6

not accept him as an expert for the reasons that I
explained. So his background information is marginally
relevant. Obviously, there has got to be some
explanation as to why he is in a position to know what he
knows. But because you are not qualifying him as expert
I don’t expect to go on in tremendous detail about every
course that he took, everything he did, everything he
knows.

I expect that you are going to establish that
he was a member of the Church of Scientology, that he
knows what the “Fair Game Policy” is, how he knows of his
personal knowledge “Fair Game Policy”, what the “Fair
Game Policy” exactly is, what the expressed policy is in
other words. And what penalties, if any, there may be
for violations for church members carrying out the “Fair
Game Policy”. I wrote that down then, and I read from my
notes now. That’s exactly verbatim what I said last
time.

Beyond that I will leave it to your good
judgment and to stay within the parameters and I will
rely on Mr. Tyson to jump up when he thinks you have
strayed and I will make that call when, and if those
happen.

MS. RIVELLINI: Do you have any problem me
asking him if he saw evidence of “Fair Game” being