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policies cannot change, the testimony that he can offer
is still relevant as to what was going on when he was
there as to what is going on here. Also, Judge, you will
have enough evidence before you in the form of testimony
and video tapes to show that what he can testify to is
still consistently carried out. So he is not testifying
necessarily in theories, but he is going to tailor down
his testimony to explain why what you see on video
happened, and the fact that it is so consistent with what
he testifies to in the written policies at the time that
there will be no question about the relevance.

THE COURT: But his testimony will consist
of the fact that he was a member of the Church of
Scientology from some period of time. That he knows what
the “Fair Game Policy” is. He is going to explain how he
knows what the “Fair Game Policy” is. And then is going
to explain what the policy is, right?

MS. RIVELLINI: Correct.

THE COURT: And that is really all he is
going to testify to, is that it in a nutshell?

MS. RIVELLINI: Well, not quite, Judge. I
asked that he be declared as an expert so that I can move
into my next area of questioning.

THE COURT: And I guess my question is,
why does he need to be an expert for purposes of the