Books Critical of Scientology Stolen and Destroyed.

"Q. Mr. Scarff, have you now located the two exhibits that you had tried to locate with reference to stealing library records?"

A. Yes, sir, I did.

"Q. Turning your attention to Exhibit-99, what is that? "

A. This is a letter that I sent to Ginnie Cooper, the Director of Libraries for Multnomah County, which is the county where Portland, Oregon rests. And it is concerning an operation in which I was a part of a -- part of which has been a long time policy within the Church of Scientology to eradicate not only from what I have spoken to already on court files but eradicating from library systems throughout the country, any information that is critical or adverse to the Church of Scientology. "And specifically within the library systems within the City of Portland, Oregon, I as well as other individuals within the Church of Scientology just as a matter of policy were ordered to destroy any and all critical materials adverse to the Church of Scientology. And this letter is to the Director of Libraries informing her that all of such books that are on file at the library which have been listed as "lost" are not lost. They had been destroyed. And I list six books there. "Specifically one book refers to -- entitled "A Piece of Blue Sky" by Jon Atack, who is a former high ranking member of the Church of Scientology who wrote an expose on Scientology. "And I recall there were approximately four to five copies of this book in the library all which were listed as lost. And this letter explains to Ms. Cooper, basically, that the Church of Scientology destroys materials on a regular basis which they consider to be adverse, including if she were to check the library's copy of Time Magazine dated May 6th of l991 they will notice that that article had been cut from the magazine because the Church of Scientology considered it to be adverse. "Exhibit-100 is a response to me from this library director in which she did a full inventory of the books that they had and claims that several of the books appear to be out of print now and the library currently has no copies. I refer to one, the book entitled "Inside Scientology" by Robert Kaufman. She said the library has no copies. "No. 2, "The Scandal of Scientology" by Paulette Cooper. She responds the library currently has no copies. "No. 3, "The Hidden Story of Scientology", by Omar Garrison. She responds there are two copies in the library and there are no copies at the central library. And it is out of print. "No. 4, book entitled wL. Ron Hubbard, Messiah or Mad Man" by Bent Corydon. She responds there are supposed to be currently 13 copies in the library. However, seven of these copies are currently listed as lost and there are two copies on order to replace the two copies lost at the central library. "No. 5, book entitled "Bare-Faced Messiah: The True Story of L. Ron Hubbard" by Russell Miller. "She responds there are supposed to be four copies in the county library, two of the four copies are listed as lost. And the book is out of print."No. 6. "A Piece of Blue Sky", she responds there are supposed to be three copies in the county library, two of these three are currently listed as lost. "She refers to the Time magazine article dated May 6th of 1991 and claims that the article is on microfilm and therefore the issue can be found in microfilm, but the print copy is missing. "She also states that she instituted safeguards to protect reordenng these books based upon the letter that I sent her.

"Q. Now, turning your attention to Exhibit-99, the last paragraph on that document, that letter states: 'These missing books were in fact stolen from the library and destroyed in fulfillment of an internal directive by the church which instructs its members to eradicate all published materials critical of Scientology and to replace it with pro-Scientology materials. ' "

A. That's correct.

"Q. How do you know that these missing books were in fact stolen from the library? "

A. Because I was very much a part of the effort to steal the books from the library and destroy them.

"Q. Was anyone else involved in that effort? "

A. Gwen Mayfield was involved. Angie Mann was involved. I know that her husband Charles Mann to have been involved. Like I said, this was an effort that Scientology has long had. I even recall back in '82 that John Carmichael had talked about removing stuff from the library and destroying it. And it was Gwen Mayfield who told me how to remove a book from the library. She showed me that within the binding of a hardback book there is a long, thin, metal strip which sets off an alarm when something like that goes through the sensors in the library and she said all you had to do was take a razor blade, slice along the bindings of the book, pull out the metal strip, rub it into a little ball and flick it away. It takes away the security aspect of this book. It was very easy to get away with it by ripping out the little metal band.

"Q. Gwen Mayfield is part of the --"

A. Gwen Mayfield is an official of the Church of Scientology and director of the Office of Special Affairs whose job in part is to do such activities as I have just described. This would be considered a covert operation. "This is not the first time this has happened although not in a library situation. When Julie Christofferson had her trial

in Portland in 1985 one newspaper by the name of Willemette Week published an expose of the Church of Scientology in which the newspaper later learned that approximately, I think the number was, 10,000 copies of the newspaper had been stolen from different places throughout the city because of the desire from the Church or officials of the church not to have any of the readership within the general public to have access to these newspapers. "And it is my understanding that the newspaper later sued the church and the church chose to end and settle the case.

"Q. How do you know about that activity? "

A. It was common knowledge within the church. It was common knowledge in the church at the time because I was involved in one other operation with John Carmichael at that time against Julie Christofferson and you have to understand that within the OSA and any time

someone succeeds in pulling off a covert operation, people don't sit around a table and talk seriously about what just happened. It is a celebrative occasion. It is like somebody needs to pull out the wine and cheese and we Will all celebrate because everyone was laughing and John Carmichael thought it was quite comical that people would try to look for a copy of the Willemette Week and there would be none found anywhere within the city.

"Q. Were you involved in the removal of those newspapers? "

A . Yes.

"Q. In what manner were you involved? "

A. I would go to 7-Elevens where at that time I believe they were being sold for like a buck apiece. And I would grab a whole stash of them and I would walk out of the store with them and destroy them.

"Q. And what was the purpose of doing that? "

A. To get them out of the store so no one could see them.

"Q. Why didn't you want anyone to see them? "

A. Because there was information in there, although not confidential, but it was critical of the Church of Scientology. And anything that is critical of the Church of Scientology does not deserve to be in the public. The Church of Scientology takes a very strong stand on constitutional rights, but they believe that constitutional rights only apply to them and nobody else. And it is okay to have positive information about Scientology out there, but if anyone dares to publish anything critical, then it has to be eradicated. It can't be seen. "And in response to the library operations, you can go into the libraries where these books have been stolen and you will notice a whole slew of pro-Scientology books that have been donated to the library. The Multnomah County Library has scores of Scientology courses that are offered on a correspondence course level that

are in the libraries listed as donations, but anything critical has been eradicated." (Deposition of Garry L. Scarff, at p. 333, in. 1 - p. 340, in. 24.)

Operations Against Richard Behar Descibed; Scarff Involved in Financial Scams for CSI; Scarff Directed to Murder Cynthia Kisser of CAN. and Move to Brazil Afterwards.

"Q. Were you subsequently involved with the Office of Special Affairs subsequent to May of 1991? "

A. I was not involved directly with the Special Affairs office until October of '91.

"Q. After your involvement with the Office of Special Affairs commenced, did you ever hear any reference made within the Scientology organization to the Time magazine article of May 1991? "

A. Plenty. Plenty of conversations regarding that. And how they were going to strike at Richard Behar.

"Q. How did the Scientology organization view the Time magazine article of May 6th, 1991? "

A. Very, very critically. I think hostile would be a better word for it. And with a desire to wreak revenge on the individuals that cooperated in that article and the comments that I heard is that "We are not going to seek justice against Mr. Beher. We are going to destroy Mr. Behar. He is going to wish to God he never published that article in the first place. "I think it is why Bowles & Moxon paid Mr. Ingram so much money to travel to New York to try to find some means with which to incriminate Mr. Behar to destroy his credibility.

"Q. Now, do you recall any such conversations as you have just mentioned to me? Any specific conversations with any specific members of the Scientology organization? "

A. Well, yes. I mean on a general level with members of the church just as they do as a matter of policy within the church, they deny anything that is critical towards the church so there was a lot of denial going on and of course if anyone was to walk up to a Scientologist and ask him about the article they would deny to the teeth that anything in that article was true and it was all made up and it was all biased and that the individuals mentioned in the article including your client Steve Fishman is a liar and he is a criminal and all you have to do is

look at their past and you know that they can't be accepted for any type of credibility. "On a general level it was just a bold-face lie created to damage by the Church of Scientology which they alone would like you to believe has all the credibility in the world to speak of.

"Q. Just to correct something you said, I represent Dr. Geertz in this case, not Mr. Fishman. "

A. I am sorry.

"Q. Do you recall --"

A. May I ask one question? On several documents you list Steve Fishman in this case. If you do not represent him why is his name listed on some of the documents which have been entered as exhibits?

"Q. He is a defendant in this case. And we cc him on documents. He is entitled to be cc'd. "

A. I don't understand lawyers, I guess. I don't understand what you lawyers do for a living.

"Q. Do you recall conversations regarding the

Time magazine article with any specific member of the Office of Special Affairs? t

A. Almost definitely. David Butterworth.

"Q. When did that conversation occur, roughly? "

A. This roughly occurred in November of 1991 at the Oklahoma City Hotel, the Sheraton


Hotel where we were staying at during the CAN disruption campaign.

"Q. Do you recall what Mr. Butterworth said to you dunng that conversation about the Time magazine article? "

A. I had brought it up to him and asked him how much of it was true because a lot had been said particularly with regards to an individual interviewed in the article referring to someone in the church having access to a certain poison that could be used to kill s

omebody. He said it was all bluff. There was no truth in it. And there was no substantiation to back it up and it was just -- Scientology was being targeted and that it was also a conspiracy by the Cult Awareness Network to destroy the Church of Scientology that it perceives to be a cult.

"Q. Are you aware that this litigation arises out of statements made in court proceedings by Mr. Fishman and my client, Dr. Geertz, which were subsequently confirmed by them to Richard Behar and published in Time magazine? "

A. The only thing that I know about this case is I thought you were representing Steve Fishman in the case and I recall Steve Fishman and Mr. Geertz being referred to in the article, but as far as the specifics of the case, I don't know what is going on.

"Q. Do you recall any reference being made to either Steven Fishman or Dr. Geertz in any of the conversations regarding the Time magazine article? "

A. I recall speaking specifically in the November meeting with -- not Eugene but David Butterworth about Steve Fishman and he said that Steve Fishman was a criminal and that he had done all these things on his own because Steve was trying to blame the Church of Scientology for what happened to him and for all his problems. "And Butterworth simply denied that the church had any type of conspiracy with Fishman in this incident. That Fishman was a bad apple and that he had committed these crimes and he was trying to blame the Church of Scientology for them and also that the FBI had cleared the Church of Scientology from any type of role in what Fishman was claiming to be the truth.

"Q. Was anything said at all about -- withdrawn. Was anything said in that conversation about Fishman having been a member of the Church of Scientology? "

A. Oh, David Butterworth admitted that he was once a member of the Church of Scientology but he had not achieved the state of clear and that he was simply someone taking introductory courses for the church.

"Q. Was any indication given as to when Mr. Fishman was a member of Scientology? "

A. No. And I didn't ask him.

"Q. You recall any other conversations with members of the Church of Scientology regarding the Time magazine article of May 6th, 1991? "

A. I have talked with Aaron Mayson about it. And I have talked to Eugene about it. And Eugene's position when I spoke with him, and again I can't recall specifics other than Mr. Ingram just said it was all baloney, that none of it was true, and that the side bar that was done on him was done without his cooperation and that he knows for a fact that all the data that was inside that article was just trumped up by the Cult Awareness Network and people associated with it along with law enforcement agencies that have -- that want the Church of Scientology to be eliminated. And that's just one big conspiracy.


; "But Mr. Ingram's position on that whenever I asked him about specifics in that article was [ that it was not true. 'I am an investigator. Trust me. It is all baloney. None of it is true. It l is all trumped up and there is no evidence to support any of the allegations in this article.' l

"Q. Have you read the Time magazine article dated May 6, l991? l "

A. I read it, yes. l

"Q. On the basis of your experience with the Church of Scientology do you have any comment l to make with regard to the truth or falsity of the statements made in that article? "

A. It is based upon my experience that the statements of that article is probably true and that l Richard Behar did an incredibly damn good job of reporting the facts in that article. In fact Eugene Ingram told me at one time if I wanted to kill somebody with cyanide that he could easily access it through a member in the church who worked in a chemical Company in Florida that had access to sodium chloride. "And I recall speaking with someone regarding this, and I don't remember if it was you or someone else that I had spoken with, but that confirmed something that was published in the Time magazine article regarding someone in the church that had access to cyanide. I don't remember that being in the article. But Eugene himself told me that he could get cyanide should we ever want to place it in someone's coffee or something. "In fact this was one of the discussions we had for disrupting the CAN conference in 1992 was to gain access to the large industrial coffeepots that hotels leave out for people at these conferences and to lace those coffeepots with sodium chloride for the purpose of making people dangerously ill which would be an effective disruption of the conference. "And that really hit me like a ton of bricks when I went back to the article to reread it and I realized that in what Mr. Ingram told me and what I was reading in the article, there seemed to be a strong connection there. "And the statements that Mr. Fishman had made and the statements that Mr. Geertz made; I don't know them personally, but I would vouch for what they are saying to be 99.9 percent the truth simply based upon my own experiences. "All you have to do is look at the history of the Church of Scientology. All you have

to do is look at all the documented facts, documented evidence we have here against Bowles, & Moxon and the Church of Scientology,

and you know there can be no doubt that the Church of Scientology is a criminal organization, in and out, and that the officials and lawyers within the Church of Scientology, and I speak of Tim Bowles, Mr. Weiner, all the attorneys that are working at Bowles & Moxon are part and parcel to this criminal organization and they all belong behind prison bars.

"Q. Nowl with regard to or. Geertz and Steven Fishman, the Time magazine article refers to allegations that Steven Fishman was convicted of being engaged in mail fraud forging activity involving a financial scam. "Have you been involved in financial scams that have been committed on behalf of or at the instructions of the Church of Scientology? "

A. Yes.

"Q. And very briefly because we will get into that later in today's deposition and later tomorrow, what were those types of financial scams that you were involved in on behalf of the church? "

A. I am speaking of one operation where I may have d

efrauded the government with student

loans and misrepresented myself as needing these funds to pay for college tuition, which they were initially geared for, but later turning this money over to the Church of Scientology. "I taught another member within the church how to defraud the government by preparing the documents necessary for getting student financial aid and getting Pell grants, money which could be used for the financial benefit of the Church of Scientology. "And then there is a financial scam that I was involved in with the personal knowledge of Tim Bowles which I am going to plead the Fifth on.

"Q. Is it your understanding that what was done in the course of that financial scam you have just mentioned, is it your understanding that that conduct would be a felony? "

A. I know for a fact that it could constitute a felony.

"Q. And was that conduct done within the last 12 months or so on behalf of the Church of Scientology? "

A. It was done within the last 12 months on behalf of Scientology at the personal directive of Mr. Bowles and Mr. Butterworth with the knowledge of Mr. Ingram.

"Q. And on the basis for your Fifth Amendment rights you don't wish to make any further statement about those activities? "

A. I will not.

"Q. Now, we will return to some of the things you just told me about, financial scams later as a result of this list of yours. "Now, Dr. Geertz and Steven Fishman also claimed at the sentencing hearing of Steven Fishman that the church had ordered Steven Fishman to murder Dr. Geertz and then commit EOC or "end of cycle." We are going to deal at length I think later today with those activities, but for the moment in relation to the Time magazine article, do you have any personal knowledge of conspiracies to murder and suicide with regard to the Church of S c ien to log y? "

A. Yes, I do.

"Q. And what is that personal knowledge briefly? As I say, we will get into it later. "

A. Through a -- through several conversations by phone, also in a personal meeting in November of 1991 and in a meeting in December of '91 at the Church of Scientology Saint Hill organization building, where the Office of Special Affairs and Bowles & Moxon is actually located, I was directed, one, to go to Chicago, Illinois and to murder Cynthia Kisser, Cynthia Kisser being the Executive Director of the Cult Awareness Network, by a staged car accident. "The suggested method was cutting her brake lines but it was later talked about that because Cynthia Kisser drives a Ford Bronco that it might not be possible to cut a brake line, so therefore, I could release brake fluid and tamper with the vehicle in such a way that it would render it out of control at which time I would be in a vehicle behind it. I would run her off the road, hopefully running her into a ditch or into a tree. And then making sure she did not survive the accident. "So the suggested ways of following up was to take a pillow and smothering her to death. Another method was dragging her out of the vehicle and drowning her. It was also discussed including her young daughter and killing her in the accident.

"Q. Mr. Scarff, Are you okay to continue? "

A. I didn't know she had a young daughter at the time.

"Q. Would you like to take a break.

"BY MR. BERRY: "Q. Mr. Scarff, you feel able to continue now? "

A. Yes.

"Q I realize this is very emotional for you. "

A. Yes.

"Q. Was what you called the conspiracy that you have just testified to the result of conversations with other people? "

A. Yes.

"Q. Can you tell me who was involved in those other conversations? "

A. It was specifically David Butterworth, Eugene Ingram and myself initially.

"Q. And where did that -- was there one conversation or more than one conversation? "

A. There was more than one conversation. The specifics of this conversation, I was told initially from David Butterworth was something very important that they wanted me to do but he could not talk about it. And it occurred very late at night following a disruption operation we had attempted to perform at the Jewish Federation Center on Wilshire Boulevard in Los Angeles where Patricia Ryan and Patricia Coates of the Cult Awareness Network were holding a Jonestown commemorative ceremony.

"Q. When did this conversation occur, roughly? "

A. Roughly after 12:30 in the morning so it would have been actually the next morning of Sunday, early morning when it occurred. nQ Sunday when? "

A. November, I believe it was 17th, which is the actual date of the Jonestown tragedy anniversary.

"Q. And then who was present at that conversation? "

A. Eugene Ingram , David Butterworth and some other people that I don't know, I didn't even know who they were, but Ingram told me that they were both from the Legal Office and they worked in the OSA.

"{Q. And by Legal Office what do you mean? "

A. There is -- they weren't individuals that I know now to have been with Bowlers & Moxon, but down on the floor where the OSA exists, there is an office adjoining the War Room which they refer to as the Legal Office. And persons in that Legal Office is Linda Sarkovich and a woman by the name of Teri whose last name I don't recall, but she was always in a Sea Org. dress blues unifomm when I spoke with her.

"Q. What is a Sea Org. uniform? "

A. The Sea Org. uniform is a pseudo-Naval uniform worn when you are a member of the Sea Org. which is a primary branch of the Church of Scientology, at least they would like you to believe is a branch, but is actually I believe in control of the Church of Scientology International. "L. Ron Hubbard always fancied himself to have been a naval hero in the U.S. Navy and a hero during World War II and his entire biography is all self-created and a pack of lies because he lacked any credibility as far as having a heroic history within the military. He created this spectacular autobiography that he was a Navy hero.

"And it seemed that the psychosis that had developed from his creations resulted in a number of activities on his part to create his own Navy within the Church of Scientology by just buying loads and loads of boats and referring it them to as his own Navy fleet. "Today, there is a yacht where high-level courses are taken called the Freewinds, which is part of the Sea Organization. And as part of that fancy that L. Ron had for the U.S. Navy, members of the Sea Organization wear psuedo-naval uniforms. If you go down to the Hollywood area of Los Angeles, people often see members both men and women wearing white uniforms that look like they are naval personnel when in fact they are Sea Org. members. On ceremonies they will wear the Navy blues with the colorful braids which signify different things within the sea organization. But it is all part and parcel to L. Ron Hubbard's fancy being a naval hero and the Church of Scientology having some relationship with a psuedo- naval military force.

"Q. Now, at this early Sunday morning meeting on or about November 17, 1991, which I think is when you testified it occurred --"

A. It occurred very late at night and it was after midnight so that's why I said Sunday morning versus Saturday night as previously stated on the record.

"Q. What was said at that meeting by whom? "

A. First David Butterworth recalled my meeting with him. Just prior to that it was like two and a half weeks prior to that when I first met him at the Cult Awareness Network conference in Oklahoma City and he recalled our conversation where I asked him if I was doing all I could to meet their conditions of amending my past where I was not obedient and where I had cursed the Church of Scientology and where I had made up lies to hurt the Church of Scientology when I was angry at the world and he said there was one more thing that they wanted to do. And it was something that would ultimately bring down the Cult Awareness Network. "They said that up to that point that everything they had tried to do was not successful and that they wanted to get rid of Cynthia Kisser once and for all because she was the whole reason that the Cult Awareness Network existed. She was the wglueW that held it together and if they could get rid of Cynthia Kisser once and for all that there would be no one there competent enough to replace her. wAnd it was Eugene Ingram that said that Priscilla Coates might step in but that the "old broad" was "not intelligent enough or didn't have enough time on her hands or something to that effect that she would be able to walk in and take over for Cynthia Kisser. "So in order to destroy the Cult Awareness Network all we had to do was destroy Cynthia Kisser. And I assumed when he said this that he meant simply attacking her credibility as they have done in the past but doing it with much more vigor than they have done so in the past.

"Q. What else was said at that conversation, at that meeting? "

A. Only that they talked to me about the specific operation where, if I performed this operation that if L. Ron was still alive he would be honored to have me at his side and that Mr. Ingram informed me that David Miscavige was personally aware of this operation and considered it an honorable role on my behalf, would welcome me with open arms if I was to perform this operation, and then we got into the specifics of what they wanted me to do. wQ. And were the specifics what you testified about with regard to Cynthia Kisser just before the break -- let me withdraw the question. | "What were the specifics of the operation very briefly? [ "

A. The specifics of the operation was for me to fly to Chicago O'Hare Airport, rent a vehicle | with the information provided to me by the Office of Special Affairs in Los Angeles and the [ OSA in Chicago particularly with the tools provided to me by Randy Kretchmar, who is an | official of the OSA in Chicago, to follow Cynthia Kisser home, run her off the road and take [ all steps necessary to render Cynthia Kisser dead. | "It was also discussed for a greater impact in these events that if someone within the Cult | Awareness Network got smart enough to replace Cynthia with someone else, and that if Cynthia Kisser had her daughter with her, it would be an added benefit to kill Cynthia Kisser | and to kill her daughter as well, because when a child dies it carries a greater impact in the ; minds of the public than if simply an adult dies, and that would send a message to the Cult }Awareness Network that it was time to end their hatred toward whom they perceived to be }cults. nQ Now, was Gene Ingraun present at that meeting? "

A. He was present, yes.

"Q. did he say anything at that meeting? | "

A. Yes, he did. He told me that there was absolutely no way that I could be held l accountable if I -- there is no way I could be caught -- first of all, that immediately after I did l it I was to fly back to Los Angeles and that Mr. Ingram would be responsible for putting me l into to a safe house and if need be, he could ferret me out of the country to Brazil or Mexico l City or one of the other places that they have established safe houses at. And that they would l keep me there until the steam blew off or until Bowles & Moxon was successful enough in l impeding any type of legal investigation towards me and that I would be held not accountable l for these crimes, and it was specifically discussed that they would put me into hiding and that l any type of criminal investigation that was pending towards me, any type of legal investigation l that may have started as a result of this murder, that Bonvles & Moxon would step in and l throw so many legal maneuvers at the courts that there is no way that I would be eventually l prosecuted for this crime. And Eugene laughed and said that --he said, 'Trust me. I mean the court dockets are so overloaded right now, if Bowles & Moxon was to throw all these legal maneuvers at the courts there do be absolutely no way that prosecutors would find the time to want to prosecute you for something like this. ' "And then we got into discussions that -- what would happen if the authorities did charge me with a crime, if there was the possibility of them catching up to me and if what he said was going to happen as security precautions did not work, that's when he mentioned that I could TKO.

"Q. And what is TKO? "

A. I didn't know if it was a Scientology phrase or it is something that Eugene Ingram used in law enforcement. Is it a law enforcement term? I don't know. But he told me that TKO was -- and he showed me with his hand. It is not something that he just told me.

"Q. What did you take him to mean by this? "

A. I asked him and he said that I could just end my life and that all it takes is a gun shot in the mouth. And -- I mean he was very specific in telling me that unlike what you see on

television where people simply stick the barrel into the mouth and pull the trigger, that l sometimes people will not die as a result of that because you have to sever your spinal cord l when you shoot into your mouth to kill yourself. So he suggested sticking it up towards the l gums so it blows my brains out. Therefore, my brain would not -- he got into technical side of l suicide, and the fact that if you blow your brains out you may not die right away but at least l your brain ceases to function and you don't have pain. He says it is a very quick, easy way to end your life.

"Q. You mentioned earlier that someone had said that L. Ron Hubbard would be pleased to have you at his side. Did you have any understanding of what was meant by that statement? "

A. Yes, I did.

"Q. What was that understanding? "

A. Because between October when I first met Eugene Ingramn after meeting David Butterworth where I had an immediate affinity for Mr. Butterworth, mentally I wanted to do everything that I could to please these people. I wanted to be accepted. I knew that my past was spotty and that there was a lot of things in the past that would render me impeachable in the eyes of many people and here I was wanting to prove myself that I could be trusted to do something correctly. And I wanted these people's affection and I wanted these people's respect. And I really trusted -- I really felt very strongly and had a high regard for Mr. Butterworth and he treated me with a lot of respect. I wanted to please him. And I wanted to do what was necessary to be considered in good standing with the church.

"Q. And Mr. Butterworth, what was his position in the church? "

A. He is the Director of the Office of Special Affairs. He is the one in charge of the covert and overt operations of the church throughout the IJ.S. and making sure they are being carried out.

"Q. Now, was L. Ron Hubbard alive at the time of this conversation as far as you are aware7 "

A. No. He dropped his body in '86.

"Q. How would you be able then to be at the side of L. Ron Hubbard? "

A. What he said is if L. Ron Hubbard was alive that he would be honored to have me at his side.

"Q. Now, I think you said that there was some discussion with Mr. Ingram as to how he could hide you after killing Cynthia Kisser? "

A. Yes. He said, like I said before, he said he had relatives in Brazil. He could get me to Brazil. I told him that I didn't have a passport because the only places that I have been out of the country was Mexico and Canada and they didn't require passports. He said he could provide me a passport. I wouldn't even have to go down to the Post Office and apply for it. That he could give me one right away. "And he also said that he had a son in Colorado going to college and that there were places in around the Denver & Boulder, Colorado areas which could be used as safe houses where they could hide me.t (Deposition of Garry L. Scarff, at p. 34_, In. 4 - p. 365, in. 9.)

Description Given of How CSI Members Hide Out While Fleeing Prosecution.


"MR. BERRY: Now, I want you to turn to what will be marked as Exhibit-110 in your folder.

(Defendant's Exhibit-No. 110 was marked for identification and is bound separately.) "BY MR. BERRY: n Q. What is Exhibit-110 very briefly? "

A. This is a top secret naerno. If you notice at the top it says, "DD," which means Dissemination Division. It is a division within the Church of Scientology which disseminates materials to their appropriate departments. "Underneath DD it says, 'Eyes Only' which I have already testified to on record means very highly confidential document within

the Church of Scientology. Underneath 'Eyes Only' it says 'Top Secret.' NQ. Also to the right of wDO" it has something else written? w

A. It looks like "Duke, here is plan to discuss. Love Bryce."

"Q. Now, is "love" a phrase that would be used within the Church of Scientology? "

A. Yes. I mean when you are tanking about -- well, it is like any other --

"Q. Now, above the word "Duke" there is what appears to be G/US and then a line. What does that mean7 "

A. I don't know what slash G means. Usually when you have Dissemination Division slash somebody, it is referring to somebody within the organization. "For example, when I testified on record, OSA/GM, meant someone within the OSA division was in charge of receiving this document. "But the specific document refers to hiding people out. It is an internal Scientology document which explains how the staff within Scientology can be effective in hiding someone out that's fleeing prosecution. If you notice the fourth line of the first paragraph states: 'This must be done in such a way so that they never can be accused of, "fleeing prosecution."' NQ. And in relation to your conversation with Gene Ingram that we have just been talking about, does this document have any significance? A. Yes. It is very related to what Mr. Ingram explained to me was an internal policy which allowed for hiding out individuals in the church that were fleeing official prosecution.

Q. And would --"

A. This substantiates everything that Ingram told me and thus far up until now the Church of Scientology has denied that any of -- that I have no credibility when I talk about stuff like this, but this document substantiates it. This is an internal Scientology document that talks about hiding people from prosecution. So I don't know why they can call me a liar when I talk about things like this occurring within the church. It just makes no sense. It has been documented." (Deposition of Garry L. Scarff, at p. 365, in. 10 - p. 367. In. 22.)

Murder Conspiracy Directed Against Ford Greene, an Attorney Who Represented Me

"Q. We are going to come back later in the deposition to the conspiracy to murder Cynthia Kisser. "But you mentioned there was another murder conspiracy as well. What was that one? "

A. In December there was a desire in the OSA to end the life of Ford Greene.

"Q. Who is Ford Greene? "

A. Ford Greene is an attorney who is also a former member of the Unification Church or what people refer to as the Moonies and he had represented former Scientologists in litigation involving the Church of Scientology.

"Q Would he be opposing counsel to Scientology lawyers? "

A. That's correct. And thus became a target of the Fair Game doctrine by the church.

"Q. Now, how did this concern regarding Ford Greene come about? "

A. One--

"Q. Was there a meeting? "

A. Yes, there was a meeting at Bowles & Moxon.

"Q. When did this meeting take place? "

A. I recall it being around December 20th and it was on a Saturday morning because I flew in on a Friday and we met on Saturday morning in the offices of Bobbies & Moxon -- within the Saint Hill organization building in Los Angeles.

"Q. What is the Saint Hill organization building? "

A. It is one of the Scientology buildings on Berendo Street. It is where people come in off the street to learn more about the church and its courses.

"Q. And--"

A. And it is one of several Scientology controlled buildings in the area, but it houses the offices of -- the Office of Special Affairs and it also houses Bowvles & Moxon although they deliberately misrepresent themselves on their stationery as being located several blocks down on Sunset Boulevard." (Deposition of Garry L. Scarff, at p. 368, in. 23 - p. 369, in. 15.)

Bowles & Moxon Part of CSI, Its Offices Located Directly Above Office of Special Affiars

"Q. Let's turn to Exhibit-103 for a second, which is in that binder. It is a document which appears to be a Bowles & Moxon letter. "

A. Yes.

"Q, What address is given on that letter? "

A. The address given on this letter is 6255 Sunset Boulevard, Suite 2000, Hollywood, Californi

A. It is the same address which has been on their stationery, as far as I can remember. wQ, Isn't that their address? "

A. No. They own -- it is my understanding they own the building and there are conference rooms in that building that they use for legal proceedings, but, no, this is not their actual offices. It acts as a maildrop. Bowles & Moxon deliberately misrepresents itself as simply a law firm that represents among its many clients the Church of Scientology. That is a deliberate lie. They know it. I know it. And it has been established in court record as a lie. "Their actual offices are on 1401 Berendo Street in the old Cedars of Lebanon Hospital building in Hollywood, Californi

A. And their offices are directly above the Office of Special Affairs which is why there is so much contact between the Office of Special Affairs and Bowles & Moxon because they

are within one floor of one another. Tim Bowles also wroks for the OSA.

"Q. Before we turn to Exhibit-21, there is a phone number under the address up there. Have you ever telephoned Bowles & Moxon before? A. Yes, I have.

"Q. Have you used that number or another number? "

A. No, this number has been changed and the fax number

has also been changed. If you look at the document that was filed with my name on it dated October of '91 -- I forgot what exhibit that was -- it is where Eugene Ingram claims that they are doing a lawful background investigation on the Cult Awareness Network. You will notice that the telephone number is different. You will notice that the fax number is different. "Also in the numerous telephone bills where I have called Bonvles & Moxon in the past you will notice that the numbers are different.

"Q. Let's take a moment to find the letter that --

here we are. Exhibit-30. "

A. You will notice that on Exhibit-30 the phone number has a 661 prefix. The fax number has a 662 prefix. Whereas on this Exhibit-103 it has a 953 prefix on both. They have changed their phone numbers.

"Q. And do you recall what the phone number of the Office of Special Affairs is? "

A. I don't recall it by memory, however, have filed as an exhibit a document called "Personal Contacts" where I have listed all my Scientology contacts I had during the years 1991 to 1992. And it lists those numbers for Bowles & Moxon. And I will search for that exhibit. n Q . Exhibit-24. "

A. If you look at No. 3, Bowles & Moxon law firm and I put in parentheses Inside Saint

Hill Org. on Catalina Street. "And to the right it says 213 and then has the 661 and 662 prefixes.

"Q. And about the phone number for the Church of Scientology Office of Special Affairs? "

A. They have a 661 and a 666 prefix.

"Q. And if you were to dial the phone number on your list for Bowles & Moxon now, what would happen? "

A. It would probably be a disconnected number.

"Q. Why don't you try it. And perhaps if you do it over here the camera can see you do it. "

A. If by doing that I can't carry this with me.

"Q. That's okay. "

A. Just dial 9?

"Q. Just dial 9 to get out and dial what it says to be the number for Bowles & Moxon,: 661-4030. "

A. On the telephone: "I am sorry, thank you very much."

Mr. Berry, it wasn't a disconnected number. A woman answered "Bowles & Moxon."

"Q. Let's go back to the deposition table. Now, referring again -- sorry, Mr. Scarff, what telephone number did you just dial? "

A. I dialed 661-4030. A woman answered the phone as announced it as the office of Bowles & Moxon.

"Q. And is that the same telephone number that is on your list of personal contacts under Item 3, Exhibit-24? "

A. It is the number listed in Exhibit-24." (Deposition of Garry L. Scarff, at p. 369, in. 16 -p. 373, in. 13.)

Bowles & Moxoll Office Inside CSl Building.

"Q. And what was your testimony about the location of the Office of Special Affairs and Bowles & Moxon? t

A. When you go into the Saint Hill Organization building -- and I was incorrect on Exhibit-24. I put there on Catalina Street. It is actually on Berendo Street. Catalina Street is the street parallel to that going I would say North to South. Anyway the buildings are bounded by Berendo, Catalina, Sunset and Fountain Streets. "If you go up two flights of stairs, and we are not talking about the cafeteria that is on the bottom level, but you go up two flights of stairs you come into the Office of Special Affairs and various classrooms. You go to the office above it is Bowles & Moxon. And they can't really deny that because if you go there you will see on the doors in big block letters Office of Special Affairsw and then going up one floor you will see in big block letters wBowl~ & Moxon" right on the door." (Deposition of Garry L. Scarff, at p. 373, in. 19 - p. 374, in. 13.)

Timothe Bowles a Member of CSI, Office of Special Affairs.

"Q. Now, turning your attention to Exhibit-No. 21 which has

been previously identified and entered into -- marked for identification, on Page 3 of that exhibit, Internal No. 33, do you recognize the photograph of a man in that picture? "

A. Yes, I do. That's Timothy Bowles.

"Q. Is there anything in that document about Timothy Bowles? "

A. Yes, there is. It is an article talking about Timothy Bowles, him becoming a patron of the International Association of Scientologists and Mr. Bowles states -- it states in the article that Timothy Bowles is an attorney for the Church of Scientology and works in the Office of Special Affairs, OSA. "When I read this article I was quite surprised because Timothy Bowles has always said on record that he is not a part of the OSA and he is with Bowlers & Moxon and they are two separate entities.

"Q. Why don't we read the rest of the article into the record. "

A. The entire article? nQ. Yes. "

A. 'Timothy Bowles is an attorney for the Church of Scientology and works in the Office of Special Affairs (OSA). He is new OTIV and a Hubbard Standard Dianetics auditor and executive status I. He has been a lawyer for ten years and is now a patron of the association. 'The association vitally needs and deserves the increased support of every Scientologist worldwide. 'I have represented the Churches of Scientology in defense of our religious liberty in America since 1978. I now work full time in this fight with the United States Office of Special Affairs. 'Following graduation from a California law school in 1977 my wife Rona and I moved to Oregon to work on staff at the Delphian School. A year later I was asked to help on the defense of a lawsuit brought against various Scientology churches in Portland, Oregon. 'The case seemed insignificant at the time as it was not conceivable that the Church of Scientology would not be given the protection provided all religions by the First Amendment of the constitution of the United States. Instead the judge in that case ignored clear First Amendment principles and in the summer of 1979 presided over a full-blown hearsay trial. 'That judge's errors were eventually corrected by an appeal to a senior judge in a higher court. Since then the fight for our religious freedom has of course continued on many different fronts. Through all of these more recent battles the association has been there as an indispensable force of reason and protection of our religious faith. 'I have recently become a patron because I feel that no matter the level of current contribution one can and should always do more to assure that spiritual freedom is preserved and expanded for all of mankind. HMankind" capitalized. L. Ron Hubbard set that standard throughout his life. I believe that this is an example of caring and contribution that all of us can only hope to equal, never surpass. For me being a patron is one very significant step along that road. 'Legal wins feel great. We at OSA intend to make that a habit. Ensuring the future of our religion through contribution to the association above the call of duty feels just as wonderful.'" (Deposition of Garry L. Scarff, at p. 374, in. 14 - p. 378, in. T7.)



End of Part 1&2 more to follow soon...

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