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get into trouble for saying they didn't follow a particular PL. The
,witness Is better off sticking to his own reality and previous statement
than by back-pedalling and modifying his testimony to make it "agree"
with a PL he Is confronted with. Don't be intimidated by this tactic! A
PL says what it says, and the witness In not responsible for those words,
nor for whether or not he applied that particular PL. That may sound
heretical at first, but unless the witness understands it and is flexible
enough to be "in court" and not "on post" or before an ethics
Investigation, he can be led Into very uncomfortable situations (and into
making statements that could hurt the Church's case).
B. In summary, the above points to teach a witness regarding
cross-exam are these:
Specifics vs. Generalities
Personal Knowledge
Be Literal
Ecclesiastical vs. Corporate/Legal
Don't Fear "lmpeachment" From PLs
9. The witness will also need to have a thorough understanding
(once again, commensurate with his post, training and experience, and
Intelligence) of the religious nature of Scientology and how this is
evident in many interrelated things.
For example, we all know that the Tech Volumes are clearly religious
In content; but what about the OEC? It contains Issues on how to run an
organization, how to get orders Issued and complied with how to write an
(0044)
Invoice and keep financial records. What's religious about that? well,
take a look at It. We have a 1st dynamic tech In auditing; we also have
a 3rd dynamic tech of dealing with groups/organizations. On the grade
chart there Is also (up the center) an Awareness Scale with awareness
characteristics In an ascending gradient. Those same awareness
characteristics appear on the org board, assigned to each of the 21
departments. Those 7 divisions of the org board are the 7 volumes of the
OEC. What is the org board? It's not a chart of any specific org; it's
a description of relationships and a way of handling life. An org may
operate off an org board, but it's equally applicable to any size group,
ox even to any individual. It's a philosophic machine, not a chart of
some commercial company. It Is based quite exactly on Scientology
doctrinal concepts. The OEC contains ethics PLs. Are they religious?
Certainly. They deal with doctrinal concepts about the being and how to
handle him. Even something as mundane and "secular" as writing an
invoice can be traced to a basic Scientology concept that "Truth Is the
exact time, place, form and event." If one cared to undertake the
project, the entirety of LRH policy could be traced to basic concepts of
communication, ethics, etc., and into the Axioms and Factors. The key
here is that to almost any Scientologist who stops to think about It, the
concepts underlying the org board and the OEC are part of our religion.
to an outsider they may seem "secular," but they carry a different and
deeper meaning for the Scientologist if for no other reason than they are
written by LRH, the Founder.
Understanding this, the witness cannot be caught off guard or put in
an uncomfortable position regarding PLs, org boards, etc. Be can know
they are religious in nature and can believe that to be true. It's
really part of his belief, it can't be questioned beyond that by a civil
court.
10. You will have seen from the points listed in this writeup and
the others about hatting and preparing witnesses that what it comes down
to Is that EVERY SCIENTOLOGY WITNESS CAN AND WILL BE ASKED ANY AND ALL
(0045)
KINDS OF QUESTIONS ON CROSS-EXAM. Don't think that a witness who was
only called to Identify a piece of paper from a file can't and won't (if
the judge is blind enough to allow this) be cross-examined on org boards,
ethics. nature of policy, hierarchical and corporate relationships, etc.
To the opposing attorney, all Scientology witnesses are "Fair Game" for
all entheta cross-exam. So ALL SCIENTOLOGY WITNESSES HAVE TO BE READY TO
HANDLE VIRTUALLY EVERYTHING, regardless of the scope of direct exam.
Prepare them accordingly and they will do well and we will win; leave
them unprepared in any of these areas an they will get caught in
something they can't control. Few Scientology witnesses are naturals at
this; some only take a little work, some take days and days. There is no
substitute for going over direct and expected or-even unexpected
cross-exam with the witness and the lawyer until it Is perfect.
The way we handled witness prep was to work up an outline of the
points to be covered in direct exam (as described In another hat
writeup). We would use this in prepping the witness, and the lawyer
would use it in court (the lawyer cannot work from a script, but he needs
the BC of an outline or list of areas to cover); the staff person working
with the lawyer will then also rely on this outline to ensure the direct
exam Is complete.