Q. OKAY. IS THERE A POLICY REGARDING STORING PC FOLDERS FOR A PERSON WHO IS NOT ACTIVELY INVOLVED IN ANY AUDITING?
A. REGARDING STORING -- TO LOOK THAT UP TO SEE IF THERE'S AN EXACT POLICY ON IT.
Q. WOULD IT BE OFF POLICY TO DISPOSE OF THEM?
A. TO DISPOSE OF THE PC FOLDERS. YOU MEAN A SCIENTOLOGIST?
Q. YES.
A. OF A SCIENTOLOGIST?
Q. YES.
A. YES. THE IDEA IS TO KEEP THE FOLDERS COMPLETE.
Q. OKAY.
A. I MEAN, I'M HAVING TROUBLE EVEN GRAPPLING WITH THIS QUESTION.
Q. OKAY.
A. THE IDEA IS -- IT'S A TECHNICAL QUESTION YOU'RE ASKING, BUT GENERALLY IT'S -- IT'S H COB, THAT STANDS FOR HUBBARD COMMUNICATIONS OFFICE BULLETIN, AS OPPOSED TO HCO PL, WHICH MEANS HUBBARD COMMUNICATIONS POLICY LETTER, AND IT'S GENERALLY TECH, MEANING H
COB, AUDITING FOLDERS COMPLETENESS AND YOU DON'T OMIT SOMETHING FROM THEM.
THE WHOLE POINT OF IT, THAT A PERSON IS RECEIVING AUDITING, ALL THE INFORMATION IS SUPPOSED TO BE THERE FOR THE AUDITOR'S BENEFIT AND THE CASE SUPERVISOR'S BENEFIT, SO THAT A PERSON GETS STANDARD CASE SUPERSTITIONS. AN EXAMPLE, IF A PERSON HAD AN INJURY AND IT WASN'T NOTED IN THE FOLDER AND THE AUDITOR WASN'T AWARE OF IT AND THE CASE SUPERVISOR WASN'T AWARE OF IT AND ANY POTENTIAL IN-GRAMS COULDN'T BE STANDARD TECH BECAUSE ALL THE INFORMATION ON THIS PERSON WAS NOT AVAILABLE IN HIS FOLDER, SO THE IDEA IS
THAT THEY'RE COMPLETE. IS THAT WHAT YOU MEAN?
Q. THEY'RE COMPLETE AND MAINTAINED. THEY'RE NOT --
A. WHAT DO YOU MEAN "MAINTAINED," LIKE THEN --
Q. YES, THROWN AWAY. IS THERE ANY POLICY UNDER WHICH -- COUNSEL IS CONFERRING OR TALKING TO THE CLIENT IN THE MIDDLE OF THE QUESTION. IS THERE ANY POLICY UNDER WHICH PC FOLDERS ARE DESTROYED?
A. ANY POLICY UNDER WHICH THEY'RE DESTROYED?
Q. YES.
A. I DON'T KNOW IF THERE'S A POLICY ON THAT EITHER WAY.
Q. IN OTHER WORDS, AS FAR AS -- IS IT YOUR TESTIMONY THAT IT'S PERFECTLY ACCEPTABLE TO DESTROY THE PC FOLDERS?
A. WELL, LET'S --
MR. HERTZBERG: HE JUST TESTIFIED -- ONE SECOND. HE JUST TESTIFIED THAT HE DIDN'T KNOW OF WHETHER THERE WAS A POLICY ONE WAY OR THE OTHER. I FIND THE FOLLOW-UP QUESTION SOMEWHAT DISINGENUOUS, BUT GO AHEAD. WHY DON'T YOU REREAD THE FOLLOW-UP QUESTION, THE WAY IT'S FRAMED.
MS. PLEVIN: LET ME CHANGE IT.
THE WITNESS: OKAY.
BY MS. PLEVIN:
Q. WOULD A MISSION THAT DESTROYED PC FOLDERS, FOR AN INACCURATE PC, BE OPERATING OFF POLICY IN DESTROYING THE PC FOLDERS? A. WHAT MISSION?
Q. ANY MISSION.
A. A MISSION?
Q. YES.
A. YOU MEAN -- WHAT SORT OF MISSION, A STEWARD MISSION OR MISSION?
Q. AN SMI MISSION. THEY MAINTAINED PC FOLDERS FOR THEIR PCS?
A. AND THERE'S A PC THAT'S A SCIENTOLOGIST?
Q. THAT'S INACTIVE.
A. WHAT DO YOU MEAN, "INACTIVE"?
Q. NOT CURRENTLY BEING AUDITED.
A. IF THE PERSON WAS A SCIENTOLOGIST IN GOOD STANDING, I DON'T SEE WHY THEY WOULD DO THAT. I DON'T KNOW -- IS THAT WHAT YOU'RE TALKING ABOUT? Q. YES.
A. A SCIENTOLOGIST?
Q. YES.
A. I THINK I'VE ANSWERED IT. THEY'RE GENERALLY MAINTAINED -- PRE-CLEAR FOLDERS FOR SCIENTOLOGISTS IN GOOD STANDING.
Q. WHAT ABOUT A PERSON WHO IS NOT IN GOOD STANDING, IS THERE A POLICY REGARDING --
A. YOU MEAN A SQUIRREL? IS THAT WHAT YOU MEAN, A SQUIRREL OR SOMEBODY WHO IS EXPELLED FROM THE CHURCH? IS THAT WHAT YOU MEAN?
Q. YES.
A. I DON'T THINK THERE'S ANY POLICY ON IT ONE WAY OR ANOTHER. THE ONLY POLICY I KNOW THAT A PERSON WHO IS EXPELLED FROM THE CHURCH, WHO IS A SQUIRREL, HAS GENERALLY REJECTED THE WHOLE GROUP, SO I DON'T KNOW. IT WOULD BE CONJECTURE AT THIS POINT WHETHER SOMEBODY DID IT OR NOT. YOU'RE ASKING A FINE TECHNICAL POINT. NO POLICY POPS INTO MY MIND ON THAT SUBJECT, NO.
Q. WELL, ISN'T IT POLICY THAT A PERSON WHO HAS BECOME AN SP OR HAS REJECTED THE CHURCH OR BECOME A SQUIRREL, MIGHT, IN FACT, DO STEPS TO GET BACK INTO THE CHURCH BY APPROACHING THE PROPER TERMINAL?
A. THAT'S RIGHT. THE DOOR IS ALWAYS OPEN A CRACK, EVEN IF JUST A TINY, WEENY BIT, THE DOOR IS ALWAYS OPEN, THAT'S RIGHT.
Q. AND IF THAT PERSON DID SO, WHAT YOUR ANSWER SUGGESTS TO ME IS THAT THEY COULD DO SO AND COME BACK INTO THE CHURCH AND THEIR PC FOLDER MIGHT HAVE BEEN DESTROYED IN THE INTERIM?
A. I DIDN'T SUGGEST ANYTHING OF THE SORT. ARE YOU ASKING ME A TECHNICAL QUESTION? MAYBE I DON'T UNDERSTAND WHAT YOU'RE DOING. YOU'RE ASKING ME ABOUT AUDITING FOLDERS AND WHY THEY'RE COMPLETE. I THOUGHT I ANSWERED THAT. Q. NO, NO. I'M ASKING YOU ABOUT THE DESTRUCTION OF PC FOLDERS.
A. ABOUT PC FOLDERS BEING DESTROYED. OKAY.
Q. FOR SQUIRRELS, SPS, WHOMEVER IS NOT CURRENTLY IN GOOD STANDING.
A. I GET IT.
Q. ARE YOU AWARE OF ANY CIRCUMSTANCES UNDER WHICH PC FOLDERS ARE REGULARLY DESTROYED?
A. NO.
Q. ARE YOU AWARE OF ANY PC FOLDERS EVER HAVING BEEN DESTROYED?
(CONFERENCE BETWEEN COUNSEL AND WITNESS.)
THE WITNESS: I DID HEAR THAT SOMEBODY DESTROYED PC FOLDERS OF INDIVIDUALS.
BY MS. PLEVIN:
Q. DO YOU KNOW WHO?
A. I HEARD THAT VICKY AZNARAN.
Q. AND IS THAT THE ONLY INSTANCE YOU'VE EVER HEARD THAT PC FOLDERS WERE DESTROYED?
A. WHAT NOW?
Q. IS THAT THE ONLY INSTANCE THAT YOU EVER HEARD OF THAT PC FOLDERS WERE DESTROYED?
A. YES. AND I ONLY HEARD THAT IT WAS DONE. I DIDN'T -- I DIDN'T SEE THIS WITH MY EYES, BUT THAT'S WHAT I HEARD.
Q. DID YOU HEAR THAT SHE WAS ORDERED TO DO THAT?
A. NO, ABSOLUTELY NOT.
Q. HAD YOU NEVER HEARD THAT NORMAN STARKEY ORDERED HER TO DO THAT?
A. NO.
Q. YOU NEVER ORDERED HER TO DO THAT?
A. NO.
Q. DO YOU KNOW WHOSE FOLDERS SHE'S ALLEGED TO HAVE DESTROYED?
A. SPECIFICALLY?
Q. YES.
A. NO.
Q. DO YOU KNOW WHEN?
A. I'LL TELL YOU WHEN I HEARD THIS, I THINK. I WOULD SAY 1984, 1985, AT A GUESS.
Q. DURING THE ARMSTRONG TRIAL -- DURING THE ARMSTRONG PROCEEDINGS?
A. NO. ACTUALLY I HADN'T CONNECTED IT WITH TEAT, NO. MAYBE -- MAYBE YOU'RE CORRECT ABOUT -- I DON'T KNOW. IT DOESN'T STICK OUT IN MY MIND TO DATE.
MR. HERTZBERG: LET ME --
THE WITNESS: I DON'T CONNECT THINGS BY THE WAY -- OKAY.
MR. HERTZBERG: LET ME JUST MAKE MY PERIODIC OBSERVATION. I'M NOT SURE HOW THIS RELATES TO MR. CORYDON'S CLAIMS. I'M NOT SPECIFICALLY AWARE OF ANY CLAIM BY MR. CORYDON THAT HIS PC FOLDER WAS DESTROYED, YOU KNOW. I'M NOT GOING TO OBJECT TO HIS ANSWERING THESE QUESTIONS FOR THE MOMENT. BUT LET'S MOVE ON.
BY MS. PLEVIN:
Q. IS RTC, IN TERMS OF ITS RESPONSIBILITIES, DOES IT HAVE THE AUTHORITY TO TRACK DOWN A MISSING PC FOLDER?
A. THE AUTHORITY?
Q. YES. COULD IT, YOU KNOW, PUT A MISSION IN, SO TO SPEAK, TO FIND OUT WHAT HAPPENED TO CERTAIN PC FOLDERS IF THEY WERE MISSING, AND NOT KNOWN SPECIFICALLY TO HAVE BEEN DESTROYED? A. THE AUTHORITY -- WELL, OKAY. LET ME CLARIFY THAT. YES, BUT SO DOES THE DIRECTOR OF TECH SERVICES OF ANY ORGANIZATION IN THE WORLD.
Q. OKAY.
A. DO YOU SEE WHAT I MEAN?
Q. YES, OKAY. SO DO YOU HAPPEN TO KNOW WHETHER, IN RESPONSE TO DISCOVERY IN THIS CASE, RTC DID A SEARCH TO FIND OUT WHAT HAPPENED TO THE PC FOLDERS OF BENT CORYDON?
A. ALL RIGHT.
MS. PLEVIN: CONSULTING WITH COUNSEL.
(CONFERENCE BETWEEN COUNSEL AND WITNESS.)
MS. PLEVIN: CONSULTING WITH THREE COUNSEL.
MR. DRESCHER: HE'S TALKING TO HIS COUNSEL PERSONALLY AND COUNSEL FOR RTC, OF WHICH HE'S CHAIRMAN OF THE BOARD. IS THAT OKAY WITH YOU?
MS. PLEVIN: I COULDN'T STOP IT.
THE WITNESS: CAN YOU ASK ME THE QUESTION AGAIN?
MS. PLEVIN: PLEASE READ THE QUESTION BACK.
(RECORD READ.)
THE WITNESS: IN RESPONSE TO A DOCUMENT REQUEST?
BY MS. PLEVIN:
Q. YES.
A. I KNOW THAT -- HERE'S WHERE I KNOW THAT A SEARCH WAS DONE THROUGH RTC FOR BENT'S FOLDERS AND THEY WEREN'T THERE.
Q. THEY WEREN'T WHERE?
A. AT RTC.
Q. WHERE WOULD THEY HAVE BEEN?
MR. HERTZBERG: WELL, WAIT A MINUTE. WAIT A MINUTE. HOW COULD -- HOW COULD HE KNOW WHERE IN THE WHOLE -- ON THE PLANET THEY MIGHT BE OTHER THAN RTC? I DON'T UNDERSTAND THAT QUESTION, "WHERE WOULD THEY HAVE BEEN." FIRST IT ASSUMES A FACT NOT IN EVIDENCE THAT THEY EXIST, AND HOW COULD HE POSSIBLY ANSWER --
MS. PLEVIN: MR. MISCAVIGE --
MR. HERTZBERG: WHERE WOULD THEY BE OTHER THAN AT RTC?
(CONFERENCE BETWEEN COUNSEL AND WITNESS.)
MR. DRESCHER: I'LL ADD MY OWN OBJECTIONS. THE QUESTION WAS VAGUE AND AMBIGUOUS, UNINTELLIGIBLE, ASSUMES FACTS NOT IN EVIDENCE, CALLS FOR SPECULATION AND CONJECTURE. MR. HELLER: I JOIN IN THE OBJECTIONS.
BY MS. PLEVIN:
Q. IS THERE SOMETHING YOU WANT TO ADD?
A. NO. GO AHEAD. ASK YOUR QUESTIONS.
Q. MR. CORYDON WAS A SCIENTOLOGIST FOR A NUMBER OF YEARS AND, AS SUCH, HAD A PC FOLDER. HIS LAST POSITION IN SCIENTOLOGY WAS AS A MISSION HOLDER AT THE MISSION OF RIVERSIDE, AND I BELIEVE HIS LAST AUDITING WAS DONE AT CLEARWATER. A. RIGHT, OKAY. I DON'T KNOW THAT, BUT I'LL ASSUME THAT.
Q. LET'S ASSUME THAT. WHERE WOULD HIS FILES LAST HAVE BEEN, TO THE BEST OF YOUR KNOWLEDGE?
MR. DRESCHER: OBJECTION. INCOMPLETE HYPOTHETICAL.
MR. HERTZBERG: DO YOU WANT HIM TO SPECULATE?
BY MS. PLEVIN:
Q. WELL, MR. MISCAVIGE IS CHAIRMAN OF THE BOARD OF RTC. RTC, PURSUANT TO DOCUMENTS AUTHENTICATED IN THIS ACTION BY CSI AND OTHERS, IS THE SENIOR MOST ENTITY IN SCIENTOLOGY REGARDING THE TECH; PC FOLDERS ARE AT THE HEART OF TECH; IS THAT RIGHT? A. AT THE HEART OF IT? HCOBS, LECTURES, BOOKS ARE AT THE HEART.
Q. IT WOULD SEEM AS CHAIRMAN OF THE BOARD OF RTC, YOU MIGHT HAVE SOME KNOWLEDGE AS TO WHERE THOSE PC FOLDERS WOULD HAVE NORMALLY BEEN IN THE ORDINARY COURSE?
MR. HERTZBERG: OKAY. WAIT A MINUTE. THE PROBLEM I HAVE WITH THE FORMULATION IS IT'S IRRELEVANT WHAT IT WOULD SEEM TO YOU. WHY DON'T YOU ASK HIM IF HE KNOWS WHERE THEY ARE. THAT MAY SORT OF BE MORE PRODUCTIVE, IN MY VIEW.
MS. PLEVIN: I WILL, IN MY OWN GOOD TIME.
MR. HERTZBERG: IF HE KNOWS. BY MS. PLEVIN:
Q. DO YOU KNOW, BASED UPON THE FACTS AS I STATED THEM TO YOU, WHERE MR. CORYDON'S LAST AUDITING WAS IN CLEARWATER, AND WHERE HE WAS A MISSION HOLDER, AND WHERE HE WAS EXPELLED, WHERE IN THE NORMAL COURSE THOSE --
A. IS THAT WHERE HE WAS EXPELLED?
Q. PARDON?
A. IS THAT WHERE HE WAS EXPELLED?
Q. NO. IT WAS AFTER HE RETURNED TO MISSION OF RIVERSIDE. WHERE IN THE NORMAL COURSE WOULD THOSE PC FOLDERS HAVE BEEN STORED?
A. THEN? I DON'T KNOW WHAT HAPPENED IN BETWEEN THERE. I MEAN, I CAN ONLY TELL YOU WHEN HE WAS GETTING AUDITING AT FLAG, THEY SHOULD HAVE BEEN THERE, AND I WOULD ASSUME THAT THEY WERE.
Q. AND THEN --
A. WHAT WAS THE TIME PERIOD INTERVENING THAT? I DON'T KNOW WHAT ELSE HAPPENED. I DON'T KNOW.
Q. BASED ON WHAT YOU SAID PREVIOUSLY, ONCE A PERSON IS AUDITED AT FLAG, THEY'RE NOT AUDITED AT MISSIONS?
A. THAT'S POLICY. THAT IS WHAT I SAID. I DON'T -- I CAN'T ANSWER FOR WHAT WAS HAPPENING AT THOSE MISSIONS IN THOSE DAYS.
Q. ALL RIGHT. BUT BASED ON YOUR EXPERIENCE IN SCIENTOLOGY, YOUR VARIOUS POSITIONS AND YOUR POSITION AS CHAIRMAN OF THE BOARD OF RELIGIOUS TECHNOLOGY CENTER, CAN YOU GIVE ME YOUR BEST UNDERSTANDING AS TO WHERE, UNDER THAT FACT PATTERN, MR. CORYDON'S PC FOLDERS WOULD NORMALLY HAVE BEEN WHEN HE LEFT SCIENTOLOGY IN 19827
A. UNDER THAT FACT PATTERN? Q. YES.
A. I GUESS FLAG.
Q. OKAY.
A. WITH THOSE FACTS AND NOT ADDING ANYTHING ELSE TO IT?
Q. RIGHT.
A. OKAY.
Q. WOULD THEY HAVE BEEN MOVED FROM FLAG, TO THE BEST OF YOUR KNOWLEDGE, SUBSEQUENT TO MR. CORYDON'S LEAVING SCIENTOLOGY? MR. HERTZBERG: I DON'T SEE HOW ANYONE CAN ANSWER THAT QUESTION.
MR. DRESCHER: I OBJECT ON THE BASIS OF SPECULATION.
MR. HERTZBERG: IT ASKS FOR GUESSWORK AND SPECULATION.
MS, PLEVIN: NOT GUESSWORK FROM THE CHAIRMAN OF THE BOARD OF RELIGIOUS TECHNOLOGY CENTER.
MR. HERTZBERG: I'M SORRY. WHAT THE PROBLEM HERE IS --
MS. PLEVIN: ARE YOU INSTRUCTING HIM NOT TO ANSWER?
MR. HERTZBERG: NO, WAIT A MINUTE, PLEASE, JUST A SECOND, PLEASE. YOU'RE IMPUGNING SOME OMNIPOTENT KNOWLEDGE BECAUSE MR. MISCAVIGE HAPPENS TO HOLD A CORPORATE BOARD POSITION WITH A CERTAIN CORPORATION, THAT HE CAN GUESS WHERE MR. CORYDON'S FILES WOULD HAVE
ENDED UP IN A PERIOD SUBSEQUENT TO 1982, WITHOUT HIS KNOWING ANY OTHER FACTS ABOUT ANYTHING ELSE THAT MAY HAVE HAPPENED, WHICH COULD HAVE AFFECTED THE FILE OR WHETHER -- WHO WAS INVOLVED WITH THE FILE AND WHAT THEY MAY OR MAY NOT HAVE DONE ON OR OFF POLICY.
MS. PLEVIN: FRANKLY I'M SEEKING
MR. MISCAVIGE'S ASSISTANCE AS CHAIRMAN OF THE BOARD OF RTC. RTC HAS SAID, CSI HAS SAID, CSC HAS SAID AND SMI HAS SAID, "WE DON'T HAVE THESE FILES. WE DON'T KNOW ANYTHING ABOUT THEM." MR. HERTZBERG: HE APPARENTLY DOESN'T EITHER.
THE WITNESS: THAT'S RIGHT. THAT'S AN ACCURATE STATEMENT.
MR. DRESCHER: I'LL OBJECT TO THE CHARACTERIZATION THAT YOU MADE ABOUT WHAT THE DISCOVERY RESPONSES WERE; THE DISCOVERY RESPONSES WERE FOR EACH OF THOSE FOUR CLAIMS, "WE DON'T KNOW; WE DON'T HAVE THEM," PERIOD, NOT THE WAY YOU CHARACTERIZED IT. BY MS. PLEVIN:
Q. MR. MISCAVIGE --
A. YES.
Q. -- HAVE YOU EVER SEEN THIS BOOKLET, THE COMMAND CHANNELS OF SCIENTOLOGY?
A. NOT THAT COPY, BUT, YES.
Q. OKAY. YOU'VE SEEN THAT DOCUMENT?
MR. HERTZBERG: DO YOU HAVE AN EXTRA FOR ME?
MS. PLEVIN: I HAVE SEVERAL.
THE WITNESS: XEROXES OR ONES LIKE THIS?
MS. PLEVIN: XEROXES.
THE WITNESS: YOU CAN'T SEE THE COLOR THEN.
MS. PLEVIN: I'M SORRY.
MR. DRESCHER: I HAVE MY COPY HERE. WE CAN ALL SHARE.
BY MS. PLEVIN:
Q. YOU'RE FAMILIAR WITH THIS DOCUMENT?
A. YES.
Q. DOES THIS DOCUMENT --
A. IF YOU WANT TO ASK ME QUESTIONS ABOUT IT, I'LL READ THE SECTIONS OR WHATEVER, BUT YES, SURE.
Q. THIS DOCUMENT WAS ISSUED IN 1988 BY CSI; IS THAT RIGHT?
A. WAS IT '88 --
Q. I BELIEVE THAT'S THE COPYRIGHT DATE ON IT.
A. '88, I GUESS SO, YES.
Q. AND AT THAT TIME DID IT, TO THE BEST OF YOUR KNOWLEDGE, ACCURATELY REFLECT THE REPORT LINES AND COMMAND CHANNELS OF SCIENTOLOGY?
A. THE COMMAND CHANNELS OF SCIENTOLOGY. IT'S NOT CALLED THE REPORT LINES AND COMMAND CHANNELS. IT'S CALLED THE COMMAND CHANNELS, YES.
Q. HAVE THERE BEEN ANY SUBSTANTIAL CHANGES SINCE THAT TIME?
A. LET ME JUST GO THROUGH THIS. SUBSTANTIAL, NO. IT SHOULD BE GENERALLY ACCURATE. IF YOU WANT ME TO NITPICK IT.
Q. NO. DID YOU PARTICIPATE IN THE PREPARATION OF THIS DOCUMENT?
A. WHAT DO YOU MEAN BY "PARTICIPATE"?
Q. DID YOU DRAFT ANY SECTIONS?
A. DRAFT -- NO, I DIDN'T DRAFT ANY SECTIONS.
Q. DID YOU REVIEW ANY DRAFTS OF THESE SECTIONS?
A. YES.
Q. DID YOU APPROVE THE FINAL DOCUMENT BEFORE IT WAS PRINTED?
A. I'M NOT SURE. I MEAN, I DID SEE IT IN A DRAFT FORM. I DON'T KNOW IF I SAW THE FINAL DRAFT BEFORE IT WAS PRINTED.
Q. DID YOU APPROVE THE DRAFT THAT YOU SAW BEFORE IT WAS SENT BACK TO BE PUT INTO THE FINAL DRAFT?
A. YES.
Q. WHO WAS THE EDITOR?
MR. HERTZBERG: JUST SO THE RECORD IS CLEAR, I'M NOT SURE THAT MR. MISCAVIGE SAID THAT THE DRAFT THAT HE APPROVED WAS THE ONE IMMEDIATELY PRECEDING THE FINAL DRAFT. THE WITNESS: I SAW IT IN ROUGH. THAT ANSWERS YOUR QUESTION, I THINK.
BY MS. PLEVIN:
Q. OKAY.
A. BY THE WAY, IN REGARDS TO "APPROVE," I DON'T KNOW WHAT YOU MEAN BY "APPROVE." I MEAN, I LOOKED AT IT AND READ IT.
Q. DID YOU MAKE ANY CHANGES?
A. MAYBE, YOU KNOW, A WORDING, YOU KNOW, THE WAY A SENTENCE WAS STRUCTURED.
Q. DO YOU KNOW WHO WAS THE PERSON IN CHARGE OF THE OVERALL COMPILATION AND WRITING OF THAT DOCUMENT?
A. NO, NO.
Q. I'M SORRY?
A. NO.
Q. HAVE YOU EVER MET BENT CORYDON, OUTSIDE OF THIS ROOM?
MR. DRESCHER: WHAT WAS THE QUESTION?
THE WITNESS: I DON'T THINK SO.
BY MS. PLEVIN:
Q. DID YOU EVER HEAR HIS NAME PRIOR TO TODAY?
A. YES.
Q. DID YOU EVER HAVE ANY OCCASION TO DISCUSS MR. CORYDON WITH ANYONE PRIOR TO TODAY, APART FROM YOUR ATTORNEY?
MR. HELLER: OTHER THAN YOUR ATTORNEYS.
MS. PLEVIN: THAT'S WHAT I SAID.
MR. HELLER: I DIDN'T HEAR THAT PART. I'M SORRY.
THE WITNESS: "DISCUSS." YOU MEAN -- WHAT DO YOU MEAN BY "DISCUSS"?
BY MS. PLEVIN:
Q. TALK ABOUT HIM.
A. ABOUT BENT?
Q. YES.
A. I DON'T KNOW THAT I'VE EVER TALKED ABOUT BENT.
Q. WITH ANYONE.
A. ABOUT HIM?
Q. YES.
MR. HERTZBERG: OTHER THAN THE ATTORNEYS?
MS. PLEVIN: OTHER THAN THE ATTORNEYS, YES.
THE WITNESS: I BELIEVE IT'S INCLUSIVE OF ATTORNEYS. TALKING ABOUT BENT --
BY MS. PLEVIN:
Q. YOU'VE NEVER TALKED ABOUT BENT WITH YOUR ATTORNEYS; ARE YOU SUGGESTING THAT?
MR. HERTZBERG: MAYBE THERE'S A MISUNDERSTANDING ABOUT THE WORD "ABOUT."
BY MS. PLEVIN:
Q. HAVE YOU EVER --
(CONFERENCE BETWEEN COUNSEL AND WITNESS.)
THE WITNESS: ALL RIGHT. I GET WHAT YOU'RE SAYING. YOU MEAN THE DISCUSSIONS WERE ABOUT THE CASE?
BY MS. PLEVIN:
Q. THIS CASE.
A. YES, SURE.
Q. DID YOU EVER CONFER WITH ANYONE ABOUT ANY OTHER LAWSUITS MR. CORYDON HAS BEEN INVOLVED IN WITH THE CHURCH OF SCIENTOLOGY OR ANY ENTITIES OR INDIVIDUALS IN THE CHURCH OF SCIENTOLOGY, OTHER THAN YOUR ATTORNEYS?
A. YES.
Q. WITH WHOM HAVE YOU HAD SUCH DISCUSSIONS?
A. MARTY, POSSIBLY VICKY AZNARAN, MAYBE -- WE'RE TALKING LIKE I KNEW HE HAD A LAWSUIT, OKAY. IS THAT WHAT YOU'RE ASKING ME?
Q. YES.
A. WHAT EXACTLY WERE YOU ASKING ME?
Q. WELL, I'M TRYING TO FIND OUT, IN GENERAL, BUT NOT WITH THAT SPECIFIC QUESTION, TRYING TO FIND OUT THE EXTENT OF YOUR KNOWLEDGE ABOUT MR. CORYDON PRIOR TO THIS LAWSUIT.
A. NOT MUCH.
MR. HELLER: YOU ASKED A SPECIFIC QUESTION AND THE DEPONENT ASKED YOU WHAT WAS THE SPECIFIC QUESTION YOU WERE ASKING, NOT GENERALLY.
MS. PLEVIN: ALL RIGHT, YES, I'M GOING TO GET BACK TO IT.
Q. I'M TRYING TO FIND OUT WHAT YOU DID KNOW ABOUT MR. CORYDON PRIOR TO THE INITIATION OF THIS LAWSUIT?
MR. LIEBERMAN: THE QUESTION WAS ABOUT ANY LAWSUITS. THAT WAS WHAT THE QUESTION WAS.
MS. PLEVIN: I KNOW THAT'S WHAT THE QUESTION WAS.
MR. HERTZBERG: SO WE HAVE A NEW QUESTION?
MS. PLEVIN: YES, WE HAVE A NEW QUESTION.
MR. HERTZBERG: WHEN YOU SAY "THIS LAWSUIT," YOU'RE TALKING ABOUT THE LAWSUIT THAT WE'RE INVOLVED, IN WITH RESPECT TO THIS DEPOSITION?
MS. PLEVIN: THAT'S RIGHT.
MR. HERTZBERG: OKAY. IS THERE A PENDING QUESTION?
MS. PLEVIN: YES.
MR. HERTZBERG: WHAT IS THE PENDING QUESTION?
MS. PLEVIN: OKAY.
Q. SO TO THE BEST OF YOUR KNOWLEDGE, THE ONLY PEOPLE YOU'VE EVER SPOKEN WITH ABOUT MR. CORYDON ARE MARTY RATHMAN AND VICKY AZNARAN?
A. OKAY. LET ME CLARIFY WHAT "ABOUT" MEANS.
Q. OKAY.
MR. HERTZBERG: NO. THAT IS A MISSTATEMENT OF THE RECORD AND HIS TESTIMONY. HE SPOKE EARLIER ABOUT THE LITIGATION.
MS. PLEVIN: RIGHT. ALL RIGHT.
MR. HERTZBERG: AND THAT'S WHAT HE ANSWERED WHEN HE SPOKE ABOUT MARTY RATHMAN AND POSSIBLY VICKY AZNARAN.
BY MS. PLEVIN:
Q. TO THE EXTENT THAT MR. MISCAVIGE STATES THAT HE'S NEVER HAD ANY OTHER CONVERSATIONS OTHER THAN ABOUT THE LITIGATION -- PERHAPS I AM ABBREVIATING IT.
A. NO. I GUESS MY CONCERN IS YOUR WORD "ABOUT."
Q. REFERRING TO, HAVING THE SUBJECT MATTER OF, MR. --
A. I THOUGHT YOU WERE TAKING ABOUT, YOU KNOW, IN REFERENCE IS A DIFFERENT TERM. YOU MEAN ANY TIME I'VE EVER -- IN OTHER WORDS, THE WORD -- THAT I WAS EITHER LISTENING OR SPEAKING THE WORDS "BENT CORYDON" WERE MENTIONED?
O. YES.
A. OH, OKAY. YEAH. MAYBE TEN TIMES FROM 1981 TO THE PRESENT TIME.
Q. OKAY. AND WITH WHOM HAVE YOU HAD THOSE DISCUSSIONS, APART FROM YOUR ATTORNEYS?
A. DAVID MAYO, BILL FRANKS, ALAN WALTERS, DEAN STOKES, INCLUDE MARTY AND VICKY, WHICH I ALREADY MENTIONED. STEVE WILLETT. THAT'S WHAT I CAN REMEMBER.
Q. OKAY. LET'S TAKE THEM ONE AT A TIME, AND YOUR CONVERSATIONS ONE AT A TIME, TO THE BEST THAT YOU CAN RECALL THEM.
A. OKAY.
Q. LET'S START WITH DAVID MAYO. TO THE BEST OF YOUR RECOLLECTION, DID YOU HAVE MORE THAN ONE CONVERSATION WITH DAVID MAYO REGARDING, OR ABOUT, BENT CORYDON?
A. MAYBE THREE.
Q. LET'S TAKE THE FIRST ONE. DO YOU RECALL WHEN THAT WAS?
A. THAT WAS IN 1981, SOMETIME, BELIEVE THE FALL OF '81.
Q. DO YOU RECALL WHERE THAT TOOK PLACE?
A. AT GILMAN HOT SPRINGS.
Q. AND WAS THIS IN PERSON?
A. YES.
Q. AND TO THE BEST OF YOUR RECOLLECTION, WHAT WAS THE SUBSTANCE OF THE COMMUNICATION REGARDING MR. CORYDON?
A. DAVID MAYO SAID TO ME THAT HE MET BENT CORYDON IN TOWN, OR SAW HIM, AND THAT BENT CORYDON KNEW WE LIVED AT GILMAN HOT SPRINGS AND I DIDN'T EVEN KNOW WHO BENT CORYDON WAS AND I TOLD HIM SO, "I DON'T KNOW WHO YOU'RE TALKING ABOUT." AND HE SAID, "HE'S A NEW ZEALANDER, HE'S RIVERSIDE," OR SOMETHING OF THAT NATURE. I DIDN'T KNOW WHO HE WAS. SO THAT WAS THE FIRST CONVERSATION. HE BROUGHT IT UP TO ME AS IF IT WAS OF INTEREST TO ME, AND IT DIDN'T MEAN ANYTHING TO ME.
Q. THIS MAY BE OBVIOUS, AND I THINK IT'S CLEAR FROM YOUR STATEMENT, BUT I JUST WANT TO PIN IT DOWN. WHEN YOU SAY THAT HE SAID TO YOU THAT "BENT CORYDON KNEW THAT WE LIVED AT GILMAN HOT SPRINGS," WOULD YOU --
A. THAT THERE WAS A PROPERTY THERE THAT WAS RELATED TO SCIENTOLOGY.
Q. OKAY. AND WAS THAT THE SUM AND SUBSTANCE OF THAT FIRST COMMUNICATION?
A. THAT WAS IT ON THAT ONE, YES. THAT MIGHT HAVE EVEN BEEN THE SUMMER OR EARLIER. I DON'T KNOW. I BELIEVE IT WAS IN 1981. IT COULD HAVE BEEN IN 1980. I WAS TRYING TO THINK OF IT. I WAS TRYING TO THINK THE FIRST TIME I HEARD BENT'S NAME. Q. DID YOU RESPOND TO THAT?
A. I SAID, "I DON'T KNOW WHO YOU'RE TALKING ABOUT."
Q. DID MR. MAYO EXPLAIN WHO HE WAS TALKING ABOUT?
A. YEAH, HE DID EXPLAIN. THE POINT OF THE CONVERSATION WAS IT WAS JUST GENERALLY LOW PROFILE THAT WE WERE LIVING THERE. THAT WAS THE POINT. IT WASN'T THAT SIGNIFICANT TO ME. HE SAID HE WAS A SCIENTOLOGIST, OF COURSE, YES, SO I MEAN THAT GOT EXPLAINED TO ME THEN. AND THAT WAS ABOUT IT.
Q. OKAY. DID YOU DO ANYTHING AS A RESULT OF THAT CONVERSATION? A. NO.
Q. DID YOU MAKE ANY NOTES AS A RESULT OF THAT CONVERSATION?
A. NO, I DIDN'T.
Q. DID YOU ASK MR. MAYO TO DO ANYTHING AS A RESULT OF THAT CONVERSATION?
A. NO, I DIDN'T. I -- NO. I -- I STILL DON'T KNOW WHAT THE POINT OF IT WAS, OKAY, SO NO. Q. WAS THIS BEFORE OR AFTER MR. MAYO WAS REMOVED FROM HIS POSITION AS CS INT?
A. SENIOR CS INT.
Q. SENIOR CS INT.
A. BEFORE.
Q. AND --
A. ALL THREE OF THESE CONVERSATIONS WERE.
Q. WERE BEFORE?
A. YES.
Q. OKAY. WHEN WAS THE NEXT CONVERSATION WITH MR. MAYO?
A. OCTOBER OR NOVEMBER OF 1981, DURING -- CONCURRENT WITH THE TIME PERIOD OF THE MISSION BOLDER MUTINY OF FLAG LAND BASE. Q. AND WAS THAT WHERE THE CONVERSATION TOOK PLACE?
A. NO, IT ISN'T.
Q. WHERE DID THE CONVERSATION TAKE PLACE?
A. IN AN AIRPLANE.
Q. YOU WERE SITTING WITH MR. MAYO, I ASSUME?
A. YES, I WAS.
Q. AND WHAT WAS THE CONTENT OF THAT CONVERSATION?
A. THE CONTENT OF THAT CONVERSATION IS THAT WE HEARD THAT THERE WAS MISSION HOLDERS AT THE FLAG LAND BASE WHO WERE THERE ON A CONFERENCE WHO HAD TURNED THE CONFERENCE GENERALLY INTO WHAT WAS TERMED A MUTINY, AND THAT THE REPORTS THAT WE'D RECEIVED IS THAT
THEY'D BEEN DRINKING QUITE HEAVILY, THAT THERE WAS A COMMENT ABOUT COMING OUT TO GILMAN HOT STRINGS WITH BASEBALL BATS TO BEAT UP -- AND THAT THE RING LEADERS OF THIS WERE BASICALLY TRYING TO SUBVERT THE EXECUTIVE DIRECTOR AND NATIONAL AT THAT TIME, BILL
FRANKS, THAT THEY WANTED TO TAKE ALL THE FINANCES AND ALL THE RESERVES OF THE CHURCH FOR THEIR OWN BENEFITS, THEY WANTED THEM DIVIDED UP, AND BENT'S NAME WAS BROUGHT UP IN THAT CONVERSATION, TO WHICH DAVID EXPLAINED -- DAVID MAYO EXPLAINED TO ME -- THAT HE HAD SPOKEN TO BENT, AND IT'S NO BIG DEAL TO BENT, HE'S COMPLETELY MONEY MOTIVATED. WHAT BENT WANTS TO BE HAPPY IS MILLIONS OF DOLLARS. HE JUST WANTS MONEY. THERE'S NO PRINCIPLE HE'S FIGHTING OVER. HE'S JUST INTERESTED IN A LOT OF MONEY. THAT WAS THE CONTEXT OF THAT CONVERSATION.
Q. DID HE ATTRIBUTE TO MR. CORYDON THE COMMENTS ABOUT TAKING BASEBALL BATS TO GILMAN HOT SPRINGS OR ANY SUCH --
A. I THINK HE MIGHT HAVE SAID THAT BENT WAS INVOLVED IN THAT, YES.
Q. DID HE STATE THAT MR. CORYDON WAS DRINKING HEAVILY?
A. NO. I THINK HE STATED THAT HE -- THAT BENT HAD STATED TO HIM OR -- THAT DAVID HAD BEEN THERE OR WHATEVER. HE SEEMED TO HAVE SOME KNOWLEDGE OF A CONVERSATION, WHAT I REMEMBER -- THE MONEY PART WAS ATTRIBUTED TO BENT IN A CONVERSATION WITH DAVID. THAT'S WHAT I PARTICULARLY REMEMBER.
I DON'T KNOW THAT THE BASEBALL BATS WAS ATTRIBUTED AS A CONVERSATION WITH BENT, AS OPPOSED TO HE WAS INVOLVED IN IT. THE MONEY WAS DEFINITELY SOMETHING RELAYED AS A CONVERSATION WITH BENT AND THE FINAL OUTCOME OF IT WAS, "I WANT MONEY.". Q. NOW, I'M CONFUSED, MR. MISCAVIGE, BY YOUR TESTIMONY. ARE YOU SAYING THAT MR. MAYO HAD A CONVERSATION WITH MR. CORYDON REGARDING THE MISSION HOLDERS MEETING IN WHICH MR. CORYDON HAD SUMMARIZED THESE --
A. FROM WHAT I COULD GRASP FROM IT, OKAY, NO, I'M NOT.
Q. SO MR. MAYO WAS CONVEYING TO YOU --
A. HE WAS --
Q. -- WHAT HE OBSERVED?
A. NO. SOME WAS OBSERVATIONS AND SOME WAS CONVERSATIONS. HE WAS CONVEYING TO ME CONVERSATIONS WITH BENT CORYDON AND I BELIEVE FROM THE CONTEXT OF THE CONVERSATION, THAT THEY WERE THE MONTH BEFORE OR SOMETIME IN THAT NATURE, WHERE BENT WAS AT A PREVIOUS MISSION HOLDERS CONVENTION AT THE FLAG LAND BASE. IT WAS ACTUALLY A PREVIOUS ONE TO THE ONE I WAS ABOUT TO ATTEND, AND IT WAS FROM THAT CONVERSATION THAT WAS BEING RELAYED TO ME THAT, "IT'S SIMPLE. BENT WANTS MONEY," YOU KNOW, "JUST SO YOU DON'T THINK IT'S A MATTER OVER PRINCIPLE, HE WANTS TO GET RICH. HE WANTS TO BE ABLE TO GET RICH ON SCIENTOLOGY." THE BASEBALL BATS WERE OBSERVATION -- YOU SAY OBSERVATION. DAVID HAD THIS INFORMATION SOMEHOW. I DON'T KNOW HOW, BUT THAT WAS NOT RELAYED AS A CONVERSATION FROM BENT, WHERE THE OTHER ONE MOST DEFINITELY WAS. IS THAT CLEAR?
Q. THAT'S CLEAR.
A. OKAY.
Q. NOW, I WANT TO GET TO THE OTHER TWO ITEMS. DID MR. MAYO RELATE TO YOU THAT MR. CORYDON HAD PARTICIPATED IN THE DISCUSSION REGARDING, YOU KNOW, SOMETHING LIKE, "LET'S GET THE BASEBALL BATS AND GO AFTER THOSE GUYS"? A. WHAT I HEARD --
Q. OR HE WAS JUST PRESENT WHEN THAT HAPPENED, IF IT HAPPENED?
A. HE DIDN'T RELAY HE WAS PART OF THAT. AS A MATTER OF FACT, I BELIEVE HE RELAYED HE WAS A PART OF IT BECAUSE BENT WAS THE ONE WHO KNEW WHERE THE WATCHDOG COMMITTEE AND CMO WERE, BECAUSE NONE OF THE OTHER ONES DID.
AS A MATTER OF FACT, BENT MAY HAVE BEEN THE MITIGATOR OF IT FROM WHAT BENT TOLD ME. HE'S THE ONE WHO HAD THE IDEA BECAUSE HE COULD TAKE EVERYBODY THERE. YOU UNDERSTAND IT WASN'T GENERAL KNOWLEDGE THAT GILMAN HOT SPRINGS PROPERTY WAS THERE; THE GENERAL SCIENTOLOGY DID NOT KNOW THAT THAT'S WHERE IT WAS, AND I GUESS BENT WAS UNIQUE.
Q. I DO UNDERSTAND THAT. DO YOU UNDERSTAND IT WAS AT THIS PERIOD OF TIME THAT
MR. CORYDON WAS STILL TRYING VERY HARD TO BE RETURNED TO HIS MISSION AND THAT IT STRIKES ME IT WOULD BE EXTREMELY UNLIKELY HE WOULD HAVE BEEN VOCAL REGARDING SUCH PROBLEMS? MR. HERTZBERG: IS THAT A QUESTION? IS THAT A QUESTION? WAIT, WAIT, WAIT.
MR. DRESCHER: IF IT'S A QUESTION, IT'S ARGUMENTATIVE AND I OBJECT.
MR. HERTZBERG: I WANT HER TO ANSWER FIRST. IS THAT A QUESTION, MISS PLEVIN?
MS. PLEVIN: NO, IT'S NOT A QUESTION.
MR. HERTZBERG: LET'S NOT ARGUE.
BY MS. PLEVIN:
Q. WERE YOU AWARE, PRIOR TO YOUR CONVERSATION WITH MR. MAYO IN THIS AIRPLANE IN 1981, THAT MR. CORYDON HAD BEEN REMOVED FROM THE MISSION OF RIVERSIDE IN 19787
A. NO.
Q. AND WERE YOU AWARE THAT FOR A LONG PERIOD OF TIME, HE HAD BEEN ATTEMPTING TO GET A BOARD OF REVIEW SO THAT HE COULD BE CLEARED OF THE FINDINGS OF THE COMMITTEE OF EVIDENCE AND BE RETURNED TO HIS MISSION?
A. NO.
Q. WERE YOU AWARE THAT SOMETIME IN OCTOBER OF 1981, THERE WAS A BOARD OF REVIEW WHICH DID CLEAR HIM OF THE FINDINGS OF THE PRIOR COMMITTEE OF EVIDENCE, WHICH WERE FOUND TO HAVE BEEN OFF POLICY AND THEREFORE PERMITTED TO RETURN TO RIVERSIDE AS MISSION HOLDER AND ED?
MR. HERTZBERG: ARE YOU AWARE OF ALL THE ABOVE THAT MISS PLEVIN -THE WITNESS: AND IN THE TIME FRAME OF ON THE AIRPLANE?
MS. PLEVIN: YES.
THE WITNESS: NO.
BY MS. PLEVIN:
Q. WERE YOU AWARE OF ANY OF THAT?
A. ALL I WAS AWARE OF, AND -- AT THAT TIME IN THE AIRPLANE, NO, NONE OF IT, NOT IN ANY WAY, SHAPE OR FORM
(RECESS TAKEN.)
MS. PLEVIN: ALL RIGHT. NOW, AS NOTED, I THINK OFF THE RECORD PREVIOUSLY, I'M NOT SURE IF IT WAS ON OR OFF THE RECORD, THE AIR CONDITIONING HAS GONE OUT AND A NUMBER OF PEOPLE ARE FEELING THE BAD EFFECTS OF IT, INCLUDING THE COURT REPORTER, WHO WAS KIND ENOUGH TO AGREE TO STAY UNTIL 6 O'CLOCK, BUT THAT DOESN'T SEEM TO BE QUITE POSSIBLE UNDER THE CIRCUMSTANCES, SO WE WILL BE ADJOURNING FOR TODAY.
MY QUESTION TO MR. DRESCHER IS: IS THERE SOME WAY WE CAN CONFIRM REGARDING TOMORROW SO THAT WE CAN COMMENCE IN A TIMELY FASHION REGARDING WHETHER THE AIR CONDITIONING IS GOING TO BE ON OR OFF?
MR. DRESCHER: I HAVE NO IDEA. ALL WE KNOW IS THAT THE ANNOUNCEMENT SAID FOR THE REMAINDER OF TODAY. SO BASED ON THAT LANGUAGE -- THE ANNOUNCEMENT I GUESS SAID IT WAS GOING TO BE ON IN THE MORNING. SO I DON'T THINK WE HAD A PROBLEM, OKAY? MS. PLEVIN: IS THERE SOME WAY WE CAN CHECK ON THAT EARLY ENOUGH TO MAKE ALTERNATE ARRANGEMENTS IF NECESSARY? COULD YOU CONFIRM WHETHER, FOR EXAMPLE, AT 8:00 O'CLOCK IT'S BACK ON SO T[IAT IF NECESSARY, WE MAKE ALTERNATE ARRANGEMENTS?
MR. DRESCHER: I DIDN'T PLAN TO GET IN QUITE THAT EARLY.
MS. PLEVIN: FROM CALLING FROM HOME OR SOMETHING.
MR. DRESCHER: THE ANSWER IS NO, I DON'T KNOW WHO TO CALL. IN GENERALLY IN ABOUT 9:00.
MR. HERTZBERG: LET'S CONVENE HERE, IF I CAN MAKE THE SUGGESTION, AT THE APPOINTED TIME, WHICH IS 10 O'CLOCK. IN THE OFF CHANCE THAT THE AIR CONDITIONING IS NOT WORKING, WE'LL ADDRESS WHAT WE DO FROM THERE, OKAY?
MS. PLEVIN: OKAY.
MR. DRESCHER: ACCORDING TO THE ANNOUNCEMENT, IT SHOULD BE ON.
MS. PLEVIN: SO WE'LL PICK UP HERE AT 10 O'CLOCK TOMORROW.
(WHEREUPON, AT 5:20 P.M., THE DEPOSITION OF DAVID MISCAVIGE WAS ADJOURNED.)
STATE OF CALIFORNIA ) COUNTY OF LOS ANGELES ) SS.
I, DAVID MISCAVIGE, HEREBY CERTIFY UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE STATE OF CALIFORNIA THAT THE FOREGOING IS TRUE AND CORRECT.
EXECUTED THIS DAY OF , 1990, AT , CALIFORNIA.
DAVID MISCAVIGE
STATE OF CALIFORNIA ) COUNTY OF LOS ANGELES ) SS.
I, DAWSHA LAYLAND BAKER, C.S.R. NO. 5166, IN AND FOR THE STATE OF CALIFORNIA, DO HEREBY CERTIFY: THAT, PRIOR TO BEING EXAMINED, THE WITNESS NAMED IN THE FOREGOING DEPOSITION, TO WIT, DAVID MISCAVIGE, WAS BY ME DULY SWORN TO TESTIFY THE TRUTH, THE WHOLE TRUTH AND NOTHING BUT THE TRUTH; THAT SAID DEPOSITION WAS TAKEN DOWN BY ME IN SHORTHAND AT THE TIME AND PLACE THEREIN NAMED, AND THEREAFTER REDUCED TO TYPEWRITING UNDER MY DIRECTION, AND THE SAME IS A TRUE, CORRECT AND COMPLETE TRANSCRIPT OF SAID PROCEEDINGS; I FURTHER CERTIFY THAT I AM NOT INTERESTED IN THE EVENT OF THE ACTION. WITNESS MY HAND THIS 3rd DAY OF AUGUST 1990.
CERTIFIED SHORTHAND REPORTER FOR THE STATE OF CALIFORNIA