Q.   All right. You said they were being shipped
      10   somewhere?
      11         A.   Yeah.
      12         Q.   Where were they being shipped?
      13         A.   To the Office of Special Affairs International in
      14   Los Angeles.
      15         Q.   All right. And who requested that?
      16         A.   It was either -- I don't know who over there did,
      17   but I got it either from Brian or Judy that that needed to
      18   be done, and I didn't question it.
      19         Q.   Well, someone put a label on the thing,
      20   Office of Special Affairs in L.A., attention so and so?
      21         A.   Yeah. I think it was the post of the Data Chief.
      22         Q.   Who's that?
      23         A.   That's Kathy O'Goreman. Data Chief,
      24   OSA International.
      25         Q.   All right.


      1          A.   I don't know that she requested them specifically.
      2          Q.   All right. Is Ken Long's name familiar to you?
      3          A.   Uh-huh.
      4          Q.   Do you know who he is?
      5          A.   Uh-huh.
      6          Q.   Who is he?
      7          A.   He is -- I don't know his position now. He works
      8    in the Legal Department there in Los Angeles.
      9          Q.   All right. Do you know if he got those folders?
      10         A.   I don't know.
      11         Q.   All right. Carol Oakes, do you know who she is?
      12         A.   Yeah.
      13         Q.   Who is she?
      14         A.   She either works in the Legal Department or
      15   Data Department in OSA Int, International.
      16         Q.   So she's in L.A. also?
      17         A.   Yeah.
      18         Q.   Do you know if she looked at those files?
      19         A.   No idea.
      20         Q.   All right. And Becky Ellenberg, do you know who
      21   she is?
      22         A.   Yeah.
      23         Q.   Who's she?
      24         A.   I don't know her position, but she's another staff
      25   member there in Los Angeles.


      1          Q.   In L.A.?
      2          A.   Yeah.
      3          Q.   Do you know if she looked at those files?
      4          A.   I don't know. I have no idea what they did over
      5    there.
      6          Q.   Okay. Once the files went to L.A., as far as
      7    you're concerned they're gone, you don't know what --
      8          A.   Exactly.
      9          Q.   -- what happened to them?
      10         A.   Yeah.
      11         Q.   You had a conversation, you indicated earlier in
      12   our sit-down here, that you had with Glen Steilo; is that
      13   correct? Did you tell me you talked to him, Steilo, the
      14   fellow from L.A.?
      15         A.   I don't -- no, I don't think I said anything about
      16   Glen here today.
      17         Q.   Oh, you didn't talk to him?
      18         A.   What's your question exactly and I'll answer.
      19         Q.   Well, my question is, did you talk to him?
      20         A.   I have spoken with him. He works with me.
      21         Q.   Okay. And why did he come from L.A.?
      22         A.   He came at the same time Ben Shaw came, and this
      23   was at the time that the -- you know, where it was becoming
      24   a real situation for the Church. It had been quiet for a
      25   long time and then it looked like, you know, we were --


      1          Q.   Bubbling up again?
      2          A.   Yeah. So things were blowing up, and Glen Steilo
      3    and Ben Shaw came from OSA International to help -- to help
      4    us.
      5          Q.   Okay. With records and stuff?
      6          A.   Well, to help us handle the situation, whatever
      7    that would be, hire counsel.
      8          Q.   Okay. So they -- they're working with the lawyers
      9    as well as counsel?
      10         A.   Yeah.
      11         Q.   Okay. All right. The -- did you ever see those
      12   PC folders again after they went to L.A.?
      13         A.   Unh-unh.
      14         Q.   Never did?
      15         A.   Unh-unh.
      16         Q.   And when was that that they were packaged up,
      17   April or May?
      18         A.   I think so.
      19         Q.   Of '96?
      20         A.   Yeah. My months might be wrong, but that's what I
      21   think.
      22         Q.   That's fine. Believe me, I'm talking years apart
      23   from when my next reference is going to be with those
      24   records.
      25              When I subpoena something -- you obviously know


      1    that I've sent out dozens and dozens of subpoenas to the
      2    Church?
      3          A.   I don't know.
      4          Q.   You don't know that?
      5          A.   Unh-unh.
      6          Q.   Who knows that? Who knows that from your end of
      7    it, from the Church end of it?
      8.         A.   Well, I would think Glen, who is in our
      9    Legal Department, would know that.
      10         Q.   He's the one that ends up looking at them?
      11         A.   Yeah.
      12         Q.   Is he the one that's -- the way the subpoena
      13   thing's been working, I send the subpoena to the fellows,
      14   Sandy and Lee, the Church counsel.
      15         A.   Okay.
      16         Q.   And who is it they pick up the phone and say, hey,
      17   I got a subpoena, we got to get some records, who's that
      18   person? It's a real simple question. I'm having trouble
      19   with it. It's been bothering me for weeks.
      20         A.   Really?
      21         Q.   Yeah.
      22         A.   Who in the Church would they call?
      23         Q.   Yeah, who would they call?
      24         A.   It, would be Ben Shaw or Glen.
      25         Q.   One of those two?


      1          A.   Yeah.
      2          Q.   And then they might delegate some responsibilities
      3    to various people to accomplish tasks in reference to
      4    record keeping?
      5          A.   Uh-huh.
      6          Q.   All right. So right now, as far as you know,
      7    when -- I don't want to know any privileged communications,
      8    but I'm asking, they're the person -- first person they
      9    contact in your office is Ben Shaw?
      10         A.   Right, or Glen.
      11         Q.   Or Glen?
      12         A.   Yeah.
      13         Q.   One of those two?
      14         A.   Yeah.
      15         Q.   Would it have ever been Brian Anderson before
      16   Ben Shaw?
      17         A.   On -- on the Lisa McPherson cycle?
      18         Q.   Yes.
      19         A.   Well, before -- before Ben and Glen came, we -- it
      20   was quiet, like I say, and the attorney that we had at the
      21   time was Bob Johnson.
      22         Q.   Right.
      23              Well, when did they come? When did Shaw and
      24   Steilo show up?
      25         A.   I think it was December or -- I remember they were


      1    here for Christmas dinner.
      2          Q.   All right. So you've never seen those PC folders
      3    again? To the best of your knowledge they're still in L.A.?
      4          A.   Yeah.
      5          Q.   Don't know?
      6          A.   I don't know where they would have been sent from
      7    there, if anywhere.
      8          Q.   All right.
      9          A.   Not -- not back in my office.
      10         Q.   Okay. Now, the reason why I asked all those
      11   questions is because, see all these documents that I got
      12   from the lawyers in reference to those subpoenas that I was
      13   talking about? And they made the Internet, they're all over
      14   the  place. But these are the caretakers' notes, the whole
      15   bunch of them. There's no trick here. This is what I got
      16   from the lawyers in reference to the daily reports that were
      17   being written by all those people that were looking after
      18   Lisa.
      19         A.   Uh-huh.
      20         Q.   Do you know how and who assembled those reports?
      21         A.   (Witness shakes head negatively.)
      22         Q.   Who knows the answer to that?
      23         A.   I don't know. Our attorneys? I don't know.
      24         Q.   Not from these guys, no. Before they went to the
      25   lawyers, who did that?


      1          A.   I would think those would have been gotten from
      2    the PC folders.
      3          Q.   Okay.
      4          A.   I'm like -- I'm just relaying how -- where things
      5    would normally be. Those would normally be in the PC
      6    folders which had already been sent to Los Angeles. So I
      7    would assume someone in Los Angeles pulled those, Xeroxed
      8    them and sent them, just to assume.
      9          Q.   Okay. All right. If you don't know, who does
      10   know? Who knows the answer to that question?
      11              MR. LAURO: I think the question is, do you
      12   know who participated in document assembly?
      13              THE WITNESS: In Los Angeles?
      14              MR. McGARRY: Anywhere.
      15              MR. LAURO: Either in Los Angeles after the
      16   case arose or in response to the subpoenas that have
      17   been issued, do you know who participated in obtaining
      18   documents from Church locations or Church offices?
      19         A.   Well, those of us in OSA here would have gathered
      20   what we had here. And in Los Angeles, I haven't been in
      21   touch with them, but how it would work normally in dealing
      22   with the legal situation, it would be the legal staff.
      23         Q.   Okay. Well, this is kind of a funny document
      24   because -- that's why I covered that business about people
      25   being Clear and not Clear in your office.


      1               Can somebody gather that document without knowing
      2    or reading it or looking at it out of the PC folder? They
      3    can't really in your office unless it's one of the Clear
      4    people, right?
      5          A.   Right.
      6          Q.   All right.
      7          A.   Now, there is -- there is information in PC
      8    folders that is not Clear information.
      9          Q.   Well, that's a good question too.
      10              Now, would this qualify as information that could
      11   not be gazed upon by someone that was not Clear, these
      12   caretaker notes?
      13         A.   No, not at all.
      14         Q.   So the answer is?
      15         A.   It's totally safe to look at those.
      16         Q.   Okay. That's my question. That's not -- so that
      17   really wouldn't qualify as something like auditing, correct,
      18   which would be the area that's protected?
      19         A.   Right.
      20         Q.   Okay. So this -- these things in the PC folders,
      21   although it's not technically auditing, these are
      22   observations made by caretakers looking after Lisa, correct?
      23         A.   It's a typical kind of --
      24         Q.   Knowledge Report?
      25         A.   There are other kinds of reports that would end up


      1    in a person's PC folders. Anything that would help them
      2    spiritually. Some -- sometimes you find Knowledge Reports
      3    in PC folders.
      4          Q.  Right. Right.
      5              Okay. Now, back to the assembly of these reports.
      6    Who is it that I can -- that I can talk to that will tell me
      7    that they have knowledge of themselves or somebody else
      8    gathering those reports I just showed you and handing those
      9    over to lawyers? Who is that person?
      10         A.   I would be inclined to direct you to one of the
      11   attorneys in the -- that the Office of Special Affairs
      12   International has. They have in-house attorneys there.
      13         Q.   So the answer to that question is all the way out
      14   in L.A. --
      15         A.   Yeah.
      16         Q.   -- responsibility?
      17         A.   I don't know of any of us who would know what --
      18   who did what there in Los Angeles.
      19         Q.   Well, they sent them, I assume, through your
      20   office here and then they got handed over to the lawyers and
      21   counsel for the Church, correct?
      22         A.   I assume. I don't know. I didn't see these
      23   things come in the mail or however they came and who they
      24   went to.
      25         Q.   All right. One more question: Who is the person


      1    that knows the answer to that?
      2          A.   I would say either Ben Shaw or Glen Steilo.
      3          Q.   Steilo doesn't know.
      4          A.   Okay.
      5          Q.   Brian Anderson doesn't know.
      6          A.   And did you ask the attorney who gave them to you,
      7    who turned them over?
      8          Q.   Well, he's not -- I can't subpoena them, talk to
      9    them, I got to go through you people.
      10         A.   I don't' know how -- I don't know who they got them
      11   from.
      12         Q.   Okay. So I'm not going to get that answer today,
      13   right? You don't know the answer?
      14         A.   Not from me.
      15         Q.   Obviously, you don't have any knowledge of that?
      16         A.   Unh-unh.
      17         Q.   Okay. Move on to something else.
      18              Were you aware of any Committee of Evidence
      19   hearings being convened on anybody?
      20         A.   (Witness shakes head negatively.)
      21         Q.   In reference to Lisa McPherson. I don't want to
      22   just leave that open end.
      23              I know a Committee of Evidence happens all the
      24   time on people, right?
      25         A.   Yeah.


      1          Q.   On various people, if they commit an infraction or
      2    don't follow the rules, correct?
      3          A.   Sometimes.
      4          Q.   Were any of them done on anybody that was remotely
      5    corrected to Lisa McPherson?
      6          A.   (Witness shakes head negatively.)
      7          Q.   How about Brian Anderson?
      8          A.   No.
      9          Q.   He didn't have --
      10         A.   He did have one of these things later on, but it
      11   wasn't because of this cycle.
      12         Q.   Something else that got messed up?
      13         A.   Yeah.
      14         Q.   Okay. How about Alain Kartuzinski?
      15         A.   I never saw any -- any such thing on -- on anyone
      16   in relation to this.
      17         Q.   Okay. So any other names I mention, it still
      18   doesn't matter --
      19         A.   No.
      20         Q.   -- the answer is none of them?
      21         A.   Yep.
      22         Q.   How about Sec Check, who has the records of a
      23   Sec Check being done on somebody? If I wanted to find out
      24   if you ever had a Sec Check that had been done on you, would
      25   there be a record of that?


      1          A.   That's something that would be in a PC folder.
      2          Q.   Your PC folder or somebody's PC folder?
      3          A.   Mine.
      4          Q.   Can you look in your PC folder?
      5          A.   Yes.
      6          Q.   Do you? Did you ever look at your PC folder?
      7          A.   No.
      8.         Q.   On the higher level they can --
      9          A.   I'm not sure. They can put things in their PC
      10   folder on the higher levels.
      11         Q.   If you wanted to go put something in your PC
      12   folders, you --
      13         A.   Yes, I can.
      14         Q.   There is some security in reference to PC folders.
      15   They aren't floating around. I can't say I'm going to go to
      16   the warehouse and get all the PC folders. Nobody can just
      17   walk in there and say, I'm going to look around, right?
      18         A.   Not just anybody, people who --
      19         Q.   Higher up people?
      20         A.   People who have the job of dealing with those can,
      21   yeah.
      22         Q.   Recordkeeping.
      23              How could you keep people -- how does the Church
      24   keep people from seeing their own PC folders? Does anybody
      25   ever want to see their own PC folder?


      1          A.   I don't think so. I've not heard of that.
      2          Q.   No? Aren't you curious about wanting to see
      3    what's in your PC folder?,
      4          A.   No. I've said everything that's in my PC folder.
      5          Q.   Other things end up in there. Now, for example,
      6    the  question about Sec Check, if somebody did a Sec Check,
      7    that would go in your PC folder and you wouldn't be able to
      8    see that, right?
      9          A.   Right.
      10         Q.   How do I find out if a Sec Check was run on
      11   Lisa McPherson?
      12         A.   I would say you'd have to find out from the PC
      13   folder.
      14         Q.   So I would style a subpoena that says, Please
      15   provide me any information in reference to a Security Check
      16   on Lisa McPherson?
      17         A.   I guess.
      18         Q.   Possibly look in the PC folder?
      19         A.   I guess you could do that.
      20         Q.   Do you know of one being run on her?
      21         A.   Unh-unh.
      22         Q.   Do you know of one being run on anybody in
      23   reference to the Lisa McPherson situation?
      24         A.   (Witness shakes head negatively.)
      25              It's not to say they were never done, it's just


      1    not something I would have anything to do with if they were
      2    done.
      3          Q.   Okay. What's your -- how does it work in your
      4    office with records? I mean, are any records -- what
      5    records can be destroyed and what records are kept? Do
      6    y'all have a way of purging files of needless information in
      7    order to, say, conserve space or something like that? Or
      8    what records can be destroyed or shredded and what should
      9    never be? There's a Hubbard tech on this, I'm sure'.
      10         A.   I don't remember seeing anything that says what
      11   you can and can't get rid of. I mean, there -- there are
      12   files we can keep what we want or shred what we want. That
      13   there isn't like any set thing that says never get rid of
      14   blah.
      15         Q.   All right. Did you ever destroy any records in
      16   reference to Lisa McPherson's case?
      17         A.   I do remember two times.
      18         Q.   Okay.
      19         A.   One is when she -- I think I have my times
      20   straight on this -- when she went to Morton Plant Hospital
      21   and, you know, there was this concern how did she get to be
      22   so stressed like that that she would snap. There was a
      23   Cram, what we call a Cram -- which is the same word "cram"
      24   that you would know, where somebody is, you know, studying
      25   up on something very rapidly to be able to know about it.


      1          Q.   Right.
      2          A.   And there was this Cram, which is just a written
      3    instruction to, in this case, to those who had audited her
      4    before -- I don't know who else, I think just the people who
      5    audited her in the past. And would have been done after
      6    review, technical review of her past auditing was done to
      7    see what might have been done, you know, not quite right or
      8    some step of some --
      9          Q.   FES'd, is that what that's called?
      10         A.   That's -- that's one type of review that can be
      11   done, yeah. I don't know -- I don't know specifically if
      12   that was done with her folder or not. I would think so in
      13   her case.
      14              But anyway, a review is done to find these things
      15   that weren't done correctly or should have been done
      16   differently. And then an instruct is written up for those
      17   people who were involved in that part of it, to train up on
      18   and get corrected on, and get, you know, restudied up on so
      19   that they have it right.
      20         Q.   And this answer was going to go to the destruction
      21   of evidence?
      22         A.   Yeah.
      23              So I remember this --
      24              MR. LAURO: I don't know if it's destruction
      25   of evidence, but it's --


      1               MR. McGARRY: Destruction of, documents.
      2          A.   I remember seeing this -- this piece of paper.
      3          Q.   Right.
      4          A.   I didn't particularly read it, because it's not
      5    something I would understand, not being an Auditor myself.
      6          Q.   Right.
      7          A.   And I remember seeing this and having to go around
      8    and collect it up from the people that were cc'd on it, like
      9    the Auditors.
      10         Q.   And you said there was another occasion?
      11              MR. LAURO: Well, just one point: This is
      12   before she died you believe that this was shredded?
      13              THE WITNESS: Yeah. Yeah.
      14         Q.   During the period she was at the Cabana?
      15         A.   Yeah.
      16         Q.   All right.
      17         A.   And in relation to her earlier auditing, before
      18   she went nuts.
      19         Q.   Okay.
      20         A.   And, oh, another time, these are actually things
      21   that you  have already, I found in my -- in a filing cabinet
      22   that I have, I found debriefs of the people that were
      23   interviewed by the police.
      24         Q.   Marcus Quirino?
      25         A.   No...


      1          Q.   Debriefs of people that were interviewed, by the
      2    police?
      3          A.   The initial interviews that were done on
      4    Paul Greenwood, Janice Johnson.
      5          Q.   Oh, yeah. They came back to the Church and did a
      6    summary of what the police asked them?
      7          A.   Yeah, and what their answers were, this is what
      8    happened in my interview. So I had those in my cabinet, but
      9    I think you have those already. Anyway, when I found --
      10         Q.   I don't think so.
      11         A.   Okay. I don't know.
      12         Q.   All right.
      13         A.   I was told that -- that there were copies of those
      14   already.
      15         Q.   I'm aware of what those were, yeah.
      16         A.   So I shredded those.
      17         Q.   All right.
      18              MR. LAURO: So you shredded either copies or
      19   an original, but you believe that there are other
      20   copies still in existence?
      21              THE WITNESS: Yes.
      22              MR. LAURO: Okay.
      23         Q.   Are you aware of anybody else in OSA that shredded
      24    documents in reference to Lisa Mcpherson's case?
      25         A.   I don't know of it, no.


      1          Q.   Okay. Nobody else did?
      2          A.   Not that I know of, no.
      3          Q.   Is there such -- is there such a thing as an
      4    Internal Investigation?
      5          A.   We don't have anything that's called that, no.
      6          Q.   What would that be called, Committee of Evidence?
      7               No?
      8          A.   No.
      9               Like for what?
      10         Q.   What if your department, OSA, wanted to find out
      11   what the heck's going on, something -- there's some bad
      12   things going on, how -- what's that called?
      13         A.   I guess an investigation.
      14         Q.   Right.
      15              Was that -- was that ever done in this case?
      16         A.   Outside of what I've told you, no.
      17         Q.   Right.
      18              I mean, how about this --
      19         A.   Like when she died?
      20         Q.   How about these folks here --
      21         A.   I don't know what they did.
      22         Q.   -- RTC?
      23         A.   I don't know what they did, if they did any -- if
      24   they did any kind of investigation.
      25         Q.   Would that be within the boundaries of their


      1    responsibility, to do an Internal Investigation as to
      2    went wrong here? Would they do that?
      3          A.   Well, I've -- I've seen them ask questions on
      4    various matters, but I -- I don't know what they do with the
      5    information. Or if they have an organized way of putting it
      6    all together and coming up with a report, I don't know. I
      7    haven't -- they don't, like, give me reports of what they
      8    do.
      9               MR. McGARRY: Of f the record.
      10                     (Off the record.)
      11                 (Luncheon recess is held.)
      13                    AFTERNOON SESSION
      14              MR. McGARRY: Okay. We'll pick up where we
      15   left off.
      16              I only have a few more questions and they're
      17   mostly about this document I've been provided and then
      18   the Detectives  might have a couple of questions for
      19   you.
      20   BY MR. McGARRY:
      21         Q.   This document, you say, was -- you created this
      22   document, right, you typed this?
      23         A.   Uh-huh.
      24         Q.   Okay. Was this on a computer or typewriter, or do
      25   you remember?


      1          A.   It looks like on a computer. I mean, the type --
      2    the type just looks like -- it doesn't look quite like the
      3    typewriter we have.
      4          Q.   All right. So that would have been done by you,
      5    though, right?
      6          A.   Uh-huh.
      7          Q.   You're the person that typed this?
      8          A.   Uh-huh.
      9          Q.   Okay. I see it says 5 December, '95 up here.
      10              Now, does that mean -- what does that mean, that's
      11   the day that this was typed?
      12         A.   Uh-huh.
      13         Q.   It does?
      14         A.   Uh-huh.
      15         Q.   Okay.
      16              MR. LAURO: Annie, you just need to answer
      17   orally.
      18         Q.   You've got to say yes or no, just so it doesn't
      19   read either way on the transcript.
      20         A.   Okay.
      21         Q.   So this means this was created on December 5th,
      22   correct?
      23         A.   Yeah.
      24         Q.   I notice that the only way to tell that the author
      25   of this is by somebody that knows who is that. Is that you?


      1          A.   That's me.
      2          Q.   Why does that say, Prediction I/C?
      3          A.   That's a post title. That's my post title.
      4          Q.   So is it --
      5          A.   I/C is "in charge."
      6          Q.   Prediction is your post title?
      7          A.   Yeah.
      8          Q.   All right. Let me break this thing down.
      9               The first couple paragraphs here are dealing with
      10   the actual -- well, the first paragraph deals with kind of a
      11   brief summary what she was doing at the Church, correct,
      12   where she was staying, what room?
      13         A.   Yep.
      14         Q.   She had attendants with her, and you told us what
      15   the purpose of those attendants are, right, to ensure her
      16   safety and keep her, from hurting herself, et cetera, and
      17   assisting her coming out of the psychotic break?
      18         A.   Yeah.
      19         Q.   Now, this paragraph here deals with -- that goes
      20   to present day, correct? I mean, when you read this
      21   paragraph, that deals with December 5th, correct?
      22         A.   Right.
      23         Q.   Okay. So this information you gained that night,
      24   correct?
      25         A.   I must have, yeah.


      1          Q.   Well, to type it on December 5th --
      2          A.   Exactly.
      3          Q.   -- you would have had to have gotten this that
      4    night?
      5          A.   Exactly.
      6          Q.   And that information included, I would assume, an
      7    interview of Janice Johnson to gain this information. Is
      8    that accurate?
      9          A.   Yeah.
      10         Q.   So you see --
      11         A.   I mean, I don't know what you call an interview.
      12         Q.   A Com cycle, how about that?
      13         A.   Fine.
      14         Q.   Better? I mean, is that --
      15         A.   Well, if I can explain.
      16         Q.   Okay.
      17         A.   How she came to be in the conversation with others
      18   on the subject is, that night when -- I explained that there
      19   were a lot of people, like when the news got out that she
      20   had  died --
      21         Q.   Right.
      22         A.   -- people concerned, executives and so forth came
      23   to OSA. And Janice, when she left the hospital, she also
      24   came to OSA., And, you know, she talked to everybody that
      25   was there. It wasn't a --


      1          Q.   Right.
      2          A.   That's how we got information.
      3          Q.   Including Quirino, right?
      4          A.   Yeah, he was there.
      5          Q.   All right. And he specifically talked to her,
      6    correct, or do you remember?
      7          A.   I don't remember. I mean, I don't remember who
      8    was --
      9          Q.   Do you remember whether or not it was a time that
      10   Quirino was asking people to write down what happened?
      11         A.   No.
      12         Q.   That didn't happen in OSA?
      13         A.   No.
      14         Q.   Well, your conversation had to deal with what
      15   Janice Johnson's observations were in reference to bruises
      16   on Lisa McPherson's body, correct? That's what you put down
      17   here?
      18         A.   Uh-huh.
      19              MR. LAURO: You know what, it may be easier
      20   if there's a copy in front of her.
      21              DETECTIVE SERGEANT.ANDREWS: Yeah, I'm sorry.
      22         Q.   Yeah, that is better.
      23              So you see what I'm saying, you had a conversation
      24   with her, and she apparently told you that she had noticed
      25   bruises on her body that were not healing as bruises


      1    normally, and that she recognized that as a sign of a more
      2    severe infection.
      3          A.   Right.
      4          Q.   She told you that, the bruises represented that to
      5    her?
      6          A.   She told the whole office that, yeah.
      7          Q.   And that was at what time on -- let's see what
      8    night that was.
      9               SPECIAL AGENT STROPE: December 5th.
      10              MR. McGARRY: What night of the week?
      11              DETECTIVE SERGEANT ANDREWS: Tuesday night, I
      12   think.
      13              MR. McGARRY: I think it was a Tuesday night.
      14   I knew Wayne would know that.
      15              Tuesday night. She died what time, fellows?
      16              DETECTIVE SERGEANT ANDREWS: 9:30 p.m.
      17              SPECIAL AGENT STROPE: Pronounced dead.
      18              DETECTIVE SERGEANT ANDREWS: Or pronounced
      19   dead at 9:30 p.m.
      20              MR. McGARRY: So Janice had to drive back
      21   from New Port Richey -- did she stay there the whole
      22   time, or do we know that?
      23              SPECIAL AGENT STROPE: She stayed there about
      24   35 minutes.
      25              MR. McGARRY: Then she could have gotten back


      1    earlier, but then she wouldn't know if she was dead.
      2    BY MR. McGARRY:
      3          Q.   You talked to Janice that night?
      4          A.   (The witness nods affirmatively.)
      5          Q.   Was that a yes?
      6          A.   Yes.
      7          Q.   Do you know what time?
      8               MR. LAURO: Is it possible you could have
      9    spoken to her at 12:30 on this evening and still dated
      10   this December 5th?
      11              THE WITNESS: Yes.
      12         Q.   I'm not trying to trick you. As far as midnight,
      13   when I say that night, if it spills over it would be
      14   December 6th.
      15         A.   Okay.
      16         Q.   Your answer is, it could have been after midnight?
      17         A.   It could have been.
      18         Q.   Okay. Then that's when you got the information
      19   that Janice had called Dr. Minkoff in seeking his advice on,
      20   what to do with her; is that correct? She relayed that to
      21   you then?
      22         A.   Yes.
      23         Q.   Where did you get the next line down, Alain
      24    explained to Dr. Minkoff the concern he had about this, that
      25    he did not want to end up in psych hands? Now, where did


      1    you get that information? That's apparently in reference to
      2    a conversation that Kartuzinski had with Minkoff. Now, were
      3    you standing there when that occurred?
      4          A.   You know what, this, looks like -- oh, I don't
      5    know. Sorry. What's your question on it?
      6          Q.   Question is, Kartuzinski is represented in your
      7    paragraph here, in your summary, as to having a conversation
      8    with Minkoff, 'cause it says here, "Alain explained to
      9    Minkoff," well, the only way he could do that, is by
      10   telephone, I assume, right?
      11         A.   I assume.
      12         Q.   Right.
      13              So were you either standing there privy to that
      14   conversation and/or you had a conversation with
      15   Mr. Kartuzinski in which he told you that?,
      16         A.   I don't remember at all.
      17         Q.   Okay.
      18              MR. LAURO: But you didn't speak to Alain
      19   before Lisa was taken to the hospital, this is all
      20   after her death?
      21              THE WITNESS: Yeah. In fact, I wonder if
      22   this is some leftover sentence from an earlier report I
      23   did. I don't know. It seems kind of weird, that
      24   sentence.
      25         Q.   Well --


      1          A.   I mean--
      2          Q.   Is there another report like this one out there
      3    somewhere that was done prior to this one?
      4          A.   Well, I would have -- not that I have or know of
      5    right now but I would have done a report when she went to
      6    Morton Plant Hospital and was nuts.
      7          Q.   Well, that would only have been six hours before
      8    this one or eight hours?
      9               DETECTIVE SERGEANT ANDREWS: No,
      10   Morton Plant.
      11         Q.   Excuse me, Morton Plant. I got what you're
      12   saying.
      13         A.   And I know a lot of information is carried forward
      14   from that data collection that was done. And this -- this
      15   is probably a sentence --
      16         Q.   Should I be looking for that report too? Is that
      17   one out there? That might be helpful towards my
      18   investigation.
      19         A.   I know we don't have that one. I mean, you can
      20   look, but --
      21         Q.   How is it you know you don't have that one?
      22         A.   Well, we looked -- we gathered -- we looked
      23   everywhere and gathered everything having to do with this.
      24         Q.   That falls under the missing records area that
      25   we're looking at here --


      1               MR. LAURO: Is it possible you had a previous
      2    report that was incorporated -- that information was
      3    incorporated into this report?
      4               THE WITNESS: Yeah, that's what I'm saying.
      5          Q.   All right.
      6          A.   That's what -- and it looks like that sentence
      7    about Alain having a conversation with Dr. Minkoff, it's not
      8    likely that he would have that conversation with Dr. Minkoff
      9    the night that she died. So it looks like it's a sentence
      10   carried over from this earlier report.
      11         Q.   Right.
      12              That's -- that's my question here. It's kind of
      13   stuck in the middle there.
      14         A.   Yeah, exactly.
      15         Q.   And you typed that, right?
      16         A.   Uh-huh.
      17         Q.   You see what I'm saying? If you continue on the
      18   next paragraph -- -
      19         A.   It's carrying on from the first sentence.
      20         Q.   Right. Minkoff, that's misspelled, then said that
      21   Lisa should be taken to his hospital in New Port Richey, at
      22   which time she was immediately taken.
      23         A.   Yeah.
      24         Q.   So you don't know where this information came
      25   from?


      1          A.   I don't remember.
      2          Q.   Did you ever have a conversation with Dr. Minkoff?
      3          A.   No. I mean, I've spoken with him, but up to that
      4    point, no, never -- never talked to him.
      5          Q.   All right. On the way to the hospital she got
      6    worse and she died in the hospital. Where did that
      7    information come from?
      8          A.   Janice. That's what Janice thought. That was
      9    her -- at that time that was her perception of what
      10   occurred.
      11         Q.   Okay. And that information would have been
      12   obtained December 5th in the evening or the early morning
      13   hours of December 6th?
      14         A.   Yeah.
      15         Q.   Did you have a conversation with Laura or
      16   Paul Greenwood in reference to that van ride?
      17         A.   No.
      18         Q.   All right.
      19         A.   Unless I -- I mean, they may have been there that
      20   night, you know, also when there were a lot of people there.
      21   I don't remember Paul and Laura specifically. I do remember
      22   Janice.
      23         Q.   Well, wasn't Alain Kartuzinski there, up at OSA?
      24         A.   Yeah.
      25         Q.   He was?


      1          A.   Uh-huh.
      2               MR. LAURO: Is it possible you talked to
      3    Alain that night and somehow that got into this report?
      4               THE WITNESS: Maybe.
      5          Q.   All right.
      6          A.   I just don't remember that specifically, that
      7    information specifically.
      8          Q.   All right.
      9          A.   I mean, there were like a lot of people talking, a
      10   lot of people just throwing, you know, what happened around,
      11   a lot of upset, a lot of -- you know, the tension was high,
      12   and I don't remember who exactly said what.
      13         Q.   Okay. Have you ever heard that -- or have you
      14   ever represented to anybody, including lawyers, that this
      15   document was created for the lawyers in L.A., this document?
      16         A.   No.
      17         Q.   Okay. So --
      18         A.   I mean; it could go to them.
      19         Q.   Well, I don't have a problem with that, but I
      20   mean, was that -- is there somehow that that information --
      21   see, that information came to me somehow, that this document
      22   was created for the L.A. lawyers. Is that why you created
      23   this document? You said earlier that it was created just in
      24   the normal course of your business, right?
      25         A.   That's -- that's correct, normal course of my --


      1          Q.   So you were not directed by any one particular
      2    lawyer either here or out in L.A. to do this?
      3          A.   No.
      4          Q.   This was not for them?
      5          A.   No.
      6               MR. LAURO: I think the confusion earlier
      7    was, it would find its way to the Legal Department in
      8    L.A., but after I interviewed her it became clear it
      9    wasn't a privileged document.
      10              MR. McGARRY: Right. And I appreciate your
      11   candor in making that assessment.
      12         Q.   The background that you put in this document seems
      13   to deal with a lot of very complicated PC file stuff that I
      14   was under the impression you weren't allowed to read.
      15         A.   Yeah, I didn't read it. I mean, what's written
      16   here is not confidential. I mean, it would be because it's
      17   personal to her, but there isn't anything written here
      18   that's -- that anybody can't read. Anybody can read this
      19   and not get into any --
      20         Q.   Oh, I see.
      21         A.   -- trouble or you're not violating any policy by
      22   writing this or reading ...
      23         Q.   Where does this stuff come from if it doesn't come
      24   from the PC file?
      25              MR. LAURO: It may come from the PC file.


      1          A.   It does come from the PC file.
      2          Q.   How do you make --
      3          A.   somebody else -- somebody else went through the PC
      4    file and either wrote or told me, I don't remember which,
      5    that this is the information.
      6          Q.   That answers my question. You're not the one
      7    picking and choosing, 'cause you can't really do that,
      8    'cause you can read this, but you just have to make sure it
      9    wasn't this, right?
      10         A.   Right.
      11              MR. LAURO: No, but what she can do is call
      12   Alain, for example, and say, What's in the PC file with
      13   respect to X, Y and Z.
      14         A.   And I already know he's not going to tell me
      15   things he's not supposed to tell me.
      16         Q.   But my question is, why in the world would
      17   somebody that doesn't have clearance to do this? This seems
      18   like really putting the cart before the horse. Why would
      19   you do this? Wouldn't it be easier for somebody that was
      20   clear to just do this?
      21              You understand what I'm saying?
      22         A.   Uh-huh.
      23         Q.   You've got a middleman in here --
      24         A.   Yeah.
      25         Q.   -- for this information.


      1          A.   Yeah.
      2               And that's standard protocol?
      3          A.   Well, we don't, like, go find a middleman.
      4    Doing -- doing a report like this is my job. And so I get
      5    the information, I put it all, in one report, I write it.
      6          Q.   But you had to have gained this information for
      7    other reports from a middleman?
      8          A.   From other people and other -- there's all kinds
      9    of sources for the information. One's the PC folder, one's
      10   the ethics file, some I got from people.
      11         Q.   I'm just talking about the PC sources.
      12         A.   Okay.
      13         Q.   That PC information had to come from someone else,
      14   written, handwritten summary, correct, or oral communication
      15   with you deciphering out the prohibited areas that you can't
      16   look at, correct?
      17         A.   I don't know, 'cause I don't know how -- how a
      18   folder like that is set up.
      19         Q.   You have to know --
      20         A.   You may be right.
      21         Q.   You got this, right?
      22         A.   He -- I asked him for the data, he gave it to me.
      23         Q.   Kartuzinski did?
      24         A.   Yeah.
      25         Q.   Okay. So Kartuzinski is the one that gave you


      2.   this information?
      2          A.   Yeah.
      3          Q.   Do you remember whether it was written or it was
      4    oral?
      5          A.   I don't remember.
      6          Q.   Well, if it was oral --
      7          A.   I mean, I don't remember it being written, so it
      8    may be oral.
      9          Q.   The reason why I ask this, he sat down at a desk
      10   with you, at a desk like this, as you sat at the keyboard --
      11         A.   Yeah.
      12         Q.   -- as he went through the file.  Do you recall
      13   that?
      14         A.   No.
      15         Q.   So you don't know which way it was?
      16         A.   No.
      17         Q.   There might be a document around,
      18   Mr. Kartuzinski's summary of the PC folder, possibly? Who
      19   knows, right?
      20         A.   I -- I don't remember seeing one myself.
      21         Q.   You mentioned that -- I'm not going to get into a
      22   lot of this stuff, because I'm not nearly the expert
      23   Sergeant Andrews is, and I'll let him do that, but something
      24   I'm curious about: It says a PTS Rundown. That's something
      25   I haven't seen before. What is that?


      1               SPECIAL AGENT STROPE: Possible Trouble
      2    Source.
      3          A.   Yeah, that's about it.
      4          Q.   I understand PTS in that respect, but I didn't
      5    understand PTS Rundown. Is that --
      6          A.   Yeah, it's an auditing position.
      7          Q.   I know these two guys are PTSs for the Church and
      8    have been for years. I read about that in your newspaper.
      9               The next paragraph I wanted to look at was the
      10   second page, it says, "Since then," about halfway down the
      11   page. See what I'm talking about?
      12         A.   Yeah. Yep.
      13         Q.   What does that mean?
      14         A.   Since then --
      15         Q.   Since then, up until her psychotic break, she had
      16   done several ethics handlings at her work. What does that
      A    mean?
      18         A.   The information that had been gotten up to that
      19   point is that at the place where she works they must have an
      20   Ethics Section or Department there, and she was doing some
      21   things in that area at her work. Just like we have an
      22   Ethics Section in the Church, sometimes businesses that are
      23   run by Scientologists incorporate the same in their own
      24   business.
      25         Q.   Okay. But you indicated earlier that you'd never


      1    met Benetta Slaughter, right?
      2          A.   Right. I mean, I've met her since, I didn't meet
      3    her that night.
      4               MR. LAURO: You did say previously that you
      5    met her the night that Lisa went to Morton Plant.
      6               THE WITNESS: No, that was David.
      A               MR. McGARRY: That was David Slaughter.
      8               MR. LAURO: Oh, excuse me. That's right.
      9          Q.   So you've met Benetta since this thing?
      10         A.   Yeah, I know who she is.
      11         Q.   So this information that you've obtained for
      12   December 5th was obtained how?
      13         A.   Which?
      14         Q.   That paragraph.
      15         A.   Oh, "Since then"?
      16         Q.   Yeah.
      17         A.   David Slaughter. David Slaughter told me that.
      18         Q.   And that would have been the night at the
      19   hospital?
      20         A.   Yeah.
      21         Q.   And you memorialized that at the hospital or
      22   sometime later?
      23         A.   I don't know. I could have remembered that from
      24   the hospital. This was probably in the report that was done
      25   after the -- after she went to Morton Plant Hospital, in the


      1    carryover. But I remember getting this information from
      2    David that night that she went to Morton Plant.
      3          Q.   Okay. Okay. It's kind of funny, Page 3, if you
      4    would, This evening, last paragraph, she was examined by --
      5    we're going back to present time, December 5th time, right?
      6          A.   Yeah.
      7          Q.   And in that paragraph you also indicate that
      8    Janice contacted Dr. Minkoff.
      A          A.   Uh-huh.
      10         Q.   So that's harkening back to your interview with
      11   Janice Johnson after this -- after everybody returned from
      12   New Port Richey?
      13         A.   Yeah.
      14         Q.   Well, my question is that, in the middle of that
      15   paragraph it says "Current data from Dr. Minkoff." How does
      16   that fit into December 5th?
      17         A.   I don't understand.
      18         Q.   Current data would mean --
      19         A.   That day. That night.
      20              MR. LAURO: Did you talk to Minkoff or is
      21   this something Johnson's reporting Minkoff said?
      22              THE WITNESS: Johnson's reporting Minkoff
      23   said that.
      24         Q.    Current data from Dr. Minkoff --
      25         A.    Well, Dr. Minkoff is also on the phone -- someone


      1    in our office, I think it was Brian, talked to Dr. Minkoff
      2    on the phone. I'm guessing. Somebody talked to Dr. Minkoff
      3    on the phone, we didn't get everything directly from Janice.
      4          Q.   And that would have been later that night, after
      5    she died?
      6          A.   Yeah. I don't know if this information here came
      7    directly from Janice as she duplicated it from Dr. Minkoff
      8    or if Dr. Minkoff told someone in my office this directly, I
      9    don't know.
      10         Q.   But it ended up with you --
      11         A.   Uh-huh.
      12         Q.   -- ultimately?
      13         A.   Yeah.
      14         Q.   Now, where does this document go after you created
      15   it?                                                                               5
      16         A.   Normally, it would go to, like, the Legal Officer.
      17         Q.   Who's that?
      18         A.   Well, at that time was Judy Fontana. It would go
      19   to Brian Anderson, it would go to --
      20         Q.   Copies or just the same one running around?
      21         A.   Copies.
      22         Q.   Copies?
      23         A.   Yeah. It would have gone to the Los Angeles
      24   office.
      25         Q.   Is this thing on a computer somewhere?


      1          A.   I'm trying to remember. I don't know.
      2               Is it now on the computer?
      3          Q.   Well, it might be, I don't know.
      4          A.   We checked -- we checked all our computers. So if
      5    it was there, it's not there now. It's kind of -- because
      6    it's on -- on legal size paper, it makes me doubt if it was
      7    on a computer or not, because our printing computers all
      8    print out on short paper. So I don't -- I don't know. The
      9    typeset looks like one of our computers.
      10         Q.   All right. The next paragraph I want to refer to
      11   was the paragraph following "Since then," it was on Page 2.
      12         A.   Okay.
      13         Q.   Where did that come from? "On the 18th," it says,
      14   "Benetta ..."
      15         A.   Right. I
      16                    (Pause.)
      17         A.   I don't remember if it came from David or Benetta
      18   or --
      19         Q.   If it came from Benetta, then it would have had to
      20   have been in a written form, correct, because you had not
      21   met her at the time?
      22         A.   Right. Or possibly over the phone, I don't
      23   remember.
      24         Q.   Same thing for the next paragraph, if you would,
      25   please.


      1          A.   Uh-huh.
      2          Q.   "As Lisa was approaching ..."
      3          A.   This information we got -- I think Benetta got
      4    this from the guy who -- whose boat this was.
      5          Q.   Benetta did?
      6          A.   Yeah. 'Cause if I remember correctly, I think she
      7    said that the guy, the owner of the boat, was in touch with
      8    AMC Publishing, trying to find out about the insurance that
      9    Lisa had so he could handle the damage to his boat.
      10         Q.   So that paragraph there is conveyed to you from
      11   what source?
      12         A.   I don't remember if it was David Slaughter,
      13   Benetta Slaughter or somebody else who had knowledge of
      14   that.
      15         Q.   But that information was given you prior to
      16   December 5th, correct?
      17         A.   Yes.
      18         Q.   Sometime during that week or maybe even
      19   December 5th, correct?
      20         A.   I would have gotten this prior to the 5th. I
      21   would have gotten this in connection with how she came to be
      22   at Morton Plant.
      23              MR. McGARRY: All right. I'll take a break
      24   and let these guys take over, but I might have
      25   something else.


      1               THE WITNESS: Okay.
      2                          EXAMINATION
      4          Q.   Would it be fair to say -- I listened to you
      5    describe your job description -- would it be fair to say
      6    I that you're some type of a public relations troubleshooter?
      7    That's the impression I got. You know, if there's a flap or
      8    something that may be embarrassing to the Church or an
      9    accident or something, you immediately go in, dig out all
      10   the facts of everybody involved and then present a report?
      11         A.   Correct.
      12         Q.   Okay. Now --
      13         A.   That's not all I do, but that's -- when we have a
      14   flap, that's what I would do.
      15         Q.   Now, in this case or other cases, if someone falls
      16   down in front of the Church, you know, and hurts themselves,
      17   who do you normally -- you would go in, do the report, and
      18   then who would you give that to? Who's your next person?
      19   Somebody needs that information.
      20         A.   Well, always I would give it to my Senior, who is
      21   now Ben Shaw, it used to be Brian Anderson.
      22         Q.   Okay. So they would get that?
      23         A.   Yeah, they would get that. And then depending on
      24   what the matter is regarding, others would get that, whether
      25   that be an Ethics Officer or a Case Supervisor or the


      1    Legal Officer.
      2          Q.   All right. On the Morton Plant incident, it seems
      3    apparent that you wrote a report on that, that was a flap?
      4          A.   Yep.
      5          Q.   What did that report contain? I
      6          A.   A lot of this information. What I knew at the
      7    time. Like, you know, what she was doing before she took
      8    her clothes off, you know, who did she see.
      9          Q.   All right. Now, who did that go to?
      10         A.   Well, Brian Anderson, I would think. The
      1l   Legal Officer.
      12         Q.   All right. Let me back up. In the police
      13   department I have a specific way that we route reports. If
      14   I have to write reports, there's a specific way.
      15              How do you route your reports to make sure that
      16   your Seniors see the report?
      17         A.   Well, I put his post title on it and I put it in
      18   his basket.
      19         Q.   Okay. Now, I don't see any titles on this at all.
      20   Were there?
      21         A.   Yeah, not on this page. Maybe there was a cover
      22   page, I don't know. These reports don't usually look like
      23   this, without any routing.
      24         Q.   Right.
      2S         A.   I don't know why this particular one does.


      1          Q.   Can you look at this document and tell me this is
      2    the document that, in its whole entirety, that you made up?
      3               You know what I'm saying. You're the author of
      4    the document.
      5          A.   Yeah.
      6          Q.   We don't have anything here, there's no signature
      7    or written hand here.
      8          A.   Yeah.                                                                                      5    A
      9          Q.   Okay. Just a "Prediction I/C."
      10              Can you look at this copy of this document and
      11   tell me that this is your whole entire document that you
      12   wrote on the night of December 5th and this is the way it
      13   looked and how it got routed?
      14         A.   I can't remember exactly how it got routed. I
      15   can't. But I did write this and I did get it at least to
      16   the Legal Officer and the -- my Senior.
      17         Q.   Okay. Now, when I talked to Brian Anderson, he
      18   tells me that he was unaware that you were doing this. Now,
      19   that seems a little strange, doesn't it? That's your normal
      20   job and apparently you were very efficient at it, you did
      21   the one on the flap at Morton Plant, you did this one and
      22   maybe some others. I found it strange. You know, I
      23   supervise six people and I know what they're responsible
      24   for. He says he didn't know that you were doing this
      25   document, that you were simply a file clerk and couldn't


      1    understand why you did that document.
      2               Is that -- is that contrary to your --
      3          A.   That seems weird to me too.
      4          Q.   That's contrary to your testimony today?
      5               MR. LAURO: Wait. I don't know whether she
      6    can comment on whether it's contrary, she can only
      7    testify to what she knows.
      8          Q.   Let me rephrase it.
      9          A.   If he says he didn't see it, maybe he didn't.
      10   Normally I would give him a copy. If he read it, I don't
      11   know.
      12         Q.   Let me restate. Brian Anderson said he didn't
      13   know you did this report and you're a file clerk. Is that
      14   contrary to your understanding?
      15              MR. LAURO: Wait a minute. We don't know
      16   what Brian Anderson said. And why don't you state on
      17   the record what your job duties were. And whether or
      18   not Brian Anderson knew that you were doing it, do you
      19   know that for fact?
      20         A.   I don't know if he was standing there watching me
      21   or if he asked me questions about it. I don't remember what
      22   his connection with me writing this report was.
      23         Q.   Okay. A couple of words in here, maybe we can go
      24   over. Quickie?
      25         A.   Two -- too short, not fully done.


      1          Q.   Cut short or not completed?
      2          A.   Exactly.
      3          Q.   Joberg?
      4          A.   That's a type of confessional procedure.
      5          Q.   Could you explain that?
      6          A.   I don't -- I don't know why it has the name
      7    Joberg, but that's the name that LRH gave that kind of
      8    confessional. And I don't even know the questions that are
      9    on it. I just know it's the type of confessional which are
      10   done in an auditing session.
      11         Q.   Serfacs, S-e-r-f-a-c-s?
      12         A.   Those are services facsimiles or pictures or
      13   incidents that a person uses to make himself right and
      14   others wrong.
      15         Q.   Is that written?
      16         A.   Yeah, there is a definition of that in the
      17   dictionary.
      18         Q.   All right. How does it differ from a
      19   Knowledge Report?
      20         A.   Serfacs? I
      21         Q.   Yeah.
      22         A.   Well, Serfacs is like something that you would do
      23   or a reason for you doing something. Like, if you want to
      24   -- let me see, try to think of an example.
      25              It's not a good thing. It's not a good thing.


      1    Like you would hurt somebody or do something bad to somebody
      2    because you're trying to make him less of whatever in order
      3    to make yourself more powerful. It's not a good thing.
      4          Q.   Okay. RD I know is rundown, but you have CCRD.
      5          A.   Clear Certainty Rundown.
      6          Q.   And that would fit into preparation for her going
      7    Clear in September?
      8          A.   Uh-huh.
      9          Q.   Okay. Tell me about overt/withhold. You used
      10   O/W, which I found to be overt/withholds.
      11         A.   Those are contrasurvival acts you commit against
      12   yourself or others.
      13         Q.   Or the Church?
      14         A.   That's what an overt is.
      15              No, anything.
      16         Q.   Okay. But it could be against the Church?
      17         A.   Like if I hit somebody's car with my car and drive
      18   away and don't leave a note, that would be an overt.
      19         Q.   Overt/withhold?
      20         A.   You would write -- The overt is actually
      21   committing the act and then the withhold's --
      22         Q.   Not telling?
      23         A.   You don't tell anybody about it. And you can
      24   either have these and not write them down, collect them up
      25   and not do anything with them. As in -- in a confessional,


      1    this is something you would talk about with your Auditors,
      2    you would tell them your overts, it's like a -- and when you
      3    write them down.
      4          Q.   Prediction is your title. Anything -- where does
      5    that come from? I mean, is there anything behind that?
      6    found it kind of hard to understand.
      7          A.   It's an odd -- it's an odd title. But there's a
      8    section on our Organization Board which has a purpose of
      9    predicting situations that may come up for the Church,
      10   either good or bad.
      11         Q.   Okay. Social Reform Officer?
      22         A.   That's a -- another area in our office that deals
      13   with social reform activities, such as reforming the field
      14   of mental health or justice -- you know, reform of criminals
      15   in the justice system.
      16         Q.   Do you have Social Reform Officers that would take
      17   care of people that were PTS-III? Do you have --
      18         A.   No.
      19         Q.   No?
      20         A.   That's not their purpose. Their purpose is to
      21   expose things that are done incorrectly or inhumanely in the
      22   field of mental health, whether that be psychiatry or
      23   something else; with a purpose of changing that to make it
      24   more -- more of a humane and safe field that people can go
      25   to and really get help.


      1          Q.   Okay. What is the Church's tech in dealing with
      2    someone who's PTS-III violent? Do you know what the tech is
      3    for that or what the recommendation would be?
      4               I haven't actually seen anything, you know,
      S    separating out different degrees of psychotic or psychosis.
      6    Like, you know, if someone is psychotic, then, you know,
      7    they get -- they get food and rest and, you know, very
      8    simple things in their environment. You know, you don't
      9    like have a conversation or noise in their environment, and
      10   you give them a chance to rest and hopefully come out of it.
      11         Q.   Okay. Do you know the number of reports that you
      12   actually physically wrote in reference to the Lisa McPherson
      13   incident from the beginning to the end?
      14         A.   Two. Two that I can tell you for sure.
      15         Q.   Okay. One being this document we're looking at
      16   today?
      17         A.   Yes. And the other being one that I would have
      18   written when she first went to Morton Plant.
      19         Q.   All right. Now let's go to that document.
      20         A.   Is that one sent and titled at the top to your
      21   boss, which would be what, CO of OSA? Would that be the way
      22   it would be titled?
      23         A.   Normally, yeah. I mean, I don't -- I don't have
      24   it, I can't tell you for sure what the routing was on top,
      25   but normally would go to my Senior and others.


      1          Q.   So that report would be very similar to this one,
      2    in that, I think you said, there would be a copy go to the
      3    CO and copy go to the Legal Officer and copy go to
      4    Los Angeles?
      5          A.   Uh-huh.
      6          Q.   Now, should that copy of your first report that
      7    you wrote about her going to Morton Plant be in Los Angeles?
      8          A.   I -- I don't know.
      9          Q.   All right. And I know maybe you can't answer
      10   this: If it did, where could I find it? That's what I'm
      11   looking for, is help. If you wrote it and it went to
      12   Los Angeles, where would it go?
      13         A.   If I were you, I would check with the Data Chief.
      14         Q.   Okay. Do you know what folder it would normally
      15   go into? These are your reports. I was wondering, these
      16   kind of -- everything that I've researched so far, these
      17   don't kind of fit into any easy folder. You know, like the
      18   Knowledge Reports go into the person's you're complaining
      19   about and maybe your folder. But your reports seem to be a
      20   little different.
      21              Do you know what they would go into? Would they
      22   go into Lisa's PC folder?
      23         A.   A copy.
      24         Q.   A copy should?
      25         A.   Yeah.


      1          Q.   And I think my research indicates that if you
      2    write some type of report and mention several people in
      3    there, copies should go into those people's folders, right,
      4    to kind of --
      5          A.   Well, it depends. If it's about that person and
      6    is concerning a technical aspect of their auditing or some
      7    ethics matter that they have.
      8          Q.   Okay.
      9          A.   I mean, it depends. There are different kinds of
      10    reports. A Knowledge Report would be on a person. You put
      11    "Knowledge Report" at the top, you put the person's name at
      12    the top that it's concerning. And there's a reference on
      13    how to route Knowledge Reports. One goes to the person it's
      14    written on, another goes to the ethics file.
      15         Q.   Is there a reference to your reports --
      16         A.   No.
      17         Q.   -- in the tech, where they would go?
      18         A.   Not that I've seen.
      19         Q.   Okay. So it's your testimony today you only can
      20   remember doing two reports on this incident, this one and
      21   one we cannot -- we don't have?
      22         A.   Right.
      23         Q.   A couple times you referred, when you were over
      24   at -- to see Lisa or to check on Lisa, you referred to the
      2S   Chief of Security. Who was that?


      1          A.   Paul Kellerhaus.
      2          Q.   Okay.
      3          A.   Well, he might not have been the Chief at that
      4    time, but he was over that area.
      5          Q.   My understanding earlier -- give you a little
      6    help -- Baxter was Chief of Security.
      7          A.   You're right.
      8          Q.   And Kellerhaus was over him. And I'm not sure
      9    what that title was;
      10                   MR. McGARRY: They're kind of
      11   interchangeable.
      12         Q.   Some kind of Inspections --
      13         A.   That was Senior evenly over and above the people
      14   with the same post title, Senior Inspections & Reports
      15   Officer.
      16         Q.   That's right. That's what it was.
      17         A.   Yeah.
      18         Q.   When you went over there and talked to Security,
      19   who did you actually talk to, Baxter or Kellerhaus?
      20         A.   Probably three. I definitely remember talking to
      21   Paul.
      22         Q.   Okay.
      23         A.   Arthur, I don't remember talking to him very much.
      24         Q.   All right.
      25         A.   Another time I -- person who was at the watch when


      2.   I checked in was this -- this Hungarian guy. I don't
      2    remember his name, but you know who I mean.
      3          Q.   There was a couple. Alfonso Barcenas?
      4    Attila Toth?
      5          A.   That's who I mean.
      6          Q.   Attila Toth, all right. We talked to Attila.
      7          A.   Now, I know you. said earlier you went over there,
      8    you talked to Alain, he told you about Lisa. You also said
      9    you talked to Security. Do you remember what they told you
      10   about Lisa? You were checking up on Lisa at that time.
      11         A.   Well, normally I would ask Paul, and he's -- he's
      12   the one that told me what worked. Like when she was doing
      13   better I asked, What worked? What changed? It was aspirin.
      14         Q.   Did he ever tell you that they were giving her
      15   regular real drugs, prescription drugs?
      16         A.   No.
      17         Q.   Okay. Now, when you gathered that information,
      18   was that information just for you or were you forwarding
      19   that onto somebody in your office or your Senior?
      20         A.   It was very unofficial. I mean, it's not
      21   something I would come back and write down and pass around.
      22         Q.   Okay.
      23         A.   I mean, I would just check because I was
      24   concerned. It wasn't like a -- a regular checking in time
      25   or report that was done on it.


      1          Q.   Okay. What made you concerned with this whole
      2    Lisa thing and the watch and all of that? Why were you
      3    concerned about it?
      4          A.  Well, such an unusual situation.
      A;         Q.  Okay.
      6          A.  It's right here in our hotel. She's loud, she's
      7    violent, you know, we have hotel guests, it's just -- it's a
      8    weird thing. Even for us it's a weird thing.
      9          Q.   Okay. So --
      10         A.   So, you know; I don't want police coming, I don't
      11   want, you know --
      12         Q.   Yeah, somebody could have called and complained.
      13         A.   I don't want the media.
      14         Q.   Police could show up and say what's going on.
      15   That was part of your job, was making sure of the PR part?
      16         A.   Yeah.
      17         Q.   Now, I don't know if I misunderstood, you said the
      18   five minutes that you were in the room, that --and I'm
      19   sorry, did you say she was licking the doorknob?
      20         A.   Yeah.
      21         Q.   Okay. I thought -- I thought maybe I missed that.
      22              She was licking the doorknob. And this was a door
      23   that went from where to where?
      24         A.   It was at the back of the room near the -- near
      25   the bathroom.


      1          Q.   Okay.
      2          A.   And it was a door that went from her room to a
      3    room next to it, but I mean, it was locked.
      4          Q.   That room would be in the front of 174 or more
      5    towards Fort Harrison Avenue, is that the way those rooms
      6    connect?
      7          A.   No, it was parallel to -- parallel to.
      8          Q.   Would that have gone to another room? I know one
      9    side, I was there --
      10         A.   You know how you can rent a room in hotels and you
      11   can rent another room --
      12         Q.   Did it go to another room or did it go to a
      13   kitchen area?
      14         A.   I think it was an adjoining room, but I don't
      15   know, I didn't see the room.
      16         Q.   Okay. Now, she was talking to someone on the
      17   other side, you know, of this room, supposedly, this door?
      18         A.   Yeah.
      19         Q.   Do you remember any part of that conversation?
      20         A.   Well, it wasn't a conversation.
      21         Q.   Well, one-sided anyway.
      22         A.   I don't remember it.
      23         Q.   Okay. Do you remember what she was wearing while
      24   you were in the room for the five minutes?
      25         A.   Shorts. She had blue jean shorts on and I think


      1    it was a pink T-shirt.
      2          Q.   All right. Was she clean?
      3          A.   Yeah. She looked good, full of life.
      4          Q.   All right. How good are you at descriptions? And
      5    only -- you know, I'm just going to ask you to describe her
      6    height, weight, hair, eyes, if you can.
      7          A.   Yeah.
      8          Q.   When you saw her that day in that room for the
      9    five minutes, how tall would you figure? And it's only
      10   approximations.
      11         A.   I'd say she was five eight. Blond. Short, curly
      12   hair. Fair, light skinned, a little freckly. Brown eyes.
      13   Medium bones, not -- not slender bones. Weight, I don't
      14   know. She had -- she had weight on her. She wasn't
      15   overweight or underweight.
      16         Q.   Okay. Can you take a guess, compared to your
      17   weight, what she weighed?
      18              MR. LAURO: She was a heavyweight compared to
      19   you.
      20              DETECTIVE SERGEANT ANDREWS: Compared to her,
      21   yeah.
      22         A.   I don't know. I'm really bad at guessing weight.
      23         Q.   All right. PC folders that you shipped to
      24   Los Angeles, do you know the boxes that the paper comes in
      25   for your copy machines, they're kind of like a file box, say


      1    about this long?
      2          A.   Yeah.
      3               Were these -- can you give us -- I'm trying to
      4    figure out the -- how big these folders were. Would it fill
      5    that box or two boxes or a half of that box? Can you give
      6    us some kind of an idea, or like maybe four folders, four
      7    inches thick, some kind of an idea what we're actually
      8    looking at?
      9          A.   Well, a full PC folder is about that thick, couple
      10   inches thick. And however many you can get into a banker's
      11   box. These were banker's boxes --
      12         Q.   Now, are those legal size folders?
      13         A.   Yeah.
      14         Q.   Okay. And so you think that whole box was filled,
      15   the cardboard banker's box like?
      16         A.   Well, there were -- there were several. There
      17   were maybe seven.
      18         Q.   About seven?
      19         A.   Yeah.
      20         Q.   Okay.
      21         A.   Not just with PC folders, the ethics file went,
      22   the CF folder, accounts file.
      23         Q.   Okay. I'm asking that because we're trying to
      24   search for missing records. It helps us try to figure out
      25   what, I you know, what we're looking for.


      1          A.   Okay.
      2          Q.   You said that someone helped you pack them up. Do
      3    you know who that was?
      4          A.   Judy Mercy.
      5          Q.   Murphy?
      6          A.   Mercy, like M-e-r-c-y.
      7          Q.   Judy Mercy.
      8               Judy Murphy, I wrote Murphy, is the one in the
      9    office that was Clear.
      10         A.   There's not a Judy Murphy, it's Judy Mercy.
      11   There are two Judys in the office. One Judy was
      12   out there at the time of the death. The second Judy,
      13   Judy Mercy, was out on medical leave at the time of death.
      14   So when she came back, she worked in my office and she and I
      l5   together packaged up these boxes.
      16         Q.   Was she Clear, Judy Mercy?
      17         A.   Yeah.
      18         Q.   Could she look in those folders?
      19         A.   She could, yeah.
      20         Q.   But she probably didn't, 'cause no one asked her
      21   to?
      22         A.   She didn't have any reason to.
      23         Q.   I'd like to get back to that Cram report.
      24   Now, I understood that it was instructions to the
      25   Auditors. I'm just surmising now, Lisa goes PTS-III,


      1    there's something wrong, everybody tries to get together
      2    information to figure out, you know, what might be bothering
      3    her, what might have made her snap. That was my
      4    understanding of the Cram report.
      5          A.   Well, that's the intention of it, yeah.
      6          Q.   Okay. Now, that was done shortly after the
      7    Morton Plant crisis?
      8          A.   Yeah.
      9          Q.   The Cram report, do you know who would comprise
      10    that Cram report? Who's responsible for that?
      11         A.   Alain.
      12         Q.   Alain?
      13         A.   Yeah.
      14         Q.   Okay. Now, you said when you testified that you
      15   were sent around to pick up the cc's or the carbon copies of
      16   this report and then that you shredded them; is that right?
      17   Or, you know, it's a while back so correct me if I'm wrong.
      18         A.   Yeah. They were gathered up, and I can't remember
      19   if I shredded them or if they were held and collected up
      20   with the other PC folders and stuff that were being
      21   collected up. But I do remember seeing more than one copy
      22   of this Cram at the time we were packaging up the boxes.
      23   And I, you know, looked at this -- these copies of the Cram
      24   and I said, well, no one's ever gonna need copies of the
      25   Cram, we should just send one copy and shred the rest, which


      1    is what I did.
      2          Q.   Okay. I'm glad that clears it up. I had an idea
      3    that you went around, got all the copies and shredded them
      4    all up. So probably, we don't know --
      5          A.   I don't think that happened, because I remember
      6    later on when I was thinking what all was packed up, I
      7    remember copies of this Cram and thinking, well, no one's
      8    ever gonna need copies, just send one and --
      9          Q.   Would that be in her PC folder too?
      10         A.   It may.
      11         Q.   In your knowledge, is that where it would normally
      12   go --
      13         A.   Yeah.
      14         Q.   -- the PC folder?
      15         A.   Yeah.
      16         Q.   Because that's pretty important stuff, personal
      17   stuff?
      18         A.   Yeah.
      19         Q.   Did you call Los Angeles the night that Lisa died, A
      20   December 5th?
      21         A.   No.
      22         Q.   Okay. Do you remember anybody in the office
      23   calling Los Angeles?
      24         A.   I'm sure they did. I wasn't there when they did,
      2S   but I know they -- I know that that was the plan, that they


      1    went to do that.
      2          Q.   Now, this is not a criticism, but I have to ask
      3    because it's bothering me: When you testified to this
      4    report you wrote, this report seems to be a very important
      5    report in the fact that Lisa died and just in this case
      6    especially that this information is very important for
      7    someone to have, either Brian to have in case somebody from
      8    Los Angeles called or said what's going on, give me a little
      9    rundown. Yet when Mr. McGarry cross examined on the report,
      10   you can't remember where a lot of it came from and a lot of
      11   where -- who said it or when they said it.
      12              Is that normal for this report?
      13         A.   There's only some parts in there where -- where I
      14   would say I don't remember where this came from. Mostly
      15   everything I can tell you where I got it.
      16         Q.   Okay. All right. You don't keep any notes on
      17   these? You know, if I do a report and I try to put it
      18   together, you put the report together, finish it up, reread
      19   it, and then destroy your notes.
      20         A.   If I had notes, yeah.
      21         Q.   Okay. The technology, language, written in this
      22   report, when I read it, appears to be language that
      23   Mr. Lauro would have a problem reading, I would have a
      24   problem reading, probably anyone in this room other than
      25   yourself or someone in Scientology.


      1               Would this be normal, for you to write this kind
      2    of language in the report with all the abbreviations that
      3    Scientology uses and all the technical terms we've gone over
      4    in, your -- this type of report?
      5          A.   Uh-huh.
      6          Q.   Okay. Now, that being because the person this
      7    report is for is the guy who's going to deal with the legal
      8    and with the press? I mean, I'm a little wondering, you
      9    now, this report was written for a whole bunch of people,
      10   but yet it would really take only a Scientologist to read
      11   this report.
      12         A.   It's written for a Scientologist, yeah.
      13         Q.   I noticed in that paragraph we talked about in
      14   Page 2 in the middle, Since then, up until her psychotic
      15   break on 18 November '95, she had done several ethics
      16   handlings at her work, ANC Publishing, owned and operated by
      17   David and Benetta Slaughter in Clearwater. She had been
      18   writing O/Ws for weeks and was acting strangely the last
      19   couple of days prior to her break, which was not reported to
      20   Flag.
      21              Now, when you indicate "several ethics handlings,"
      22   now, is that a bad thing, ethics handlings, when somebody
      23   has to handle you ethically?
      24         A.   No, not particularly. Sometimes a person will
      25   want to see the Ethics Officer if they're having trouble


      1    with something in their life, they want to handle something.
      2    Maybe it's an ethics matter, maybe it's really something
      3    else. I don't know what was going on with her at the time,
      4    if there was something she wanted to address, you know.
      5               There's -- there's a datum in Scientology, if
      6    you're sad or not doing well, you know, there may be an
      7    I ethics situation. And it's been found to be helpful that
      8    when you, you know, do a bit of a confessional. Which one
      9    way of doing that is writing down your overts or withholds.
      10   You can either write them down, that's one way, or you can
      11   tell them to an Auditor, that's another way.
      12         Q.   When you gained this information, did it appear to
      13   you that someone at AMC was handling her ethics?
      14         A.   I mean, I hadn't thought really either way.
      15         Q.   Okay.
      16         A.   But that's possible, yeah.
      17         Q.   I know that her boss, Benetta Slaughter, was an
      18   OT-VIII.
      19         A.   Yeah.
      20         Q.   So she's Clear and then a bunch?
      21         A.   Uh-huh.
      22         Q.   So she could handle Lisa's ethics and O/Ws at the
      23   office? Would that be something she could do?
      24         A.   That would be okay.
      25         Q.   That would be okay, she's so far up on that


      1    bridge?
      2          A.   No. Doesn't matter where the person is when
      3    they're dealing with ethics matters, doesn't matter.
      4          Q.   Okay. You don't have to be above the person?
      5          A.   No.
      6          Q.   Okay. Now, these O/Ws that she was writing for
      7    weeks, where would those go?
      8          A.   I don't know.
      9          Q.   Okay.
      10         A.   I mean, they didn't come to me.
                 Q.   All right. Normally, can you tell me from just
      12   your knowledge of Scientology where they would go?
      13         A.   Well, there is a reference from LRH that says
      14   they're supposed -- the originals are supposed to go into
      15   the PC folder.
      16         Q.   Okay.
      17         A.   I don't know if hers made it there.
      18              DETECTIVE SERGEANT ANDREWS: I don't have any
      19   more. Thank you very much.
      20              THE WITNESS: Okay.
      21                  EXAMINATION
      23         Q. When people go to, Public especially, go to
      24   Morton Plant or any hospital in the area, are they handled
      25   the same way, the same urgency as Lisa was, with the same


      1    amount of attention?
      2          A.   (Witness shakes head   negatively.)
      3          Q.   Was this an unusual  circumstance?
      4          A.   Yes, it was unusual.
      5          Q.   Well, what --
      6          A.   And, no, not everyone's handled that way.
      7          Q.   And what does -- what makes this unusual?
      8          A.   Well, it's not very often that someone goes crazy
      9    anywhere, whether in the Church or -- or not.
      10         Q.   But it almost appears to someone who, of course,
      11   wasn't there that -- that maybe there was a chance that
      12   prior to Lisa becoming involved in the accident she was in
      13   maybe some type of procedure at Fort Harrison or somewhere
      14   on Church property. Have you heard anything along those
      15   lines?
      16         A.   Right before or months before?
      17         Q.   Right before. Maybe she was leaving and running
      18   away from something.
      19         A.   I have never heard that.
      20         Q.   From some of the statements she made at the scene,
      21   there is some conjecture that maybe she was running from
      22   I something.
      23         A.   I never heard that. I heard what I wrote here,
      24   that's all I heard about what she was doing before this
      25   happened.


      1          Q.   I mean, it would make more sense that all these
      2    people showed up at the hospital if that were the case,
      3    right?
      4          A.   I don't know.
      5          Q.   Okay. What would be the reason that -- again,
      6    we've got testimony, I know you don't have any knowledge of
      7    that, but we have testimony Sec Checks were done concerning
      8    the Lisa McPherson case by people from Los Angeles prior to
      9    their being interviewed by police.
      10              What would be the reason for Sec Checks in that
      11   circumstance, do you know?
      12         A.   I don't know. It's not something that I would,
      13   like, suggest or order for some reason, because I'm not sure
      14   what the reason would be for that.
      15         Q.   Can you order Sec Checks on someone?
      16         A.   Uh-huh.
      17         Q.   What is the definition of Sec Checks? What
      18   exactly does that particular check -- what's its function?
      19         A.   Well, it's a -- basically, it's where a person
      20   would have a confessional in -- oh, this is one difference
      21   between the Joberg type of confessional, which is done in
      22   auditing, and what's called an HCO Security Check, which is
      23   also done in auditing, but in the Joberg, this is something
      24   that's -- that they just do the confessional, they're
      25   acknowledged for their communication, they're forgiven,


      1    basically, in the auditing session and that's the end of it.
      2    In the other type, in the HCO confessional, here the Auditor
      3    writes up situations that have come up in this confessional
      4    that the person should see an Ethics Officer about so that
      5    he can change his unethical ways, if that's what came up.
      6          Q.   Sec Check, that's Security Check?
      7          A.   Uh-huh.
      8          Q.   Could that check be used, for instance, to check
      9    someone who may or may not consider talking to the police or
      10   say something contrary to Scientology to assure that that
      11   person is going to stay on the Scientology page? Could it
      12   be used for that?
      13         A.   I don't know. I've not observed it being used for
      14   that purpose or ordered in -- you know, ordered with that
      15   purpose.
      16         Q.   You seem pretty schooled in the vernacular of
      17   Scientology. Have you ever heard the term
      18   Merchants of Chaos?
      19         A.   Uh-huh.
      20         Q.   What's the definition of Merchants of Chaos as far
      21   as the tech is concerned?
      22         A.   It's not a technical term particularly, it's LRH's
      23   definition of someone who deals in -- in chaos and promoting
      24   chaos and making chaos bigger, because that's how they make
      25   their living, such as the media.


      1          Q.   And law enforcement, isn't that correct, in his
      2    vernacular of Merchants of Chaos, law enforcement was also
      3    part of that?
      4          A.   I can see how that might fit under there.
      5          Q.   Okay.
      6          A.   I don't remember him specifically --
      7          Q.   The rules to deal with Merchants of Chaos are much
      8    different than dealing with average people, right?
      9          A.   I don't know.
      10         Q.   Okay. Who -- I guess you answered my question --
      11   who has the power to say everybody who is involved, not
      12   necessarily this. case, but any case, is going to be
      13   Sec Checked? Who would be able to do that? You could do
      14   that?
      15         A.   I wouldn't do that with without coordination,
      16   because this -- this case is, like, not mine, it's not
      17   something I'm --
      18         Q.   Whose case was it then?
      19         A.   The McPherson case?
      20         Q.   Who's the lead investigator for OSA on the
      21   McPherson case?
      22         A. After she died?
      23         Q. Yeah.
      24         A. I don't remember an investigation really happening
      2S   after she died. There -- there was a lot of attention on


      1    the case and on legal and investigations and PR after the
      2    autopsy came out, and there was big --
      3          Q.   Who was handling that? We'll change it to
      4    investigation or flap or whatever you want to call it.
      5          A.   After the autopsy came out?
      6          Q.   Well, after her death.
      7               Did it change after the autopsy came out?
      8          A.   Well, it got bigger.
      9          Q.   Okay.
      10         A.   Than it had a lot more importance then.
      11         Q.   Let's say between the time of her death and the
      12   autopsy, who was really calling the shots?
      13         A.   I don't know, I guess.
      14         Q.   Well, you had to know.
      15         A.   There were two of us in the office where I
      16   work --
      17         Q.   Okay.
      18         A.   -- who does data collection, investigations,
      19   whatever you want to call it.
      20         Q.   Who was Senior of the two?
      21         A.   Judy Mercy, but she -- during the time of the
      22   death and for some months after the death she was out on a
      23   medical leave, so I was there by myself and had so much work
      24   to do, I was hardly even doing any ...
      25         Q.   During this period of time you were only working


      1    on the case -- I only use the word "case," you don't have to
      2    use it -- this incident, whatever you want to call it?
      3          A.   Okay. In some aspects, yeah. I mean, there was
      4    myself, Brian Anderson, Judy Fontana, there was direction
      5    given from OSA Int on what to do, and attorneys.
      6          Q.   What about after the autopsy?
      7          A.   Well, then Ben Shaw and Glen Steilo came, came to
      8    our office and basically took over.
      9          Q.   Now, when -- when in that period of time were
      10   these files moved  to Los Angeles, after the autopsy?
      11         A.   No, before.
      12         Q.   Okay. And at whose directions were they moved?
      13   You may have told us that.
      14         A.   I either got the direction from Brian Anderson or
      15   Judy Fontana, I forget which.
      16         Q.   Do you remember where they were delivered to in
      17   Los Angeles?
      18         A.   To -- I believe the routing that we put on it was
      19   the Data Chief, OSA Int.
      20         Q.   What's his name?
      21         A.   That's Kathy O'Goreman.
      22         Q.   Is that spelled just how it sounds,
      23   O-'G-o-r-m-a-n?
      24         A.   G-o-r-e-m-a-n.
      25         Q.   Is that person still in Los Angeles?


      1          A.   Uh-huh.
      2          Q.   Is that the person who was in charge, ultimately,
      3    of all these files and folders in Los Angeles, so the
      4    Custodian of Records for these files or folders?
      5          A.   I -- I don't know.
      6          Q.   Well, who in California could we give a subpoena
      7    to that would have access to all these records, ultimate
      8    access to all records?
      9               MR. LAURO: Do you know?
      10         A.   Well, I can guess.
      11         Q.   Who?
      12         A.   I would say Kathy O'Goreman.
      13         Q.   Do you know what her title is?
      14         A.   She's the Data Chief, OSA International.
      15         Q.   Is this normal procedure for folders? When either
      16   a Public or a Staff passes away, do you do this? Do you --
      17   or is there a period of time that you would go through
      18   before you ship all the files out?
      19         A.   I don't know. I've not had contact with anybody
      20   else that passed away.
      21         Q.   Is this the first time that you've shipped this
      22   big a folder to Los Angeles?
      23         A.   Yeah.
      24         Q.   This is the only incident that you've been there
      25   that it's happened, that you've been a party to?


      1          A.   Yeah.
      2          Q.   You obviously don't write these reports on
      3    everybody that goes to the hospital, right?
      4          A.   No.
      S          Q.   Are the people that fit into -- is there a
      6    category of people that you would write these reports on,
      7    just serious cases or Public or --
      8          A.   Serious cases.
      9          Q.   Serious cases?
      10         A.   Whether they were Staff or Public.
      11         Q.   How many times have you written these types of
      12   reports on these incidents?
      13         A.   I don't know.
      14         Q.   Many, many times or -- what I'm getting at, this
      15   isn't the only one, right?
      16         A.   This is not the only one, no.
      17         Q.   What kind of training does it take to be -- to
      18   work in OSA? Do you go somewhere for special training?
      19         A.   I've never had special training.
      20         Q.   Never had any special training?
      22         A.   (Witness shakes head negatively.)
      22         Q.   You never talked to Benetta Slaughter?
      23         A.   Not before Lisa went crazy, no.
      24         Q.   Okay. How about since then?
      25         A.   Yeah.


      1          Q.   Have you talked to her about Lisa since then?
      2          A.   Yeah.
      3          Q.   What was that conversation about? Did she have
      4    ideas about what happened to Lisa?
      5          A.   I think this -- this information about the -- the
      6    guy who owns the boat and was calling, trying to get
      7    information about insurance, I got this from her, from
      8    Benetta. I may have gotten some of this other information
      9    from Benetta, what she was doing, you know, how they had
      10   this agreement to go to Benetta's house and -- and Benetta
      11   got concerned when Lisa didn't arrive at the house, I think
      12   I got that from Benetta.
      13         Q.   Is Benetta on Staff at OSA?
      14         A.   No.
      15         Q.   Are you familiar with Elliot Abelson?
      16         A.   Yes.
      17         Q.   Are you familiar with Mr. Render?
      18         A.   Yes.
      19         Q.   Do you know Mr. Anderson?
      20         A.   Yes.
      21         Q.   Did you attend a meeting sometime after the
      22   autopsy report where Mr. Abelson, Render, Anderson and
      23   Benetta Slaughter were present in the Clearwater building,
      24   the bank, in the conference room?
      25         A.   No.


      1          Q.   You weren't at that meeting with
      2    Benetta Slaughter?
      3          A.   I wasn't there.
      4          Q.   Were you. familiar with that meeting?
      I          A.   No.
      6          Q.   Did Alain Kartuzinski ever have to write any
      7    reports concerning this? I mean, he was the Chief --
      8    Senior Case Supervisor. Did he himself have to write
      9    reports to his Senior, do you know?
      10         A.   I don't know.
      11         Q.   Do you think he would have? Is that a normal
      12   procedure?
      13         A.   If -- if they were requested to do that.
      14         Q.   If he did write reports or if -- what is it --
      15   what does the manual say about where these reports would be
      16   directed? Who would his Senior be? I
      17         A.   Manual doesn't say.
      18              If his Senior wants a report, they'll ask him and
      19   he would normally write it.
      20         Q.   That's his Senior's discretion?
      21         A.   Yeah.
      22         Q.   If they said don't worry, don't write reports,
      23   that's it, essentially?
      24         A.   Yeah.
      2S         Q.   But if someone is ordered to write a report, say


      1    Alain Kartuzinski orders caretakers to write reports,
      2    they're written?
      3          A.   Yeah.
      4          Q.   Okay. They have to be written then?
      5          A.   Yeah.
      6          Q.   Okay. And that's the way it's written, it's
      7    written, right?
      8          A.   Yeah.
      9          Q.   Okay. Did the OSA have the power to stop the
      10   watch, send Lisa to the hospital, over and above
      11   Alain Kartuzinski's ruling?
      12         A.   Yeah.
      13         Q.   And you have -- you know of no
      14   Committee of Evidence, as to your knowledge about this case,
      15   concerning this case?
      16         A.   Right, I don't know of any.
      17         Q.   When this -- on December 5th of '95, how many
      18   members in OSA were there? There was yourself, Brian.
      19         A.   Let's see. Brian. Me. I'm not going to count
      20   the girl who was out on medical leave.
      21         Q.   That was Mercy?
      22         A.   Yes. Judy, Alain, Mary and Diana.
      23         Q.   Did they all have something to do with this case,
      24    ever so much, little bit, anything?
      25         A.   Just Judy Fontana, myself and Brian.


      1          Q.   The other people were busy doing their own thing?
      2          A.   Yeah.
      3          Q.   They didn't -- had nothing to do with this case?
      4          A.   Right. I
      5          Q.   Okay. Is there any technical advice or reason
      6    that during a Sec Check, if you found something during a
      7    Sec Check that was criminal, that you would -- you would
      8    involve a local police department for assistance or is that
      9    not part of the way you do things?
      10         A.   We wouldn't do that.
      11         Q.   So no matter what you find, you wouldn't involve
      12   the local police department?
      13         A.   We wouldn't call -- call them directly. If -- I
      14   mean, if I were an Ethics Officer and I had a parishioner in
      15   front of me who had just gotten done with a -- with an
      16   HCO Sec Check and on there had that he murdered somebody,
      17   let's say, I would encourage that parishioner to go to turn
      18   himself in and tell -- tell the truth, but I wouldn't pick
      19   up the phone and call the police and say I have a murderer
      20   in my office.
      21         Q.   Okay. So if somebody came in and told you that
      22   they're sexually abusing your children or something, you'd
      23   keep that to yourself, let him turn himself in?
      24              MR. LAURO: Similar to if a priest is told
      25   that. Similar to-- you may be familiar with that in


      1    the Catholic Church.
      2               SPECIAL AGENT STROPE: Very familiar.
      3          Q.   Have you gone over your testimony here today with
      4    anybody in the past year? Anybody talk to you about this
      5    testimony here today?
      6          A.   Well, I've gone over, you know, what happened
      7    and -- I mean, I've gone over a lot of this information.
      8          Q.   Has anybody told you, asides from your attorney --
      9    not that he would do that, and I know what he's going to
      10   do -- what to say and what not to say here today?
      11         A.   No.
      12         Q.   And we are Merchants of Chaos, you believe that,
      13   right? So it really doesn't matter, right?
      14         A.   (No response.)
      15         Q.   Right?
      16         A.   I don't know that that's a -- an issue in the
      17   case, but ...
      18         Q.   Okay. Were you -- I know on the night that Lisa
      19   was taken to HCA, the minute that Paul Greenwood --
      21   Paul Greenwood, Laura Arrunada arrived back at Fort Harrison
      21   they were asked to write reports. Were you privileged to
      22   those reports?
      23         A.   No.
      24         Q.   You didn't use those reports to assist you in this
      2S   at all?


      1          A.   I don't remember seeing anything from them.
      2          Q.   You weren't familiar with that?
      3          A.   Unh-unh.
      4          Q.   And you say this report in its entirety, the way
      5    it sits here today, was written on December 5th?
      6          A.   Yes.
      7          Q.   There was nothing added or changed since
      8    December 5th? This is just exactly the way you wrote it?
      9          A.   Absolutely.
      10         Q.   Okay.
      11              DETECTIVE SERGEANT ANDREWS: Nothing missing
      12   either?                                                                            A
      13              THE WITNESS: Like taken out?
      14              DETECTIVE SERGEANT ANDREWS: Well, yeah.
      15              THE WITNESS: I'm not saying that's
      16   everything that the whole Church knew at the time, but
      17   that's what I knew at the time that I wrote the report.
      18              DETECTIVE SERGEANT ANDREWS: Okay. Earlier
      19   you were puzzled about the heading and said there may
      20   have been another page.
      21              THE WITNESS: Yeah.
      22              DETECTIVE SERGEANT ANDREWS: Is there another
      23   page missing?
      24              THE WITNESS: I don't know. I mean, I just
      25   I don't remember the heading connected with this, if any


      1    heading was connected with it.
      2               SPECIAL AGENT STROPE: Well, it's just
      3    peculiar to us, it's -- I'm not saying you had anything
      4    to do with this. It's peculiar, here it is almost two
      5    years into this investigation, you said yourself these
      6    copies were sent everywhere, and we are just now
      7    getting them.
      8               MR. McGARRY: He's going to tell you that
      9    was--
      10              SPECIAL AGENT STROPE: We're a little
      11   suspicious.
      12              MR. McGARRY: -- another lawyer that had an
      13   issue in that.
      14              SPECIAL AGENT STROPE: I mean, we think maybe
      15   differently than lawyers do, 'cause we're --
      16              MR. LAURO: In fairness to --
      17              THE WITNESS: I understand.
      18              MR. LAURO: In fairness to her, this report
      19   was disclosed --
      20              SPECIAL AGENT STROPE: I prefaced my
      21   statement with that.
      22              MR. LAURO: This report was disclosed by her
      23   at an appropriate time. It was not something she kept
      24   from anybody.
      25              SPECIAL AGENT STROPE: I know she has no


      1    power over when it's released. I'm not blaming her at
      2    all.
      3               MR. McGARRY: Let me finish with one question
      4    and we can terminate this thing.
      5                             EXAMINATION
      6    BY MR. McGARRY:
      7          Q.   I've got to clear this up. I'm so confused about
      8    this Benetta thing involved here.
      9               Page 2 of your report, these paragraphs. Correct
      10   me if I'm wrong, didn't you tell me you hadn't met
      11   Benetta Slaughter until after she died, correct?
      12         A.   Right.
      13         Q.   All right. And then you just a minute ago with
      14   Agent Strope, you indicated that you got this stuff from
      15   Benetta. Well, that's not possible, because if this --
      16         A.   Okay, let me clarify. I never knew Benetta before
      17   the trouble with Lisa McPherson. I never knew
      18   Lisa McPherson before the trouble with Lisa McPherson.
      19         Q.   Right.
      20         A.   I don't -- I was -- I did talk to Benetta after
      21   Lisa McPherson went crazy. Whether that was in person or on
      22   the phone, I don't -- I know it was only on the phone,
      23   'cause --
      24         Q.   Well, that would have been prior to her death?
      25         A.   Yeah.


      1          Q.   To get this information in this report?
      2          A.   That's true, I did talk to Benetta.
      3          Q.   Unless it was the six hours between her death and
      4    when you typed this?
      5          A.   It's true, I did talk to Benetta before Lisa died.
      6          Q.   All right.
      7          A.   I didn't know Benetta before Lisa went crazy.
      8          Q.   The problem is with the semantics we're having
      9    here, you didn't know her but you talked to her?
      10         A.   I don't know. Maybe you want to ask me the
      11   question that's pertinent and I'll answer.
      12         Q.   I will.
      13         A.   Okay.
      14         Q.   This paragraph reads like she told you this
      15   information.
      16         A.   Yeah.
      17         Q.   Now, since you don't know how you got that
      18   information -- is that accurate?
      19              MR. LAURO: Well, but you think you got this
      20   information from Benetta. Is it possible you got it
      21   from her before Lisa died?
      22              THE WITNESS: Yes.
      23              MR. LAURO: Okay.
      24         Q.   See where that confuses me? I -- because I
      25   previously asked if you knew her or ever spoke to her, I


      1    believe, and the answer was no, just her husband at
      2    Morton Plant.
      3          A.   Yeah.
      4          Q.   See what I'm saying?
      5          A.   Okay.
      6          Q.   So all of a sudden this information pops into a
      7    December 5th report and you hadn't met her yet.
      8          A.   Right. I see -- I don't know.
      9          Q.   Do you see what I'm talking about?
      10         A.   I did have conversations with Benetta after Lisa
      11   went crazy. And according to this --
      12         Q.   So you did know her? Do we need to change that?
      13         A.   Okay.
      14         Q.   Now's the time to do it.
      15         A.   I'm glad we're going over it.
      16         Q.   We're under oath. That's a big, fat ambiguity in
      17   here. I'm trying to clear it up for you and your lawyer.
      18   They'd probably like it cleared up too.
      19         A.   Okay.
      20         Q.   If you'd like to retract that and clear it up now,
      21   do it now, 'cause I might go talk to Benetta. You never
      22   know who I might talk to next. So if there's a problem --
      23   'cause we're suspicious about things -- you should clear it
      24   up now.
      25         A. That's good, yeah.


      1          Q.   The answer now is what?
      2          A.   I never knew Benetta before Lisa went crazy. When
      3    Lisa went crazy, I talked to Benetta.
      4          Q.   If there's something on there that you didn't
      5    speak to Benetta until after the death, that would be
      6    incorrect, inaccurate?
      7          A.   Exactly.
      8          Q.   So we've straightened that up?
      9          A.   Yeah.
      10         Q.   So possibly these two paragraphs came from those
      11   conversations --
      12         A.   That's possible.
      13         Q.   -- during the week?
      14         A.   Yeah.
      15         Q.   All right.
      16              MR. McGARRY: I have nothing else.
      17              DETECTIVE SERGEANT ANDREWS: Just two quick
      18   ones.
      19                      EXAMINATION
      21         Q.   You referred to Social Reform Officer going to
      22   Morton Plant. Who was that?
      23         A.   That was Humberto Fontana.
      24         Q.   Did he work for OSA?
      25         A.   Yes.


      1          Q.   I think we left him out. We said Judy Fontana was
      2    in the office. Humberto was also in the office?
      3          A.   Yes.
      4          Q.   And quickly, I don't think -- when Agent Strope
      5    asked you about who you discussed your testimony with other
      6    than your attorney, you said yes, I have discussed it. Do
      7    you know who? Who was that with?
      8               MR. LAURO: I don't think she said she
      9    discussed her testimony, she discussed the underlying
      10   facts.
      11         A.   This subject, the subject matter.
      12         Q.   Who was that with?
      13         A.   Ben Shaw.
      14              MR. LAURO: You were interviewed by Church
      15   counsel as well at that point?
      16              THE WITNESS: Well, by you.
      17              MR. McGARRY: No, Sandy and Lee.
      18              THE WITNESS: Oh, Sandy, that's right.
      19         Q.   Okay. Was Ben Shaw after Sandy? Sandy first,
      20   then Ben Shaw sometime before you came here?
      21         A.   I don't remember.
      22         Q.   All right. Let me go this way: Ben Shaw is your
      23   boss now?
      24         A.   Yeah.
      25         Q.   Did you discuss this with him in the office?


      1          A.   Yeah.
      2          Q.   Okay. Tell me about the discussion.
      3          A.   Well, he had asked me about -- about documents,
      4    you know, what -- what documents I was familiar with in
      5    relation to this, did I see any of the -- the daily reports
      6    from the guys that were caring for her. I think that's
      7    basically it. I mean, I'm sure the conversation went longer
      8    than just that, but that's what I remember.
      9          Q.   Did you take the questioning by Ben Shaw to be
      10   that he was investigating this?
      11         A.   I don't know. Ben -- Ben works with the lawyers.
      12   I don't know what he -- what he does with -- with what I
      13   tell him.
      14         Q.   Okay.
      15              DETECTIVE SERGEANT ANDREWS: Thank you.
      16              MR. McGARRY: Thank you.
      17              THE WITNESS: Thanks.
      19    CONCLUDED AT 3:10 P.M.)


      1                      CERTIFICATE OF OATH
      3    STATE OF FLORIDA    )
           COUNTY OF PINELLAS  )
      5           I, the undersigned authority, certify that the
           aforesaid deponent personally appeared before me and was
      6    duly sworn.
      7           WITNESS my hand and official seal this _29th_  day
           of ___August___, 1997.

      10                       RUTH M. MARTIN, R.M.R.
                               Notary Public .- State of Florida
      11                       Commission No. CC 643284
                               Commission Expires: 4/29/2001
            STATE OF FLORIDA    )
      14    COUNTY OF PINELLAS  )
                       I, RUTH M. MARTIN, Registered Merit Reporter,
      16   certify that I was authorized to and did stenographically
           report the sworn statement of the aforenamed deponent and
      17   that the transcript is a true and complete record of my
           stenographic notes.
      18               I further certify that I am not a relative,
           employee, attorney, or counsel of any of the parties, nor am
      19   I a relative or employee of any of the parties' attorney or
           counsel connected with the action, nor am I financially
      20   interested in the action.

      21                   DATED this _29th_ day of __August___,
      22   1997.

      25                            RUTH M. MARTIN, RMR

                      KANABAY COURT REPORTERS - (813) 821-3320