Stipulation of Evidence in the USA vs. Mary Sue Hubbard

Scientology lawyer Kendrick Moxon named as unindicted co-conspirator
Scientology lawyer Kendrick Moxon named as unindicted co-conspirator

Notes about the following document from the person who scanned it

in from the original:

Presented for your edification is the complete Stipulation

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

this document is particularly important in understanding the

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

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

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

of documentation in this case alone. Additionally are some strange

and interesting documents. Such as the letters of character reference

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

Letters from the heads of a number of Scientology related

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

up a fair amount; mostly pleading against the inordinate delays

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

aspect).

In light of the recent revelations involving the Church of

Scientology in Greece, it becomes clear that the same guidelines

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

for the theft of confidential government files).

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

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

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

number of typos and formatting inconsistencies itself. I have not

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

formatting problems that existed in the original.

From my understanding, the following document was agreed upon by

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

that would normally accompany such an extensive legal case. The

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

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

defendants in return for an agreement that the prosecution would

not go after L. Ron Hubbard.

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

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

Footnote seperators are marked with an incomplete line accross the

page like so:

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

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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA

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

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

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

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

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

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

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

EXHIBIT

NUMBER DESCRIPTION SECTION PAGE

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

56E Document #1410 p. 43 IIIA 21

5T Document #11120 IIIH 106

58 Document 01427 III I 110-111

59 Document #21704 IIIJ 114-115

60 Document #21724 IIIJ 116-117

61 Meisner IRS Identification IIIK 121

card

62 Document #21626 IIIJ 118

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

64 Document #3956 IIIH 99-100

65 Document #1097 IIIL 124-125

66 Document #1098 IIIL 123-124

67 Document #14768 IIIL 126-127

68 Document #1412 IIIJ 118

69 Document #15779 IIIM 131

70 Document #15780 IIIM 131

71 Document #15781 IIIM 131

72 Document #15778 IIIM 132

73 Document #3102 IIIN 137-138

74 Document #3035 IIIN 137-138

75 Document #3036 IIIN 137-138

76 Document #3033 IIIN 137-138

77 Document 03099 IIIN 137-138

78 Document #10963 III01 141

79 Document 010958 III01 l4l-l42

80 Document #2459 III02 146-147

81 Document 12462 III02 148

82 Document #11561 III02 148

83 Document #11562 III02 148

84 Document #11584 III02 148

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vii

EXHIBIT

NUMBER DESCRIPTION SECTION PAGE

85 Documerit #2463 IIIO2 148-149

86 Document #15777 III02 148-149

87 Document #2461 III03 152

88 Document #14111 III03 152

89 Document #14110 III03 152

90 Document #14109 11103 152

91 Document #14108 III03 152

92 Document #14107 III03 152

93 Document #9989 III03 153

94 Document #9990 III03 153

95 Document #15772 III03 154

96 Document #826 IIIP 156-159

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

Log of May 21, 1976

98 Document #3044 IIIP 164

99 Document #11571 IIIP 165

100 Document #14114 IIIP 165

101 Courthouse Sign-in Log IIIP 167

of May 28, 1976

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

Log of May 28, 1976

103 Document #18601 IIIP 168

104 Document #14113 IIIP 168

105 Document #898 IIIP 170

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

of June 11, 1976

107 Document #1550 IIIC 52

108 Document #8598 IVA 189

109 Document #555 IIIM 127

110 Document #17416-17417 IIIP 173

111 Document #8567 IIIG 91

112 Document 08908 IIIP 174

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viii

EXHIBIT

NUMBER DESCRIPTION SECTION PAGE

113 Quality Inn Motel (Arlington) IIIP 176

Registration Card

114 Document #11176 IVA 177

115 Document #3125 IVA 180

116 Document #14751 IVA 179

117 Document #14738 IVB 191

118 Document #14744 IVB 192

119 Document #14745 IVB 193

120 Document #14742 IVB 194

121 Document #14749 IVB 195

122 Document #14748 IVB 195

123 Document #13789 IVC 198

124 Document #13785 IVD 198-199

125 Document #11078 IVD 201

126 Document #11076 IVD 201

127 Document #11055 IVD 203-204

128 Document #14662 IVD 205

129 Docunent #14737 IVD 207

129A Document #14737 p. 2 IVD 206

129B Document #14737 P. 3 IVD 207

130 Document #14672 IVE 211

131 Document #11231 IVD 207-209

132 Document #11425 IVE 210-211

133 Document #13755-13756 IVE 212

134 Document #13758 IVE

212

135 Document #10755 IVF 218,219

136 Document #14658 IVF 218

137 Document #111667 IVF 216

138 Document #10706 IVF 219-220

139 Document #10744 IVF 222

140 Document #13757 IVF 222

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EXHIBIT

NUMBER DESCRIPTION SECTION PAGE

141 Document #14746 IVF 223-224

142 Document #14741 IVF 225

143 Document #10722 IVG 226

144 Document #10709 IVG 227-228

145 Document #8580 IVG 229

146 Document #1071@5 IVG 229

147 Document #14687 IVG 231

147A Document #14687 (2d letter IVG 232

from end)

147B Document #14687 last letter) IVG 232

148 Document #14689 IVH 232-233

149 Document #8575 IVH 234

150 Document #11215 IVH 235

151: Document #11175 IVH 236

152 Document #3135 IVH 237

153 Document #11179 IVH 238

154 Document #3146 ivi 238

155 Document #3145 ivi 238

156 Document #3144 ivi 239

157 Document #3143 ivi 240

158 Document #11232 ivi 240

159 Document #3153 ivi 241-242

160 Document #10066 ivi 243

161 Document #8574 ivi 243-244

162 Document #8576 ivi 243-244

163 Document #10067 ivi 244-245

164 Document #8573 ivi 246

165 Document #8572 ivi 246

166 Document #10070 ivi 245

167 Document #10071 ivi 247

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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

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EXHIBIT

NUMBER DESCRIPTION SECTION PAGE

199 Spring steel shims IIIH 102

200 Spring steel shims IIIH 102

201 Spring steel shims IIIH 102

202 Key micrometer IIIH 102

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

kit

204 Handwriting given by Moxon IVE 212

to Hansen of FBI

205 Wolfe Personnel Record at IIIA 18

IRS

206 Thomas Personnel Record IIIG 94

at DOJ

207 Thomas Identification Card IIIG 94

at DOJ

208 Conference memorandum of IIIB 31

Lewis Hubbard of Nov. 1,1974

209 Conference memorandum of Lewis IIIB

Hubbard of Nov. 1, 'L974

210 FBI Lab Decode of document IIIB 30-31

#20106

211 FBI Lab Decode of documents IIIB 30-31

#20107

212 FBI Lab decode of document IVA 18o

#14751

213 FBI Lab decode of document IVB 194

#14742

214 Grand Jury docket entry Dec. IVG 225

15 9 1976

215- Gerald Wolfe Grand Jury IVK 255-260

testimony of June 10, 1977

216 FBI Lab decode of document IVB 192

#14744

217 Photograph of bugging equipment IIIB 25

218 Photograph of lockpicking IIIH 102

equipment

219 Document #7984 IVM 274-275

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

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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA

V Criminal No. 78-401

MARY SUE HUBBARD, et al.

STIPULATION OF EVIDENCE

The United States of Americal through its attorneys,

United States Attorney Carl S. Rauh, Assistant United States

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

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

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

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

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

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

Weigand and Gregory Willardson; Michael Nussbaum, Esquire, and

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

Mitchell Hermann, also known as Mike Cooper; John Kenneth

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

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

well as the above-mentioned defendants themselves , agree and

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

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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.

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

supervisor and an auditor in Urbana, Illinois. In August

1972, lie assumed the position of Executive Director of the

franchise until June 1973.

In mid-May 1973, the defendant Duke Snider recruited

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

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

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

become part of the Intelligence Bureau of the Guardian's

Office. The Intelligence Bureau became the Information Bureau

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

wife Patricia were accepted for the Guardian's Office and

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

tion for assuming their duties as officials of that orgainiza-

tion. Upon becoming an officer of the Intelligence Bureau,

Mr. Meisner was instructed by the defendant Duke Snider that

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

that is, it dealt with safeguarding the environment within

which Scientology existed by locating, removing and rendering

harmless all thore perceived to be enemies of Scientology,

This was accomplished by infiltration, theft of documents and

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

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.

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

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.

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

maintained by the Guardian's Office and its Information

Bureau. The absolute necessity of correctly labelling and

filing all documents obtained and kept by the Information

Bureau was emphasized to Mr. Meisner. Strict adherence to

these policies was mandated to assure that the Information

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

efficient manner.

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

In that position he was responsible for internal security

matters. These included both the physical security of the

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

ing of all dissident and disaffected Scientologists. with

regard to the latter, his duties included obtaining personal

information which would prevent them fron becoming a nuisance

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

Jane Kember elevated Mr. Meisner to the position of Assistant

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

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

and covert intelligence investigations and operations. This

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

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-

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

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

in East Grinstead, Sussex, England; United States headquarters

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

of Coluubia and some thirty other cities throughout the

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

posed of five bureaus: Information (prior to July 1973

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

Finance, and Social Coordination. A sixth bureau not shown

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

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

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

was headed by an Assistant Guardian.

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

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

Scientology, overall supervisor of the Guardian's Office.

- ---------

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

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

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

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

Angeles; American Saint Hill Organization (Los Angeles);

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

tion of the United States Guardian's Office).

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

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

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

second person in the hierarchy of Scientology, had duties

which included supervision of the Guardian's Office. Jane

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

the daily operations of all Guardian's Offices, reporting

directly to the defendant Mary Sue Hubbard who in turn reported

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

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

Mo Budlong (hereafter Mo Budlong). He supervised all

Information Bureaus around the world and reported

to Jane Kember. The defendant Henning Heldt was the Deputy

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

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

Jane Kember.

_Government Exhihit No. 1B_ is an organizational chart of

the Information Bureau in the United States from November

1973 until January 1976 when it was reorganized. The defendant

Duke Snider was Deputy Guardian for Information in the United

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

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

thereafter held by the defendant Richard Weigand. Beginning

in January 1975 and at all other relevant times charged in

the indictment, the defendant Snider was Deputy Deputy Guardian

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

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

Gregory Willardson became the Deptuty Deputy Guardian for Infor-

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

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

ant Cindy Raymond was the Collections Officer for the United

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

covert data collection for the Information Bureau.

_Government Exhibit 1C_ is an organization chart of the

Information Bureau in the United States after its reorganiza-

tion in January 1976. Following the removal of the defendant

Richard Weigand from the position of Deputy Guardian for

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

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

after by the defendant Gregory Willardson. From January 1976

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

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

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

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 reffered to in Scientology as a

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

the routing portion of certain documnets and which connotes

that an individual ia assuring the responsibilities of more

than one position at the same time.

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

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

The routing on each document prepared within the Guard-

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

lying bureaus, tracks the organizationial charts. (Government

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

document is the abbreviation of each of the positions held

by the Persons who were to receive the particular documents,

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

Government Exhibit 14, discussed at page 48, infra.

From 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.

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

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/Guatrdian 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.

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

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.11 (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 directecd 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

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

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 headquaters of the Guardian's offfice

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. Futhermore,

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. i-I II e

member was one or four persons in the Church of Scientology

who was a signitory 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.

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

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 Beldt, to the DC Info US, the defendant

Richard Weigand. Next to the abbreviation "DO 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,

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

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. Meisnier 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

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

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 Washignton, 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 Hichael 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

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

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.

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

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. Clauduis from a file cabinet in Room 5 at the Cedars Complex.

ll/ 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.

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

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 Scicntology.

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

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

"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.

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

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

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

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.

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

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, Mesiner 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 mueseum 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.

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

entire meeting over the FM radio of the car. Following the

conclusion of the meeting, the defendant Hermann creentered

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 intercepton

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.)

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

Covernnent 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 requiremennts 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. Goverment 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.

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

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 viecks 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.

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

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,

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

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 Exhibils 7A and 7B) Agent Eberhardt decoded

Government Exhibits 6 and 187. He did so by writing above

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

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 Goverment 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 bugginng 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

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

room. Numerous other high officials of the IRS attended

this meeting. Mr. Hubbard states that the IRS held the

November 1, 1974 conference to disscuss 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 prepaired 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

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

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.

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

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

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

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

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

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

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

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 indenti-

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]

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

(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 Decembecr 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-

poso of their entry was to show to the defendant Gerald Bennett

Wolfe that documents could easily be taken from the Internal

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

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 propobly by made by the defendant

Snider. Mr. Meisner recognizes each set of initial as being

made by the defendants Heldt and Duke Snider respectively.

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

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 Governmant Exhibit

No. 11, dated "9 December 74," is the defendant Willardson's

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

response io 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 subordinite

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.

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

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. Meisncr 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 backgound. 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 documnets

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

conferance that was bugged by Scientology agents.

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

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 subsequant

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 documnets 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 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.

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

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 Bereau, and the Collec-

tions Officer. He also sent a copy of the material to the

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

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 Bereau 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.

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

memorandum from Mr. Mesiner to the defendant, Cindy Rayrmond

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

Stipulation of Evidence in the USA vs. Mary Sue Hubbard

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA

TABLE OF CONTENTS

PAGE

A. The Order to infiltrate the Internal Revenue

B. The Bugging of the IRS Chief Counsel's

C. The First Infiltration of the IRS in the

D. Infiltration of the Tax Division of the

F. The Theft of IRS Documents Exempted from

G. The Guardian Program Order Instituting An "Early

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

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

K. The Entry Into the IRS identification Room and

L. Guardian Program Order 302 and the Theft of

M. Burglaries of the Suite of Offices of the

N. Burglaries of the Office of International

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

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

B. The Defendant Gerald Bennett Wolfe is Arrested

C. The United States Case Against the Defendant

D. The Guardian's Office Harbors and Conceals

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

G. The Federal Grand Jury Investigation in the

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

K. The Defendant Wolfe's Sentencing and Subsequent

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

M. Michael Meisner Surrenders to the Federal

TABLE OF EXHIBITS

EXHIBIT

EXHIBIT

EXHIBIT

EXHIBIT

EXHIBIT

EXHIBIT

EXHIBIT

EXHIBIT

UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA

STIPULATION OF EVIDENCE

1. The Witness Michael J. Meisner

II.

Organizational Structure of the Guardian's Office

The routing on each document prepared within the Guard-

III.

A. The Order to Infiltrate the Internal

16. Collect data on the Justice Dept.

17. When the correct areas are isolated,

B. The Bugging of the IRS Cheif Counsel's

C. The First Infiltration of the IRS in the

TELEX

Until January 1976, all such memoranda and supporting documents