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				      200
						       
	that he did not know how the FBI had connected "John M.
	Foster" to Michael Meisner.  He suggested, however, that they
	might have been able to locate his former apartment house and
	have his photograph identified by a tenant. 145/ On the
	evening of August 30, the defendant Weigand contacted Mr.
	Meisner and requested him to come to his office, which had
	since been moved to a warehouse in Glendale, California. In
	the presence of the defendant Hermann and Assistant Guardian
	for Information in Clearwater, Florida, Joe Lisa, he informed
	Mr. Meisner of the outstanding warrant for his arrest, and
	instructed him to sever all outward connections to the
	Guardian's Office. He told him that the defendant Hermann
	would assist him in moving out of the Weigand residence into
	a motel. He also removed him from the position of National

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

	145/ Handwriting expert James Miller concludes that it
	is "probable" that the signature "Dick" was written by the
	defendant Weigand, and that the initials next to the title "DG
	US" on the August 30 and September 2 letters were written by
	the defendant Heldt.  Mr. Meisner recognizes the signature
	of the defendant Weigand and the initial of the defendant
	Heldt.

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					  201

	 Secretary for the United States. Mr. Meisner was given funds
	 for the motel.  With the defendant Hermann's assistance, Mr.
	 Meisner moved to the RegaLodge on 200 West Colorado Boulevard,
	 in Glendale, where he registered as "Jeff Burns". On
	 September 1, Mr. Meisner moved to the Bon Air Motel at 1727
	 North Western Avenue in Los Angeles, where he stayed until
	 September 8. He registered there as "Jeff Marks." During
	 that time, the defendant Hermann/Cooper ordered Mr. Meisner
	 to change his appearance. (Government Exhibit No. 125.) 146/
	      In a letter dated 3 September 1976 the defendant Weigand
	 notified the defendant Hermann/Cooper that the defendant
	 Heldt had issued new orders relating to "Jeff Murphy" - Mr.
	 Meisner's alias at the time. (Government Exhibit No. 126.) 147/

- --------------
		
	146/ Government Exhibit No. 125 was seized by Special
	Agent Brunson from a file cabinet outside the office of the
	defendant Raymond in Room 15 at the Cedars Complex. Mr.
	Meisner was ordered to change his appearance so as to create
	"the image of an aging guy wanting to look hip as a means of
	regaining his youth a bit," to wear a "mod wardrobe," to
	shave his head, to wear contact lenses, to have a tooth capped,
	to lose or gain some weight, and to wear earth shoes to
	change his posture.

	147/ Government Exhibit No. 126 was seized by Special
	Agent Brunson from a file cabinet outside the defendant
	Raymond's office at the Cedars Complex.

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					  202

	   The defendant Weigand suggested that Los Angeles was a better
	   place to hide Mr. Meisner since it was "a huge city and he
	   can get lost here very successfully," while still being close
	   to the Guardian's Office.  He directed the defendant Hermann/
	   Cooper to give this matter "top priority and lets [sic] get it
	   done." 148/
		On September 10, 1976, Mr. Meisner moved to the Westgate
	   Hotel located at 445 South Western Avenue in Los Angeles.  At
	   midnight, as a result of new developments in the District of
	   Columbia, Mr. Meisner was moved by the defendants Willardson
	   and Hermann/Cooper to the Wilshire Dunes Motel at 4300 Wilshire
	   Boulevard, also in Los Angeles.  He registered at both
	   locations as "Jeff Marks", and stayed at the latter until
	   September 12. Mr. Meisner was then moved by the defendant
	   Hermann-Cooper to the Travelodge at 7370 Sunset Boulevard for
	   one night.  On September 13 and 14, he stayed at the Sunset 8
	   Motel at 6516 Sunset Boulevard. Then, on September 15, he

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

	   148/ Mr. Meisner identifies the handwritten notations
	   on the lower half of this letter as having been written by the
	   defendant Hermann/Cooper.

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				    203

	registered at the Burbank Hotel located in Burbank, California,
	where he remained until early October.  Mr. Meisner paid for
	all of these hotels with Guardian's Office funds supplied to
	him by the defendant Hermann/Cooper who was his immediate con-
	tact.
	    In a September 18, 1976 letter, the defendant Mary Sue
	Hubbard informed the defendant Weigand that she had "at last
	gotten a copy of the warrant" for the arrest of Mr. Meisner.
	She concluded that there was "the need to establish an alibi
	for MM", The defendant Weigand responded to the defendant
	Hubbard's letter on 22 September 1976 in which he expressed
	his belief that her plan would "encounter difficulties" in
	view of the fact that the FBI had the defendant Wolfe's and
	Mr. Meisner's handwriting on the log books of the Courthouse.
	He stated his opinion that establishing an alibi as she bad
	suggested, would "come down to our word(s) against 2 FBI
	agents, cleaners and guards, plus handwriting experts, ear
	experts and possibly fingerprint experts."
	    He concluded that there were two options open:
		      
		      1.  Turn Mike in at the most opportune time

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					   204
		      
		      (when we can get some better prediction of
		      what will be done with him and us, which
		      as you wrote should follow the handling of
		      Silver.)

		      2. Not turn him over. Which means he
		      hides or runs for 5 years at least (that
		      being the statute of limitations.). 149/

	"The worst," he stated "from my viewpoint is that M would get
	5 years in jail and a $2000 fine that being the maximum
	for the action. Also, there would be attempts to get him to
	turn or otherwise implicate us or others in various wrong
	doings." He added that "[i]f the investigation continues I
	expect that more data will be turned up linking us with M's
	and others [sic] actions." He asked the defendant Hubbard to
	send him her views. (Government Exhibit No. 127.) 150/
			   
- -------------------------
		 
	149/ The defendant Weigand's perception in this regard
	was, of course, erroneous.

	150/ Government Exhibit No. 127 was seized by Special
	Agent Brunson from a file cabinet outside the defendant
	Raymond's office at the Cedars Complex.  Mr. Meisner identifies
	the initials next to the words "Info" and "Return" as having
	been written by the defendant Heldt.

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				    205

		The defendant Hermann/Cooper and Mr. Meisner met for
	   some two hours on September 20, 1976. Mr Meisner told the
	   defendant Hermann/Cooper that he was absolutely opposed to
	   leaving the country. (See also Government Exhibit No.
	   128.) 151/ The defendant Hermann/Cooper advised Mr. Meisner
	   that, pursuant to a Guardian's Office directive, a San Diego
	   police lieutenant had made an inquiry through the National
	   Crime Information Center (NCIC) computer to determine the
	   specifics regarding the arrest warrant which had been issued
	   for Mr. Meisner on August 5. The defendant Hermann/Cooper
	   stated that the NCIC check revealed that the Meisner warrant
	   was for the forgery of government identification cards. He
	   told Mr. Meisner that the FBI had contacted the police
	   lieutenant to find out why he had made that inquiry.

- ----------------                
		
	151/ Government Exhibit No. 128 was seized by Special
	Agent Brunson from a file cabinet located outside the defendant
	Raymond's office at the Cedars Complex.  Mr. Meisner identifies
	the handwriting around the caption of the September 21, 1976
	letter, from the defendant Hermann/Cooper to the defendant
	Weigand, as that of the defendant Hermann/Cooper.

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				      206

	    San Diego police lieutenant Warren Young, a member of
	the Church of Scientology, told the FBI that he had made the
	NCIC check because he had arrested Mr. Meisner for a pedestrian
	violation the previous day in San Diego. In fact, Mr. Meisner
	had never been to San Diego.  In a handwritten letter dated
	16 September 1976, the defendant Duke Snider stated to the
	defendant Weigand that "[i]t looks as though AG SD [Assistant
	Guardian for San Diego] has set C of S [Church of Scientology]
	up to be accused of conspiring with this policeman to violate
	the law."  He directed the defendant Weigand to take the
	necessary steps to handle the matter. (Government Exhibit
	No. 129A.) On the same day, the defendant Weigand responded
	to the defendant Snider that, while he did not know whether
	the policeman was "cool", he knew that the police officer was
	a lieutenant who "is on SCN (Scientology] lines". He observed
	that they "have laid a nice false lead for the FBI which
	cant [sic] help but help us while dispersing their investigation.
	This according to reliable sources is one thing that can draw
	an investigation to a quik [sic] close.'' (Government Exhibit No.

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

					207

	129B.) The defendant Snider, in a handwritten notation thanked
	the defendant Weigand and stated that he was "glad to see it
	is under control". 152/
	    On September 28, 1976, Deputy Guardian for Information
	World-Wide Mo Budlong, in a letter to the defendant Weigand
	"Re: Murphy [Meisner]", stated:

		     The answer for this gentleman is to have
		  him depart for some whereabouts wherein he
		  can obtain documents concerning his ability

- ---------------
		 
	       152/ See also Government Exhibit No. 129. Handwriting
	  expert James Miller is "positive" that all of the handwriting
	  on the Snider letter marked Government Exhibit No. 129A is in
	  the handwriting of the defendant Snider.  He is "positive"
	  that the handwritten notation signed "Duke" on Government
	  Exhibit No. 129B is in defendant Snider's handwriting. He
	  also concludes that the handwritten notation signed "Love
	  Cindy", as well as the initials and date next to the "natl
	  sec" entry on Government Exhibit No. 129, are positively in
	  the handwriting of the defendant Raymond.  Government Exhibit
	  No. 129 was also seized by Special Agent Brunson from a file
	  cabinet outside the defendant Raymond's office at the Cedars
	  Complex.
	       In fact, Special Agent Christine Hansen requested the
	  FBI Field Office in San Diego, California, to question police
	  lieutenant Warren Young, and follow the lead, given by him,
	  that Mr. Meisner was in that city.  This false lead diverted
	  the resources of the FBI in the instant investigation to yet
	  another city.

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					208
	  
		  to drive but does not have to give details
		  of his life history, if you know what I
		  mean, to obtain the documents.

		     Then he should find some out of the way
		  large city where he can rent himself a quiet
		  place to do research or some such for an
		  article or a book or whatever.

		     He can then live and work there for some
		  time undisturbed.

		     Once Silver has completed his cycle we will
		  have some idea of which way things are moving
		  and we will be able to ascertain Murphy's next
		  move, but for the time being he should keep
		  himself fairly exclusive.

		     Silver should admit what he did but
		  let his representative do his talking for him
		  and should not volunteer any further informa-
		  tion.

		     To achieve this of course Silver and his
		  representative will have to push for the big
		  event to occur as soon as possible.

		     Once the Silver event is over we can
		  reassess the whole cycle in light of the
		  data that comes up, which you will have
		  to work out some way of reporting to me.

		     _If any of the above is not clear,
		  please ask immediately as I don't want
		  any confusions on what has to be done_.
		  (Emphasis added.)

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					  - 209 -
		  
	(See Government Exhibit No. 131.) 153/
	

			 E. The Guardian's Office Gives
			      the FBI and the Grand Jury
			      False Handwriting Exemplars.

	    In late September 1976, FBI Special Agent Hansen
	requested the Church of Scientology in Washington, D.C., to
	supply the government investigators with exemplars of Mr.
	Meisner's handwriting. In Los Angeles, California, the
	defendant Raymond met with Mr. Meisner to discuss what should
	be given to the FBI. She informed Mr. Meisner that it had
	been decided to give false exemplars to the FBI. In a
	letter dated September 30, 1976, to the defendant Weigand,
	the defendant Mary Sue Hubbard stated that she was aware that
	the FBI had requested Meisner handwriting exemplars and that
	those would be compared to the log books of the buildings
	which Mr. Meisner had entered.  She, thus, requested the defend-

- ------------------
		
	153/   Government Exhibit No. 131 was seized by Special
	Agent Henry L. Williams from the desk of the defendant Cindy
	Raymond at the Cedars Complex. It was inventoried and initialed
	by Special Agent Raymond Mislock.

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					  210

	ant Weigand to furnish her with a list of all the buildings
	which Mr. Meisner had illegally entered. The defendant
	Hubbard stated in that letter that she was, as of that date,
	fully aware of the existence of an arrest warrant for Mr.
	Meisner. (Government Exhibit No. 132.) 154/
	    In order to respond to the defendant Hubbard's inquiry
	the defendant Raymond met with Mr. Meisner to obtain from
	him a list of all the buildings he had illegally entered in
	the District of Columbia and the details of those entries.
	She then relayed that information to the defendant Weigand
	who responded to the defendant Hubbard's request in a late
	October 1976 letter. (Government Exhibit No. 132 at page
	1.)  In that letter, the defendant Weigand informed the defend-
	ant Hubbard that the buildings illegally entered by Mr.
	Meisner included the Department of Justice, the Internal
	Revenue Service, the Office of International Operations, as

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

	154/ Government Exhibit No. 132 was seized by Special
	Agent Raymond Mislock from a file cabinet located in Room 30
	of the Information Bureau at the Cedars Complex.

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					    211

	well as a number of other private and Government build-
	ings. 155/ The defendant Weigand pointed out to the defendant
	Hubbard that he was in the process of "working out a full
	cover that would cover the log book sign-ins along the lines
	of they were done to reveal the insecurity within the govern-
	ment for a series of articles that M [Meisner] would be
	writing as exposes." 156/

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

	155/ The other buildings listed in that letter include
	the Post Office, the Labor Department's National Office, the
	Federal Trade Commission, the Department of the Treasury,
	the U.S. Customs Building, the Drug Enforcement Administration,
	the American Medical Association's law firm offices in
	Washington D.C., and the offices of the law firm representing
	the St. Petersburg Times, also in Washington, D.C. Handwriting
	expert James Miller concludes that it is "highly probable"
	that the signature "Dick" at the end of the October 8 letter
	was written by the defendant Weigand.  Mr. Meisner, himself,
	recognizes that signature as in the handwriting of defendant
	Weigand, and explains that the initials "DW/jf" to the left
	of the signature are those of the defendant Weigand and his
	communicator (secretary) Janet Finn.

	156/ For another series of letters to the defendant Mary
	Sue Hubbard discussing the District of Columbia incident and
	the Wolfe/Meisner situation, see Government Exhibit No. 130,
	which includes a "CSW" from Mr. Meisner to the defendant
	Hubbard as well as memoranda from the defendant Hermann/Cooper
	to the defendant Hubbard.  Mr. Meisner states that the defendant
	Hermann/Cooper's handwriting appear in the following locations:
	the word "secret" at the top of page one, and the signature on
	the last page. Government Exhibit No. 130 was seized by
	Special Agent Brunson from a file cabinet outside the defendant
	Raymond's offices.

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					     212

	On October 8, 1976, FBI Special Agent Hansen served
	upon Assistant Guardian for the Legal Bureau in Washington,
	D.C.  Kendrick "Rick" Moxon a Grand Jury subpoena for all
	original known handwriting exemplars of Michael Meisner and
	the employment application and personnel records of Mr.
	Meisner in the possession of the Church of Scientology.
	That subpoena was returnable on October 14, 1976. Assistant
	Guardian for Information in the District of Columbia Richard
	Kimmel immediately notified the defendant Hermann/Cooper
	of the service of that subpoena. The defendant Hermann/Cooper
	then notified the defendants Heldt and Weigand in an October
	9, 1976 memorandum. (Government Exhibits Nos. 133 and 134 at
	p. 1.) 157/ In that same memorandum, the defendant Hermann/
	Cooper requested approval from the defendants Heldt and Weigand
	for a mission by Randy Windment, the real name of Bruce
	Raymond, the National Operations Officer for the Information

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

	157/ Government Exhibits Nos. 133 and 134 were seized by
	Special Agent Brunson from a file cabinet in room 10 at the
	Cedars Complex.

- ---------------------------------------------------------------------
					    
					    213

	Bureau in the United States. Mr. Windment/Raymond was to go
	to the District of Columbia to check the security of the
	Guardian's Office and the covert operatives who were still
	functioning--namely the defendant Sharon Thomas (also known
	as "Judy") and Ms. Nancy Douglass (also known as "Pitts").
	Both the defendants Weigand and Heldt signed their approval
	of that mission. (See Government Exhibit No. 134.) 158/
	    On October 14, 1976, District of Columbia Assistant
	Guardian for the Legal Bureau Kendrick "Rick" Moxon, submitted

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

	158/ Handwriting expert James Miller concludes that it
	is "probable" that the handwritten initials next to the words
	"mission approved" on page one of Government Exhibit No. 134
	were written by the defendants Heldt and Weigand.  Similarly,
	Mr. Miller finds it "probable" that the initials and date
	next to the title "DG Info US" on page one are in the hand-
	writing of the defendant Weigand, and the initial next to
	item 2 (vital targets) on page two is probably in the
	handwriting of the defendant Heldt. Mr. Meisner identifies
	those initials as in the handwriting of the defendants Weigand
	and Heldt respectively, as he does all of the handwriting on
	page three as that of the defendant Hermann/Cooper. Mr. Meisner
	also identifies the signature "Mike" at page one of Government
	Exhibit No. 134 and the handwriting on pages three and five
	of Government Exhibit No. 133 as that of the defendant
	Hermann/Cooper.

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					  214
	
	an affidavit with nine pages of handwritten material. In
	the affidavit, he stated that he was unable to locate a
	personnel file for Mr. Meisner, and that the nine pages of
	appended handwriting were those of Mr. Meisner.  However, as
	the defendant Raymond stated to Mr. Meisner in a meeting in
	late September 1976, Mr. Moxon had been directed to supply
	the government with fake handwriting samples in lieu of Mr.
	Meisner's true handwriting exemplars.


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


	    In early October 1976, the defendant Raymond decided
	that it would be best for Mr. Meisner to move from his motel
	to an apartment, thereby reducing the expenses of the Guardian's
	Office.  Paul Poulon, the Collections Officer for the Informa-
	tion Bureau, rented an apartment for Mr. Meisner at 444 South
	Burlington Street in Los Angeles, California, to which Mr.
	Meisner moved on October 6.   Mr. Meisner, at that time, was
	spending most of his days at local libraries doing research

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					 215

	  on the security of government buildings, in order to support
	  one of the cover-up stories, _viz._, that he had entered various
	  government buildings to do an expose on the lack of security.
	  The defendant Raymond and Mr. Meisner met approximately
	  twice a week to discuss the ongoing cover-up. Mr. Meisner
	  requested of the defendant Raymond that she set up a meeting
	  between him and the defendant Snider as soon as possible.
	  Mr. Meisner had been anxious to communicate his views regarding
	  the cover-up in the current District of Columbia situation
	  with someone in a position of higher authority.  He thus
	  selected the defendant Snider because of his high position
	  in the Guardian's office as well as the fact that he had
	  known him for a long time. Indeed, the defendant Snider
	  had recruited Mr. Meisner for the Information Bureau of the
	  Guardian's office.  On October 28, the defendant Snider and
	  Establishment Officer Peeter Alvet met with Mr. Meisner at
	  the Burlington Street apartment.  Mr. Meisner told the defend-
	  ant Snider that he was concerned about the length of time
	  that the cover-up operation was taking.  The defendant Snider

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

					  216

	  cautioned Mr. Meisner that "we didn't want him doing something
	  too fast as we wanted to see what happened with Silver [Wolfe]
	  first, the threat of a Grand Jury." Government Exhibit No.
	  137, is a letter dated 4 November 1976 in which the defendant
	  Snider wrote the defendant Heldt of the outcome of his meeting
	  with Mr. Meisner. 159/ In it, the defendant Snider stated
	  that Mr. Meisner "seemed to finally realize . . .  that his
	  actions would ultimately seriously effect [sic] the church
	  . . ."  Mr. Meisner had expressed concern for his wife and
	  his parents as well as for the fact that he was being kept
	  almost totally uninformed of Guardian's Office actions on
	  the ongoing cover-up. The defendant Snider' assured Mr.
	  Meisner that he would be briefed on all decisions taken by
	  the Guardian's Office and that his views would henceforth be
	  considered.  He assured Mr. Meisner that the defendant Mary
	  Sue Hubbard was concerned about the situation and was fully

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

	      159/ Government Exhibit No. 137 was seized by Special
	  Agent Brunson from a file cabinet located outside the office
	  of the defendant Raymond.
- --------------------------------------------

					   217

	   aware of it, and that anything Mr. Meisner wanted to express
	   to the defendant Hubbard would be sent directly to her. At
	   the conclusion of the meeting, the defendant Snider asked
	   Mr. Meisner to continue doing work for the Information Bureau.
	   In his letter to the defendant Heldt reporting on that meeting
	   (Government Exhibit No. 137), the defendant Snider concluded
	   that Mr. Meisner "_is not a traitor and will cooperate_" with
	   the Guardian's Office. (Emphasis added.)
		Three days later, in a letter to defendant Weigand the
	   defendant Hubbard added yet another dimension to the cover-up
	   plan. She suggested that the following scenario be considered:
	   Mr. Meisner (whom she refers to by the letter "H" for the code
	   name Herbert which Mr. Meisner had assumed since going under-
	   ground after the issuance of his arrest warrant) was having
	   marital trouble and was jealous that his wife was being more
	   productive than he. Therefore, he took it upon himself to
	   organize the burglaries of government buildings and thefts of
	   documents from those buildings to prove that he too could
	   produce for the Guardian's Office.  She instructed the defend-

- ----------------------------------------------------------------------                        
					   218

	ant Weigand that "[i]f this seems workable" then Mr. Meisner
	should be ordered to work on the details of this aspect of
	that plan. (Government Exhibit No. 135.) 160/ In response
	to an order that he received from his "senior", the defendant
	Heldt directed the defendant Willardson to contact the defend-
	ant Wolfe and instruct him to "push his lawyer to get the
	scene handled." (Government Exhibit No. 136.) 161/
	     On November 5, pursuant to the decision made during
	his meeting with the defendant Snider, Mr. Meisner was moved
	by Mr. Paul Poulan to a new apartment located at 840 South
	Serrano Street in Los Angeles, California. Mr. Meisner

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

		 160/ Government Exhibit No. 135 was seized by
	 Special Agent Brunson from a file cabinet in Room 10 in the
	 Information Bureau at the Cedars Complex.  Mr. Meisner identi-
	 fies the handprinting on that letter above the typewritten
	 words as being in the handwriting of the defendant Raymond.
	 He further recognizes the initial next to the title "DG US"
	 as having been written by the defendant Heldt.

		 161/ Government Exhibit No. 136 was seized by Special
	 Agent John C. Kammerman from Room 15 in the Information Bureau
	 at the Cedars Complex. It was inventoried and initialed by
	 Special Agent Michael Ray Napier.


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					219

	rented that apartment in the name of "Jeff Marks" with funds
	provided him by Mr. Poulon.  Mr. Meisner resided at that
	location until the end of April 1977. On November 26, Mr.
	Meisner wrote a lengthy letter to the defendant Mary Sue
	Hubbard explaining to her the extent of his predicament.
	Government Exhibit No. 138.) 162/ In that letter, he
	expanded upon the various aspects which she had proposed in
	her October 31 letter to the defendant Weigand (Government
	Exhibit No. 135). Mr. Meisner told the defendant Hubbard,
	that regardless of what cover story was eventually used to
	handle the ever expanding Federal investigations in the
	District of Columbia, it would be necessary to explain
	where he had been living since June 11 when he was confronted
	by the FBI in the United States Courthouse. He explained
	that, in any event, the FBI would want to know how Mr. Meisner
	was able to support himself during all the time that be was
	in hiding.  Thus, Mr. Meisner told the defendant Hubbard that

- -------------
	      162/ Government Exhibit No. 138 was seized by Special
	  Agent Kammerman from a file cabinet in Room 15 in the
	  Information Bureau at the Cedars Complex. It was initialed
	  by Special Agent Napier.

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					   220

	   he and the defendant Raymond had already worked out a plan,
	   whereby Mr. Meisner would tell the FBI that he had been
	   living with a friend in Canada. Mr. Meisner wrote that
	   Canada was selected because the FBI had no authority to
	   conduct investigations there. However, he also stated that
	   a cover would have to be created in Canada. He concluded in
	   a postscript that "in my opinion, no matter what story we
	   use, the longer we wait to implement it, the less believeable
	   it will be and the more that the government will be inclined
	   to believe that the Church is behind it."
	       On November 30, the defendant Mitchell Hermann (a/k/a
	   Mike Cooper) wrote a briefing memorandum outlining step-by-step
	   the activities in which the defendant Wolfe (Silver) and Mr.
	   Meisner (Herbert/MM) had been involved in the District of
	   Columbia, and the cover story which had been prepared since
	   their encounter with the FBI. The defendant Hermann/Cooper
	   explained that the defendant Wolfe and Mr. Meisner had been
	   involved, from 1974 through June 1976, in the burglaries of
	   Government offices and thefts of Government documents in

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

					 221

	 Washington, D.C. In the spring to summer of 1976, they had
	 directed their attention to the office of Assistant United
	 States Attorney Nathan Dodell in the United States Courthouse
	 in Washington, D.C. It was there, on June 11, 1976, that
	 they were confronted by the FBI. The defendant Hermann/Cooper
	 stated that on June 12, Mr. Meisner had come to Los Angeles,
	 where over the next few days a cover-up story and plan was
	 prepared to contain and terminate the FBI investigation. On
	 June 30, the defendant Wolfe was arrested by the FBI and
	 subsequently gave the previously prepared cover-up story to the
	 FBI and the Office of the United States Attorney for the
	 District of Columbia. Then, on July 28, the defendant Wolfe's
	 case was referred to a grand jury for investigation.  On
	 August 5, he pointed out, a sealed warrant had been issued for
	 Mr. Meisner.  He concluded that "an overall cover story for
	 MM and Silver is being put together by Natl Sec to submit
	 uplines for final approval." That briefing memorandum was
	 sent on December 1, 1976, to the Deputy Guardian for Informa-
	 tion World-Wide, via the defendants Heldt and Weigand, with

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					  222


	a copy to the defendant Raymond. (Government Exhibit No.
	139.)  163/   The defendant Raymond sent to the defendant
	
- -------------
	
	163/  Government Exhibit No. 139 was seized by Special
	Agent Kammerman from a file cabinet in Room 15 in the
	Information Bureau at the Cedars Complex. It was initialed
	by Special Agent Napier.  At that time, the defendant Raymond
	held the position of National Secretary for the Information
	Bureau in the United States. Mr. Meisner identifies the
	handwritten word "Secret" at the top of page one as having
	been written by the defendant Hermann/Cooper.
	     During this time Mr. Meisner was undergoing regular
	auditing pursuant to the directive of the defendant Heldt.
	See Government Exhibit No. 140.  Handwriting expert James
	Miller concludes as follows: "positive" that the word
	"handroute" at the top of page one and the notation "cc: DDGUS
	. . . ." in the routing portion also on page one were in the
	handwriting of the defendant Raymond; "positive" that the
	handwritten notation in the upper right-hand portion of page
	two, the 28 November 1976 letter from the defendant Heldt, as
	well as the signature on that page were written by the
	defendants Raymond and Heldt respectively; "positive" that
	the notation to "Cindy" in the upper part of page three was
	written by the defendant Heldt; "positive" that the notation
	"(enemy formula)" at the bottom of page six was written by the
	defendant Raymond; "positive" that the notation "CR: note no
	folders . . . ." two-thirds down on the eleventh page was
	written by the defendant Raymond; "positive" that the notations
	in the left margin were written by the defendant Raymond;
	"positive" that the handwritten routing on the reverse of
	page seventeen and the notation at the top of page eighteen
	were written by the defendant Raymond. Government Exhibit
	No. 140 was seized by Special Agent Brunson from a file
	cabinet in Room 10 of the Cedars Complex.

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					 223

	  Weigand the cover-up plan and story intended to stall the
	  FBI investigation in the District of Columbia (Government
	  Exhibit No. 141 at p. 2 et seq.) 164/  She stated that
	  once the defendant Wolfe's District of Columbia case was
	  resolved, Mr. Meisner (Herbert) would be surrendered by
	  the Church of Scientology and would give the agreed-upon
	  cover-up story which she outlined. That story conformed to
	  the one prepared and approved by the defendants Heldt, Snider,
	  Weigand, and Willardson in mid-June, and given to the defendant
	  Wolfe.  Appended to her letter was a project for the
	  containment of the investigation which was being conducted
	  by the FBI and United States Attorney's Office in the District
	  of Columbia.
	       The defendant Weigand simultaneously informed the defend-
	  ant Mary Sue Hubbard that the cover-up plan had been completed.

- -------------               
	       164/ Government Exhibit No. 141 was seized by
	  Special Agent Brunson from a file cabinet outside Room 15 at
	  the Information Bureau at the Cedars Complex. It was inven-
	  toried and initialed by Special Agent Napier.

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				       224
			
	 He explained that:


			As I see things now:

			1. We turn Herbert in.

			2. He says he did it via an
		   attorney who should check the accuracy
		   of the charge(s).

			3. He says nothing more than
		   guilty.

			4. We establish lines as possible
		   to see if the govt continues its investi-
		   gation of us and if so we hit them with
		   a full scale attack using BI, PR and
		   Legal.

			5. We get the Herbert case super-
		   vised closely by Legal and see that he
		   gets the best treatment possible.

			And that does it.  The key thing
		   being Herbert [Meisner] does not have
		   to get into any cover with the
		   Government . . . . The only complication
		   I can see is that they might try to hit
		   Herb for flight to avoid which needs to
		   be worked out with Legal so that the handling
		   is effective.
	 
	 
	 (Government Exhibit No. 141.) The defendant Weigand sent the
	same information to Deputy Guardian for Information World-

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					  225
					  
	 Wide Mo Budlong. (Government Exhibit No. 142.) 165/


		  G. The Federal Grand Jury Investigation
		  in the District of Columbia Continues
	       
	       On December 15, 1976, the Grand Jury investigation
	 continued before a new Grand Jury of the United States District
	 Court for the District of Columbia with the appearance of
	 Special Agent Christine Hansen. 166/
	       In a briefing paper dated January 7, 1977, the defendant
	 Hermann/Cooper informed the defendant Heldt that the Commodore
	 Staff Guardian, defendant Mary Sue Hubbard, had "approved"
	 a plan identical to the one previously laid out by the

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

	       165/ Handwriting expert James Miller concludes that it
	 is "highly probable" that the writing "Love, Dick" at the end
	 of that letter is that of the defendant Weigand.  Government
	 Exhibit No. 142 was seized by Special Agent Brunson from a
	 file cabinet outside Room 15 in the Cedars Complex. It was
	 inventoried and initialed by Special Agent Napier.

	       166/  As mentioned _supra_, at page 212, a previous Grand
	 Jury of that Court had, in October, issued a subpoena directing
	 the Church of Scientology to surrender the personnel records
	 and exemplars of Michael Meisner's known handwriting.  See
	 also Government Exhibit No. 214 for the Grand Jury docket
	 entry reflecting Agent Hansen's appearance.

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					 226
					 
	defendant Raymond on December 10, 1976. (Government Exhibit
	No. 143.) 167/ In that briefing paper the defendant
	Hermann/Cooper outlined for the defendant Heldt the following
	events: the arrest of the defendant Wolfe; the investigation
	which was being conducted by the FBI and the United States
	Attorney's Office; the cover-up story given by the defendant
	Wolfe; Principal Assistant United States Attorney Carl S.
	Rauh's statement that he did not believe that story; the
	assignment of the investigation to Assistant United States
	Attorney Garey Stark of the Fraud section; the statement by
	Wolfe's attorney "_that the case has been prepared to go to the
	grand jury_" (emphasis added); and the various attempts which 
	were being made by the FBI to locate Mr. Meisner in Washington,

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

	    167/ See page five of Government Exhibit No. 143 and
	 compare to Government Exhibit No. 141 at page 2 et seq.
	 Handwriting expert James Miller concludes that it is "highly
	 probable" that the signature "Love, Mike" at page four was
	 written by the defendant Hermann/Cooper. Mr. Meisner identi-
	 fies that signature, as well as the one on page six, and the
	 handwriting in the routing portion of page one as having
	 been written by the defendant Hermann/Cooper. A copy of
	 Government Exhibit No. 143 was sent to the "CSG", defendant Mary
	 Sue Hubbard, and to the defendant Raymond. Government Exhibit
	 No. 143 was seized by Special Agent Kammerman in a file
	 cabinet In Room 15 of the Cedars Complex.  It was inventoried
	 and initialed by Special Agent Napier.

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					   227

	  D.C. He suggested that research should be conducted to
	  determine if a "guilty plea would then eliminate the grand
	  jury."  He also stated that the defendant Wolfe had been
	  directed not to give any further information beyond the
	  cover-up story prepared for him by the Guardian's Office.
	  (See Government Exhibit No. 143 at P. 5.)
	       On January 23, 1977, the defendant Hermann/Cooper
	  notified the defendants Heldt and Weigand that the defendant
	  Wolfe had a scheduled meeting with the United States Attorney's
	  Office in Washington, D.C.  He suggested that that meeting
	  be used to present "further cover story to them as a possible
	  means of forstalling [sic] a possible grand jury." He added,
	  however, that the "furthr [sic] cover story needs to be
	  elaborated." Thus, he appended to his "CSW" the original
	  story with the additions that were prepared to "dovetail"
	  with it.  (Government Exhibit No. 144.) 168/  In handwritten

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

	      168/   Handwriting expert James Miller has reached the
	  following conclusions: "positive" that the notation "Cindy's
	  copy" on page one, the entire fourteen-line handwritten
	       (footnote continued on next page.)

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					 228

	notations throughout the document, the defendant Raymond
	opposed some of the changes in the cover-up story proposed by
	the defendant Hermann/Cooper,
	   In an appended report beginning at page five of Government
	Exhibit No. 144, the defendant Hermann/Cooper outlined the
	final proposed cover-up story which in fact was given by the
	defendant Wolfe to the United States Attorney's Office, the
	FBI, and later to the United States Grand Jury for the
	District of Columbia.   He included in that report the names
	of restaurants and bars which had earlier been left unnamed.
	One week later the defendant Hermann/Cooper reminded the
	Deputy Guardian for Legal Affairs in the United States Mary

- -------------
	     (footnote continued from preceding page.)

	 notation on page two, and the notations in the right-
	 hand margins of pages three, four and seven, are all in the
	 handwriting of the defendant Raymond.  Mr. Meisner also
	 identifies the notation in the left-hand margin of page one
	 as having been written by the defendant Raymond, and the
	 notation in the upper portion of page 5 as having been
	 written by the defendant Hermann/Cooper. Government Exhibit
	 No. 144 was seized by Special Agent Kammerman from a file
	 cabinet in Room 15 in the Inform-ation Bureau in the Cedars
	 Complex. It was inventoried and initialed by Special Agent
	 Napier.

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					  229
				   
	Rezzonico that "it is still planned to get Silver [Wolfe]
	out here for briefing prior to the meeting" which Wolfe had
	scheduled with the United States Attorney's Office. He
	expressed the defendant Wolfe's concern that the United
	States Attorney's Office would attempt to strike a deal with
	him to become a government witness. (Government Exhibit No.
	146.) 169/
	      During the months of February and March 1977 the cover-
	up preparation by the Guardian's Office and Information Bureau
	slowed considerably due to the failure of the defendant

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

	     169/ During the same period the defendant Hermann/Cooper
	requested Paul Klopper the Legal Branch II Director U.S., to
	research whether the United States Attorney's Office could
	still conduct a grand jury investigation if the defendant Wolfe
	entered a guilty plea. (Government Exhibit No. 145.) Govern-
	ment Exhibit No. 145 was seized by Special Agent Aldrich from
	a file cabinet in the office of the defendant Willardson at
	the Cedars Complex. Government Exhibit No. 146 was seized
	by Special Agent Kammerman from a file cabinet in Room 15 of
	the Information Bureau at that complex. The latter document
	was inventoried and initialed by Special Agent Napier. Mr.
	James Miller, the handwriting analyst, concludes that it is
	"probable" that the signature "Mike" on Government Exhibit
	No. 146 was written by the defendant Hermann/Cooper.  Mr.
	Meisner identifies that signature as that of the defendant
	Hermann/Cooper.


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

					  230
			    
	Mitchell Hermann (a/k/a Mike Cooper) to complete the outstand-
	ing aspects of the cover-up story, and because of the defendant
	Wolfe's waiver of the rule requiring an indictment within
	forty-five days of arrest. 170/  The defendant Raymond and
	Mr. Meisner continued to elaborate upon various portions of
	that cover-up story. The defendants Willardson and Raymond
	assigned Mr. Meisner the task of preparing other covert
	operations and projects. During this period, Mr. Meisner
	continued to be audited three times a week.
	     Towards mid-March, however, Mr.  Meisner became upset
	at the lengthy delays and complained to the defendant Raymond,
	who informed her superiors of Mr. Meisner's dissatisfaction.
	The defendant Weigand notified Mr. Meisner that the defendant
	Hermann/Cooper had been removed from the Information Bureau
	in part for his failure to properly handle the cover-up, and
	was assigned to the Services Bureau.  He was replaced as

- -------------
		
		170/ Rule 4(a)(1) of the _Rules of the United States
	   District Court for the District of Columbia_ provides that
	   indictments are to be returned within forty-five days of any
	   arrest which occurred prior to July 1, 1976.
		
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					 231
		
	cover-up coordinator by the defendant Raymond. Simultaneously,
	Brian Andrus was appointed to replace the defendant Hermann/
	Cooper Southeast U.S. Secretary. 171/ Soon thereafter, Mr.
	Andrus also became Mr. Meisner's case officer.
		On March 27, 1977, the defendant Raymond sent a "CSW" to
	the defendants Heldt and Weigand emphasizing the need for
	action in regard to the defendant Wolfe's and Mr. Meisner's
	situation in Washington, D.C.   She pointed out that she had
	recently been assigned the task of coordinating the cover-up
	and reminded them that the Commodore Staff Guardian, the
	defendant Mary Sue Hubbard, and the Guardian's Office World-Wide
	had ordered the containment of the grand jury investigation.
	(Government Exhibit No. 147.) 172/

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

	      171/ See Government Exhibit No. 147 at page three where
	  the defendant Raymond indicated that the defendant Hermann/
	  Cooper "was badly suppressing the lines and giving no or
	  false information, keeping both Legal and BI in a confusion
	  as to exactly what to do." Government Exhibit No. 147 was
	  seized by Special Agent Brunson from a file cabinet outside
	  Room 15 of the Cedars Complex. It was inventoried and initialed
	  by Special Agent Napier.

	      172/ During the few months prior to March 1977, the
	  defendant Raymond had shown Mr. Meisner much of the
	      (footnote continued on next page.)


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					 232

		      H. The Guardian's Office Cover-Up
			 Moves Into its Final Phase

	In late March, Mr. Meisner wrote to the defendant Heldt
	requesting him to take a more active role in the handling
	of the District of Columbia situation because the delays were
	becoming intolerable.  Mr. Meisner stated that he was prepared
	to return to the District of Columbia and handle the matter
	himself.  Soon thereafter, the defendant Heldt became more
	active in supervising the execution of the cover-up. To
	that end, on April 1, 1977, the defendant Heldt told the
	
- -------------        

		(footnote continued from preceding page.)
	  correspondence within the Guardian's Office concerning ongoing
	  research for the cover-up.  See, e.g., Government Exhibits
	  Nos. 147A and 147B.  Handwriting expert James Miller positively
	  identifies the handwriting of the defendant Raymond on the
	  following pages: page one - the notation "A Rush"; page two -
	  the three-line handwritten notation in the middle of the
	  first line; pages four, five and six - the handwritten
	  notations; page nine - the handwriting at the bottom of the
	  page; page thirteen - all writings in both margins; page
	  seventeen - the handwritten notation in the upper portion of
	  the right margin.  Mr. Miller also positively identifies the
	  initials and date next to the title "DG I US" in the routing
	  portion of page one as being in the handwriting of the defend-
	  ant Weigand. Moreover, Mr. Meisner identifies the initials
	  next to the title "DG US" on that same routing as being in
	  the handwriting of the defendant Heldt.

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					 233
	
	defendant Mary Sue Hubbard that Mr. Meisner was concerned
	about the delays.   He told her that he was now taking a more
	active role in the handling of Mr. Meisner and that he was
	sending the defendant Weigand to speak to Mr. Meisner "to
	cool him off". (Government Exhibit No. 148.) (The appended
	handwritten letter explains the coding contained in the
	typewritten one.) 173/ The defendant Heldt then responded to
	Mr. Meisner's earlier letter, stating that he was convinced
	that both the defendant Wolfe and Mr. Meisner should enter
	guilty pleas in the District of Columbia. He also told Mr.
	Meisner that Brian Andrus would keep in constant contact with
	him and inform him of all new developments and solicit his
	views on all future matters.  Heldt also promised Mr. Meisner
	that within six weeks the defendant Wolfe would enter his guilty
	plea and pave the way for Mr. Meisner's surrender to Federal
	authorities in Washington, D.C. Mr. Andrus handed that letter
	      
- ---------------
	      
	      173/ Government Exhibit No. 148 was seized by Special
	  Agent Brunson from a file cabinet located outside Room 15 in
	  the Information Bureau at the Cedars Complex. It was initialed
	  and inventoried by Special Agent Napier.  Handwriting expert
	  James Miller positively identifies the defendant Heldt as the
	  writer of the entire handwritten letter beginning at page six
	  of this exhibit.

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

					   234

	to Mr. Meisner.
	     On April 6, in a letter to the defendant Heldt, Mr.
	Meisner reviewed the issues which were of concern to him.
	He complained that "the data I had been given was false,
	incorrect, misinformed, etc., and I caved in." He expressed
	relief that the defendant Heldt was now in control of the
	Situation. (Government Exhibit No. 149.) 174/ Mr.
	Meisner also wrote to the defendant Weigand on April 7, 1977,
	suggesting that, since the defendant Heldt had indicated that
	Mr. Meisner would shortly be surrendering in Washington, an
	attorney should be chosen to handle his case. He also
	recommended that an "FSM" be placed in the appropriate govern-
	ment agency to obtain information regarding anticipated action
	by federal authorities. 175/

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

	     174/ Government Exhibit No. 149 was seized by Special
	Agent Aldrich from a file cabinet in the defendant Willardson's
	office in the Cedars Complex.

	     175/ By memorandum dated 12 April 1977, Brian Andrus
	informed the defendant Weigand that Mr. Meisner (Herb) had
	inquired about the delay in receiving a response from the
	defendant Weigand to his letter of 7 April 1977. (Government
		 (footnote continued on next page.)

- ----------------------------------------------------------------------                        
    
				     235

	Mr. Andrus and United States. Deputy Guardian for Legal
	Bureau Mary Rezzonico gave the defendant Heldt's letter to
	Mr. Meisner during a meeting they had at his apartment. At
	that meeting, Mr. Meisner told Mr. Andrus and Ms. Rezzonico
	that he did not believe it was necessary to enter a guilty
	plea.  He preferred to return to the District of Columbia,
	surrender to the authorities, and go to trial putting the
	government to its burden as required by law. Mr. Meisner
	felt that in this manner he could challenge FBI Agent Hansen's

- ---------------
	      (footnote from preceding page.)

	 Exhibit No. 150.)  In a handwritten note on that memorandum,
	 the defendant Weigand responded that he had not as yet read
	 Mr. Meisner's letter, and that he wished to receive Andrus'
	 and Raymond's proposals before responding. The handwriting
	 analyst, Mr. James Miller, concludes that it is "probable"
	 that that notation was written by the defendant Weigand.  Mr.
	 Meisner identifies that notation, and the initials next to
	 the title "DG I US", as having been written by the defendant
	 Weigand.  He also recognizes the signature on the memorandum
	 as that of Mr. Andrus.  Government Exhibit No. 150 was seized
	 by Special Agent Henry Williams in the defendant Raymond's
	 desk at the Cedars Complex.  It was inventoried and initialed
	 by Special Agent Mislock.

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					  236
	
	identification of him as one of the two persons she had
	confronted in  the United States Courthouse in the District
	of Columbia. (See also Government Exhibit No. 151.) 176/
	In a briefing memorandum dated April 15, Mr. Andrus
	stated that Mr. Meisner had thanked him for being willing to
	listen to his point of view.  Mr. Andrus concluded that Mr.
	Meisner was now once again in the fold.  A few days thereafter,
	the defendant Wolfe arrived in Los Angeles, California, where
	he was briefed on various aspects of the cover-up story by
	Mr. Andrus, Ms. Rezzonico, and Paul Pflueger, a Legal Bureau
	official. Mr. Andrus informed Mr. Meisner of the defendant
	Wolfe's presence and of the briefing sessions.
		On April 20, 1977, Guardian World-Wide Jane Kember
	criticized the defendant Heldt for his "sloppy reporting and
	poor co-ordination" of the Wolfe/Meisner District of Columbia
	situation.  She formulated the following "strategy", whereby

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

	   176/ Government Exhibit No. 151 was seized by Special
	Agent Henry Williams from the defendant Raymond's desk at the
	Cedars Complex. It was inventoried and initialed by Special
	Agent Mislock.

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					   237

	the defendant Wolfe would request an immediate meeting with
	the United States Attorney's Office, admit his guilt stating
	the cover-up story, waive his right to a Grand Jury indictment
	plead guilty, and would be "sentenced lightly" as a first
	offender.  Meisner would then surrender and also enter a
	guilty plea based on the cover-up story, giving "an informal
	story on where he had been for the last 7 months", and also
	receive a suspended sentence.  If the United States Attorney's
	Office were to insist on continuing with its Grand Jury
	investigation, then Wolfe would be directed to "refuse to
	testify". Ms. Kember also demanded an explanation for the
	long delay in resolving the Wolfe case. (Government Exhibit
	No. .152.) 177/
	     At the same time, the Commodore Staff Guardian, defendant
	Mary Sue Hubbard, directed the defendant Heldt to begin
	creating a Canadian cover to explain Mr. Meisner's fugitive

- ---------------              
	      
	    177/ Government Exhibit No. 152 was seized by Special
	Agent William R. Stovall from the defendant Heldt's desk at
	the Fifield Manor.  Mr. Meisner identifies the whole letter
	as being in the handwriting of Ms. Kember.

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

					  238

	status without connecting Mr. Meisner to the Church of Scien-
	tology.  The defendant Heldt immediately informed Mr. Andrus
	of the defendant Hubbard's order and charged him with the
	task of putting it into effect. (See Government Exhibit
	No. 153.) 178/

		       I. The Guardian's Office Retrains
			  and Guards Michael Meisner

	     On April 27, Mr. Andrus, following a meeting with Mr.
	Meisner, notified the defendant Weigand that Mr. Meisner was
	so concerned about the slowness of the Guardian's Offices
	actions that Mr. Meisner intended on "leaving for either
	Canada or DC Saturday." (Government Exhibit No. 154.) .179/
	
- ---------------              

	178/  Handwriting expert James Miller positively concludes
	that the defendant Heldt was the writer of the two letters to
	Mr. Andrus contained in Government Exhibit No. 153. That
	exhibit was seized by Special Agent Williams from Room 15 in
	the Information Bureau at the Cedars Complex.  It was
	inventoried and initialed by Special Agent Mislock.

	       179/  Government Exhibit No. 154 was seized by Special
	Agent William R. Stovall from defendant Heldt's desk at the
	Fifield Manor.   Mr. Meisner identifies the signature on page
	five as having been written by Mr. Andrus.
	     On April 28, Mr. Andrus spoke to the defendant Wolfe and
	was informed that it was impossible to withdraw the waiver of
	the rule requiring an indictment within 45 days of arrest.
	(Government Exhibit No. 155.) That exhibit was also seized by
	  Special Agent Stovil from the defendant Heldt's desk.

- ----------------------------------------------------------------------                        
					
					239


	      On April 28, Ms. Rezzonico and Mr. Andrus, together
	with Jim Fiducia, Mr. Meisner's auditor, visited Mr. Meisner
	at his Serrano Street apartment in order to convince him that
	it was not in his best interest to leave Los Angeles and
	return to the District of Columbia on his own. Mr. Meisner,
	however, was adamant that he would leave by April 30 unless
	he received assurances that the Wolfe situation in the District
	of Columbia would be resolved promptly. In a 29 April letter
	to the defendant Heldt summarizing the April 28 meeting, Ms.
	Rezonico stated her conclusion, based upon additional conver-
	sations with the defendants Raymond and Weigand, that there
	were reasons for concern about Mr. Meisner's situation.  She
	also stated that she had been notified by the Assistant
	Guardian for the Legal bureau in the District of Columbia,
	Kendrick "Rick" Moxon, that the defendant Wolfe's attorney
	had reported that the United States Attorney's Office "had
	made 'noises' about the Grand Jury." (Government Exhibit
	No. 156.) 180/  That same day, the defendant lieldt informed

- ---------------
	       
	       180/  Government Exhibit No. 156 was seized by Special
	 Agent Stovall from the defendant Heldt's desk. Mr. Meisner
	 recognizes Ms. Rezzonico's signature at page three of that
	 letter.

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					 240

	the defendant Mary Sue Hubbard that "Herb [Meisner] is threat-
	ening to return to DC and handle the scene as he sees fit if
	the waiver is not withdrawn this week."  He told her that he
	was ordering the Information Bureau to "arrange to restrain
	Herb and prevent him from leaving, and to guard him so that
	he does not do so." (Government Exhibit No. 157.) 181/
	The defendant Heldt then directed the defendant Weigand and
	Ms. Rezzonico that "Herb is to be restrained and guarded.
	He is not to be permitted to leave."  He further directed
	that the Canadian cover be set up within ten days even if it
	required trips to Canada, and that the Legal Bureau should
	assume much closer supervision and control over the defendant
	Wolfe and direct him to conclude his case in the District of
	Columbia promptly. (See Government Exhibit No. 158.) 182/

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

	      181/ Handwriting expert James Miller concludes that the
	 entire letter was written in the defendant Heldt's handwriting.
	 The letter was seized by Special Agent Stovall from the
	 defendant Heldt's desk at the Fifield Manor.

	      182/  Government Exhibit No. 158 was seized by Special
	 Agent Hillman from Room 15 in the Information Bureau at the
	 Cedars Complex. It was inventoried and initialed by Special
	 Agent Gonzales.

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

					     241

	 Mr. James Miller, the handwriting expert, positively concluded
	 that the letter was handwritten by the defendant Heldt.
	       Or. April 29, Mr. Andrus met with Mr. Meisner at Mr.
	 Meisner's South Serrano Street apartment and informed him that
	 from that day on he would be placed under guard. (Government
	 Exhibit No. 159 at p. 4 et seq.)  Mr. Meisner told Andrus
	 that he would not accept the presence of guards.  Mr. Meisner,
	 also made it clear that if he were charged as a fugitive he
	 would not enter a guilty plea.  He complained that his whole
	 situation had been mishandled by the Guardian's Office and
	 had resulted in his becoming a fugitive. He demanded that
	 the defendant Heldt explain to him what action was being
	 taken regarding his case.  At the end, of that meeting Mr.
	 Andrus placed the guards outside Mr. Meisner's apartment.
	 (See 29 April letter to the defendant Weigand.)  That same
	 day, the defendant Heldt reported to the defendant Mary Sue
	 Hubbard that Mr. Meisner was now under guard and that Mr.
	 Meisner had "reacted violently to the arrival of persons to
	 insure he did not blow." He added that he had directed the

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

					  242

	 Information Bureau to locate "a more isolated" apartment
	 where Mr. Meisner could be kept under the watch of "some
	 trustworthy . . . Body Guards".  He also stated that he was
	 sending the defendants Weigand and Willardson to see Mr.
	 Meisner, and "get control" over him. (Government Exhibit No.
	 159.)  According to handwriting expert James Miller that
	 letter was written in its entirety by the defendant
	 Heldt. 183/
	      Pursuant to the defendant Heldt's directive, the defend-
	 ants Weigand and Willardson together with Southeast U.S.
	 Secretary Brian Andrus and three guards, visited Mr. Meisner
	 at approximately 2:15 a.m. on April 30. The defendant Weigand
	 warned Mr. Meisner that he would no longer be permitted to
	 make "demands and threats on the Church,"  and "that he was
	 to start becoming a decent, cooperative, contributing part
	 of the venture and nothing else was to be tolerated." With
	 the guards' assistance,   the defendant Willardson searched

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

	      183/ Government Exhibit No. 159 was seized by Special
	 Agent Daniel P. LeVine from the defendant Heldt's desk at the
	 Fifield Manor.

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

					   243

	Mr. Meisner's apartment and personal property and removed
	any evidence connecting Mr. Meisner to the Church of Scien-
	tology. At approximately 6:30 a.m., the meeting concluded
	"with the guards in charge."  184/   On May 3, 1977, the
	defendant Weigand forwarded this report to Deputy Guardian
	for Information World-Wide Mo Budlong. Copies were sent to
	"DG US", the defendant Heldt, and "CSG", the defendant Hubbard.
	On May 1, Mr. Andrus gave Mr. Meisner a handwritten dispatch
	from the defendant Mary Sue Hubbard which explained to Mr.
	Meisner that she was aware that he had been placed under
	guard, and that it was being done for his own good and the
	good of Scientology. She promised Mr. Meisner that if he
	followed orders, the guards would be eventually removed. 185/

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

	       184/ For a detailed report of that meeting, see Govern-
	ment Exhibit No. 160. That exhibit was seized by Special
	Agent Frederick S. Hillman from a file cabinet in the defendant
	Raymond's office. It was inventoried and initialed by Special
	Agent Martin A. Gonzalez.
			    
	       185/  See Government Exhibits Nos. 161 and 162 at pages
	 four. The second document is a coded version of the first
	 one.  They were both seized by Special Agent Aldrich from the
	 defendant Willardson's office. Mr. Meisner identifies the
	 signature "Brian" on pages four and eight as having been written
	 by Mr. Brian Andrus.
			    
- ----------------------------------------------------------------------                        

					     244

		 On May 1, at approximately 6 p.m., Brian Andrus, Peeter
	    Alvet, Information Bureau official Chuck Reese and two
	    bodyguards visited Mr. Meisner and told him that he was to
	    be moved to another apartment.  Mr. Meisner refused to leave,
	    threatening to cause a commotion if forced to do so.  The two
	    guards handcuffed him behind his back, gagged him and dragged
	    him out of the building. Outside, they forced him onto the
	    back floor of a waiting car. In the car one of the guards
	    held Mr. Meisner down with his feet. Mr. Meisner was taken
	    to an apartment which he later learned was located at 3219
	    Descanso Drive, in Los Angeles, California. After Messrs.
	    Andrus and Alvet left, three guards remained in the apartment
	    with Mr. Meisner. 186/  On Monday, May 2, the defendant
	    Heldt approved the defendant Raymond's funds requests for Mr.

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

		 186/   This incident is detailed by the defendant Weigand
	    in a 2 May 1977 letter, to Mr. Budlong (Government Exhibits
	    Nos. 161 and 162.) The routing on that letter indicates that
	    copies of it were sent to the defendants Mary Sue Hubbard and
	    Henning Heldt, and to GWW Jane Kember.

- ----------------------------------------------------------------------                        
							 
				     245


	Meisner's guards. (See Government Exhibit No. 163.) 187/
	During the ensuing three weeks, Mr. Meisner, continued to
	be guarded and prevented from leaving his apartment. By May

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

		  187/    In that "CSW", the defendant Raymond requested
	  $202.48 for Mr. Meisner's guards' expenses, including food,
	  and a fine for one of the guard's car, which had been towed.
	  Handwriting expert James Miller positively identifies the
	  handwritten note at the top of page one next to the title "DG
	  US" as having been written by the defendant Raymond.  Mr.
	  Miller further identifies the initial next to Mr. Heldt's
	  title and next to the word "approved" on page two as probably
	  having been written by the defendant Heldt.  Mr. Meisner
	  identifies that initial as having been written by the
	  defendant Heldt. He also recognizes the signature at the
	  bottom of page two and the handwriting on that page as that
	  of the defendant Raymond. Mr. Miller also positively identi-
	  fies the following handwriting on the envelope appended to
	  the end of the exhibit: ."A Rush" - positively written
	  by the defendant Raymond; "Good - disp rec'd. Love H." -
	  positively written by the defendant Heldt; the initial next
	  to the title "DG US" - probably made by the defendant Heldt.
	  Government Exhibit No. 163 was seized by Special Agent Hillman
	  from the defendant Raymond's office at the Cedars Complex.
	  It was inventoried and initialed by Special Agent Gonzalez.
	      An additional request for funding for Mr. Meisner's
	  guards was made by Acting Collections Officer Jim Douglass
	  to the defendant Heldt on May 13, 1977. (Government Exhibit
	  No. 166.) That request included money for food, gas, and a 
	  battery that was stolen from one of the guard's jeeps. Govern-
	  ment Exhibit No. 166 was seized by Special Agent Hillman from
	  Room 15 at the Cedars Complex. It was initialed by Special
	  Agent Gonzales.


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						    246


	5, Mr. Meisner determined that it was in his best interest to
	cooperate with his captors. He corresponded with the defendant
	Heldt in an attempt to resolve his predicament and to have
	the guards removed. 188/ He also accepted auditing. 189/
		On May 13, 1977, the defendant Wolfe entered a plea of
	guilty to a one-count information charging him with the
	wrongful use of a Government seal, in violation of 18 U.S.
	Code, Section 1017, before United States District Judge

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

	     188/ See Government Exhibit No. 164 at P. 3 et seq.
	That exhibit was seized by Special Agent Aldrich from the
	defendant Willardson's office at the Cedars Complex.

	     189/ Meisner's account of the events of the first
	days in May is corroborated by the defendant Weigand in a
	letter to Mr. Budlong, by Mr. Andrus in a letter to the
	defendant Heldt, (see Government Exhibit No. 164), and by
	the defendant Weigand in a letter, dated May 8, 1977 to the
	defendant Heldt. (See Government Exhibit No. 165.) According
	to Mr. Miller, the handwritten letter signed "H" and addressed
	to "Herb", located at page six and seven of Government Exhibit
	No. 164, was written in its entirety by the defendant Heldt.
	Mr. Meisner concurs in that finding. Handwriting expert
	Miller, concludes that the defendant Heldt wrote the note to
	Brian Andrus on the 5 May 1977 letter appended to the Government   
	Exhibit No. 165. Mr. Miller also finds that it is "probable"
	that the defendant Heldt wrote the initial next to the title
	"DG US" on that letter. Mr. Meisner identifies that initial
	as having been written by the defendant Heldt.  Furthermore,
	he recognizes the signature at the end of that letter as
	having been written by Mr. Brian Andrus.


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						247

	Thomas A. Flannery in Washington, D.C. The defendant Wolfe's
	plea specifically involved the June 11, 1976 entrance into
	the United States Courthouse in that city and his use of the
	IRS identification card bearing the name "Thomas Blake".   A
	few days thereafter, Mr. Meisner was informed of this new
	development by Mr. Andrus. By the third week of May, in
	part due to Mr. Meisner's cooperation, his watch was relaxed
	and his guards began to take him out of the apartment. 190/
	At that time, Brian Andrus showed Mr. Meisner  a program

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

	    190/ In a letter dated 13 May, the defendant Willardson
	instructed the defendant Raymond to take control of the
	guards.  He complained that they could not involve any more
	Information Bureau personnel in this matter.  See Government
	Exhibit No. 167. Page four of that exhibit included a weekend
	guard schedule for "Herbert" (Mr. Meisner). It listed the
	following individuals as guards: Jim Douglass, Chuck Reese,
	Peeter Alvet, John Lake, George Pilat, and Gary Lawrence.
	Handwriting expert James Miller concludes as follows: "positive"
	that the first two pages were handwritten by the defendant 
	Willardson; "positive" that the notation on the third page
	from "Cindy" to "Greg" was written by the defendant Raymond;
	and "positive" that the handwritten notation on the last page
	addressed "Dear Cindy" was written by the defendant
	Willardson. Government Exhibit No. 167 was seized by Special
	Agent Hillman from Room 15 at the Cedars Complex. It was
	inventoried and initialed by Special Agent Gonzales.


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					248

	written by DG I WW Mo Budlong which approved the final plan
	for handling the cover-up.  Mr. Andrus told Mr. Meisner that
	Mr. Budlong had decided that Mr. Meisner could not surrender
	to the FBI in Washington, D.C. until the IRS had granted the
	Church of Scientology of California's request for tax exempt
	status.

		    J.  Michael Meisner's First
			Escape from his Guards


	By the end of May, Mr. Meisner was guarded by just one
	person. On May 29, while he was out with his guard, John
	Matoon, Mr. Meisner escaped by jumping into a taxicab. He
	went to the Greyhound Bus Station, and took a bus to Las
	Vegas.  Mr. Meisner did not have much money, but having been
	there previously he knew a motel which he could afford. He
	escaped from his guard because he wanted time to think about
	his predicament and to determine an appropriate course of
	action.  At that time, Mr. Meisner was still committed to
	Scientology, and  did not want to leave the organization
	precipitously.
			
- ----------------------------------------------------------------------                        
					
					249

	     On May 30, Mr. Meisner telephoned the defendant Raymond
	in Los Angeles and requested to speak to either Mr. Brian
	Andrus or Mr. Jim Douglass. Since Mr. Andrus was unavail-
	able, Mr. Douglass spoke to Mr. Meisner. Mr. Meisner refused
	to state where he was staying in Las Vegas until he first
	spoke to defendant Heldt. Therefore, a telephone call was
	scheduled for 8:30 that evening. The defendant Heldt pleaded
	with Meisner to return to Los Angeles and the Guardian's
	Office of the Church of Scientology. 191/ While Mr. Meisner

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

	191/ The defendant Raymond immediately notified her new
	superior, Temporary Deputy Guardian for Information US (T/DG
	I US) Brian Andrus, of Mr. Meisner's telephone call to her
	and of the defendant Heldt's telephone discussion with Mr.
	Meisner that evening. She concluded that "[t]he only thing I
	can think of is that we work a _cover_story_ that he is trying
	to blackmail the Church for money by pretending that the
	Church harbored him for the last months making the Church a
	party to the crime." (Emphasis added.) (Government, Exhibit
	No. 168.)
	     That same day, the defendant  Raymond sent Ms. Mary
	Rezzonico (DG L US) a letter requesting her to brief the
	thirteen people who had had contact with Mr. Meisner and who
	knew he had been harbored by Scientology. ( See Government 
	Exhibit No. 169.) Both documents were seized by Special 
	Agent Williams from a desk in Room 15 in the Information
	Bureau in the Cedars Complex. They were inventoried and
	initialed by Special Agent Mislock. Handwriting Expert 
	James Miller positively identifies the handwriting on pages
	three and five of Government Exhibit No. 168 as having been
	written by the defendant Raymond.


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					    250

	  initially refused, he did agree to meet with Douglass the
	  next day in Las Vegas.
		On May 31, Mr. Meisner met with Mr. Douglass at a
	  prearranged crowded location.  They discussed Mr. Meisner's
	  concerns, and Mr. Douglass urged Mr. Meisner to return with
	  him.  Mr. Meisner refused. By the next morning the Guardian's
	  Office had learned where he had been staying, and he was
	  confronted by information Bureau official Chuck Reese, who
	  insisted that Mr. Meisner return with him to Los Angeles. Mr.
	  Reese represented to Mr. Meisner that the defendant Weigand
	  had been removed from his position as Deputy Guardian for
	  Information in the United States, and had been temporarily
	  replaced by Brian Andrus, who had been Mr. Meisner's case
	  officer. Mr. Meisner first spoke to the defendant Heldt who
	  promised to meet with him that evening if he returned to Los
	  Angeles. Mr. Meisner, still troubled and confused, agreed,
	  nonetheless, to return to Los Angeles
	      That same night, Mr. Meisner and the defendant Heldt
	  met at Canter's Restaurant in Los Angeles. The defendant Heldt

- ----------------------------------------------------------------------                        
					      
					      251
	  
	assured Mr. Meisner that he understood Mr. Meisner's feelings.
	He told him that both L. Ron Hubbard and the defendant Mary
	Sue Hubbard were working on his case and would do everything
	to help him. He explained that while Mr. Meisner would have
	to continue to be guarded, he should consider his guards his
	friends and not his enemies. Mr. Meisner agreed to remain
	with the Guardian's Office. He was driven to his Descanso
	Drive apartment by the defendant Heldt and Mr. Reese. When
	he arrived, Mr. Meisner was met by Mr. Douglass who had
	been waiting to guard him. Mr. Meisner describes the then-
	existing situation as an "armed truce".
	     In the meantime, Brian Andrus, on May 31, had ordered
	the defendant Raymond to find a "secured" place for Meisner
	to stay if and when he returned from Las Vegas. He suggested
	"a place where he could be locked in a room that has no or a
	very small window" and where he would have "no outside
	contact". (Government Exhibit No. 170.) 192/ On June 1,

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

	     192/ Government Exhibit No. 170 was seized by Special
	Agent Williams from a desk in Room 15 at the Cedars Complex.
	It was inventoried and initialed by Special Agent Mislock.
	Mr. Meisner identifies the handwriting notation "changed by
	verbal order" as having been written by the defendant
	Raymond, and the signature "Brian" as having been written
	by Mr. Andrus.


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

					      252



	Mr. Meisner was moved by his guards to in apartment located
	at 327 South Verdugo in Glendale, California. During the
	entire month be continued to be guarded by at least one person.

		     K. The Defendant Wolfe's Sentencing and
			Subsequent Testimony Before the Grand
			Jury in the District of Columbia.

	     On June 10, the defendant Wolfe was sentenced by United
	States District Judge Thomas A. Flannery to a term of probation,
	and was required to perform one hundred hours of community
	service. Inasmuch as he resided in Minnesota, the case was
	transferred both for probation supervision and jurisdiction
	to that state. Immediately following his sentencing, the
	defendant Wolfe was served with a subpoena to appear that
	same afternoon before the United State Grand Jury for the
	District of Columbia which had been investigating the entries
	into the United States Courthouse there.
	     At approximately 1 p.m., the defendant Wolfe appeared
	before the October 1976 Grand Jury of the United States
								  
- ----------------------------------------------------------------------                        

					253

	District Court for the District of Columbia. 193/  He was
	represented by attorney, David Schmidt, Esquire. The defend-
	ant Wolfe was sworn by Grand Jury Foreperson Mildred Chaplin.
	The record was transcribed by an official Grand Jury reporter,
	Ms. Judith Bracegirdle Warner, who states that Government
	Exhibit No. 215 is the complete testimony given by the
	defendant Wolfe on that day.
	    At the time of the defendant Wolfe's appearance, the
	Grand Jury was conducting an investigation to determine
	whether violations of statutes of the United States and the
	District of Columbia had been committed in the District of
	Columbia. The Grand Jury  was attempting to identify the
	individuals who had committed, caused the commision of, and
	conspired to commit such violations. lt was material to its
	investigation for it to determine the reasons for the presence
	of the defendant Wolfe and one "John M. Foster" in the United

- ---------------
	193/ United States District Court Clerk James F. Davey
	states that the records of that court reveal that the October
	1976 Grand Jury had been sworn in on October 13, 1976, and
	was authorized to conduct investigations and hear evidence on
	behalf of the Court on June 10, 1977. Its term did not expire
	until April 1978.
			

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				       254

	States Courthouse in the District of Columbia on May 21, 28
	and June 11, 1976.  The Grand Jury was seeking the reasons
	for the defendant Wolfe's use on May 28 of an identification
	card bearing the last name "Haake", and his use on June 11,
	1976, of counterfeit IRS credentials bearing the name of
	"Thomas J. Blake".  It was also material for the Grand Jury
	to determine whether, while in the United States Courthouse,
	the defendant Wolfe and the individual using the name "Foster"
	had entered the office of any Assistant United States Attorney
	for the District of Columbia, and, if so, whether they had
	unlawfully taken any documents or files located therein.
	Moreover, the Grand Jury wanted to learn whether the defendant
	Wolfe and "Mr. Foster" had photocopied any documents which
	were the property of the Office of United States Attorney
	for the District of Columbia, and the United States of America,
	on photocopying machines within that office. The Grand Jury
	sought to learn from the defendant Wolfe the true identity
	of the individual who had entered the Courthouse with him
	and used the name "John M. Foster".  It also was inquiring into

- ----------------------------------------------------------------------                                  
						255
	  
	the manner in which the defendant Wolfe and "Mr. Foster" had
	obtained the counterfeit and forged IRS credentials which
	they had used to enter the Courthouse. Finally, the Grand
	Jury was attempting to determine whether any other individual
	in the District of Columbia or elsewhere had conspired with,
	aided and abetted, or caused the defendant Wolfe to obtain
	his counterfeit IRS credentials, or assisted him in entering
	the United States Courthouse for the District of Columbia.
	      During his testimony under oath before the federal Grand
	Jury, the defendant Wolfe knowingly made the following false
	declarations regarding the above-mentioned material matters which
	the grand jury was investigating:
				     
				     Statement No. 1

		      Q.  When did you first come to know that
		D.C. Bar Association had a library on the third
		floor of this building?

		      A.  I don't remember exactly the date.

		      Q.  Why did you want to come to this library.

		      A.  _To study._


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

					256



		   Q. To study what?
					 
		   A.   _To learn how to do legal research._

		   Q.   Why did you want to learn to do legal
			research?
				     
		    A. Well, I was planning on going back to
	       Minneapolis to complete or further my studies in
	       music and I thought that in addition to clerical
	       skills that I had that if I could learn to do some
	       legal research that I could perhaps get a better
	       paying, more interesting job to help pay for my
	       school.

		     Q.  Where would you find that job?

		     A.  In Minneapolis, I presume.

		     Q.  Who would hire you in Minneapolis?

		     A.  I don't know. A law firm, perhaps.

		     Q.  Did you embark on this program to learn
	       how to do legal research with the idea in mind of
	       presenting yourself to a Minneapolis law firm and
	       saying, "I can do legal research for you"?

		     A.  Yeah I think so.

		     Q.  You don't know?

		     A.  That's what I had in mind.

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				       257

		   Q.  How did you propose to learn to do legal
	     research in the D.C. Bar library?

		   A.  _Someone was going to teach me._

		   Q. Who was that someone?

		   A. John Foster. (Govertiment Exhibit No.
		   215 at 15-16, 17-18) 194/


		*               *               *


				Statement No. 2

		   Q.  Now, the first night that you were here
	      in the courthouse, did you xerox anything?

		   A. I don't think so, but I don't recall
	      exactly, you know, which night.

		   Q. How long were you here on that first
	       occasion?

		   A.  I don't remember how long exactly.

		   Q. Approximately.

		   A. I don't know.  Guessing, I'd say maybe
	      an hour.

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

	      194/ The underscored portions of the declarations of
	 the defendant Wolfe were material to the Grand Jury and the
	 Indictment charges that the Defendant Wolfe "then and there
	 well knew, were false."


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

				     258
						 

		      Q. Did you go anywhere else but the library
		 that night?

		      A. I don't know. I do know that one or more
		 of the times here I did go to the men's room. Now,
		 whether it was the first night or not that I couldn't
		 recall exactly.

		      Q. Did you have to leave the library to go to
		 the men's room?

		      A. Yes.

			 
			 *              *               *


		      Q.   Apart from going to the men's room, did you
		 go anywhere else in the Courthouse that night?


		      A.  _ I don't think so._

		      Q. From the first to the third floor library
		 and back onto the first floor, and out?

		      A. Right. (Government Exhibit No. 215 at 173, 174.)


			*               *               *

				
				Statement No. 3


		      Q.   Do you recall ever doing any xeroxing
		 on the third floor of this building on any of the
		 three occasions?


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					     259
				

		      A  Yes.


		      *               *               *

				
		      Q. What did you xerox?

		      A.   _Case histories._

		      Q.   Case histories?   What's a case history?

		      A.   Well, a case out of a law book which
			contains cases.


			*               *               *

		      
		      Q.   Did you bring the books from the library
			to the xerox machines?

		      A.   Myself, _yes,_ some of then.

		      Q.   Did Mr. Foster carry books?

		      A.   _Yes._

		      Q.   How many did you carry?

		      A.   Approximately five.
		      
		      Q.   And how many did he carry?

		      A.   Approximately the same.

		      Q.   Were they the same type of books?

		      A.   You mean the same as mine? Yes, I think so.

			*               *               *
- ----------------------------------------------------------------------                        

				260


			Q. And how long did you use the xerox 
		       machine?

			A. Approximately fifteen minutes to a half
		       hour.

			Q.  No longer than half an hour?

			A.  I don't think so.

			Q.  And what did you do when you left?
			

			A.  _Brought the books back, to the library
			and just left._ (Government Exhibit No. 215 at
			179-180, 184-185)


			*               *               *

					 
				Statement No. 4

		     MR. STARK: Let me inform you, however,
		that the grand jury and the U.S. Attorney's
		Office have a joint responsibility to investigate
		criminality that occurs within the District of
		Columbia.

		      Now, you may have made your plea of guilty
		in this case and have been sentenced today but Mr. Foster
		has not. Now, we are investigating Mr. Foster's
		involvement in this and there may come a time when
		Mr. Foster is sitting either in that chair or in 
		the defendant's chair before a petit jury.

		      And your version of what happened on these
		three occasions will aid this grand jury in it's
		determination of what if anything to charge Mr.                                          
		Foster with. Do you understand that?


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						261

		     Q. Now, did you know Mr. Foster by any other
		name?

		      A. _No. I didn't._

		      Q. You only knew him by John Foster?

		      A. _Right._  ( Government Exhibit No. 215 at
		      200-201.) 195/

	    The defendant Wolfe knew that the testimony he was giving
	to the Grand Jury of the United States District Court for the
	District of Columbia on June 11, 1977, was false in all
	material respects. He knew that the individual who had entered
	the Courthouse with him using the name "John M. Foster" was in
	fact Michael Meisner, who at the time of the entries was the
	Assistant Guardian for Information in the District of Columbia,
	He knew Mr. Meisner's address and telephone number in Arlington,
	Virginia, asi well as Mr. Meisner's telephone number at the
	Church of Scientology offices at 2125 S Street, N.W., in


- -----------------                        
			
	195/ The complete transcript of Mr. Wolfe's Grand Jury
	    testimony is submitted to the Court as evidence, and is
	    incorporated as part of this record. See Government Exhibit
	    No. 215.

- ----------------------------------------------------------------------                        
					 
					 262

	 Washington, D.C. The defendant Wolfe had attained employment
	 at the Internal Revenue Service knowing that he was a covert
	 operative for the Guardian's Office of the Church of Scien-
	 tology, and that his purpose for being at the IRS was to
	 have access to Government documents in order to steal them 
	 for the Guardian's Office.  He was aware that the counterfeit
	 IRS credentials had been used by himself and Mr. Meisner to
	 make illegal entries into various Government buildings for
	 the purpose of burglarizing offices and stealing documents
	 and photocopies thereof located therein. He and Mr. Meisner
	 had entered the United States Courthouse on May 21, 28 and
	 June 11, 1976, for the purpose of burglarizing the Office Of
	 Assistant United States Attorney Nathan Dodell and stealing
	 documents from that office.  Indeed, they had accomplished
	 that task on May 21 and 28, 1976. The defendant Wolfe also
	 was fully aware that he and Mr. Meisner had not gone into 
	 the United States Courthouse to use the Library of the Bar
	 Association of the District of Columbia to do legal research,
	 and that Mr. Meisner was not to teach him to do any legal research.


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

				 263

	he knew that they did not, at any time, photocopy law books
	or cases contained in law books which were taken from the
	library but had, in fact, photocopied, with United States
	Government equipment and supplies, United States Government
	documents taken from Mr. Dodell's office. The defendant
	Wolfe further knew that the burglaries of, and thefts of
	documents from, the office of Assistant United States Attorney
	Dodell were pursuant to Guardian Program Order 158. Mr.
	Meisner had fully briefed him on that Guardian's Program Order,
	as well as the orders which he had received from his superiors
	in Los Angeles, California, including the defendants Heldt,
	Weigand, Willardson, Snider, Raymond, Hermann, and Hubbard.
	The defendant Wolfe participated in the preperaton of the
	cover-up story in Los Angeles, California, on June 14, 1976,
	together with the defendants Willardson, Weigand and Mr.
	Meisner. He was repeatedly briefed by Guardian's Office
	officials both in the District of Columbia and in Los Angeles
	regarding the cover-up story and his contrived statements
	to the United States Attorney Office for the District of


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

				   264
					       

	Columbia, Federal Bureau of Investigation, and the Grand
	Jury of the United States District Court for the District of
	Columbia. Indeed, when the defendant Wolfe appeared before
	the Grand Jury on June 10, 1977, he was under specific orders
	from the Guardian's Office of the Church of Scientology,
	including, at one time or another, the defendants Hubbard,
	Heldt, Snider, Weigand, Willardson, Raymond and Hermann, to
	make false material declarations to that Grand Jury for the
	purpose of derailing the Grand Jury investigation and prevent-
	ing that Grand Jury from discovering the actual facts about
	the involvement of the above-named defendants, the Guardian's
	Office of the Church of Scientology in the United States and
	at World-Wide, and Mr. Meisner.   All of the defendant Wolfe's
	testimony before the Grand Jury of the United States District
	Court in the District of Columbia, on June, 10, 1977, including
	the statements quoted above and at counts 25 through 28 of
	the indictment, conformed in detail to the cover-up plan and
	story prepared by the defendant Wolfe, the above-named defend-
	ants and Mr. Meisner. All the false declarations made by the

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

					    265

	defendant Wolfe were material to the Investigation being
	conducted by the October 1976 Grand Jury of the United States
	District Court of the District of Columbia with the assistance
	of the Office of the United States Attorney for the District
	of Columbia.
		      
		      L.  The Defendant Wolfe is Debriefed
			  by the Guardian's Office After his
			  Grand Jury appearance.

	     Immediately following his Grand Jury appearance the
	defendant Wolfe went to the office of the Church of Scientology
	at 2125 S Street, N.W., in Washington, D.C. where he was
	debriefed by Guardian's Office officials. The next day
	on June 12, a transcript of that debrief was sent to the
	Guardian's Office in Los Angeles, California, and excerpted
	by legal Bureau official Paul Klopper in a memorandum to his
	superior, Deputy Guardian for the Legal Bureau Mary Rezzonico.
	That memorandum, entitled "Silver Hearing and Grand Jury"
	summarizes the sentencing proceedings before Judge Flannery
	and the testimony or the defendant Wolfe. (Government Exhibit

- ----------------------------------------------------------------------                        
											
					266
				    266
					   
	No. 173.) 196/ According to the routing on the June 12
	letter, copies of that letter and debrief were sent to the
	"CSG", defendant Mary Sue Hubbard, the "DG US",  defendant
	Henning Heldt, the "DGI US" Brian Andrus and the Guardian
	World-Wide Jane Kember.  197-/ Pursuant to the order of
	the defendant Heldt (Government Exhibit No. 171) 198/
	Ms. Rezzonico and Mr. Andrus gave Mr. Meisner the debrief
	contained in Government Exhibit No. 173 to read so that he
	could start adjusting his cover-up story to that given by
	the defendant Wolfe in the Grand Jury. Mr. Meisner read the 
	defendant Wolfe's Grand Jury debrief at his apartment on South
	Verdugo. 199/ In his directive to Ms. Rozzonico and Mr. Andrus,


- ----------------
	    
	    196/  Government Exhibit No. 173 was seized by Special 
	    Agent William R. Stovill from the defendant Heldt's desk at 
	    the Fifield manor.

	    197/ Mr. Meisner identifies the handwriting of the
	    defendant Raymond at page five, the margins at page ten,
	    eleven, thirteen, twenty-one through twenty-four and at the
	    bottom of page twenty-six.

	    198/  Government Exhibit No. 173 was seized by Special 
	    Agent Levine from the defendant Heldt's desk at the 
	    Fifield manor.
	    
	    199/  Appended to the Wolfe Grand Jury debrief were two
	    newspaper clippings from the Washington Post and Washington
	    Star, regarding Wolfe's sentencing.

- ----------------------------------------------------------------------                        
							      
					267

	the defendant Heldt also ordered them to research any possible
	fugitive charge against Mr. Meisner and to increase security. 200/
	On June 16, Mr. Andrus informed Ms. Rezzonico that "Herb
	[Meisner] was given the news. His reaction was mild pleasure.
	He uplifted his eyebrows and said something like 'not bad'.
	He learned the news by reading the hearing debrief." (Govern-
	ment Exhibit No. 172.) 201/
	    According to Mr. Andrus, Mr. Meisner complained that
	"he didn't feel that anyone was concerned or really looking
	out for his own welfare." Mr. Andrus assured him that he would
	keep him informed of all new developments and would see him
	again soon.
	    On June l3, the defendant Heldt and Mr. Andrus visited
	Mr. Meisner in order to show him a handwritten letter from
		      
- ------------
		      
	200/ Handwriting Expert James Miller has positively
	identified the defendant Heldt as the writer of the entire
	letter marked Government Exhibit No. 171.

	201/ Government Exhibit No. 172 was seized by Special
	Agent Williams from a desk in room 15 of the Information               
	Bureau in the Cedars Complex. It was inventoried and initialed
	by Special Agent Mislock. Mr. Meisner identifies the signature
	at the end of that letter as that of Mr. Andrus.


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

				268

	the defendant Mary Sue Hubbard. The defendant Heldt read to
	him that letter in which the defendant Hubbard warned Mr.
	Meisner that if he escaped from his guards again he would be
	on his own.
	     On June 17, Mr. Andrus met once again with Mr. Meisner.
	He discussed with him the potential legal defenses prepared
	by the Legal Bureau, and left the meeting feeling that "Herb
	was again in better shape communication and duplication wise.
	     In Government Exhibit No. 174, Mr. Andrus informed the
	Temporary Deputy Guardian for Information in the United
	States of the meeting, which he had with Mr. Meisner. 202/
	      
	      
			 M.   Michael Meisner Surrenders 
			      to the Federal Bureau of 
			      Investigation

	     By mid-June, Mr. Meisner had decided that if the watch
	over him were ever relaxed, he would immediately leave the
	   
- ---------

	202/ Government Exhibit No. 174 was seized by Special
	Agent Williams from a desk in Room 15 in the Information
	Bureau in the Cedars Complex. It was inventoried and initialed
	by Special Agent Mislock.

- ----------------------------------------------------------------------                        
		  
				     269

	Guardian's Office, surrender to the Federal authorities,
	plead guilty, and cooperate in the ongoing investigation.
	Thus, he feigned cooperation with his captors and his superiors
	in the Guardian's Office in the hope that eventually his
	guards might be removed. As a reward for this cooperation,
	Mr. Meisner's watch was relaxed. In fact, beginning on the
	evening of Friday, June 17, he was no longer guarded at night.
	His guards would leave his apartment at night and return at
	9 a.m. the next morning.
	    On Monday, June 20 at 6 a.m. Mr. Meisner, taking a
	few clothes with him, left his apartment on South Verdugo
	in Glendale, California, for the purpose of surrendering
	to Federal  Authorities. In order to elude any potential
	follower, Mr. Meisner took two buses to a bowling alley, from
	which he placed a collect call to Assistant United States 
	Attorney Garey Stark in Washington D.C. Mr. Meisner identi-
	fied himself to the operator as "Gerald Wolfe" because he
	feared that the Guardian's Office of the Church of Scientology
	might have placed a covert operative in the United States
	Attorney's Office. When Mr. Stark answered the telephone

		
- ----------------------------------------------------------------------
		
					 270

	Mr. Meisner identified by his real name, informed
	Mr. Stark that he was ready to surrender, plead guilty for
	his participation in the criminal activities of the Guardian's
	Office, and cooperate with the United States. Mr. Stark
	directed him to stay at the bowling alley and wait for Federal
	Bureau of Investigation agents. Approximately two hours
	later, three agents of the FBI met Mr. Meisner at the bowling
	alley. Mr. Meisner surrendered to the agents and was taken
	by them to Los Angeles airport, where he was placed on an
	airplane to the Baltimore-Washington International Airport
	Upon his arrival in Baltimore, he was met by FBI Special
	Agents Robert S. Tittle and James S. Kramarsic. He was kept
	that night in a motel and taken the next morning, June 21,
	to the office of Assistant United States Attorney Garey  
	G. Stark. At the insistence of the Assistant United States 
	Attorney assigned to the investigation, Mr. Meisner conferred
	with an attorney appointed to him by United States Magistrate
	Henry H. Kennedy, Jr. After conferring with his court-
	appointed attorney, Mr. Meisner agreed to enter a plea of 

- ----------------------------------------------------------------------
					  
					  271
					  
	guilty to a five-year conspiracy felony pursuant to 18 U.S.
	Code, Section 371, without any other condition except that he
	would fully cooperate with the Grand Jury investigation.
	Mr. Meisner was, of course, warned that any false testimony
	he made would be prosecuted as perjury. Mr. Meisner requested
	and was granted protective custody by the United States
	Marshall Service.  He has been in the Marshal Service's
	protective custody since June 2l, 1977.               
	     From June 20 to June 22, the defendants and other
	officials of the Guardian's Office notified each other of
	Mr. Meisner's disappearance. On June 20, the defendant
	Willardson informed the defendant Heldt that "Herbert [Meisner]
	was found missing today." He stated that Brian Andrus had
	found in Mr. Meisner's apartment a note stating that Mr.
	Meisner would call in a week, that he was not going anywhere
	where he could be located, and that there was no purpose in
	discussing his motivations. The defendant Willardson informed
	the defendant Heldt that Mr. Meisner had last been seen by
	his guard on Sunday, June 18 at 6:00 p.m. He speculated

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

					272

	that Mr. Meisner was hiding somewhere in Los Angeles, probably
	doing legal research in a library regarding his possible
	legal defenses in the District of Columbia case. He added
	that a Guardian's Office official had been to Mr. Meisner's
	apartment to remove any documents connecting Mr. Meisner to 
	Scientology, and to wipe-out all possible fingerprints.
	(Government Exhibit No. 175.)  203/ A copy of that letter
	was sent to the defendant Mary Sue Hubbard ("CSG"), the
	defendant Raymond ("BI DC Scene Co-Ord (Natl Sec)") and
	Mary Rezzonico (as "BI DC Scene Co-Ord (DG L)") That same day
	Ms Rezzonico notified the defendant Mary Sue Hubbard that
	Mr. Meisner had escaped. Ms. Rezzonico speculated that Mr.
	Meisner had become concerned about additional fugitive from
	justice charges.  She stated that the defendant Willardson
	had agreed to have all those individuals in Washington, D.C.
	who might be affected by Mr. Meisner's appearance briefed
			    
- ---------------                            

	203/ Government Exhibit No. 175 was seized by Special
	Agent Aldrich from the defendant Willardson's office in the
	Cedars Complex. Handwriting Expert James Miller concludes
	that it is "probable" that the signature "Greg" is in the        
	handwriting of the defendant Willardson. Mr. Meisner identi-
	fied that signature as being in the handwriting of the defendant
	Willardson.

- ----------------------------------------------------------------------
						 
					273

	on what to do if he should return there. She also stated
	that the defendant Heldt ("DG US") had ''suggested the
	possibility of creating some confusion with some phone calls
	and a false arrest set-up -- leading the government to believe
	that Patsy [Mr. Meisner's wife] would be meeting her
	ex-husband at some clandestined [sic] meeting -- then have
	her and Greg Taylor [another Guardian's Office Official who
	resembled] Mr. Meisner meet." Thus, the FBI would, presumably,
	arrest the wrong person. (Government Exhibits Nos. 176 and
	177) 204/.
	    In a letter also dated 20 June, the defendant Willardson
	ordered the defendant Raymond and Mr. Brian Andrus to
	"[c]ontinue to fully work out Herb's [Meisner's] cover story
	per the program eventualities so that we are prepared".
	(Government Exhibit No. 178). 205/ He also directed

- ----------------
		   
	204/ Government Exhibits Nos. 176 an 177 are identical.
	However, they were seized by the FBI from two different
	locations. Government Exhibit No. 176 was seized by Special
	Agent Levine from the defendant Heldt's desk at the Fifield 
	Manor; Government Exhibit No. 177 was seized by Special
	Agent Williams from the desk in Room 15 in the Information
	Bureau it the Cedars Complex. The later document was inven-
	toried and initialed by Special Agent Mislock.

	205/ Government Exhibit No. 177 was seized by Special
	Agent Aldrich from a file cabinet in the defendant Willardson's
	office at the Cedars Complex
			     
- ----------------------------------------------------------------------

					274

	that Mr. Meisner's wife be ordered not to follow her husband's
	instructions should he contact her. 206/ Furthermore,
	Guardian's Office personnel were to continue checking all
	libraries in Los Angeles on the assumption that Mr. Meisner
	was doing research. The defendant Willardson ordered the
	removal of all incriminating documents from the Guardians
	Office and their placement in the "Red Box". (Government
	Exhibit No. 219.) 207/

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

	206/ Brian Andrus, in a letter dated 22 June, 1977,
	informed the defendant Willardson that he had contacted Mr
	Meisner's wife on June 21 and briefed her about her husband's
	unauthorized departure from his apartment. She was ordered
	to notify Andrus immediately upon being contacted by Mr. 
	Meisner. She was directed "not to take any instructions
	from him, but to simply ack[nowledge] him and contact me."
	See Government Exhibit No. 132 seized by Special Agent Williams
	from a desk in Room 15 of the Information Bureau at the 
	Cedars Complex. It was inventoried and initialed by Special
	Agent Mislock.

	207/ Government Exhibit No. 219 is the directive regarding
	"Red Box". It orders that "[a]ll the Red Box material from
	you areas must be centrally located, together in a movable
	container (ideally a briefcase), locked, and marked." Appended 
	to that document is the "Red Box Data Information Sheet"                
	which defines "what is a Red Box?" Under that definition,
	"Red Box" includes:
		(footnote continued on next page.)
					   
- ----------------------------------------------------------------------

				      275 

	    In a letter dated June 21, 1977, the defendant Mary Sue
	Hubbard explained to Ms. Mary Rezzonico that she believed Mr.
	Meisner's escape had resulted from a refusal on his part to
	recognize the need to plead guilty on the fugitive from
	justice charge. She felt that that charge, with it's five
	years and/or $5,000 fine was too heavy for Mr. Meisner to
	bear. She speculated that Mr. Meisner had probably gone some-
	where where he could do legal research to prepare his case.
	However, she concluded that she did not think that he would remain
	in the Los Angeles area but that he was more likely to go to 
	San Francisco, a possibly Berkeley. (Government Exhibit

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

		 (footnote continued from preceding page.)

		 a)  Proof that a Scnist is involved in criminal
		     activities.
		 b)  Anything illegal that implicates MSH, LRH.
		 c)  Large amount of non-FOI docs.
		 d)  Operations against any government group
		     or persons.
		 e)  All operations that contain illegal activities.
		 f)  Evidence of incriminating activities.
		 g)  Names and details of confidential financial
		     accts.

	Government Exhibit No. 219 was seized by Special Agent
	Aldrich from the defendant Willardson's office in the Cedars
	Complex.


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

					      276

	No. 179 at P. 2.) 208/
	    Following her receipt of the defendant Hubbard's letter,
	Ms. Rezzonico notified "DG I US", the defendant Willardson,
	and "B-1 CO-ORD US", the defendant Raymond as well as "NAT'L
	CASE OFF (SEUS SEC)" Brian Andrus of the defendant Hubbard's
	directive. 209/ That same day, the defendant Willardson
	notified Ms. Rezzonico in her capacity as "DC Scene Co-
	Ord[inator]" that the CSG, defendant Mary Sue Hubbard, had
	ordered that the Information Bureau  "not waste resources"
	looking for Mr. Meisner, since he might be anywhere. The
	defendant Willardson also notified Mr. Mo Budlong by telex
	that Mr. Meisner had "_blown_ again" and that "no real avenues

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

	208/ Government Exhibit No. 179 was seized by Special
	Agent Aldrich from a file cabinet in the defendant Willardson's
	office in the Cedars Complex. Handwriting expert James
	Miller positively concludes that the signature on that letter
	was written by the defendant Hubbard.

	209/ Handwriting expert James concludes positively  
	that the notation on the lower part of that letter "Mary,
	Could you please clarify this? GW" was written by the defend-
	ant Willardson. Mr. Meisner identifies the four-lines of text
	signed "M" as having been written by Ms. Rezzonico.

- ----------------------------------------------------------------------
						
				       277

	[were] open to locate [him]." He told him that Mr. Meisner's
	apartment was "_cleaned_out_ and _wiped_down_", and that "all
	_his_GO_ associates [were] to be briefed". He states that
	a "[P]lan [was] in the works to remove sensitve GO data
	shud [sic] It become necessary in future". (Government Exhibit No.
	No. 180). 210/ In a 22 June 1977 letter, the defendant
	Raymond updated the information which the defendant Willardson
	had telexed to Mr. Budlong. She informed him that "[w]e are
	working on a plan to create another false arrest scene type
	of action along ops [operations] lines", to sidetrack the
	ongoing Grand Jury investigation in the District of Columbia.
	(Government Exhibit No. 181.) 211/

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

	210/ Handwriting expert James Miller concludes that he is 
	"positive" that the telex was written by the defendant
	Willardson. He also identifies the initials and letters
	"OK'd" next to the title "DG US" on the envelope appended to
	the telex as probably in the handwriting of the defendant
	Heldt. Mr. Meisner identifies the initials and letters as
	having been written by the defendant Heldt. Government
	Exhibit No. 180 was seized by Special Agent Aldrich from a
	file cabinet in the defendant Willardson's office in the
	Cedars Complex.

	211/ Government Exhibit No. 181 was seized by Special
	Agent Williams from a desk in Room 15 of the Information
	Bureau in the Cedars Complex. It was inventoried and initiated
	by Special Agent Mislock.

- ----------------------------------------------------------------------
				   
				     278

		 
	     On June 21, the defendant Mary Sue Hubbard instructed
	the defendant Willardson not to "waste time or resources"
	searching for Mr. Meisner in the Los Angeles area. She stated
	that she believed that he was more likely to be in a
	city or community such as San Francisco or Berkeley where
	there were good libraries available. She further informed
	the defendant Willardson that she had already instructed Ms.
	Rezzonico to prepare a program to handle the present situation.
	The next day, the defendant Willardson agreed with the defend-
	ant Hubbard that Mr. Meisner was "probably on the west coast
	somewhere" and that there were "too many possibilities to
	make a check worthwhile." He pointed out that the Information
	Bureau's checks of the local libraries in Los Angeles had 
	been negative. (Government Exhibit No. 183.) 212/   All the

- -------------                 
		 
	212/ Handwriting expert James Miller concludes that he 
	is "positive" that the signature "Mary Sue" on the June 21
	letter was written by the defendant Hubbard. He also stated
	that it is "probable" that the signature "Greg" on the June
	22 letter was written by the defendant Willardson. Mr
	Meisner identifies both signatures as those of the defendants
	Hubbard and Willardson respectively.   Government Exhibit No.
	183 was seized by Special Agent Aldrich from a file cabinet
	in the defendant Willardson's office at the Cedars Complex.

- ----------------------------------------------------------------------
					    
				      279

	  defendants and officials of the Guardian's Office firmly
	  believed that Mr. Meisner was still a devoted member of the
	  Guardian's Office and had not surrendered to the federal
	  authorities.
		On June 29 the defendant Willardson informed Ms.
	  Rezzonico that he had met with the defendants Raymond and Mr. 
	  Andrus to "iron out some bugs on Herb's [Meisner's] story".
	  He indicated that he had directed Mr. Andrus and the defendant
	  Raymond to continue to work over the next few days on the
	  "basic story". He expressed concern that Mr. Meisner had
	  not called the Guardian's Office since his escape on June 20,
	  and that the situation "could potentially leave us open
	  to crossing up stories or facts to both Herb's and our
	  defendant." He concluded, however, that he was convinced
	  that Mr. Meisner had not surrendered to the authorities and
	  was still with the Guardian's Office. (Government Exhibit
	  No. 184) 213/ On that same day the defendant Willardson
	  
- ----------------

	213/ Government Exhibit No. 184 was seized by Special
	Agent Aldrich from a file cabinet in defendant Willardson's 
	office at the Cedars Complex

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

				     280

	  notified the defendant Heldt that he had "just got word from
	  Herb." The defendant Willardson had just been informed that
	  Mr. Andrus had received a letter from Mr. Meisner postmarked
	  San Francisco. The letter which had been sent by Mr. Meisner
	  after his surrender to the federal authorities and after the
	  United States Attorney's Office for the District of Columbia
	  had decided to obtain a search warrant for Guardian's Office
	  premises, stated:
		     
		     Brian -

			I know you don't understand what's 
		     going on, but I still need time to myself.
		     I'm making enough to get by on so
		     there's no problems.

			I'll be in touch in a couple of weeks.

		     Herb.

	  (Government Exhibit No. 185 at p. 4.) 214/

- ---------------
						    
	214/ Government Exhibit No. 185 was seized by Special
	Agent LeVine in the defendant Heldt's desk at the Fifield
	Manor. Mr. Meisner identifies the signature on that letter
	as having been written by the defendant Willardson.
	
- ----------------------------------------------------------------------

				      281
	
	   The defendant Willardson concluded that "as CSG [the defendant
	Hubbard] predicted" Mr. Meisner had been doing legal research
	in the San Francisco area. He suggested that the Guardian's
	Office send a "missionaire" to "scout the legal libraries
	and perhaps law schools to locate him [Meisner]." A copy
	of this letter was sent to the "CSG", the defendant Mary Sue
	Hubbard, National Secretary, the defendant Raymond, and
	Southeast Secretary, Brian Andrus.
	     The defendant Hubbard, in a handwritten letter dated
	July 3, told the defendant Heldt:

		I frankly wld [would] not waste Bur1
		resources looking for him [Meisner]
		but wld instead utilize resources to
		figure out a way to defuse him shld [should]
		he turn traitor.

	(Government Exhibit No. 185 at p. 3.) 215/ The defendant
	Heldt immediately notified the defendant Willardson of the 
	defendant Hubbard's directive not to look for Mr. Meisner.

- -------------
	       
	215/ Handwriting expert James Miller states that he is 
	"positive" that the bulk of the letter was written by the 
	defendant Hubbard.

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

						282

	He instructed him to "produce a plan or plans in report form
	early this week" to carry out the defendant Hubbard's directive.
	(Government Exhibit No. 185 p. 2.) 216/

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

	215/ Handwriting expert James Miller is "positive" that the 
	entire letter was written by the defendant Heldt. Additionally,
	Mr. Miller finds that the envelope on page one of the series of
	letters was handwritten by the defendant Hubbard ("To: DG US,
	Frm: CSG").

- ----------------------------------------------------------------------
						283

	    The above 262-page _Stipulation of Evidence_ is accepted 
	by the United States of America, the defendants, and their
	attorneys, as the uncontested evidence of the United States
	in the instant case.


	_____________________                _____________________
	CARL S. RAUH                         Leonard B. Boudin
	United States Attorney               Counsel for Defendant
						Mary Sue Hubbard
						
	_____________________                _____________________
	RAYMOND BANOUN                       MICHAEL L. HERTZBERG
	Assistant United States              Counsel for Defendant
	  Attorney                              Mary Sue Hubbard

	_____________________                _____________________
	TIMOTHY J. REARDON, III              MARY SUE HUBBARD
	Assistant United States              Defendant
	  Attorney                                  
						   
	_____________________                _____________________
	STEVEN C. TABACKMAN                  PHILIP J. HIRSCHKOP
	Assistant United States              Counsel for Defendants
	 Attorney                               Henning Heldt
						Duke Snider

	_____________________                _____________________
	HENRY F. SCHUELKE,                   HENNING HELDT
	Assistant United States              Defendant
	 Attorney                               
					     
	_____________________                _____________________   
	JUDITH HETHERTON                     DUKE SNIDER
	Assistant United States              Defendant
	 Attorney                               

					     _____________________
					     ROGER ZUCKERMAN
					     Counsel for Defendants
						Richard Weigand
						Gregory Willardson

					     _____________________
					     ROGER SPAEDER
					     Counsel for Defendants
						Richard Weigand 


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

				284
					  
					  _____________________
					  RICHARD WEIGAND
					  Dcfendant         

					  _____________________
					  GREGORY WILLARDSON
					  Dcfendant         

					  _____________________
					  MICHAEL NUSSBAUM
					  Counsel for defendants
					     Cindy  Faymond
					     Mitchell Hermann

					  _____________________
					  EARL C. DUDLEY
					  Counsel for Defendants
					     Cindy Raymond
					     Mitchell Hermann
						       
					  _____________________
					  CINDY RAYMOND
					  Defendant

					  _____________________
					  MITCHELL HERMANN             
					  Defendant

					  ______________________
					  JOHN KENNETH ZWERLING
					  Counsel for Defendant
					   Gerald Bennett Wolfe

					  _____________________
					  GERALD BENNETT WOLFE
					  Defendant

					  _____________________
					  LEONARD J. KOENICK
					  Counsel for Defendant
					   Sharon Thomas

					  ____________________
					  SHARON THOMAS
					  Defendant


		      Accepted by the court this ___ day of
		      October, 1979.

		      _________________________
		      CHARLES R. RICHEY
		      UNITED STATES DISTRICT JUDGE

- ----------------END OF DOCUMENT--------------------------------------

Note: all of the people whose names are mentioned in the above 2 pages 
with ___ lines over them have signatures appearing on the original where
the ___ lines are.
