Stipulation of Evidence in the USA vs. Mary Sue Hubbard

 

Scientology lawyer Kendrick Moxon named as unindicted co-conspirator

Notes about the following document from the person who scanned it

in from the original:

 

Presented for your edification is the complete Stipulation

of Evidence in the USA vs. Mary Sue Hubbard et al. case. I think

this document is particularly important in understanding the

lengths to which the Church of Scientology's agents (be they

GO, OSA, or RTC) will go to in order to protect their leaders.

 

This 300 page document is but a very small part of the 45,000+ pages

of documentation in this case alone. Additionally are some strange

and interesting documents. Such as the letters of character reference

for Mary Sue Hubbard in support of a plea for probation/parole.

Letters from the heads of a number of Scientology related

organizations (e.g. CCHR) are included. Paulette Cooper's name comes

up a fair amount; mostly pleading against the inordinate delays

created (e.g. 6 months to depose Mary Sue Hubbard on one particular

aspect).

 

In light of the recent revelations involving the Church of

Scientology in Greece, it becomes clear that the same guidelines

and policies are being applied in some areas (e.g. giving awards

for the theft of confidential government files).

 

The original is a very faded document that required a large amount

of editing to get a decent digital copy. As a result, there may be

some typos (not many, I hope). However, the original had a fair

number of typos and formatting inconsistencies itself. I have not

inserted any [sic]'s or other markings to indicate misspelling or

formatting problems that existed in the original.

 

From my understanding, the following document was agreed upon by

the defendants as a way to eliminate some of the discovery process

that would normally accompany such an extensive legal case. The

only reasoning I can come up with is that the prosecution and

defense were willing to make an open and shut case against the named

defendants in return for an agreement that the prosecution would

not go after L. Ron Hubbard.

 

Page breaks are marked with a complete line accross the page like so:

- ------------------------------------------------------------------

Footnote seperators are marked with an incomplete line accross the

page like so:

 

- ------------------

********************************************************************

- ------------------------------------------------------------------

********************************************************************

 

 

UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA

V. Criminal No. 78-401 MARY SUE HUBBARD, et al.

S T I P U L A T I O N O F E V I D E N C E

- ----------------------------------------------------------------------

• i -

 

TABLE OF CONTENTS

PAGE

I. The Witness Michael J. Meisner 1

II. Organizational Structure of the Guardian's Office 6

111. The Conspiracy to Intercept Oral Communications, 12

Burglarize and Steal, and the Substantive Acts

Committed Pursuant Thereto

 

A. The Order to infiltrate the Internal Revenue

Service in Washington, D,C. 17

B. The Bugging of the IRS Chief Counsel's

Conference Room on November 1, 1974 22

C. The First Infiltration of the IRS in the

District of Columbia Pursuant to GO 1361 32

D. Infiltration of the Tax Division of the

United States Department of Justice 57

E. The Guardian's Office Awards its GO 1361 Workers 79

F. The Theft of IRS Documents Exempted from

Disclosure Under the Freedom of Information Act 81

G. The Guardian Program Order Instituting An "Early

Warning System" to Detect Possible Legal Actions

Against L. Ron Hubbard and Ilary Sue Hubbard 90

 

H. The Los Angeles Guardian's Office Sends Help to

the District of Columbia @Quardian's Office 100

I. The Guardian's Office Orders Mr. Meisner to

Los Angeles for Debriefing and Auditing 106

J. Mr. Meisner Returns to the District of Columbia 112

K. The Entry Into the IRS identification Room and

the Making of Counterfeit Identification Cards 119

L. Guardian Program Order 302 and the Theft of

Documents Withheld by the United States Under

the FOIA 123

 

M. Burglaries of the Suite of Offices of the

Deputy Attorney General of the United States 127

N. Burglaries of the Office of International

Operations of the Internal Revenue Service

and Theft of Documents Therefrcm 133

 

O. Burglaries and Thefts or Documents Fro-.n the

Department of Justice in Washington, D.C. 139

1. Office of Paul Figley 139

2. Interpol Liaison Office at the Department

of Justice 142

- ----------------------------------------------------------------------

 

• ii -

 

Offices of Special Assistant to Assistant

Attorney General ror Administration

John F. Shaw

150

P. Burglaries and Thefts or Docu-.ients from Assistant

United States Attorney Nathan Dodellt-Office,

Located in the United States Courthouse for the

District of Columbia 155

 

IV. The Conspiracy to Obstruct Justice, to Obstruct

an Investigation, to Harbor a Fugitive and to

Make False Declarations Before the Grand Jury 176

A. The Preparation or the Cover-up Story 176

B. The Defendant Gerald Bennett Wolfe is Arrested

in Washington, D.C., by the Federal Bureau of

Investigation 190

 

C. The United States Case Against the Defendant

Gerald Bennett Wolfe is Referred to the Grand

Jury, and an Arrest Warran*- is Issued for

Michael Meisner 196

 

D. The Guardian's Office Harbors and Conceals

Fugitive From Justice Michael Me@isner 198

E. The Guardian's Office Gives the FBI and the

Grand Jury False Handwriting Exemplars 209

F. The Guardian's Office Refines its Cover-up Plans 214

G. The Federal Grand Jury Investigation in the

District of Columbia Continues 225

H. The Guardian's Office Cover-up Moves Into

its Final Phase 232

1, The Guardian's Office Restrains and Guards

Michael Meisner 238

J. Michael Meisner's First Escape from His Guards 248

K. The Defendant Wolfe's Sentencing and Subsequent

Testimony Before the Grand Jury in the District

of Columbia 252

 

L. The Defendant Wolfe is Debriered by the Guardian's

Office After his Grand Jury Appearance 265

M. Michael Meisner Surrenders to the Federal

Bureau of Investigation 268

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iii

TABLE OF EXHIBITS

EXHIBIT

NUMBER DESCRIPTION SECTION PAGE

1A Organizational Chart II 6,7,11

Guardian's Office

1B Organizational Chart II 8,11

Guardian's Office

(pre-January 1, 1976)

 

1C Organizational Chart II 9,11

Guardian's Office

(post-January 1, 1976)

 

1D Organizational Chart II 10,11

Assistant Guardian's

Office DC

 

2 Document #13969 III 12,14,-17,

95,163

3 Document #3060 IIIA 19-22

4 Document #9317 IIIA 19-22

5 Document #6131 IIIB 26-27

6 Document #20106 IIIB 28-30

7A Document #20276 IIIB 28-29

7B Document #20277 IIIB 28-29

 

8 Document #2065 iiic 32-35,39

8A Document #2065 P. 7 IIIc 32-34

8B Document #2065 p. 6 IIIc 32,34

8C Document #2065 p. 5 IIIc 32,34-35

8D Document #2065 P. 4 IIIc 32,35

8E Document #2065 P. 3 IIIc 32,35

9 Document 02064 IIIc 32,36-37

9A Document #2064 p. 2 IIIc 32,36

10 Document #2062 IIIc 32,39

IOA Document 02062 p. 2 IIIc 32,38--39

11 Document #2057 IIIc 32,39-40

12 Document #12636 IIIc 44-46

13 Document 019692 IIIc 47

14 Document #1433 IIIc 48-52

- ----------------------------------------------------------------------

iv

EXHIBIT

NUMBER DESCRIPTION SECTION PAGE

15 Document #118 liic 53-55

16 Document #115 iiic 56-57

17 Document #19669 IIID 59-61

18 Document #3778 IIID 60

19 Document #3801 IIID 59-61

20 Document #12898 IIID 59-61

21 Document #3799 IIID 59-61

22 Document #3661 IIID 59-61

23 Document #3664 IIID 59-61

24 Document #3806 IIID 59-61

25 Document #11244 IIID 59-61

26 Document #7394 IIID 61

27 Document #3656 IIID 59-61

28 Document #3610 IIID 61

29 Document #3811 IIID 61

30 Document #3814 IIID 61

31 Aerial photograph --

32 Document #8742 IIID 62-65

33 Document #3005 IIID 65-67

34 Document #2044 IIID 68-70

35 Document #2304 IIID 70-71

36 Document 014395 IIID 72-74

37 Document #14395 p. 57 at IIID 74

bottom right hand side.

38 Document #14399 IIID 72

38A Document #14399 p. 4 IIID 72-64

39 Document #2048 IIID 75-76

40 Document #4012 IIIF 82-83

41 Document #1405 IIID 77

- ----------------------------------------------------------------------

v

EXHIBIT

NUMBER DESCRIPTION SECTION PAGE

41A Documcnt 01405 p. 2 IIID 77

42 Document t2O55 IIID 78

43 Document #1403 IIIE 79-80

43A Document #1403 p. 2 IIIE 79

43B Document 01403 p. 4 IIIE 79

43C Document 01403 p. 5 IIIE 79

43D Document #1403 p. 6 IIIE 79

43E Document #1403 P. 3 IIIE 79-80

44 Document 012584 IIIF 83-85

45 Document 012607 IIIF 84-85

46 Document 01419 IIIF 85,108,110

46A Document #1419 p. 20 IIIC 40,85

[Document #1419, p. 61]

46B Document #1419 p. 21 IIIF 85,108-109,

[Document #1419, p. 8-101]

46C Document #1419 p. 23 IIIF 85

46D Document #1419 p. 25 IIIF 85

4T Document #12608 IIIF 83-84,86

48 Document #1431 IIIF 83

48A Document #1431 P. 3 IIIF 84,86

49 Document #1421 IIIF 87-88

50 Document 03660 IIIF 83-84,89

51 Document #3066 IIIc 51

52 Document #1541 III02 142-143

53 Document #9322 IIIG 90-92

54 Document #3676 IIIG 97-98

55 Document #3677 IIIG 97-98

56 Document #1410 IIID 78

56A Document #1410 p. 20 IIIF 89

56B Document #1410 p. 21 IIIF 89

56C Document #1410 p. 22 IIIH 105-106

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vi

EXHIBIT

NUMBER DESCRIPTION SECTION PAGE

56D Document #1410 p. 23 IIIH 104-105

56E Document #1410 p. 43 IIIA 21

5T Document #11120 IIIH 106

58 Document 01427 III I 110-111

59 Document #21704 IIIJ 114-115

60 Document #21724 IIIJ 116-117

61 Meisner IRS Identification IIIK 121

card

62 Document #21626 IIIJ 118

63 Document #798 IIIG,O 95,142-143

64 Document #3956 IIIH 99-100

65 Document #1097 IIIL 124-125

66 Document #1098 IIIL 123-124

67 Document #14768 IIIL 126-127

68 Document #1412 IIIJ 118

69 Document #15779 IIIM 131

70 Document #15780 IIIM 131

71 Document #15781 IIIM 131

72 Document #15778 IIIM 132

73 Document #3102 IIIN 137-138

74 Document #3035 IIIN 137-138

 

75 Document #3036 IIIN 137-138

76 Document #3033 IIIN 137-138

77 Document 03099 IIIN 137-138

78 Document #10963 III01 141

 

79 Document 010958 III01 l4l-l42

80 Document #2459 III02 146-147

81 Document 12462 III02 148

82 Document #11561 III02 148

83 Document #11562 III02 148

84 Document #11584 III02 148

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vii

EXHIBIT

NUMBER DESCRIPTION SECTION PAGE

85 Documerit #2463 IIIO2 148-149

86 Document #15777 III02 148-149

87 Document #2461 III03 152

88 Document #14111 III03 152

 

89 Document #14110 III03 152

90 Document #14109 11103 152

91 Document #14108 III03 152

92 Document #14107 III03 152

93 Document #9989 III03 153

94 Document #9990 III03 153

95 Document #15772 III03 154

96 Document #826 IIIP 156-159

97 D.C. Bar Library Sign-in IIIP 162

Log of May 21, 1976

98 Document #3044 IIIP 164

99 Document #11571 IIIP 165

100 Document #14114 IIIP 165

101 Courthouse Sign-in Log IIIP 167

of May 28, 1976

102 D.C. Bar Library Sign-in IIIP 167

Log of May 28, 1976

103 Document #18601 IIIP 168

104 Document #14113 IIIP 168

105 Document #898 IIIP 170

106 D.C. Bar Library Sign-in Log IIIP 171

of June 11, 1976

107 Document #1550 IIIC 52

108 Document #8598 IVA 189

109 Document #555 IIIM 127

110 Document #17416-17417 IIIP 173

111 Document #8567 IIIG 91

112 Document 08908 IIIP 174

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viii

EXHIBIT

NUMBER DESCRIPTION SECTION PAGE

113 Quality Inn Motel (Arlington) IIIP 176

Registration Card

114 Document #11176 IVA 177

115 Document #3125 IVA 180

116 Document #14751 IVA 179

117 Document #14738 IVB 191

118 Document #14744 IVB 192

119 Document #14745 IVB 193

120 Document #14742 IVB 194

121 Document #14749 IVB 195

122 Document #14748 IVB 195

123 Document #13789 IVC 198

124 Document #13785 IVD 198-199

125 Document #11078 IVD 201

 

126 Document #11076 IVD 201

127 Document #11055 IVD 203-204

128 Document #14662 IVD 205

129 Docunent #14737 IVD 207

129A Document #14737 p. 2 IVD 206

129B Document #14737 P. 3 IVD 207

130 Document #14672 IVE 211

131 Document #11231 IVD 207-209

132 Document #11425 IVE 210-211

133 Document #13755-13756 IVE 212

134 Document #13758 IVE

212

135 Document #10755 IVF 218,219

136 Document #14658 IVF 218

137 Document #111667 IVF 216

138 Document #10706 IVF 219-220

139 Document #10744 IVF 222

140 Document #13757 IVF 222

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ix

EXHIBIT

NUMBER DESCRIPTION SECTION PAGE

141 Document #14746 IVF 223-224

 

142 Document #14741 IVF 225

143 Document #10722 IVG 226

144 Document #10709 IVG 227-228

145 Document #8580 IVG 229

146 Document #1071@5 IVG 229

147 Document #14687 IVG 231

147A Document #14687 (2d letter IVG 232

from end)

147B Document #14687 last letter) IVG 232

148 Document #14689 IVH 232-233

149 Document #8575 IVH 234

150 Document #11215 IVH 235

151: Document #11175 IVH 236

 

152 Document #3135 IVH 237

153 Document #11179 IVH 238

154 Document #3146 ivi 238

155 Document #3145 ivi 238

156 Document #3144 ivi 239

157 Document #3143 ivi 240

158 Document #11232 ivi 240

159 Document #3153 ivi 241-242

160 Document #10066 ivi 243

161 Document #8574 ivi 243-244

162 Document #8576 ivi 243-244

163 Document #10067 ivi 244-245

164 Document #8573 ivi 246

 

165 Document #8572 ivi 246

166 Document #10070 ivi 245

 

167 Document #10071 ivi 247

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x

EXHIBIT

NUMBER DESCRIPTION SECTION PAGE

168 Document #11184 IVJ 249

169 Document #11183 IVJ 249

170 Document #11185 IVJ 251

171 Document #3148 IVL 266

172 Document #11201 IVL 267

173 Document #13141 IVL 266

174 Document #11199 IVL 268

175 Document #8555 IVM 272

176 Document #3150 IVM 273

177 Document #11203 IVM 273

178 Document #8558 IVM 273

179 Document #8548 IVM 274-276

180 Document #8544 IVM 277

181 Document #11204 IVM 277

182 Document #11202 IVM 274

183 Document #8561 IVM 278

184 Document #8563 IVM 279

185 Document #3147 IVM 280-282

187 Document #20107 IIIB 28-30

188 Document #20034 IVA 179-180,192

189 [not used]

190 FH Radio Monitor IIIB 25

191 Electronic device in gold IIIB 25

colored box

192 Battery connection IIIB 25

193 Telephone resonator IIIB 25

194 Wall receptacle IIIB 25

195 Spring steel shims IIIH 102

 

196 Spring steel shims IIIH 102

197 Spring steel shims IIIH 102

198 Spring steel shims IIIH 102

- ----------------------------------------------------------------------

xi

EXHIBIT

NUMBER DESCRIPTION SECTION PAGE

199 Spring steel shims IIIH 102

200 Spring steel shims IIIH 102

 

201 Spring steel shims IIIH 102

202 Key micrometer IIIH 102

203 H.P.C., Inc. lock picking IIIH 101-102

kit

204 Handwriting given by Moxon IVE 212

to Hansen of FBI

 

205 Wolfe Personnel Record at IIIA 18

IRS

206 Thomas Personnel Record IIIG 94

at DOJ

207 Thomas Identification Card IIIG 94

at DOJ

208 Conference memorandum of IIIB 31

Lewis Hubbard of Nov. 1,1974

209 Conference memorandum of Lewis IIIB

Hubbard of Nov. 1, 'L974

210 FBI Lab Decode of document IIIB 30-31

#20106

211 FBI Lab Decode of documents IIIB 30-31

#20107

212 FBI Lab decode of document IVA 18o

#14751

213 FBI Lab decode of document IVB 194

#14742

214 Grand Jury docket entry Dec. IVG 225

15 9 1976

215- Gerald Wolfe Grand Jury IVK 255-260

testimony of June 10, 1977

216 FBI Lab decode of document IVB 192

#14744

217 Photograph of bugging equipment IIIB 25

218 Photograph of lockpicking IIIH 102

equipment

219 Document #7984 IVM 274-275

 

*All of the above exhibits are appended to the instant stipulation.

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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA

V Criminal No. 78-401

MARY SUE HUBBARD, et al.

STIPULATION OF EVIDENCE

The United States of Americal through its attorneys,

United States Attorney Carl S. Rauh, Assistant United States

Attorneys Raymond Banoun, Timothy j. Reardon, III, and Steven

C. Tabackman, and the attorneys for the defendants: Leonard B.

Boudin, Esquire, and Michael L. Hertzberg, Esquire, for the

defendant Mary Sue Hubbard; Phillip j. Hirschkop, Esquire,

for the defendants Henning Heldt and Duke Snider; Rcger Zukerman,

Esquire, and Roger Spaeder, Esquire, for the defendants, Richard

Weigand and Gregory Willardson; Michael Nussbaum, Esquire, and

Earl C. Dudley, Esquire, for the defendants Cindy Raymond and

Mitchell Hermann, also known as Mike Cooper; John Kenneth

Zwerling, Esquire, for the defendants Gerald Bennet Wolfe; and

Leonard J. Koenickp Esquire for the defendant Sharon Thomas; as

well as the above-mentioned defendants themselves , agree and

stipulate that the evidence as to all the defendants is as follows:

 

- ----------------------------------------------------------------------

 

1. The Witness Michael J. Meisner

Michael J. mEisner, 29, was born in Chicago, Illinois.

He attended parochial elementary and secondary schools. He

studied at the University of Illinois at Urbana for two and

a half years from 1968 through 1970. Mr. Meisner became

interested in Scientology in November 1970 when he was intro-

duced to it by a friend. During the next two months,

he took several courses at the Urbana Church of Scientology

franchise and in January 1971 left the University to become a

full time course supervisor. He held this Position until

May 1971 when he was sent to the Church of Scientology of

St. Louis for two weeks of further training. He then returned

to Urbana, Illinois, where he resumed his duties as a course

supervisor until September 1971. At that time, he returned

to the St. Louis Church of Scientology where for the next eight

months he was trained to become an auditor. 1/ From May

1972 until August 1972, he resumed his duties as a course

 

- -------------------

1/ An "auditor" is a person who counsels Scientologists by applying the teachings and therapy methods of Scientology.

- ----------------------------------------------------------------------

 

2

supervisor and an auditor in Urbana, Illinois. In August

1972, lie assumed the position of Executive Director of the

franchise until June 1973.

In mid-May 1973, the defendant Duke Snider recruited

Mr. Meisner for the Guardian's Office of the Church of Scien-

tology in Washington, D.C. In a meeting in Washington,

D.C., the defendant Snider told him that he wanted him to

become part of the Intelligence Bureau of the Guardian's

Office. The Intelligence Bureau became the Information Bureau

Bureau [sic] in July 1973. In mid-June 1973, Mr. Meisner and his

wife Patricia were accepted for the Guardian's Office and

moved to the District of Columbia to take courses in prepara-

tion for assuming their duties as officials of that orgainiza-

tion. Upon becoming an officer of the Intelligence Bureau,

Mr. Meisner was instructed by the defendant Duke Snider that

that Bureau was in the forefront of the Guardian's Office

that is, it dealt with safeguarding the environment within

which Scientology existed by locating, removing and rendering

harmless all thore perceived to be enemies of Scientology,

This was accomplished by infiltration, theft of documents and

 

- ----------------------------------------------------------------------

• 3 -

 

covert operations. Following a week of training in Guardian's

Office procedures and policies in the District or Columbia,

Mr. Meisner was sent to Los Angeles, California, for more

intensive training in the Intelligence (Information) Bureau.

From July 1973 until October 1973, Mr. Meisner's training

in the Information Bureau of the Guardian's Office in Los

Angeles, California, included intensive courses in administra-

tive procedures, policies and practices of the Information

Bureau, as well as the Guardian's Office as a whole. These

included courses on the preparation of documents, such as

reports, "CSWS" (completed staff work), 2/ "programs," (later

denominated "Guardian Program Orders") "projects," "Guardian

Orders," and daily Intelligence reports. He also learned

the routing and format required in the preparation of documents.

Mr. Meisner was taught that strict adherence to the chain

of command and seniority within the organizational structure

- ---------

21 A "CSW" (completed staff work) is a request to a senior official for approval or disapproval of proposed action.

- ----------------------------------------------------------------------

• 4 -

 

was of paramount importance in the day-to-day operations of

the Guardian's Office, and more specifically the Information

Bureau. Mr. Meisner was Instructed that the routing placed

on each written document followed strictly that chain of

command so that each memorandum, report, etc., went to the

appropriate persons for approval and/or information. In a

clinical setting, Mr. Meisner also learned to conduct covert

investigations, surveillances "suitable guise" investiga-

tions, 3/ the recruiting and supervising of covert agents,

the placing of these agents in organizations that were to he

infiltrated, the theft of documents, and other overt and

covert intelligence gathering techniques. The defendant

Gregory Willardson, among others, supervised him in the

these areas. For a three-week period Mr. Meisner also cross-

filed memoranda and other [sic] covertly and overtly obtained

documents of interest to Scientology. He thereby became

intimately familiar with the sophisticated filing system

 

- ---------

3/ A "suitable guise" investigation is one where the investigator assumes a false or misleading identity in order to gain information otherwise unavailable to him.

- ----------------------------------------------------------------------

• 5 -

 

maintained by the Guardian's Office and its Information

Bureau. The absolute necessity of correctly labelling and

filing all documents obtained and kept by the Information

Bureau was emphasized to Mr. Meisner. Strict adherence to

these policies was mandated to assure that the Information

Bureau and the Guardian's Office functioned in a proper and

efficient manner.

In November 1973 Mr. Meisner returned to the District of Columbia as Branch II Director of the Information Bureau.

In that position he was responsible for internal security

matters. These included both the physical security of the

premises of the local Guardian's Office as well as the handl-

ing of all dissident and disaffected Scientologists. with

regard to the latter, his duties included obtaining personal

information which would prevent them fron becoming a nuisance

to Scientology. In January 1974, the Guardian World-Wide

Jane Kember elevated Mr. Meisner to the position of Assistant

Guardian for Information in the District of Columbia (AG I DC)

In his new post, Mr. Meisner was responsible for all overt

and covert intelligence investigations and operations. This

 

- ----------------------------------------------------------------------

 

6

included the implementation of all Guardian orders, programs,

and projects within the District of Columbia applicable to

the Information Bureau, as well as overall supervision of

all covert operatives in private and governmental agencies.

Until March 1974, the defendant Duke Snider was Mr. Meisner's

immediate supervisor. At that time, the defendant Snider

was Assistant Guardian for the District of Columbia (AG DC)

the highest position in the local Guardian's Office.

 

II.

Organizational Structure of the Guardian's Office

As a result of his intensive training in the Guardian's

Office as well as having held high positions within the

Information Bureau Mr. Meisner became thoroughly familiar

with the organizational structure of the Guardians Office

and its bureaus, both nationally and internationally. _Govern-

ment Exhibit No. 1A_ is a chart showing the organizational

structure of both the World-Wide and United States Guardian's

offices. At all times material to the indictment, the Guard-

 

- ----------------------------------------------------------------------

• 7 -

 

ian's Office had World-Wide headquarters at St. Hill Manor

in East Grinstead, Sussex, England; United States headquarters

in Los Angeles, California; and a local office in the District

of Coluubia and some thirty other cities throughout the

United States. 4/ Each of the Guardian's Offices was con-

posed of five bureaus: Information (prior to July 1973

known as the Intelligence Bureau), Public Relations, Legal,

Finance, and Social Coordination. A sixth bureau not shown

on _Government Exhibit No. 1A_ was known as the Services Bureau.

Each bureau was headed both at the World-Wide and national

level by a Deputy Guardian. At the local level each bureau

was headed by an Assistant Guardian.

At all times material to the indictment, L. Ron Hubbard

was, by virtue of his role as the founder and leader or

Scientology, overall supervisor of the Guardian's Office.

 

- ---------

4/ Including: New York City; Philidelphia, Clearwater,

Florida; Miami; Chicago; Detroit; St. Louis; Houston; Denver;

Seattle; San Diego; San Francisco; Sacramento, California;

Hawaii; I.as Vegas; Los Angeles; Advanced Organization of Los

Angeles; American Saint Hill Organization (Los Angeles);

Portland, Oregon; Mexico City (which is under the jurisdic-

tion of the United States Guardian's Office).

 

- ----------------------------------------------------------------------

 

8

His wife, the defendant Mary Sue Hubbard, held the titles of

"Controller" and "Commodore Staff Guardian" (CSG) and, as the

second person in the hierarchy of Scientology, had duties

which included supervision of the Guardian's Office. Jane

Kember held the title of "Guardian World-Wide" (GWW) and headed

the daily operations of all Guardian's Offices, reporting

directly to the defendant Mary Sue Hubbard who in turn reported

directly to L. Ron Hubbard. The Deputy Guardian for Informa-

tion World-liide (DG I WW) was Morris Budiong, also known as

Mo Budlong (hereafter Mo Budlong). He supervised all

Information Bureaus around the world and reported

to Jane Kember. The defendant Henning Heldt was the Deputy

Guardian for the United States (DG US) supervising all Guard-

ian's Offices in the United States. He reported directly to

Jane Kember.

_Government Exhihit No. 1B_ is an organizational chart of

the Information Bureau in the United States from November

1973 until January 1976 when it was reorganized. The defendant

Duke Snider was Deputy Guardian for Information in the United

States (DG I US) from March 1974 until January 1975, a position

 

- ----------------------------------------------------------------------

9

thereafter held by the defendant Richard Weigand. Beginning

in January 1975 and at all other relevant times charged in

the indictment, the defendant Snider was Deputy Deputy Guardian

for the United States (DDG US) and in that capacity was the

defendant Heldt's top assistant. In October 1975, the defendant

Gregory Willardson became the Deptuty Deputy Guardian for Infor-

mation U.S. (DDG I US). Prior to that date he had held the

position of Branch I Director U.S. (BR I DIR US). The defend-

ant Cindy Raymond was the Collections Officer for the United

States (COLL OFF US). She was responsible for the overt, and

covert data collection for the Information Bureau.

_Government Exhibit 1C_ is an organization chart of the

Information Bureau in the United States after its reorganiza-

tion in January 1976. Following the removal of the defendant

Richard Weigand from the position of Deputy Guardian for

Information U.S. on approximately May 15, 1977, that postition

was assumed by Brian Andrus until June 16, 1977, and there-

after by the defendant Gregory Willardson. From January 1976

until May 1977, Mr. Willardson held the position of Deputy

Deputy Guardian Information U.S. (DDG I US). For the period

 

- ----------------------------------------------------------------------

 

10

January 1976 to June 1976, Mr. Willardson also held the

position of National Secretary for the Information Bureau U.S.

(NATL SEC US). 5/ From June 1976 until August 1976 the

position of National Secretary was held by Michael Meisner,

who was succeeded in September 1976 by the defendant Cindy

Raymond.

Government Exhibit No. 1D is an organizational chart of

the Information Bureau in the District of Columbia. From

January 1974 until June 1976, Mr. Meisner held the position of

Assistant Guardian for Information in the District of Columbia

(AG I DC). Immediately under him was the defendant

Hermann who held the position of Information Branch I Director

from January 1974 until March 1975. The defendant Hermann,

using the alias "Mike Cooper," subsequently held the position

of Southeast U.S. Secretary (SEUS SEC) from January 1976

until March 1977 when he was succeeded by Brian Andrus.

 

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5/ That was commonly reffered to in Scientology as a

position "held from above" or "HFA" both of which appear on

the routing portion of certain documnets and which connotes

that an individual ia assuring the responsibilities of more

than one position at the same time.

 

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11

(See Government Exhibit No. 1C, supra.)

The routing on each document prepared within the Guard-

ian's Office of the Church of Scientology, and its under-

lying bureaus, tracks the organizationial charts. (Government

Exhibits Nos. IA-ID.) Thus, in the routing portion of each

document is the abbreviation of each of the positions held

by the Persons who were to receive the particular documents,

as well as that of the author of the document. (See, e.g.

Government Exhibit 14, discussed at page 48, infra.

From