1 IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR HILLSBOROUGH COUNTY 2 CIVIL DIVISION
3 ESTATE OF LISA McPHERSON, by and through the Personal Representative, 4 DELL LIEBREICH,
5 Plaintiff,
6 vs. Case No.: 97?01235
7 CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC.; JANIS 8 JOHNSON; ALAIN KARTUZINSKI; and DAVID HOUGHTON, D.D.S., 9 Defendants. 10 VIDEOTAPED DEPOSITION OF ROBERT VAUGHN YOUNG 11 Volume V
12 C O N F I D E N T I A L
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24 Susan D. Wasilewski, RPR, CRR January 20 & 21, 2000 25
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1 APPEARANCES
2 Counsel for Plaintiff: MR. KENNAN G. DANDAR 3 Dandar & Dandar, P.A. Attorneys at Law 4 5340 West Kennedy Boulevard, Suite 201 Tampa, Florida 33609 5 Counsel for Defendant Church of Scientology Flag 6 Service Organization: MR. MORRIS WEINBERG, JR. 7 Zuckerman, Spaeder, Taylor & Evans, LLP Attorneys at Law 8 401 East Jackson Street, Suite 2525 Tampa, Florida 33602 9 MR. MICHAEL LEE HERTZBERG 10 Attorney at Law 740 Broadway, 5th Floor 11 New York, New York 10003
12 Counsel for Defendant Alain Kartuzinski: MR. DOUGLAS J. TITUS, JR. 13 Attorneys at Law George & Titus, P.A. 14 100 South Ashley Drive, Suite 1290 Tampa, Florida 33601 15 Counsel for Defendant Janis Johnson: 16 MR. RONALD P. HANES Trombley & Hanes 17 Attorneys at Law 707 North Franklin Street, 10th Floor 18 Tampa, Florida 33602
19 Counsel for Defendant David Houghton, D.D.S.: MR. ROBERT P. POLLI 20 Robert P. Polli, P.A. Attorney at Law
21 101 East Kennedy Boulevard, Suite 1265 Tampa, Florida 33602 22 Also Present: 23 Mr. Michael Garko Mr. Jesse Prince 24 Mr. Michael Rinder Ms. Lara Cartwright 25 Ms. Wendy Beccaccini (via the Internet)
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1 I N D E X
2 WITNESS PAGE
3 Called by the Defendant Church of Scientology Flag
4 Service Organization:
5 ROBERT VAUGHN YOUNG
6 DIRECT EXAMINATION BY MR. WEINBERG......... 672
7 SIGNATURE PAGE................................. 796
8 CERTIFICATE OF REPORTER OATH................... 797
9 REPORTER'S DEPOSITION CERTIFICATE.............. 798
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11
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13 EXHIBITS
14 Defendant's Exhibit A.......................... 678
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1 IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR HILLSBOROUGH COUNTY 2 CIVIL DIVISION
3 ESTATE OF LISA McPHERSON, by and through the Personal Representative, 4 DELL LIEBREICH,
5 Plaintiff,
6 vs. Case No.: 97?01235
7 CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC.; JANIS 8 JOHNSON; ALAIN KARTUZINSKI; and DAVID HOUGHTON, D.D.S., 9 Defendants. 10 VIDEOTAPED DEPOSITION OF ROBERT VAUGHN YOUNG 11 Volume V
12 C O N F I D E N T I A L
13 PURSUANT TO NOTICE for the taking of the
14 deposition of ROBERT VAUGHN YOUNG, upon oral
15 examination in the above?styled cause, at the
16 instance of the Defendant Church of Scientology
17 Flag Service Organization, for the purposes of
18 discovery or use at trial or both, pursuant to
19 Florida Rules of Civil Procedure, proceedings
20 therefor were held before Susan D. Wasilewski,
21 Registered Professional Reporter, Certified
22 Realtime Reporter, and Notary Public in and for the
23 State of Florida at large, at 220 East Madison
24 Street, 12th Floor, Tampa, Florida, on January 20,
25 2000, at 3:50 p.m.
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1 VIDEOTAPING SERVICES were provided by
2 Thomas Hallahan and Rick Spector.
3 THEREUPON, the following proceedings were
4 had and taken:
5 ROBERT VAUGHN YOUNG, called as a witness
6 by the Defendant Church of Scientology Flag Service
7 Organization, having been previously duly sworn,
8 continued to testify as follows:
9 MR. DANDAR: Today is January 20th, 19 ??
10 2000, excuse me. This is the continuation of
11 Robert Vaughn Young's discovery deposition.
12 MR. WEINBERG: Now, a few housekeeping
13 things: You ?? we got ?? you just brought in
14 a box of something. What is that, Ken?
15 MR. DANDAR: Those are the exhibits to
16 the plaintiff's response to Flag's motion for
17 summary adjudication on the issue of
18 religiosity.
19 MR. WEINBERG: All right. And that would
20 be you would say what, about a foot high, or
21 what do you think?
22 MR. DANDAR: I don't think that comes out
23 to 12 inches, no.
24 MR. WEINBERG: Something like nine inches
25 or something like that?
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1 MR. DANDAR: That's probably six to seven
2 inches.
3 MR. WEINBERG: Okay. And then we got a
4 fax with 13 pages including the cover page
5 that was a one?page response to
6 interrogatories that was handwritten out, and
7 is that ?? this is the response to the expert
8 interrogatories, that's what it is?
9 MR. DANDAR: That's ?? that's correct,
10 signed by me, notarized.
11 MR. WEINBERG: Okay. I guess it came in
12 this afternoon right around three o'clock.
13 MR. DANDAR: Okay.
14 MR. WEINBERG: And then there are 11
15 letters ??
16 MR. DANDAR: Right.
17 MR. WEINBERG: ?? that go from June 30th,
18 1997, until April 3rd, 1998, which purports to
19 be correspondence between you or your office
20 and the Youngs. Is that right?
21 MR. DANDAR: I think they're mostly
22 Vaughn Young but they speak for themselves.
23 Those are all the documents in the world that
24 exist between my office and Robert Vaughn
25 Young, and if you want to throw Stacy Brooks
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1 into there, the former Stacy Young, that would
2 include her, too, because I don't think that
3 ?? unless something says it's addressed to
4 her, there wouldn't be anything to her.
5 MR. WEINBERG: My question to you, was
6 there any correspondence in May of 1997
7 between you and/or your office and either of
8 the Youngs or both of the Youngs?
9 MR. DANDAR: If it's not in front of you,
10 it doesn't exist, never was.
11 MR. WEINBERG: So you're not withholding
12 anything?
13 MR. DANDAR: Oh, no, no. No.
14 MR. WEINBERG: And somebody did a search
15 of your records?
16 MR. DANDAR: Yeah. We have a file called
17 Robert Vaughn Young. That's where everything
18 is kept.
19 MR. WEINBERG: Because my recollection is
20 that the testimony indicated that the
21 communications were earlier than June 30th,
22 1997, and that there was some communication in
23 May, and so my question is are you sure?
24 MR. DANDAR: Well, here's one on
25 June 30th ?? let's just say to the best of my
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1 ability at this moment in time, this is it.
2 MR. WEINBERG: Well ??
3 MR. DANDAR: I mean I did the search as
4 well as my staff and this is what was there.
5 Now, I can tell you that if you just look at
6 the June 30th, '97 letter it says here's the
7 retainer check in the amount of $2,000. That
8 was the first check.
9 MR. WEINBERG: Yeah, except that
10 Mr. Young testified that a lot happened
11 between when he got paid and when he first
12 communicated with you.
13 MR. DANDAR: Right. There is nothing in
14 writing to that. There is nothing written.
15 MR. WEINBERG: Okay. Now, what about the
16 other items that we asked for with regard
17 to ??
18 MR. DANDAR: Why don't you ?? yeah, go
19 down the list and I'll tell you.
20 MR. WEINBERG: ?? a letter ?? any
21 agreements or other communication other than
22 these letters?
23 MR. DANDAR: No, there is no written
24 agreement at all.
25 MR. WEINBERG: Copies of documents
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1 regarding his two stays at Well Spring?
2 MR. DANDAR: Well, I believe we had ??
3 that was previously objected to on the grounds
4 of privilege.
5 MR. WEINBERG: Well, do you have
6 anything?
7 MR. DANDAR: I don't have anything.
8 MR. WEINBERG: Does Mr. Young have
9 anything?
10 MR. DANDAR: You have to ask him that.
11 DIRECT EXAMINATION
12 BY MR. WEINBERG:
13 Q. Do you have anything?
14 A. Have what?
15 Q. Do you have any documents with regard to
16 your stays at Well Spring?
17 A. No.
18 Q. Do you have any documents of
19 communications, addressing both of you now, with
20 Bob Minton as it relates to Mr. Young?
21 MR. DANDAR: No, nothing at all.
22 Q. Anything?
23 A. No.
24 Q. Record of payments, direct or indirect?
25 MR. DANDAR: From Minton?
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1 MR. WEINBERG: Yes.
2 MR. DANDAR: Nothing.
3 Q. From Minton?
4 A. No.
5 Q. What about the records with regard to the
6 Friends of the Animals Foundation?
7 MR. DANDAR: It turns out that we were
8 able to contact, following Judge Moody's
9 recommendation this morning at the hearing,
10 Stacy Brooks and she has absolutely nothing
11 and Vaughn Young has nothing.
12 MR. WEINBERG: Do you know ??
13 MR. HERTZBERG: He testified that she had
14 it.
15 MR. DANDAR: Well, I asked her today if
16 she had anything and she said no.
17 THE WITNESS: That wasn't my testimony,
18 Mr. Hertzbertg. I said at the last ?? my last
19 knowledge, she had it when I left.
20 MR. HERTZBERG: Yeah, you said she had it
21 and now that we ?? maybe we can clarify, to
22 expedite matters, where it went.
23 THE WITNESS: Right. I asked her ?? I
24 asked her ?? I asked her and she said she did
25 not know where they were.
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1 MR. DANDAR: We're stipulating he's
2 already ?? continuing to be under oath?
3 MR. WEINBERG: Yeah, under oath, yes.
4 MR. DANDAR: Okay. Right. And I was
5 present at that conversation, so ??
6 BY MR. WEINBERG:
7 Q. All right. I'm handing you a subpoena
8 which calls for the production of documents,
9 including the ones that we just ??
10 MR. DANDAR: Is this something new?
11 MR. WEINBERG: Yeah, it's something new
12 since this is an emergency and we've got to go
13 forward, and if I give you, Ken, a subpoena
14 for Stacy Young, will you accept that?
15 MR. DANDAR: Sure. Go ahead, just to
16 expedite everything.
17 MR. WEINBERG: Okay.
18 MR. DANDAR: Now, can you give me a copy
19 of the Jesse Prince subpoena that you served
20 on me, because I just ?? Michael Hertzberg
21 mentioned that today to me and I ??
22 MR. WEINBERG: We'll make a note and get
23 it to you, yeah.
24 MR. HERTZBERG: Yeah, I may have it with
25 me. Do you want it stated on the record when
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1 we're going to receive the production?
2 MR. DANDAR: No. I have to look at the
3 subpoena.
4 MR. HERTZBERG: You haven't looked at it
5 before?
6 MR. DANDAR: I thought ?? well, I did and
7 I thought we responded to it. You said we
8 didn't, so I've got to see what happened.
9 MR. WEINBERG: Ken, again, it's been a
10 while since I looked at Mr. Young's testimony
11 but I just want to make sure. Is it your
12 representation that there is no ?? that you
13 never ?? that there is no correspondence where
14 you sent Mr. Young or Ms. Young, in the 1997
15 time period I'm talking about, copies of a
16 proposed complaint in order to ?? I mean a
17 proposed amended complaint to add parties?
18 MR. DANDAR: If it's not here ??
19 MR. WEINBERG: But I'm asking you. I see
20 that it's not there.
21 MR. DANDAR: Well, then I didn't do it,
22 right. I ?? I mean I'm sure not testifying
23 today but I would respond to you that if it's
24 not here, no, we didn't do that.
25
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1 BY MR. WEINBERG:
2 Q. And is it your testimony, Mr. Young, that
3 you never got a proposed amended complaint to add
4 parties including Mr. Miscavige?
5 A. I testified to that effect last time.
6 MR. DANDAR: And also, you know, make sure
7 we're clear. That was a totally different
8 question. You just asked him if I sent him a
9 proposed complaint.
10 MR. WEINBERG: In the 1997 time frame.
11 MR. DANDAR: To add Miscavige?
12 MR. WEINBERG: Right.
13 MR. DANDAR: Right. No, but that was a
14 different question that what you asked me.
15 MR. WEINBERG: Well, I'll ask you the
16 same question.
17 MR. DANDAR: The answer is the same but,
18 you know, it's a different question.
19 MR. WEINBERG: Okay. Here's the Jesse
20 Prince subpoena.
21 MR. DANDAR: All right.
22 MR. WEINBERG: All right. Shall we go
23 forward?
24 MR. DANDAR: We may. Would you like some
25 water before we start?
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1 THE WITNESS: No.
2 MR. WEINBERG: I made that request myself
3 but I don't see it anywhere. Do you?
4 THE WITNESS: Only one person brought
5 water.
6 MR. DANDAR: We don't want to share from
7 that bottle.
8 BY MR. WEINBERG:
9 Q. Okay. Now, Mr. Young, did you review
10 Mr. Dandar's answers to interrogatories with regard
11 to what it is that you were supposed to testify
12 about?
13 A. Yes.
14 Q. When did you review that?
15 A. Today.
16 Q. Did you help him prepare it?
17 A. No.
18 Q. Let me mark as an exhibit, as the next
19 exhibit, a fax from Mr. Dandar to Mr. Hanes which
20 includes the interrogatory response and all those
21 letters that we've just been talking about as the
22 next exhibit. Okay?
23 MR. WEINBERG: Do we know ??
24 MR. HANES: Can we note that there is
25 some error on the fax document that would
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1 indicate an inaccurate date and time?
2 MR. WEINBERG: Yeah.
3 MR. DANDAR: What's wrong with it?
4 MR. WEINBERG: What's wrong with it?
5 MR. HANES: You seemed to have signed it
6 yesterday, according to the ??
7 MR. DANDAR: Oh, I correct the notary as
8 well. It's not the 19th I signed this. I
9 signed this today, the 20th of January, 2000.
10 I wonder what else has the wrong date on it?
11 MR. WEINBERG: We're not going to have
12 many exhibits today. I'll just call it
13 Defendant's Exhibit A.
14 (Defendant's Exhibit A was marked for
15 identification.)
16 MR. DANDAR: So even though we were
17 talking a while, let's just say we started at
18 what, 10 to 4:00?
19 MR. WEINBERG: Yeah. No, how about now?
20 I mean we're starting now.
21 MR. DANDAR: Want to start now? Okay.
22 MR. WEINBERG: Four o'clock. 3:58 is
23 what my clock says.
24 MR. DANDAR: Okay. That's fine.
25
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1 BY MR. WEINBERG:
2 Q. Now, what is it, as you understand it,
3 Mr. Young, that you are being called ?? well, first
4 of all, are you being called as an expert in
5 anything?
6 A. In this case, yes.
7 Q. And what is that, expert in what?
8 A. My familiarity with command lines, how the
9 Sea Organization works, the religious presentation
10 of Scientology.
11 Q. Anything else?
12 A. Those are pretty big subjects. I'm sure
13 there are subjects in there that will come out but
14 that's ??
15 Q. Well, can you think of any subjects?
16 A. Well, as these come up within them, but
17 that's the primary subjects.
18 Q. Well, when you say religious presentation
19 of Scientology, what are you talking about,
20 general, what are we talking about? Religious
21 presentation of Scientology you're being called as
22 an expert in, so can you explain that field to me?
23 A. In public relations, how you present a
24 subject to various publics so that they ?? you
25 create an image, which is pretty much what public
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1 relations is about, as in like advertising, and in
2 this subject of how the Church of Scientology
3 presented itself as a church and as a religion.
4 Q. Well, are you testifying that Scientology
5 is not a religion, is that going to be your
6 testimony?
7 A. No. I was testifying as to how they
8 presented the image.
9 Q. Yeah, but I'm asking you, are ?? is it ??
10 are you being called to testify that Scientology is
11 not a religion?
12 A. I was not called to testify on that
13 specific point.
14 Q. Right. Well, is it your belief that
15 Scientology is a religion?
16 A. No, I don't believe it is a religion.
17 Q. Now, are you being called to testify that
18 Scientology is not entitled to a tax exempt status
19 by the IRS, are you being called to testify as to
20 that?
21 A. No.
22 Q. Well, this area, religious presentation of
23 Scientology, is it that you're just testifying
24 about how Scientology presents itself to the world,
25 is that what your testimony is going to be about?
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1 A. That would be part of it.
2 Q. For what purpose would you be testifying
3 that?
4 A. Well, I was asked if I had knowledge of
5 that and I do have knowledge of that. I am being
6 asked my experience and opinion on that subject.
7 I'm not simply volunteering it, I have been asked
8 and that's what I am presenting.
9 Q. Your opinion on the subject of how
10 Scientology presents itself to the world?
11 A. And whether or not that is accurate.
12 Q. And what relation does that have with any
13 issue in this case as far as you know?
14 MR. DANDAR: I will object to the extent
15 that calls for him to express a legal opinion,
16 which I think it does, but if he can answer
17 the question, fine.
18 Q. Okay. Go ahead.
19 A. I was just about to say I'm not the one to
20 judge that. I'm only responding to ??
21 Q. No, no, but I'm asking you. What ??
22 you're sitting here and you're going to, tomorrow
23 or whenever it is, you're going to testify as to ??
24 and we'll get into the opinions in a minute ??
25 testify as to how Scientology presents itself to
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1 the world and I'm asking do you have any
2 understanding of how that would relate to a
3 wrongful death case?
4 A. Well, I did manage while I was here in
5 Tampa, I believe it was yesterday, to see something
6 that was filed by your client that ?? and you'll
7 have to pardon my legal language, I'm not an
8 attorney on this, but trying to claim First
9 Amendment privileges with regard to this case by
10 claiming that it was a valid religion. To that
11 degree, I suppose then at that point it does become
12 a serious religious issue whether or not it would
13 be a valid religion, one that is held sincerely by
14 the organization.
15 Q. So you're being asked to testify that in
16 your opinion it is not a valid religion, is that
17 your understanding?
18 A. That is not the entirety of my testimony.
19 Q. But is that part of your testimony?
20 A. That would be part of it.
21 Q. Well, in the interrogatory answers that
22 we've marked as Exhibit A, under the area of
23 subject matter on which Vaughn Young will testify
24 it says the organization and command lines of
25 Scientology, and then it says the issue of
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1 religiosity in Scientology. Where does that fit
2 into these three things that you told me about, the
3 issue of religiosity in Scientology, what's that?
4 A. I said the presentation of the religious
5 image.
6 Q. Okay. In English, does the issue of
7 religiosity of Scientology, does that relate to
8 the ?? to your contention that it's not a religion
9 or not a valid religion?
10 A. Not validly presented is what I'm doing.
11 The image that I and others presented was not
12 sincerely held within the organization and was
13 pretty much like a Hollywood front for like a
14 movie. You get the front that is put up and then
15 you step behind it, there is other actions that are
16 being taken so that it's not being actually
17 sincerely presented.
18 Q. So are you testifying that the millions of
19 people that are not staff members in Scientology
20 that practice Scientology, is it your testimony
21 that they are practicing a religion that is not a
22 valid religion, is that what your testimony is?
23 A. Well, first of all, sir, I would seriously
24 question the millions. There is not millions.
25 There never was millions.
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1 Q. How many are there?
2 A. I would estimate in the United States, the
3 best count, there is probably around less than
4 100,000 active.
5 Q. Okay. And how many in the rest of the
6 world?
7 A. Oh, if we're lucky, maybe 25,000, 30,000.
8 Q. So the 125,000, according to you, people
9 that are members of the public that believe in
10 Scientology, is it your ?? is it your testimony
11 that they are practicing a religion that is not
12 valid, is that what you're here to testify about?
13 A. No, that's not what I said.
14 Q. Well, do you believe that there are people
15 in ?? that there are at least 125,000 people in the
16 world that believe in what Scientology is about?
17 A. That's a different ??
18 Q. I'm asking you.
19 A. Could you ask that one again because we
20 just shifted subjects, if you could ask that again?
21 Q. I think she could probably read that to
22 you.
23 (The question was read by the reporter.)
24 A. That would be a fair characterization,
25 what Scientology is about.
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1 Q. That there are ?? that there are at least
2 100,000 people in the world, if your numbers are
3 right, that believe that Scientology is a religion?
4 A. No, I wouldn't believe that. In fact,
5 that's contrary to my own experiences. Most people
6 in there do not consider it to be a religion.
7 Q. And they consider it to be what?
8 A. Standard tech, Hubbard, ways to improve
9 your life, an applied philosophy, business
10 techniques. That's what I'll be able to testify,
11 that most of them really don't, and there is, in
12 fact, different opinions about that within the
13 organization, in the public.
14 Q. That most of the people in the public
15 don't believe that it's a religion?
16 A. I would subscribe to that, yes.
17 Q. All right. And so that's what you're
18 going to testify about when you testify?
19 A. That would be one of the topics that I
20 would ??
21 Q. And that's based on what work that you
22 have done in the last ten years in dealing with
23 people that are Scientologists?
24 A. That comes from since 1968, my experience
25 with the organization ??
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1 Q. No. My question was the last ten years.
2 A. Talking to people, what I'm reading and
3 what I'm finding out.
4 Q. Well, are you doing surveys of public
5 members of Scientology around the world in the last
6 ten years?
7 A. No. It's pretty much the same basis on
8 which I based my answers when you asked me in the
9 last deposition my opinions of Scientology and
10 Scientologists, and if you accepted my basis for
11 those, those answers, it would be the same basis.
12 Q. Believe me, I haven't accepted one basis
13 that has come out of your mouth with regard to
14 Scientology.
15 MR. DANDAR: Excuse me. Excuse me.
16 A. You asked me regarding psychiatry.
17 MR. DANDAR: That's argumentative. Let's
18 not ??
19 Q. Psychiatry is a different story.
20 MR. DANDAR: Let's try to keep to the
21 questions only, please.
22 Q. Now, so that your being called as an
23 expert to testify generally about your familiarity
24 with the command lines, what do you mean by that?
25 A. How different parts of the ?? if I just
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1 may use Scientology in general, how they have
2 communicated with each other over the decades,
3 pretty much how it operates by the sending of
4 orders, reports, distribution of material,
5 et cetera.
6 Q. And that has what to do with any issue in
7 this case, as far as you know?
8 A. Well, it would have to do with how Flag
9 Service Organization, for example, connects back
10 into other organizations that are senior to it.
11 Q. Any particular issue in this case that the
12 command lines of Scientology that you supposedly
13 have expertise in has to do with in this case?
14 A. Well, that actually being able to show
15 that there is really no corporate integrity when it
16 comes to within Scientology, that there is another
17 form of control that is used within the
18 organization that is not immediately perceptible to
19 the general public, to the media, or has even been
20 perceptible to the courts, in my opinion.
21 Q. Or the IRS, right?
22 A. Or the IRS.
23 Q. I mean you realize the IRS investigated,
24 and you were part of that investigation,
25 Scientology for over a decade, right?
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1 A. No, I was not part of that investigation.
2 Q. You had nothing to do with the dealings
3 with the IRS, is that right, while you were in
4 Scientology, while you were on staff?
5 A. No, I did not meet with anybody in the
6 IRS.
7 Q. You understand that the IRS investigated
8 the tax exempt issue for over a decade?
9 A. I understand that they investigated it.
10 Q. Yeah. You know that they did a full?blown
11 audit of all of the organizations and corporations
12 of Scientology, you understand that, don't you?
13 A. Yes.
14 Q. And you understand at the conclusion of
15 that that they determined that the various
16 Scientology churches and corporations were entitled
17 to tax exempt religious status, you understand
18 that, don't you?
19 A. That was their ruling.
20 Q. And you understand that they looked at
21 issues like whether or not the Sea Organization, in
22 fact, was as you are about to say, really controls
23 Scientology as opposed to the corporate structure,
24 right, you understand they looked at that issue?
25 A. Yes.
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1 Q. And you know that they determined that it
2 did not, don't you?
3 A. Yes.
4 Q. Okay. So you're here today or tomorrow to
5 basically say that the IRS got it wrong?
6 A. Well, they were defrauded, but I'm not
7 here for the IRS part.
8 Q. No, you just want to undo what was done
9 seven years ago.
10 A. No. I did not ever say that and I would
11 resent the accusation I'm trying to do that. I'm
12 here on behalf of Mr. Dandar.
13 Q. Now, you said that there is no corporate
14 integrity and that really the ?? I take it by that
15 you mean that the organization, the various
16 corporations that were ?? well, strike that.
17 In 1982 there was a major reorganization
18 of the corporate structure in Scientology, correct?
19 A. It actually started in '81.
20 Q. Okay.
21 A. In that period.
22 Q. RTC was created, CSI was created, you
23 know, over a period of time all the churches around
24 the world were reincorporated or incorporated, I
25 mean all that happened, correct?
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1 A. Yes.
2 Q. All right. Now, do I understand you to
3 say that it is your testimony that that corporate
4 reorganization was in name only and didn't exist in
5 practice, is that what you're saying?
6 A. That's ?? I can't immediately assent to
7 that because that's a very large, difficult
8 question.
9 Q. Well, explain what it is generally that
10 your position is. We had this ?? the church had
11 this corporate reorganization beginning in 1981 in
12 which at the end of the process you had the RTC
13 that had its ?? you know, had its function as the
14 protector of the integrity of Scientology or the
15 purity of Scientology, had SCI that was set up, you
16 know, as the mother church, you had all these other
17 organizations that were incorporated, churches
18 under it, you had licensing agreements, you know,
19 where the marks were licensed by RTC to CSI and
20 then sublicensed from CSI to the various churches,
21 correct?
22 A. Yes.
23 Q. And you had a whole corporate structure
24 that was set up with a, you know, with trustees,
25 directors, officers in all of these organizations,
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1 correct?
2 A. Yes.
3 Q. All right. Now, is it your testimony that
4 that is not, in fact, how Scientology in practice
5 was run?
6 A. That is correct.
7 Q. Okay. Now, who then ?? what is your
8 testimony as to what organization or people were
9 running Scientology as opposed to the ?? to what
10 the IRS found in 1993 was this corporate structure?
11 A. Pretty much runs through Sea Organization
12 channels between the organizations.
13 Q. What's that mean?
14 A. That there is a Sea Organization structure
15 that is the actual nexus that, like the nervous
16 system of the body connecting different organs, are
17 the ones that actually commands, controls and runs
18 this from the very top echelon to as low as it
19 really wants to go within the Scientology structure
20 and that this pierces any cooperate veil that may
21 be there so that Sea Organization actions can be
22 directed down into an organization from the very
23 top to the bottom with regard to corporate
24 integrity.
25 Q. And the ?? and that has what relevance as
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1 far as you understand it, to any issue in this Lisa
2 McPherson case?
3 A. Well, right now, with Mr. Miscavige added
4 as a defendant, it has a very key issue in showing
5 that the Sea Organization is actually the
6 controlling force within Scientology.
7 Q. The Sea Organization is a corporation?
8 A. No.
9 Q. The Sea Organization is an entity?
10 A. It's a very difficult thing to describe.
11 Q. I'm just asking you. The Sea Organization
12 is an entity?
13 A. Yes, I would say it's an entity.
14 Q. And what kind of entity is it?
15 A. It's a paramilitary organization
16 consisting of highly dedicated individuals that are
17 willing to execute commands and get things done.
18 Q. Sort of like the Jesuits?
19 A. No. I can't speak to that because I'm not
20 familiar with Jesuits.
21 Q. Paramilitary, you keep ?? you know, all of
22 your affidavits over the years is cluttered with
23 references like that. What do you mean
24 paramilitary?
25 A. It has, of course, on the outside, the
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1 military uniforms, the demeanor, the language, but
2 inside there is a military structure, the
3 vocabulary, people muster in the mornings in ranks.
4 There are people with ?? that you address officers
5 by sir. Internally this is carried out. It's not
6 merely just putting on a uniform. It is executed.
7 The command lines are executed in a military
8 fashion. In fact, to understand how it operates,
9 you would use a military model rather than even a
10 corporate model.
11 Q. And what relevance does that have to
12 anything?
13 A. This is how it penetrates the various
14 corporations around the world.
15 Q. Now, it's your position that whatever
16 L. Ron Hubbard has written is the gospel and is
17 scripture in Scientology, is that your position?
18 A. No, I don't consider it scripture.
19 Q. Well, is it your testimony that ?? I
20 thought I read it in your ?? one of your
21 affidavits, that whatever Mr. Hubbard wrote is part
22 of the scripture of Scientology.
23 A. I've never used the word scripture.
24 Q. And that it can't be changed, it has to be
25 relied on by Scientologists. Isn't that your
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1 testimony?
2 A. No. You're altering my testimony.
3 Q. Well, what is your testimony?
4 A. Do you have a question?
5 Q. Yeah. What is your testimony with regard
6 to the writings of L. Ron Hubbard, what
7 significance do they have in this religion?
8 A. Well, first of all, I can't respond to the
9 religion part, so if you can give me a different
10 question, I can answer it.
11 Q. That's my question. What part does the
12 writings of L. Ron Hubbard have with regard to the
13 religion of Scientology?
14 A. Very little. Because I don't consider it
15 a religion, that's sort of a loaded question.
16 Q. Well, what is the significance of the
17 writings of L. Ron Hubbard in Scientology?
18 A. He's considered source and founder.
19 Q. Which means what, source?
20 A. That he was the one that originated it and
21 came up with the idea.
22 Q. That his word is the gospel, is that what
23 source means?
24 A. No. Bill Gates is the source of Microsoft
25 but I would hardly consider him gospel.
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1 Q. Now, in your affidavit that was ?? well,
2 Scientologists refer to the writings of L. Ron
3 Hubbard as scripture, don't they?
4 A. No.
5 Q. They don't?
6 A. No.
7 Q. So you've never heard, in the 21 years
8 that you were in Scientology, you never heard
9 anybody in Scientology refer to the writings of L.
10 Ron Hubbard as scripture?
11 A. The only ones who called it scripture were
12 the PRs and the people creating the image. I never
13 once heard a Scientologist internally call it
14 scripture, never once in my 21 years.
15 Q. All right. And Scientologists don't have
16 legitimate beliefs in various things that have been
17 written by L. Ron Hubbard then?
18 A. They might or they might not. I can't
19 speak for individual Scientologists.
20 Q. You didn't when you were a Scientologist?
21 A. Didn't what?
22 Q. You never believed in thetan, you never
23 believed anything in the 21 years that you were in
24 Scientology?
25 A. No, I had a number of beliefs.
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1 Q. Well, what were the beliefs that you had
2 when you were in Scientology?
3 A. It evolved. It changed. I mean that's ??
4 Q. How did it start out, what did you
5 believe?
6 A. Well, it started out, I ?? it started out
7 with my interest in ?? as a philosophy, and I was
8 interested in a resolution of the mind/body problem
9 and I thought Hubbard had a very interesting
10 approach by taking a ?? sorry, it's a technical
11 term ?? solipsistic attitude, which means that the
12 individual starts as the center of the belief
13 system rather a Cartesian or a Kantian or other
14 approach. So I wanted to see if by starting with
15 the individual as the center and moving out, you
16 could resolve certain philosophical problems.
17 Q. And did you have sincere beliefs when you
18 were a Scientologist?
19 MR. DANDAR: Object to the form.
20 A. I have difficulty with that question,
21 sincere beliefs.
22 Q. All right. Now, religious presentation of
23 Scientology, what qualifies you as an expert in
24 being able to discuss in front of a jury the issue
25 of religiosity in Scientology, what are your expert
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1 qualifications?
2 A. Well, starting with my own personal
3 experiences of doing it, I suppose.
4 Q. In doing what?
5 A. Creating a religious image.
6 Q. Well, did you ?? have you ever been
7 qualified as an expert in the religiosity of
8 Scientology, ever qualified as an expert?
9 A. I don't believe so.
10 Q. Has any judge ever considered whether or
11 not you were an expert with regard to religiosity
12 in Scientology, any judge ever considered that?
13 A. No.
14 Q. So no judge has rejected you as an expert
15 then?
16 A. No.
17 MR. DANDAR: I think that no meant
18 correct.
19 Q. Has any lawyer ever offered you to a
20 judge as an expert in anything?
21 A. I'm sorry. I lost the question because he
22 was speaking.
23 Q. Okay. Has any judge ever offered you as
24 an expert ?? has any lawyer ?? strike that. New
25 question.
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1 Has any lawyer ever offered you as an
2 expert in anything to a court?
3 A. I've never ?? the only time I testified in
4 court was in the FACT Net case, so I'm sorry, I'm
5 sort of losing ??
6 Q. In that case you testified as a fact
7 witness, didn't you?
8 A. No. I testified both as an expert and as
9 a fact witness.
10 Q. Let me show you the copy of the
11 transcript, reporter's transcript. This is in the
12 motion for a preliminary injunction, September
13 11th, 1995. You were called by Mr. Kelley, is that
14 right?
15 A. Yes.
16 Q. Okay. This is in front of Judge Cane. Is
17 that who the judge was?
18 A. Yes.
19 Q. Mr. Kelley: The defendant will call the
20 first witness, Robert Vaughn Young.
21 The Court: Mr. Young.
22 Mr. Cooley ?? that was the Scientology
23 lawyer, right?
24 A. He was, yes.
25 Q. May I inquire whether Mr. Young is being
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1 called as a fact witness or expert witness?
2 Mr. Kelley: As far as I know, Your Honor,
3 he is being called as a fact witness.
4 A. Okay.
5 Q. So you accept that?
6 A. Yes.
7 Q. Now, what is the ?? okay. So what is the
8 basis for you being an expert in the religiosity of
9 Scientology? You've told us 21 years of PR in
10 Scientology. What else?
11 A. Well, I was trained specifically for the
12 purpose of presenting religious image to the
13 public.
14 Q. Trained by whom?
15 A. By the organization.
16 Q. Well, what ?? you took a course in it?
17 A. There were courses, yes.
18 Q. What courses did you take ??
19 A. The public ??
20 Q. ?? in presenting the image?
21 A. Such as the public relations course.
22 Q. Well, what is that course? Who taught the
23 course?
24 A. That was taught by Department 20.
25 Q. When did you take the course?
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1 A. I first took it in 1971, when the
2 religious image campaign was first really being
3 geared up, and then I took it again ?? took the
4 expanded, it had been expanded and I took it again
5 in I believe it was 1975 at St. Hill.
6 Q. What did you call the course, public
7 relations course?
8 A. Public relations course.
9 Q. How long did the course take?
10 A. Couple of months.
11 Q. So do you read scripture?
12 A. No, you read policies and whatever else is
13 relevant on the checklist, in the check sheet.
14 Q. All right. So you took a public relations
15 course twice. What else ?? what other training did
16 you have that would qualify you for the first time,
17 by the way, as an expert in religiosity of
18 Scientology?
19 A. Well, it was also the experience since the
20 organization put me forward as their spokesman on a
21 number of occasions and I was a representative for
22 the organization, such as in 1977 when I was the
23 national spokesman and I can be found in such
24 publications as the New York Times, so that I ??
25 you know, an hour on the Tom Snyder Show, one hour
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1 after Johnny Carson.
2 Q. But you're not suggesting that being on
3 the Tom Snyder show would qualify you as an expert
4 on the religiosity of Scientology, are you?
5 A. Well, to the degree the organization has
6 asked me to operate on their behalf, I'm most
7 intimately familiar with how that is done,
8 especially since I was their representative.
9 Q. Well, what else qualifies you? Okay. The
10 Tom Snyder Show, these two public relation courses,
11 but what else qualifies you as an expert on the
12 religiosity according to these interrogatories, the
13 religiosity in Scientology, issue of religiosity in
14 Scientology?
15 A. Isn't that the whole purpose of my long
16 deposition?
17 Q. I'm asking you. What else qualifies you?
18 A. Well, there is 21 years. Do we want to
19 spend our two hours now in covering the 21 years
20 what I did? I'm willing.
21 Q. You said 21 years, you said two courses in
22 public relations, you said the Tom Snyder Show.
23 Was there something else?
24 A. Well, I think 21 years counts for a lot.
25 If you want to go into all that I did and studied
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1 and trained and the people that I trained ?? I mean
2 I even ?? Mr. Rinder is sitting here at the table.
3 There was a time when I went down to Clearwater and
4 I even instructed Mr. Rinder on things to do with
5 regard to Clearwater.
6 Q. Are you an expert in the tech?
7 A. The Red on White?
8 Q. Yes.
9 A. That's what I consider the tech. On the
10 Red on White, no, I would not consider ?? count
11 myself nor testify as an expert.
12 Q. All right. And the Red on White is the ??
13 is what the Scientologists, people that believe in
14 Scientology, would look to first, really, or almost
15 first, with regard to issues concerning their
16 religion, wouldn't they, their beliefs?
17 A. No. No.
18 Q. No?
19 A. No.
20 Q. Well, what is the Red on White?
21 A. The Red on White ?? we've covered this
22 before. There is Red on White and basically Green
23 on White, and there is other color combinations,
24 but those two are the primary ones.
25 Q. Yeah, and the Red on White ??
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1 A. Those are combined. Every course that you
2 take is a combination of Red on White and Green on
3 White, combination of bulletins and policies. You
4 never ?? I have never seen one course ??
5 Q. Okay. The HCL bulletins, which is what
6 you're calling the Red on White, right?
7 A. Or the bulletins.
8 Q. Or the bulletins, the Red Volumes, those
9 are the volumes that deal with auditing and
10 training, that's the spiritual or ecclesiastical
11 part of Scientology, correct?
12 A. Well, the spiritual and ecclesiastical,
13 that's how the organization characterizes it.
14 Q. But am I right?
15 A. No.
16 Q. These volumes have to do with some of the
17 most fundamental what Scientologists would
18 characterize as religious practices in Scientology,
19 auditing and training, correct, that's what the Red
20 on White has to do with?
21 A. Well, if you want me to try to turn it
22 into a religion, I can't do that, sir.
23 Q. Is that right? Am I right?
24 A. I cannot respond yes to that question.
25 Q. I recognize that you do not agree with
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1 Mr. Rinder in what he believes, but what I'm asking
2 you is Mr. Rinder and other people like Mr. Rinder
3 look to the Red on White Volumes as the volumes
4 that discuss some of ?? two of the most fundamental
5 spiritual and religious parts of Scientology, which
6 is auditing and training, correct, that's what he
7 looks to?
8 A. Mr. Rinder, no; but as far as spiritual,
9 no; auditing and training, yes. And if you ?? I
10 will even give you some concessions if you will.
11 That is the core where Mr. Hubbard discusses the
12 individual, the nature of the individual, how the
13 individual interacts with himself, and that is the
14 core, that is correct, that is the core of
15 Scientology.
16 Q. Of the belief system in Scientology, isn't
17 it?
18 A. Yes.
19 Q. Yes. Now, you sit here and say it's not a
20 religion and Mr. Rinder and many other people in
21 the world will say it is a religion because I
22 believe in it, correct?
23 A. Mr. Rinder is paid to do that the way I
24 was paid to do it.
25 Q. Well, there are people that are publics,
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1 like Lisa McPherson, that practiced Scientology and
2 practice it as their religion, aren't there?
3 A. There are some.
4 Q. Okay. And those people that practice
5 Scientology as their religion would look at the HCO
6 bulletins, the Red Volumes, as the volumes that
7 would set forth the spiritual and ecclesiastical
8 part of Scientology, training and auditing?
9 A. I never once heard one person ever say the
10 word ecclesiastical in training.
11 Q. The Green Volumes, which are the HCO
12 policy letters, that has to do with the
13 administration of the church, policies with regard
14 to the administration of the church, right?
15 A. No, not entirely.
16 Q. Well, what's it have, what do the Green
17 Volumes have to do with?
18 A. It does include administration but it also
19 includes social matters. There is a number of
20 policy letters where he talks about ?? I don't want
21 to get into Scientology terminology but ??
22 Q. Why? You're an expert. Why not get into
23 the Scientology ??
24 A. Okay. Third dynamic matters, third
25 dynamic issues are covered on Green on White and
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1 he's very specific that Red on White deals with
2 first dynamic issues, although there is a lot in
3 the Red Volumes that deal with third dynamic
4 issues.
5 Q. Now, are you an expert on the HCO policy
6 letters, the Green Volumes, are you an expert in
7 that?
8 A. I wouldn't say I'm an expert on policy
9 letters and I never claimed to be policy letters.
10 I just claimed to be an expert as I described it.
11 Q. Well, do you know what the LRH executive
12 directives are?
13 A. Yes.
14 Q. What are those?
15 A. Those are Blue on White. They came
16 directly from Hubbard and dealt with a variety of
17 topics.
18 Q. Including technical topics?
19 A. Not exactly. It was more when he would
20 announce like a technical breakthrough and here's
21 what we're going to do, we're going to be setting
22 up this, or it might be just simply like he would
23 do a journal and he would take an overview on
24 things. It was a ?? it was sort of a mishmash of
25 topics that he did with his executive directives.
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1 Q. Well, are you an expert in the LRH
2 executive directives?
3 A. Well, all I can say is I've read them all.
4 Q. Well, what have you read in Scientology?
5 A. That's ?? I would dare say tens of
6 thousands of pages.
7 Q. Have you read all the Red Volumes?
8 A. No.
9 Q. Have you read all the Green Volumes?
10 A. Most of the Green Volumes.
11 Q. Have you listened to the 3,000 taped
12 lectures by Hubbard?
13 A. No.
14 Q. Have you looked at the ones that have been
15 transcribed?
16 A. Many of them, hundreds of them.
17 Q. Have you watched the films?
18 A. I've watched a lot of films.
19 Q. Have you read all the books?
20 A. I may have read all the basic books.
21 Q. Well, Scientologists would consider as
22 scripture, as the documents that contain the ??
23 what the religion is about to include in
24 Scientology the books, like Dianetics, that were
25 written by L. Ron Hubbard, correct?
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1 A. Again, I've never heard once a
2 Scientologist use the word scripture, and you've
3 loaded my ?? the question ??
4 Q. Well, what do Scientologists consider
5 people that believe, people that believe in
6 Scientology as their religion, what do they ?? how
7 would you describe as an expert what they consider
8 the books like Dianetics?
9 A. They would consider that Mr. Hubbard has
10 made a number of breakthroughs that they consider
11 to be valued, valuable. You're not too long in
12 there before you learn of something called standard
13 tech and that there is one precise way to do
14 something. You come to learn that the ?? there is
15 various gradients of learning, that the books are
16 one part of it, then the courses and the policies
17 and the bulletins are another part of it, and then
18 you ?? then you just take it from there. But they
19 consider ?? I'm not denying Mr. Hubbard is
20 considered in high esteem by a great many
21 Scientologists. That is not ?? I would never
22 challenge that. But they ?? his esteem is held as
23 a person who made a number of breakthroughs pretty
24 much the way Freud had made breakthroughs.
25 Q. And that's your opinion?
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1 A. Yes.
2 Q. Now, are you ?? were you trained as a
3 classed auditor?
4 A. I was trained as a dianetic auditor, which
5 is a class.
6 Q. Which is ??
7 A. It's on the chart.
8 Q. Well, what course did you take ?? it's on
9 the charts?
10 A. Yes.
11 Q. What's a classed auditor?
12 A. In my definition right now, it would be
13 one of the persons on the gradation chart who
14 received a certificate for completion of the
15 course.
16 Q. And you weren't trained to do any of that,
17 were you?
18 A. I was trained as a Hubbard dianetic
19 auditor and received my certificate and I audited
20 professionally as one.
21 Q. You didn't do ?? you didn't take the
22 student hat, correct?
23 A. Yes, I did.
24 Q. Professional TR course?
25 A. Yes.
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1 Q. Did you take the academy level courses?
2 A. No.
3 Q. The minister's course?
4 A. Yes.
5 Q. Were you trained to do class zero to four?
6 A. No.
7 Q. Were you trained in staff status one?
8 A. Excuse me a second. Are we going to get
9 water pretty soon or some way to ?? we'll go on but
10 if there is some way we could just take a break and
11 I go find water.
12 THE VIDEOGRAPHER: There is a water
13 fountain, sir.
14 Q. There is a water fountain right there.
15 A. Could I just get a drink real fast?
16 (Recess from 4:37 until 4:39 p.m.)
17 BY MR. WEINBERG:
18 Q. What are the qualifications and training
19 to be a course supervisor? Are you trained in
20 that?
21 A. No.
22 Q. What are the qualifications and training
23 to be a staff member, are you trained in that?
24 A. Yes.
25 Q. Were you an executive?
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1 A. Yes.
2 Q. In any organization?
3 A. Yes.
4 Q. What?
5 A. I was an executive in Department 20,
6 started in 1971.
7 Q. What was your position?
8 A. I was an assistant guardian for public
9 relations.
10 Q. How long were you in that position?
11 A. About two and a half years.
12 Q. Did you have any juniors?
13 A. No.
14 Q. Pretty low on the totem pole?
15 A. No.
16 Q. Well, what other executive positions did
17 you have other than assistant guardian for public
18 relations?
19 A. For a while I was the PR establishment
20 officer for Department 20, US.
21 Q. When was that?
22 A. That was '73, 1973.
23 Q. Did you have any juniors in that?
24 A. The entire bureau, the entire public
25 relations bureau was my ?? because I was
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1 responsible for their establishment, their training
2 and their hatting and et cetera.
3 Q. And that was an executive position ??
4 A. Yes.
5 Q. ?? that you had? What do you ?? how do
6 you describe an executive position as opposed to a
7 staff position?
8 A. Well, all executives are staff. It's not
9 a comparison.
10 Q. What's an executive position in
11 Scientology?
12 A. I'd say an executive position would be any
13 department head on up would be ?? qualify for an
14 executive position.
15 Q. What else? What other executive positions
16 did you have?
17 A. Then in 1982 I was director of public
18 affairs for Author Services, Inc.
19 Q. Nineteen what?
20 A. 1982.
21 Q. Okay. Anything else?
22 A. That was it.
23 Q. Were you ever a director?
24 A. Yes, I just named those for you.
25 Q. So those are direct ?? so that's what you
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1 ?? those are director positions? Were you ever a
2 director of one of the corporations?
3 A. Oh, a director of a corporation. No.
4 Q. Were you an officer of a corporation?
5 A. No.
6 Q. Were you a commanding officer of an
7 organization?
8 A. No.
9 Q. Were you on the watch dog committee?
10 A. No.
11 Q. Were you an executive in the CMO,
12 International?
13 A. No.
14 Q. Ever held a position in church management?
15 A. That's kind of a yes and no since we ran
16 church management but we were not part of church
17 management. That's where we get into the Sea Org.
18 Q. Ever on the Flagship Apollo?
19 A. No.
20 Q. Ever on staff at FSO?
21 A. No.
22 Q. Now, what ?? is there ?? what you're being
23 called for, would you describe this as some
24 recognized field of expertise?
25 A. I'm not sure I understand what you mean.
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1 Q. Well, I mean if you were a, for example,
2 an expert here to discuss eye fluid or vitreous
3 fluid, as we have other people that profess to be
4 in this case, there are other people in the world
5 that are ?? that have written, testified about,
6 done studies with regard to eye fluid and there is
7 a field of study or expertise with regard to this
8 vitreous fluid. So my question is what field of
9 expertise are you in?
10 A. I can't respond to your question because I
11 really don't understand field. All I know is what
12 I can testify about and I can't compare myself
13 to ??
14 Q. Well, who else in the world has ever, as
15 far as you know, written or testified about what it
16 is that you're coming here to testify about?
17 A. Well, it's appeared in various ways. I
18 know Mr. Prince has spoken a great deal about
19 command channels, but I don't know if he's been
20 described in exactly the language that mine has
21 been put down, so I can't respond in that way.
22 Q. Fortunately, we're in the room with two of
23 the people in the world that have testified or
24 written about this subject. Other than Mr. Prince,
25 is there someone else in the world that has ?? that
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1 you know of that has written about or testified
2 about this field of expertise that you are being
3 called to testify about today?
4 MR. DANDAR: Move to strike gratuitous
5 comments. Go ahead.
6 A. I don't ?? I really don't understand the
7 way that you're wording the question because we go
8 back to this thing about expert fields. All I can
9 say is I can tell you and you certainly know who
10 has testified as experts in Scientology.
11 Q. No, no, no. You're under oath and ??
12 A. That doesn't mean I understand the
13 question.
14 Q. Well, is there anybody that you know that
15 has ever been qualified by a judge anywhere in the
16 world on the issue of the religiosity of
17 Scientology?
18 A. I don't know because I don't know every
19 case in the world ??
20 Q. I'm just asking if you know. Is there
21 anybody?
22 A. I know that people who have been qualified
23 to testify about Scientology and who have presented
24 evidence, whether or not that got accepted
25 somewhere else, I don't know. I know like Stacy
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1 Brooks Young ??
2 Q. Your ex?wife you're talking about.
3 A. She certainly testified. There is other
4 people that have presented testimony. Whether or
5 not ??
6 Q. Just give me the names.
7 A. There was a gentleman who testified in the
8 FACT Net case in Denver. I don't remember his
9 name. I don't remember if he came up as a fact
10 witness or an expert witness but he testified prior
11 to me. I don't ?? you know, I just don't pay
12 attention to such matters. There might have been
13 people in England. There could have been people in
14 Copenhagen, Germany, I don't know.
15 Q. Well, you're being offered as an expert on
16 the religiosity of Scientology, among other things,
17 correct?
18 A. In the ?? not as an expert on experts.
19 Q. You're being offered as an expert in this,
20 right?
21 A. Yes. Yes.
22 Q. And what I'm trying to find out is who
23 else in the world are you aware of or have you
24 relied on in reaching these opinions on the same
25 issue?
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1 A. Well, that's now a different question than
2 before. Who else have I relied upon ??
3 Q. Just answer my question, please, okay?
4 A. Okay. I just wanted to clarify it's a
5 different question. Who else have I relied upon?
6 I certainly have spoken with Mr. Prince, I've
7 certainly spoken with Stacy Brooks Young. In my
8 own way, Mr. Wollersheim had his certain level of
9 expertise just from his years of litigation with
10 the organization. I learned some things from him.
11 Q. Who else?
12 A. There is a number of people that I've
13 learned things from.
14 Q. Can you give us the names, please?
15 A. Well, such as John Atak.
16 Q. Who is that?
17 A. He's an author, wrote a book called Piece
18 of Blue Sky. I learned a lot from that book and
19 from speaking with him.
20 Q. When did he write that book?
21 A. Oh, I don't know. I first found it in
22 nineteen ?? circa 1991, I guess. I don't know when
23 it was published.
24 Q. So you saw it after you left the Church of
25 Scientology?
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1 A. Yes.
2 Q. Who else?
3 A. Peoples whose books I've read that I
4 haven't spoken with.
5 Q. Like what? I'm asking what are you
6 relying on?
7 A. Well, okay. Well, as far as rely upon,
8 that's ?? you said spoken with. What I rely upon
9 is, one, my own experience and the documents of the
10 organization. I don't rely upon the opinions of
11 others. If Mr. Atak, for example, had information
12 that I go, oh, that's interesting and I can track
13 it down, then I would, but in the end, all I rely
14 upon that I would testify would be either
15 percipient knowledge or something that I could
16 stand by from a document from the organization, but
17 I'm not going to rely upon in my testimony upon the
18 opinions or experiences of another. They can only
19 guide me to something ??
20 Q. Since you left the church in whenever it
21 was, 1989, you have no percipient knowledge of what
22 has gone on in the Church of Scientology, is that
23 correct?
24 A. No, that's not true.
25 Q. Oh, so what, have you been a fly on the
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1 wall there, or what?
2 A. No.
3 Q. So have you been ?? have you participated
4 in Scientology courses since 1989?
5 A. No.
6 Q. Have you done auditing since 1989?
7 A. No.
8 Q. Have you been on staff since 1989?
9 A. No.
10 Q. So have you ?? what have you done since
11 1989 that would make you a percipient witness of
12 what is occurring in Scientology?
13 A. Well, first of all, you can read their own
14 publications, that's one of the best ways, because
15 that's how the organization reaches its own
16 membership, how the membership comes to know what's
17 going on in the ??
18 Q. So you read their publications. Okay.
19 Anything else?
20 A. Read the publications, and since 1989 have
21 visited, you know, dropped in on a few
22 organizations and chatted with Scientologists.
23 Q. Chatted with Scientologists?
24 A. Yes.
25 Q. Okay. And that has ?? anything else?
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1 A. No.
2 Q. Now, other than Mr. Prince, your ex?wife,
3 Larry Wollersheim, can you think of anyone else in
4 the world that you would consider to be an expert
5 in these matters that Mr. Dandar says that you are
6 going to testify about?
7 A. That I could call forward right now?
8 Q. Yes.
9 A. I can't think of anybody else right now.
10 Q. Has anybody ?? has anybody published on
11 the issue of religiosity in Scientology that you
12 can refer us to?
13 A. I think Mr. Steve Kent up in Canada did
14 some papers on it.
15 Q. Who is Steve Kent?
16 A. He's a scholar with a university up in
17 Canada. I can't remember it but Mr. Rinder has got
18 his phone number, home address and everything I'm
19 sure.
20 Q. And what ?? and what's the story on Steve
21 Kent? I mean have you read his works?
22 A. I've seen some of the things he's written.
23 He ??
24 Q. I didn't ask you whether you saw it. Have
25 you read and studied his work, if there is such a
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1 thing?
2 A. All I can say is I have read material from
3 him. I don't know if it is the works, as you put
4 it. I don't know if that is the entirety but I've
5 read some papers.
6 Q. What is it?
7 A. It's regarding various aspects of
8 Scientology. This was a couple of years ago.
9 Q. And what's his thesis?
10 A. Well, basically, he approaches it from an
11 academic scholarly approach, pretty much like a
12 social scientist would approach it, as an
13 academician might approach it, as opposed to John
14 Atak approaches it or Russell Miller approaches it
15 or the New York Times might approach it. He
16 approaches it with a lot of footnotes and
17 cross?referencing it to works ??
18 Q. Well, what's his thesis?
19 A. That Scientology is a social phenomenon
20 that has certain characteristics and should be
21 studied as a social phenomenon, and that's a pretty
22 unique view.
23 Q. What do you mean unique view?
24 A. Because most of the time the way
25 Scientology ends up being analyzed in the ?? I
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1 would just say in publications in general is in a
2 sort of a sensational way, and so he's taken a more
3 scholarly approach and I think that's a very good
4 way to do it, rather than just sort of overnight
5 newspaper or magazine stories. He spends time ??
6 Q. So you agree with what his conclusions are
7 about Scientology?
8 A. No. I agree with his approach. I think
9 it's very ??
10 Q. And what about his conclusions don't you
11 agree with?
12 A. I don't remember any particular
13 conclusions that I can cite that I agree or
14 disagree. It's more of the case that I approve
15 greatly of the approach. That he bases his upon
16 interviews with people, study of the material,
17 correlating it to existing studies.
18 Q. Does he compare it to other religions?
19 A. I think he may have made some social
20 comparisons. I don't remember any comparisons in
21 the nature of religious philosophy.
22 Q. Is Buddhism a religion?
23 A. I would call it a religious philosophy.
24 Q. Would you consider it ?? would you
25 consider a Buddhist, somebody that practices
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1 Buddhism, would you consider that ?? is it your
2 position that they are practicing a valid religion?
3 A. I would say they are religious but
4 Buddhism is especially difficult because it is such
5 a catch as catch can religion, which I put in
6 quotes, but it's right on the fringe, but, yeah, I
7 suppose I could say, yeah, it's a religion. It's
8 just that it's such an individual religion.
9 Q. You think there might be a few million
10 people in the world that would ?? tens of millions
11 of people in the world that might disagree with
12 you, that is absolutely not a fringe religion, that
13 it is a religion?
14 A. Oh, yes. At the same time, same with the
15 Tao, which a number of people would say, even
16 though they are Taoists, they don't consider it a
17 religion, they consider it a way of life. So when
18 you get into the Eastern religions, it gets to be a
19 very sticky subject.
20 Q. What do you mean Buddhism is a fringe or
21 on the fringe or is a fringe religion?
22 A. I didn't say fringe religion. I said it's
23 one that by its practice, you have Buddhist
24 organizations which are definitely Buddhist
25 organizations and religions in that sense of the
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1 word, but at the same time you have a number of
2 practicing Buddhists that are independent and very
3 free?floating and practice it on such an individual
4 level that they wouldn't say it's a religion as
5 much as it's more in the way of the Tao, it's a way
6 of life, it's a way of behaving more than it is a
7 discipline.
8 Q. Sort of like Scientology, it's a way of
9 life, it's a belief system, it's a religion
10 considered by many people, correct?
11 A. That would be a comparable thing, yeah.
12 Q. All right. I believe in the past you were
13 probably quoted as comparing Scientology in some
14 way to Buddhism.
15 A. Back when I was in the organization, yes.
16 Q. Now, what have you published on this area
17 of expertise that you have?
18 A. Well, I published an article in Quill
19 Magazine.
20 Q. When was that?
21 A. Oh, gee.
22 THE WITNESS: Hey, Rinder, what year was
23 that?
24 Q. Just answer the question. Okay? Were
25 you in Scientology?
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1 A. No. This is like circa 1992 or so.
2 Q. Fine. And that ?? and that was a what, a
3 lengthy article, a short article?
4 A. Well, it was lengthy, it was ?? it had
5 a ?? Quill, first of all, is the magazine of The
6 Society for Professional Journalists and it was
7 lengthy in that there was the main article and then
8 there was a large side ?? what they call a sidebar,
9 which was one page, which a one?page article itself
10 would be enough but that was a large sidebar. Then
11 there was two or three more sidebars to that which
12 were one?column pieces that each of those stood by
13 themselves, so ??
14 Q. And you wrote favorable things about
15 Scientology in this article?
16 A. Depends upon your definition of favorable.
17 It was truth ??
18 Q. In other words, it was a very critical
19 article. It was after you had decided to leave the
20 religion and you started getting paid to testify
21 against it, correct?
22 A. I ?? that's totally false.
23 Q. Oh, you've never been paid to testify
24 against Scientology?
25 A. I just said your statement was false.
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1 I've never been paid to testify against
2 Scientology.
3 Q. And you're not being paid today either,
4 right?
5 A. I'm here as an expert. I expect to get
6 paid only for my time because you want me.
7 Q. Now, other than this Quill Magazine ??
8 were you paid for that article, by the way?
9 A. Yes.
10 Q. How much were you paid for it?
11 A. Oh, I don't remember, just a few hundred
12 dollars.
13 Q. Now, other than that article, have you
14 been published anywhere with regard to Scientology,
15 with regard to the issue of ?? by the way, did that
16 article have to do with the issue of religiosity in
17 Scientology?
18 A. In a sense, because it was how I
19 manipulated the media to create the image that was
20 needed and how we misled the press and ?? to create
21 an image that really wasn't true.
22 Q. Kind of a life story?
23 A. No.
24 Q. Anything else that you published with
25 regard to the issue of religiosity in Scientology
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1 or this other ?? how the Sea Org works or the
2 familiarity with command lines?
3 A. Peripherally, there was the article that I
4 wrote for Der Spiegel Magazine.
5 Q. Which you got $20,000 for, right?
6 A. Well, that was part of it. The rest was
7 for consultation.
8 Q. Other than those two?
9 A. I believe that's all.
10 Q. Okay. What ?? what college or advanced
11 degrees have you gotten with regard to this area of
12 expertise, the religiosity of Scientology or
13 religion, for that matter? Have you taken courses
14 with regard to comparative religions or religions
15 or religious philosophy or the world religions or
16 anything like that?
17 A. Well, my major in college was philosophy.
18 Q. Well, do you have any advanced degrees
19 with regard to religion?
20 A. With regard to religion just as generally
21 as philosophy, I did ?? no, my emphasis was
22 philosophy of psychology, which I was working on a
23 Ph.D.
24 Q. Which you never got, right?
25 A. No, I did not get it.
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1 Q. So I take it the answer is you don't have
2 any advanced degrees with regard to religion, is
3 that right?
4 A. That is correct.
5 Q. What opinions are you being asked to give,
6 as you understand it?
7 A. Basically, how the organization ?? well, I
8 gave that a while ago, describing it.
9 Q. Just do it again. How the organization
10 works ??
11 A. How the organization operates and moves as
12 interacts between the pieces.
13 Q. Okay.
14 A. How the religious image ?? the history of
15 creating religious image in the organization and
16 how that was done. And back ?? going back on the
17 first point, of course, then it would be the
18 entities and the operations of what moves those ??
19 on those command or information channels.
20 Q. And then the Sea Org, is that the last
21 thing?
22 A. Well, that is ?? that would be the ??
23 Q. Part of that?
24 A. The entity that by which ??
25 Q. Now, but are there any ?? are there any
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1 opinions that you're being asked to give, as you
2 understand it, with regard to Scientology? Are you
3 being ?? I mean you understand the difference
4 between a percipient witness and an expert, right?
5 You understand that there is a difference?
6 A. Yes.
7 Q. Now, all you've told me so far, as I
8 understand it, is you're going to come in here and
9 tell us about your experiences in Scientology,
10 which sounds sort of like a percipient witness. So
11 what I'm asking you is what is it, as you
12 understand it, that you're being asked to give an
13 opinion on or an expert opinion on as opposed to
14 your 21 years worth of experience in misleading the
15 public with regard to Scientology, according to
16 what you say?
17 A. Well, I'm capable of actually finding,
18 showing and interpreting, showing how Scientology
19 publications and directives reflect the points that
20 I'm trying to ??
21 Q. That's great. But the whole purpose of
22 this deposition is for me to ask and you to tell me
23 what it is you're going to testify about.
24 A. Yes.
25 Q. Okay. So when you say I'm capable of
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1 doing that, that doesn't do anything for me. I
2 want to know what it is you're going to do with
3 regard to your testimony.
4 A. I'll be able to show how the organization
5 moves and offer my opinion that it has operated on
6 that for decades and continues to operate on that
7 because of the policies of Hubbard, and how they
8 are embedded in the organization and have been for
9 many decades so that the public relations
10 publications do give an actual, accurate reflection
11 of this, as well as the directives, and that the
12 organization continues to operate this way.
13 At the same time, I can also show that the
14 religious issue is not sincerely held.
15 Q. Okay. You understand the problem I'm
16 having here? It's ?? you know, it's terrific that
17 you ?? that you want to come in here and ?? I don't
18 think it's terrific but you want to come in here
19 and tell us about your experience. Okay. Great.
20 I'm not interested in your experience. What I'm
21 interested in is what opinions are you going to
22 give? Now, you've told me generally. I just want
23 to know what opinions ?? let's start with the
24 religious issue. What is the opinion that you're
25 going to give with regard to the religious issue?
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1 MR. DANDAR: Asked and answered.
2 MR. WEINBERG: No, it's not, Ken.
3 A. That any presentation that this is a ??
4 that this is ??
5 MR. WEINBERG: Excuse me for a second.
6 Look, Ken ??
7 MR. DANDAR: Don't argue.
8 MR. WEINBERG: No, this is nonsense.
9 MR. DANDAR: I made my objection.
10 MR. WEINBERG: You give interrogatories
11 here that are a bunch of garbage and we're
12 getting garbage from Mr. Young now, and what I
13 want is some opinions. And you know we're
14 getting sandbagged horribly in this situation.
15 You serve on us a motion, you don't give us
16 the documents, it's a bunch of nonsense.
17 BY MR. WEINBERG:
18 Q. Now, what I'm asking you, Mr. Young, is
19 tell us what you're going to testify to tomorrow as
20 your opinion as to the religious issue. Just tell
21 us that.
22 A. The presentation Scientology is a valid
23 religion and deserves the protection of the First
24 Amendment is wrong, that it should not be granted,
25 that it is not sincerely held within the
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1 organization and has never been held within the
2 organization, and that the presentation of that
3 particular topic is one that is created by
4 Mr. Rinder's section, by Department 20, and has
5 been that way for decades.
6 Q. That's your opinion?
7 A. Yes.
8 Q. That's the opinion? Okay. Now, what is
9 the basis for your opinion that the presentation of
10 Scientology is valid is wrong?
11 A. Documents and personal experiences and
12 speaking with ??
13 Q. I'm just asking specifically, what is the
14 basis? Spell it out for us. Which documents, what
15 experience?
16 A. Having seen it, done it, trained people in
17 it, been trained in it, even with working with
18 Mr. Rinder on it, 21 years of seeing it, doing it,
19 represented in the press, et cetera, for the same
20 reason that I wrote the article in Quill Magazine,
21 why I was able to try to educate journalists on
22 really how the organization operates.
23 Q. What documents are you relying on?
24 A. For which part?
25 Q. What you just said. You said that it ??
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1 that you're going to give an opinion that
2 Scientology ?? that Scientology is ?? that the ??
3 in essence, Scientology is not a valid religion,
4 from your experience, you said, in Scientology, you
5 haven't given us the specific experience, and from
6 various documents. Which documents?
7 A. For example, I'm not going to be able to
8 cite specifically because I didn't know you were
9 going to be asking me these questions.
10 Q. What's he going to ask you tomorrow? Are
11 you going to cite specifically tomorrow or are you
12 just going to come in and say I was there for 21
13 years and based on my 21 years, it's not valid?
14 A. Calm down, sir. For example, there is a
15 policy letter that Mr. Hubbard wrote. I don't want
16 to be quoted exactly on this but I believe it was
17 nineteen ?? maybe it was 1970 in which he says
18 that, for example, about the religious nature of
19 Scientology, and how the year 1970 is going to be
20 a big push to establish Scientology as a religion.
21 That policy is contained in the most
22 recent volumes of the organization, the Green on
23 White volumes. The difficulty is that the original
24 issue that came out in the first Green on White
25 volumes had some extra paragraphs that they have
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1 deleted without telling anybody, and the deletion
2 is exactly how you manipulate things. The ?? what
3 was deleted from Mr. Hubbard's policy was where he
4 says don't worry, this doesn't change anything,
5 this is just a matter for the accountants and
6 solicitors, and another paragraph where he talks
7 about selling shares.
8 So they deleted that because that shows
9 that he was selling shares in his religion and that
10 he just said, really guys, what we're doing on this
11 religious issue of pushing religion doesn't have
12 anything to do with anything, it's just a matter
13 for the lawyers and the accountants.
14 And the fact that the organization deleted
15 it from their newly?released volumes is exactly how
16 you manipulate image. They are going to take the
17 volumes and they'll present them to the Court and
18 they'll say see, your Honor, here is Mr. Hubbard
19 talking about religion. And all I have to do is I
20 just have to remind somebody that what Mr. Hubbard
21 said in the original issue is a little bit
22 different and presents a very different picture.
23 And this is how you manipulate the courts.
24 Q. All right. But your testimony is it's not
25 a valid religion. That's your testimony, right,
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1 that's your opinion?
2 A. Yes.
3 Q. Okay. Now, what standard have you used ??
4 can you tell us what ?? how you would ?? is there
5 some standard, some rule of law that you as an
6 expert are familiar with as to what is a religion,
7 a valid religion, and what is not a valid religion?
8 Can you elucidate on that for us?
9 A. The main thing I would first of all cite
10 myself would be the sincerity in the presentation
11 of the organization, that if the organization and
12 the leadership is presenting this thing as a
13 religion and you're like some shyster evangelist
14 travelling sideshow, that you're out front
15 preaching about Jesus and then going back and high
16 fiving and counting the til and figuring out how
17 many more ladies you can bilk, I wouldn't consider
18 that sincere and I wouldn't consider that to be the
19 presentation of a religion, regardless of what the
20 people out front may have thought. And that's
21 exactly the first thing I would testify to is that
22 the presentation that is being made by the
23 organization ?? you used the word scriptures. Like
24 I said, I've never heard one Scientologist in 21
25 years ever do that. I never heard one ??
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1 Q. Was that part of the test, so if you don't
2 call it scriptures you're not a religion?
3 A. No, I'm just ??
4 Q. What is the test for being a religion?
5 You're the expert. What is the test for being a
6 religion?
7 A. I'm telling you my first ?? you asked me a
8 question, I'm responding. I said the first thing
9 would be with regard to the sincerity of
10 presentation. Is it actually being sincerely
11 presented? The second test I would do on it is is
12 it being honestly presented as to what the
13 organization is actually there to do? Is it really
14 there to do what it is presenting, is it being
15 honestly presented? I don't believe it's being
16 honestly presented. We never honestly presented
17 it. I don't think ??
18 Q. Of course, you haven't been there for ten
19 years, have you?
20 A. Inside as a staff member, no.
21 Q. Yes.
22 A. But Mr. Hubbard ?? they can't change
23 Mr. Hubbard's writings, it stays the same. They
24 testify to that. I don't need to know anything
25 different other that what they continue to do.
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1 Q. So it's just ?? it's just your assumption
2 that no one on the staff of Scientology has a
3 sincere belief in Scientology. Is that your
4 testimony?
5 A. That's not what I was just saying.
6 Q. Is it your testimony ??
7 A. That's not what I was just saying.
8 Q. Is it your testimony that no one on the
9 staff of Scientology has an honest belief in
10 Scientology?
11 A. No, I didn't say that.
12 Q. Well, what are you saying?
13 A. I just tried to say ?? first of all, you
14 ask me a question, I answer and then you just say I
15 didn't say it. So either we can read back the
16 transcript ??
17 Q. No. No. What are you saying?
18 A. I just said it. Didn't you hear me?
19 Q. No. Well, I may have heard the words.
20 They don't make any sense, Mr. Young.
21 A. Well, I'll start again. We'll start again
22 on the sincerity one. We'll start again, okay?
23 Q. Fine.
24 A. Okay. It's your nickel.
25 Q. What do you meant it's my nickel?
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1 A. It's your time. You've got a couple of
2 hours. If you want me to cover my testimony again,
3 I'm more than willing to do it again.
4 So we'll start on sincerity. It's a
5 matter of the sincerity of whether or not what the
6 organization is presenting is truly being presented
7 sincerely or if it's not being presented sincerely.
8 I know from experience and I can show it by things
9 and I will cite again, the matter of an issue that
10 Mr. Hubbard presented ??
11 Q. You've already told us about that.
12 A. Well, you said you didn't hear it, you
13 didn't believe it.
14 Q. So your test of a religion is whether it's
15 sincere as presented by, I guess, not the members
16 of the religion but the people that ?? the
17 ministers in the religion. Is that what you're
18 saying?
19 A. The organization.
20 Q. The organization. And then whether it's
21 honest ?? whether they're honest about their
22 beliefs, that's the second test. Is there any
23 other test for what would be a valid religion in
24 the Vaughn Young world?
25 MR. DANDAR: Object to the form.
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1 A. If you want to just not make accusations,
2 I'll answer your question.
3 Q. It's a very sincere question.
4 A. I'm not going to ??
5 Q. You have presented yourself as one of
6 three experts in the world, two of which are in
7 this room, on the religiosity of Scientology. So
8 I'm asking you in your world, in that very small
9 world, you know, what is your test for what a valid
10 religion is beyond sincerity and honesty?
11 MR. DANDAR: Object to the form. Move to
12 strike.
13 A. I don't have a world from which I'm
14 responding. If you want to just ask me for mine, I
15 will give it to you.
16 Q. I just asked you.
17 A. No, you didn't.
18 MR. WEINBERG: Ken, he's not being
19 responsive. This is going to take ??
20 MR. DANDAR: You're asking argumentative
21 questions.
22 MR. WEINBERG: Ken, I'm not asking
23 argumentative questions.
24 MR. DANDAR: Here we go again. The last
25 time was 20 seconds.
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1 MR. WEINBERG: What I'm getting is
2 argument and it's nonsense and this is the
3 most preposterous, ridiculous testimony I have
4 ever heard in my entire life.
5 MR. DANDAR: Well, you know, thank you
6 for your opinion but you asked him a question,
7 he's answering them.
8 MR. WEINBERG: No, he's not. He hasn't
9 even tried to answer them.
10 MR. DANDAR: Well, then adjourn and let's
11 go to the judge.
12 MR. WEINBERG: Oh, stop. We will go back
13 to the judge, there is no question about that.
14 MR. DANDAR: You better believe we will.
15 MR. WEINBERG: Oh, no, we will. This is
16 preposterous.
17 BY MR. WEINBERG:
18 Q. What is your test for a religion,
19 sincerity, honesty, what else?
20 A. The next category that I would do would
21 just be the presentation of the organization in
22 toto, which you're asking for my particular
23 opinion.
24 Q. What else can I do? I'm asking for your
25 opinion. What else can I do?
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1 A. I'm not arguing, I'm just responding.
2 Q. Well, go on.
3 A. God, you ask me to respond and then you
4 challenge me when I respond.
5 The organization, for example, and this
6 goes back to when I say in toto, this goes back to,
7 let's say, physical presentation. When an
8 organization creates a physical appearance with
9 structure and garb, which is slightly different,
10 that is also intended to be misleading.
11 Q. I don't understand what you just said.
12 What do you mean by that? Sort of like a Catholic
13 priest? What are you talking about with garb?
14 MR. DANDAR: I'm going to object to you
15 interrupting him. Don't interrupt him. Wait
16 until he's done and then ask him those ??
17 MR. WEINBERG: He was done.
18 A. I was not done. I was about to say it.
19 For example, when the religion campaign started in
20 '70 and then picked up when I got it in '71, we
21 were instructed to create chapels, set aside
22 sections of the organizations for chapels so that
23 we had a religious image. They weren't intended
24 for use but if somebody walked in and they saw a
25 chapel, they got the impression. We were
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1 instructed to wear crosses around our necks, not
2 because we were religious but because we needed the
3 image.
4 And you build these things, you create
5 this edifice up there so people look at it and they
6 think, oh, this must be a church. And so again,
7 you're creating ??
8 Q. Do you think a collar that a priest wears,
9 is that just ?? is that just for show?
10 A. It is in Scientology.
11 Q. I'm saying a collar for a priest, is that
12 for show in the Catholic church?
13 A. You'd have to ask that priest.
14 Q. I'm asking you as an expert on religion.
15 A. I'm not an expert on priests, sir. I'm
16 just only testifying about Scientology.
17 Q. So the only religion you're an expert in,
18 according to your testimony, is Scientology? You
19 can't compare it to any other religion, is that
20 right?
21 A. I'm familiar with other religions.
22 I've studied other religions but I'm not going to
23 testify ??
24 Q. Which other religions have you studied?
25 MR. DANDAR: Wait, you're interrupting
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1 him.
2 A. Let me finish my ??
3 MR. DANDAR: Just calm down, guys. Look,
4 let him finish his answer.
5 Q. Go ahead.
6 A. I'm not going to testify about other
7 religions. I am familiar with them only to the
8 degree that I am familiar with them with my own
9 education, but I'm not going to testify about other
10 religions.
11 Q. Which other religions have you studied?
12 A. Well, I've studied Christianity.
13 Q. In college? When did you study
14 Christianity?
15 A. Well, I was raised as a Christian, so you
16 start with that. There is a lot of ??
17 Q. When I say study I'm talking about
18 something more than being raised. What ?? did you
19 take some training in Christianity beyond your
20 youth?
21 A. No.
22 Q. What other religions have you studied?
23 A. One ?? studies is ?? you're going to argue
24 with me about that but one studies religions just
25 in gaining degrees in philosophy when one studies
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1 various movements and developments of philosophy.
2 I did not study the religion to sit down, per se.
3 You study them within the context of the
4 development of thought. So you just study whether
5 or not the ?? Catholicism, how it influenced, say
6 came out ?? was influenced by Aristotelian
7 thoughts, influenced Galileo, developed into the ??
8 into some other form.
9 Q. It's a simple question. I just asked
10 you ??
11 A. Hey, wait a minute. I gave ??
12 Q. I'm getting some nonsense about
13 Aristotelian thoughts. Is it Catholic, fine,
14 Catholic, is it Buddhist, fine, Buddhist, just tell
15 me.
16 A. You know, I'm answering your question.
17 Q. No, you're not.
18 A. Well, you take that ?? what that person
19 just did and give it to anyone and they'll find
20 that as a valid response.
21 Q. Let's go to the next question.
22 A. The problem is you don't like my
23 responses.
24 Q. No, I don't ?? like your responses? We'll
25 be here for the next month and a half because you
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1 don't answer the question.
2 A. Take that response to the judge. It will
3 be found to be a valid response.
4 MR. DANDAR: He's talking about in the
5 area of philosophy, which is what his
6 Ph.D. candidacy was in.
7 MR. WEINBERG: Just stop. Just stop.
8 MR. DANDAR: But you don't want to hear
9 that? Fine. Just make sure you're not making
10 a mistake here.
11 MR. WEINBERG: Excuse me?
12 MR. DANDAR: Just make sure you're not
13 making a mistake here.
14 MR. WEINBERG: No, you're making a
15 mistake here.
16 BY MR. WEINBERG:
17 Q. What is ?? what are the opinions ?? are
18 you giving an opinion tomorrow as to whether
19 Scientology is a valid religion? Are you giving an
20 opinion as to that?
21 A. That I don't consider it to be a valid
22 religion in the sense that we normally use it in
23 this ??
24 Q. We, being who?
25 A. Can I finish my sentence, please?
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1 Q. I'm just trying to clarify.
2 MR. DANDAR: No, you're interrupting him.
3 THE WITNESS: I'd like to take a break.
4 A. I mean seriously sir, all you do is in
5 the middle of my sentence, and the record will show
6 it, you interrupt me and then you challenge me and
7 then you say I'm not answering your question when
8 I'm trying to answer your question.
9 Q. You haven't tried to answer my question.
10 Let's start over again.
11 A. That is bullshit, sir.
12 Q. Excuse me?
13 A. I'm sorry. That is bullshit when you say
14 I'm not answering your question when you interrupt
15 me.
16 MR. DANDAR: Stop. Do you need a break?
17 Do you need a break?
18 A. You asked me a question and the record
19 will show you cut right into the middle and then
20 you say I'm not answering your question.
21 MR. DANDAR: Robert, you're right but do
22 you need a break?
23 THE WITNESS: No, it's just, I mean
24 really ??
25 MR. DANDAR: Do you need a break?
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1 THE WITNESS: I need a glass of water.
2 MR. DANDAR: Let me get you some water.
3 All right. Let's take a water break.
4 (Recess from 5:17 until 5:19 p.m.)
5 BY MR. WEINBERG:
6 Q. What is your ?? you say you're going to
7 give an opinion that Scientology is not a valid
8 religion. What is that opinion based on,
9 specifically based on?
10 A. Didn't I just spend a half an hour doing
11 that?
12 Q. Just answer my question.
13 MR. DANDAR: Yes. Asked and answered.
14 A. Okay. We'll start this again.
15 MR. DANDAR: Wait. Let me interrupt you.
16 You are right, it's their time, just answer
17 their question.
18 THE WITNESS: I'm more than happy to do
19 it again.
20 MR. DANDAR: If they want it 20 times, go
21 ahead.
22 A. No, I'll do it again. This is based upon
23 my 21 years of experience, my ability to locate
24 documents, my ability to integrate the information,
25 to show how the organization operates by
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1 manipulation. Mr. Hubbard wrote something in 1970
2 with regard to religion, which in the older volumes
3 shows that he cited something else, which was
4 that ?? where he says this is purely for the
5 solicitors and the accountants. The presentation
6 of something like this now in new volumes as if it
7 always existed that way is a prime example of how
8 the organization manipulates its image to create a
9 document that it can use in the courts. This was
10 something we did constantly in the organization and
11 so it's clearly still doing it with these current
12 volumes that are there.
13 I can also find other instances and bring
14 these forward with regard to how the organization
15 manipulates its image and that this is done through
16 the Sea Org channels.
17 Q. So that's the basis, what you just said,
18 for what your opinion is going to be that
19 Scientology is not a valid religion, is that right?
20 A. And, to finish ?? if I may finish my
21 thought that was cut off before, in the sense that
22 we normally use this in the United States, which
23 usually comes to be an ??
24 Q. Use what though, use religion you mean?
25 A. I'll try to finish my sentence. Could I
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1 finish my sentence?
2 Q. Yeah.
3 MR. DANDAR: Go ahead.
4 A. Of which we use this in the United States
5 in which usually we mean this as an established,
6 recognized, religious organization, which usually
7 comes also to mean landed, which means it has a
8 base location, et cetera, which is different than
9 say Taoism practiced in the United States. I don't
10 think you can find a Taoist church or building
11 around, perhaps you could. And yet we would call
12 that a religion. But we have to be very careful in
13 doing so because people say what's the basis of it
14 being a religion, can it get a tax exemption?
15 Well, Taoism is just simply a religion. In the
16 United States when we talk about religion, we
17 usually end up throwing it into IRS categories and
18 501C?3 categories and can it get an exemption for
19 state taxes, et cetera. So we have to be careful
20 here.
21 If we talk about religion in a
22 philosophical sense as I was studying it, then it
23 becomes simply a subject. It's got nothing to do
24 with 501C?3, it's got nothing to do with landed.
25 It's got to do with the development of religious
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1 thought and religious philosophy.
2 As I was trying to explain before, then
3 you study how Catholicism integrated with the
4 scientific movement, how it developed through the
5 Renaissance ??
6 Q. But I asked you the basis for your opinion
7 that Scientology was not a valid religion. So now
8 is it ?? is it that it's not landed, is that what
9 you're ?? is that what you're saying? In addition
10 to everything else that you said, is that what you
11 just got through saying?
12 A. Were you really listening or just doodling
13 while I was talking? Because you were doodling all
14 the time I was talking. You're obviously bored.
15 Q. Obviously, you're watching me doodle. I
16 mean are you ??
17 A. Well, you're not listening to me.
18 Q. Trying to. It's not making a lot of
19 sense.
20 A. And you interrupted me again.
21 Q. I had to because you were talking about
22 Catholicism. I'm talking about Scientology and
23 your opinion that it's not a valid religion.
24 A. I answer your question and then you say I
25 don't answer your question. So either it ?? you
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1 know, if you don't want to count it as an answer
2 then you don't count it as an answer. But I'm
3 trying to explain to you why I'm ?? how I'm going
4 to use the word religion and I'm going to try to
5 use it very carefully. And if you want to doodle
6 and say it's not an answer ??
7 Q. Okay. How are you going to use the word
8 religion? Since your opinion has to do with
9 religiosity, I assume religion is part of
10 religiosity?
11 A. As a subject.
12 Q. Right. So how are you ?? how are we ??
13 how are you defining the word religion tomorrow
14 when you say that Scientology is not a valid
15 religion?
16 A. I will use it in the sense of being a
17 landed organization that should be fully recognized
18 by government as a valid operating religion, which
19 you switched to sort of a slightly different sense.
20 I would characterize it more as of, you know, a
21 traveling circus show of the old '20s.
22 Q. Scientology?
23 A. That's ?? pretty much that's how Hubbard
24 set it up.
25 Q. Okay. Now, what do you mean by ?? since
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1 we ?? now we finally got a definition for religion.
2 What do you mean by landed organization, what's
3 that mean?
4 A. In the sense that you can locate it. If
5 you will, just let me just say something without
6 interruption. It's very easy to have a religious
7 movement or a philosophical movement based upon a
8 book, for example. Someone puts out a book and
9 there is suddenly a movement. People are talking
10 about it, there is news stories about it. You
11 know, like, just off the top of my head, it's
12 certainly not a religion but this guy that wrote
13 Men are from Mars and Women are from Venus, and it
14 took off and this whole thing. That is not a
15 landed movement. It's not located somewhere.
16 Where do I go find out about it? It's just a
17 movement like hula hoops or something.
18 A landed organization is one that you can
19 go find it and say where do I go to find out about
20 it and there are people and they tell me about it,
21 et cetera. That's different than just a general
22 movement. Okay?
23 Q. Okay. Now, Scientology is a landed
24 organization?
25 A. Definitely.
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1 Q. Okay. So we've met that part of the
2 definition of religion when you say ??
3 A. No. No. Just ?? I'm sorry, I
4 misunderstood you.
5 Q. Now you're interrupting me, aren't you?
6 A. You're absolutely right, Mr. Weinberg, and
7 I apologize.
8 Q. Now, Scientology is a landed organization,
9 correct?
10 A. Correct.
11 Q. All right. Because I can find it, can't
12 I?
13 A. Yes.
14 Q. All right. Then you say a landed
15 organization that should be fully recognized by
16 government, and in the United States, Scientology
17 is fully recognized by the government of the United
18 States as a religion that is entitled to tax exempt
19 status, isn't it?
20 A. No. I have to dispute you when you say
21 fully recognized by the government of the United
22 States. Just because you got recognized for tax
23 exemption doesn't mean you are recognized by the
24 entire United States government.
25 Q. Well, excuse me for a second, but how does
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1 one get recognized by the entire United States
2 government?
3 A. Beats me.
4 Q. Okay. So the best I can do when we're
5 talking about religions and tax exempt status is to
6 be recognized by that part of the United States
7 government that's responsible for it, which is the
8 IRS, right?
9 A. No. There is other sections and I ??
10 this goes back into what else I can testify to.
11 Different sections of the government grant
12 recognitions according to their needs. In 1975, I
13 was the one within the organization responsible for
14 gaining recognition from the US State Department
15 granting the Church of Scientology religious
16 recognition for the purpose of visas. I was also
17 responsible for gaining the recognition from the US
18 Labor Department, which granted the Church of
19 Scientology recognition with regard to labor law.
20 Each section of government has its own peculiar
21 recognition that may be extended to any
22 organization with regard to that particular domain.
23 Q. Right. And the State of Florida, State of
24 California, various other states have recognized
25 the Church of Scientology for various things,
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1 including tax exempt status, haven't they?
2 A. That might be.
3 Q. Fine. So that ?? do you know of any part
4 of the government of the United States that hasn't
5 recognized the Church of Scientology for whatever
6 it was that the Church of Scientology wanted to be
7 recognized for?
8 A. Not right now, no.
9 Q. And courts have recognized the Church of
10 Scientology as a religion, haven't they?
11 A. I don't know that that ?? that has been
12 argued and recognized in an actual court as being
13 argued and recognized.
14 Q. Well, haven't you ?? have you read ?? did
15 you read the Eleventh Circuit opinion with regard
16 to the City of Clearwater and Scientology, did you
17 read that?
18 A. I ?? pardon me on Eleventh Circuit. I
19 lose track on ??
20 Q. That's the circuit that has to do with
21 this part of the country, Eleventh Circuit Court of
22 Appeals, Federal.
23 A. Okay. But I would ?? I would have to see
24 that to remember if I read it.
25 Q. Well, do you remember that the Eleventh
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1 Circuit spoke eloquently about Scientology and how
2 it's protected by the First Amendment and how the
3 City of Clearwater had discriminated against it for
4 20 years?
5 A. No.
6 Q. You don't remember that?
7 A. No, not offhand.
8 Q. Now, so your definition, I'm going to your
9 definition of religion, landed organization, which
10 we've acknowledged is Scientology, that should be
11 fully recognized by the government, and you just
12 told me in addition to tax exempt status you were
13 successful in getting the State Department to
14 recognize visas and the Labor Department to
15 recognize various labor things, and you just said
16 that you don't know of any section of government
17 that hasn't recognized the Church of Scientology.
18 So my question is why doesn't Scientology meet your
19 definition? It's a landed organization that was
20 fully recognized in the United States by the
21 government as an operating religion.
22 A. Because we were obtaining those
23 recognitions from government fraudulently and I was
24 part of that fraud.
25 Q. All right. So what you're saying is ??
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1 when we get right down to it, is that you concede
2 that Scientology is landed, you concede that
3 Scientology has been recognized by government, but
4 you're here to try to undo the recognition because
5 you say that you, sir, committed a fraud for over
6 21 years?
7 A. No.
8 Q. That's your testimony?
9 A. No.
10 Q. Well, what is your testimony then?
11 A. Well, okay. I'll start again.
12 Q. No, don't start again.
13 A. Sir, you just asked me what's my
14 testimony. That's a pretty general question.
15 MR. DANDAR: No, he just wants to ?? I
16 can't help you out. I don't know.
17 Q. The ?? it is your position then that even
18 though you define religion as a landed organization
19 fully recognized by government, that Scientology
20 doesn't qualify because you say you participated in
21 a fraud for 21 years?
22 A. That was just one point I cited, sir.
23 Q. Okay. Is there some other point, because
24 it certainly seems to meet your definition?
25 A. No. I cited a number of other points. If
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1 we want to do this again, I'm more than happy to do
2 it again.
3 Q. Well, is the definition any different, or
4 is this ??
5 A. No.
6 Q. There is no other aspect of the definition
7 of religion than landed organization that should be
8 fully recognized by government as an operating
9 religion. That is your definition of religion?
10 A. I make that subject to change. If you
11 want me to sit down and write one as opposed to
12 being in a deposition and toss it off the top of my
13 head ??
14 Q. See, you're the expert and I'm here to
15 find out what your opinion is. All I'm asking is
16 what's your definition of religion? You're in here
17 testifying about religion. It's not a difficult
18 question.
19 A. I'm trying ?? no. Only when you don't let
20 me answer it.
21 Q. You can say that all you want to but I've
22 given you plenty of opportunities to answer.
23 A. Okay.
24 Q. Is there some other definition of religion
25 or is it going to change between now and tomorrow?
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1 A. No. We'll just discuss it tomorrow and
2 you can cross?examine at that point, I suppose.
3 Q. All right. Is there ?? as to the Sea Org,
4 you say that the Sea Org controls all of
5 Scientology, is that what you say?
6 A. No, I didn't say that.
7 Q. What are you saying about the Sea Org?
8 A. The Sea Org is a ?? an organization who's
9 influence and command channels have not been
10 recognized ?? do you want me to wait until you're
11 done?
12 Q. Just go ahead.
13 MR. DANDAR: Go ahead, Robert.
14 Q. All I'm reading is ?? I asked you a
15 question. You're saying that the Sea Org controls
16 all of Scientology. I'm reading here from these
17 interrogatories that you helped Mr. Dandar write,
18 provide a summary of the grounds for each of your
19 opinions. And then you say in here ?? in here in
20 Exhibit, whatever it is, A, the voluminous Sea Org
21 and Scientology documents show that Sea Org
22 controls every facet of all of Scientology. And my
23 question was, you say the Sea Org controls all of
24 Scientology, and your answer to that was no, I'm
25 not saying that. So I don't get it.
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1 A. There is a lot of questions in there.
2 First of all, I ?? I told you before I did not help
3 him write that.
4 Q. So this is wrong then, you're not going to
5 say that the Sea Org controls all of Scientology?
6 A. No, I did not say that.
7 MR. DANDAR: Just tell him what you're
8 going to say. That's all he wants to know.
9 A. I'm not sure he wants to know. I started
10 to and you interrupted me, sir. May I finish my
11 sentence?
12 MR. DANDAR: Just wait for another
13 question.
14 A. Okay.
15 Q. You say that Sea Org controls all of
16 Scientology, is that right?
17 A. I'm saying that the Sea Organization is
18 that organization that permeates from the top down
19 to the lowest echelons on which control, commands,
20 information flows, and has been heretofore
21 unrecognized as to its influence and how it
22 operates. It extends as far as the Sea Org wants
23 it to extend.
24 Q. What are the command lines of the Sea Org?
25 A. Whatever it wants to be is the way it
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1 actually operates by current ?? through Mission
2 Tech. They can send any individual into any
3 organization with full, unlimited power to take
4 over the organization. That means somebody from
5 RTC could fly into the Copenhagen org and just show
6 up and take it over. It's not a command line.
7 It's like ??
8 Q. Do you know what I mean by command line?
9 A. Yes.
10 Q. Okay. Is there a command line in the Sea
11 Org?
12 A. Yes and no.
13 Q. Well, yes, what is the command line?
14 A. The command lines starts with David
15 Miscavige.
16 Q. As what?
17 A. As the captain of the Sea Org.
18 Q. And what is the command line under it?
19 A. Then it goes to his immediate aides.
20 Q. Well, what are the ?? you're the expert,
21 you're here to talk about Scientology. What are
22 the command lines?
23 A. I'm telling you that the command lines of
24 Scientology and the command lines of the Sea
25 Organization are two slightly different subjects.
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1 Because the command lines of Scientology are
2 intended to be corporately separate so the command
3 lines that they are showing are different slightly
4 from the Sea Organization. The Sea Organization
5 are the nerves, I try to say, that connect the
6 various organizations the way ??
7 Q. I'm asking you a really simple question.
8 What are the ?? I'll change it. What ?? the Sea
9 Org command lines are by rank, aren't they?
10 A. Yes and no. There is earned rank and
11 there is brevet rank.
12 Q. Okay. And what is earned rank?
13 A. Earned rank is what you have actually
14 earned, so that you are a petty officer or a
15 midshipman or a commander. A brevet rank is the
16 rank that you are given according to the position
17 that you hold in the organization. So the
18 commanding officer of, let's say, the advanced
19 organization in Los Angeles or the commanding
20 officer of the FSO will be a captain because the
21 captain, as in a captain of the ship, is in charge
22 of the entire organization. But the earned rank of
23 that individual might be a midshipman or it could
24 be a petty officer.
25 Q. What was your earned rank?
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1 A. My earned rank was petty officer.
2 Q. Which is right at the bottom, right?
3 A. No.
4 Q. What's the bottom?
5 A. The bottom is swamper.
6 Q. All right. And then petty officer is the
7 next, right?
8 A. No.
9 Q. What's after swamper?
10 A. Let's see, what was after swamper? Then
11 you get up to ?? gosh, I forget right now.
12 Q. Isn't it petty officer?
13 A. No. Gosh, there is one in between and
14 then you get up to petty officer.
15 Q. All right. So you were at the low rank?
16 A. Well, and earned, like a number of them,
17 yes.
18 Q. All right. And what was your brevet ??
19 what was your highest brevet rank?
20 A. I didn't hold a brevet rank.
21 Q. Because you didn't have a position of
22 authority in any of the ?? in any of the
23 organizations, correct?
24 A. No, no, that's not true. It was not a Sea
25 Org organization which we had to wear uniforms and
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1 therefore carry brevet ranks. You only do that
2 within the Sea Org organization.
3 Q. So in this case that you're testifying
4 about, your testimony is that David Miscavige's
5 earned rank is that of captain, is that right?
6 A. Yes.
7 Q. And that his brevet rank is that of
8 captain as well?
9 A. He has no brevet rank.
10 Q. Well, other ?? other heads of other
11 organizations are captains then? Who are the other
12 captains in the Sea Org?
13 A. There is other captains that hold brevet
14 ranks but there is no other earned rank of captain.
15 Q. That's what I just asked you. What is ??
16 who are the other brevet rank captains?
17 A. I don't have them in front of me.
18 Q. Can you name one?
19 A. Well, the last I knew Mark Yager, I knew
20 probably Mr. LaServe, I think Guillon might be.
21 The problem is that I don't have the list in front
22 of me.
23 Q. When I asked you if you were in
24 management, you said yes and no. Is that because
25 you ran people in management?
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1 A. Well, it's because we issued orders from
2 Author Services into management but we were not to
3 be recognized as management. So if anybody asked
4 us if we were management we had to deny it because
5 what we were doing was illegal.
6 Q. When you were doing the PR in the early
7 '70s, were you in the Sea Org?
8 A. No.
9 Q. When did you join the Sea Org?
10 A. I believe it was 1981.
11 Q. Well, the ?? does every swamper get
12 ordered by every petty officer third class?
13 A. No.
14 Q. When you were in ASI, what ?? what was
15 your rank? Petty officer, is that what it was?
16 A. Yes.
17 Q. You were giving orders to WDC, is that
18 right?
19 A. I think I issued a couple of orders into
20 WDC but it was ??
21 Q. Well, you were ?? so you were giving
22 orders to Sea Org members?
23 A. Yes.
24 Q. And you weren't a Sea Org member at the
25 time, were you?
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1 A. No, I was. I didn't start issuing those
2 orders until I was at Author Services.
3 Q. What were the orgs you ran?
4 A. I didn't run orgs, I just did sections.
5 Q. Well, who gave you orders in each org that
6 you were in, who was your immediate person giving
7 you orders?
8 A. For every org I was in?
9 Q. Yeah.
10 A. For 21 years?
11 Q. There weren't that many, were there?
12 Let's say for the last five.
13 A. Well, that would be at ASI. Orders were
14 being given by, for example, David Miscavige.
15 Q. But the person right above you, who was
16 the person giving you orders?
17 A. That's not the way it works, sir.
18 Q. Who was your superior in ASI?
19 A. That's not the way it works. If you want
20 to know who my superior was as opposed to who gave
21 me orders, those are two different things. That's
22 why I'm trying to explain this.
23 Q. Just name me one person that was your
24 superior in ASI.
25 A. David Miscavige.
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1 Q. Well, another person other than David.
2 A. I'm sorry you don't like the answer but
3 that's ??
4 Q. Somebody other than David Miscavige.
5 There were people that gave you orders that ?? that
6 had a lower rank than you, correct?
7 A. At ASI, Sea Org rank had nothing to do
8 with it. We weren't a Sea Org organization,
9 therefore, we did not even know each other's ranks.
10 Q. Were you in RTC?
11 A. No.
12 Q. What are the Sea Org organizations?
13 A. The primary ones, starting with the
14 advanced organizations, FSO, Advanced Organization
15 LA, Advanced Organization in Copenhagen, RTC would
16 be considered a Sea Org organization, Golden Era
17 Productions would be a Sea Org organization.
18 Q. What was the rank of David Miscavige at
19 ASI?
20 A. He did not have a rank. We were not a Sea
21 Org organization.
22 Q. Well, he was a member of the Sea Org while
23 he was at ASI, wasn't he? So he had a rank, what
24 was his rank when he was at ASI?
25 MR. DANDAR: Object to the form.
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1 A. He did not ?? he did not have a rank and
2 this is the ?? this is what goes on, this is why it
3 is not understood, apparently, even by you,
4 Mr. Weinberg. In a Sea Org organization, rank does
5 appear. If you're not a Sea Org organization ??
6 for example, let's say the Miami Church of
7 Scientology, let's say it's not a Sea Org
8 organization. You will find no Sea Org rank
9 appearing. You will find people just in their
10 every day jobs. He is the director of
11 communications, he's the director of processing, he
12 is the qualifications secretary. They will have
13 positions on the organizing board and Sea Org will
14 appear nowhere, even though they may be Sea Org
15 members.
16 Q. So you get your authority from your
17 position in the organization, not from your rank in
18 the Sea Org, correct?
19 A. Yes and no. Again, these are the two
20 faces of Scientology. If you don't understand it,
21 then you're going to have to have them explain it
22 to you or I can explain it to you tomorrow.
23 Q. How about explaining it to me now?
24 A. Okay. Good. Scientology has two faces.
25 It has a face that is public and a face that is
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1 private. The private face, then there are two more
2 levels. There is the Sea Org level and there is
3 the nonSea Org level. Let's move down to what is a
4 franchise, what we used to call a franchise, is now
5 called a mission. A small organization, they
6 deliver a communications course, they do basic
7 auditing, book auditing, et cetera. They don't
8 even deliver what we call the grades, let alone
9 anything beyond that. Very likely there is not one
10 Sea Org member there because you have to be a
11 member of an org basically to do that. So you're
12 not going to find Sea Org members unless they got
13 busted down to it. There is no Sea Org rank or
14 anything. The positions and titles they carry are
15 the positions of their jobs or their hats.
16 Let's move up to the FSO. At the FSO,
17 suddenly the commanding officer becomes the captain
18 of the organization. Sea Org rank and org board
19 position begin to take on parallel courses here, at
20 which point then the Sea Org rank follows down the
21 organizational board. So the people at the top,
22 the organizational secretary, the public executive
23 secretary or the HCO secretary will have higher Sea
24 Org ranks than their juniors. And those are your
25 brevet ranks. The earned rank turns out to be a
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1 whole other thing because there is captains of the
2 organization who have been petty officers.
3 Q. So they get their authority from their
4 position in the organization, not from their
5 position or rank in the Sea Org, correct?
6 A. In the organization ??
7 Q. Just answer that question.
8 A. Yes and no.
9 Q. Why is it no, why isn't it yes?
10 A. Because they can be ordered by somebody
11 that has junior rank if they come in from a senior
12 position. The captain of the FSO, if a mission
13 arrives, sent in by RTC ?? she may be a captain but
14 in comes somebody of lower rank. They are a
15 missioner sent in by RTC, and per policy, they have
16 total and absolute unlimited power over that
17 person ??
18 Q. And that's the policy that they get from
19 the incorporation and the letters of incorporation
20 of RTC, which ?? in which RTC was set up to protect
21 the integrity of religion, correct?
22 A. Well, first of all I didn't finish my
23 sentence but I'll go back and try to deal with your
24 question.
25 MR. DANDAR: No, answer his first question
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1 then deal with the second question.
2 A. By coming in, that person holds authority
3 over them, which has nothing to do with the org
4 board position, nothing to do with the local Sea
5 Org brevet rank position, but has only the
6 authority of Sea Org and has nothing to do ??
7 anticipating your question, if I might ?? has
8 nothing to do with RTC. It is total Sea Org. And
9 this is how Hubbard set it up and I will be able to
10 show the directives from Hubbard where he says Sea
11 Org mission. He doesn't say a mission sent by an
12 organization. Sea Org, not RTC.
13 Q. Which ?? just name us one directive that
14 says that.
15 A. Oh, I don't remember the name. It's a
16 Flag Order which was reprinted in the RTC
17 management bulletin, I think Number ?? either
18 Number one or Number two, in an article by David
19 Miscavige that he ?? I think he ?? well, he either
20 authored the article or he authorized the article.
21 It was a front page one, I can see it. It's either
22 executive ?? you know, this management bulletin
23 Number one or two. And in it was quoted the
24 Hubbard Flag Order that gives unlimited power to
25 Sea Org missions.
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1 Q. Okay. Was Mr. Hubbard alive when RTC was
2 organized?
3 A. Yes.
4 Q. All right. So that Mr. Hubbard blessed
5 the reorganization of Scientology, which included
6 the creation of RTC, CSI and the incorporation of
7 the various churches around the world, correct?
8 MR. DANDAR: Object to the form.
9 Q. Is that right?
10 A. I don't know that.
11 Q. Well, you must have ?? you don't know that
12 Mr. Hubbard ?? you never read anything that
13 Mr. Hubbard published that ?? in which he ?? in
14 which he blessed or in which he ratified what
15 occurred with regard to the reorganization in 1981
16 and 1982?
17 A. That's not what I said, sir.
18 Q. Did he?
19 A. I don't know that because ?? well, I don't
20 want to answer more than you ask. I don't know
21 that.
22 Q. So you don't know whether Mr. Hubbard
23 ratified the reorganization of Scientology in 1981
24 and 1982?
25 A. I don't know how much Hubbard ??
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1 Mr. Hubbard actually knew and how much he was
2 actually being manipulated.
3 Q. Did you ever read anything that
4 Mr. Hubbard wrote after the reorganization in 1981
5 and 1982 in which he made it very clear that RTC
6 was ?? not the Sea Org, that RTC was responsible
7 for maintaining the integrity and purity of
8 Scientology?
9 A. I read what has been represented as that,
10 yes.
11 Q. And what was that?
12 A. That he had turned that particular
13 function over to RTC.
14 Q. And if in fact that happened, if in fact
15 that happened, then you're just wrong about the Sea
16 Org being able to do this all on their own, aren't
17 you?
18 A. No.
19 Q. And why is that?
20 A. Because Mr. Hubbard's policies stand.
21 What he turns over to RTC does not change his
22 policies. In fact, RTC and other sections operate
23 by those same policies still.
24 Q. Even though ?? so Scientology couldn't
25 even change their policies while Mr. Hubbard was
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1 alive, which he was in 1981 and 1982, is that your
2 testimony?
3 A. He was supposed to be the only one that
4 could change them, not Scientology.
5 Q. My question is ?? you're certainly not
6 here testifying that what occurred in 1981 and 1982
7 with regard to the creation of RTC and CSI and the
8 reorganization of Scientology was not approved by
9 Mr. Hubbard. You're not testifying that are you?
10 A. No.
11 MR. WEINBERG: The court reporter has to
12 make a tape change.
13 THE WITNESS: I'll take a piss break.
14 (Recess from 5:49 until 5:51 p.m.)
15 MR. DANDAR: I'm handing back to Sandy the
16 subpoena and check.
17 MR. HERTZBERG: He's not ready, okay?
18 MR. DANDAR: For the Stacy Young
19 subpoena. I will accept it when you change it
20 to Stacy Brooks because that's not her legal
21 name.
22 MR. HERTZBERG: Okay. Well, if we're
23 going to put that on the record, I'll change
24 it right now. We'll do it by hand.
25 MR. DANDAR: You can't change a check by
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1 hand.
2 MR. WEINBERG: What's the problem?
3 MR. DANDAR: Just change the subpoena and
4 check to Stacy Brooks and then I can do that.
5 That's all.
6 MR. WEINBERG: Just take the subpoena.
7 We'll get another check.
8 MR. HERTZBERG: This is just ?? you're
9 doing this on an expedited basis.
10 MR. WEINBERG: I'm not sure I even have
11 to have a check.
12 MR. DANDAR: What's expedited about her?
13 MR. HERTZBERG: Because it's relevant to
14 him. Now you're playing games. This is all
15 games playing.
16 MR. WEINBERG: I don't know what her name
17 is but ??
18 MR. DANDAR: Oh, you want this produced
19 tomorrow morning?
20 MR. HERTZBERG: That's what the subpoena
21 says.
22 MR. DANDAR: I didn't agree to that. I
23 tell you what, I didn't agree to that but I
24 will do my best to comply. All right? I
25 can't guarantee anything.
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1 MR. HERTZBERG: We know that all right.
2 THE VIDEOGRAPHER: We're on the video
3 record.
4 BY MR. WEINBERG:
5 Q. Now, all FSO staff are Sea Org members,
6 right?
7 A. Yes.
8 Q. And as a Sea Org member, they can go on a
9 Sea Org mission, right?
10 A. Yes, if they are ?? if they hold the
11 qualifications to do that.
12 Q. Can FSO send a mission to RTC or CSI?
13 A. Not as itself but FSO staff may be used on
14 the mission but the organization itself would not
15 send the mission.
16 Q. Why not, why can't they do that?
17 A. Because you don't send missions up, you
18 only send missions out or down.
19 Q. So you mean RTC is at the top?
20 A. No. It's by Sea Org. That's where the
21 top of the Sea Org is.
22 Q. Now, what do you mean that that's where
23 the top of the Sea Org is at RTC?
24 A. Because that's where Captain Miscavige is
25 and that's where ??
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1 Q. And why is Captain Miscavige, as you call
2 him, at RTC?
3 A. Because he wanted to go there. It's sort
4 of like the question where does a 400?pound gorilla
5 sleep? Wherever it wants to.
6 Q. Isn't he there because RTC is at the ??
7 has been ?? has been given the right and the
8 responsibility and the power to maintain the purity
9 and the integrity of Scientology, isn't that why
10 David Miscavige is at RTC?
11 A. No, it's quite the opposite.
12 Q. What do you mean quite the opposite?
13 A. If I may use the parallel of what
14 Mr. Hubbard used for commodore, the flagship of any
15 fleet is where the commodore resides. The power of
16 Scientology was always where Mr. Miscavige resided.
17 When he was chairman of the board at ASI, we were
18 the top of the heap. When he moved to RTC, it
19 became the top of the heap. The top of the
20 Scientology heap was where Mr. Miscavige is. He
21 does not go there because it is the top of the
22 heap, it's the top of the heap because he goes
23 there.
24 Q. What are the responsibilities that David
25 Miscavige ?? you're the expert. What are the
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1 responsibilities that the chairman of the board of
2 RTC has?
3 A. As chairman of the board, that's a ??
4 Q. I'm just asking you as an expert, what are
5 the responsibilities that the chairman of the board
6 of the RTC has?
7 A. Whatever he wants.
8 Q. That is because ??
9 A. Because he's a 400?pound gorilla and he
10 can sleep whenever he wants.
11 Q. Or is it because of the corporate
12 structure of the RTC?
13 A. Corporate structure has nothing to do with
14 the powers of David Miscavige.
15 Q. That's your testimony tomorrow?
16 A. I wasn't planning to make that statement
17 but if you want me to I will.
18 Q. And that's based on your experience in
19 Scientology in the last ten years?
20 A. Experience as well as you can see it in
21 the documents.
22 Q. Right. Now, when did David Miscavige
23 become the chairman of the board of the RTC?
24 A. I don't remember exactly, what was that,
25 nineteen ?? maybe 1985.
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1 Q. All right. And you were not in the RTC at
2 that point, right?
3 A. I was never in the RTC.
4 Q. You didn't observe David Miscavige carry
5 out his responsibilities as the chairman of RTC on
6 a day?to?day basis, did you?
7 A. I was never there, no.
8 Q. Now, do you know if your ?? if your
9 theory, your testimony with regard to religiosity
10 has ever been subjected to a peer review?
11 A. No, I don't know that.
12 Q. Did I ?? has it ever ?? do you know if the
13 theory has ever been tested at all, your theory,
14 anywhere?
15 A. No, I don't know that.
16 Q. Do you know if your theory that you're
17 going to testify about, religiosity, has been
18 generally accepted in any scientific community or
19 academic community or any community whatsoever?
20 A. Mr. Kent, I believe, covered it briefly
21 with something that he wrote but I don't have an
22 exact recall on it. That's as close as I could
23 come.
24 Q. Now, you testified that David Miscavige
25 was ?? was not in the Sea Org at ASI, is that
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1 right?
2 A. No, I did not say that.
3 Q. But I think I heard you testify that he
4 was the top of the heap when he was at ASI, right?
5 A. Yeah.
6 Q. But the Sea Org had no responsibility at
7 ASI?
8 A. No, that's not what I testified.
9 Q. What did you testify to?
10 A. Okay. We'll try it again. ASI was not a
11 Sea Org organization. Although all of its members
12 were members of the Sea Org, we carried no ranks or
13 Sea Org designation of ranks in any of our job
14 titles, nor did we wear any Sea Org uniforms.
15 Therefore, our Sea Org rank had nothing to do with
16 our ASI position. So while he may have had a Sea
17 Org rank, I may have had a Sea Org rank, somebody
18 else at ASI had a Sea Org rank, it did not carry
19 any weight as it does in a Sea Org organization
20 that operates as a Sea Org organization, such as
21 the FSO, advanced organization, et cetera.
22 Q. What was his Sea Org rank when he was in
23 charge of ASI?
24 A. He had no Sea Org rank in charge of ASI.
25 Q. So in 1980, 1981, 1982, whenever it was,
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1 '83, David Miscavige did not have a Sea Org rank,
2 is that right?
3 MR. DANDAR: Object to the form.
4 A. He may have had a Sea Org rank during
5 that time but it was not prevalent in ASI.
6 Q. What was his Sea Org rank, I'm asking you?
7 In the time period before he went to RTC, what was
8 his Sea Org rank?
9 A. I don't know what his Sea Org rank was.
10 Q. Wasn't it lieutenant JG?
11 A. At one point I know it was but I don't
12 know what it was when he went to RTC. I know he
13 just jumped from lieutenant JG to suddenly becoming
14 captain.
15 Q. But he still controlled the Sea org, is
16 that what you're saying, even though he didn't have
17 a Sea Org rank in ASI? Is that what your testimony
18 is?
19 A. No, I didn't say that.
20 Q. Well, who controlled the Sea Org while
21 David Miscavige was at ASI?
22 A. That was the period of power change that
23 went on ?? in fact, what was at issue at ASI was
24 finally who was going to control the Sea Org,
25 whether it was David Miscavige or Pat Broker.
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1 Q. What was Landon Spurlock's rank?
2 A. I believe he was a warrant officer.
3 Q. What was Kathy Bleka's rank?
4 A. I think she was a petty officer.
5 Q. What was Marty Rathbun's rank?
6 A. I don't know Marty's rank. Again, we did
7 not refer to each other by any Sea Org ranks.
8 Q. You were referred by your position in the
9 organization, correct?
10 A. Right. If you were just director of
11 communications that was your title, no Sea Org
12 rank.
13 Q. And that's ?? that's what your
14 responsibility was as director of communications?
15 A. Yes.
16 Q. What ?? when you testified at the
17 beginning that ?? the familiarity with the command
18 lines, were you just talking about basically the
19 Sea Org? Is that what you were talking about?
20 A. No.
21 Q. Well, what were you talking about? Is
22 there some other opinion there?
23 A. Well, there is other command lines besides
24 just the Sea Org command lines and that's the
25 command lines that have been published, for
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1 example, in the booklet on command lines.
2 Q. And those are what?
3 A. That's how it moves down from WDC through
4 management, you know, to various organizations.
5 Q. How about from RTC to CSI to the various
6 churches, is that a command line?
7 A. RTC doesn't like to say it's a command
8 line since they only monitor the trademarks. The
9 command line is supposed to start only with WDC.
10 In fact, if you look ??
11 Q. When you say WDC, you mean CSI, NCSI, is
12 that what you're talking about?
13 A. Yes. And so the command chart booklet
14 shows no line from RTC to WDC. The lines actually
15 start with WDC.
16 Q. Except that CSI gets its ability to use
17 the marks from RTC, correct?
18 A. The licenses granted by RTC, yes.
19 Q. So is that essentially ?? when you say the
20 organization and command lines of Scientology, it's
21 essentially what you generally described with
22 regard to the various organizations, is that what
23 you're talking about command lines?
24 A. If you're saying if I've described it the
25 way I've described it, I have to say yes. I don't
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1 know what else to say to that question.
2 Q. Well, I mean is there something else that
3 you haven't told us about, you know, about your
4 opinion concerning the ?? your familiarity with the
5 command lines that you plan to say tomorrow?
6 A. No. I think we've covered it several
7 times.
8 Q. Are you going to be asked to offer any
9 opinion as to Lisa McPherson?
10 A. Now, that's going to be up to ??
11 Q. I'm asking you. I don't know what else I
12 can do than to ask you.
13 A. I ?? I don't know. As I've testified
14 before, I don't know Lisa McPherson. I'm not ready
15 to offer an opinion about Lisa McPherson.
16 Q. I'm not trying to quarrel with ?? what I'm
17 asking you is the whole purpose of the deposition
18 is for us to have the opportunity to find out in
19 advance what it is you're going to be offering an
20 opinion on. My question is are you going to be
21 offering an opinion as to what occurred with regard
22 to Lisa McPherson?
23 A. No.
24 Q. Are you going to be offering an opinion as
25 to what, if any, role any particular individual had
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1 with regard to Lisa McPherson?
2 A. No.
3 Q. Are you going to be offering any opinions
4 as to David Miscavige tomorrow?
5 A. Yes.
6 Q. What are those opinions?
7 A. Well, as to his position in the Sea Org,
8 which I've been covering already today.
9 Q. Other than that? That doesn't sound like
10 much of an opinion. That's just a statement that
11 you're going to make that in his position he's the
12 captain of Sea Org, right?
13 A. Yes.
14 Q. Well, are you going to be offering any
15 opinions as to David Miscavige, what David
16 Miscavige does, as far as you know?
17 A. Well, I've been asked and whether or not I
18 get asked it again will be up to Mr. Dandar, but I
19 have been asked whether ?? you know, how report
20 lines occur when people find out about certain
21 things, how do reports move, what priorities do
22 they take? And as an example that I gave, for
23 example ??
24 THE WITNESS: Are we into attorney work
25 product here?
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1 MR. DANDAR: No, give whatever your
2 opinions are.
3 THE WITNESS: Okay. Cool.
4 A. For example, if I said ?? if I were in
5 the Detroit, you know, if I was in the Detroit
6 organization and two things happened this week;
7 one, we were given a million dollars and two, a
8 staff member shot himself or ?? yeah, let's say a
9 staff member shot himself at home. Which one gets
10 reported first? Well, normally people think the
11 good news gets reported first. Wrong, the bad news
12 goes up immediately, right now, out the door. The
13 million dollars goes later, which gives you a sense
14 of priority of what moves up the lines. In fact,
15 there is even material from RTC which says which is
16 to be things that are to be reported immediately to
17 RTC, and you don't usually find that sort of
18 urgency put into communications.
19 Q. Okay. As to Mr. Miscavige, anything in
20 particular that you believe you're going to testify
21 about?
22 A. Just how reports move and who finds out
23 about reports and what's the ?? what's the
24 probability of people knowing about things. And
25 all I can do is tell how it was done. As far as
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1 percipient knowledge, I can't say. I just know how
2 the organization has for the last 40 years handled
3 reports.
4 Q. But as you sit here today, you're not
5 going to be asked your opinion as to whether or not
6 David Miscavige ordered ?? made any orders with
7 regard to Lisa McPherson or did anything with
8 regard to Lisa McPherson? You're not going to be
9 asked an opinion as to that, is that right?
10 A. I don't know.
11 Q. Well, I'm asking you. That's what ?? I
12 mean that's what this is all about.
13 A. I have ?? I don't know specific questions
14 any more than I can anticipate your specific
15 questions, Mr. Weinberg.
16 MR. WEINBERG: Well then, Ken, I'll ask
17 you. Is he going to be offered ?? is he going
18 to be asked any opinions with regard to what
19 happened with regard to Lisa McPherson? I
20 mean if I ??
21 MR. DANDAR: He's going to be asked if,
22 based upon his knowledge and experience, what
23 role, if any, David Miscavige would have
24 played in the management of the public
25 relations flap caused by Lisa McPherson,
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1 including her confinement.
2 Q. And your opinion on that? Do you have an
3 opinion on that?
4 A. I can offer an opinion how ??
5 Q. Can you tell us what it is?
6 A. Can I finish my sentence? How such flaps
7 are handled. And now I'm anticipating your
8 previous question, is that ??
9 Q. Let me just interrupt. His question is
10 very specific. That he plans to ask you your
11 opinion with regard to David Miscavige's role with
12 what would have happened, what he would have done
13 vis?a?vis a public relations flap like Lisa
14 McPherson.
15 A. Right.
16 Q. Okay. What's your opinion?
17 A. An incident like that where a person goes
18 Type III, downtown, ends up engaged with the
19 police, is the first level of flap that takes it
20 beyond the ordinary. At that point, when that sort
21 of flap happens, Department 20 is called in
22 immediately. It goes up the lines to OSA
23 Department 20 and it also, to the degree we're
24 dealing with a Type III, it would go up the RTC
25 lines immediately. And in these days of e?mails ??
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1 back in the old days it would have been a telex.
2 In today's technology, it would be immediate e?mail
3 with ccs to various people, such as the senior CS.
4 The way that such things are handled is
5 that when they are reported, they must be reported,
6 not just as somebody killed themselves today ?? I'm
7 not saying this is the Lisa McPherson, but going
8 back to my example of Detroit. Somebody killed
9 themselves today, that's what's called a flap, an
10 alarming report. You must report it as somebody
11 killed themselves today but here's what we've done
12 to handle it. We talked to the chief of police of
13 such and such, we got the attorney on such, we
14 dealt with the mother, dealt with the newspaper.
15 You go through all these handlings and you show
16 what you've done and then you show what you are
17 proposing else to be done. This goes up as to how
18 you're doing it because what you want to avoid is
19 an order back down.
20 So this would have gone up to OSA because
21 it involves external entities such as the police,
22 it would have gone up RTC lines because it's a
23 technical matter, we've got a Type III going. And
24 what you have to do is make your proposals for it.
25 Whether or not you get an order back from a senior
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1 echelon basically depends upon how well you have
2 handled it and how well you have proposed you're
3 handling it. If you what Hubbard calls handle the
4 hell out of it, you hear nothing, and that's the ??
5 that's the greatest blessing that every staff
6 member can always hope for, you hear nothing other
7 than just good, keep it up, or maybe just fine,
8 thank you. The worst thing you can get is a flap,
9 you've just gotten orders, et cetera. I don't know
10 what was issued. I can just know what has been the
11 tradition for 40 years and how the organization
12 would respond.
13 Q. The answer to Mr. Dandar's question is you
14 don't know and couldn't know what, if anything,
15 went to David Miscavige with regard to Lisa
16 McPherson, right?
17 A. Percipiently, no.
18 Q. As an expert, you couldn't either because,
19 if I understood what you said, all you said was is
20 that there ?? there may have been or might have
21 been a report to OSA, which is in RTC, but whether
22 it went ?? where it went from there, you wouldn't
23 know.
24 A. No.
25 Q. Depending on the circumstances, would you?
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1 A. It would have gone to OSA and to RTC, and,
2 in my opinion, David Miscavige would know about
3 somebody that went Type III in ?? this is so
4 important, as I tried to explain to Mr. Dandar. It
5 depends where it happens. Somebody that goes
6 Type III in Detroit is not the same thing as
7 somebody going Type III in Clearwater. Clearwater
8 has been a powder keg for ?? since day one, since
9 it came out of the closet as to what it really was,
10 that it wasn't the United Churches of Florida. It
11 is very volatile. And because it is volatile,
12 there are ?? you report faster and it goes up
13 farther depending upon that.
14 I have no doubt David Miscavige would have
15 learned about a situation in Clearwater because it
16 is so sensitive, because they are gaining ground,
17 they are trying to gain influence, et cetera, as
18 opposed to Detroit.
19 Q. When would he have learned that?
20 A. When?
21 Q. Yeah, what's your opinion? And this is a
22 public, not a staff member.
23 A. No, public has nothing to do with it. The
24 fact she was in contact with the police downtown,
25 taking off her clothes, walking around, has been
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1 picked up by an EMT and she's in the care of ??
2 however you want to cut it off that your report
3 goes up, it's because this is so volatile it would
4 have been ?? I don't know when he would have
5 learned about it but it would have been on his
6 computer system within hours.
7 Q. So that's what your opinion is that you're
8 going to give tomorrow?
9 A. That I would give, yes.
10 MR. WEINBERG: Is there any other ?? is
11 there any other opinion, Ken, since he doesn't
12 seem to know what they are going to be, that
13 you're going to ask him, opinion testimony?
14 A. I don't know what his questions will be.
15 Q. Well, see that's the whole purpose of this
16 and that's what the purpose of interrogatories are
17 and the deposition.
18 A. I understand.
19 Q. If you don't know, it doesn't do me much
20 good to ask him. I have to ask him.
21 MR. DANDAR: Where is the copies that I
22 had here, mine?
23 THE WITNESS: I didn't touch them.
24 MR. WEINBERG: Of what?
25 MR. DANDAR: My answers to ?? oh. That's
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1 it. That's it. And you've eaten into the
2 hour time tomorrow.
3 MR. WEINBERG: Hold on a second.
4 MR. DANDAR: By ten minutes. Let's go.
5 We're done. So now you got 50 minutes
6 tomorrow morning.
7 THE WITNESS: Are you instructing me to
8 take off this?
9 MR. DANDAR: Yeah, it's done. I don't
10 want to wear you out.
11 MR. HANES: Ken, I took ?? we took at
12 least eight to nine minutes in breaks. I show
13 the time on the court reporter's screen to be
14 6:10.
15 MR. WEINBERG: I got one more question
16 I've got to ask.
17 MR. DANDAR: You can ask.
18 MR. HANES: Are you going to supplement
19 your interrogatory regarding Lisa McPherson
20 considering that's not on there?
21 MR. DANDAR: It's on there.
22 MR. HANES: Because you told the judge it
23 had nothing to do with us, number one. He
24 just testified to something that relates to
25 the individuals.
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1 MR. DANDAR: It has nothing to do with
2 the individuals.
3 MR. HANES: Oh, okay.
4 BY MR. WEINBERG:
5 Q. When you were in the GO, the USGO before
6 you were in the Sea Org, did you have authority to
7 order staff in local orgs?
8 A. Yes.
9 Q. Did that include Sea Org members and ASHO
10 and AOLA?
11 A. Excuse me. Was I authorized to order into
12 the AOLA, is that what you say?
13 Q. Yes. In other words, did you have
14 authority to order staff in local orgs ??
15 A. Such as?
16 Q. ?? including Sea Org members and the ASHO
17 or the AOLA?
18 A. Yes.
19 MR. DANDAR: What time do you have, Sandy?
20 MR. POLLI: 6:10.
21 MR. WEINBERG: 6:10.
22 MR. DANDAR: Okay. That's fine.
23 (Recessed at 6:15 p.m.)
24 THEREUPON, the deposition of ROBERT VAUGHN
25 YOUNG was recessed at 6:10 p.m.
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1 NOTE: The original and one copy of the
2 foregoing deposition will be held by Mr. Weinberg;
3 copy to Mr. Dandar.
4 ARRANGEMENTS for the reading and signing
5 of the deposition transcript will be handled by the
6 office of Mr. Kennan Dandar of the firm Dandar &
7 Dandar, 5340 West Kennedy Boulevard, Suite 201,
8 Tampa, Florida.
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McPherson v Church of Scientology / 97?01235 796
1 SIGNATURE PAGE
2 Volume V
3 I, ROBERT VAUGHN YOUNG, have read the
4 foregoing deposition given by me on January 20,
5 2000, in Tampa, Florida, and the following
6 corrections, if any, should be made in the
7 transcript:
8 PAGE LINE CORRECTION AND REASON THEREFOR
9
10
11
12
13
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15
16
17
18 Subject to the above corrections, if any,
19 my testimony reads as given by me in the foregoing
20 deposition.
21 SIGNED at _________________, Florida, this
22 __________ day of ____________________, 2000.
23
24 ________________________________
25 ROBERT VAUGHN YOUNG
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797
1 CERTIFICATE OF REPORTER OATH
2
3 STATE OF FLORIDA
4 COUNTY OF POLK
5
6
7 I, the undersigned authority, hereby
8 certify that the witness named herein personally
9 appeared before me and was duly sworn.
10 WITNESS my hand and official seal this
11 22nd day of January, 2000.
12
13
14
15
16 _________________________________
17 Susan D. Wasilewski, RPR, CRR
18 Notary Public ? State of Florida
19 My Commission Expires: 10?23?03
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24
25
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798
1 REPORTER'S DEPOSITION CERTIFICATE
2 STATE OF FLORIDA
3 COUNTY OF POLK
4 I, Susan D. Wasilewski, Registered
5 Professional Reporter, Certified Realtime Reporter
6 and Notary Public in and for the State of Florida
7 at large, hereby certify that the witness appeared
8 before me for the taking of the foregoing
9 deposition, and that I was authorized to and did
10 stenographically and electronically report the
11 deposition; and that a review of the transcript was
12 requested; and that the transcript is a true and
13 complete record of my stenographic notes and
14 recordings thereof.
15 I FURTHER CERTIFY that I am neither an
16 attorney nor counsel for the parties to this cause,
17 nor a relative or employee of any attorney or party
18 connected with this litigation, nor am I
19 financially interested in the outcome of this
20 action.
21 DATED THIS 22nd day of January, 2000, at
22 Lakeland, Polk County, Florida.
23 ________________________________ 24 Susan D. Wasilewski, RPR, CRR My Commission Expires: 10?23?03 25 Transcript ordered: 1?20?00
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