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checks?
THE WITNESS: The memo section was different. There were different
explanations on various checks that I received from him.
Q. So it wasn't always witness fees and expenses. Let me back up
here.
A. Let me refer to an earlier exhibit. Looking back to
Exhibit-31, for example, dated October 9th of '91, there was an
explanation in the memo box which does not, at least from what I
can read here, say expense fees. And I don't recall at that time
whether I wrote witness fees.
I believe in this example he wrote witness slash and then there
was another explanation. And I don't recall what that explanation
was. And then on this check it was witness fees plus expenses.
Q. Was Exhibit-31 and Exhibit-32, were those checks presented to
you at the time that you prepared the four declarations with
Mr. Ingram?
A. They were payment for me following my signature on the
declarations. But they were payment for my role in the deliberate
creation of these phony declarations, yes.
Q. And after that Exhibit-16 was created which was the lawsuit
that you were to filed against the Cult Awareness Network,
correct?
A. That is correct.
Q. And then Exhibit-80, which we have just been looking at, was
after the creation of the draft lawsuit, correct?
A. That's correct.
(Defendant's Exhibit-No. 80 was marked for identification and is
bound separately.)
Q. Was there more than one occasion in which you received
reimbursement from Mr. Ingram?
A. Monthly.
Q. And what were that reimbursement for?
A. For witness fees and expenses.
Q. And was that what they were actually for?
A. No.
Q. What were they for?
A. Expenses reflected the out-of-pocket expenses that I had in
the various operations that I was involved in, whether it be
letter writing complaints, phone calls, threatening phone calls
to individuals, any type of unlawful activity that may have
incurred an expense, Eugene reimbursed me for and I also provided
him with receipts, copies of my telephone bills and anything that
I could get a receipt on. And then from that he would reimburse
me.
(Deposition of Garry L. Scarff, at p. [179], ln. 3 - p. [183],
in. 13.)
=================================================================
Substantiation of Scarff's Relationship With Scientology.
=================================================================
Q. Now, turning to Exhibit-81, what is Exhibit-81 or the various
things which appear to be photocopied onto Exhibit-81?
A. These are just things that I provided to Dan Leipold to in
part substantiate my relationship with Scientology. It includes
the business card of Eugene Ingram. Business card from Henry
Kriegel, who is a member of a Montana cult. A business card of
Mary Anne Ahmad who is a public relations director of the Church
of Scientology in Chicago. And also a letter I received from Mary
Anne Ahmad.
Q. By 'letter' you mean a photocopy of an envelope?
A. That's correct.
(Defendant's Exhibit-No. 81 was marked for identification and is
bound separately.)
(Deposition of Garry L. Scarff, at p. [183], in. 14 - p. [184],
in. 6.)
=================================================================
Scarff's Scientology Operations Against CAN; Scarff Defects from
Scientology.
=================================================================
Q. Exhibit-82, that is a two-page letter unsigned. What is
that?
A. This is a confidential letter that I sent to Cynthia Kisser
when I made the decision to defect from the Church of
Scientology.
Q. And what was the purpose of that letter?
A. Purpose of that letter was to offer to speak with her
attorneys and to relay a decision on my part to make amends for
all the anguish and pain that I caused a number of people as a
result of the Scientology operations that I was a part of on
behalf of Scientology
(Defendant's Exhibit-No. 82 was marked for identification and is
bound separately.)
MR. WEINER: Excuse me, if I can interrupt, I don't believe you
asked him anything about the signature. I notice it is not
signed. If I may ask is the original of this letter signed?
THE WITNESS: Yes. The original of this was signed
BY MR. BERRY:
Q. And this was your copy of that letter?
A. That's correct.
(Deposition of Garry L. carff, at p. 184, in. 8 - p. 185,
in. 10.)
=================================================================
Ingram Paid Emplovee of Bowles & Moxon: Scarff Threatened Because
of Operations Against CAN.
=================================================================
Q. Does Eugene Ingram work for the law firm of Bowles & Moxon?
A. Eugene Ingreun represents himself as a private investigator
who works for Bowels & Moxon that just happens to represent one
of many clients and that one client being the Church of
Scientology. That is a deliberate lie and a deliberate
misrepresentation meant not only to deceive the public but to