Stipulation of Evidence in the USA vs. Mary Sue Hubbard

 

Scientology lawyer Kendrick Moxon named as unindicted co-conspirator

  • Notes about the following document from the person who scanned it
  • in from the original:
  •  

  • Presented for your edification is the complete Stipulation
  • of Evidence in the USA vs. Mary Sue Hubbard et al. case. I think
  • this document is particularly important in understanding the
  • lengths to which the Church of Scientology's agents (be they
  • GO, OSA, or RTC) will go to in order to protect their leaders.
  •  

  • This 300 page document is but a very small part of the 45,000+ pages
  • of documentation in this case alone. Additionally are some strange
  • and interesting documents. Such as the letters of character reference
  • for Mary Sue Hubbard in support of a plea for probation/parole.
  • Letters from the heads of a number of Scientology related
  • organizations (e.g. CCHR) are included. Paulette Cooper's name comes
  • up a fair amount; mostly pleading against the inordinate delays
  • created (e.g. 6 months to depose Mary Sue Hubbard on one particular
  • aspect).
  •  

  • In light of the recent revelations involving the Church of
  • Scientology in Greece, it becomes clear that the same guidelines
  • and policies are being applied in some areas (e.g. giving awards
  • for the theft of confidential government files).
  •  

  • The original is a very faded document that required a large amount
  • of editing to get a decent digital copy. As a result, there may be
  • some typos (not many, I hope). However, the original had a fair
  • number of typos and formatting inconsistencies itself. I have not
  • inserted any [sic]'s or other markings to indicate misspelling or
  • formatting problems that existed in the original.
  •  

  • From my understanding, the following document was agreed upon by
  • the defendants as a way to eliminate some of the discovery process
  • that would normally accompany such an extensive legal case. The
  • only reasoning I can come up with is that the prosecution and
  • defense were willing to make an open and shut case against the named
  • defendants in return for an agreement that the prosecution would
  • not go after L. Ron Hubbard.
  •  

    Page breaks are marked with a complete line accross the page like so:

    - ------------------------------------------------------------------

  • Footnote seperators are marked with an incomplete line accross the
  • page like so:
  •  

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    UNITED STATES DISTRICT COURT
    FOR THE DISTRICT OF COLUMBIA

    UNITED STATES OF AMERICA

    V. Criminal No. 78-401 MARY SUE HUBBARD, et al.

    S T I P U L A T I O N O F E V I D E N C E

    - ----------------------------------------------------------------------

    • i -

     

    TABLE OF CONTENTS

    PAGE

    I. The Witness Michael J. Meisner 1

    II. Organizational Structure of the Guardian's Office 6

    111. The Conspiracy to Intercept Oral Communications, 12

  • Burglarize and Steal, and the Substantive Acts
  • Committed Pursuant Thereto
  •  

    A. The Order to infiltrate the Internal Revenue

    Service in Washington, D,C. 17

    B. The Bugging of the IRS Chief Counsel's

    Conference Room on November 1, 1974 22

    C. The First Infiltration of the IRS in the

    District of Columbia Pursuant to GO 1361 32

    D. Infiltration of the Tax Division of the

    United States Department of Justice 57

    E. The Guardian's Office Awards its GO 1361 Workers 79

    F. The Theft of IRS Documents Exempted from

    Disclosure Under the Freedom of Information Act 81

    G. The Guardian Program Order Instituting An "Early

  • Warning System" to Detect Possible Legal Actions
  • Against L. Ron Hubbard and Ilary Sue Hubbard 90
  •  

    H. The Los Angeles Guardian's Office Sends Help to

    the District of Columbia @Quardian's Office 100

    I. The Guardian's Office Orders Mr. Meisner to

    Los Angeles for Debriefing and Auditing 106

    J. Mr. Meisner Returns to the District of Columbia 112

    K. The Entry Into the IRS identification Room and

    the Making of Counterfeit Identification Cards 119

    L. Guardian Program Order 302 and the Theft of

  • Documents Withheld by the United States Under
  • the FOIA 123
  •  

    M. Burglaries of the Suite of Offices of the

    Deputy Attorney General of the United States 127

    N. Burglaries of the Office of International

  • Operations of the Internal Revenue Service
  • and Theft of Documents Therefrcm 133
  •  

    O. Burglaries and Thefts or Documents Fro-.n the

    Department of Justice in Washington, D.C. 139

    1. Office of Paul Figley 139

    2. Interpol Liaison Office at the Department

    of Justice 142

    - ----------------------------------------------------------------------

     

    • ii -

     

  • Offices of Special Assistant to Assistant
  • Attorney General ror Administration
  • John F. Shaw
  • 150

    P. Burglaries and Thefts or Docu-.ients from Assistant

  • United States Attorney Nathan Dodellt-Office,
  • Located in the United States Courthouse for the
  • District of Columbia 155
  •  

    IV. The Conspiracy to Obstruct Justice, to Obstruct

  • an Investigation, to Harbor a Fugitive and to
  • Make False Declarations Before the Grand Jury 176

    A. The Preparation or the Cover-up Story 176

    B. The Defendant Gerald Bennett Wolfe is Arrested
  • in Washington, D.C., by the Federal Bureau of
  • Investigation 190
  •  

    C. The United States Case Against the Defendant
  • Gerald Bennett Wolfe is Referred to the Grand
  • Jury, and an Arrest Warran*- is Issued for
  • Michael Meisner 196
  •  

    D. The Guardian's Office Harbors and Conceals

    Fugitive From Justice Michael Me@isner 198

    E. The Guardian's Office Gives the FBI and the

    Grand Jury False Handwriting Exemplars 209

    F. The Guardian's Office Refines its Cover-up Plans 214

    G. The Federal Grand Jury Investigation in the

    District of Columbia Continues 225

    H. The Guardian's Office Cover-up Moves Into

    its Final Phase 232

    1, The Guardian's Office Restrains and Guards

    Michael Meisner 238

    J. Michael Meisner's First Escape from His Guards 248

    K. The Defendant Wolfe's Sentencing and Subsequent
  • Testimony Before the Grand Jury in the District
  • of Columbia 252
  •  

    L. The Defendant Wolfe is Debriered by the Guardian's

    Office After his Grand Jury Appearance 265

    M. Michael Meisner Surrenders to the Federal

    Bureau of Investigation 268

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    iii

    TABLE OF EXHIBITS

    EXHIBIT

    NUMBER DESCRIPTION SECTION PAGE

    1A Organizational Chart II 6,7,11

    Guardian's Office

    1B Organizational Chart II 8,11

  • Guardian's Office
  • (pre-January 1, 1976)
  •  

    1C Organizational Chart II 9,11

  • Guardian's Office
  • (post-January 1, 1976)
  •  

    1D Organizational Chart II 10,11

  • Assistant Guardian's
  • Office DC
  •  

    2 Document #13969 III 12,14,-17,

    95,163

    3 Document #3060 IIIA 19-22

    4 Document #9317 IIIA 19-22

    5 Document #6131 IIIB 26-27

    6 Document #20106 IIIB 28-30

    7A Document #20276 IIIB 28-29

    7B Document #20277 IIIB 28-29

     

    8 Document #2065 iiic 32-35,39

    8A Document #2065 P. 7 IIIc 32-34

    8B Document #2065 p. 6 IIIc 32,34

    8C Document #2065 p. 5 IIIc 32,34-35

    8D Document #2065 P. 4 IIIc 32,35

    8E Document #2065 P. 3 IIIc 32,35

    9 Document 02064 IIIc 32,36-37

    9A Document #2064 p. 2 IIIc 32,36

    10 Document #2062 IIIc 32,39

    IOA Document 02062 p. 2 IIIc 32,38--39

    11 Document #2057 IIIc 32,39-40

    12 Document #12636 IIIc 44-46

    13 Document 019692 IIIc 47

    14 Document #1433 IIIc 48-52

    - ----------------------------------------------------------------------

    iv

    EXHIBIT

    NUMBER DESCRIPTION SECTION PAGE

    15 Document #118 liic 53-55

    16 Document #115 iiic 56-57

    17 Document #19669 IIID 59-61

    18 Document #3778 IIID 60

    19 Document #3801 IIID 59-61

    20 Document #12898 IIID 59-61

    21 Document #3799 IIID 59-61

    22 Document #3661 IIID 59-61

    23 Document #3664 IIID 59-61

    24 Document #3806 IIID 59-61

    25 Document #11244 IIID 59-61

    26 Document #7394 IIID 61

    27 Document #3656 IIID 59-61

    28 Document #3610 IIID 61

    29 Document #3811 IIID 61

    30 Document #3814 IIID 61

    31 Aerial photograph --

    32 Document #8742 IIID 62-65

    33 Document #3005 IIID 65-67

    34 Document #2044 IIID 68-70

    35 Document #2304 IIID 70-71

    36 Document 014395 IIID 72-74

    37 Document #14395 p. 57 at IIID 74

    bottom right hand side.

    38 Document #14399 IIID 72

    38A Document #14399 p. 4 IIID 72-64

    39 Document #2048 IIID 75-76

    40 Document #4012 IIIF 82-83

    41 Document #1405 IIID 77

    - ----------------------------------------------------------------------

    v

    EXHIBIT

    NUMBER DESCRIPTION SECTION PAGE

    41A Documcnt 01405 p. 2 IIID 77

    42 Document t2O55 IIID 78

    43 Document #1403 IIIE 79-80

    43A Document #1403 p. 2 IIIE 79

    43B Document 01403 p. 4 IIIE 79

    43C Document 01403 p. 5 IIIE 79

    43D Document #1403 p. 6 IIIE 79

    43E Document #1403 P. 3 IIIE 79-80

    44 Document 012584 IIIF 83-85

    45 Document 012607 IIIF 84-85

    46 Document 01419 IIIF 85,108,110

    46A Document #1419 p. 20 IIIC 40,85

    [Document #1419, p. 61]

    46B Document #1419 p. 21 IIIF 85,108-109,

    [Document #1419, p. 8-101]

    46C Document #1419 p. 23 IIIF 85

    46D Document #1419 p. 25 IIIF 85

    4T Document #12608 IIIF 83-84,86

    48 Document #1431 IIIF 83

    48A Document #1431 P. 3 IIIF 84,86

    49 Document #1421 IIIF 87-88

    50 Document 03660 IIIF 83-84,89

    51 Document #3066 IIIc 51

    52 Document #1541 III02 142-143

    53 Document #9322 IIIG 90-92

    54 Document #3676 IIIG 97-98

    55 Document #3677 IIIG 97-98

    56 Document #1410 IIID 78

    56A Document #1410 p. 20 IIIF 89

    56B Document #1410 p. 21 IIIF 89

    56C Document #1410 p. 22 IIIH 105-106

    - ----------------------------------------------------------------------

    vi

    EXHIBIT

    NUMBER DESCRIPTION SECTION PAGE

    56D Document #1410 p. 23 IIIH 104-105

    56E Document #1410 p. 43 IIIA 21

    5T Document #11120 IIIH 106

    58 Document 01427 III I 110-111

    59 Document #21704 IIIJ 114-115

    60 Document #21724 IIIJ 116-117

    61 Meisner IRS Identification IIIK 121

    card

    62 Document #21626 IIIJ 118

    63 Document #798 IIIG,O 95,142-143

    64 Document #3956 IIIH 99-100

    65 Document #1097 IIIL 124-125

    66 Document #1098 IIIL 123-124

    67 Document #14768 IIIL 126-127

    68 Document #1412 IIIJ 118

    69 Document #15779 IIIM 131

    70 Document #15780 IIIM 131

    71 Document #15781 IIIM 131

    72 Document #15778 IIIM 132

    73 Document #3102 IIIN 137-138

    74 Document #3035 IIIN 137-138

     

    75 Document #3036 IIIN 137-138

    76 Document #3033 IIIN 137-138

    77 Document 03099 IIIN 137-138

    78 Document #10963 III01 141

     

    79 Document 010958 III01 l4l-l42

    80 Document #2459 III02 146-147

    81 Document 12462 III02 148

    82 Document #11561 III02 148

    83 Document #11562 III02 148

    84 Document #11584 III02 148

    - ----------------------------------------------------------------------

    vii

    EXHIBIT

    NUMBER DESCRIPTION SECTION PAGE

    85 Documerit #2463 IIIO2 148-149

    86 Document #15777 III02 148-149

    87 Document #2461 III03 152

    88 Document #14111 III03 152

     

    89 Document #14110 III03 152

    90 Document #14109 11103 152

    91 Document #14108 III03 152

    92 Document #14107 III03 152

    93 Document #9989 III03 153

    94 Document #9990 III03 153

    95 Document #15772 III03 154

    96 Document #826 IIIP 156-159

    97 D.C. Bar Library Sign-in IIIP 162

    Log of May 21, 1976

    98 Document #3044 IIIP 164

    99 Document #11571 IIIP 165

    100 Document #14114 IIIP 165

    101 Courthouse Sign-in Log IIIP 167

    of May 28, 1976

    102 D.C. Bar Library Sign-in IIIP 167

    Log of May 28, 1976

    103 Document #18601 IIIP 168

    104 Document #14113 IIIP 168

    105 Document #898 IIIP 170

    106 D.C. Bar Library Sign-in Log IIIP 171

    of June 11, 1976

    107 Document #1550 IIIC 52

    108 Document #8598 IVA 189

    109 Document #555 IIIM 127

    110 Document #17416-17417 IIIP 173

    111 Document #8567 IIIG 91

    112 Document 08908 IIIP 174

    - ----------------------------------------------------------------------

    viii

    EXHIBIT

    NUMBER DESCRIPTION SECTION PAGE

    113 Quality Inn Motel (Arlington) IIIP 176

    Registration Card

    114 Document #11176 IVA 177

    115 Document #3125 IVA 180

    116 Document #14751 IVA 179

    117 Document #14738 IVB 191

    118 Document #14744 IVB 192

    119 Document #14745 IVB 193

    120 Document #14742 IVB 194

    121 Document #14749 IVB 195

    122 Document #14748 IVB 195

    123 Document #13789 IVC 198

    124 Document #13785 IVD 198-199

    125 Document #11078 IVD 201

     

    126 Document #11076 IVD 201

    127 Document #11055 IVD 203-204

    128 Document #14662 IVD 205

    129 Docunent #14737 IVD 207

    129A Document #14737 p. 2 IVD 206

    129B Document #14737 P. 3 IVD 207

    130 Document #14672 IVE 211

    131 Document #11231 IVD 207-209

    132 Document #11425 IVE 210-211

    133 Document #13755-13756 IVE 212

    134 Document #13758 IVE

    212

    135 Document #10755 IVF 218,219

    136 Document #14658 IVF 218

    137 Document #111667 IVF 216

    138 Document #10706 IVF 219-220

    139 Document #10744 IVF 222

    140 Document #13757 IVF 222


    - ----------------------------------------------------------------------

    ix

    EXHIBIT

    NUMBER DESCRIPTION SECTION PAGE

    141 Document #14746 IVF 223-224

     

    142 Document #14741 IVF 225

    143 Document #10722 IVG 226

    144 Document #10709 IVG 227-228

    145 Document #8580 IVG 229

    146 Document #1071@5 IVG 229

    147 Document #14687 IVG 231

    147A Document #14687 (2d letter IVG 232

    from end)

    147B Document #14687 last letter) IVG 232

    148 Document #14689 IVH 232-233

    149 Document #8575 IVH 234

    150 Document #11215 IVH 235

    151: Document #11175 IVH 236

     

    152 Document #3135 IVH 237

    153 Document #11179 IVH 238

    154 Document #3146 ivi 238

    155 Document #3145 ivi 238

    156 Document #3144 ivi 239

    157 Document #3143 ivi 240

    158 Document #11232 ivi 240

    159 Document #3153 ivi 241-242

    160 Document #10066 ivi 243

    161 Document #8574 ivi 243-244

    162 Document #8576 ivi 243-244

    163 Document #10067 ivi 244-245

    164 Document #8573 ivi 246

     

    165 Document #8572 ivi 246

    166 Document #10070 ivi 245

     

    167 Document #10071 ivi 247

    - ----------------------------------------------------------------------

    x

    EXHIBIT

    NUMBER DESCRIPTION SECTION PAGE

    168 Document #11184 IVJ 249

    169 Document #11183 IVJ 249

    170 Document #11185 IVJ 251

    171 Document #3148 IVL 266

    172 Document #11201 IVL 267

    173 Document #13141 IVL 266

    174 Document #11199 IVL 268

    175 Document #8555 IVM 272

    176 Document #3150 IVM 273

    177 Document #11203 IVM 273

    178 Document #8558 IVM 273

    179 Document #8548 IVM 274-276

    180 Document #8544 IVM 277

    181 Document #11204 IVM 277

    182 Document #11202 IVM 274

    183 Document #8561 IVM 278

    184 Document #8563 IVM 279

    185 Document #3147 IVM 280-282

    187 Document #20107 IIIB 28-30

    188 Document #20034 IVA 179-180,192

    189 [not used]

    190 FH Radio Monitor IIIB 25

    191 Electronic device in gold IIIB 25

    colored box

    192 Battery connection IIIB 25

    193 Telephone resonator IIIB 25

    194 Wall receptacle IIIB 25

    195 Spring steel shims IIIH 102

     

    196 Spring steel shims IIIH 102

    197 Spring steel shims IIIH 102

    198 Spring steel shims IIIH 102

    - ----------------------------------------------------------------------

    xi

    EXHIBIT

    NUMBER DESCRIPTION SECTION PAGE

    199 Spring steel shims IIIH 102

    200 Spring steel shims IIIH 102

     

    201 Spring steel shims IIIH 102

    202 Key micrometer IIIH 102

    203 H.P.C., Inc. lock picking IIIH 101-102

    kit

    204 Handwriting given by Moxon IVE 212

    to Hansen of FBI

     

    205 Wolfe Personnel Record at IIIA 18

    IRS

    206 Thomas Personnel Record IIIG 94

    at DOJ

    207 Thomas Identification Card IIIG 94

    at DOJ

    208 Conference memorandum of IIIB 31

    Lewis Hubbard of Nov. 1,1974

    209 Conference memorandum of Lewis IIIB

    Hubbard of Nov. 1, 'L974

    210 FBI Lab Decode of document IIIB 30-31

    #20106

    211 FBI Lab Decode of documents IIIB 30-31

    #20107

    212 FBI Lab decode of document IVA 18o

    #14751

    213 FBI Lab decode of document IVB 194

    #14742

    214 Grand Jury docket entry Dec. IVG 225

    15 9 1976

    215- Gerald Wolfe Grand Jury IVK 255-260

    testimony of June 10, 1977

    216 FBI Lab decode of document IVB 192

    #14744

    217 Photograph of bugging equipment IIIB 25

    218 Photograph of lockpicking IIIH 102

    equipment

    219 Document #7984 IVM 274-275

     

    *All of the above exhibits are appended to the instant stipulation.

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    UNITED STATES DISTRICT COURT

    FOR THE DISTRICT OF COLUMBIA

    UNITED STATES OF AMERICA

    V Criminal No. 78-401

    MARY SUE HUBBARD, et al.

    STIPULATION OF EVIDENCE

    The United States of Americal through its attorneys,

  • United States Attorney Carl S. Rauh, Assistant United States
  • Attorneys Raymond Banoun, Timothy j. Reardon, III, and Steven
  • C. Tabackman, and the attorneys for the defendants: Leonard B.
  • Boudin, Esquire, and Michael L. Hertzberg, Esquire, for the
  • defendant Mary Sue Hubbard; Phillip j. Hirschkop, Esquire,
  • for the defendants Henning Heldt and Duke Snider; Rcger Zukerman,
  • Esquire, and Roger Spaeder, Esquire, for the defendants, Richard
  • Weigand and Gregory Willardson; Michael Nussbaum, Esquire, and
  • Earl C. Dudley, Esquire, for the defendants Cindy Raymond and
  • Mitchell Hermann, also known as Mike Cooper; John Kenneth
  • Zwerling, Esquire, for the defendants Gerald Bennet Wolfe; and
  • Leonard J. Koenickp Esquire for the defendant Sharon Thomas; as
  • well as the above-mentioned defendants themselves , agree and
  • stipulate that the evidence as to all the defendants is as follows:
  •  

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    1. The Witness Michael J. Meisner

    Michael J. mEisner, 29, was born in Chicago, Illinois.

  • He attended parochial elementary and secondary schools. He
  • studied at the University of Illinois at Urbana for two and
  • a half years from 1968 through 1970. Mr. Meisner became
  • interested in Scientology in November 1970 when he was intro-
  • duced to it by a friend. During the next two months,
  • he took several courses at the Urbana Church of Scientology
  • franchise and in January 1971 left the University to become a
  • full time course supervisor. He held this Position until
  • May 1971 when he was sent to the Church of Scientology of
  • St. Louis for two weeks of further training. He then returned
  • to Urbana, Illinois, where he resumed his duties as a course
  • supervisor until September 1971. At that time, he returned
  • to the St. Louis Church of Scientology where for the next eight
  • months he was trained to become an auditor. 1/ From May
  • 1972 until August 1972, he resumed his duties as a course
  •  

    - -------------------

    1/ An "auditor" is a person who counsels Scientologists by applying the teachings and therapy methods of Scientology.

    - ----------------------------------------------------------------------

     

    2

  • supervisor and an auditor in Urbana, Illinois. In August
  • 1972, lie assumed the position of Executive Director of the
  • franchise until June 1973.
  • In mid-May 1973, the defendant Duke Snider recruited

  • Mr. Meisner for the Guardian's Office of the Church of Scien-
  • tology in Washington, D.C. In a meeting in Washington,
  • D.C., the defendant Snider told him that he wanted him to
  • become part of the Intelligence Bureau of the Guardian's
  • Office. The Intelligence Bureau became the Information Bureau
  • Bureau [sic] in July 1973. In mid-June 1973, Mr. Meisner and his
  • wife Patricia were accepted for the Guardian's Office and
  • moved to the District of Columbia to take courses in prepara-
  • tion for assuming their duties as officials of that orgainiza-
  • tion. Upon becoming an officer of the Intelligence Bureau,
  • Mr. Meisner was instructed by the defendant Duke Snider that
  • that Bureau was in the forefront of the Guardian's Office
  • that is, it dealt with safeguarding the environment within
  • which Scientology existed by locating, removing and rendering
  • harmless all thore perceived to be enemies of Scientology,
  • This was accomplished by infiltration, theft of documents and
  •  

    - ----------------------------------------------------------------------

    • 3 -

     

  • covert operations. Following a week of training in Guardian's
  • Office procedures and policies in the District or Columbia,
  • Mr. Meisner was sent to Los Angeles, California, for more
  • intensive training in the Intelligence (Information) Bureau.
  • From July 1973 until October 1973, Mr. Meisner's training

  • in the Information Bureau of the Guardian's Office in Los
  • Angeles, California, included intensive courses in administra-
  • tive procedures, policies and practices of the Information
  • Bureau, as well as the Guardian's Office as a whole. These
  • included courses on the preparation of documents, such as
  • reports, "CSWS" (completed staff work), 2/ "programs," (later
  • denominated "Guardian Program Orders") "projects," "Guardian
  • Orders," and daily Intelligence reports. He also learned
  • the routing and format required in the preparation of documents.
  • Mr. Meisner was taught that strict adherence to the chain
  • of command and seniority within the organizational structure
  • - ---------

    21 A "CSW" (completed staff work) is a request to a senior official for approval or disapproval of proposed action.

    - ----------------------------------------------------------------------

    • 4 -

     

  • was of paramount importance in the day-to-day operations of
  • the Guardian's Office, and more specifically the Information
  • Bureau. Mr. Meisner was Instructed that the routing placed
  • on each written document followed strictly that chain of
  • command so that each memorandum, report, etc., went to the
  • appropriate persons for approval and/or information. In a
  • clinical setting, Mr. Meisner also learned to conduct covert
  • investigations, surveillances "suitable guise" investiga-
  • tions, 3/ the recruiting and supervising of covert agents,
  • the placing of these agents in organizations that were to he
  • infiltrated, the theft of documents, and other overt and
  • covert intelligence gathering techniques. The defendant
  • Gregory Willardson, among others, supervised him in the
  • these areas. For a three-week period Mr. Meisner also cross-
  • filed memoranda and other [sic] covertly and overtly obtained
  • documents of interest to Scientology. He thereby became
  • intimately familiar with the sophisticated filing system
  •  

    - ---------

    3/ A "suitable guise" investigation is one where the investigator assumes a false or misleading identity in order to gain information otherwise unavailable to him.

    - ----------------------------------------------------------------------

    • 5 -

     

  • maintained by the Guardian's Office and its Information
  • Bureau. The absolute necessity of correctly labelling and
  • filing all documents obtained and kept by the Information
  • Bureau was emphasized to Mr. Meisner. Strict adherence to
  • these policies was mandated to assure that the Information
  • Bureau and the Guardian's Office functioned in a proper and
  • efficient manner.
  • In November 1973 Mr. Meisner returned to the District of Columbia as Branch II Director of the Information Bureau.

  • In that position he was responsible for internal security
  • matters. These included both the physical security of the
  • premises of the local Guardian's Office as well as the handl-
  • ing of all dissident and disaffected Scientologists. with
  • regard to the latter, his duties included obtaining personal
  • information which would prevent them fron becoming a nuisance
  • to Scientology. In January 1974, the Guardian World-Wide
  • Jane Kember elevated Mr. Meisner to the position of Assistant
  • Guardian for Information in the District of Columbia (AG I DC)
  • In his new post, Mr. Meisner was responsible for all overt
  • and covert intelligence investigations and operations. This
  •  

    - ----------------------------------------------------------------------

     

    6

  • included the implementation of all Guardian orders, programs,
  • and projects within the District of Columbia applicable to
  • the Information Bureau, as well as overall supervision of
  • all covert operatives in private and governmental agencies.
  • Until March 1974, the defendant Duke Snider was Mr. Meisner's
  • immediate supervisor. At that time, the defendant Snider
  • was Assistant Guardian for the District of Columbia (AG DC)
  • the highest position in the local Guardian's Office.
  •  

    II.
    Organizational Structure of the Guardian's Office
  • As a result of his intensive training in the Guardian's
  • Office as well as having held high positions within the
  • Information Bureau Mr. Meisner became thoroughly familiar
  • with the organizational structure of the Guardians Office
  • and its bureaus, both nationally and internationally. _Govern-
  • ment Exhibit No. 1A_ is a chart showing the organizational
  • structure of both the World-Wide and United States Guardian's
  • offices. At all times material to the indictment, the Guard-
  •  

    - ----------------------------------------------------------------------

    • 7 -

     

  • ian's Office had World-Wide headquarters at St. Hill Manor
  • in East Grinstead, Sussex, England; United States headquarters
  • in Los Angeles, California; and a local office in the District
  • of Coluubia and some thirty other cities throughout the
  • United States. 4/ Each of the Guardian's Offices was con-
  • posed of five bureaus: Information (prior to July 1973
  • known as the Intelligence Bureau), Public Relations, Legal,
  • Finance, and Social Coordination. A sixth bureau not shown
  • on _Government Exhibit No. 1A_ was known as the Services Bureau.
  • Each bureau was headed both at the World-Wide and national
  • level by a Deputy Guardian. At the local level each bureau
  • was headed by an Assistant Guardian.
  • At all times material to the indictment, L. Ron Hubbard
  • was, by virtue of his role as the founder and leader or
  • Scientology, overall supervisor of the Guardian's Office.
  •  

    - ---------

  • 4/ Including: New York City; Philidelphia, Clearwater,
  • Florida; Miami; Chicago; Detroit; St. Louis; Houston; Denver;
  • Seattle; San Diego; San Francisco; Sacramento, California;
  • Hawaii; I.as Vegas; Los Angeles; Advanced Organization of Los
  • Angeles; American Saint Hill Organization (Los Angeles);
  • Portland, Oregon; Mexico City (which is under the jurisdic-
  • tion of the United States Guardian's Office).
  •  

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    8

  • His wife, the defendant Mary Sue Hubbard, held the titles of
  • "Controller" and "Commodore Staff Guardian" (CSG) and, as the
  • second person in the hierarchy of Scientology, had duties
  • which included supervision of the Guardian's Office. Jane
  • Kember held the title of "Guardian World-Wide" (GWW) and headed
  • the daily operations of all Guardian's Offices, reporting
  • directly to the defendant Mary Sue Hubbard who in turn reported
  • directly to L. Ron Hubbard. The Deputy Guardian for Informa-
  • tion World-liide (DG I WW) was Morris Budiong, also known as
  • Mo Budlong (hereafter Mo Budlong). He supervised all
  • Information Bureaus around the world and reported
  • to Jane Kember. The defendant Henning Heldt was the Deputy
  • Guardian for the United States (DG US) supervising all Guard-
  • ian's Offices in the United States. He reported directly to
  • Jane Kember.
  • _Government Exhihit No. 1B_ is an organizational chart of

  • the Information Bureau in the United States from November
  • 1973 until January 1976 when it was reorganized. The defendant
  • Duke Snider was Deputy Guardian for Information in the United
  • States (DG I US) from March 1974 until January 1975, a position
  •  

    - ----------------------------------------------------------------------

    9

  • thereafter held by the defendant Richard Weigand. Beginning
  • in January 1975 and at all other relevant times charged in
  • the indictment, the defendant Snider was Deputy Deputy Guardian
  • for the United States (DDG US) and in that capacity was the
  • defendant Heldt's top assistant. In October 1975, the defendant
  • Gregory Willardson became the Deptuty Deputy Guardian for Infor-
  • mation U.S. (DDG I US). Prior to that date he had held the
  • position of Branch I Director U.S. (BR I DIR US). The defend-
  • ant Cindy Raymond was the Collections Officer for the United
  • States (COLL OFF US). She was responsible for the overt, and
  • covert data collection for the Information Bureau.
  • _Government Exhibit 1C_ is an organization chart of the

  • Information Bureau in the United States after its reorganiza-
  • tion in January 1976. Following the removal of the defendant
  • Richard Weigand from the position of Deputy Guardian for
  • Information U.S. on approximately May 15, 1977, that postition
  • was assumed by Brian Andrus until June 16, 1977, and there-
  • after by the defendant Gregory Willardson. From January 1976
  • until May 1977, Mr. Willardson held the position of Deputy
  • Deputy Guardian Information U.S. (DDG I US). For the period
  •  

    - ----------------------------------------------------------------------

     

    10

  • January 1976 to June 1976, Mr. Willardson also held the
  • position of National Secretary for the Information Bureau U.S.
  • (NATL SEC US). 5/ From June 1976 until August 1976 the
  • position of National Secretary was held by Michael Meisner,
  • who was succeeded in September 1976 by the defendant Cindy
  • Raymond.
  • Government Exhibit No. 1D is an organizational chart of

  • the Information Bureau in the District of Columbia. From
  • January 1974 until June 1976, Mr. Meisner held the position of
  • Assistant Guardian for Information in the District of Columbia
  • (AG I DC). Immediately under him was the defendant
  • Hermann who held the position of Information Branch I Director
  • from January 1974 until March 1975. The defendant Hermann,
  • using the alias "Mike Cooper," subsequently held the position
  • of Southeast U.S. Secretary (SEUS SEC) from January 1976
  • until March 1977 when he was succeeded by Brian Andrus.
  •  

    - --------------------

    5/ That was commonly reffered to in Scientology as a

  • position "held from above" or "HFA" both of which appear on
  • the routing portion of certain documnets and which connotes
  • that an individual ia assuring the responsibilities of more
  • than one position at the same time.
  •  

    - -----------------------------------------------------------

    11

    (See Government Exhibit No. 1C, supra.)

    The routing on each document prepared within the Guard-
  • ian's Office of the Church of Scientology, and its under-
  • lying bureaus, tracks the organizationial charts. (Government
  • Exhibits Nos. IA-ID.) Thus, in the routing portion of each
  • document is the abbreviation of each of the positions held
  • by the Persons who were to receive the particular documents,
  • as well as that of the author of the document. (See, e.g.
  • Government Exhibit 14, discussed at page 48, infra.
  • From

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