BY MS. PLEVIN:
Q. APART FROM ANY ESTATES AND ORCHARD RELATED PROJECTS, WHAT OTHER KINDS OF PROJECT OPS WERE YOU INVOLVED WITH WHILE AT LA QUINTA? MR. HERTZBERG: EXCUSE ME. I WANT TO BE CLEAR. I'M NOT SURE MR. MISCAVIGE IS SAYING THAT HE -- THERE WERE SPECIFIC --
MS. PLEVIN: NO, AGREED.
MR. HERTZBERG: MAY I FINISH, PLEASE, WITHOUT HAVING MY OBJECTION CUT. I'M NOT SURE THAT THERE WERE SPECIFIC PROJECTS THAT MR. MISCAVIGE MENTIONED. I'M NOT SURE HE TESTIFIED THAT THOSE WERE DONE WHILE HE WAS ON THAT POST. I THINK HE WAS GIVING THEM FOR EXAMPLES.
MS. PLEVIN: FINE. I'LL CLARIFY.
MR. HERTZBERG: I THOUGHT YOUR QUESTION ASSUMED --
MS. PLEVIN: IT DID NOT INTEND TO. LET ME MAKE IT CLEAR.
Q. PUTTING ASIDE ANYTHING HAVING TO DO WITH ESTATES MANAGEMENT, WHAT KINDS OF PROJECT OPS WERE YOU INVOLVED WITH WHILE YOU WERE AT LA QUINTA? A. CAN I CLARIFY THIS? YOU WERE ASKING ME WHEN I WAS ON AND OFF DIR OF I&R?
Q. YES.
A. IS THAT WHAT YOU WANT TO KNOW?
Q. YES.
A. ASIDE FROM ESTATES PROJECTS?
Q. YES.
A. NONE.
Q. NOW, WHEN YOU CONCLUDED BEING --
A. AND I'LL ADD TO THAT THAT THE GRASS WAS NOT AN EXAMPLE THAT HAPPENED BUT THE ORCHARD WAS, SO THAT'S A LITERAL EXAMPLE.
Q. THAT'S IMPORTANT TO CLARIFY. NOW I KNOW THERE WAS AN ORCHARD OUT THERE.
MR. HELLER: MISS PLEVIN, I TAKE IT THAT REMARK WAS A SARCASTIC ONE, SO LET'S GO FORWARD.
MS. PLEVIN: IT WAS INTENDED TO BE LIGHT, NOT NECESSARILY SARCASTIC. YOU MAY HAVE WANTED TO INTERPRET IT THAT WAY.
Q. NOW, YOU WERE AT LA QUINTA FOR A FEW MONTHS YOU INDICATED; IS THAT RIGHT?
A. NO.
Q. HOW LONG WERE YOU AT LA QUINTA ALTOGETHER FROM 1977, PERIOD, EXCLUDING ANY SMALL PERIODS AWAY?
A. APPROXIMATELY TWO YEARS.
Q. OKAY. AND APART FROM THE DIRECTOR OF INSPECTIONS AND REPORTS POSITION, WHICH YOU HAD ON AND OFF FOR A FEW MONTHS, WHAT WAS THE NEXT POST YOU HAD? A. I THINK THAT'S HCO SECRETARY, CMO AT SU.
Q. AND WHAT FUNCTIONS DID THAT ENTAIL, MR. MISCAVIGE, PLEASE?
A. BEING RESPONSIBLE FOR THE HCO DIVISION, CALLED THE CMO UNIT.
Q. AND, FOR THE RECORD, HCO DIVISION MEANS WHAT?
A. HUBBARD COMMUNICATIONS OFFICE.
Q. NOW --
A. THAT'S WHAT THE INITIALS MEAN, IF THAT'S WHAT YOU'RE ASKING ME.
Q. OKAY. FOR THE RECORD, THAT CLARIFICATION IS NECESSARY. WHAT DID IT MEAN IN FUNCTION?
A. WHAT IT MEANT IN FUNCTION WAS THAT I WAS OVER THE DEPARTMENT 1, WHICH WAS DEPARTMENT OF PERSONNEL, AND ROUTING, AND DEPARTMENT 2, DEPARTMENT OF COMMUNICATIONS, AND DEPARTMENT 3, DEPARTMENT OF INSPECTIONS AND REPORTS. Q. WHO DID YOU REPORT TO IN THIS POSITION?
MR. HERTZBERG: DON'T GUESS.
THE WITNESS: GAIL IRWIN.
BY MS. PLEVIN:
Q. DID YOU HOLD ANY OTHER POSITIONS IN THE TWO YEARS THAT YOU WERE AT LA QUINTA, OTHER THAN THE ONES YOU'VE ALREADY MENTIONED?
A. OF COURSE.
Q. WHAT WERE THOSE?
A. ALL OF THEM. LET'S SEE. CAMERA CHIEF, JBCIC, VIDEO IC, ACTION CHIEF, CMO SU, PROJECT OPS, CMO SU, EPF WHQ, GUARD, WHQ, NIGHT WATCH WHQ, INSTRUCTION, IN CHARGE WHQ, AND I WAS A MESSENGER.
Q. TURNING TO CMO SU, WHAT DID THAT ENTAIL?
A. I DON'T UNDERSTAND THAT. I DON'T THINK I SAID THAT. THERE'S MISCOMMUNICATION.
MR. DRESCHER: THERE MAY BE A DROPPED COMMA, MISS PLEVIN. I THINK IT WAS A DESIGNATION DESCRIBING AN ACTUAL POST.
THE WITNESS: I THINK I SAID THERE WAS A POSITION IN THAT ORGANIZATION.
BY MS. PLEVIN:
Q. CMO AT SU?
A. IS THERE SOMETHING RIGHT BEFORE THAT?
Q. ACTION.
A. CHIEF CMO.
Q. SO IT'S ACTION CHIEF CMO?
A. I WAS GIVING YOU THE ORG DESIGNATION.
Q. OKAY. AND WHAT WAS THE ACTION CHIEF ROLE?
A. THE ACTION CHIEF WAS IN CHARGE OF THE ACTION BRANCH THAT WOULD HANDLE SEA ORG MISSIONS AND IN THE INSTANCE OF THAT POST, OBVIOUSLY IT WAS RELATED IN SOME DEGREE TO SU OR IN TOTAL DEGREE.
Q. WHICH MEANT IT WAS RELATED, IN SOME DEGREE, TO SOMETHING THAT L. RON HUBBARD WANTED DONE?
A. ABSOLUTELY NOT. I DID NOT SAY THAT. YOU'RE PUTTING WORDS THERE. I DON'T THINK YOU UNDERSTAND IT AT ALL.
Q. PLEASE CLARIFY.
A. IT DOESN'T MEAN THAT. THERE'S A CLARIFICATION.
Q. WE WON'T QUIBBLE. WHAT DOES IT MEAN THEN?
A. IT MEANS EXACTLY WHAT I SAID IT MEANT.
MR. HERTZBERG: IT'S BEEN ASKED AND ANSWERED.
BY MS. PLEVIN:
Q. COG MISSIONS AT SU?
A. HAVING TO DO WITH SU, AT SU.
Q. SUCH AS?
A. OKAY. SUCH AS NEW PROPERTY WAS PURCHASED,AT GILMAN HOT SPRINGS, SEEING THAT THAT WAS SET UP, THAT ALL THE ROOF LEAKS WERE HANDLED, THAT THE PROPERTY WAS ABLE TO BE MOVED INTO BY A CREW, SUCH AS THAT. THERE'S AN EXAMPLE.
Q. OTHER EXAMPLES?
MR. HERTZBERG: I'M GOING TO LET HIM ANSWER, BUT WE'RE GETTING FAR AFIELD. WE'RE ASKING FOR EXAMPLES THAT HAPPENED AT A PARTICULAR LOCATION THAT HAVE NOTHING TO DO WITH THIS COMPLAINT, EVEN ARGUABLY. THEY PREDATE THE COMPLAINT AGAIN, BUT GO AHEAD AND FINISH, IF YOU CAN THINK OF ANY OTHER EXAMPLES.
THE WITNESS: I CAN REMEMBER ONE OTHER. THAT'S GETTING VIDEO EQUIPMENT REPAIRED. BY MS. PLEVIN:
Q. NOW, WHEN YOU SAY THAT --
A. OKAY. FINE. I WASN'T DONE. BUT THAT'S OKAY, IF THAT WILL DO.
Q. WHAT ELSE HAVE YOU GOT?
A. NOTHING ELSE YET. I WAS TRYING TO THINK FOR YOU, BUT THERE YOU GO.
Q. THE ACTION BRANCH CMO, ONE OF ITS PROJECTS WAS HANDLING THE NEW PROPERTY PURCHASED? A. NO. I DIDN'T SAY "NEW PROPERTY PURCHASED." IT WAS ALREADY PURCHASED.
Q. THAT'S WHAT I WANTED, TO PURCHASE IT. DO YOU KNOW WHO PURCHASED IT?
MR. HELLER: OBJECTION ON RELEVANCE.
MR. HERTZBERG: YOU'RE ASKING IS HE AWARE, YES OR NO, OF SOME CORPORATE ENTITY PURCHASING SOMETHING IN DATES THAT PREDATE THE COMPLAINT? MS. PLEVIN: YES.
(CONFERENCE BETWEEN COUNSEL AND WITNESS.)
MR. HERTZBERG: I'M GOING TO NOTE AGAIN, FOR THE RECORD, THAT WE'RE -- IN MY VIEW, WASTING TIME, BUT HE MAY ANSWER.
MR. DRESCHER: I'LL JOIN IN THAT OBJECTION.
BY MS. PLEVIN:
Q. DO YOU KNOW WHO PURCHASED IT?
A. NO.
Q. DO YOU KNOW WHO AUTHORIZED THE FUNDS TO PURCHASE IT?
MR. DRESCHER: SAME OBJECTION.
THE WITNESS: NO.
BY MS. PLEVIN:
Q. WHERE DID YOU GO WHEN YOU LEFT LA QUINTA?
A. WHERE DID I MOVE TO?
Q. MM-HMM.
A. TO GILMAN HOT SPRINGS.
Q. WHAT WERE YOUR POSTS THERE?
A. WHEN? THEN WHEN I MOVED THERE? THE SAME.
Q. SO YOU STAYED THE SAME, MEANING WHICH ONE?
A. ACTION CHIEF.
Q. ACTION CHIEF. AND HOW LONG WERE YOU IN THAT POST?
A. I CAN'T RECALL EXACTLY.
Q. OKAY. NOW, IS ACTION CHIEF -- I'M SORRY?
MR. HERTZBERG: IF YOU CAN'T RECALL, YOU CAN'T RECALL.
THE WITNESS: OKAY. THAT POST YOU'RE ASKING ME IS ACTION CHIEF CMO SU.
BY MS. PLEVIN:
Q. RIGHT. I UNDERSTAND. DID SU MOVE TO GILMAN HOT SPRINGS?
A. YES.
Q. OKAY.
A. THAT'S A BIT OF A MISNOMER THOUGH. THE TITLE WENT WITH IT. OBVIOUSLY THE PROPERTY COULDN'T MOVE THERE. IT WAS A DESIGNATION FOR THE PROPERTY. Q. SURE. BUT THE TITLE AND THE FUNCTION OF THE SPECIAL UNIT?
A. EXACTLY. THE ESTATES FUNCTIONS PARTICULARLY. I DON'T KNOW THAT ALL OF THEM DID.
Q. WHAT WAS YOUR NEXT POSITION AFTER ACTION CHIEF CMO SU?
A. ACTION CHIEF CMO INT.
Q. HOW DID THAT DIFFER?
MR. DRESCHER: HOW DID THAT DIFFER --
MR. HERTZBERG: FROM WHAT?
MS. PLEVIN: ACTION CHIEF CMO SU.
THE WITNESS: IT'S A BIT OF AN ODD QUESTION. I DON'T KNOW WHAT YOU MEAN. FOR INSTANCE, YOU'RE AN ATTORNEY. IF YOU MOVE FROM ONE FIRM TO ANOTHER, YOU'RE STILL AN ATTORNEY, AND I ASK YOU "HOW DOES THAT DIFFER." IN THAT CONTEXT, THAT'S THE TROUBLE I'M HAVING ANSWERING THIS.
BY MS. PLEVIN:
Q. CMO INT, CLARIFY WHAT THAT MEANS.
A. COMMODORE'S MESSENGER ORG INTERNATIONAL.
Q. SO THE FUNCTIONS OF CMO INTERNATIONAL, THEY HAVE A BROADER REACH THAN CMO SU IN TERMS OF THE POSSIBLE AREAS THEY MIGHT BE ACTING IN? IS THAT REASONABLE? MR. HERTZBERG: IS THAT A QUESTION?
MR. DRESCHER: OBJECT TO THE FORM. IT'S VAGUE AND AMBIGUOUS, WHETHER IT'S REASONABLE OR NOT.
MR. HELLER: JOIN IN THE OBJECTION AND IT'S VAGUE. I DON'T UNDERSTAND IT, PUTTING ASIDE THE WORD "REASONABLE."
MR. HERTZBERG: DON'T ANSWER IT AS PHRASED. WHY DON'T YOU REPHRASE IT THEN.
BY MS. PLEVIN:
Q. DO YOU UNDERSTAND THE QUESTION, MR. MISCAVIGE?
A. NO.
Q. CMO SU RELATED TO THE SPECIAL UNIT?
A. THAT'S IT.
Q. OKAY. CMO INTERNATIONAL RELATES TO WHAT?
A. THEN? WHEN ARE YOU ASKING ME?
Q. WELL, LET'S -- THEN. WE'LL TAKE IT AT DIFFERENT TIMES.
MR. HERTZBERG: "THEN" BEING A YEAR OR TWO BEFORE THE COMPLAINT, THE FIRST ALLEGATION IN THE COMPLAINT.
MS. PLEVIN: "THEN" BEING WHEN HE MOVED TO GILMAN HOT SPRINGS.
THE WITNESS: OKAY. THEN? WHEN I MOVED TO GILMAN HOT SPRINGS?
BY MS. PLEVIN:
Q. RIGHT.
A. CMO DIDN'T EXIST WHEN I MOVED TO GILMAN HOT SPRINGS.
Q. OKAY. BUT IT WAS THE NEXT POSITION YOU TOOK, ACCORDING TO YOUR TESTIMONY?
A. THAT'S CORRECT.
Q. ALL RIGHT. SO THERE WAS SOME LAPSE IN TIME AFTER YOU GOT TO GILMAN HOT SPRINGS, WHILE YOU WERE NOT ON POST?
A. NO, THAT'S NOT WHAT I SAID.
MR. HERTZBERG: THAT'S NOT WHAT HE SAID.
THE WITNESS: YOU ASKED ME --
MR. HERTZBERG: THAT'S FINE.
BY MS. PLEVIN:
Q. THE NEXT POSITION YOU TOOK AFTER CMO SU WAS CMO INT; IS THAT RIGHT?
A. NO.
Q. WHAT WAS THE NEXT POSITION AFTER CMO SU?
A. THAT'S NOT A POSITION I EVER HELD.
Q. ACTION CHIEF CMO SU?
A. OKAY.
Q. WHAT WAS YOUR NEXT POSITION?
A. ACTION CHIEF CMO INT.
Q. ACCORDING TO WHAT YOU JUST TESTIFIED, CMO INT WAS NOT FUNCTIONAL WHEN YOU FIRST --
MR. HERTZBERG: THAT'S BEEN ASKED AND ANSWERED.
BY MS. PLEVIN:
Q. CHA; IS THAT RIGHT?
A. PRECISELY.
Q. OKAY. SO WAS THERE SOME -- WAS THERE ANY GAP IN TIME BETWEEN ACTION CHIEF CMO SU AND ACTION CHIEF CMO INT?
MR. HELLER: ANSWER THE QUESTION AS PHRASED.
MR. HERTZBERG: I DON'T KNOW WHAT YOU MEAN --
THE WITNESS: YES.
BY MS. PLEVIN:
Q. THE GAP IN TIME, IN TERMS OF YOUR HAVING A POST, WAS THERE A PERIOD WHEN YOU WERE NOT ON POST?
A. NO.
Q. SO YOUR NEXT POSITION WAS CMO INT?
A. NO, NO. MY NEXT POSITION AFTER ACTION CHIEF CMO SU WAS ACTION CHIEF CMO INT. THE MISUNDERSTANDING HERE IS YOU KEEP CONFUSING FUNCTIONS OR DUTIES OR POST POSITIONS WITH ORGANIZATIONS, SO -- AT ANY RATE, I WAS TRYING TO HELP YOU OUT THERE. Q. THAT'S FINE. THE DEPOSITION IS TO CREATE CLARITY AND INFORMATION, MR. MISCAVIGE.
A. VERY WELL.
MR. DRESCHER: NO. IT'S TO PHRASE QUESTIONS THAT ARE INTELLIGIBLE. AND HE'S HELPING THAT, AND I APPRECIATE THAT, TOO.
BY MS. PLEVIN:
Q. WHAT KINDS OF PROJECTS WERE YOU INVOLVED WITH AS ACTION CHIEF CMO INT?
MR. HERTZBERG: IF YOU WERE INVOLVED IN ANY PROJECTS.
THE WITNESS: RIGHT. WHAT DO YOU MEAN BY "INVOLVED"?
BY MS. PLEVIN:
Q. OKAY. PARTICIPATE IN, SUPERVISE, REVIEW, PLAN, ALL OF THE ABOVE.
A. OKAY. ALL RIGHT. WHAT KIND OF PROJECTS -- GET TELEPHONES INSTALLED, GETTING INTERCOMS SET UP ON THE BASE, GETTING MEMEOFILES CREATED, PUTTING TOGETHER HAT PACKS -- LET'S SEE -- GETTING THE BUILDINGS PAINTED, GETTING A STUDIO BUILT, GETTING A CAMERA MAN
TRAINED.
Q. ANYTHING ELSE?
MR. HERTZBERG: WELL, OKAY. JUST SO WE'RE CLEAR, YOUR PREVIOUS QUESTION WAS GIVE EXAMPLES. ALL RIGHT. NOW, YOUR QUESTION IS CAN HE REMEMBER ANY OTHERS, OTHER THAN THE ONES HE MENTIONED. BY MS. PLEVIN:
Q. ARE THERE A GREAT NUMBER OF OTHERS?
A. WHAT EXACTLY WAS YOUR QUESTION THOUGH, SO I'M SURE I'M ANSWERING THE RIGHT ONE HERE?
Q. AS ACTION CHIEF CMO INT, WHAT I'M LOOKING FOR IS THE KIND OF PROJECTS YOU WERE INVOLVED IN.
A. PROJECTS, THAT'S WHAT YOU'RE ASKING ME?
MR. HERTZBERG: HE ANSWERED THAT.
THE WITNESS: OKAY.
BY MS. PLEVIN:
Q. WHAT OTHER KIND OF FUNCTIONS DID YOU HAVE AS ACTION CHIEF CMO INT?
A. WHAT ARE THE KINDS OF FUNCTIONS?
Q. YES.
A. RUNNING MISSIONS, SEEING THAT MISSIONS WERE BRIEFED, SEEING THAT MISSIONS WERE PREPPED, SEEING THAT MISSIONS WERE FIRED, SEEING THAT BRIEFING PACKS WERE PUT TOGETHER, SEEING THAT MISSION ORDERS WERE WRITTEN, ARRANGING TRANSPORTATION. Q. FOR MISSIONAIRES?
A. PRECISELY; SEEING THAT MISSIONAIRES WERE WORD CLEARED ON THE MATERIALS NEEDED TO ACCOMPLISH THEIR PURPOSE IN LIAISON WITH THE QUALIFICATIONS.
Q. OKAY. FOR CLARITY ON THE RECORD, WHEN YOU SAY "MISSIONS" IN THIS CONTEXT, WOULD YOU DESCRIBE WHAT THAT IS, PLEASE?
A. YES, A MISSION IS -- I THOUGHT I DESCRIBED THIS ALREADY ACTUALLY.
MR. HERTZBERG: UNLESS IT'S DIFFERENT FROM WHAT YOU SAID BEFORE, IT'S BEEN ASKED AND ANSWERED.
MS. PLEVIN: IT'S SIMPLY TO CREATE A RECORD AT THIS POINT THAT'S CLEAR. I'M NOT --
MR. HERTZBERG: IS IT THE SAME AS WHAT YOU SAID BEFORE?
THE WITNESS: YES.
MR. HERTZBERG: DO YOU WANT TO AMPLIFY? GO AHEAD.
THE WITNESS: WHAT IS A MISSION? OKAY. WELL, YOU HAVE A SITUATION AND A SITUATION IS DEFINED AS A DEPARTURE, MAJOR DEPARTURE FROM THE IDEAL SCENE, AND AT THE BOTTOM OF THAT THERE'S SOME Y. Y IS DEFINED AS AN EXPLANATION THAT OPENS A DOOR TO A HANDLING, AND
IF YOU HAVE ACTUALLY PULLED THE STRINGS ON THE SITUATION, ALL THE WAY DOWN, YOU WILL NOW HAVE A Y, WHICH MEANS THAT THAT SITUATION CAN BE RESOLVED.
A MISSION WOULD TAKE A SITUATION, KNOWING WHAT THE Y IS, AND THEREFORE, KNOWING WHAT EXACT HANDLING STEPS ARE THUS POSSIBLE AS A RESULT OF THE DOOR BEING OPENED BECAUSE THE Y WAS FOUND BY EVALUATION, AND THEY WOULD BE ON -- THEY WOULD OPERATE ON WHAT IS KNOWN AS A SET OF MISSION ORDERS, AND THE SET OF MISSION ORDERS IS AN EXACT SERIES OF STEPS, SOMETIMES CONSECUTIVE, SOMETIMES NOT, SOMETIMES THEY CAN BE DONE CONCURRENTLY WITHIN EACH OTHER. THEY ARE NUMBERED IN EACH STEP.
THEY LIST OUT THE PRECISE ACTIONS THAT THESE PERSONS WOULD DO, KNOWING, OF COURSE, THAT ONCE THEY ARE PERFORMING THEM, THEY ARE TO BE SENSIBLE ABOUT WHAT THEY'RE DOING, IF THEY COME UPON ANY OTHER INFORMATION, AND THEY NEED TO RESOLVE SUCH MATTERS TO ACCOMPLISH THEIR MISSION PURPOSE. THESE MISSION ORDERS HAVE AN EXACT PURPOSE TO BE ACCOMPLISHED, EXACT MAJOR TARGETS, EXACT PRIMARY TARGETS EXACT VITAL TARGETS, EXACT OPERATING TARGETS; THEY HAVE LISTED THE MEANS OF MISSION COMMUNICATION, AND THEY ALSO HAVE LISTED THE TARGET DATE FOR COMPLETION.
THE MISSIONAIRES -- THERE WOULD BE A SERIES OF PEOPLE SELECTED TO DO THIS. IDEALLY AT LEAST TWO, AND HIGHER, GENERALLY YOU WOULD THINK TWO TO THREE, ALTHOUGH AT TIMES YOU MIGHT HAVE AN ADDITIONAL MISSIONAIRE KNOWN AS AN INSURANCE MISSIONAIRE. THEY WOULD READ THESE MISSION ORDERS. THEY WOULD READ ANY APPROPRIATE MATERIALS THAT WERE RELEVANT TO THESE MISSION ORDERS SO THAT THEY WERE THOROUGHLY SKILLED IN WHAT SITUATION THEY WOULD BE DEALING WITH. THEY WOULD ALSO REVIEW THEIR MAJOR TARGETS AND HAVE TO DEMONSTRATE THEM IN CLAY TO GIVE A PERFECT EXAMPLE THAT THEY KNEW WHAT THEY WERE TRYING TO ACCOMPLISH, AND THAT WAS IN AGREEMENT WITH WHAT THEIR MISSION OPERATIONS WANTED THEM TO ACCOMPLISH AND WHAT WAS STATED ON THE MISSION ORDERS.
AT SUCH A POINT AS ALL THIS BRIEFING WAS COMPLETED, THEY WOULD THEN FIRE AND THEY WOULD BE OPERATED WHEREBY THEY WOULD REPORT ON THEIR OT TARGETS, DONE, IP, BUG, AND THE MISSION OPS WOULD KEEP TRACK OF THESE MISSION TARGETS THAT WE DONE IP OR BUG, AND MAKE SURE THAT THEIR MISSION STAY DEBUGGED, THAT THEY COMPLETED THEIR MISSION TARGETS, THAT THEY ACCOMPLISHED THEIR MISSION PURPOSE AND ACHIEVED THE MAJOR TARGETS OF THEIR MISSION, AT WHICH POINT THEY RETURNED HOME.
BY MS. PLEVIN:
Q. THE MISSIONAIRES WERE PRINCIPALLY MEMBERS OF THE SEA ORG; IS THAT A CORRECT STATEMENT? A. YES -- NO. THAT'S ENTIRELY INACCURATE. ALWAYS.
Q. ALWAYS MEMBERS OF THE SEA ORG?
A. YES.
Q. WOULD THEY INCLUDE OTHER MEMBERS OF THE CMO SOMETIMES?
A. POSSIBLY.
Q. CMO MEMBERS ARE SEA ORG AS WELL AS CMO; IS THAT A CORRECT STATEMENT?
A. NO, THAT'S NOT A CORRECT STATEMENT.
MR. DRESCHER: I'M LOST ON THE TIME FRAME. ARE YOU TALKING ABOUT BACK THEN?
MS. PLEVIN: YES.
MR. HELLER: THE QUESTION HAS BEEN ANSWERED.
MR. HERTZBERG: SHE'S ASKING AT THE TIME THAT YOU'RE TALKING ABOUT, A COUPLE OF YEARS BEFORE 1978, THE OPERATIVE DATE OF THE COMPLAINT, WERE THE MEMBERS OF THE CMO AND SEA ORG, AS UNDERSTAND, YOU'RE ASKING WHETHER THEY'RE MEMBERS OF BOTH? MS. PLEVIN: NO. I WAS ASKING WHETHER -- TO SIMPLIFY, I WAS ASKING WHETHER A MEMBER OF THE CMO IS ALWAYS A MEMBER OF THE SEA ORG. IS THAT A CORRECT STATEMENT?
MR. DRESCHER: AT THAT TIME?
MS. PLEVIN: AT THAT TIME.
THE WITNESS: YES.
BY MS. PLEVIN:
Q. AND AT THE PRESENT TIME, HAS IT CHANGED?
A. NO.
I MEAN SEA ORG MEMBERS ARE WHAT MAKE UP -- THEY ARE SEA ORG MEMBERS. I DON'T WANT TO CONFUSE THIS ISSUE BECAUSE YOU'RE ASKING IF THEY'RE BOTH. THEY'RE --
Q. CAN A PERSON BE A CMO WITHOUT BEING A MEMBER OF THE SEA ORG TODAY?
A. NO, NO.
Q. OKAY. THAT CLARIFIES THAT. BUT NOT ALL SEA ORG MEMBERS ARE MEMBERS OF THE CMO?
A. THAT'S CORRECT.
Q. OKAY. THAT'S SIMPLE ENOUGH.
A. OKAY.
Q. AT THE TIME YOU WERE RUNNING MISSIONS, SUCH AS YOU'VE DESCRIBED, PRIOR TO THAT TIME, HAD YOU TAKEN OEC COURSES, ORGANIZATION EXECUTIVE COURSES, OR DONE ANY TRAINING ON THE OEC?
A. YES.
MR. HELLER: OBJECT ON RELEVANCE.
BY MS. PLEVIN:
Q. HAVE YOU DONE THE WHOLE SERIES?
A. I DON'T KNOW WHAT YOU MEAN BY HAVE I DONE THE WHOLE SERIES.
MR. HERTZBERG: FIRST SHE'S ASKING YOU, AT THE TIME, HAVE YOU DONE THE WHOLE SERIES. IF YOU DON'T UNDERSTAND THE QUESTION, MAYBE SHE CAN CLARIFY.
BY MS. PLEVIN:
Q. YOU INDICATED YOU HAD STUDIED -- DONE SOME OF THE OEC STUFF? HAD YOU COMPLETED THE OEC COURSE MATERIALS --
MR. HERTZBERG: LET'S NOT TALK ABOUT "OEC STUFF." LET'S NOT USE THAT. IF WE'RE TALKING ABOUT COURSES, LET'S TALK ABOUT COURSES.
MS. PLEVIN: FINE
(RECESS TAKEN.)
MS. PLEVIN: WE'RE BACK ON THE RECORD. WAS THERE A QUESTION PENDING?
(RECORD READ.)
BY MS. PLEVIN:
Q. DID YOU EVER STUDY ALL THE ORGANIZATION EXECUTIVE COURSES, MR. MISCAVIGE?
A. WELL, WHAT DO YOU MEAN BY THAT? LET ME ASK YOU THAT.
Q. WELL, THERE'S A SET OF GREEN VOLUMES --
A. MM-HMM.
Q. -- GENERALLY REFERRED TO AS THE OEC VOLUMES.
A. HMM.
Q. THERE ARE STUDIES THAT GO ALONG WITH STUDYING THE ORGANIZATIONAL MANAGEMENT FUNCTION WITH THOSE VOLUMES; IS THAT A CORRECT STATEMENT?
A. NO, IT'S VERY INACCURATE.
Q. OKAY. WHY DON'T YOU DESCRIBE TO ME HOW A PERSON GOES AROUND STUDYING THE OEC MATERIALS?
A. GOES AROUND --
Q. GOES ABOUT STUDYING THE OEC MATERIALS. IS IT A CHECK SHEET FORMAT?
A. HOW A PERSON GOES AROUND STUDYING THE OEC MATERIALS.
Q. IS IT A COURSE FORMAT, A CHECK SHEET FORMAT?
A. THE OEC VOLUMES?
Q. THE OEC VOLUMES.
A. NO, THEY'RE IN VOLUMES; THEY'RE IN BOOKS.
Q. SO IT'S SELF STUDY?
A. I DON'T -- NO. I'M REALLY NOT TRACKING WITH WHAT YOU'RE SAYING HERE, I'M SORRY.
Q. WHEN YOU STUDY THE OEC VOLUMES, IT'S A COURSE THAT YOU TAKE, ISN'T IT?
A. THERE IS A COURSE, BUT YOU SAY WHEN YOU STUDY THE OEC VOLUMES, IT'S A COURSE THAT YOU TAKE, AND I'M TELLING YOU IT'S ENTIRELY INACCURATE.
Q. OKAY. OKAY. THE OEC COURSE IS ENTIRELY SEPARATE FROM THE OEC VOLUMES?
A. YES. MAYBE. THAT'S 50-50. NO, I MEAN -- NO, IT'S NOT AN ACCURATE STATEMENT.
Q. THERE'S SOME INTERPLAY ON THE OEC COURSE, GREEN VOLUMES?
A. POSSIBLY.
Q. ARE THERE SEVERAL DIFFERENT COURSES OFFERED FOR STUDYING THE OEC MATERIALS OR THE OEC COURSE -- IS IT A SINGLE COURSE? LET'S START THERE. IS IT A SINGLE COURSE, SEVERAL COURSES? YOU HAD IT ONCE AND THAT'S IT?
MR. DRESCHER: WHICH QUESTION --
MR. HERTZBERG: WHICH QUESTION DO YOU WANT HIM TO ANSWER?
BY MS. PLEVIN:
Q. I'M TRYING TO HELP HIM FORMULATE HOW BEST TO RESPOND.
MR. HERTZBERG: WE HAVE TO FORMULATE THE BEST QUESTION FIRST BEFORE HE CAN RESPOND. WHAT QUESTION ARE YOU ASKING? YOU ASKED THREE OR FOUR DIFFERENT QUESTIONS THERE IN SEQUENCE. WHICH QUESTION DO YOU WANT HIM TO RESPOND TO?
MS. PLEVIN: I'M TRYING TO GET HIM TO RESPOND TO A SIMPLE QUESTION, IF HE STUDIED THE OEC COURSE.
Q. DO YOU UNDERSTAND THAT QUESTION, MR. MISCAVIGE? DID YOU STUDY THE OEC COURSE? DID YOU TAKE THAT COURSE, AND IF THERE'S MORE THAN ONE COURSE, LET'S CLARIFY THAT.
MR. HERTZBERG: HE TESTIFIED TO THAT ALREADY.
THE WITNESS: OKAY. LET ME --
MR. HERTZBERG: THERE'S NO SUCH THING AS "THE OEC COURSE."
THE WITNESS: THAT'S CORRECT -- YOU DON'T KNOW WHAT "OEC" MEANS. OEC MEANS ORG EXEC COURSE. SO YOU'RE ASKING ME IF I TOOK THE ORG EXEC COURSE, COURSE. OF COURSE, I DIDN'T BECAUSE THERE'S NO SUCH THING AS THE ORG EXEC COURSE, COURSE.
BY MS. PLEVIN:
Q. BUT THERE'S AN ORG EXECUTIVE COURSE?
A. YES.
Q. DID YOU TAKE THAT COURSE?
A. WHICH ONE? THAT'S WHERE THE CONFUSION IS ENTERING HERE.
Q. ALL RIGHT. HOW MANY ARE THERE?
A. WHEN, NOW?
Q. HOW MANY ORG EXECUTIVE COURSES ARE THERE NOW IS FINE.
A. ARE THERE NOW?
MR. HERTZBERG: NOW, TODAY?
MS. PLEVIN: NOW, TODAY.
MR. HERTZBERG: I'M GOING TO LET HIM ANSWER. I'M NOT SURE HOW THAT'S RELEVANT TO ANYTHING IN THE COMPLAINT, BUT YOU MAY ANSWER.
THE WITNESS: I DON'T KNOW WHAT YOU MEAN BY THAT. I REALLY DON'T. YOU'RE CONFUSING A SET OF VOLUMES WITH A COURSE. WHAT EXACTLY ARE YOU ASKING ME?
MS. PLEVIN: I THINK THE QUESTION STANDS FOR ITSELF.
MR. HELLER: WELL, IF YOUR RESPONSE IS YOU CAN'T UNDERSTAND, THAT'S YOUR RESPONSE. DON'T ANSWER A QUESTION YOU CANNOT UNDERSTAND.
BY MS. PLEVIN:
Q. WHAT IS IT YOU DIDN'T UNDERSTAND?
A. YOU ASKED ME HOW MANY ORG EXECUTIVE COURSES ARE THERE.
Q. NO. I SAID HOW MANY --
A. I DON'T GET IT. HOW MANY ORG EXECUTIVE COURSES.THERE HAVE BEEN NUMEROUS. THAT'S MY ANSWER.
Q. HOW MANY HAVE YOU TAKEN SINCE -- EVER?
MR. HERTZBERG: WAIT. YOU MEAN IN THE ENTIRE TIME THAT MR. MISCAVIGE HAS BEEN INVOLVED IN THE CHURCH OF SCIENTOLOGY?
MS. PLEVIN: WELL, IF THERE ARE TOO MANY TO MENTION, I'M SURE HE'LL TELL ME THAT.
MR. HERTZBERG: FIRST OF ALL, I'M BEGINNING TO PERCEIVE A LITTLE SARCASM. LET'S KEEP THIS ON AN EVEN KEEL, MISS PLEVIN. HE CAN ANSWER. I THINK THIS HAS NOTHING TO DO WITH THE COMPLAINT, BUT IF YOU CAN APPROXIMATE OR -- IF YOU UNDERSTAND THE QUESTION, AND YOU CAN APPROXIMATE, TELL --
(CONFERENCE BETWEEN COUNSEL AND WITNESS.)
THE WITNESS: OKAY. I'LL TRY TO EXPLAIN TO YOU WHAT I'M TALKING ABOUT. THERE ARE A SET OF VOLUMES CALLED THE OEC VOLUMES, MEANING THE ORG EXECUTIVE COURSE VOLUMES. THEY GO 0, 1, 2, 3, 4, 5, 6, 7. THEY WERE PUBLISHED SOMETIME IN THE EARLY 1970'S. THERE IS OR HAS BEEN A COURSE CALLED THE ORG EXECUTIVE COURSE. THAT ORG EXECUTIVE COURSE HAS NOT NECESSARILY BEEN THE SAME COURSE, ALWAYS.
INDIVIDUALLY THERE ARE ORG EXECUTIVE COURSE VOLUMES, AS I SAID, 0, 1, 2, 3, 4, 5, 6, 7. FOR EXAMPLE, 0 NOW, TODAY, IS NOT THE SAME AS 0 FIVE YEARS AGO. BY MS. PLEVIN:
Q. YOU'RE TALKING ABOUT THE VOLUME?
A. PRECISELY.
Q. ALL RIGHT.
A. FURTHERMORE YOU ASKED -- THE ORG EXECUTIVE COURSE IS NOT, AND HAS NOT, ALWAYS BEEN JUST THE VOLUMES, OR PARTICULARLY WHAT'S IN THE VOLUMES, SO YOU ASKED ME -- I DON'T KNOW. HAS THAT CLARIFIED IT FOR YOU? DO YOU SEE WHAT MY CONFUSION IS, WHAT YOU'RE ASKING ME?
Q. MM-HMM.
A. THEIR MATERIALS -- I DON'T KNOW HOW -- WELL, YOU COULDN'T, BUT A SCIENTOLOGIST COULD BUY A SET OF OEC VOLUMES. YOU ASKED ME HOW WOULD HE STUDY THESE? I DON'T KNOW. Q. HAVE YOU STUDIED THE OEC VOLUMES?
A. WHAT DO YOU MEAN BY THAT? REALLY, I'M SERIOUS. CLARIFY FOR ME --
Q. DO YOU CONSIDER YOURSELF TO BE FAMILIAR WITH THE POLICIES THAT ARE IN THE OEC VOLUMES?
A. EVERY SINGLE --
MR. HERTZBERG: I WAS GOING TO ASK --
BY MS. PLEVIN:
Q. GENERALLY, NOT EVERY SINGLE ONE.
A. YES.
Q. OKAY. AND I APPRECIATE THAT YOU'VE CLARIFIED THAT THE COURSE HAS NOT ALWAYS BEEN THE SAME. I TAKE IT THAT PERHAPS THE COURSE GETS REVISED FROM TIME TO TIME.
A. NOT AS A MATTER OF COURSE, NOT AS A MATTER OF ABSOLUTE NECESSITY EVERY SIX MONTHS, IF THAT'S WHAT YOU'RE ASKING ME, BUT IT HAS, YES. IF YOU WERE TO PICK UP A SET OF OEC VOLUMES TODAY, THEY ARE PRETTY MUCH THE SAME VOLUMES THAT WERE PUBLISHED IN THE EARLY 1970'S, SO I WOULDN'T CALL THEM COMPLETELY ACCURATE OR COMPLETE.
Q. OKAY.
A. THERE YOU GO.
Q. I'M TALKING ABOUT THE COURSE NOW, THE COURSE HAS BEEN REVISED? A. YES.
Q. OKAY. AND THE COURSE --
A. I WOULDN'T SAY REVISED. I'D SAY UPDATED OR CHANGED. ALL RIGHT. IN MANY DIFFERENT WAYS, YES, EVEN HOW YOU GO ABOUT STUDYING IT. Q. OKAY.
A. ALL RIGHT.
Q. WHEN DID YOU FIRST TAKE THE ORGANIZATION EXECUTIVE COURSE? WHENEVER --
A. AS THE ORGANIZATION EXECUTIVE COURSE?
Q. YES.
A. I CAN'T ANSWER THAT QUESTION. YOU ASKED --
Q. YOU DON'T REMEMBER?
A. YOU'RE ASKING ME WHEN WAS THE FIRST TIME I EVER READ A POLICY?
Q. NO. WHEN WERE YOU FIRST ON COURSE FOR --
A. EVER?
Q. FOR THE ORG EXECUTIVE COURSE.
A. FOR THE ORG --
MR. DRESCHER: IF THE ANSWER IS NOT ANSWERABLE, YOU DON'T HAVE TO TRY TO INTERPRET IT.