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A. An employee of Bowles & Moxon by the name of Eugene Ingram.
Q. Have there been occasions on which your home has been visited
by people who give you concern to fear for your safety?
A. Yes.
Q. What is the basis for your concern as to your safety if you
put your address on the record here?
A. In addition to the threats which I have received by officials
of the Church of Scientology, I have been visited by individuals
that I suspect may be involved in the Church of
Scientology. People who have come to my door and refused to speak
with me until I answered the door and suspicious activity very
close to my apartment and people coming asking questions of my
neighbors about me, questions that they would not know about
unless they were personally intimately involved with me. It is
just part of the Fair Game policy instituted by the Church of
Scientology against me. And I will not allow you to have my
residential address at this time.
Q. Was there any incident involving vehicles?
A. Yes.
Q. Could you tell us about that?
A. I was visited by a gentleman at the front door who knocked on
my door. I opened the window of my living room which opens out
on to the street level.
I asked him what he wanted. He said that I would have to open the
door because he needed to speak with me, that he had some papers
that he needed to give me. And I heard some whispering and I
looked over to the left looking out the screen to the left and I
saw a gentleman with his back to the wall next to my door trying
to conceal himself.
I also noticed a red van out in the parking lot with a door ajar
with an individual in the van looking at my apartment.
At that time I advised the person that I was calling 911. I got
on the phone to call 9 l l and I said I am calling the
police. The next thing I heard was the van screeching out of the
parking lot. The individuals are no longer at my door. The van
was taking off at a high speed outside my parking lot. And then I
noticed an older car like an Oldsmobile rushing within a few feet
behind it out of the parking lot taking off.
(Deposition of Garry L. Scarff, at p. [22], in. 18 - p. [24],
in. 19.)
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Plan 100 Scheme-SLAPP Suits Against Cult Awareness Network.
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Q. Turning now to Exhibit-16 what is Exhibit-16, Mr. Scarff?
A. 16 is a copy of a lawsuit which was part of the OSA, Office
of Special Affairs, and Bowles & Moxon's scheme called Plan 100,
which was number of SLAPS suits which were filed against the Cult
Awareness Network, and this was a lawsuits which Bowles & Moxon
had intended to file on my behalf.
THE WITNESS: And on the last page you will notice a Timothy
Bowles representing himself as my attorney in this lawsuit.
BY MR. BERRY:
Q. Is there any indication on the top of the documents as to its
source?
A. Yes. This exhibit is actually the second -- I am sorry, the
third draft of the complaint. If you notice under the complaint
for damages it says Scarff No. 3. At the time it was faxed to me
on January 27, 1992 from Bowles & Moxon.
Q. And that appears to be a 13-page document?
A. It is a 13-page document
(Defendant's Exhibit-No. 16 was marked for identification and is
bound separately.)
(Deposition of Garry L. Scarff, at p. [49], in. 21 - p. [50],
In. 24.)
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Campaign to Incriminate Without Merit Cult Awareness Network.
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Q. Now, you referred to a campaign. What did you mean by that?
A. It was another operation against the Cult Awareness Network
to incriminate without merit the Cult Awareness Network.
Q. And who conducted this operation?
A. The Office of Special Affairs in coordination with Bowles &
Moxon, in coordination with Eugene Ingram and a number of other
individuals that have worked with us. Dr. George Robertson and a
slew of other individuals who wanted to see the Cult Awareness
Network cease to exist.
Q. Did you actually hear people say that they wanted the Cult
Awareness Network to cease to exist?
A. On many occasions. Many occasions, yes.
Q. And were these people within the Office of Special Affairs?
A. Office of Special Affairs. Also at Bowles & Moxon. And
various Scientology entities throughout the United States that I
had contact and association with.
(Defendant's Exhibit-No. 66 was marked for identification and is
bound separately.)
(Deposition of GalTy L. Scarff, at p. [129], in. 18 - p. [130],
in. 19.)
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Office of Special Affairs Operation attempting to get Criminal
Charges Reinstated Against Rick Ross.
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Q. And just so we don't have any misunderstanding, when we refer