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litigation tactic employed by Scientology.
29. During other-litigation in Los Angeles known to me as the
Wollersheim case, I was told that the judge had ordered the
production of Wollersheim's folders. As ordered, I "culled" these
files. In other words, I removed contents that might have been
damaging to Scientology or might have supported Wollersheim's
claims against Scientology. For example, I removed evidence of
events involving his family, the anguish this caused him,
evidence of disconnection from family and evidence of fair game.
30. I was involved in numerous meetings concerning what is known
to me as the Christofferson case in Portland, Oregon. This case
was tried twice. In the first case, a Scientology witness by the
name of Martin Samuels was coached and drilled for hours on how
to lie convincingly or avoid telling the truth. Before or during
the second trial, he admitted to this course of conduct. In this
litigation, a Scientologist by the name of Joan Shriver produced
responsive documents that may have been incriminating. This was a
serious breach of policy for which she was punished. These
documents were ordered produced on such a short notice that
apparently files were not thoroughly "culled". In another case,
an attorney was severely criticized and almost fired for failing
to properly coach and feed the desired answers to Heber Jentzsch.
Mr. Jentzsch was, for public relations reasons, the purported
head of the Church of Scientology International. During his
deposition, Mr. Jentzsch was unable to answer fundamental
questions concerning the management of Church of Scientology
International.
31. While involved in Scientology I became aware of various
operations directed against an author who had written a negative
book about Scientology. The author, Paulette Cooper, was
subjected to various forms of harassment. One operation included
an attempt to frame her. A false bomb threat was written on her
stationery. Ms. Cooper was subjected to an investigation and was
not cleared until an FBI raid resulted in the seizure of
Scientology documents that exposed the operation as a frame-up.
There was at least one other operation directed against Ms.
Cooper. The substance of it was to plant a boyfriend to reinforce
and play upon her suicidal tendencies in the hopes that she would
commit suicide.
32. In 1976 and 1977, the then Mayor of Clearwater, Florida, Gabe
Cazares, was involved with litigation against Scientology.
Arrangements were made to have an attorney by the name of Merrit
Vanniere, a Scientologist, represent Mr. Cazares and sabotage his
case. This plot was also exposed by documents obtained in an FBI
raid of a Scientology facility. Also, in response to Mr. Cazares'
litigation against Scientology, an attempt was made to implicate
Mr. Cazares in a staged hit and run accident.
33. In later 1979 and early 1980, there was a massive document
destruction program undertaken to destroy any evidence showing
that L. Ron Hubbard ("LRH") controlled Scientology. I
participated in this activity in Clearwater, Florida and am
informed that there was also intensive document destruction at
facilities in Gilman Hot Springs, California. From at least that
point onward there was a continuous effort to hide or destroy any
evidence of Hubbard's control. For example, during an IRS
investigation in 1984 and 1985, while in bed with pneumonia, I
was ordered out of bed by Norman Starkey, who told me that they
had received a tip from a Los Angeles police officer advising
them of a pending IRS raid in Los Angeles.
Mr. Starkey ordered me to go to a computer facility and insure
that all information on the computers in Los Angeles that might
show Hubbard's involvement and control of Scientology's money was
destroyed except for one copy of each document. These copies were
to be saved on computer disks which were to be hidden in secure
storage places. At the time I was also instructed to destroy
anything that would show the control of Mr. Starkey or Mr.
Miscavige over Scientology.
SCIENTOLOGY INFILTRATES THE U.S. GOVERNMENT
34. In or about 1981, while working in a Scientology organization
known as the Guardian's Office, I had access to and observed
various written and oral communication pertaining to illegitimate
activities participated in by the Guardian's Office. The
Guardian's Office attempted to infiltrate both governmental and
private agencies including the IRS, the Department of Justice,
the American Medical Association and the National Institute of
Mental Health. The purpose of this was to steal documents
pursuant to Hubbard's "Snow White" program. The goal of this
program was to eliminate any negative reports about Hubbard and
Scientology that may have been held by these various agencies.
FISHMAN ALLEGATIONS ARE CREDIBLE
35. I have examined certain documents regarding Steven Fishman's