Title: Deposition of Robert Friend
Author:
rkeller@netaxs.com (Rod Keller)
Date: 24 Jul 1997 12:10:22 GMT

I have 23 pages of an 80 page deposition of Robert Friend, brother of
Roxanne Friend. This is all I have, so I don't know exactly who all these
folks are. I assume it's Graham Berry and Scientologist Laurie Bartilson. 
I don't know who Mr. Wynne is. 

-------

               SUPERIOR COURT OF THE STATE OF CALIFORNIA
                      FOR THE COUNTY OF LOS ANGELES

ROXANNE FRIEND,
    Plaintiff,

  vs.                                 No. BC 018003

CHURCH OF SCIENTOLOGY, et al.,
    Defendants

DEPOSITION OF: ROBERT L. FRIEND
TAKEN ON:      November 8, 1991
VOLUME I:      Pages 1 through 80, Inclusive

[starting with page 27]

BY MR. WYNNE:

Q There came a time at about that period of time when Roxanne was not
allowed to be by herself, correct? 

A That's the kind of question that calls for a short answer to something
that really contained quite a lot of circumstance and events. 

THE WITNESS: Maybe this would be a good time to take a cigarette break if
you don't mind.

MR. WYNNE: I certainly don't mind. 

(Recess taken 10:43 a.m, to 10:57 a.m.) 

BY MR. WYNNE: 

Q At some time during this general period of time we're talking -- late
December or early January '89, '90 -- did some other people come out and
start working with you in terms of what was going on with Roxanne? 

A Oh yeah. 

Q That was Jim Sydejko? 

A Yes. 

Q And Mary Float? 

A Yes. 

Q They're both on staff at Flag?

A Jim is still on staff. Mary, I presume is still on staff.

Q Were they at that time?

A Yes.

Q Do you know what their posts were?

A Jim I know is a class nine auditor. He was Roxanne's auditor.  And Mary
was, I don't know what her post was actually. She was there primarily to
be a female of comparable terminal for Roxanne. Someone awareness. 

Q As far as you know, did anyone contact them from Los Angeles and request
them to come out? 

A Not that I know of, no,

Q Did anyone - Did Warren orally tell you that they had requested someone
to come out from Flag? 

A Not that I remember.

Q You didn't personally call and ask them?

A No.

Q About what time did they arrive?

A Just before year end.

Q Prior to their arrival had you and Warren and Lisa taken any steps to
try to make sure that Roxanne was always accompanied? 

A Uhm, I think it's fair to say that the answer to that is yes.  - I
recall going to, making an effort to spend time with Roxanne. For example,
she went to her barn quite often. And I remember accompanying her there on
two occasions, There wasn't, however, any effort to prevent her from being
alone. But it was clearly -- I think everybody was in agreement that
Roxanne was in a not fully -- I'm severely agitated state and was trying
to think of television or movie type terminology here that I might know. 
She wasn't fully capable at that point already to take care of herself. 

Q Prior to the arrival of Sydejko and Float was Roxanne allowed to be an
her own from time-to-time? 

A Yes. 

Q Prior to their arrival was she allowed to drive in her car? 

A Yes.

Q After their arrival was there a time in which there was a concerted
effort not to let her be - alone? 

A Initially, when they first arrived -- you have to understand that
everything that we did, we were all friends of Roxanne, I was her brother.
Jim was her auditor, Someone that you develop a ministerial relationship
with.  This was her roommate. This was a very long-term friend. I'm
talking about Lisa and Warren and myself, we were all trying to help
Roxanne. The auditor came out to further help Roxanne.  So when they
arrived they proceeded on the same basis we had been, Rox was -- it was
more than obvious that Roxanne was not also there. Yet we made an effort
to grant her enough understanding, we were trying to create a very safe
environment for her so that continued when the auditors came. 

In answer to your question, yes, after some paint a determination was made
that, no, Roxanne could not use the phone in an indiscriminate manner that
was inciting the police, for example, to chase down spurious leads about
secret agents and so forth, or calling people all over the country that
she hadn't talked to in tens of years, for hours on end. 

That Roxanne, her -- she shouldn't be driving around. Her driving was very
erratic. I drove with her on two occasions and was quite

[skip to page 33]

you state it to?

A I think I made it very plain to Roxanne.  I believe I grabbed the phone
out of her hand. 

Q Did you communicate this to anybody else who was staying there? 

A Yeah, I think I made it plain to Lisa and to Warren that we didn't, that
it was not good for her, that she was feeding her own agitation by making
phone calls that, and continually restimulating whatever was going on with
her. 

Q There was also a point in time where she was not allowed to use her car,
correct? 

A Yes. 

Q Let me try to establish some foundation about talking about time here. 
Subsequently there was a point in time in which you and some others
traveled to Clearwater with Roxanne, correct? 

A Yes. 

Q Yesterday Mr. Mareton referred to the paint of time of about a week
before that as "the watch."  Is that, do you remember referring to that
portion of time as "the watch?" 

A Okay, yes. 

Q Is that something that you have referred to in the past? 

A There was a period of about six or so days prior to leaving for Florida
where we made every effort to protect Roxanne from herself.  That she had
gotten herself into such a state that she was, in my opinion and her
friend's opinion, was in serious jeopardy, both from her seeming uncanny
ability at that time to create confrontation with people she didn't even
know, and also because of her erratic behavior of getting picked up by the
police, or institutionalized or getting in a car accident. 

Q During that - For what period of time was Roxanne not allowed to make
telephone calls? 

A I would say about a six, seven day period prior to leaving for Florida. 

Q. For what period of time was she not allowed to drive? 

A Similar period. 

Q For what amount of time was an effort made to make sure that she was
never by herself? 

A Similar period. 

Q During that period of time you were staying in the apartment, correct? 

A Yes. 

Q Where were you sleeping? 

A Lisa had an office next door, and I would sometimes sleep in there or
sometimes in Lisa's bedroom, on the floor. 

Q During that period of time Mr. Sydejko and Ms. Float ware present in Los
Angeles, correct? 

A That's right. 

Q Were they staying over at the apartment or in the office next door? 

A The office next door. 

Q During that period of time did Mr.  Sydejko write any reports concerning
what was going on, to your knowledge? 

A I did not directly observe him write any reports.  I would assume he
wrote daily, if not more frequent, reports. It's quite serious trying to
handle somebody who is psychotic. 

Q What is the basis of your assumption that he would have been writing
reports daily or more frequently? 

A The basis of my assumption is that Jim is an auditor. He applies certain
technology in ministering his craft.  The general program of what he's to
do is prescribed in effect by the case supervisor. So Jim would never, no
auditor would ever go off on their own, willy nilly, trying different
methods or techniques to handle a person, to make them feel better,
without case supervisor monitoring. 

Q So you would expect that in the custom and practice -

A The normal course of events he would post the case supervisor on any
handlings that he was doing. 

Q Do you know if during that period of time Mr. Sydejko was in
communication with the case supervisor? 

A I do remember specifically that he sent a couple of facsimiles to Flag
from the Advanced Organization in Los Angeles.  I can -- like I say, I
presumed there were regular communications, but I do remember one or two
occasions where I myself accompanied him to the Advanced Org so he could
send these communications. 

Q How many times during the watch did you actually go to the Advanced Org? 

A I remember I believe two times. 

[skip to page 50]

question. 

I move to -- I didn't move to strike, but I think the question is a proper
question as phrased.  And I'll ask it again. 

MS. BARTILSON: I'm going to object as argumentative. Misstates the
testimony of the witness. 

BY MR. WYNNE: 

Q Roxanne, when the medication was first available to her didn't want to
take it, did she? 

A As I was about to say, your tone has the connotation that she was, had
an adverse reaction to the whole question of taking the drug.  And I would
say her attitude was more of -- I'm not sure that's the answer -- her
response was more of boredom. It wasn't, she didn't rale against the idea,
she didn't say don't give me drugs.  There was no refusal to take it.  You
know, there was no insistence she did take it. She was not forced to take
it. At some point, as I said before, she did not -- as I said, when the
drugs arrived she did not take them right away, that is true.  Later she
did. That is also true. 

Q There came a point when a decision was made to transport Roxanne back to
the land base, correct? 

A Yes. 

Q Who made that decision? 

A The decision was a mutual decision.  I believe the suggestion was her
auditor's. 

Q That was Jim? 

A Yeah. 

Q When you say it was a mutual decision, mutual between who? 

A Between the parties involved.  Myself.  Jim.  Lisa.  Warren. 

You know, her friends who were trying to help her. 

Q During the course of this decision making did you talk to Roxanne about
it? 

A No. 

Q Was there any involvement with the case supervisor in terms of the
making of this decision to your knowledge? 

A I have no direct knowledge of that involvement. 

As I said, standard procedure would suggest that the case supervisor at a
minimum would have been appraised of that notion. 

Q About what date, if you can remember, did the trip actually commence? 

A It seems to me that it was just after New Years.  Maybe a day or two
after.

Q What time of day did the trip commence? 

A It was quite early in the morning, about 5:00 a.m. or so.  It was still
dark out. 

Q The trip was made in a Winnebago, correct? 

A Yes. 

Q Do you know whose Winnebago it was? 

A As I understand, it belonged to a Scientologist who offered to make the
vehicle available for this use.  I don't know the name. 

Q At any time prior to the commencement of the trip did Roxanne tell you
that she wanted to go back to Florida? 

A Not to my recollection. 

[skip to page 57]

A I don't know what "authorization" means.  It's very difficult to speak
to the whole issue of authorization to leave because I'm not entirely
clear what that means.  And I have no, I have no direct knowledge of
Roxanne prior, this time period you're talking about -- her visit in,
perhaps it was November and December of '89 -- of her not being allowed to
leave or being prevented from leaving the land base, since my
understanding is she did in fact do that. 

BY MR. WYNNE: 

Q Do you have any knowledge of circumstances under which when you arrive
at the land base you have to surrender any airline ticket you're carrying? 

MR. BERRY: Same objection. 

MS. BARTILSON: Same objection.  Vague and unintelligible.  Who do you mean
when you say "you?"  Are you asking the witness if that's ever happened to
him? 

A That's not a standard practice and I know nothing about it. 

BY MR. WYNNE: 

Q The trip began early in the morning on about January 2nd, correct? 

A Yes. 

Q Who went on the trip? 

A Jim Sydejka.  Myself.  Warren.  Roxanne.  The other girl who came from
Flag.  And another staff member, I believe also from Flag. 

Q When you say the "other girl who came from Flag," are you referring to
Ms. Float? 

A Yes. 

Q At some point prior to the trip another staff member from Flag joined
you in Los Angeles, correct? 

A That's true. 

Q Was his first name Phil? 

A I'm not sure.  Big guy. Kind of overweight a little bit. 

Q What was his post at Flag? 

A He was security personnel. 

Q Were you told anything about the purpose for his coming to Los Angeles? 

A. That his purpose was to help us with the cross country trip. And I was
told that he had experience in dealing with psychotic people in the past. 

Q So it was your understanding that this staff member was actually there
to help out on the trip, correct? 

A Yeah, definitely. 

Q Do you remember when he arrived?  I'm asking that in terms of the number
of days before the trip actually commenced? 

A Maybe two days or so. 

Q Did he undertake any particular security procedures while he was present
in Los Angeles? 

A No, not really. 

Q During that time, during the watch prior to the trip was Roxanne ever
physically restrained from leaving the apartment? 

A I know for sure I restrained her on one occasion. 

Q. Did anyone else restrain her from leaving the apartment? 

A I remember Jim, I believe, Jim Sydejko blocking the door on one
occasion. 

Q Did the other male staff member from Flag ever physically restrain her
from leaving the apartment? 

A My recollection is that he was, Roxanne wasn't aware of his presence
until we actually made the trip. 

Q Had he been present in the apartment? 

A I don't recall. 

Q Did Jim ever tell you that he had requested this other staff person to
come out? 

A I don't recall. 

Q Do you remember anybody else, of the people involved, telling you that
they had made the request that this other staff member come out? 

A No recollection. 

THE WITNESS: Cigarette break? 

MR. WYNNE: Sure. 

MS. PLEVIN: We're close to lunch hour, maybe we should go a few more
minutes and break for lunch. 

(Recess taken 11:55 a.m. to 12:00 p.m.) 

[skip to page 63]

MR. BERRY: Do you have the original there? 

MR. WYNNE: This is not the original, this is a full-sized xerox of the
original. We have the original in the office.  I'm looking at it and it
appears that all the handwriting has been reproduced on the standard size
copy. 

MR. WYNNE: Do you want to compare? 

MR. BERRY: Not at the moment.  I would like to see the original, but not
at this second. 

MR. WYNNE: I'll ask you to look at the page, looks like that? 

THE WITNESS: (Complying) 

BY MR. BERRY: 

Q Do you know whose handwriting that is? 

A No. 

Q Did you have any discussion with any of the other people who traveled
back to Flag concerning the use of a mummy wrap? 

A I don't recall. 

Q Did you have any discussion with any of the people who traveled back to
Flag about the possibility of using physical restraint to keep Roxanne
going on the trip? 

A Yes.

Q Who was that discussion with?

A All of the people involved.

Q So was this one discussion with the group? 

A No, there were actually, as I recall, several discussions; how we would
get her into the Winnebago, how we would act during the trip. 

Q What was the substance of those conversations?  And if it's necessary
for me to break it down, let me know. But I think probably you can
summarize what those conversations included. 

A I think the basic substance was that there was the overriding intention
that Roxanne not be allowed to run off.  We discussed how we would walk
from the apartment building to the Winnebago. Keeping someone behind her
and in front of her and someone on the side at all times so that she
wouldn't go running off. 

And we discussed that in the Winnebago someone would sit near the door so
she wouldn't go running out of the Winnebago. 

Q Did you have any discussions about the

[skip to page 68]

Q Emotionally, how did she appear to you during the course of the trip? 

A At times excited, at times sad. Most of the time sort of like far away. 
She had a lot on her mind. 

Q Was she crying at any time during the trip? 

A I don't recall any time of her crying. 

Q Did the other people who were traveling leave the Winnebago from
time-to-time? 

A Yes. We made periodic stops to get food for the group. 

Q After you arrived in -- strike that.  After you arrived at Flag was
Roxanne then taken inside? 

A What do you mean "taken inside?". 

Q Taken inside the Flag building or - strike that. What happened after you
arrived at Flag in terms of where Roxanne went, as far as you know?

A We went directly to an apartment where Roxanne could stay and continued
to be watched and isolated so that she wouldn't have anything that would
restimulate her or feed this psychotic break. 

Q How long did you stay in Clearwater? 

A About three weeks I believe. 

Q You were present in Clearwater during that period of time? 

A I was there the whole time, yes. 

Q Did you see Roxanne during that period of time? 

A I saw Roxanne on one occasion that I recall. 

Q Where did you see her? 

A At the apartment. 

Q About what point in that three-week period was that? 

A After, I believe it was about after two weeks, I was led to understand
that Roxanne had been complaining that she didn't want to be there. And
there was a last sort of effort to get her to try and have auditing to
handle the psychosis. 

Q Who told you that she didn't want to be there? 

A A staff member whose responsibility deals with ethics. 

Q Do you remember that person's name? 

A No, but I remember who she is.

Q Who is she?

A She at that time was the director of inspections and reports.  A blonde
haired lady of Scandinavian origin. 

Q Was her name Barbro?

A Barbro what?

Q Just first name, do you remember?

A I don't recall.

Q Aside from that one visit you didn't see Roxanne during the period of
time that you were at Clearwater? 

A No.  As I said, the intention was to keep her without anything to
restimulate her. And I was, you know, the people who were with her were
people she didn't know is my understanding. 

Q Did you speak to her case supervisor.  during that period of time? 

A It is not general procedure that one talks directly to a case
supervisor, and I've never spoken, that I recall, to Roxanne's case
supervisor. 

Q Did you talk to anyone else who was involved in Roxanne's staying there
except for Barbro? 

A I was in communication with the president of the Flag Service
Organization from time-to-time. 

Q Who is that? 

A I can't remember her name.

Q What did she tell you in the times that you spoke to her? 

A Mostly those conversations concerned my parents who were, wanted to know
how Roxanne was doing, what was wrong.  And I spoke to my parents.  And
also the president of the Flag Service Org spoke to my parents. 

Q At what point was that that you spoke to your parents in terms of three
week's stay? 

A I think I spoke to them shortly after we arrived in Florida, within a
day or two.  And maybe once or twice over the next two weeks. 

Q Where you initially talked to them in Florida, what did you tell them? 

A I basically explained what I've explained here, that the purpose of the
watch was that -- first off, that Roxanne was quite psychotic, which I
believe they were aware from her phone calla.  That the purpose was to
create an environment where she could calm down and hopefully snap out of
it and not be off running around where she could get herself into trouble. 

Q Did your parents give their permission for Roxanne to be at Clearwater? 
And I'm talking about during these telephone conversations when you were
in Clearwater? 

A There was no, there was no -- the subject of permission never came up. 

Q Did you discuss prior to the trip, with either of your parents, the fact
that Roxanne was going to be transported back to Florida? 

A It's possible. I don't recall.  In essence, you know, I feel like if
there was, this issue of permission, it was me who gave that permission. I
was involved in what occurred from beginning to end. 

Q At some point were you presented with a bill for the cost of the
transportation? 

A No. 

Q Do you know if either of your parents were presented with some kind of
bill for the cost of seeing to it that Roxanne was transported to Florida? 

A Not that I know of. 

Q After your three-week stay in Clearwater, you then traveled in the
Winnebago to Massachusetts? 

A Yes. 

Q Who traveled with you? 

A It was me, Roxanne and just two ordinary junior staff people. 

Q Did you - Were you ever presented with a bill for Roxanne's stay at
Clearwater? 

A I was asked to contribute money to auditing that Roxanne might get if
she ever snapped out of it, and -- but I was not presented with any bills. 

Q You were asked to make a contribution? 

A Uh hum. 

THE REPORTER: Is that a yes? 

A Yes. 

Q BY MR. WYNNE: 

Q What was the amount of the contribution that you made? 

A I didn't make any contribution. 

Q Were you asked to contribute some particular amount for future auditing? 

A Yes. 

Q What was that amount? 

A Five thousand dollars. 

Q Who asked you for that? 

A The registrar. A registrar at Flag. 

Q Do you remember the name of that person? 

[end of page 73]

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