SCI
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Since every Scientology witness must be prepared for cross on a
multitude of areas, we used a checklist as a tool for this. It was
rather like assessing a list with a PC. We had an overall list of areas
To cover. These are some examples:
Corporate vs ecclesiastical
Nature of Policy
Is DEC Religious?
Relationship of Flag to S0
What was 0TC?
Ever asked to backdate a document?
Flag's relationship to CSC
Fair Game
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We would run down that list with each witness asking a question or
two about the item to see how the witness would handle; perhaps he knew
nothing about corporations or OTC or Flag. When we would hit a "hot"
area (where the witness appeared to have knowledge and could be
questioned but gave an unfavorable answer or otherwise showed he didn't
duplicate the implications of cross-exam In that area), we would take it
up at length, Practicing cross and hatting the witness on the concepts
(e.g. OEC as religious) until he was stable and confident. Once through
the entire list (this might take days), that witness was ready to testify
and only needed brushup on direct and cross on the day before going on
the stand.
The purpose Of going over direct and anticipated cross is not to
inculcate "Pat" answers or robotism, but to nurture understanding and the
ability to handle the cross-exam questions. It goes without saying that
you also have to have a lawyer who (1) Is very experienced at trial work,
And 2) has a very thorough working knowledge of Scientology. For an
experienced lawyer who doesn't really understand Scientology, It will be
unreal to him that every witness has to be able to defend himself in
every area. He will think that he can effectively use the "Rules" (of
Evidence) to prevent improper cross-exam. He could be in for a very
unpleasant surprise about that at trial. There is no other animal on the
face of the Earth like a Scientology trial and he'll have to know
It--or we get another Christo case.
That's It.
DD/GUS
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