Notes about the following document from the person who scanned it 
in from the original:


Presented for your edification is the complete Stipulation
of Evidence in the USA vs. Mary Sue Hubbard et al. case. I think 
this document is particularly important in understanding the 
lengths to which the Church of Scientology's agents (be they
GO, OSA, or RTC) will go to in order to protect their leaders.

This 300 page document is but a very small part of the 45,000+ pages
of documentation in this case alone. Additionally are some strange 
and interesting documents. Such as the letters of character reference 
for Mary Sue Hubbard in support of a plea for probation/parole. 
Letters from the heads of a number of Scientology related 
organizations (e.g. CCHR) are included. Paulette Cooper's name comes 
up a fair amount; mostly pleading against the inordinate delays 
created (e.g. 6 months to depose Mary Sue Hubbard on one particular 
aspect).

In light of the recent revelations involving the Church of 
Scientology in Greece, it becomes clear that the same guidelines 
and policies are being applied in some areas (e.g. giving awards 
for the theft of confidential government files). 

The original is a very faded document that required a large amount
of editing to get a decent digital copy. As a result, there may be
some typos (not many, I hope). However, the original had a fair 
number of typos and formatting inconsistencies itself. I have not 
inserted any [sic]'s or other markings to indicate misspelling or 
formatting problems that existed in the original. 

From my understanding, the following document was agreed upon by 
the defendants as a way to eliminate some of the discovery process
that would normally accompany such an extensive legal case. The
only reasoning I can come up with is that the prosecution and 
defense were willing to make an open and shut case against the named 
defendants in return for an agreement that the prosecution would
not go after L. Ron Hubbard.

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

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

Footnote seperators are marked with an incomplete line accross the 
page like so:

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

********************************************************************                         
- ------------------------------------------------------------------
********************************************************************                         
			 
			 
			 UNITED STATES DISTRICT COURT
			 FOR THE DISTRICT OF COLUMBIA

      UNITED STATES OF AMERICA
		  V.                             Criminal No. 78-401
      MARY SUE HUBBARD, et al.



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


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

					- i -


				TABLE OF CONTENTS

								     PAGE


	 I.   The Witness Michael J. Meisner                             1


	 II.  Organizational Structure of the Guardian's Office          6


	 111. The Conspiracy to Intercept Oral Communications,           12
	      Burglarize and Steal, and the Substantive Acts
	      Committed Pursuant Thereto

	      A.  The Order to infiltrate the Internal Revenue
		  Service in Washington, D.C.                            17

	      B. The Bugging of the IRS Chief Counsel's                 
		 Conference Room on November 1, 1974                    22

	      C.  The First Infiltration of the IRS in the
		  District of Columbia Pursuant to GO 1361               32

	      D.  Infiltration of the Tax Division of the
		  United States Department of Justice                    57

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

	      F.  The Theft of IRS Documents Exempted from
		  Disclosure Under the Freedom of Information Act        81

	      G.  The Guardian Program Order Instituting An "Early
		  Warning System" to Detect Possible Legal Actions
		  Against L. Ron Hubbard and Mary Sue Hubbard           90

	      H.  The Los Angeles Guardian's Office Sends Help to
		  the District of Columbia Guardian's Office            100

	      I.  The Guardian's Office Orders Mr. Meisner to
		  Los Angeles for Debriefing and Auditing                106

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

	      K.  The Entry Into the IRS identification Room and
		  the Making of Counterfeit Identification Cards         119

	      L.  Guardian Program Order 302 and the Theft of
		  Documents Withheld by the United States Under
		  the FOIA                                               123

	      M.  Burglaries of the Suite of Offices of the
		  Deputy Attorney General of the United States           127

	      N.  Burglaries of the Office of International
		  Operations of the Internal Revenue Service
		  and Theft of Documents Therefrom                       133

	      O.  Burglaries and Thefts or Documents From the

		  Department of Justice in Washington, D.C.             139

		  1. Office of Paul Figley                              139

		  2. Interpol Liaison Office at the Department
		      of Justice                                        142

- ----------------------------------------------------------------------                        
				
				- ii -

		     Offices of Special Assistant to Assistant
		     Attorney General for Administration
		     John F. Shaw
								      150

	      P. Burglaries and Thefts or Documents from Assistant
		 United States Attorney Nathan Dodell's Office,
		 Located in the United States Courthouse for the
		 District of Columbia                                 155

	IV.   The Conspiracy to Obstruct Justice, to Obstruct
	      an Investigation, to Harbor a Fugitive and to
	      Make False Declarations Before the Grand Jury           176

	      A. The Preparation or the Cover-up Story                176

	      B. The Defendant Gerald Bennett Wolfe is Arrested
		 in Washington, D.C., by the Federal Bureau of
		 Investigation                                        190

	      C. The United States Case Against the Defendant
		 Gerald Bennett Wolfe is Referred to the Grand
		 Jury, and an Arrest Warrant is Issued for
		 Michael Meisner                                      196

	      D. The Guardian's Office Harbors and Conceals
		 Fugitive From Justice Michael Meisner               198

	      E. The Guardian's Office Gives the FBI and the
	      Grand Jury False Handwriting Exemplars                  209

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

	      G. The Federal Grand Jury Investigation in the
		 District of Columbia Continues                       225

	      H. The Guardian's Office Cover-up Moves Into
		 its Final Phase                                      232

	      1, The Guardian's Office Restrains and Guards
		 Michael Meisner                                      238

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

	      K. The Defendant Wolfe's Sentencing and Subsequent
		 Testimony Before the Grand Jury in the District
		 of Columbia                                          252

	      L. The Defendant Wolfe is Debriefed by the Guardian's
		 Office After his Grand Jury Appearance               265

	      M. Michael Meisner Surrenders to the Federal
		 Bureau of Investigation                              268

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

					iii

				  TABLE OF EXHIBITS

       EXHIBIT
       NUMBER                DESCRIPTION             SECTION          PAGE

	   1A         Organizational Chart              II          6,7,11
			 Guardian's Office

	   1B         Organizational Chart              II           8,11
			 Guardian's Office
			 (pre-January 1, 1976)

	   1C         Organizational Chart              II           9,11
			 Guardian's Office
			 (post-January 1, 1976)

	   1D         Organizational Chart              II           10,11
			 Assistant Guardian's
			 Office DC

	   2          Document #13969                  III         12,14,-17,
								      95,163

	   3          Document #3060                   IIIA            19-22

	   4          Document #9317                   IIIA            19-22

	   5          Document #6131                   IIIB            26-27

	   6          Document    #20106               IIIB            28-30

	   7A         Document    #20276               IIIB            28-29

	   7B         Document    #20277               IIIB            28-29
						    
	   8          Document    #2065                iiic         32-35,39

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

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

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

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

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

	   9          Document    02064                IIIc         32,36-37

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

	10            Document    #2062                IIIc            32,39

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

	11            Document    #2057                IIIc         32,39-40

	12            Document    #12636               IIIc            44-46

	13            Document    019692               IIIc            47

	14            Document    #1433                IIIc            48-52

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

					 iv



      EXHIBIT
      NUMBER              DESCRIPTION                SECTION          PAGE

	  15        Document #118                      liic           53-55

	  16        Document #115                      iiic           56-57

	  17        Document #19669                    IIID           59-61

	  18        Document  #3778                    IIID           60

	  19        Document  #3801                    IIID           59-61

	  20        Document  #12898                   IIID           59-61

	  21       Document  #3799                    IIID           59-61

	  22        Document  #3661                    IIID           59-61

	  23        Document  #3664                    IIID           59-61

	  24        Document  #3806                    IIID           59-61

	  25        Document  #11244                   IIID           59-61

	  26        Document  #7394                    IIID           61

	  27        Document  #3656                    IIID           59-61

	  28        Document  #3610                    IIID           61

	  29        Document  #3811                    IIID           61

	  30        Document  #3814                    IIID           61

	  31        Aerial photograph                                  --

	  32        Document #8742                     IIID           62-65

	  33        Document #3005                     IIID           65-67

	  34        Document  #2044                    IIID           68-70

	  35        Document  #2304                    IIID           70-71

	  36        Document  014395                   IIID           72-74

	  37        Document  #14395  p. 57 at         IIID           74
		    bottom right hand side.

	  38        Document  #14399                   IIID           72

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

	  39        Document  #2048                    IIID           75-76

	  40        Document  #4012                    IIIF           82-83

	  41        Document  #1405                    IIID           77

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

					v

     EXHIBIT
     NUMBER            DESCRIPTION               SECTION           PAGE

	41A        Documcnt 01405  p.  2             IIID            77

	42         Document  t2O55                   IIID            78

	43         Document  #1403                   IIIE            79-80

	43A        Document  #1403 p. 2              IIIE            79

	43B        Document  01403 p. 4              IIIE            79

	43C        Document  01403 p. 5              IIIE            79

	43D        Document  #1403 p. 6              IIIE            79

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

	44         Document  012584                  IIIF            83-85

	45         Document  012607                  IIIF            84-85

	46         Document  01419                   IIIF        85,108,110

	46A        Document  #1419 p. 20             IIIC            40,85
		   [Document #1419, p. 61]

	46B        Document #1419 p. 21             IIIF        85,108-109,
		   [Document #1419, p. 8-101]

	46C        Document #1419 p. 23              IIIF            85

	46D        Document  #1419 p. 25             IIIF            85

	4T         Document  #12608                  IIIF          83-84,86

	48         Document  #1431                   IIIF            83

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

	49         Document  #1421                   IIIF            87-88

	50         Document  03660                   IIIF         83-84,89

	51         Document  #3066                   IIIc            51

	52         Document  #1541                   III02         142-143

	53         Document  #9322                  IIIG            90-92

	54         Document  #3676                   IIIG            97-98

	55         Document  #3677                   IIIG            97-98

	56         Document  #1410                   IIID            78

	56A        Document  #1410 p. 20             IIIF            89

	56B        Document  #1410 p. 21             IIIF            89

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


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

					vi

	EXHIBIT       
	NUMBER              DESCRIPTION              SECTION         PAGE

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

	 56E         Document #1410 p.    43          IIIA          21

	 5T          Document #11120                  IIIH          106

	 58          Document 01427                   III I       110-111

	 59          Document #21704                IIIJ        114-115

	 60          Document #21724                  IIIJ        116-117

	 61          Meisner IRS Identification       IIIK          121
		       card

	 62          Document #21626                  IIIJ          118

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

	 64          Document  #3956                  IIIH        99-100

	 65          Document  #1097                  IIIL        124-125

	 66          Document  #1098                  IIIL        123-124

	 67          Document  #14768                 IIIL        126-127

	 68          Document  #1412                  IIIJ          118

	 69          Document  #15779                 IIIM          131

	 70          Document  #15780                 IIIM          131

	 71          Document  #15781                 IIIM          131

	 72          Document  #15778                 IIIM          132

	 73          Document  #3102                  IIIN        137-138

	 74          Document  #3035                  IIIN        137-138
       
	 75          Document  #3036                  IIIN        137-138

	 76          Document  #3033                  IIIN        137-138

	 77          Document  03099                  IIIN        137-138

	 78          Document  #10963                 III01         141
						     
	 79          Document  010958                 III01       l4l-l42

	 80          Document  #2459                  III02       146-147

	 81          Document  12462                  III02         148

	 82          Document  #11561                 III02         148

	 83          Document  #11562                 III02         148

	 84          Document  #11584                 III02         148

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

					 vii

       EXHIBIT
       NUMBER              DESCRIPTION            SECTION         PAGE

	85         Document #2463               III02           148-149

	86         Document  #15777              III02           148-149

	87         Document  #2461               III03           152

	88         Document  #14111              III03           152
					     
	89         Document  #14110              III03           152

	90         Document  #14109              11103           152

	91         Document  #14108              III03           152

	92         Document  #14107              III03           152

	93         Document  #9989               III03           153

	94         Document  #9990               III03           153

	95         Document  #15772              III03           154

	96         Document  #826                IIIP            156-159

	97          D.C. Bar  Library Sign-in     IIIP            162
		      Log of  May 21, 1976

	98          Document  #3044               IIIP            164

	99          Document  #11571              IIIP            165

       100          Document  #14114              IIIP            165

       101          Courthouse Sign-in Log        IIIP            167
		      of May 28, 1976

       102          D.C. Bar  Library Sign-in     IIIP            167
		      Log of  May 28, 1976

       103          Document  #18601              IIIP            168

       104          Document  #14113              IIIP            168

       105          Document  #898                IIIP            170

       106          D.C. Bar  Library Sign-in Log IIIP            171
		      of June 11, 1976

       107          Document #1550                IIIC            52

       108          Document  #8598               IVA             189

       109          Document  #555                IIIM            127

       110          Document  #17416-17417        IIIP            173

       111          Document  #8567               IIIG            91

       112          Document  08908               IIIP            174

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

					viii

      EXHIBIT
       NUMBER             DESCRIPTION                 SECTION         PAGE

	 113         Quality Inn Motel (Arlington)     IIIP            176
		       Registration Card

	 114         Document #11176                   IVA             177

	 115         Document #3125                    IVA             180

	 116         Document  #14751                  IVA             179

	 117         Document  #14738                  IVB             191

	 118         Document  #14744                  IVB             192

	 119         Document  #14745                  IVB             193

	 120         Document  #14742                  IVB             194

	 121         Document  #14749                  IVB             195

	 122         Document  #14748                  IVB             195

	 123         Document  #13789                  IVC             198

	 124         Document  #13785                  IVD          198-199

	 125         Document  #11078                  IVD            201
						  
	 126         Document  #11076                  IVD             201

	 127         Document  #11055                  IVD          203-204

	 128         Document  #14662                  IVD             205

	 129         Document  #14737                  IVD             207

	 129A        Document  #14737  p. 2            IVD             206

	 129B        Document  #14737  P. 3            IVD             207

	 130         Document  #14672                  IVE             211

	 131         Document  #11231                  IVD          207-209

	 132         Document  #11425                  IVE          210-211

	 133         Document  #13755-13756            IVE              212

	 134         Document  #13758                  IVE
									212
	 135         Document  #10755                  IVF          218,219

	 136         Document  #14658                  IVF              218

	 137         Document #111667                  IVF              216

	 138         Document #10706                   IVF           219-220

	 139         Document #10744                   IVF              222

	 140         Document #13757                   IVF              222   
	 

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

						    ix

    EXHIBIT
    NUMBER                    DESCRIPTION        SECTION        PAGE

    141            Document #14746                 IVF        223-224
								    
    142            Document #14741                 IVF          225

    143            Document #10722                 IVG          226

    144            Document #10709                 IVG        227-228

    145            Document #8580                  IVG           229

    146            Document #10715                IVG           229

    147            Document #14687                 IVG           231

    147A           Document #14687    (2d letter   IVG           232
		    from end)

    147B           Document #14687  last letter)   IVG           232

    148            Document #14689                 IVH         232-233

    149            Document #8575                  IVH            234

    150            Document #11215                 IVH            235

    151:           Document #11175                 IVH            236
							   
    152            Document #3135                  IVH            237

    153            Document #11179                 IVH            238

    154            Document #3146                  ivi            238

    155            Document #3145                  ivi            238

    156            Document #3144                  ivi            239

    157            Document #3143                  ivi            240

    158            Document #11232                 ivi            240

    159            Document #3153                  ivi          241-242

    160            Document #10066                 ivi             243

    161            Document #8574                  ivi          243-244

    162            Document #8576                  ivi          243-244

    163            Document #10067                 ivi          244-245

    164            Document #8573                  ivi             246
							       
    165            Document #8572                  ivi             246

    166            Document #10070                 ivi             245
    
    167            Document #10071                 ivi             247

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

					x

   EXHIBIT
   NUMBER              DESCRIPTION           SECTION              PAGE

      168           Document #11184              IVJ               249

      169           Document #11183              IVJ               249

      170           Document #11185              IVJ               251

      171           Document #3148               IVL               266

      172           Document #11201              IVL               267

      173           Document #13141              IVL               266

      174           Document #11199              IVL               268

      175           Document #8555               IVM               272

      176           Document #3150               IVM               273

      177           Document #11203              IVM               273

      178           Document #8558               IVM               273

      179           Document #8548               IVM            274-276

      180           Document #8544               IVM               277

      181           Document #11204              IVM               277

      182           Document #11202              IVM               274

      183           Document #8561               IVM               278

      184           Document #8563               IVM               279

      185           Document #3147               IVM            280-282

      187           Document #20107              IIIB             28-30

      188           Document #20034              IVA        179-180,192

      189           [not used]                              

      190           FH Radio Monitor            IIIB             25

      191           Electronic device in gold   IIIB             25
			   colored box

      192           Battery connection          IIIB             25

      193           Telephone resonator         IIIB             25

      194           Wall receptacle             IIIB             25

      195           Spring steel shims          IIIH             102
 
      196           Spring steel shims          IIIH             102

      197           Spring steel shims          IIIH             102

      198           Spring steel shims          IIIH             102

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

					    xi

  EXHIBIT
  NUMBER        DESCRIPTION                     SECTION             PAGE

  199          Spring steel shims               IIIH              102

  200          Spring steel shims               IIIH              102
					   
  201          Spring steel shims               IIIH              102

  202          Key micrometer                   IIIH              102

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

  204          Handwriting given by Moxon       IVE                212
		 to Hansen of FBI
	 
  205        Wolfe Personnel Record at          IIIA               18
	       IRS

  206          Thomas Personnel Record          IIIG               94
	       at DOJ

  207          Thomas Identification Card       IIIG               94
		at DOJ

  208          Conference memorandum of         IIIB               31
		Lewis Hubbard of Nov. 1,1974

  209          Conference memorandum of Lewis   IIIB
	       Hubbard of Nov. 1, 'L974

  210          FBI Lab Decode of document       IIIB               30-31
	       #20106

  211          FBI Lab Decode of documents      IIIB               30-31
	       #20107

  212          FBI Lab decode of document       IVA                18o
	       #14751

  213          FBI Lab decode of document       IVB                194
	       #14742

  214          Grand Jury docket entry Dec.     IVG                225
	       15 9 1976

  215-         Gerald Wolfe Grand Jury          IVK                255-260
	       testimony of June 10, 1977

  216          FBI Lab decode of document       IVB                192
	       #14744

  217          Photograph of bugging equipment  IIIB                25

  218          Photograph of lockpicking        IIIH               102
	       equipment

  219          Document #7984                   IVM                274-275

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

			    UNITED STATES DISTRICT COURT
			    FOR THE DISTRICT OF COLUMBIA


	 UNITED STATES OF AMERICA

		 V                            Criminal No. 78-401

	 MARY SUE HUBBARD, et al.


			      STIPULATION OF EVIDENCE


	      The United States of America, through its attorneys,
	United States Attorney Carl S. Rauh, Assistant United States
	Attorneys Raymond Banoun, Timothy J. Reardon, III, and Steven
	C. Tabackman, and the attorneys for the defendants: Leonard B.
	Boudin, Esquire, and Michael L. Hertzberg, Esquire, for the 
	defendant  Mary Sue Hubbard; Phillip J. Hirschkop, Esquire,
	for the defendants Henning Heldt and Duke Snider; Rcger Zukerman,
	Esquire, and Roger Spaeder, Esquire, for the defendants, Richard
	Weigand and Gregory Willardson; Michael Nussbaum, Esquire, and
	Earl C. Dudley, Esquire, for the defendants Cindy Raymond and
	Mitchell Hermann, also known as Mike Cooper; John Kenneth
	Zwerling, Esquire, for the defendants Gerald Bennet Wolfe; and
	Leonard J. Koenickp Esquire for the defendant Sharon Thomas; as
	well as the above-mentioned defendants themselves , agree and
	stipulate that the evidence as to all the defendants is as follows:

- ----------------------------------------------------------------------
		      
		      1. The Witness Michael J. Meisner

	     Michael J. Meisner, 29, was born in Chicago, Illinois.
	He attended parochial elementary and secondary schools.  He
	studied at the University of Illinois at Urbana for two and
	a half years from 1968 through 1970.  Mr. Meisner became
	interested in Scientology in November 1970 when he was intro-
	duced to it by a friend.  During the next two months,
	he took several courses at the Urbana Church of Scientology
	franchise and in January 1971 left the University to become a
	full time course supervisor.   He held this Position until
	May 1971 when he was sent to the Church of Scientology of
	St. Louis for two weeks of further training.  He then returned
	to Urbana, Illinois, where he resumed his duties as a course
	supervisor until September 1971.   At that time, he returned
	to the St. Louis Church of Scientology where for the next eight
	months he was trained to become an auditor. 1/ From May
	1972 until August 1972, he resumed his duties as a course

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

- ----------------------------------------------------------------------
				       
				       2 

	 supervisor and an auditor in Urbana, Illinois.   In August
	 1972, lie assumed the position of Executive Director of the
	 franchise until June 1973.
	      In mid-May 1973,   the defendant Duke Snider recruited
	 Mr. Meisner for the Guardian's Office of the Church of Scien-
	 tology in  Washington,   D.C.   In a meeting in Washington,
	 D.C., the defendant Snider told him that he wanted him to
	 become part of the Intelligence Bureau of the Guardian's
	 Office.  The Intelligence Bureau became the Information Bureau
	 Bureau [sic] in July 1973. In mid-June 1973, Mr. Meisner and his
	 wife Patricia were accepted for the Guardian's Office and
	 moved to the District of Columbia to take courses in prepara-
	 tion for assuming their duties as officials of that organiza-
	 tion.   Upon becoming an officer of the Intelligence Bureau,
	 Mr. Meisner was instructed by the defendant Duke Snider that
	 that Bureau was in the forefront of the Guardian's Office
	 that is, it dealt with safeguarding the environment within
	 which Scientology existed by locating, removing and rendering 
	 harmless all thore perceived to be enemies of Scientology,
	 This was accomplished by infiltration, theft of documents and

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

				 - 3 -

	   covert operations.  Following a week of training in Guardian's
	   Office procedures and policies in the District or Columbia,
	   Mr.  Meisner was sent to Los Angeles, California, for more
	   intensive training in the Intelligence (Information) Bureau.
		From July 1973 until October 1973, Mr. Meisner's training
	   in the Information Bureau of the Guardian's Office in Los
	   Angeles, California, included intensive courses in administra-
	   tive procedures, policies and practices of the Information
	   Bureau, as well as the Guardian's Office as a whole. These        
	   included courses on the preparation of documents, such as
	   reports, "CSWS" (completed staff work), 2/ "programs," (later
	   denominated "Guardian Program Orders") "projects," "Guardian
	   Orders," and daily Intelligence reports.  He also learned
	   the routing and format required in the preparation of documents.
	   Mr.  Meisner was taught that strict adherence to the chain
	   of command and seniority within the organizational structure
	- ---------
		21   A "CSW" (completed staff work) is a request to a 
	   senior official for approval or disapproval of proposed
	   action.

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

					       - 4 -

	   was of paramount importance in the day-to-day operations of
	   the Guardian's Office, and more specifically the Information
	   Bureau.   Mr.   Meisner was Instructed that the routing placed
	   on each written document followed  strictly that chain of
	   command so that each memorandum, report, etc., went to the
	   appropriate persons for approval and/or information. In a
	   clinical setting, Mr. Meisner also learned to conduct covert
	   investigations, surveillances, "suitable guise" investiga-
	   tions, 3/   the recruiting and supervising of covert agents,
	   the placing of these agents in organizations that were to he
	   infiltrated, the theft of documents, and other overt and
	   covert intelligence gathering techniques.  The defendant
	   Gregory Willardson, among others, supervised him in the
	   these areas.  For a three-week period Mr. Meisner also cross-
	   filed memoranda and other [sic] covertly and overtly obtained
	   documents of interest to Scientology. He thereby became
	   intimately familiar with the sophisticated filing system

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

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

					- 5 -

	   maintained by the Guardian's Office and its Information
	   Bureau. The absolute necessity of correctly labelling and
	   filing all documents obtained and kept by the Information
	   Bureau was emphasized to Mr. Meisner. Strict adherence to
	   these policies was mandated to assure that the Information
	   Bureau and the Guardian's Office functioned in a proper and
	   efficient manner.
		In November 1973 Mr. Meisner returned to the District of
	   Columbia as Branch II Director of the Information Bureau.
	   In that position he was responsible for internal security
	   matters.  These included both the physical security of the
	   premises of the local Guardian's Office as well as the handl-
	   ing of all dissident and disaffected Scientologists. with
	   regard to the latter, his duties included obtaining personal
	   information which would prevent them from becoming a nuisance
	   to Scientology.    In January 1974,  the Guardian World-Wide
	   Jane Kember elevated Mr. Meisner to the position of Assistant
	   Guardian for Information in the District of Columbia (AG I DC)
	   In his new post, Mr. Meisner was responsible for all overt
	   and covert intelligence investigations and operations. This

- ----------------------------------------------------------------------
						
				      6

	included the implementation of all Guardian orders, programs,
	and projects within the District of Columbia applicable to
	the Information Bureau, as well as overall supervision of
	all covert operatives in private and governmental agencies.
	Until March 1974, the defendant Duke Snider was Mr. Meisner's
	immediate supervisor. At that time, the defendant Snider
	was Assistant Guardian for the District of Columbia (AG DC)
	the highest position in the local Guardian's Office.

					II.

		Organizational Structure of the Guardian's Office

	As a result of his intensive training in the Guardian's
	Office as well as having held high positions within the
	Information Bureau Mr. Meisner became thoroughly familiar
	with the organizational structure of the Guardians Office
	and its bureaus, both nationally and internationally. _Govern-
	ment Exhibit No. 1A_ is a chart showing the organizational
	structure of both the World-Wide and United States Guardian's
	offices.  At all times material to the indictment, the Guard-

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

					- 7 -

	ian's Office had World-Wide headquarters at St. Hill Manor
	in East Grinstead, Sussex, England; United States headquarters
	in Los Angeles, California; and a local office in the District
	of Columbia and some thirty other cities throughout the
	United States. 4/   Each of the Guardian's Offices was con-
	posed of five bureaus: Information (prior to July 1973
	known as the Intelligence Bureau), Public Relations, Legal,
	Finance, and Social Coordination.   A sixth bureau not shown
	on _Government Exhibit No. 1A_ was known as the Services Bureau.
	Each bureau was headed both at the World-Wide and national
	level by a Deputy Guardian.    At the local level each bureau
	was headed by an Assistant Guardian.
	At all times material to the indictment, L. Ron Hubbard
	was, by virtue of his role as the founder and leader or
	Scientology, overall supervisor of the Guardian's Office.

- ---------
	4/  Including: New York City; Philadelphia, Clearwater,
	Florida; Miami; Chicago; Detroit; St. Louis; Houston; Denver;
	Seattle; San Diego;  San Francisco; Sacramento, California;
	Hawaii; I.as Vegas; Los Angeles; Advanced Organization of Los 
	Angeles; American Saint Hill Organization (Los Angeles);
	Portland, Oregon; Mexico City (which is under the jurisdic-
	tion of the United States Guardian's Office).

- ----------------------------------------------------------------------
					
					8

	 His wife, the defendant Mary Sue Hubbard, held the titles of
	 "Controller" and "Commodore Staff Guardian" (CSG) and, as the
	 second person in the hierarchy of Scientology, had duties
	 which included supervision of the Guardian's Office. Jane
	 Kember held the title of "Guardian World-Wide" (GWW) and headed
	 the daily operations of all Guardian's Offices, reporting
	 directly to the defendant Mary Sue Hubbard who in turn reported
	 directly to L. Ron Hubbard.  The Deputy Guardian for Informa-
	 tion World-Wide (DG I WW) was Morris Budlong, also known as
	 Mo Budlong  (hereafter Mo Budlong). He supervised all
	 Information Bureaus around the world and reported
	 to Jane Kember. The defendant Henning Heldt was the Deputy
	 Guardian for the United States (DG US) supervising all Guard-
	 ian's Offices in the United States. He reported directly to
	 Jane Kember.
	      _Government Exhibit No. 1B_ is an organizational chart of 
	 the Information Bureau in the United States from November
	 1973 until January 1976 when it was reorganized. The defendant
	 Duke Snider was Deputy Guardian for Information in the United
	 States (DG I US) from March 1974 until January 1975, a position


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

					9

	thereafter held by the defendant Richard Weigand. Beginning
	in January 1975 and at all other relevant times charged in
	the indictment, the defendant Snider was Deputy Deputy Guardian 
	for the United States (DDG US) and in that capacity was the
	defendant Heldt's top assistant. In October 1975, the defendant
	Gregory Willardson became the Deputy Deputy Guardian for Infor-
	mation U.S. (DDG I US). Prior to that date he had held the
	position of Branch I Director U.S. (BR I DIR US). The defend-
	ant Cindy Raymond was the Collections Officer for the United
	States (COLL OFF US). She was responsible for the overt, and
	covert data collection for the Information Bureau.
	      _Government Exhibit 1C_ is an organization chart of the
	Information Bureau in the United States after its reorganiza-
	tion in January 1976.  Following the removal of the defendant
	Richard Weigand from the position of Deputy Guardian for
	Information U.S. on approximately May 15, 1977, that position
	was assumed by Brian Andrus until June 16, 1977, and there-
	after by the defendant Gregory Willardson. From January 1976
	until May 1977, Mr. Willardson held the position of Deputy
	Deputy Guardian Information U.S. (DDG I US).  For the period


- ----------------------------------------------------------------------
						    
				  10

	     January 1976 to June 1976, Mr. Willardson also held the
	     position of National Secretary for the Information Bureau U.S.
	     (NATL SEC US). 5/  From June 1976 until August 1976 the
	     position of National Secretary was held by Michael Meisner,
	     who was succeeded in September 1976 by the defendant Cindy
	     Raymond.
		   Government Exhibit No. 1D is an organizational chart of
	     the Information Bureau in the District of Columbia. From
	     January 1974 until June 1976, Mr. Meisner held the position of
	     Assistant Guardian for Information in the District of Columbia
	     (AG I DC).      Immediately under him was the defendant
	     Hermann who held the position of Information Branch I Director
	     from January 1974 until March 1975.   The defendant Hermann,
	     using the alias "Mike Cooper," subsequently held the position
	     of Southeast U.S. Secretary (SEUS SEC)  from January 1976
	     until March 1977 when he was succeeded  by Brian Andrus.

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

		   5/    That was commonly referred to in Scientology as a 
	     position "held from above" or "HFA" both of which appear on 
	     the routing portion of certain documents and which connotes
	     that an individual ia assuring the responsibilities of more
	     than one position at the same time.

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

					11
									   
	    (See Government Exhibit No. 1C, supra.)
		The routing on each document prepared within the Guard-
	    ian's Office of the Church of Scientology, and its under-
	    lying bureaus, tracks the organizational charts. (Government
	    Exhibits Nos. IA -- ID.) Thus, in the routing portion of each
	    document is the abbreviation of each of the positions held
	    by the Persons who were to receive the particular documents,
	    as well as that of the author of the document. (See, e.g.
	    Government Exhibit 14, discussed at page 48, infra.
		 From January 1974 when Mr. Meisner joined the Guardian's
	    Office until he left the Church of Scientology in June 1977,
	    Mr. Meisner had extensive person to person contacts with
	    the defendants Henning Heldt,  Duke Snider, Richard Weigand,
	    Gregory Willardson, Cindy Raymond, Mitchell Hermann, Gerald
	    Bennett Wolfe and Sharon Thomas.  During some of the periods
	    charged in each conspiracy, the latter four defendants were
	    in fact, subordinates of Mr. Meisner. Mr. Meisner repeatedly
	    met with each of these eight defendants. He exchanged many
	    written communication with them, especially the first six
	    named defendants as well, as the defendant Mary Sue Hubbard.

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

					       12

	   He became intimately familiar, with the handwriting and signa-
	   ture of the defendants, and thus is able to identify their
	   writings and signature wherever it appears on the documents
	   appended to the instant record as Government Exhibits. Indeed
	   he witnessed most of the defendants write and sign their
	   names in his presence.

					III.

			     The Conspiracy to Intercept Oral
			     Communications, Burglarize and
			     Steal, and the Substantive Acts
			     Committed Pursuant Thereto.

		 On November 21, 1973, Jane Kember, the Guardian World-
	Wide (Guardian W/W) wrote a letter to the Temporary Deputy
	Guardian U.S. (T/D/Guardian US) Henning Heldt "Re Interpol
	Washington." (See Government Exhibit No. 26/ at page 3,

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

		  6/ Government Exhibit No. 2, as well as all documents
	    marked Government Exhibits No. 3 to 30, 32-60, 62-96,
	    103-105, 107-112, 114-185, 187-188, 210-213, 216, 219
	    seized by agents of the Federal Bureau of Investigation from
	    two Guardian's Office locations known as the Fifield Manor
	    and the Cedars Complex in Los Angeles, California, pursuant
	    to lawful United States Magistrate search warrants executed
	    July 7, 1977.  Government Exhibit No. 2 was seized by Special
	    Agent Lawrence W. Cross from a file cabinet in the office of
	    the defendant Willardson at the Cedars Complex.

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

					  13
									   
	et seq.) in that handwritten letter, she informed the defendant
	Henning Heldt that the Guardian's Office has "some documents,
	_illegally_obtained_, that indicate Interpol Washington was in
	touch with Interpol Paris, London, Melbourne, Ottawa and
	Lomba Malawi." (Emphasis added.)  She added at page two of
	that letter that "we now know that Washington D.C. has police
	files on LRH, and _if_ the  reference is correct,  Interpol
	Washington has a file on LRH as well."  She then directed that
	"[I]t is important that we get cracking and obtain these
	files and I leave you to work out how." Attached to that
	letter were a number of Interpol documents.
		In his three and one half years as an official of the
	Guardian's Office, including serving as the highest
	official of the Information Bureau in the District of Columbia
	and the national Secretary of the Information Bureau in the
	United States, Mr. Meisner met and exchanged communications
	with Ms. Kember. He has also seen numerous communications
	from her to other Guardian's Office officials. Based on that
	experience, Mr. Meisner became familiar with her handwriting.
	He Recognizes the handwriting in the above-mentioned letter

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


						14

	as that of Jane Kember. Mr. Meisner also recognizes the
	routing in the upper left-hand corner, or page three to be in
	accordance with the required routing procedures of the Guard-
	ians Office. 7/
		Government Exhibit No. 2, pages one and two, is a letter
	signed "Henning" addressed to "Dear Dick" dated 29 April 1975,

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

		 7/   Kathryn E. Hirsch, another former official of the
	    Church of Scientology, held many positions in that organization
	    both in Los Angeles, California, and in the United Kingdom at
	    East Grinstead, Sussex. From December 1972 until March 1973
	    and from June 1973 until September, 1973, she worked at the
	    World-Wide headquarters of the Guardian's Office
	    of Scientology at St. Hill Manor, East Grinstead, Sussex, in
	    Great Britain. During that period she held the position of
	    Finance Actions Director World-Wide and had personal contact
	    with the Guardian World-Wide, Jane Kember.  She  repeatedly
	    witnessed Ms. Kember sign her name and written memoranda and
	    exchanged handwritten correspondence with her.   Furthermore,
	    as Finance Director, World-Wide she was responsible
	    for keeping financial records or all Scientology organizations
	    throughout the world and was also custodian of signatory
	    cards for all bank accounts of these organizations.   Each
	    member was one or four persons in the Church of Scientology
	    who was a signatory for each Scientology  bank account. As a
	    result of her, position, Ms. Hirsch became intimately familiar
	    with and able to identify Ms. Kember's handwriting. Ms. 
	    Hirsch recognizes the handwriting on Government Exhibit No.
	    2, pages three and four as that of Ms. Kember. She also
	    recognizes the routing in the upper, left-hand corner of page
	    three to be in accordance with the routing procedure required
	    by the Guardian's Office.

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

					      15

	    referring specifically to the November 21, 1973 order of
	    Jane Kember which, the letter indicated, was attached to it.
	    The letter concluded "while Legal is doing FOI [Freedom of
	    Information Act] actions to obtain these (documents), please
	    have B-1 [Information Bureau-Bureau 1] obtain them (the
	    Legal route is at best lengthy.)" According to the routing
	    portion located on the upper left hand corner of the document
	    the letter was sent by the Deputy Guardian U.S. (DG US) , the
	    defendant Henning Heldt, to the DC Info US, the defendant
	    Richard Weigand.  Next to the abbreviation "DG Info US" are
	    the initials "DW" of the defendant Richard [Dick] Weigand.
	    Mr. Meisner identifies the signature and handwritten entry
	    on page two of Government Exhibit No. 2 as the handwriting
	    of the defendant Henning Heldt. The Government's handwriting
	    analysis expert, Mr. James Miller, positively concludes that
	    both the signature and the three-line handwritten note on
	    page two of that document is in the handwriting of the defendant
	    Heldt.
		  In July 1974 the defendant Duke Snider, who was at the
	    time Deputy Guardian for Information in the United States,

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

					      16

	    sent a written order to Michael Meisner, the Assistant Guardian
	    for Information in the District of Columbia. That order
	    referred to Jane Kember's outstanding order to obtain Interpol
	    files regarding Scientology from District of Columbia Interpol
	    offices.  The Snider order directed Mr. Meisner to prepare a
	    "project" to obtain all these Interpol files. Pursuant to that
	    directive, Mr.  Geiser, drafted such a "project" and sent it
	    to the defendant Snider in Los Angeles for laws approval. The
	    "project" called for the infiltration of the Interpol National
	    Central Bureau for the United States, then located in the
	    United States Department of the Treasury main building in
	    Washington, D.C., in order to obtain all files regarding, or,
	    referring to, Scientology and its founder L. Ron Hubbard
	    The defendant Snider acknowledged the receipt of that "project,"
	    and by return mail approved its issuance. Mr. Meisner there-
	    after assigned the "project" to the defendant Mitchell Hermann,
	    who was then Branch I Director in the District of Columbia
	    Information Bureau.  The Interpol files required to be obtain- 
	    ed by Ms. Kember's outstanding order of November 21, 1973
	    (Government Exhibit No. 2) and Mr. Snider's order of July


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

					      17

	  1974, were not taken, however, until the burglaries of the
	  office of Assistant United States Attorney Nathan Dodell in
	  the United States Courthouse for the District of Columbia in
	  May 1976.   In a 2 May 1975 letter to Henning Heldt, the DG
	  US, appearing on the last page of Government Exhibit No. 2,
	  the defendant Richard Weigand stated that as of that date
	  the order requiring the obtaining of the "IP" [Interpol] DC
	  files hasn't begun yet".  Mr. Meisner identifies the signature
	  "Dick" as having been made by the defendant Weigand.
		       
		       A.   The Order to Infiltrate the Internal
			   Revenue Service in Washington, D.C.

		In the late summer of 1974, the defendant Cindy Raymond,
	who then held the position of Collections Officer in the US
	Information Bureau in Los Angeles, California, sent a directive
	to Michael Meisner ordering him to recruit a loyal Scientologist
	to be placed as a covert agent at Internal Revenue Service
	in Washington, D.C. That covert operative was to obtain
	employment with the Internal Revenue Service for the pur-
	pose of taking from that agency all documents which dealt with



- -----------------------------------------------------------
						 
				18

      Scientology, including those concerning pending litigation
      initiated by Scientology against the United States Government.
      Mr. Meisner discussed the recruiting of that covert operative
      with the defendant Raymond on at least a weekly basis for                 
      three to four weeks. 8/  As a result of the directive
      which he received from Ms. Raymond and the discussions with
      her, Mr. Meisner and the defendant Mitchell Hermann proceeded
      to interview Scientologists as prospective agents for the
      IRS infiltration. The efforts of Messrs. Meisner and Hermann
      proved futile however, and the defendants Raymond in September,
      1974 informed Mr. Meisner that she had selected defendant
      Gerald Bennett Wolfe to infiltrate the IRS on behalf of the
      Church of Scientology. Mr. Wolfe arrived in the District of
      Columbia in October 1974, and eventually obtained employment
      at the IRS on November 18, 1974, as a clerk typist.

	    8/   Mr. Meisner had repeated and extensive dealings with
       the defendant Raymond who was one of his superiors in Los
       Angeles; he had  with her on several occasions and had
       become able to identify her voice.

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

				19

	 Government Exhibit Nos. 3 9/and 4 10/ are virtually
    identical copies of Guardian Order 1361 issued 21 October
    1974 Mr. Meisner and Ms. Hirsch state that the document
    in question was issued by the Guardian World-Wide Jane Kember
    in accordance with required Guardian Office procedure for
    the issuance of Guardian Orders. 11/ Ms. Hirsch identifies
    the initials which appear at the lower, left-hand of page ten
    on each exhibit as those of Lexie Ramirez (Ms. Kember's
    secretary at the time). Furthermore, Mr. Meisner states
    that certain targets (target number 10, 16 and 17 located at
    page nine of Government Exhibit Nos. 3 and 4), were specif-
    cally assigned to him to carry out in the District of Columbia.

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

		  9/ Government Exhibit No. 3 was seized by Special Agent
	    James R. Kramarsic from a file cabinet in the office of the
	    defendant Heldt at Fifield Manor.

		10/ Government Exhibit No. 4 was seized by Special Agent
	    Robert H. Claudius from a file cabinet in Room 5 at the Cedars
	    Complex.

		 11/   A "Guardian Order" (later called "Guardian Program
	    Order") is an official order directing the implementation of
	    a program, outlining it's purpose, the "ideal scene" which its
	    implementation is to create, and the various targets which
	    have to be put into effect. It also designates the official
	    and bureau responsible for carrying out, the particular target(s).
	    Only L. Ron Hubbard, Mary Sue Hubbard and Jane Kember have
	    authority to issue Guardian Orders. While such orders may
	    be drafted and proposed by other high officials, they may be
	    issued only by one of the above-mentioned three individuals.


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

				20

	   These targets were as follows:

		      10. Immediately get an agent into DC
			    IRS to obtain files on LRH.
			    Scientology, etc. in the Chief
			    Council's [sic] office, the Special
			    Services staff, the intelligence
			    division, Audit Division, and any
			    other areas.

		      16.   Collect data on the Justice Dept.
			    Tax Division for the org board, the
			    current terminals, and the people
			    handling Scientology.

		      17.   When the correct areas are isolated,
			    infiltrate and get the files.


	   The entry at the end of each target, and connected to it by a
	   straight line,  refers to the bureau and official whose task it 
	   is to achieve that particular target. Guardian Order 1361
	   (generally known as GO 1361) also called for the placing of


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

				21

	  "an agent, trustworthy and well grooved in, to infiltrate
	  the IRS LA office" (target 2).  That "agent" was "to obtain
	  any files on LRH, Scientology", etc. from both the Intelligence
	  Division (target 3) and the Audit Division (target 4) of the Los
	  Angeles IRS Office.  It also called for the location (target 20)
	  and infiltration  (target 22)  of the IRS London Office in
	  order to "obtain all documents" (target 22). 12/ Guardian
	  Order 1361 directed that once documents had been obtained
	  clandestinely, the designated bureau and official would
	  create "suitable cover" to disguise the manner in which "the
	  data was obtained" so that they may be released to "PR [Public
	  Relations] for dead agenting," that is, for possible use in
	  impeaching those perceived as enemies of Scientology.

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

	       12/  On or about March 3, 1976, U.S. Directorate Secretary
	  World-Wide Michael Taylor informed the defendant Willarson
	  that the IRS London targets had been "handled." See the hand-
	  written notation at the lower left hand side of Government
	  Exhibit No. 56E. Mr. Meisner identifies the "Greg" signature
	  at the end of the letter and the initials "GW" next to the
	  title "Natl Sec US B1" in the routing as having been made by
	  the defendant Willardson.

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

				       22

	      The defendant Cindy Raymond repeatedly discussed GO 1361
      and its various targets with Mr. Meisner over a period of two
      years. Indeed, defendants Henning Heldt, Duke Snider, Richard
      Weigand, Gregory Willardson,  Mitchell Hermann, and Gerald
      Bennett Wolfe also discussed on many occasions with Mr.
      Meisner the actual implementation of GO 1361. in the District
      of Columbia.  These conversations occurred both in person, in
      writing and by telephone. Those in person took place in
      Washington, D.C., and Los Angeles, California, and are dis-
      cussed at length infra. At all times these seven defendants
      expressed their agreement with, and total understanding of,
      the targets within GO 1361, a number of which involved the
      infiltration of Government offices and the theft of government
      documents and photocopies thereof as called for by targets
      10, 16 and 17.

		      B.    The Bugging of the IRS Cheif Counsel's
		      Conference Room on November 1, 1974

		  A few days before November 1, 1974, Don Alverzo, who held
	      the position or Deputy Information Branch I Director US tele-
	      phoned Mr. Meisner from Los Angeles, California, to inform

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

				      23
				
	him that he was coming to the District of Columbia to place
	an electronic bugging device in the Chief Counsel's
	conference room at the Internal Revenue Service where a major
	meeting concerning Scientology was to be held. On October
	30, 1974, Mr. Meisner met Mr. Alverzo at the Guardian's Office
	located at 2125 S Street, Northwest, in the District of
	Columbia. Also present at this meeting were the defendants
	Mitchell Hermann and Bruce Ullman who held the position of
	Information Branch II Director in the District of Columbia.
	Alverzo showed Meisner the bugging device  which he had
	brought with him from Los Angeles.  One of the items Alverzo
	had was a multiple electric outlet containing a transmitting
	device.   In the late afternoon of October 30 Mr. Meisner
	and the defendant Mitchell Hermann entered the main IRS build-
	ing located at 1111 Constitution Avenue, northwest, for the
	purpose of locating the conference room of the Chief Counsel's
	office where the meeting was to be held on November 1, 1974 13/

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

		13/   The Guardian's Office had received notification that 
	such a meeting was to be held through attorneys who represented 
	the Church of Scientology in their pending lawsuit regarding
	the tax exempt status of some churches of Scientology.

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

						24
		
	     On November 1, 1974, because of other pressing business
	Mr. Meisner did not accompany Mr. Alverzo during the IRS
	bugging. However, on the evening of November 1, 1974
	subsequent to the IRS conference,  Meisner met with the
	defendant Mitchell Hermann who described to him what had
	taken place. The defendant Hermann told Mr. Meisner that ha
	had entered the main IRS building on the morning of November
	1, 1974, gone to the conference room, where the meeting was
	to be held and placed the bugging device in a wall socket
	in that room.  The room was located on the fourth floor of
	the Internal Revenue Service main building in Washington
	D.C. and faced the driveway of the Smithsonian Institution
	Museum of History and Technology on Constitution Avenue
	Northwest. 14/  Thereafter, Hermann left the building and
	waited in a car in the driveway of the museum with Don Alverzo
	and Carla Moxon (the Assistant Guardian Communicator (Secretary)
	in the District of Columbia) and overheard and taped the 

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

	  14/   In fact, that conference room was actually located
	there on November 1, 1974.

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

				   25

	entire meeting over the FM radio of the car. Following the
	conclusion of the meeting, the defendant Hermann reentered
	the IRS building, removed the bugging equipment from the
	conference room and took various papers, including the agenda
	for the meeting, which had been left by the participants.
	He showed these items to  Mr. Meisner. Soon afterwards Alverzo
	returned to Los Angeles. He took with him the bugging device,
	and the tape recording of the meeting. 15/
	
	- ------------------

	    15/    During the lawful execution of United States Magi-
	trate search warrants unpn premises of the Church of Scientology
	of California known as the Cedars Complex on July 8, 1977
	Federal Bureau of Investigation  Special Agent Eusebic Benavidez
	seized a black suitcase containing electronic bugging
	devices from the office of the defendant Gregory Willardson
	These included Exhibits 190 to 194.  See photograph marked
	Government Exhibit No. 217 appended hereto. Federal Bureau
	of Investigation Agent James O. Davis, assigned to the labora-
	tory at FBI headquarters and an expert on electronic bugging
	devices, concludes that Government Exhibit No. 190 is  an FM
	radio monitor; Government Exhibit No. 191 is an electronic
	device in a gold colored box which he found to be "a miniature
	transmitter primarily used for the surreptitious interception
	or oral communications"; and Government Exhibit No. 192 is a
	battery connection which he concluded was a "miniature frequency
	modulated radio transmitter." Agent Davis also finds that 
	Exhibit No. 193 is a telephone resonator which he describes
	as a "transmitter unit from a standard phone handset." It
	also allows one to use a standard FM radio to monitor phone
		   (Footnote continued on next page.)

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

				       26

		Governnent Exhibit No. 5 16/ is a November 1, 1974
	letter, entitled "Re: IRS Top Planning Session," from the
	defendant Duke Snider who was then, as reflected by the
	routing on the upper left hand side of the first page, the
	DG Info US. to Mo Budlong, the DG Info World-Wide. The
	letter is sent via a number of other individuals. A copy
	was also sent, according to the routing on the upper portion
	of the first page, to CSG, the defendant Mary Sue Hubbard.
	Mr.  Meisner states that the routing conforms to the standard
	routing requirements of the Guardian Office and indicates
	that it was sent by the defendant Snider to Mr. Budlong.
	Handwriting expert,  James Miller, concludes that it is
	probable that the handwritten notations "Top Planning Session"

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

		       (footnote continued from proceeding page.)
	conversation. Government Exhibit 194 is a wall receptacle
	which Agent Davis states is a "miniature frequency modulated
	radio transmitter concealed in a standard three-plug wall
	receptacle," and which would allow the user to employ a 
	standard FM radio  for monitoring purposes. Agent Davis
	concludes that in his opinion all these items are "primarily
	used for the surreptitious interception of oral communications."

		16/       Government Exhibit No. 5 was seized by Agent
	Jerry D. Delap, from a filing cabinet located in the Information
	Bureau at the Cedars Complex, and inventoried and initialed
	by Special Agent John F. Keller.

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

				     27
	
	in the title of the letter and the one on the second page
	or the document are in the handwriting  of the defendant
	Duke Snider. Mr. Meisner himself recognizes that handwriting
	to be that of the defendant Duke Snider.
		The letter stated that "[t]oday we gained access to the
	top level IRS planning conference on what to do about Scien-
	tology.  This was done electronically so we don't know exactly
	who was present but we have a fair estimate. Legal had told
	us several weeks ago that there was to be a big IRS Pow Wow
	on what to do about us on 1 Nov. . . . "   The letter further
	stated that the meeting was held in IRS Chief Counsel's
	conference room and that the participants discussed some of 
	the matters which were taken up at the meeting. In the
	letter, the defendant Snider stated that he "will probably
	be able to got more data as to who attended when our mission-
	aire 17/ gets back from DC.  All the  data we have at present
	came by phone.''

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

		17/ A missionaire is a person sent to a certain location
	with specific mission orders to carry out -- in this case Mr.
	Alverzo.

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

				     28

	   Government Exhibits Nos. 6 and 187 are coded transcripts
	of the bugged IRS meeting of November 1, 1974. Government
	Exhibit No. 6 is a summary of the meeting. Mr. Meisner
	identifies Government Exhibit No. 6 by the routing in the
	upper left-hand and right-hand sides of the first page. As
	reflected in its routing, it was sent by the then DG Info US,
	the defendant Snider, to the DG Info World-Wide, Mo Budlong,
	via. the DG US, the defendant Henning Heldt and the Guardian
	World-Wide, Jane Kember, with a copy to CSG, the defendant
	Mary Sue Hubbard. Government Exhibit Nos. 7A and 7B are code
	Jade.    The handwritten entries on page two of Government
	Exhibit No. 7B, indicated that this was a code which is to
	be used for correspondence between the United States
	Office and the World-Wide Guardian's Office among others.
	Code Jade was not to be used with "outer-orgs" meaning local
	Guardian's Offices. Government Exhibits Nos. 6, 7 and 187 were
	seized on July 8, 1977, in Los Angeles, California, by Federal
	Bureau of Investigation Special Agent Eusebio Benavidez pursuant
	to the Court-authorized search warrant described in footnote six,

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

				    29
	
	supra, from a file cabinet in the office of Gregory Willardson
	in the Cedars Complex.
	    Federal Bureau of Investigation Special Agent Arthur R.
	Eberhardt, a Federal Bureau of Investigation cryptanalyst
	examined Government Exhibits Nos. 6 and 187 and concludes that
	they were coded texts each utilizing two different methods of
	substitution codes. One method is a "digital code" which
	uses the substitution of digits 10 through 99 for the various
	letters of the alphabet, thereby allowing the author to sub-
	stitute a variety of digits for any  given plaintext letter
	The other method is a "literal code" which involves the
	substitution of letters or a word or words. Encoded letters
	have only one plaintext value and retain the same value at
	all times.    Agent Eberhardt also analyzed Government Exhibit
	Nos. 7A and 7B and concludes that code Jade as set forth in
	these exhibits was the code used It-Iri prepare the
	marked Government Exhibit Nos. 6 and 187. Using code Jade
	(Government Exhibits 7A and 7B) Agent Eberhardt decoded
	Government Exhibits 6 and 187. He did so by writing above

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

					   30
	
	 all coded items its decoded meaning.  Thus Government Exhi-
	 bit 6 as decoded is Government Exhibit 210 and Government
	 Exhibit 187 as decoded is Government Exhibit 211.  These
	 exhibits are transcripts of the bugged meeting held in the
	 IRS Chief Counsel's conference room on November 1, 1974.
	 Government Exhibit 210 is a summary of that transcript and
	 Government Exhibit 211 is the full transcript. At the bottom
	 of page six and at the top of page seven of Government Exhibit
	 210 the defendant Snider wrote to his superior Mo Budlong
	 that "[w]e must be careful with this transcript as even in the
	 distant future in the hands of the enemy the repercussions
	 would be great. There are new laws on this federally and a
	 strong post-Watergate Judicial climate."   Thus, the
	 Duke Snider, himself recognized in this letter the criminal
	 implications of the bugging of the IRS meeting on November
	 1, 1971.
		 On November 1, 1971, Mr. Lewis Hubbard, was employed by
	 the Office of the Chief Counsel of the Internal Revenue
	 Service at 1111 Constitution Avenue, Northwest, and on that
	 date attended a meeting in the Chief Counsel's conference

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

			       31

      room. Numerous other high officials of the IRS attended
      this meeting. Mr. Hubbard states that the IRS held the
      November 1, 1974 conference to discuss pending legal actions
      involving the various churches Of Scientology and to establish
      general guidelines for determination oh what constituted a
      "religious institution" entitled to exemption from taxation
      under the Internal Revenue Code. Mr. Hubbard has produced
      from his files a lengthy pre-conference memorandum which he
      prepared at the request of the Chief Counsel in order to
      brief all persons who were to attend the November 1, 1974
      conference regarding the topics to be discussed (Government
      Exhibit No. 208). He has also produced a post-conference
      memorandum which he prepared following the conclusion of the
      November 1, 1974 conference and which outlines the matters
      discussed at that conference (Government Exhibit No. 209).
      A comparison of these two exhibits with Government Exhibits
      Nos. 210 and 211, (the FBI decodes of Government Exhibits Nos.
      6 and 187 respectively seized from the offices of the defendant
      Willardson at the Cedars Complex by the Federal Bureau of

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

				       32
	
	Investigation) demonstrates that all four exhibits deal with
	precisely the same discussions.

		  C. The First Infiltration of the IRS in the
		     District of Columbia Pursuant to GO 1361


	      Government Exhibits Nos. 8-11  18/ are a series of
	 documents containing numerous telexes and letters dealing
	 with the infiltration of the Internal Revenue Service by the
	 defendant Gerald Bennett Wolfe pursuant to GO 1361. Mr.
	 Meisner identifies the telexes as being in the standard
	 telex routing and format employed by the Guardian's Office
	 and the Information Bureau whenever sending telexes during
	 this period. Government Exhibit No. 8A reads as follows:


					TELEX

		    311039GOUS 4 AGI DC VIA DG US MIKE
		    WHAT HAPPENED ON GETTING FSM PAST HIRING
		    FREEZE ON TARGET ARC AM CHECKING OUR LINES
		    FOR JUSTICE PERSON AS PREVIOUS ONE FELL
		    THROUGH ARC CONTINUE TO LOOK YOUR END ARC
		    TLX REPLY LOVE DUKE DGI US

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

	       18/ Government Exhibits Nos. 8-11 were seized by
	  Special Agent James J. Smith from Room 4 of the Information
	  Bureau at the Cedars Complex.

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

					   33

	       Mr. Meisner explains that the numerals at the beginning
	  of the first line of the telex represent the following:

	       31  - day
	       10  - month
	       39  - number of the telex sent from the U.S.
		     Guardian's Office on 31/10/1974
	       GOUS -    Guardian Office US, originator of the telex
	       4 - the number of telexes on that topic
	       AGI DC - the addressee

	  The date "3110," meaning October 31, using the European system
	  for setting out the date indicates that the first telex
	  on this topic was sent on October 31.  The routine also shows
	  that this is the fourth telex on the topic discussed in the
	  text of the telex, and the handwritten notation on the
	  states that it was sent on "11.10.74" or November 10, 1974.
	  The concluding line "Love Duke DGI US" reveals that it was
	  sent by the defendant, Duke Snider, the Deputy Guardian for
	  Information in the United States.   The abbreviation "ARC" is
	  a Scientology term used in telexes as an alternative to
	  "STOP". "FSM" is an abbreviation for "field staff member"
	  a term, used in the Information Bureau for covert operatives.
	  All other telexes in Government Exhibits Nos. 8 through 11
	  carry the same routing and format and thus explain when they

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

				       34

	were sent, by whom, and to whom, as well as the sequence
	in which they were sent. Thus, Government Exhibit No. 8A is
	a telex from the defendant Snider, the "DGI US" to Michael
	Meisner the "AGI DC." Mr. Meisner recalls having received
	it from the defendant Snider.  In it, the defendant Snider
	inquired whether Gerald Bennett Wolfe, the "FSM" to be placed
	at the IRS had been able to obtain employment in view of the
	hiring freeze there. Handwriting expert James Miller concludes
	that it is "highly probable" that the initials "DS" next
	to "DGI US" were written by the defendant Snider. Mr.
	Meisner identifies them as initials made by the defendant 
	Snider.  Government Exhibit No. 8B is the telex which Mr.
	Meisner, the "AGI DC," sent to "DGI US" Duke Snider, via
	"DG US" Henning Heldt stating that Gerald Wolfe, the "FSM"
	had apparently passed the hiring freeze and that they "will
	know for sure" Whether he has received employment by November
	18 at the latest. A notation on that telex indicates that it
	was received on "11.11.74" at "2000" hours (8:00 p.m.).
	Government Exhibit No. 8C is a telex from the defendant Snider,
	the "DGI US," to Mr. Meisner, the "AGI DC," stating "excellent

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

					 35

	 on both pls [please] keep me informed by telex". Mr. Meisner,
	 also recalls receiving that telex from the defendant Snider.
	 The handwriting "IRS + JUSTICE PENETRATION" in the upper
	 portion of Government Exhibit No. 8C is identified by
	 Meisner, as that of the defendant Duke Snider.
	      Government Exhibit No. 8D is a telex from Mr. Meisner
	 to the Guardian's Office U.S. in Los Angeles, California,
	 informing it that "FSM past freeze and in initial placement
	 in Income Tax Division as clerical." In this manner, Meisner
	 notified the Los Angeles Guardian's Office that the defendant
	 Wolfe had obtained employment and was working as a clerk at
	 the IRS Income Tax Division. Mr. Meisner recalls sending
	 this particular telex to the defendant Snider, Government
	 Exhibit No. 8E is a response to the previous telex from
	 "DGI US" Duke Snider to "AGI DC" Meisner congratulating Mr.
	 Meisner for his work.   The abbreviation "VVWD" means "very
	 very well done". Mr. Meisner recalls receiving that telex.
	 Government Exhibit 8, the cover letter dated November 11,
	 1974 was written by Mr. Joe Lisa, the Deputy Deputy Guardian
	 for Information U.S. (DDG I US), to the defendant Gregory

- ---------------------------------------------------------------
							 
				  36
	
	Willardson, the Information Branch I Director U.S., regarding
	the "IRS evaluation" GO 1361, target 10, and directed Mr.
	Willardson "to get this started immediately and push this
	hard" to get it accomplished. 19/
	      Government Exhibit No. 9A is a telex sent on "14.11"
	November 14 1974) by "DGI US" Duke Snider, to DGI WW,"
	Mo Budlong, "Re: GO 1361 Tar [target] 10," which informed Mr.
	Budlong, that despite the national hiring freeze defendant
	Gerald Bennett Wolfe had accepted employment at the IRS.
	Mr. James Miller, the handwriting expert, positively identi-
	fied the defendant Henning Heldt as the writer of the initials
	next to "DG US" and states that the initials next to "DGI US"
	were probably written by the defendant Duke Snider. Mr.
	Meisner himself recognizes the handwriting "despite freeze"
	and the initials next to "DGI US" are made by the defendant
	Snider, and the initials next to "DG US" as made by the defendant
	Heldt.   Government Exhibit No. 9 is a telex received "15.11.74"
	 
- -------------------

	    19/ Mr. Meisner states that GO 1361 was also known as
	"IRS EVAL" [evaluation]

- ---------------------------------------------------------------
							  
				   37

	(November 15, 1974) at "2000" hours (8:00 P.M.) from Mr.
	Budlong to the defendant Snider, the "DGI US," which con-
	gratulated him on the placement of a covert agent at IRS.
	The routing at the beginning of the telex indicates that
	it is in response to Government Exhibit No. 9A. Mr. Meisner
	recognizes the handwriting on the upper portion of Government
	Exhibit No. 9 as that of the defendant Duke Snider.
	     During the first week of December 1974 Meisner and the
	defendant Mitchell Hermann entered the IRS building located
	at 1111 Constitution Avenue, Northwest, Washington, D.C., and
	remained inside until sometime after 7:00 p.m. At that
	time, Mr. Meisner and the defendant Hermann entered without
	permission offices of the Exempt Organization Division on
	the seventh floor; removed from the building one file relat-
	ing to Scientology and took it to the Guardian's Office in
	Washington, D.C.; and photocopied it there. The next day,
	the defendant Hermann returned it to  the IRS files. The pur-
	pose of their entry was to show to the defendant Gerald Bennett
	Wolfe that documents could easily be taken from the Internal
					       
- ---------------------------------------------------------------

					38
	
	Revenue Offices. Following that entry, Mr. Meisner called
	the defendant Duke Snider in Los Angeles, California, and
	told him what he and Hermann had accomplished inside the IRS
	and what documents had been stolen. He told the defendant
	Snider that the entry which he and Hermann had made proved
	conclusively the ease with which documents could be taken from
	the IRS.
	     Government Exhibit No. 10A is a telex sent on December 4,
	1974 at "2200" hours by the "DGI US," Duke Snider, to the "DGI
	WW" Mo Budlong regarding "GO 1361 TAR 10." The telex informed
	Mr. Budlong that the defendant Snider and his associates had 
	received "two shipments from DC . . .  about ten inches" thick
	containing documents which the defendants Hermann and Wolfe and
	Mr. Meisner had stolen from the IRS. Handwriting Expert
	James Miller concludes that the initials next to "DGUS" were
	probably made by the defendant Heldt and that the initials
	next to "DGIUS" were highly probably by made by the defendant
	Snider. Mr. Meisner recognizes each set of initial as being
	made by the defendants Heldt and Duke Snider respectively.

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

					39

	Government Exhibit No. 10, a telex from Mr. Budlong to the
	defendant Snider is a response to Government Exhibit No. 10A
	stated "Duke such news brings joy to my heart ARC Absolutely
	fantastic ARC I can't wait to see the data."  Mr. Meisner
	recognizes the handwriting in the upper portion of Government.
	Exhibit No. 30, with the exception of "DW6/12" as that
	of the defendant Snider; and the handwriting "DW6/12" as that
	of the defendant Richard "Dick" Weigand.  The telex indicated
	that it was received at "1400" (2:00 p.m.) hours on "5.12.74"
	(December 5, 1974).
		Government Exhibit No. 11 contains two letters. The
	second and earlier letter in the exhibit, dated November 11,
	1974 is from Joe Lisa, the then Deputy Deputy Guardian for
	Information U.S. to the defendant Willardson, the Branch I
	Director US. It directed the District of Columbia Guardian's
	Office to immediately obtain documents from the IRS pursuant
	to Target 10 of GO 1361. (The letter is identical to Govern-
	ment Exhibit. No. 8.) The first page of Government Exhibit
	No. 11, dated "9 December 74," is the defendant Willardson's

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

					40

	response in Lisa's November 11 letter. It informed Mr. Lisa
	that Target 10 of GO 1361, which called for getting an "FSM"
	into the IRS in the District of Columbia, had been achieved,
	and that compliance had already been reported to the World-
	Wide Guardian's Office.
	     During his initial employment at the IRS, the defendant
	Wolfe was supervised by the defendant Hermann. As such the
	defendant Hermann maintained all contacts with defendant
	Wolfe. 20/ Defendant Hermann himself was a direct subordinate
	of Mr. Meisner during this period and reported regularly to
	Mr. Meisner, on defendant Wolfe's accomplishments. In mid-
	December 1974, the defendant Mitchell Hermann went on vaca-
	tion, and Meisner took over the supervision of the defendant
	Gerald Bennett Wolfe. Before he left, however, the defendant
	Hermann arranged for Mr. Meisner to meet the defendant Wolfe

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

	    20/  Government Exhibit No. 46A (page six of Exhibit 46)
	is a handwritten note dated January 9, 1975, which states "I
	attest that I have placed and am running an FSM at Silver
	[code name for the IRS] and am attaching the accompanying
	documents as evidence." Handwriting expert James Miller
	positively identifies the note as having been written by the
	defendant Hermann.

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

				       41

	in an Arlington, Virginia, parking lot and bring him over to
	the defendant Hermann's house located on Fessenden Street,
	Northwest, Washington, D.C., to coordinate future plans.  At
	the parking lot, Mr. Meisner introduced himself to the defend-
	ant Wolfe using his real name; however because Wolfe felt
	more comfortable being called by a name other than his own,
	Mr. Meisner called the defendant Wolfe "Kelly". During the
	subsequent one-half hour meeting in the defendant Hermann's
	house, Meisner and the defendant Wolfe discussed Wolfe's
	job and background. The defendant Wolfe had previously been
	informed by the defendant Hermann that Mr. Meisner was the
	Assistant Guardian for Information in the District or Columbia
	The defendant Wolfe was also told by Mr. Meisner that he
	could reach him at any time by calling him either at his
	office at 2125 S Street, northwest, Washington, D.C. or at
	his home in Arlington, Virginia. The defendant Hermann instruc-
	ted the defendant Wolfe continue obtaining all documents
	related to Scientology from the IRS office of Barbara Bird,
	an attorney in Refund Litigation Service. 21/

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

	21/ Ms. Bird was also a participant in the November 1, 1974
	conference that was bugged by Scientology agents.

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

					42

	Thereafter, a few days prior to December 30, 1974, the
	defendant Wolfe entered the office of Barbara Bird located
	in the main building of the IRS at 1111 Constitution Avenue
	northwest, Washington, D.C., without  permission ,and took
	from her files many documents related to Scientology. He
	photocopied them on a photocopying machine in the IRS Building
	using United States property and paper to accomplish the
	task. Upon completion of the photocopying, the defendant
	returned the documents to Ms. Bird's office. At a subsequent
	meeting with Mr. Meisner at a Lums Restaurant in nearby
	Virginia, he gave him the stolen documents.  22/ He explained
	to Mr. Meisner, how he had obtained the documents from a
	file in Barbara Bird's office which contained documents related
	to Scientology which Bird had acquired from former IRS official
	Charlotte Murphy. Mr. Meisner, took the documents to his office

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

	22/   Mr. Wolfe told Mr. Meisner that Ms. Bird had two doors
	leading to her suite of offices, one of which was blocked by a 
	table. Mr. Wolfe went in during the day, unlocked the latter
	door and proceeded to use the door whenever he entered her
	office either at night or on weekends.

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

					43

	at 2125 S Street, Northwest, reviewed them, and summarized
	them in a memorandum to his superiors in the U.S. Guardian's
	Office.
	    Whenever he received stolen documents from the defendant
	Wolfe, Mr. Meisner marked each one with an initial at the
	lower, right-hand side, underlined those portions which he
	believed to be particularly important to his superiors in
	the Guardian's Office, and typed any one which was either
	handwritten or illegible. He then prepared a memorandum
	addressed to his immediate superiors in Los Angeles which
	summarized each important point in the documents, and placed
	at the end of each excerption the corresponding number of
	the document which he had just summarized.  He then routed
	the finished memorandum through the Assistant Guardian for
	the District of Columbia to his superiors in Los Angeles
	who included the Deputy Guardian for the United States, the
	Deputy Guardian for Information in the United States, the
	Branch I Director of the Information Bureau, and the Collec-
	tions Officer. He also sent a copy of the material to the

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

					     44

	Commodore Staff Guardian (CSG) , the defendant Mary Sue Hubbard.
	Until January 1976, all such memoranda and supporting documents
	were sent to the defendant Cindy Raymond who as Collections
	Officer within the Information Bureau, was in charge of the
	gathering of covertly obtained documents. After the reorgan-
	ization of the Information Bureau in January 1976, almost
	all memoranda regarding stolen documents were sent to the
	defendant Hermann under his alias "Mike Cooper".  The defendant
	Hermann was, subsequent to January 1976, the Southeast U.S.
	Secretary of the Information Bureau, and as such had
	immediate supervision over the Information Bureau in the
	District of Columbia. The only exception to this January
	1976 procedure occurred in regards to stolen Interpol documents,
	which were still to the defendant Raymond who had become
	the Information Bureau Director National U.S. All such
	memoranda were typed by Mr. Meisner himself and were prepared
	in accordance with established Guardian's Office procedures.
	Government Exhibit No. 12 23/ is a 30 December 1974

- ------------------
	
	23/ Government Exhibit No. 12 was seized by Special Agent
	Roger L. Lehman from a file cabinet in Room 30 in the Informa-
	tion Bureau at the Cedars Complex.
						     
- ---------------------------------------------------------------                                                     
						     
				    45

	memorandum from Mr. Meisner to the defendant, Cindy Raymond
	entitled "Raw Data Report Re: IRS-Charlotte Murphy Scientology
	File." It summarizes documents taken by the defendant Gerald
	Bennett Wolfe from the offices of Barbara Bird at the IRS as
	outlined supra. Mr. Meisner appended to that memorandum, and
	sent it to Los Angeles, at least ninety eight pages of documents
	taken from the IRS. (See Government Exhibit No. 12 at p. 7,
	paragraph 3). The routing portion which appears in the
	upper left-hand side of the memorandum reflects that the "AG
	Info DC", Michael Meisner, sent the memorandum to the Collec-
	tion Officer US,  the defendant  Raymond, via the Assistant
	Guardian for the District of Columbia, Lynn McNeil, who
	initialed it on "30/12" (30 December 1974). McNeil's notation
	shows that she reviewed it on that day and transmitted it
	to the Deputy Guardian Communicator (Secretary) for the United
	States and the Deputy Guardian for the United States, the
	defendant Heldt. "DG Info US", the defendant Weigand, placed
	his initials next to his title on January 6, 1975 ("6/1/75"),
	as did the "Info Br I Dir US", the defendant Willardson,

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

					46

	who initialed it on 10 January 1975 ("10 Jan") The defendant
	Willardson then wrote a note to the defendant Raymond indi-
	cating he had reshuffled the order, of the documents. 24/
	During the early part of January 1975, the defendant
	Hermann returned to the District of Columbia from his vacation
	and resumed his duties as supervisor of all Scientology co-
	vert operatives, who included the defendants Wolfe and Sharon
	Thomas and Ms. Nancy Douglass. The defendant Thomas was at
	the time a Scientology covert agent at the Coast Guard
	Intelligence. Ms. Douglass was a Scientology covert operative
	at the Drug Enforcement Administration (DEA) from where she
	stole documents and photocopies thereof and transmitted them
	over to the defendant Hermann. The defendant Hermann contin-
	ued his duties in the District of Columbia until early March

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

	24/ Handwriting analysis shows that it is "highly
	probable" that the defendant Willardson wrote the handwritten
	note. Mr. Meisner recognizes the initials of Ms. McNeil and
	the defendants Weigand and Willardson next to their respective
	titles in the routing portion of the document, as well as 
	the handwriting of the defendant Willardson in the note to
	"Cindy". The routing also indicates that a copy of the memo-
	randum and attached documents were sent to the "CSG" (Commodore
	Staff Guardian) the defendant Hubbard.

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

					    47

	1975 when he was transferred to Chicago, Illinois, to continue
	to work for the Guardian's Office.
	      Government Exhibit No. 13 25/ is a memorandum from the 
	defendant "Mitch" Hermann to defendant  Raymond regarding
	documents stolen from the Chief Counsel's file room at the
	IRS pursuant to "GO 1361 TGT #10." The March 1, 1975 memo-
	randum, which summarized the stolen documents, was routed
	through the Acting Assistant Guardian for the District of
	Columbia who, at the time, was Mr. Meisner. The defendant
	Hermann was then Acting Assistant Guardian for Information in
	the District of Columbia.  26/ The defendant Cindy Raymond
	received the memorandum and placed on the upper right-hand side

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

	25/  Government Exhibit No. 13 was seized by Peter J.
	Flanagan from a file cabinet located in the Information
	Bureau at the Cedars Complex. It was inventoried by Special
	Agent  Richard W. Noyes.

	26/ Next to the title for the "INFO BR I DIR US" in the
	routing portion of the memorandum is the signature of the
	defendant Gregory Willardson, indicating that he received
	the documents on March 7, 1975. Handwriting expert Miller
	concluded that it is "probable" that the defendant Willardson
	wrote the four-line notation beginning with his initials and
	date.

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

						48
	
	of page one above the date "CC: DG Legal US, DG PR US". 27/
	   In  late May 1975, the defendant Gregory Willardson directed
	Mr. Meisner to implement "Project Horn" which Willardson, him
	self, authored. "Project Horn" appended to Government Exhibit
	No. 14 28/ was issued in order to "provide a cover for PR
	[Public Relations] and legal for the way they obtained IRS
	docs." The project further implemented Guardian Order 1361,
	Target 6, which had already provided for the creation or a
	"suitable cover" to disguise the true manner in which stolen
	documents had been obtained from the IRS so that the Public
	Relations Bureau could use them without fear of being connected
	to the thefts. Towards this end, defendant Gregory Willardson

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

	    27/ Mr. Miller positively identifies the defendant
	  Raymond as the writer of that notation. He also concludes
	  as "probable" that the defendant Hermann signed "Mitch" at
	  page two or the memorandum. Mr. Meisner specifically recog-
	  nizes that signature as that of the defendant Hermann and
	  moreover, recognizes the entire document based upon his
	  recollection of having received it from Hermann and having
	  sent it with the appended documents to his superiors in
	  Los Angeles, with i copy to "CSG", the defendant Mary Sue
	  Hubbard.

		28/  Exhibit No. 14 was seized from Room 4, of the 
	   Information Bureau at the Cedars Complex by Special
	   Agent James J. Smith and inventoried by Special Agent Gilberto
	   Valencia.

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

					  49

	  assigned to Mr. Meisner, as the Assistant Guardian for Informa-
	  tion in the District of Columbia, the task of stealing IRS
	  documents concerning organizations other than Scientology.
	  Thus, whenever any stolen IRS documents were later released,
	  those other organizations would also be perceived as having
	  received them and their publications would, thereby, not point
	  to the Church of Scientology alone.  Additionally, the project
	  ordered the theft of IRS stationery so it might be used by
	  members of the Guardian's Office to draft false letters from
	  a fictitious IRS employee disgruntled with the organization.
	  The stolen documents would then be attached to the letters which
	  would be sent to private organizations such as Scientology.
	  Government Exhibit No. 14 (at page 1) is a 9 April, 1975
	  letter from the defendant Willardson to Jane Kember and Mo
	  Budlong stating that he had complied with GO 1361 target 6
	  by devising the "Project Horn" which he appended to that
	  letter. 29/ In a letter dated 9 April 75 found at page six of

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

	   29/ The signature "Greg" on page one has been positively
	identified by handwriting analysis as that of the defendant
	Willardson. Similarly, the handwritten notation "sent to DC,
		   (footnote continued on next page.)


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

				50

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

		(footnote continued from proceeding page.)
		       
	late May. GW" at the lower right-hand corner of that page has
	also been positively identified as having been written by the
	defendant Willardson. Handwriting expert James Miller has
	concluded that it is "highly probable" that the defendant
	Richard Weigand wrote the handwritten notation "Greg - What
	was this? L. Dick" located at the top of the page. Mr.
	Meisner identifies the handwritten notation "A very good
	method!" located above the title of the letter, as in the hand-
	Writing of Mo Budlong, and the handwritten notation "Dear
	Greg, This is a really bright idea. Very well done. love
	Jane" located at the lower portion of the letter, as in the
	handwriting of Jane Kember. The routine appearing in the
	upper left-hand side of Government Exhibit No. 14 also
	shows that the letter was written by the "Br I Dir US Info",
	the defendant Gregory Willardson, and sent to the "Guardian
	WW," Jane Kember via, among others, the "DG I WW", Mo
	Budlong, who initials it on "22/4" (April 22), the "DG US",
	the defendant Henning Heldt, who initials it as well, "DDG
	US" the defendant Duke Snider, who initials it and dates it
	"9.4" (April) and the "DG I US", the defendant Richard Weigand
	immediately below the title "Br I Dir US info" at the bottom
	of the routing is an arrow with the initials "GW" which have
	been identified by the handwriting expert as probably made
	by the handwriting of the defendant Willardson.
	    
	    Page two of Government Exhibit No. 14 outlines the
	general plan of "Project Horn" as creating a situation
	where a "staff member in the IRS. . . mails out IRS files to
	the persons/groups mentioned in their  files." It then explains
	that such a plan "will provide a cover for PR and legal to
	expose the documents."  The document is issued by "Br 1 Dir"
	who was identified by his own handwriting on page one as the
	defendant Gregory Willardson. The signature "Greg" located at
	the end of the two letters dated 9 April 1975 located at pages
	five and six, respectively, of Government Exhibit No. 14
	have been positively identified by both Mr. James Miller and
	Mr. Meisner as having been written by the defendant Willardson.

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

					 51

	Government Exhibit, No. 14 the defendant Willardson writes to
	the Deputy Guardian of Public Relations for the United States,
	Arthur "Artie" Maren, informing him that "the majority of
	documents called for in this eval [GO 1361] have been obtain-
	ed." He then invited Mr. Maren to come to the Information
	Bureau offices to view the documents "since the quantity of
	data is so extensive." 30/ In accord with "Project Horn"

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

	    30/  On October 13, 1975, the defendant Heldt sent a
	"CSW" (completed staff work) to Jane Kember, the Guardian
	World-Wide, dealing with "the turnover of B-1 data from IRS
	LA, IRS DC, and Justice Dept.  Tax Division to PR and legal to
	get the reports D/A'd (dead agented), and for attacking along
	PR and legal lines." (Government Exhibit No. 51.) The "CSW" is
	requested for proposed Guardian Order 1361-1 to complete
	targets 6-8, 14-15, and 19 of GO 1361 (Government Exhibits
	Nos. 3 and 4). The appended proposed Guardian Order 1361-1
	calls for placing additional "FSMs" into the Los Angeles and
	District of Columbia "target areas'', and preparing the
	stolen government documents for release to the press and for
	use in possible Scientology legal cases. Government Exhibit
	No. 51 was routed through the Deputy Guardians for the Infor-
	mation, Legal, and Public Relations Bureaus World-Wide.
	GO 1361-1 was approved by Jane Kember and issued on 7 November
	1975. (Government Exhibit No. 52.) Mr. Meisner and Ms. Hirsch
	state that it was issued according to established Guardian's
	Office procedures. Ms. Hirsch also testifies that the initials 
	"LR" at the lower, left-hand corner next to the name Jane
	Kember is that of Lexie Ramirez, Ms. Kember's communicator
	(secretary).

		     (footnote continued on next page.)

- ---------------------------------------------------------------
				     
				     52

	
	the defendant Wolfe took from the IRS, stationary of that
	agency and turned it over to Mr. Meisner. Wolfe also took
	from the IRS, without permission, documents related to Bob
	Jones University in South Carolina and the Unification Church.
	After receiving those documents from the defendant Wolfe, Mr.
	Meisner notified the defendant Willardson that he had complied 
	with the preliminary steps of his "Project Horn."

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

			(footnote continued from proceeding page.)

	In a "CSW" dated 27 May 1976 to the defendant Heldt, the
	defendant Weigand informed him that GO 1361-1 target 2 called
	for the "replacement" of "FSMs" at the IRS in the District 
	of Columbia and Los Angeles, California. However, the
	defendant Weigand pointed out that since they had no plans to
	have the "existing "FSM in DC [Wolfe] replaced" and since they
	had been successful in getting the documents from Los Angles
	IRS through other covert means, there was no longer a need
	for target 2 of GO 1361-1. Thus he requested approval for
	the cancellation of that target.  (Government Exhibit No. 107.)
	The defendant Heldt, in handwritten notes positively identified
	as his by handwriting expert James Miller, informed the defen-
	dant Weigand that since the Guardian World-Wide had approved 
	GO 1361-1 only she could approve cancellation. The defendant
	Heldt also enquired whether it would no be prudent to have
	"back-up FSMs" in case the present ones were blown. Mr.
	Miller concludes that the signature "Disk" was probably made
	by the defendant Weigand. Mr. Meisner recognizes the signa-
	ture as having been made by the defendant Weigand and the
	handwriting in the margin as that of the defendant Heldt.
	Government Exhibit Bo. 107 was seized by Special Agent Gilberto
	Valencia from Room 4 in the Information Bureau at the Cedars 
	Complex.

- ---------------------------------------------------------------
								
				   53
	
	      During the first five months of 1975, the defendant
	Wolfe stole documents and photocopies thereof belonging to
	the IRS from the offices of Barbara Bird and Lewis Hubbard of
	the Chief Counsel's Office and from the Chief Counsel's file
	room, as well as from other offices within the suite of
	offices comprising the Office of the Chief Counsel. These
	documents totalled some ten feet in height. The defendant
	Wolfe at that time was employed in the Income Tax Division of
	the IRS and had no authority to enter any of the offices in
	the Chief Counsel's area. Upon receiving these documents,
	the defendant Hermann and Mr. Meisner forwarded them to their
	superiors in the Information Bureau in Los Angeles, California,
	without excerpting them as had previously been done
	because of the enormous backlog of stolen documents not sent
	to Los Angeles. (See Government Exhibits Nos. 12 and 13)
	This circumstance is detailed in Government Exhibit No. 15, 31/                                           
	
- -----------------        
	
	31/ Government Exhibit No. 15 was seized by Special
	Agent Smith from Room 4 of the Information bureau at the
	Cedars Complex. It was inventoried by Special Agent Valencia

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

					54

	"CSW" (completed staff work) 32/  dated 7 May 1975 sent by
	the defendant Willardson to Deputy Guardian for information
	World-Wide, Mo Budlong, and Deputy Guardian for Finance World-
	Wide, Herbie Parkhouse. It explained that the collection of
	U.S. Government documents pursuant to GO 1361 had created a
	crisis in the Information Bureau by causing a slowdown in the 
	collection progress required by GO 1361 which "urgently
	need[ed] to be eliminated." In it, Mr. Willardson states
	that some "15,000" documents had been sent by the District
	of Columbia Information Bureau without excerption in order
	to speed up the process of advising the Deputy Guardian for
	the United States, the defendant Heldt and Commodore Staff
	Guardian, the defendant Hubbard, "as fast as possible as to
	the IRS's intentions in regards to the Church during the ongoing


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

	32/ A "CSW" or "completed staff work" is a request for
	approval or disapproval of a proposed course of action. It
	outlines the problem which it attempts to solve with supporting 
	data, and concludes with the proposal for which approval is
	sought. It ends with two lines marked "approved" and "dis-
	approved" with space for signature. The routing carries
	greater significance in a "CSW."   When initialed next to a 
	title in the routing it indicates that it has both been
	reviewed and approved by that person.

- ---------------------------------------------------------------
					    
				      55

	IRS tax exemption negotiations." The letter added that "[t]his
	was a valuable action in that it resulted in a more real
	estimate as to the IRS scene than was visable [sic] from the
	_Legal_viewpoint_." (emphasis added) 33/ The "CSW" requests the 
	Guardian's Office World-Wide to approve an additional expendi-
	ture of funds for the excerption, xeroxing and cross-filing
	of these "15,000" documents. 34/
	     During the period prior to the theft of the documents
	referred to in Government Exhibit No. 15 the Church of
	Scientology through its subsidiary Church in Hawaii, was
	engaged in extensive litigation with the IRS regarding its
	entitlement to exemption from taxation. The IRS was also
	conducting an audit of the Church of Scientology of Hawaii.
	The defendants Richard Weigand, Gregory Willardson and Cindy

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

	    33/  Handwriting expert James Miller concludes that
	the signature "Greg" at page three is positively in the hand-
	writing of the defendant Willardson. He also concludes that
	it is "probable" that the entry "DW 8/5" next to the title
	"DG I US," in the routing portion of the upper left-hand of
	the front page, is in the handwriting of the defendant Weigand;
	and that the initial next to the title "DG US" is in the
	handwriting of the defendant Heldt. Moreover, Mr. Meisner
	recognizes the handwrititig of both the defendants Willardson
	and Heldt in the document.

		311/  (Footnote on next page.)

- ---------------------------------------------------------------
					   
					   56

	Raymond, personally and in writing, instructed Mr. Meisner to
	direct his attention and that or his covert operative the
	defendant Wolfe, to the theft of all documents relating to
	that tax excemtion battle from the office of IRS attorney
	Lewis Hubbard, located in the main IRS building at 1111
	Constitution Avenue, N.W.in Washington, D.C.  (see pgs.
	71-74, infra).   Mr. Hubbard at that time was overseeing the
	audit for the IRS Chief Counsel's Office and had in his
	care, custody and control within his office documentation,
	daily notes and memoranda relating to the tax exemption case
	involving the Hawaii Church.

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

	34/ (Footnote from previous page.)
		Government Exhibit No. 16 is a "purchase order" dated
	"14 May 1975," signed by the defendant Gregory Willardson
	whose signature "Greg W," along with all other handwriting
	on the first page of that exhibit, is positively identified
	by the expert handwriting analyst James Miller as being that
	of the defendant Willardson. In his "purchase order", the 
	defendant Willardson requests $3,141.20 for one week of 
	supplies for GO 1361 documents.  He states that his purpose 
	in purchasing the photocopying equipment listed in the attach-
	ments to Government Exhibit No. 16 is "to get vital data
	uplines to WW (World Wide) & CS-G [the defendant Mary Sue
	Hubbard]; and to get it properly x-filed for use by USGO,
	WW, CS-G." The page identified by the seizing agent as "3
	of 8" , at its bottom right-hand corner is a form entitled
	"EPO" (Estimated Purchase Order) dated "12 May 1975" covering
	the months of May to June of 1975, requesting that "$6,648.10"
	       (footnote continued on next page.)

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

					    57
	   
		    D. Infiltration of the Tax Division of the
			 United States Department of Justice.

	     Guardian Order 1361, target 17, directed the infiltration
	and theft of files relating to Scientology from the Tax Division
	or the United States Department of Justice in Washington, D.C.
	In order to carry out the directive of target 17 of GO 1361,
	Mr. Meisner obtained a directory of the United States Depart-
	ment of Justice in April 1975 and isolated those offices
	within the Tax Division which had previously been identified
	to hin as offices which would have files related to pending

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

		(footnote continued from preceding page.)

	be set aside by the Financial Planning Committee of the United
	States Guardian's Office for the purchase of "materials needed"
	"to eliminate vital info backlogs on GO 1361." This form
	is signed "GW" next to the printed entry "originator".
	Handwriting analysis has positively identified the defendant
	Willardson as the writer or the "bulk of the writings" on
	that page. Mr. Meisner has often used, such Purchase orders
	as well as Estimated Purchase Order forms during his tenure
	as an official of the Information Bureau of the Guardian's 
	Office, and is therefore familiar with the proper format and 
	manner in which such forms are to be completed according to 
	Guardian's Office procedures. He states that Government Exhi-
	bit No. 16 was prepared in accordance with these policies.
	Government Exhibit No. 16 was seized by Special Agent Smith,
	from Room 4 of the Information Bureau at the Cedars Complex.
	It was inventoried by Special Agent Valencia.

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

					  58

	Scientology litigation. Mr. Meisner had been informed by
	the Guardians office Legal Bureau that trial attorney Harold
	Larsen and Chief of Refund Litigation Section 3, Stanley
	Krysa, had represented the United States in the cases involv-
	ing the Church of Scientology of Hawaii and the Church of
	Scientology of Florida. Mr. Larsen was the trial attorney
	assigned to these cases, while Mr. Krysa, as his immediate
	supervisor, had participated in the litigation. Mr. Meisner
	discovered that the Tax Division offices of the Department
	of Justice were located in the Star Building at 1101 11th
	Street, Northwest, in Washington, D.C. Accordingly, Mr.
	Meisner directed the defendant Gerald Bennett Wolfe to enter
	the offices of Messrs. Krysa and Larsen to obtain all their
	files which were in any way related to Scientology. Conse-
	quently, on three successive Saturdays, May 3, 10, and 17,
	1975, the defendant Wolfe entered the Star Building using 
	his identification card and proceeded to the fourth floor
	offices of the Tax Division. The defendant Wolfe then entered
	the offices of Messrs. Krysa and Larsen and stole twelve
	separate files related to Scientology cases and photocopied

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

					59
	
	them on a photocopying machine within the Tax Division offices,
	using paper and equipment belonging to the United States of
	America.  The defendant Wolfe then returned the documents to
	their original location and stole copies of them. The defendant
	Wolfe then gave to Mr. Meisner all the copies of documents
	which he had taken from the Tax Division on the day following
	each entry at meetings which he and Mr. Meisner had at the
	Lums Restaurant in nearby Arlington, Virginia. Meisner, then
	reviewed the documents and summarized them in twelve separate
	memoranda prepared in the manner described at page 43, supra
	These twelve files contained notes and other memorandum of
	the United States Department of Justice, Tax Division attorneys
	dealing with their trial and pretrial strategy in Scientology
	court cases.  Government Exhibit Nos. 17, 19 - 25, and 27 -
	30, are the twelve memoranda prepared by Mr. Meisner. Each
	memorandum is addressed to the defendant Cindy Raymond and
	is entitled "Raw Data Report Re: Department of Justice - Tax
	Division - Refund Trial Section No. 3," parts 1 to 12. 35/

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

	35/   Government Exhibit No. 17 was seized by Special
	Agent Peter J. Flannigan from a file cabinet in room 23 of
	the Cedars Complex. Government Exhibits 19, 21, 24 and 28
		 (footnote continued on next page.)

- ---------------------------------------------------------------
					  
					  60

	each of the Meisner memoranda follows the standard routing
	required by Guardian Office procedure. 26/ Government

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

			(footnote continued from preceding page.)
	30 were seized by Special Agent Bradley N. Maryman from the
	file cabinet in one of the hallways of the Information Bureau
	at the Cedars Complex. Government Exhibit No. 20 was seized
	by Special Agent Stanley R. Currey from a file cabinet located
	in room 30 (the Archives room) at the Cedars Complex. Govern-
	ment Exhibits 22, 23 and 27 were seized by Special Agent
	Edward J. Miller from a file cabinet. located in room 30 at
	the Cedars Complex. Government exhibit No. 25 was seized by
	Special Agent Henry Williams from a shelf adjacent to the
	desk of the defendant Cindy Raymond in room 15 at the Cedars
	Complex. It was inventoried and initialed by Special Agent
	Raymond Mislock. Government Exhibit No. 18, which was
	seized by Special Agent Maryman from a file cabinet in one
	of the hallways in the Information Bureau at the Cedars
	Complex, is the folder which contained Government Exhibits
	Nos. 18, 19, 21, 24 and 28 to 30.

	     36/ Government Exhibits Nos. 17, 19, 25, 27, and 29, 30
	all have identical routing. They were sent by Mr. Meisner to
	the Collection Officer U.S., the defendant Cindy Raymond, via
	the Assistant Guardian for the District of Columbia Lynn
	McNeil, and, among others, the Deputy Guardian of the United
	States, the defendant Heldt, the Deputy Guardian for Informa-
	tion U.S., the defendant Weigand, and the Information Branch
	I Director U.S., the defendant Willardson, with a copy to
	the Commodore Staff Guardian, the defendant Mary Sue Hubbard.
	Government Exhibit No. 28 added to the routing the Information
	Branch II Director, U.S. Mr. Meisner identifies the initials
	in the handwriting of the defendant Heldt as appearing next
	to his title "DG US" in the routing portion of Government
	Exhibit Nos. 17, 21, 23, 25, 27 and 29. He also identifies
			  (footnote continued on next page.)

- ---------------------------------------------------------------
						 
				 61
	
	Exhibit No. 26 is a copy of a document entitled "Memorandum
	for the File" signed by Mr. Stanley F. Krysa and taken from
	the Tax Division files which were then in the care, custody
	and control of Justice Department attorney Harold Larsen.
	Mr. Meisner identifies the number  "37"  appearing at the
	lower right-hand corner of that document as a numeral which
	he placed upon receiving the document from the defendant Wolfe.
	That numeral indicates the page on which it appears was the
	thirty seventh in a series of documents appended to his
	memorandum of 14 May 1975 (Government Exhibit No. 25). The
	underlining on the Government Exhibit No. 26 was made by Mr. 

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

		 (footnote continued from preceding page.)
	the initials and date appearing on Government Exhibits Nos. 17,
	19, 25 and 27, 30 as in the handwriting of the defendant
	Willardson. Additionally, he identifies the note on Government
	Exhibits Nos. 28, 30 appearing next to the initials "GW"
	as in the handwriting of the defendant Willardson. Hand-
	writing expert James Miller positively identified the initials,
	date and handwritten notes appearing on Government Exhibits
	Nos. 28, 30 as being in the handwriting of the defendant
	Willardson.  Mr. Meisner further identifies the initials and
	date appearing next to "Coll Off US" on Government Exhibit
	No. 17 as having been written by the defendant Cindy Raymond
	and the printing at the bottom of page one of Government
	Exhibit No. 27 as the handwriting of the defendant Raymond.

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

					62

	  Meisner and that exhibit is referred to in Mr. Meisner's
	  memorandum of 14 May 1975 at page two, paragraph two.
	  (Government Exhibit No. 25.) Neither Messrs. Krysa nor
	  Larsen had given permission to the defendant Wolfe or anyone
	  associated with the Guardian's Office of the Church of Scien-
	  tology to enter their offices, remove from their files
	  documents within their care, custody and control, and make
	  photocopies of their documents. Mr. Larsen states that most
	  of the documents covered in the Meisner memoranda would never
	  have been turned over to any Scientology attorneys, inasmuch
	  as they represent attorney  "work project" material and were
	  therefore not discoverable under the Federal Rules of Civil
	  Procedure.
	       Government Exhibit No. 32 37/ is a letter dated 20 May
	  1975, from the defendant Willardson, identified in the routing
	  portion of the document as "Br I Dir US I", addressed to
	  Michael Taylor, the "US Dir Sec WW" (U.S. Directorate Secretary
	  World-Wide), routed via the Deputy Guardian for Information

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

	       37/   Government Exhibit No. 32 was seized by Special
	  Agent Gary Aldrich from a file cabinet in the office of the
	  defendant Willardson at the Cedars Complex.

- ---------------------------------------------------------------
					
					63

	World-Wide, the Guardian World-Wide, the Deputy Guardian
	United States, and the Deputy Guardian for Information in the
	United States.   The letter entitled " Re: B & E's Yours to
	DG I, 5 May 75, DG I's to you 14 May 75" states:

			When Dick [Weigand] first wrote you
		    on this subject a few of us in the office
		    had been comparing notes and smatterings
		    of legal knowledge on this subjects with the
		    end result of deciding we needed to research
		    the differences between "breaking & entering" 
		    and "unlawful entry".
			Upon searching through legal dictionaries
		    and various legal sources I discovered   . . .
		    the technical difference between "b & e" and
		    "unlawful entry" become relatively meaningless
		    when it can be seen that a large portion, if
		    not the majority, of our high priority successful
		    Collections actions fall into the category of
		    second degree burglary, which is a felony.

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

					  64

		     Some of our successful collections actions
		  in the recent past and present which fall into
		  this category are: (past). . . GO 1361, GO
		  1344, . . . DEA; (present) GO 1361, Go 1344, DEA.
		  (this is not an exhaustive rundown, just enough
		  to demonstrate the importance)
		     From my study of the codes and from my know-
		  ledge of how the collections actions are done,
		  one of the key points in solidifying the burglary
		  commission is basically the theft of xerox paper
		  and xerox machine use of whatever group is approach-
		  ed. Without this theft, then the distinction
		  between "b & e" and "unlawful entry" would become
		  important and could mean the difference between
		  a felony and a misdemeanor.

		  *             *               *

		     Because the legal definition of burglary in
		  the US to fit more spot on as to our actions

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

					    65

		  than B&E and because it is a felony, as is a
		  "B & E" I thought you should be appraised [_sic_]
		  or this.    (Emphasis added.)

	   Appended to the letter is a summary of the law on burglary.
	   Handwriting expert James Miller positively identifies the
	   handwritten signature "Greg" as having been written by the
	   defendant Gregory Willardson. 38/ Government Exhibit No. 33,
	   contains a series of letters and "compliance reports" setting
	   forth the Church of Scientology's "IRS Strategy". Page five of
	   that exhibit is a letter dated May 27, 1975, signed "Much Love,
	   Mary Sue" (Hubbard), the Commodore Staff Guardian. The letter
	   is addressed to Jane Kember and the defendant Henning Heldt.
	   The routing in the upper left-hand portion of the Document

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

	     38/   Mr. Meisner states that GO 1344 is a Guardian Order
	   which was issued in approximately September 1974 by Jane
	   Kember and which directed the infiltration and theft of 
	   documents from the United States Coast Guard. Pursuant to
	   that Guardian Order the defendant Sharon Thomas was placed as 
	   a Scientology covert operative within the Coast Guard's
	   Intelligence Division in Washington, D.C. Similarly, Mr. 
	   Meisner and Ms. Nancy Douglas, a former Scientology covert
	   operative at DEA, state that "DEA", in Government Exhibit No.
	   32, refers to the theft of government documents from the Drug
	   Enforcement Administration by Ms. Douglas.

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

					 66

	  indicates that. it was sent by "CS-G", the defendant, Mary
	  Sue Hubbard to the "Guardian WW" Jane Kember, with a copy to
	  "DG US", the defendant Heldt. It states "[o]ur overall
	  strategy with the IRS shall be as follows: 1. [t]o use any
	  method at our disposal to win the battle and gain our non-profit
	  status.   2. [t]o buy all the time we can in terms of years
	  . . . [s]o we work to win, but _also_ to delay as time works
	  on our side, not theirs." (Emphasis in original.) Page six
	  of Government Exhibit No. 33 is a letter from Deputy Guardian
	  U.S. Henning Heldt to the chief officers of the Legal, Finance,
	  Public Relations and Information Bureaus of the Guardian's
	  Office informing them of the "IRS strategy, as established
	  by CS-G." The defendant Heldt's letter directed these officials
	  to inform their respective staffs of the defendant Hubbard's
	  directive, and ordered them to conform "upcoming actions with
	  the above strategy." Page two of Government exhibit No. 33 is
	  a letter dated 9 June 1975 from the defendant Mary Sue Hubbard
	  signed in handwriting which is positively identified as hers
	  by handwriting expert James Miller. The letter, entitled
	  "IRS Strategy," was addressed to the defendant Henning Heldt

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

					   67

	  and stated: "I agree with the strategy completely as laid
	  down." Pages three and four of that same exhibit constitute
	  a compliance report dated 18 June 1975 prepared by the defend-
	  ant Heldt and addressed to Jane Kember and the defendant
	  Mary Sue Hubbard. It is entitled "Re: IRS: CS-G Order 27
	  May 75". It stated  that the overall strategy was laid out in
	  the "CSG" order of 27 May 75 was as follows: "To use any
	  method at our disposal to win the battle and gain our non-
	  profit status." It further outlined that "B-I's [Bureau 1]
	  major action is the completion of its GO 1361 collection
	  targets, and working out the means to turn those over to
	  legal and PR for use. Bureau I's actions are moving along
	  steadily and full completion is expected in two to three
	  months." 39/
	       On June 4, 1975, the defendant Gregory Willardson, in a
	  handwritten letter addressed to Mr. Meisner, the Assistant
	  Guardian for Information in the District of Columbia. (Govern-

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

	       39/ Government Exhibit No. 33 was seized by Special
	  Agent William B. Stovall from a file cabinet in the defendant
	  Henning Heldt's office in Fifield Manor.

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

					68

	ment Exhibit No. 34), 40/ directed Mr. Meisner to complete
	target 10 of GO 1361 which called for the placing of "an
	agent in DC IRS to obtain files on LRH, Scientology, etc."
	by "no later that, 30 August." The defendant Willardson stated
	that based on a conversation which he had with the defendant
	"Mitch" Hermann, it appeared to him that the only documents
	still to be obtained were from "(1) OIO [Office of International
	Operations], (2) Intell [Intelligence], (3) SSS [Special
	Services Staff]" of the Internal Revenue Service.  The
	defendant Willardson added:
	
		Mitch explained to me that he had
		planned to get Silver in OIO, and hope-
		fully gain access to Intell via OIO.
		Further, that all SSS does no longer
		exist in IRS but some were given over to
		Intell-thus Mitch expected to get SSS via
		Intell.

- -----------------
	    
	    110/ Government Exhibit No. 34 was seized by Special
	Agent James J. Smith from Room 4 of the Information Bureau at
	the Cedars Complex.

- ---------------------------------------------------------------
						 
				     69

		What I need from you is your plan of
		action here on how to complete target 10
		no later than 30 Aug . . . .
	
	The letter concluded that "[i]f you are going to need to get
	another FSM [covert operative] in you'd have to start soon
	as it takes some time, etc." The defendant Willardson demanded
	a response "in project form within 24 hrs." In a postscript,
	the defendant Willardson inquired "[w]hen will Silver be in
	OIO?" 41/ Mr. Meisner states that he received this letter
	in early June 1975. Prior to this, the defendant,
	Hermann had suggested to Mr. Meisner that "Silver" [the code
	name for Gerald Wolfe] be moved from IRS to OIO. Mr. Meisner,
	however, had considered shifting Ms. Douglas from the covert
	operation at the Drug Enforcement Administration to the
	Office or International Operations, (OIO) of IRS.  The defend-
	ant Wolfe also inquired about possible openings at OIO, but
	found none available.

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

	41/  Handwriting expert Miller positively concluded that
	the defendant Gregory Willardson is the writer of the entire
	letter.

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

				  70

	    Pursuant to the directive of the defendant Willardson,
	(Government Exhibit No. 34) Mr. Meisner prepared a project
	entitled "Beetle Cleanup" dated 11 June 1975 (Government
	Exhibit No. 35). 42/ The project called for obtaining
	"all DC IRS files on LRH, Scientology, etc., in the Intelli-
	gence section, OIO, and SSS". It proposed the placement of
	"FSMs" in the "required areas or good access developed", and
	further that "Pitts" (the code name for Nancy Douglass) and
	"Silver" attempt to obtain employment at the Internal
	Revenue Service Intelligence Division and Office of Inter-
	national Operations respectively. Appended to that project
	is a letter signed by Mr. Meisner dated 11 June 1975, addressed
	to the defendant Willardson, stating that Mr. Meisner was
	attaching a project in "compliance to your attached order".
	It indicated that the only road block to achieving the goal
	prescribed by the defendant Willardson Was the fact that
	Nancy Douglass a/k/a "Pitts" still had three files to 
	obtain from the Drug Enforcement Administration and that no
	positions might be available in the two IRS areas contemplated

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

	42/ Government Exhibit No. 35 was seized by Special
	Agent Donald P. Kinder from Room 4 at the Cedars Complex.

- ---------------------------------------------------------------
							  
					71

	by the project. In a handwritten 43/ notation signed "Cindy"
	and addressed to Peggy Tyson, the Information Programs Officer,
	the defendant Raymond stated In regard to "Beetle Cleanup":
	"As this is pjct [project) off a major pgm [program] we can
	_PUSH_ it together." (Emphasis in original.) In a handwritten
	letter dated 30 July 1975, (page three of Government Exhibit
	No. 35) the defendant Gregory Willardson responded to Mr.
	Meisner thanking him for his project and stating that he
	was turning it over to the Collections Officer, the defendant
	Cindy Raymond, to carry out. 43/
	     In June 1975, the defendant Gerald Bennet Wolfe made 
	two entries into the office of Lewis Hubbard of the
	IRS Chief Counsel's Office to obtain documents related
	to the Church of Scientology of California's pending audit.

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

	   /43 Handwriting expert James Miller positively concludes 
	that that notation is in the handwriting of the defendant
	Raymond. Similarly, Miller concludes that it is
	"probable" that the initials next to the entry "DG US" in
	the routing were written by the defendant Heldt.
 
	   /44 Handwriting expert James Miller positively concludes 
	that the bulk of the letter is in the handwriting of the
	defendant Willardson.

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

				   72
	
	These entries occurred on or about June 21 and June 30,
	1975.  On each occasion following the entry by the defendant
	Wolfe, Mr. Meisner met Wolfe and received from him copies of
	documents which Wolfe had taken from Lewis Hubbard's office.
	Upon receipt of the documents, Mr. Meisner returned to his
	office at 2125 S Street, N.W. in Washington, D.C. and produced
	memoranda summarizing the documents employing the procedure
	previously described. He appended to each memorandum the stolen
	documents, numbering each document in his own handwriting in
	the lower right-hand corner of the document. Government Exhi-
	bits Nos. 36 and 38A 45/ are the Meisner memoranda summarizing
	the documents taken on those two occasions by the defendant
	Wolfe from Mr. Hubbard's office. Government Exhibit No. 36
	entitled, "Present IRS Situation" stated that the fifty-seven
	pages of appended documents "are the daily notes of Lew
	Hubbard."  This memorandum, was addressed to the defendant

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

	    45/ Government Exhibits Nos. 36 and 38 were seized by 
	Special Agent William A. Cohendet from Room 14 of the Informa-
	tion Bureau at the Cedars Complex.

- ---------------------------------------------------------------
								      
					73

	Cindy Raymond, with copies to the Commodore Staff Guardian,
	the defendant Mary Sue Hubbard. This memorandum was routed
	through the Deputy Guardian U.S., the defendant Heldt, the
	Deputy Guardian for Information U.S., the defendant Weigand,
	and the Information Branch I Director U.S., the defendant
	Willardson. Government Exhibit No. 38A was also addressed to
	the defendant Raymond. It contains at least twenty-six
	pages of documents taken from Mr. Hubbard's office. The
	defendant Wolfe explained to Mr. Meisner that, in each in-
	stance, he took the documents from the office of Mr. Hubbard
	to a photocopying machine located in the IRS, and, using
	Government resources and paper, he proceeded to make copies
	of those documents and then return them to their original
	location. He then took the copies of the documents from
	the IRS building and turned them over to Mr. Meisner. Mr.
	Hubbard had never given permission to the defendant Wolfe
	either to enter his office, to take any documents for the 
	purpose of photocopying them, or to obtain copies of the
	documents for the Guardian's Office of the Church of Scien-

- ---------------------------------------------------------------
					      
				     74

	tology. Indeed, Mr. Hubbard states that the copies of the
	documents appended to Government Exhibits Nos.  36 and 38A
	originated from his office and are his own daily memoranda to
	himself which, coincidentally, contain many personal notes as
	well as notes regarding cases unrelated to the Church of
	Scientology. 46/ Mr. Hubbard's files were kept either in
	one of the two credenzas in his office or on a window sill
	behind his desk in Room 3549 at the main IRS building in Wash-
	ington, D.C.   All the documents appended to Government Exhibits
	Nos. 36 and 38A were in Mr. Hubbard's care, custody and
	control in June 1975. 47/

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

	   46/ The left-hand portion of Government Exhibit No. 37
	is a document in the handwriting of Lewis Hubbard, on
	the right-hand portion of the page is a typewritten copy of
	that handwritten document which was prepared by Mr. Meisner
	after the defendant Wolfe had given the handwritten document
	to him.  The document was typed in order to make it more legible
	to his superiors in Los Angeles, California.

	   47/ The routing in the upper left-hand side of both
	Government Exhibits Nos. 36 and 38A conforms to the required
	routing procedure of the Guardian's Office and are identical
	in form.  In Government Exhibit No. 38A, Mr. Meisner identifies 
	the initials next to his title "DG US" as the handwriting of
	the defendant Heldt; both the initials next to the title "Info
	Br I Dir US" and the handwritten notation immediately beneath
		 (Footnote continued on next page.)

- ---------------------------------------------------------------
					  
				  75

	    In a letter dated July 2, 1975, addressed to the Deputy
	Guardian for Information U.S., the defendant Richard "Dick"
	Weigand, entitled "Re: GO 1361", the defendant Duke Snider
	reviewed the accomplishments of the Information Bureau pursuant
	to GO 1361. (Government Exhibit No. 39). 48/ Referring to
	target 10, he indicated that "IRS DC is progressing", and
	pointed out that the defendant Gregory Willardson had ordered
	the District of Columbia Guardian's Office to complete by 30
	August 1975 the collection of all documents called for by
	target 10.  The defendant Snider concluded that target 10 was
	proceeding on schedule.  Referring to target 17, which he
	described as a directive "to infiltrate selected areas of
	the Justice Dept Tax Div for all files on _US_", he complained
	that no data had been received on "the status of Tax Div DC
	action." While the defendant Snider recalled that some
	had been "acquired from that area" he noted the he could not

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

	      (footnote continued from proceeding page.)

	 it as the handwriting of the defendant Willardson. Mr.
	 Meisner also identifies as the defendant Willardson's handwrit-
	 ing the notation that "sent to WW [World Wide]", which indicates
	 that it was forwarded to the Guardian's Office in England.

	      48/ Government Exhibit No. 39 was seized by Special Agent
	 James J. Smith from Room 4 or the Information Bureau of the
	 Cedars Complex.

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

				     76

	tell whether "all were gotten or not." On page two of his
	letter, he ordered that if target 10 files had not been
	obtained, "do a project to get them and complete the DC
	aspect of this tgt [target]." He admonished the defendant
	Weigand to "consider this a high priority matter and get
	these actions quickly done." 49/ In a second letter con-
	tained in Government Exhibit No. 39, Dated 23 July 75, from
	Peggy Tyson, the Information Bureau Programs Officer, to the
	defendant Duke Snider, she stated that she had contacted the
	District of Columbia and that "tgt 17 _is) done." (Emphasis
	in the original.)  Ms. Peggy Tyson telephoned Mr. Meisner
	and asked him to immediately send a dispatch to the defendant
	Cindy Raymond outlining the status or all target 17 actions
	and indicate what remained to be accomplished. Therefore,

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

	49/ Handwriting expert James Miller concludes that it is
	"highly probable" that the signature "Duke" at the end of
	page two is in the handwriting of the defendant Snider.
	Moreover, Mr. Meisner also identifies the handwriting in the
	letter as that of the defendant Snider.

- ---------------------------------------------------------------
					     
				   77

	Mr. Meisner forwarded to the defendant Raymond a memorandum
	dated 11 August 1975 entitled "GO 1361-TGT 17 STATUS", (Govern-
	ment Exhibit No. 41A), 50/ stating that "Peggy [Tyson]
	asked me to send you a dispatch re the areas checked for target
	17 of GO 1361." He informed the defendant Raymond that the
	only data found in the Tax. Division was in the offices
	of Messrs. Krysa and Larsen. He noted that the only areas
	in the Justice Department that should be checked "fall [are
	located] in the main Treasury [sic] building" and "would
	require infiltration - probably several different FSMs."
	Government Exhibit No. 41 is a 12 August 1975 letter from
	Ms. Tyson to the defendants Snider and Weigand 51/ which
	alluded to Mr. Meisner's statement that he "has gotten
	files from the Justice Dept. Tax Division." In a letter
	dated 10 September 1975, headed "CONFIDENTIAL -SHRED WHEN
	FINISHED", the defendant Cindy Raymond wrote to Mr. Meisner

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

	50/ Government Exhibits Nos. 41 and 42 were seized by
	Special Agent Smith from Room 4 at the Cedars Complex.
	
	51/ They are respectively identified in the routing
	as the Deputy Deputy Guardian U.S. and Deputy Guardian for
	Information U.S.

- ---------------------------------------------------------------
						       
				     78

	that since there may have been some confusion regarding GO
	1361, target 17, she was "reissuing the target." (Government
	Exhibit No. 42.) She reminded him that targets 16 and 17
	required the infiltration of the Justice Department Tax Division
	to obtain all files on Scientology, and instructed him that
	"[w]hat you need to do to comply to this is survey all areas
	that we have checked, and then take a look at any area (Tax
	Div) that we need to check and then get the data."  She
	concluded that "[tlhis should clarify waht [sic] is needed and
	wanted in the way of tgt 17. Send compliance as soon as you
	can . . . ." Mr. Meisner received that letter in Washington,
	D.C. and notified the defendant Raymond that all documents
	from the Department of Justice Tax Division relating to
	Scientology had been already obtained. 52/
	     
- -----------

	   52/ In a memorandum from a Guardian's Office official
	dated October 3, 1975 to the defendant Richard Weigand
	(Government Exhibit No. 56), requesting a compliance report
	regarding target 17 of GO 1361, the defendant Weigand, added
	a handwritten note stating that target 17 "is almost done"
	in Washington, D.C., but still required six weeks to be
	completed as far as the Justice Department Tax Division
	in Los Angeles, California was concerned. Handwriting
	expert James Miller concludes that the note was probably
	written by the defendant Weigand. Mr. Meisner also identifies
	the note as having been written by the defendant Weigand.
	Government Exhibit No. 56 was seized by Special Agent Smith
	from Room 4 in the information Bureau at the Cedars Complex.

- ---------------------------------------------------------------
					 
					 79


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

	     On September 21, 1975, the defendant Gregory Willardson,
	in his capacity as Branch I Director for the Information
	Bureau in the United States, wrote a "CSW" (Completed Staff
	Work) to Guardian World-Wide Jane Kember requesting her to
	issue certain "commendations" and "awards" to certain Bureau I
	staff members. They had been involved in the execution of GO
	1361 during the period March to late June 1975, when it
	had been necessary for Mr. Meisner to send thousands of
	documents to Los Angeles without first excerpting them.
	Among the individuals for whom official recognition were sought
	was the defendant Cindy Raymond. The attached "Guardian
	Condition Order" (Government Exhibit No. 43E) 53/ listed
	all the individuals to be so honored. It was approved by
	the defendants Heldt, Weigand and Willardson, and
	Budlong and Lisa for the Guardian World-Wide, Jane Kember.

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

	   53/ Government Exhibit No. 43 was seized by Special Agent
     Smith from Room 4 in the Information Bureau at the Cedars Complex.

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

					   80

     The 12 September 1975 "CSW" from the defendant Willardson
     was routed through, among others, the Deputy Guardian for
     Information World-Wide, Mo Budlong, who inserted a notation
     "Okay by me[,] Love MB".  Mr. Meisner recognizes it as being
     in the handwriting of Mr. Budlong. The Deputy Guardian for
     the United States, the defendant Heldt, initialed the "CSW"
     next to his title, thereby indicating his approval, as did
     the Deputy Guardian for Information in the United States, the
     defendant Richard Weigand, who also initialed the document
     next to his title.  The Guardian World-Wide, Jane Kember,
     approved the "CSW" by signing her name next to the entry
     "approved".  On the right-hand side of the document, she also
     requested the defendant Willardson to keep the information
     confidential since it mentioned Bureau I names. Mr. Meisner
     recognizes that handwriting as well as the signature next to
     the word "approved" as that of Ms. Kember. 54/

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

	    54/ Handwriting expert James Miller identifies the
	handwriting of the defendant Willardson on Government Exhibit
	No. 43 as follows: On page one, "highly probable" as to the
	notation in the upper right-hand corner under the date, on
	page two, "positive" as to the notation signed "Greg" above
	the date; on page four, "positive" as to the entire letter;
	on pages five and six, "highly probable" as to the signature
	"Greg". Moreover Mr. Meisner recognizes the initials of the
	defendants Heldt and Weigand.

- ---------------------------------------------------------------
					    
					    81
							   
		   F. The Theft of IRS Documents Exempted from
		      Disclosure Under the Freedom of Information Act

	    In July 1975 the defendant Cindy Raymond informed Mr.
	Meisner that the Church of Scientology had initiated a Freedom
	of Information Act (FOIA) lawsuit against the IRS and directed
	him to be alert to any documents in the offices of Charles
	Zuravin, an attorney in the Disclosure Division of the Chief
	Counsel's Office, since he was representing the United States
	in that case. Mr. Zuravin's offices were located in the main
	IRS building at 1111 Constitution Avenue, N.W., in Washington
	D.C. Mr. Meisner immediately notified the defendant Wolfe and 
	instructed him to add Mr. Zuravin's office to the list of
	offices within the IRS's main building in Washington D.C.
	which he had to constantly monitor. This began a series of
	entries into Mr. Zuravin's offices by the defendant Wolfe from
	July 1975 through November 1975. As a result or the defendant
	Wolfe's entries, the Guardian's office learned that Mr. Zuravin
	had been amassing all documents dealing with Scientology from
	all IRS offices around the country in order to prepare an FOIA

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

					82
	
	index. 55/
	   The defendant Wolfe made his first entry into Mr. Zuravin's
	office on or about July 28, 1975, and copied Mr. Zuravin's
	file on the pending Freedom of Information Act lawsuit. He
	removed that file out, photocopied it using United States
	Government property, returned it to Mr. Zuravin's office,
	stole the copies, and turned them over to Mr. Meisner at their
	weekly meeting. Mr. Meisner summarized the documents taken
	by the defendant Wolfe in a memorandum addressed to the defend-
	ant Raymond dated 28 July 1975, and sent a copy of that
	memorandum to the defendant, CSG, Mary Sue Hubbard (See
	Government Exhibit No. 40.) /56  The defendant Wolfe made
	four additional illegal entries into Mr. Zuravin's office at
	the IRS between mid-September and late November 1975. In
	each instance, the defendant Wolfe took documents which Mr.

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

	  55/ This index, known as a _Vaughn_ index, is required by
	the Courts, and lists all documents potentially subject to
	the FOIA with reasons for all those sought to be exempted 
	from the reach of the Act.

	56/ Government Exhibit No. 40 was seized from a file
	cabinet located in the Information Bureau at the Cedars 
	Complex.   Mr. Meisner identifies the initials next to the
	title "DG US" in the routing portion of the document as being
	in the handwriting of the defendant Heldt, and the initials
	next to the title "INFO BR I DIR US" as being the handwriting
	of the defendant Willardson.
