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A. Because David Butterworth instructed me that with everything
that had been happening, particularly after a number of incidents
that resulted out of the church's Fair Game Doctrine against
individuals it perceived to be its enemies, that they wanted to
kind of blind-side the Cult Awareness Network by promoting
dialogue which would be an overt operation and at the same time
they would continue their covert operations against the Cult
Awareness Network. But that the purpose of this letter was to
promote dialogue and hopefully communicate to those families
which Mr. Butterworth told me had expressed some opposition to
practices and decisions made within the Cult Awareness
Network. And if we could reach those families and get those
families to rebel and to leave the Cult Awareness Network, it
would assist the OSA into working toward their goal of destroying
the Cult Awareness Network .
Q. When did Mr. Butterworth tell you all this?
A. He told me this in July of '92
Q. Did he tell you this in a telephone call or --
A. Yes.
Q. -- in person?
A. No. These were a series of telephone calls both made to my
home and to the Mission of Davis where I was at the time.
Q. And did you make any calls to Mr. Butterworth regarding this
matter?
A. Yes. And my telephone records will prove that.
Q. And with regard to the revisions to this letter, how did that
process work?
A. Mr. Butterworth again told me that prior to making any
statements with regards to Cynthia Kisser that it needed the
approval of Mr. Bowles or another legal within Bowles & Moxoo to
make sure that nothing in the content of this letter could be
legally held against them.
Q. I understand that but this letter went through several
revisions, correct?
A. It did go through several revisions.
Q. How did the creation, revision and finalization process work
in terms of the letter going backwards and forwards?
A. Initially it was simply a dialogue letter, but because of the
hold that Mr. Butterworth and others felt that Cynthia Kisser had
on the Cult Awareness Network because she had been in an
authority position within the Cult Awareness Network for many
years and had gained the respect of quite a few people, that we
needed to formulate a letter which would not only promote
dialogue but also show, quote, the truth, end quote, of the lack
of integrity that Ms. Kisser has exercised both in her personal
and professional life.
And so it was kind of a two-part letter. We had to denigrate
Cynthia Kisser but at the same time promote this dialogue.
Q. Did drafts go back and forth between you and Mr. Butterworth?
A. Yes, it did. I didn't have a fax machine so I had to go into
downtown to Mission of Davis and fax it through Mission of Davis
to Mr. Butterworth and he would fax it back to the Mission of
Davis for me.
Q. And did there come a point in time where the very final draft
of this letter had been approved by Mr. Butterworth?
A. Yes.
Q. And what happened then?
A. The letter was sent to 550 plus members of the Cult Awareness
Network and their associates.
Q. Did you send that letter to the 500 people?
A. Yes.
(Deposition of Garry L. Scarff, at p. [167], in. 12 - p. [171],
in. 4.)
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Deliberate Creation of False Declarations to be Used in
Litigation Against CAN.
=================================================================
Q. Moving on to Exhibit-No. 80, that is a two-page
document. What is that?
A. The front copy is a copy of a check I received from Eugene
Ingram on August 14th, 1992 for what he refers to as witness fees
and expenses. And then the second copy is just an example of the
types of things that I sent to Eugene Ingram and asked for
reimbursement from.
Q. So the second page is not the expenses that are being
reimbursed by the first page?
A. That's correct. That's correct.
Q. If this is an example of the sort of things that are being
reimbursed, what is the notation 'witness fees and expenses' at
the bottom of Mr. Ingram's check?
A. As I have said on record before, I was acting under the
scheme of Scientology as the witness, as the suffering witness
for Eugene Ingram against the Cult Awareness Network. I was not
perceived to be the member of the Church of Scientology doing
these things against the Cult Awareness Network. I was the
witness. So on every check that he sent me that had absolutely
nothing to do with any type of legal process, he would always
write there witness fees.
Q. And that was irrespective of the nature of the expense being
reimbursed?
THE WITNESS: That's correct, because Mr. Ingram was an employee
of Bowles & Moxon, a law firm, and I was considered a witness for
Bowles & Moxon.
Q. You received a number of checks from Mr. Ingram, did you?
A. Yes.
Q. And what was written in the memo section of those various