BY MS. PLEVIN:
Q. DID YOU DO ANYTHING ON THE TRAINING GRADE CHART, MR. MISCAVIGE, WHILE YOU WERE AT CLEARWATER DURING THE PERIOD WHILE YOU WERE ON THE EPP AND PHOTO SHOOT ASSISTANT? MR. HERTZBERG: ALL RIGHT. WHAT DO YOU MEAN BY THE "CHART"? WHAT DO YOU MEAN BY THAT?
MAY THE RECORD REFLECT THAT COUNSEL IS BEING ADVISED BY HER CLIENT AT THIS POINT. WOULD YOU TELL ME WHAT YOU MEANT BY THAT, BY THAT QUESTION?
MS. PLEVIN: WELL, WHY DON'T WE ASK MR. MISCAVIGE WHAT THE GRADE CHART IS, PLEASE.
MR. HERTZBERG: NO. NOW, WHEN YOU -- ARE YOU WITHDRAWING THE LAST QUESTION?
MS. PLEVIN: NO.
MR. HERTZBERG: YOU'RE NOT WITHDRAWING IT? LET'S ADDRESS THE QUESTION THAT I OBJECTED TO.
MS. PLEVIN: THERE ARE A SERIES OF TRAINING GRADES ON THE GRADE CHART OF SCIENTOLOGY, FROM BOTTOM TO TOP. I'M ASKING MR. MISCAVIGE WHEN -- IF HE TOOK ANY OF THOSE COURSES DURING THE PERIOD OF TIME AND I INTEND TO ASK HIM WHEN HE TOOK ANY AND ALL OF THOSE COURSES ANY TIME.
MR. HERTZBERG: ARE YOU TALKING ABOUT HIS RELIGIOUS TRAINING COURSES?
MS. PLEVIN: ABSOLUTELY.
MR. HERTZBERG: I'M INSTRUCTING HIM NOT TO ANSWER UNLESS YOU CAN INDICATE TO ME HOW THAT IS RELEVANT TO THE ALLEGATIONS IN THE COMPLAINT AGAINST MR. MISCAVIGE BY BENT CORYDON. MR. DRESCHER: I'LL JOIN IN THAT SAME OBJECTION.
MS. PLEVIN: ALL RIGHT. AS I BELIEVE I STATED PREVIOUSLY, MR. MISCAVIGE'S POSITION ENCOMPASSES BOTH ECCLESIASTICAL AND CORPORATE MATTERS. IF HE HAS ECCLESIASTICAL TRAINING FOR THOSE POSITIONS AS THEY RELATE, AND MAY RELATE TO THE ORGANIZATIONAL STRUCTURE, I'M ENTITLED TO KNOW WHAT THEY ARE. IF YOU'RE REFUSING TO ANSWER, THAT'S FINE. I WILL GO ONTO ANOTHER QUESTION.
MR. DRESCHER:I WANT TO TAKE ISSUE WITH YOUR LAST REMARK.
MS. PLEVIN: WE'LL DO IT OFF THE RECORD --
MR. HERTZBERG: NO.
MR. DRESCHER: I'M ENTITLED TO REPRESENT MY CLIENTS, MISS PLEVIN.
MS. PLEVIN: EXCUSE ME. WHAT YOU'VE DONE NOW, GENTLEMEN, COLLECTIVELY, IS IN LESS THAN 20 MINUTES, DOMINATED WHAT MUST BE MORE THAN 60 PERCENT OF THE TEXT WITH YOUR OBJECTIONS. AS YOU KNOW, MR. DRESCHER, AND AS MR. HELLER KNOWS AND AS THE NEW YORK ATTORNEYS HERE MAY NOT KNOW, I CAN AND I WILL SEEK, AT THE VERY LEAST, YOUR CONTRIBUTION TO THE COST OF THIS DEPOSITION BASED ON UNNECESSARY, LONG ON-THE-RECORD OBJECTIONS, ESPECIALLY SINCE I'M GOING TO ASK SPECIFICALLY THAT WE GO OFF THE RECORD, AND FURTHERMORE, THAT THESE EXTENDED OBJECTIONS, OVER WHAT I CONSIDER TO BE ISSUES OF RELEVANCE AND NOT ISSUES OF -- AT THE BEST, ISSUES OF RELEVANCE WHICH ARE IMPROPER OBJECTIONS TO RAISE SO FREQUENTLY AND AGGRESSIVELY DURING THE DEPOSITION, THERE'S NO CALL FOR IT. THERE'S NO CALL FOR IT WHATSOEVER. WE COULD HAVE GONE THROUGH A GREAT DEAL MORE AT THIS POINT.
MR. HERTZBERG: YOU SEE, WE'RE NOT GOING TO GO THROUGH THE -- THE POINT PRECISELY IS WE'RE NOT GOING TO GO THROUGH A HARASSIVE DEPOSITION WHICH DOES NOT RELATE TO THE CONTENTS OF MR. CORYDON'S COMPLAINT.
ONE THING THAT I'M MINDFUL OF, AND I MIGHT AS WELL MAKE THAT CLEAR TO YOU AT THE OUTSET, IS THAT MR. CORYDON HAS TESTIFIED UNDER OATH THAT HE IS WRITING OR INTENDS TO WRITE SHORTLY ANOTHER BOOK ABOUT THE CHURCH OF SCIENTOLOGY AND I HAVE HAD GRAVE QUESTIONS IN MY MIND ABOUT WHAT THE REAL PURPOSE OF THIS DEPOSITION IS, AND WHAT I'VE HEARD SO FAR THIS MORNING HAS VIRTUALLY NOTHING TO DO WITH THE COMPLAINT.
WE ARE HERE TO DEAL WITH THE COMPLAINT. AND WE ARE GOING TO OBJECT, OR I'M GOING TO OBJECT TO ANYTHING WHICH I CONSIDER TO BE TOTALLY REMOTE, AS THESE QUESTIONS ARE, WHICH FAR PREDATE ANY EVENTS IN THE COMPLAINT THAT WOULDN'T BE RELEVANT ANYWAY, AND FORTUNATELY THERE ARE JUDGES WHO WILL DECIDE WHETHER WE ARE --
MS. PLEVIN: OH, THERE CERTAINLY ARE.
MR. HERTZBERG: -- WHETHER WE ARE WITHIN OUR RIGHTS TO OBJECT.
MR. DRESCHER: AND I WILL FURTHER RESPOND BY SAYING I INTEND TO OBJECT, TOO, WHEN THE SUBJECT MATTER APPEARS SELF-EVIDENTLY FROM THE QUESTIONS, TO BE AN INTENT IMPROPERLY TO PROBE THIS WITNESS'S RELIGIOUS BELIEFS, HIS RELIGIOUS TRAINING OR ANY PART OF THE ECCLESIASTICAL OR RELIGIOUS BELIEFS --
MS. PLEVIN: MR. DRESCHER, YOUR CLIENTS HAVE OBJECTED TO DISCOVERY AND TO MANY MATTERS IN THIS COMPLAINT ON THE GROUNDS THAT THE EFFORTS INVADE ECCLESIASTICAL MATTERS, AND THAT THE CORPORATE STRUCTURE IS INHERENTLY PART OF AN ECCLESIASTICAL STRUCTURE AND I
CAN'T GET AT ANY OF THAT STUFF BECAUSE OF THE 1ST AND 14TH AMENDMENTS, ALL OF WHICH I THINK IS GARBAGE.
MR. DRESCHER: IF THAT'S TRUE, THEN WE'LL JUST PROCEED, BECAUSE YOU'VE JUST ADMITTED YOU CAN'T GET AT IT.
MS. PLEVIN: WHICH YOU CLAIM I CAN'T GET AT, WHICH IS TOTALLY IN ERROR AS A MATTER OF LAW. HOWEVER, THE -- AS I'VE MADE QUITE CLEAR, FREQUENTLY ENOUGH, THE CONTROL AND THE BACKGROUND OF THE PEOPLE WHO ARE IN CONTROL OF THE SCIENTOLOGY ORGANIZATION IS EXTREMELY IMPORTANT, AND I INTEND TO INQUIRE INTO THEM.
MR. DRESCHER: IT'S EXTREMELY IMPORTANT FOR SOME AGENDA OTHER THAN THIS LAWSUIT. SO WE'LL CONTINUE TO ASSERT THE OBJECTIONS AS NECESSARY.
MS. PLEVIN: FOR THE APPROPRIATE -- THE COURT HAS ALREADY RULED THAT OUR INQUIRY INTO THE ALTER EGO THEORY IS TOTALLY APPROPRIATE.
MR. DRESCHER: HE HAS NOT.
MS. PLEVIN: I'M GOING TO SAY AGAIN THAT I WISH THAT THIS DISCUSSION WERE OFF THE RECORD. THIS IS PROLONGING. THIS IS INAPPROPRIATE. THIS IS COSTLY. I'M GOING TO GO ON WITH THE QUESTIONS. MR. HELLER: NEXT QUESTION.
BY MS. PLEVIN:
Q. YOU REFUSE TO ANSWER QUESTIONS; IS THAT RIGHT?
MR. HERTZBERG: DON'T ANSWER THAT QUESTION. HE'S RECEIVED THE INSTRUCTIONS. ASK YOUR NEXT QUESTION, PLEASE.
BY MS. PLEVIN:
Q. MR. MISCAVIGE --
MR. HERTZBERG: AND BY THE WAY, I'M INSTRUCTING HIM ON A QUESTION-BY-QUESTION BASIS, LET THE RECORD BE CLEAR. THERE WAS A QUESTION PENDING. ON THAT QUESTION, AS THE RECORD WILL REFLECT, I INSTRUCTED HIM NOT TO ANSWER. NOW ASK YOUR NEXT QUESTION, PLEASE. BY MS. PLEVIN:
Q. WHAT WAS THE NEXT POST YOU HELD WITHIN THE ORG, OR STAFF POSITION, AFTER YOU COMPLETED YOUR WORK AS A PHOTO SHOOT ASSISTANT AND AFTER YOU COMPLETED YOUR ESTATES PROJECTS FORCE POSITION AT CLEARWATER?
A. I CAN'T RECALL THE NEXT ONE.
Q. DO YOU REMEMBER WHERE IT WAS LOCATED?
A. YES.
Q. WHERE WAS IT LOCATED?
A. I WAS IN CLEARWATER.
Q. FOR HOW LONG WERE YOU IN CLEARWATER?
A. UNTIL 1977.
Q. AND WAS THERE SOME TIME WHILE YOU WERE STILL AT CLEARWATER, BETWEEN THE TIME YOU CONCLUDED YOUR POSITION AS PHOTO SHOOT ASSISTANT AND THE TIME YOU LEFT CLEARWATER, TO WHEREVER YOU WENT NEXT?
A. YES.
Q. BUT YOU DON'T RECALL WHAT POST YOU HELD AT THAT TIME?
MR. HERTZBERG: THAT WAS ASKED AND ANSWERED.
(CONFERENCE BETWEEN COUNSEL AND WITNESS.)
THE WITNESS: I DON'T REMEMBER WHAT THE VERY NEXT ONE WAS. THAT'S WHAT I STATED.
BY MS. PLEVIN:
Q. OKAY. IF YOU DON'T REMEMBER WHAT THE IMMEDIATE NEXT ONE WAS, WHAT WAS THE NEXT ONE AFTER THAT, TO THE BEST OF YOUR RECOLLECTION?
A. I DON'T RECALL IT THAT WAY.
Q. WAS IT -- I'M SORRY?
A. YOU'RE ASKING ME AN EXACT, THIS ONE, THAT ONE.I DON'T -- THE EXACT, I CAN'T ANSWER THE NEXT ONE IF I DON'T REMEMBER WHAT THE PREVIOUS ONE WAS.
MR. HERTZBERG: I THINK THE DIFFICULTY, MISS PLEVIN, WAS WHEN WE'RE TALKING ABOUT EVENTS SO REMOTE IN TIME, MR. MISCAVIGE IS INDICATING HE CANNOT REMEMBER THEM IN THE CHRONOLOGICAL SEQUENCE THAT YOU APPARENTLY ARE SEEKING.
BY MS. PLEVIN:
Q. HOW DO YOU REMEMBER THE NEXT CHANGE IN YOUR STATUS WITHIN SCIENTOLOGY ORGANIZATIONS?
MR. HELLER: OBJECTION. THAT QUESTION IS UNINTELLIGIBLE, "HOW DO YOU REMEMBER IT."
MS. PLEVIN: HE SAID IT'S NOT THE WAY HE RECALLS IT, SO I'M ASKING HIM: WHAT IS THE WAY YOU DO RECALL IT?
MR. HERTZBERG: WHY DON'T YOU ASK HIM THE NEXT POST THAT HE REMEMBERS. I THINK THAT'S PROBABLY THE EASIEST.
MS. PLEVIN: YOU CAN ANSWER MY QUESTION.
MR. HELLER: IF YOU'RE ABLE.
MR. HERTZBERG: SHE WANTS TO KNOW HOW YOUR MIND WORKS TO REMEMBER --
THE WITNESS: I REMEMBER IN MY MIND. I CAN TELL YOU NUMEROUS. THAT'S MY ANSWER TO YOU.
BY MS. PLEVIN:
Q. YOU CAN TELL ME NUMEROUS WHAT?
A. POSTS.
Q. YOU JUST DON'T REMEMBER WHICH ONE WAS THE NEXT ONE?
A. PRECISELY.
Q. WHICH IS THE NEXT ONE THAT STANDS OUT IN YOUR MIND?
A. NUMEROUS. NONE OF THEM STAND OUT IN MY MIND.
Q. YOU CAN'T PUT THEM INTO ANY ORDER?
MR. HERTZBERG: THAT'S WHAT HE SAID.
BY MS. PLEVIN:
Q. ALL RIGHT. THEN LET'S TAKE EACH OF THEM. LET'S TAKE EACH POST YOU'VE HELD.
A. OKAY. LET'S SEE. ASSISTANT ECFH, PROGRAM CMO --
Q. LET'S TAKE THEM ONE -- ALL RIGHT.
A. STEWARD EPF, FMO 1672, 73, TELEX OP.
Q. THESE ARE ALL THE POSITIONS THAT YOU RECALL THAT YOU EVER HELD IN ANY SCIENTOLOGY ORG OR POST?
MR. HERTZBERG: WELL, WAIT A MINUTE.
MS. PLEVIN: OKAY. THAT'S WHAT I'M CLARIFYING. YOU --
MR. HERTZBERG: LET ME UNDERSTAND THIS QUESTION. YOU'RE SAYING THIS IS THE ONLY -- THOSE ARE THE ONLY POSTS HE CAN EVER RECALL EVER HOLDING IN THE CHURCH THAT HE HASN'T MENTIONED SO FAR. IS THAT THE QUESTION?
MS. PLEVIN: HE LISTED THESE ORGANIZATIONS, MR. HERTZBERG, IN RESPONSE TO A QUESTION OF "WELL, WHAT NEXT STANDS OUT IN YOUR MIND. YOU TELL THEM TO ME THE WAY YOU WANT TO TELL THEM TO ME." AND THEN HE STOPPED. I DIDN'T ASK HIM TO STOP AT CLEARWATER OR WHATEVER. WHERE --
Q. YOU LISTED THESE ORGANIZATIONS TOGETHER, MR. MISCAVIGE. HOW -A. THEY'RE NOT ORGANIZATIONS.
Q. OR, I'M SORRY. YOU LISTED THESE POSITIONS IN A UNIT.
A. MM-HMM.
Q. NOW, WHY ARE THEY PART OF A SINGLE UNIT?
MR. HERTZBERG: WHAT DO YOU MEAN BY "UNIT"?
MS. PLEVIN: IN RESPONSE TO A SPECIFIC QUESTION.
MR. HELLER: ASSUMES FACTS THAT ARE NOT IN EVIDENCE. I DIDN'T HEAR ANYTHING IN THE PRECEDING QUESTION THAT HE WAS TO LIST ANYTHING TOGETHER. YOU ASKED HIM TO LIST CERTAIN POSTS AND HE DID SO AND THEY'VE INDICATED IT WASN'T ANY UNIT. MR. HERTZBERG: LET'S --
MS. PLEVIN: MR. --
MR. HERTZBERG: I THINK HE CAN CLARIFY THINGS.
MS. PLEVIN: WELL, THANK YOU. THAT'S WHAT I WAS ASKING HIM TO DO.
MR. HERTZBERG: THE QUESTIONS ARE VERY CONFUSING.
BY MS. PLEVIN:
Q. WOULD YOU PLEASE CLARIFY WHY YOU LISTED THESE -- WHAT'S THE COMMON DENOMINATOR?
A. THEY'RE IN CLEARWATER.
Q. AND THESE WERE ALL POSITIONS YOU HELD BEFORE YOU LEFT CLEARWATER SOMETIME IN 1977, TO THE BEST OF YOUR RECOLLECTION?
A. YES.
Q. OKAY. FOR THE RECORD, SO THAT IT IS CLEAR, WOULD YOU PLEASE STATE THE FULL MEANING OF ASSISTANT ECFC?
A. I DIDN'T SAY THAT. I SAID ASSISTANT ECFH.
Q. I'M SORRY. FH. WHAT IS THAT?
A. ASSISTANT IN EXTERNAL COM, FORT HARRISON. THAT'S THE NAME OF A HOTEL.
Q. AND DID THAT POSITION INVOLVE COMMUNICATION WITH THE NONSCIENTOLOGY WORLD? WHAT DOES "EXTERNAL COM" MEAN, MR. MISCAVIGE?
A. IT MEANS COMMUNICATIONS THAT ARE EXTERNAL AND NOT INTERNAL.
Q. OH, INTERNAL TO WHAT?
A. THE BUILDING.
Q. SO IN THAT POSITION, IT WOULD INVOLVE COMMUNICATIONS BETWEEN THAT BUILDING AND OTHER SCIENTOLOGY ENTITIES; IS THAT RIGHT?
A. NO.
Q. WHAT DID IT INVOLVE?
A. WHAT DID -- I'M NOT SURE I KNOW WHAT YOU WANT TO KNOW, "WHAT IT INVOLVED." WHAT?
Q. POSITION OF BEING ASSISTANT EXTERNAL COM, WHAT WAS INVOLVED IN THAT POSITION?
A. OH, IN THE POST POSITION?
Q. YES.
A. BEING A COM RUNNER.
Q. FOR WHOM?
A. FOR WHOM?
Q. BETWEEN WHO AND WHO WERE YOU RUNNING COMMUNICATIONS?
MR. HERTZBERG: YOU MEAN YOU WANT HIM TO NAME EVERY PERSON?
MR. HELLER: IF INDEED IT ENTAILED PERSONS.
MR. HERTZBERG: IS THAT YOUR QUESTION?
MS. PLEVIN: I'M NOT ASKING HIM TO NECESSARILY NAME EVERY PERSON. WAS IT BETWEEN A CERTAIN GROUP OF ORGANIZATIONS AND OTHER GROUP OF ORGANIZATIONS?
THE WITNESS: WELL, YOU ASKED WHO I -- PEOPLE I RAN BETWEEN?
MS. PLEVIN: RIGHT.
THE WITNESS: NONE.
BY MS. PLEVIN:
Q. WHAT ENTITIES DID YOU RUN BETWEEN?
MR. HERTZBERG: IF HE RAN BETWEEN ANY ENTITIES.
BY MS. PLEVIN:
Q. WHO WERE YOU COMMUNICATING WITH? WHO WERE YOU RUNNING COMMUNICATIONS FOR?
A. IT'S AN UNANSWERABLE QUESTION.
Q. ALL RIGHT. DESCRIBE WHAT THE FUNCTION OF A COM RUNNER IS, PLEASE.
A. OKAY. YOU HAVE A COMMUNICATION PARTICLE, AND I GUESS YOU COULD RUN, BUT YOU BASICALLY DELIVER IT TO ITS RECIPIENT.
Q. WAS THAT A MESSENGER AT FORT HARRISON?
A. NO.
Q. DID YOU WORK FOR ANY SPECIFIC DEPARTMENT?
A. EXTERNAL COM FH.
Q. DID YOU TAKE --
A. EXCUSE ME. COULD I GO TO THE BATHROOM REAL QUICK?
MS. PLEVIN: YES, OF COURSE.
(RECESS TAKEN.)
MS. PLEVIN: WE'RE BACK ON THE RECORD. WAS THERE A QUESTION PENDING?
(RECORD READ.)
BY MS. PLEVIN:
Q. IS THERE ANY OTHER WAY YOU CAN EXPLAIN THE FUNCTION OF COM RUNNER AS TO HOW YOU WERE FACILITATING COMMUNICATIONS?
A. AS A GENERAL SUBJECT ON COM RUNNERS OR IN THAT POSITION?
Q. IN THAT POSITION.
MR. HERTZBERG: I'M GOING TO LET HIM ANSWER THE QUESTION, BUT I WANT TO NOTE THAT WE'RE NOW GETTING INTO MINUTIAE UPON IRRELEVANCY, I, WHICH I THINK IS REALLY QUITE A WASTE OF TIME. BUT YOU MAY ANSWER.
THE WITNESS: COULD I HAVE THE QUESTION AGAIN, PLEASE
(RECORD READ.)
THE WITNESS: YES.
BY MS. PLEVIN:
Q. AND WOULD YOU DO SO, PLEASE?
A. DELIVERING TELEXES.
Q. DID YOU HAVE A CERTAIN ROUTE THAT YOU WERE DELIVERING TELEXES TO?
A. NO.
MR. DRESCHER: I REALLY DON'T UNDERSTAND THE RELEVANCY --
MS. PLEVIN: WELL, MR. --
MR. DRESCHER: I'M ALLOWED TO MAKE AN OBJECTION, MS. PLEVIN, AND I'D APPRECIATE IF YOU'D LET ME DO IT AND WE'LL MOVE MUCH QUICKER. I'M GOING TO OBJECT TO THE RELEVANCE TO ANY OF THIS, WHAT ROUTES HE MIGHT HAVE HAD OR MIGHT NOT HAVE HAD I HAVE NO IDEA WHAT THIS MAY BE IN RELATION TO THE COMPLAINT, AND I BELIEVE WE'RE STILL IN THE TIME PERIOD PREDATING THE EARLIEST ALLEGATION.
MR. HERTZBERG: WE ARE INDEED, AND I DON'T -- I ALSO NOTED THAT WHEN YOU START INTERRUPTING MR. DRESCHER, YOU VOICED SOME PERSONAL OPINION THAT MR. MISCAVIGE WAS OBSCURING SOMETHING PURPOSEFULLY. WE DON'T NEED THAT KIND OF COMMENT AND I DON'T WANT TO HEAR THAT KIND OF COMMENT AGAIN BECAUSE I DON'T THINK IT'S USEFUL OR PROPER.
MS. PLEVIN: THE FACT THAT A DEPONENT FAILS TO FULLY ANSWER WHAT IS CLEARLY AN INTELLIGIBLE QUESTION, IS SUBJECT FOR A MOTION TO COMPEL.
MR. HELLER: I THINK I CAN --
MS. PLEVIN: I'LL BE MOVING TO COMPEL A GREAT DEAL.
MR. HERTZBERG: YOU CAN MOVE TO COMPEL. WHAT I DON'T THINK WE SHOULD HAVE IS A RECORD WITH YOUR EDITORIAL COMMENTS AND YOUR INTERPRETATIONS AND I ALSO DON'T WANT TO HAVE ARGUMENTATIVE QUESTIONS. WHY DON'T WE PROCEED. BY MS. PLEVIN:
Q. MR. MISCAVIGE, NOW, DID YOU HOLD THAT POSITION WHILE YOU WERE PROGRAM CFO?
A. NO, BUT I WASN'T PROGRAM CFO.
Q. IT WAS WHAT?
A. CMO.
Q. ALL RIGHT. WHAT DOES "PROGRAM CMO" STAND FOR, PLEASE?
A. PROGRAMS, COMMODORE'S MESSENGER WORK.
Q. DID THAT INVOLVE YOU IN PLANNING PROGRAMS OF SOME KIND?
A. NO.
Q. WOULD YOU EXPLAIN WHAT RESPONSIBILITIES YOU HAD AS PROGRAM CMO?
MR. HERTZBERG: WE'RE TALKING ABOUT IN 1976?
MS. PLEVIN: WHENEVER IT WAS.
MR. HERTZBERG: WAS IT IN 1976?
THE WITNESS: YES.
MR. HERTZBERG: OKAY.
THE WITNESS: YES.
BY MS. PLEVIN:
Q. WHAT FUNCTIONS DID THAT INVOLVE?
A. GETTING A SERIES OF STEPS ON A PROGRAM DONE. YOU KNOW, IF THERE WAS A PROGRAM -- MORE LIKE, YOU KNOW, AN ADMINISTRATOR THAT YOU WOULD NOTE IF THE TARGETS WERE DONE ON A PROGRAM AND IF NOT, BASICALLY KEEP YOUR ATTENTION ON THE PROGRAM, SO ATTENTION WAS KEPT ON THE PROGRAM AND IT WOULD BE COMPLETED.
Q. OKAY. WERE YOU SUPERVISING OTHER PEOPLE IN THEIR PERFORMANCE OF PROGRAMS? A. NO.
Q. THESE WERE YOUR PROGRAMS, THE PROGRAMS THAT YOU WERE COMPLETING?
A. OH, NO, I DON'T UNDERSTAND -- I WAS, AND SO WERE OTHER PEOPLE.
Q. I'M SORRY?
A. BOTH IS THE ANSWER.
Q. YOU WERE AND SO WERE OTHER PEOPLE?
A. CORRECT.YOU SAID DOING THE PROGRAM?
Q. YES.
A. YES, BOTH.
Q. OKAY. WERE THESE SPECIFIC PROGRAMS OR PROGRAMS THAT COULD BE GENERATED AT ANY TIME BY ANYONE?
A. THE LATTER.
Q. OKAY. WERE THEY --
A. BUT CLARIFY THAT. NOT ANYONE AT ANY TIME, BUT THEY'RE RANDOM, TO ANSWER YOUR QUESTION. I MEAN -- I'M NOT EXACTLY SURE WHAT YOU'RE ASKING ME. Q. WERE THEY GENERATED BY A SENIOR TO YOU IN CMO?
A. OH, NO.
Q. WERE THEY GENERATED BY A SENIOR TO YOU?
A. NO.
Q. WHAT WAS THE POSITION OF STEWARD EPF, PLEASE?
A. THAT'S TWO DIFFERENT POSITIONS.
Q. OH, OKAY. THE WAY YOU SAID IT, IT WASN'T QUITE CLEAR.
A. I'M SORRY.
Q. STEWARD FOR --
A. STEWARD, SERVING FOOD.
Q. AND EPF IS BACK ON THE ESTATES PROJECT FORCE?
A. PRECISELY.
Q. WHAT'S FMO 1672 AND 1673?
A. FLAG MISSION ORDER 1672; FLAG MISSION ORDER 1673.
Q. AND WOULD YOU EXPLAIN FOR THE RECORD WHAT THAT'S ABOUT?
A. A MISSION IS WHEN A GROUP OF PEOPLE ARE ON A SET OF MISSION ORDERS TO HANDLE A SPECIFIC SITUATION TO IDEALLY ACHIEVE A SPECIFIC END RESULT, AND THAT'S THEIR FUNCTION. Q. OKAY. AND YOU WERE A MISSIONAIRE?
A. I WAS FMO 1673, WORKING WITH FMO 1672.
O. OKAY.
A. IN THAT CAPACITY. YOU COULD HAVE CALLED ME THEN A MISSIONAIRE.
Q. OKAY. NOW, GOING BACK TO THE QUESTION HOPEFULLY TO CLARIFY, WHILE YOU WERE PROGRAM CMO, WHO DID GENERATE THE PROGRAMS THAT YOU WERE -- SEEN GOT DONE?
MR. HERTZBERG: YOU WANT THE NAMES OF ALL THE PEOPLE?
(CONFERENCE BETWEEN COUNSEL AND WITNESS.)
BY MS. PLEVIN:
Q. WHO DID GENERATE THOSE PROGRAMS?
A. PROGRAMS -- I DON'T REMEMBER ALL OF THE PROGRAMS. I CAN REMEMBER ONE IN PARTICULAR, JUST I DON'T KNOW WHY I DO, BUT I REMEMBER ONE, AND I DON'T REMEMBER THE NAME OF THE PERSON, BUT I KNOW IT WAS SOMEBODY IN THE REGISTRATION DEPARTMENT IN THE FLAG SERVICE ORG AND IT HAD TO DO WITH GETTING SEVERAL ADDITIONAL WATTS TELEPHONE LINES INSTALLED.
Q. AND YOU OPERATED A TELEX AT THAT TIME?
A. I WAS A TELEX OP, TYPED. I TYPED TELEXES.
Q. OKAY. OUTGOING TELEXES FROM FORT HARRISON? A. NO. I DIDN'T DO THAT FROM FORT HARRISON, NO. Q. WHERE DID YOU DO THAT FROM?
A. THE CB.
Q. WHAT IS A CB, PLEASE?
A. CLEARWATER BUILDING.
Q. AND WERE THEY FOR ANY PARTICULAR DIVISION AT THE CLEARWATER BUILDING? A. THE ONES THAT I TYPED?
Q. MM-HMM.
A. NO.
Q. ANYBODY WHO HAD OUTGOING TELEXES?
A. YES.
Q. OKAY. WHILE YOU WERE AT CLEARWATER, DID YOU TAKE ANY OEC COURSES, ORGANIZATIONAL EXECUTIVE COURSE? A. NO.
Q. AFTER YOU LEFT CLEARWATER, WHERE DID YOU GO?
A. LA QUINTA, CALIFORNIA.
Q. WHAT WAS YOUR POST OR STAFF POSITION IN LA QUINTA?
A. WHEN?
Q. WHEN YOU FIRST GOT THERE.
A. DIR OF I&R, I THINK.
Q. WOULD YOU CLARIFY THAT FOR THE COURT REPORTER, PLEASE.
A. DIRECTOR OF INSPECTIONS AND REPORTS. CMO, SU -- THAT'S STANDING FOR SPECIAL UNIT.
Q. NOW, THE SPECIAL UNIT WAS -- WHAT WAS THE SPECIAL UNIT?
A. WHAT WAS --
MR. HERTZBERG: I'M NOT SURE I UNDERSTAND THAT QUESTION. WHAT WAS THE SPECIAL UNIT?
BY MS. PLEVIN:
Q. DO YOU UNDERSTAND THE QUESTION, MR. MISCAVIGE?
A. I'M NOT SURE I UNDERSTAND THE QUESTION THAT YOU -- WHATEVER YOUR UNDERSTANDING IS. WHY DON'T YOU EXPLAIN EXACTLY WHAT --
Q. I WANT TO KNOW WHAT SPECIAL UNIT IS.
MR. HERTZBERG: WAIT, WAIT, WAIT. THAT'S A DIFFERENT QUESTION. WE WERE TALKING ABOUT LA QUINTA. WE WERE TALKING, I ASSUME NOW -MS. PLEVIN: IN 1977 WHEN HE GOT THERE, WHAT WAS THE SPECIAL UNIT?
MR. HELLER: I'LL OBJECT. THAT'S AMBIGUOUS AS TO WHAT WAS. IT'S NOT INTELLIGIBLE.
MR. HERTZBERG: GO AHEAD.
THE WITNESS: NUMEROUS THINGS.
BY MS. PLEVIN:
Q. INCLUDING SUCH AS?
A. OKAY. GROUNDS MAN, ENGINEER, MEANING PLUMBER, MOTOR POOL, ORCHARD, ESTATE TYPE FUNCTIONS. THAT'S WHAT SU WAS, AT THAT PROPERTY. Q. AT THAT PROPERTY?
A. RIGHT.
Q. AND THAT PROPERTY WAS DESIGNATED SPECIAL UNIT BECAUSE THAT'S WHERE L. RON HUBBARD WAS AT THE TIME; IS THAT RIGHT?
A. I HAVE NO IDEA.
Q. WAS L. RON HUBBARD THERE AT THE TIME?
A. YES.
Q. AND WHO DID YOU REPORT TO AS DIRECTOR OF INSPECTIONS AND REPORTS?
A. I CAN'T RECALL.
Q. HOW LONG WERE YOU IN THAT POSITION, APPROXIMATELY?
A. OFF AND ON, MAYBE A FEW MONTHS.
Q. WHO WAS YOUR SENIOR?
A. I CAN'T RECALL. I THINK YOU JUST ASKED ME THAT, TOO.
MR. HERTZBERG: THAT WAS ASKED AND ANSWERED.
BY MS. PLEVIN:
Q. OKAY. WHEN YOU WERE NOT THERE DURING THOSE FEW MONTHS THAT YOU SAID WERE OFF AND ON, WERE YOU ON ANOTHER ASSIGNMENT OR WERE YOU JUST TEMPORARILY ABSENT FROM LA QUINTA? A. I WAS NOT TEMPORARILY ABSENT, SO I DIDN'T SAY I WAS GONE AT ALL.
Q. OKAY. YOU WERE OFF AND ON DIRECTOR OF INSPECTIONS AND REPORTS; IS THAT WHAT YOU MEANT?
A. YES, EXACTLY.
Q. WHEN YOU WERE NOT DIRECTOR OF INSPECTIONS AND REPORTS, WHAT WAS YOUR FUNCTION?
A. THAT'S DIRECTOR OF INSPECTIONS AND REPORTS CMO AT SU. AND THERE IS A DIFFERENCE. I'M NOT TRYING TO NITPICK. THERE IS A DIFFERENCE. WHAT WERE THEIR FUNCTIONS?
Q. YES.
A. OFF AND ON, AS CMO AT SU AND PROJECT OPS, AND THAT ANSWERS THAT QUESTION.
Q. NOW, PROJECT OPS, EXPLAIN WHAT THAT IS ABOUT?
MR. HERTZBERG: HE CAN ANSWER THE QUESTION, BUT JUST NOTE MY CONTINUING OBJECTION TO QUESTIONS ABOUT POSTS AND FUNCTIONS THAT WERE HELD BY MR. MISCAVIGE AT LEAST A YEAR, IF NOT MORE, PREDATING THE EARLIEST DATE ALLEGED IN THE COMPLAINT. GO AHEAD.
THE WITNESS: OKAY. WELL, YOU HAVE TO UNDERSTAND WHAT A PROJECT IS.I CAN GIVE YOU A LITTLE EXAMPLE. FOR INSTANCE, JUST TO TAKE A COMPLETELY BLAND EXAMPLE. LET'S TAKE, FOR INSTANCE, IF YOU HAD -- IF SOMEBODY HAD THEIR LAWN NOT MOWED AND GARBAGE OVER THE YARD, AND THEY HADN'T BEEN ABLE TO HANDLE THEIR OWN PERSONAL PROPERTY, WELL INSTEAD OF GOING ABOUT PICKING UP THE GARBAGE AND MOWING THE LAWN THEY MIGHT DECIDE THEY WANT TO IMPROVE THEIR AREA AND HANDLE THEIR LANDSCAPING -- YOU WOULD BREAK THIS DOWN INTO PROJECT FORM SO THAT IT COULD BE LISTED OUT STEP BY STEP BY STEP. AND THERE'S AN EXAMPLE. FOR INSTANCE, PICK UP THE GARBAGE, MOW THE GRASS, VACUUM UP THE GRASS, SWEEP OFF THE SIDEWALK NEXT TO IT THOSE ARE ALL INDIVIDUAL AREAS.
SO THE DUTY OF THE PROJECT OPS WOULD BE -- FOR INSTANCE, A SIMILAR EXAMPLE, IF THERE WAS A PROJECT, FOR INSTANCE, TO PREVENT THE GRAPEFRUIT ORCHARD AT THE BASE FROM BEING FROSTED IN THE WINTER AND BEING SUNBURNED IN THE SUMMER, YOU HAVE TO PAINT THE BARK ON THE SIDE OF THE GRAPEFRUIT ORCHARD BECAUSE THE SUN IS SO INTENSE AND YOU HAVE TO GET THE WINDMILLS OPERATIONAL. YOU WOULD BASICALLY SEE THE PEOPLE RESPONSIBLE FOR THIS. IT'S SORT OF LIKE A REMINDER, EITHER THEY DROP IT OR FORGET ABOUT IT; AND THE IDEA IS EITHER TO HANDLE A SITUATION LIKE THAT OR PREVENT A FUTURE ONE, SO THE DUTIES -- I MEAN YOU TAKE THE PROGRAM, YOU GO OVER AND FIND OUT IF THERE ARE ANY POTENTIAL BUGS IN COMPLETING THIS, AND IF THERE WERE, SORTING IT OUT, SO IT WAS DEBUGGED AND THE PROJECT WOULD GET DONE. THAT'S THE FUNCTION OF A PROJECT OP IN THAT POSITION.