(Scarff affidavit continued) part 3

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Moxon Involved in Operation Snow White and Conspiracy to Murder Cynthia Kisser and Ford Greene.

 

"Q. Now, there is the word "Moxon" in the word Bowles & Moxon. Do you know who Moxon refers to?

"A. Yes. That refers to attorney Kendrick Moxon.

"Q. And have you met attorney Kendrick Moxon?

A. Yes, I have.

"Q. And during the worst of your meetings with Kendrick Moxon, have you obtained any understanding as to part of his background? "

A. Yes, I have.

"Q. And what is that understanding you have as to earlier significant events in his background? "

A. In both conversations with Mr. Moxon himself, he seems pretty proud of the fact, and in conversations with Eugene Ingram, David Butterworth and Sue Taylor, who is the Director of Public Affairs, Church of Scientology in Washington, D.C., Mr. Moxon was one of the original coconspirators involved in Operation Snow White against the FBI and the Internal Revenue Service which resulted in the arrest and conviction of 11 high-ranking members of the Church of Scientology in Washington, D.C. which also included the imprisonment of L. Ron Hubbard's wife, Mary Sue Hubbard. "Mr. Moxon is very proud of the fact that he was intimately involved in that whole unlawful affair and the FBI never caught him. He is proud of fact that he got away with doing unlawful stuff and he never got arrested or convicted for it.

"Q. Have you had any conversations with Mr. Moxon in which

you gave he that impression? "

 

A. Yes. I did. When I spoke to Moxon my serious concerns about being caught and prosecuted for killing both Cynthia Kisser and killing Ford Greene, he mentioned this Snow White operation in which he was a part of and he tried to assure me there was absolutely nothing to worry about because I could trust him and I could trust the other legals to help me get away with this. He claimed there was no way anyone was going to find out." (Deposition of Garry L. Scarff, at p. 378, in. 18 - p. 380, in. 13.)

Bowles & Moxon to Intervene on Scarfs Behalf Once Ms. Kisser Was Murdered.

. Q. Before we proceed with a discussion of the meeting regarding the conspiracy to murder Ford Greene, I would like to return briefly to the meeting you testified to regarding the conspiracy to murder Cynthia Kisser. "Now, did there come a time that weekend or at the end of that weekend when you left Los Angeles? "

A. Yes, I did. I left on Monday.

"Q. And before you left Los Angeles did you have any further

meetings at the Church of Scientology? "

A. Yes, I did.

"Q. And with whom did you have any such further meetings? "

A. Eugene Ingrarn took me upstairs to the offices of Bowles & Moxon because he said that Tim and Kendrick wanted to say good-bye to me because they had not had the chance to speak with me before. And I said good-bye to Tim but Kendrick was in a depo or a session of some sort according to Eugene so I didn't get to see him. But Tim greeted me very warmly and said that he knew that I was there for the weekend but he was busy with stuff and hadn't had the chance to talk with me, and that was it.

"Q. By 'Tim and Kendrick' who do you mean? "

 

A. I'm talking about Timothy Bowles and Kendrick Moxon, who are attorneys for Bowles & Moxon, the in-house law firm for Scientology.

 

"Q. Now, did you have any understanding as to their knowledge, if any, of the meeting you had had regarding the conspiracy to murder Cynthia Kisser? "

 

A. I presumed from my knowledge and my experience within the Church of Scientology and the policies that are strictly adhered to within the Church of Scientology that one does not speak on behalf of another, and that when Mr. Ingram and Mr. Butterworth were advising me that once the murder had been committed that we would have Bowles & Moxon intervene on my behalf on a legal basis, I was confident then that Tim Bowles and Kendrick Moxon knew exactly about the conspiracy because Ingram -- particularly David Butterworth, who is a Scientology member, in the face of being punished with RPF would not compromise his high- ranking position in the Church of Scientology by saying something with regards to Bowles and Moxon unless Bowles & Moxon was specifically aware of the statement that was being made to me. "And so it was my confident feeling that Timothy Bowles given the fact of the way that he greeted me, said that he knew that I was in L.A., that Timothy Bowles was very knowledgeable about the plan for me to go to Chicago and kill Cynthia Kisser and her daughter." (Deposition of Garry L. Scarff, at p. 382, in. 15 - p. 384, in. 21.)

Eugene Ingram. David Butterworth. Tim Bowles, Ken Moxon. Lauri Bartilson and Scarff Present at Meeting Where Murder of Ford Greene Discussed; Meeting at Bowles & Moxon Office: Specifics of Murder Discussed; Bartilson Took Notes.

 

 

"Q. Now, a little while ago before the lunch break you started to talk about a subsequent meeting that took place regarding a conspiracy to murder Attorney Ford Greene. "

 

A . That ' s correct.

"Q. Can you tell me when that meeting took place and where it took place and who was there? "

 

A. It took place on or about December 20th -- I believe it to be December 20th. It was Saturday morning -- at the Bowles & Moxon office at the Saint Hill organization building, Church of Scientology International, Los Angeles. In that meeting were Gwen -- I'm sorry. Strike that -- Eugene Ingram, David Butterworth, attorneys Tim Bowles, Ken Moxon, Laurie Bartilson and myself.

"Q. Who is Laurie Bartilson? "

A. Laurie Bartilson is an attorney for Bowles & Moxon who is currently representing

Scientology in a lawsuit against Gerry Armstrong, a former Scientologist.

"Q. Do you know about what time did that meeting take place? "

A. Approximately 8:00, say 8:00 in the morning. It lasted for several hours. w

Q. You said it took place in the offices of Bowles & Moxon? "

A. That's correct.

"Q. Whereabouts in the offices of Bowles & Moxon? "

A. I'm sorry.

"Q. Was it in -- did you know whose --"

A. It was a conference room. To the left as you go in the doors you have a receptionist's desk on the left and you have several offices, and just beyond the receptionist's desk there is a little conference room and this is the conference room we were in.

"Q. I see. Is that the office of Bowles & Moxon that you previously said was on the floor above the Office of Special Affairs in the Saint Hill building?

A. Yes, it is.

"Q. Now, can you tell me what was said at that meeting and by whom? "

A. Eugene Ingram was the primary talker in all of this, and Eugene told me that reflecting on our conversation in November, whereby Mr. Ingram had filed a complaint against Ford Greene for ethics violations to try to get him disbarred, Mr. Ingram said that nothing was going successfully with that, that the Bar Association in the State of California is a pansy organization and that nothing was happening with that. "And that Gerry Armstrong, who was a former member of the church, very well known and who has been very publicized because of his departure from the church and the litigation he has been involved with the church since then, had joined forces with Ford Greene and that both of them were in fact homosexual, and the term he used is that they were "fuck buddies", and that Gerry Arrnstrong and Ford Greene were on a kind of a vigilante type of effort against the Church of Scientology. "And that Mr. Armstrong, who had signed a settlement with the Church of Scientology in 1986 in which he agreed he would no longer criticize the church or say anything detrimental about the church, was in fact working with Ford Greene in a manner which was very adverse to the Church of Scientology and that he was basically raising legal issues to attack the Church of Scientology.

Q. So was anything else said at that meeting? "

 

A. Well, yes. We talked about killing Ford Greene.

"Q. So what was said with regard to that? "

 

A. Eugene told me that there is "no loss in a dead fag" and he basically said it would be a much easier operation for me to perform since I had failed in carrying out my planned effort to murder Cynthia Kisser. He said that Ford would be an easier target and that Ford was a major target that had to be eliminated. And they said because Ford had a history of cocaine abuse and alcohol abuse and it was known that he enjoyed driving his car at very high speeds, and I could recall 90 miles to a 100 miles per hour on the highway back in 1987, that it would be easy to run this man off the road and kill him. Eugene even commented about the aspect of running him off the Golden Gate Bridge, which would insure his death, and that there wouldn't be a lot of investigation behind that simply because Ford Greene had a very impeachable reputation to begin with. But they definitely saw Ford Greene as a threat simply because of him getting together with Gerry Armstrong.

"Q. So what else was, if anything, was said at that

meeting and by whom? "

 

A. Mr. Butterworth and Mr. Ingram discussed with me other ways to get at Ford Greene. If not to kill Ford Greene, Mr. Ingram told me that he could gain access to incriminating materials like child pornography, which to possess is a violation of federal law, drugs and to break into Ford Greene's law office and plant these items and then to call the police and have Ford Greene arrested for possession of child pornography.

"Q. Did Mr. Ingram indicate where he might obtain these materials? "A. Yes, he did. Mr. Ingram has told me in the past that he is an honorable -- strike that. He is an honored veteran of the Los Angeles Police Department where he received an honorable discharge for something and that he had a lot of contacts within the law enforcement community in California and that he could easily gain access to the evidence rooms facilitated by the Los Angeles Police Department and could access cocaine, guns, and anything there that he needed to use in his investigations.

"Q. Was anything else said about the plan to murder

Ford Greene at that meeting? "

 

A. Not that I can recall right now.

"Q. Now, you said that Tim Bowles, Ken Moxon and Laurie Bartilson of the law firm of Bowles & Moxon were present during that meeting. Did they say anything during that meeting? "

 

A. Laurie was totally silent during the entire meeting. She said absolutely nothing. Tim Bowles said that Ford Greene was a decisive threat because of his relationship with Gerry Armstrong. I questioned that because having known Ford Greene in 1987, at which time I carried out an operation against him, I told Tim that the man was a drug addict, he was a drunk, he was very insecure, mentally unstable and that he was not a threat, but they seemed to feel that he was a decisive threat because of his relationship with Gerald Armstrong and that -- we had to lose him.

"Q. Tim Bowles said that? "

 

A. Yes. Tim Bowles himself.

"Q. Did Mr. Bowles voice any opposition to the of killing of Ford Greene? "

A. Absolutely not. Kendrick Moxon did not voice any opposition to him. In fact, when Eugene made the comment there is "no loss in a dead fag," everyone laughed. Everyone thought it was incredibly funny.

"Q. What about Miss Bartilson, did she say anything with regard to the killing of Ford Greene? "

 

A. Absolutely not. she sat there writing on a note pad such as yours, and she wrote notes and that was it. It's like she was a secretary writing for the meeting.

"Q. Did anyone oppose the killing of Ford Greene at that meeting? "

A. I would say the only person that had any opposition to killing Ford Greene at that meeting was myself because I was afraid of the consequences of doing that.

"Q. Was there any discussion of what the consequences of doing that might be? "

A. Yes. If I was caught I would end up on Death Row in the State of California.

"Q. What discussion took place regarding that? "

A. I was told I had absolutely nothing to worry about because Bowles & Moxon would take of it. Eugene would take care of it. If necessary they could get me out of the country and put me into hiding. Tim Bowles said don't worry. We'll take care of it. And when they said "we'll take care of it," I assumed that, as had been discussed in the November meeting, that they would file the numerous legal maneuvers in the courts against prosecutors basically to impede in any type of prosecution against me, and I figured that's what they meant.

"Q. What did Gene Ingram say about what might be done after Ford Greene had been killed?

"A. He simply brought up what we had discussed in November again with the possibility if I saw no other way out, that I could kill myself.

"Q. And that was to commit suicide like you told us about before? "

A. That was to put a gun barrel in my mouth, stick it up to my gums and blow my brains out.

"Q. Have you ever heard of a phrase of R245 in Scientology?

A. No, sir.

"Q. Was there any further discussion at that meeting regarding the specifics of how Ford Greene was to be killed? "

A. Not that I can recall.

"Q. Did you have any further discussions -- sorry. How long did that meeting take or last? "

A. Approximately two to three hours. It was about 11:00 when we broke."

(Deposition of Garry L. Scarff, at p. 385, in. 22 - p. 393, in. 4.)

Scarff Confirms that Tim Bowles was at Meeting When Murder of Ford Greene was Discussed.

"Q. Now, you're certain that Tim Bowles was at that meeting? "

A. Yes. Tim Bowles --

"Q. You're aware that he has filed a declaration in another lawsuit, which we'll deal with later, denying that he was present? "

A. Yes, yes.

"Q. Do you have any comment at this time to make with regard to that declaration? "

A. Yes. In fact, in a lawsuit regarding Jerry Armstrong I had provided a declaration of Ford Greene, and I told Ford Greene that on the weekend of -- it was approximately December 20th I met with Tim Bowles, and Tim Bowles filed a declaration on his -- on himself saying that he had been in Oklahoma and that he had returned to Los Angeles on Saturday, December 20th, and spent December 20th through December 26th with his family in Los Angeles and that he has proof to show that he wasn't here on December l9th. "I told Ford that Ford had misunderstood -- when I provided him the declaration on the telephone, that he had typed his declaration in error because I said it was approximately that time, not that specific date, which Mr. Bowles challenges in his declaration. And Ford told me that because he had already submitted the declaration to the court that I could simply correct that when I appeared in court.

"Q. Now, Mr. Scarff, I have now located the calendar for the year 1991 that I was looking for, the year 1992, along with the declaration of Timothy Bowles, Exhibit-20. "Placing before you a document which we shall mark as Exhibit-169, a series of calendars for the years 1990, '91 and '92, does that document assist you to refresh your recollection as to the exact date on which the meeting at Bowles & Moxon with Gene Ingram, David Butterworth, Timothy Bowles, Kendrick Moxon, Laurie Bartilson and yourself occurred in reference to the conspiracy to murder Ford Greene? "

A. Yes, it does. As I maintained all along, it occurred on a Saturday morning. I just got the date wrong. According to the calendar it was Saturday, December 21st. "Q. On the previous occasions both in this case and in the Wisel case when you have testified about these dates, have you had the benefit of a calendar? "

A. I have not."

(Deposition of Garry L. Scarff, at p. 393, in. 23 - p. 396, in. 9.)

Conspiracy to Murder Ford Greene Involved Ken Moxon. Tim Bowles, Lauri Bartilson, Eugene Ingram and David Butterworth.

"Q. Now, turning to Paragraph 8 of the declaration of Timothy Bowles dated March 1, 1993, l Mr. Bowles states that he first met you on December 17, 1992 in Portland, Oregon. What do you have to say about that, if anything? "

A. Mr. Bowles -- to you or to the camera? Mr. Bowles, you're a liar.

"Q. Why is Mr. Bowles a liar? "

A. Because I have met Mr. Bowles in 1991, at which time he knows, as well as other members of the Office of Special Affairs, that we were all involved in a solicitation to kill two people, Ford Greene and Cynthia Kisser, which I am very confident he was very much aware of or he would have objected or said something and he did not. And Mr. Bowles is either totally ignorant and a very stupid individual or he knew exactly what was happening and just chose not to say anything about it.

"Q. Do you have any doubt that anyone present at the meeting at Bowles & Moxon on December 21, 1993 --

A '92

"Q. -- 1992 where the killing of Ford Greene was planned --"

A. I'm sorry. '91.

"Q. -- '91, do you have any doubts whether anyone present at that meeting were mistaken about the nature of the discussion that was taking place? "

A. Absolutely not, absolutely not. They had to be incredibly stupid if they didn't know what was going on, and the fact that they were all sitting in that conference room prepared to discuss this situation, how could they not know? I mean, this was a preplanned meeting on Saturday at 8:00 in the morning which they flew me in from Portland for. When you go to the Saint Hill organization building, most staff members don't show up to their posts until around 9:00 in the morning or thereafter. This happened at 8:00 in the morning, and for them to say that they didn't know anything -- how can you even imagine that they wouldn't know, being attorneys? "Q. Is it your testimony that everyone present at the meeting was part of the plan to kill Ford Greene? "A. If I had killed Ford Greene, everyone in that room, Ken Moxon, Tirn Bowles, Laurie Bartilson, Eugene Ingram and David Butterworth, would all belong on Death Row right alongside me." (Declaration of Garry L. Scarff, at p. 398, in. 13 - p. 400, In. 13.)

Discrepancy in Declaration Explained.

"Q. Now, let's turn to the declaration you gave to Ford Greene, Exhibit-l9, and see if we can clarify a discrepancy here. "

A. Sure.

"Q. Paragraph 7 of that declaration, which is referred to in the Bowles declaration, contains a list of people present at a meeting, which you say in that declaration took place on December 20, which you've subsequently revised having reference to the calendar. "

A. Well, if you notice Ford Greene's explanation, he also says 'On or about"' which to me means the same thing as 'approximately.'

"Q. Is the meeting referred to in Paragraph 7 the same meeting that you have just been describing? "A. Yes, it is, and there is a discrepancy in that paragraph, and again, this is something I brought up to Ford Greene on February l9th when he flew me here to Los Angeles to testify as a witness for Jerry Armstrong, and he told me not to worry about it, that it's something I could simply clear up in court because he had gotten names mixed up. "Q. Now, when you had that discussion with Ford Greene, was there any discussion as to who the correct participants at the meeting being referred to in Paragraph 7? "

A. Yes. Because when he called me and said he wanted a declaration from me, he called me at work, and I had to take a break from work, and over a five-minute period this is basically what happened. And so this was quickly read over the phone to Ford Greene, and Ford Greene asked me on the phone, 'You did not mention Randy Spencer, and you said in prior testimony that you've had some dealings with Randy Spencer. Was he present?' And I said, 'No.' And he said, 'Okay.' "And then when this declaration was kicked out, and I recall Mr. Greene faxing a copy back to me the same day for my review and signature, it said Randy Spencer and Eric Moran. And he said, 'I'll take Randy out. I'll put Laurie in.' When the final copy came out, nothing had been changed, and Ford said that he had been very busy with a number of things getting ready for this trial because it was a very big trial that he was preparing for and not to worry about it because when I got into court, was put on the stand, I could simply correct the discrepancies in the report. That it was no big deal.

"Q. If you were given the opportunity to do that, how would you have corrected those discrepancies? "

A. In Item 7 I would omit Randy Spencer and put Laurie Bartilson's name.

"Q. Anything else? "

A. And it has Eric Moran in here, and Eric wasn't there.

Q. So if there was a -- if you were given the opportunity in the Armstrong case to revise the list of participants at the meeting in Paragraph 7 and the date of that meeting, what would you say? "

A. You mean as far as the lawyers?

"Q. As to who was there and what date it took place. "

A. Ken Moxon, Tim Bowles, Laurie Bartilson, David Butterworth, Eugene Ingrain and myself.

 

"Q. And with regard to the date, would you make any change to that? "

A. December 21st, Saturday.

"Q. Now, following the Saturday, December 21st, 1991 meeting at Bowles & Moxon, did anything else occur regarding the conspiracy to murder Ford Greene? "

A. You mean in that same weekend?

"Q No. I mean just generally. "

A. Well, I didn't carry it out. I could not bring myself to harm or kill anybody." (Deposition of Garry L. Scarff, at p. 400, in. 14 - p. 403, in. 19.)

David Butterworth Pressures Scarff to Murder Ford Greene.

"Q. Were there any further discussions regarding that conspiracy to kill Ford Greene? "

A. There was the talk of Eugene Ingram going to Florida to extract a declaration from Margery Wakefield. It wasn't dealing with the actual killing, is that what you're asking, the actual conspiracy to kill, or another operation to discredit Ford?

"Q. Well, first of all, was there any further conversations between you and anyone at Scientology for Bowles & Moxon regarding the killing of Ford Greene? "

A. It came up later in the spring of '92 when Butterworth called me and asked me when was I going to start following orders and doing what was expected of me, and it was brought up again in August of '92 when it became a very insistent issue. And it was that constant pressure that brought me to write a letter to Cynthia Kisser asking to speak with her attorneys because I didn't know anyone else to turn to. I didn't have any credibility with the Cult Awareness Network at that point, and certainly there was no one within the Church of Scientology I could go to for help because they all follow the same party line. If I told anyone in the Portland Org. that I was disturbed, I knew immediately that would go right back through the lines to David Butterworth.

"Q. By 'disturbed' you mean disturbed about what? "

A. Disturbed about why they chose me as the individual that they wanted to kill Cynthia Kisser and Ford Greene, and I asked David Butterworth on different occasions why me, why not somebody else. He felt that I was the perfect individual for it. That he knew that I had been angry with different people and that I would be the most effective person to do it, and that I had spoken to him in the past, and it was just -- I remember the conversations to be a manipulation of our earlier conversations on how if I wanted to be in the best graces of the church that I needed to follow directives, and this is one way of gaining that respect and gaining my dignity back as a Scientologist that I had lost with the numerous violations that occurred in my past history with the church." (Deposition of Garry L. Scarff, at p. 403, in. 20 - p. 405, in. 15.)

Planned Murders. of Cynthia Kisser and Ford Greene Discussed; Planned Release of False Information; Scarff Threatened by Ingram.

"Q. Had you ever heard of a phrase "for the greater good of Scientology"? "

A. Yes.

"Q. In what context? "

A. Well, back in November of '91, for example, killing Cynthia Kisser, David Butterworth mentioned that it would be for the greater good of Scientology. And there was also some discussion to that on Saturday morning, I believe it was November 16th or 17th, when David Butterworth told me that he wanted to introduce me to his entire OSA staff, and I went out into the hallway, and his entire staff -- not only the OSA but all the adjoining offices in the area were standing out in the hallway at parade rest in ranks of three, and there were approximately I would say 50+ people there at parade rest. And he had me address his staff, and he introduced me as someone that was going to eliminate the Cult Awareness Network within one year, that we had a lot of surprises for Cynthia Kisser and her other cue conspirators and that Mr. Scarff was going to be one way of effectively destroying the Cult Awareness Network.

"Q. At that meeting where the killing of Cynthia Kisser was planned, did anyone present at that meeting seem to have any doubts as to the reality of what was being planned? "

A. No one expressed any doubts whatsoever, and as I've stated on record before, I wasn't entirely confident of my support system in that meeting and I wasn't entirely confident in the December meeting with the fact that they were going to come to my aid if I did anything criminal. And I also had a very difficult time with a personal conscience telling me that it was wrong to kill anybody because I had never physically injured anybody in my life and I questioned why they were having me do it. I got the sense that there was an awful lot of things that they weren't telling me and they probably wanted me dead as well as they wanted Cynthia Kisser dead. And they kept me telling me that it wasn't that case at all. It's just something that needed to be done and they wanted me to do it. "And then when Ingram discussed putting a gun in my mouth and pulling the trigger, I wondered just how much these people really did care for me. I guess it was that and my own personal conscience that told me that something just wasn't right here. And I guess someone can look at me and say well, why didn't you leave the Church at that time, but I didn't. I was too dependent on them, and I mean, there -- anyone looking in on this would look at the death plots and they might question how Scientology creates these operations and plans to carry them out, but they need to look at it with the perspective that this is a very organized criminal organization that has everything intricately plotted out. The problem that people don't realize is that when I was in Scientology working for the OSA, in addition to talking about murdering Ford Greene and murdering Cynthia Kisser, they were throwing all these other projects, all these other cycles that needed to be completed. all these other things that had to be done by me. And so I was continually running six, seven operations at the same time. "And at the same time that they were talking about killing Ford Greene they were talking about discrediting his professional and personal integrity by having someone file a declaration against Ford Greene stating that Ford agreed to provide legal services in return for homosexual activity and that he agreed to barter his legal services in return for sex, and Eugene Ingram even talked about flying to Tampa, Florida where ex- Scientologist Margery Wakefield lives, being that Margery Wakefield is someone that had earlier sued the church of Scientology and received a financial settlement, that the church was very interested in incriminating Margery. And they were talking about Eugene going down there to Florida and posing as someone other than a investigator for Bowles & Moxon and not revealing his direct connections with Scientology and thus getting a declaration against Ford Greene because Eugene said that he had information which proved that Ford Greene had once compromised his legal position by not only representing Margery Wakefield in a lawsuit but, at the same time, involving her in a sexual relationship and that he uses sexual relationships to manipulate his clients. "Flying around the country under the misrepresentation of someone else is something that Eugene Ingram is very good at. I know of a Cathy Lane, who filed a declaration against Cynthia Kisser alleging that Cynthia is a former strip dancer in Arizona, and Scientology even had me speak at a press conference that Cynthia Kisser was not only a strip dancer but a former prostitute, in an attempt to destroy her professional credibility in the media

A. None of it is true. Eugene Ingrain flew to New York to substantiate the facts in the Fallon deprogramming that I had been involved in at one time, and knowing that the Fallons had an anti-Scientology attitude, he misrepresented himself as a writer for a magazine for retired firemen called "Backdraft", and that he was able to manipulate Mrs. Fallon into providing him information through his misrepresentations. "He also got a declaration from a Santa Fe police officer when Eugene flew to Santa Fe, New Mexico in an attempt to incriminate Joe Szimhart, and Eugene told this police officer that Joe Szimhart was a kidnapper and deprogrammer that had broken the laws by kidnapping and deprogramming people and that Theresita Scolly, the woman that Joe Szimhart was working with was the girlfriend of this police officer. So through misrepresentation and insinuating police misconduct, Eugene was able to get a declaration under duress from this Santa Fe police officer, and Eugene gloats about his successes and how easy it is for him to lie and to misrepresent himself and get the intended results." (Deposition of Garry L. Scarff, at p. 405, ln. 16 - p. 410, ln. 12.)

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