go to part 13

BY MS. PLEVIN:

Q. ARE YOU READY TO PROCEED, MR. MISCAVIGE?

A. DO YOU WANT ME TO COMPLETE MY ANSWER?

MR. HERTZBERG: WAIT. I'M GOING TO ALLOW MR. MISCAVIGE TO RESPOND TO THE PENDING QUESTION INSOFAR AS THIS TOPIC HASN'T BEEN ASKED AND ANSWERED BEFORE, YESTERDAY; IN OTHER WORDS, INSOFAR AS HE HASN'T ALREADY IDENTIFIED COMMUNICATIONS IN HIS TESTIMONY YESTERDAY, AND ALSO SUBJECT TO THE STIPULATION THAT WE MADE YESTERDAY IN RESPONSE TO QUESTIONS IN THE SAME AREA THAT HE MAY RESPOND WITH RESPECT TO COMMUNICATIONS DEALING WITH BENT CORYDON, SQUIRRELS, MISSIONS, OR THE FOURTH CATEGORY THAT YOU ADDED YESTERDAY, ABOUT HIS POWER WITHIN THE CHURCH.

MS. PLEVIN: OKAY.

MR. HERTZBERG: SUBJECT TO THAT LIMITATION.

THE WITNESS: THIS IS WITHIN THAT LIMITATION. "RON'S JOURNAL 38" -- AND I BELIEVE THAT WAS CALLED "TODAY AND TOMORROW: THE PROOF," AND THAT TAPE WAS SENT TO ME ASKING ME IF I COULD, PLEASE, TAKE THIS TAPE AND GET IT COPIED OFF SO IT COULD BE SENT OUT TO SCIENTOLOGY ORGANIZATIONS AROUND THE WORLD, AND IT DEALT WITH MANAGEMENT WITHIN THAT TAPE WHEREBY IT TALKED ABOUT, BASICALLY, TECHNICAL MATTERS AND SCIENTOLOGY AS RELIGION LOOKING FORWARD INTO THE FUTURE.

BY MS. PLEVIN:

Q. DID YOU DO SO?

A. WHAT, GET THE TAPE OUT? Q. YES.

A. YES, I DID.

Q. WAS IT TRANSCRIBED, OR DID YOU MAKE COPIES OF THE TAPE?

A. THE TAPE WAS COPIED. YEAH, THERE'S THOUSANDS UPON THOUSANDS UPON THOUSANDS UPON THOUSANDS OF COPIES. TRANSCRIBED? I DON'T RECALL. Q. DO YOU KNOW IF COPIES OF THAT TRANSCRIPT ARE STILL AVAILABLE?

A. I JUST SAID I DON'T KNOW IF TRANSCRIPTS WERE MADE.

Q. I'M SORRY. OKAY. BUT IS "THE PROOF" STILL AVAILABLE IN SOME FORM?

A. DO YOU MEAN THE TAPE?

Q. YES.

A. THE CASSETTE?

Q. YES.

A. YES.

Q. ANY OTHER COMMUNICATIONS DIRECTED TO YOU FROM MR. HUBBARD REGARDING MANAGEMENT OF SCIENTOLOGY ORGANIZATIONS SUBSEQUENT TO YOUR ARRIVAL AT GILMAN HOT SPRINGS? MR. HERTZBERG: YOU MEAN OTHER THAN --

MS. PLEVIN: OTHER THAN THESE TWO.

MR. HERTZBERG: OTHER THAN WHAT HE JUST TESTIFIED TO?

MS. PLEVIN: RIGHT.

MR. HERTZBERG: OTHER THAN WHAT HE MAY HAVE IDENTIFIED PREVIOUSLY, AND WITHIN THE FRAMEWORK OF THE FOUR LIMITATIONS THAT WE STIPULATED TO?

MS. PLEVIN: NO. I'M NOT GOING TO ACCEPT THE LIMITATIONS OF THOSE FOUR. I MEAN, THAT'S WHY I'M ASKING SPECIFICALLY ABOUT MANAGEMENT WHICH WAS NOT ONE OF THE FOUR CRITERIA WE DISCUSSED YESTERDAY. MR. HERTZBERG: OKAY. SO YOU NOW -- YOU'RE GOING OUTSIDE THE STIPULATION FROM YESTERDAY?

MS. PLEVIN: I DIDN'T AGREE TO THAT STIPULATION.

MR. HERTZBERG: THE RECORD WILL REFLECT --

MS. PLEVIN: YOU PUT THE LIMITATION THAT HE ANSWER THE QUESTION, AND I AGREED TO LET HIM ANSWER THE QUESTION IN THAT FORM. I DIDN'T AGREE TO WITHDRAW MY QUESTION AS TO GOING FORWARD WITHOUT -MR. HERTZBERG: THE RECORD WILL SPEAK FOR ITSELF.

MS. PLEVIN: -- THOSE LIMITATIONS.

MR. HERTZBERG: YOU'RE ASKING FOR SOMETHING -- FOR HIM TO TESTIFY NOW ABOUT COMMUNICATIONS OUTSIDE THOSE FOUR CATEGORIES?

MS. PLEVIN: YES, I AM.

MR. HERTZBERG: I'M INSTRUCTING HIM NOT TO ANSWER.

MS. PLEVIN: ALL RIGHT. AND THE SAME INSTRUCTION AS TO THE GUARDIAN'S OFFICE?

MR. HERTZBERG: I DON'T KNOW WHAT THAT MEANS.

MS. PLEVIN: ALL RIGHT.

MR. LIEBERMAN: WHAT'S THE QUESTION? "THE SAME INSTRUCTION AS TO THE GUARDIAN'S OFFICE?"

MS. PLEVIN: I'M GOING TO ASK HIM A SERIES OF QUESTIONS, MR. HERTZBERG, REGARDING COMMUNICATIONS FROM L.R.H. SUBSEQUENT TO MR. MISCAVIGE'S ARRIVAL AT GILMAN HOT SPRINGS, IN WRITING, IN PERSON, AND THROUGH AN INTERMEDIARY REGARDING, AS I HAVE, THE MANAGEMENT OF SCIENTOLOGY ORGANIZATIONS, THE GUARDIAN'S OFFICE, THE ESTABLISHMENT AND MANAGEMENT OF WISE, THE PURPOSE OF WISE, THE ESTABLISHMENT OF SMI, THE SEA ORG, AND THE BOOK I CAMPAIGN.

NOW -- IF YOU'RE GOING TO HAVE THE SAME INSTRUCTION AS TO ALL, LET'S HAVE THAT FOR THE RECORD AND MOVE ON.

MR. HERTZBERG: NO. I WILL NOT DO THINGS THAT WAY BECAUSE I DON'T WANT THE RECORD TO BE DISTORTED. YOU'RE GOING TO HAVE TO ASK A QUESTION, AND THEN I'M GOING TO HAVE TO RESPOND ON A QUESTION-BY-QUESTION BASIS. SO LET'S GET ON WITH IT. MS. PLEVIN: ALL RIGHT.

Q. MR. MISCAVIGE --

A. YES.

Q. SUBSEQUENT TO THE TIME YOU WENT TO GILMAN HOT SPRINGS --

THE WITNESS: DO YOU MIND IF I SMOKE, IS THIS GOING TO BOTHER YOU?

THE REPORTER: NO.

THE WITNESS: GOOD. THANK YOU.

BY MS. PLEVIN:

Q. DID YOU RECEIVE ANY COMMUNICATIONS FROM MR. HUBBARD, EITHER IN PERSON, IN WRITING, OR THROUGH INTERMEDIARY REGARDING THE GUARDIAN'S OFFICE?

MR. HERTZBERG: SHE'S JUST ASKING YOU -- READ THAT AGAIN.

MS. PLEVIN: READ THE QUESTION BACK.

(RECORD READ.)

MR. HERTZBERG: YOU CAN ANSWER THAT "YES" OR "NO."

THE WITNESS: YES.

BY MS. PLEVIN:

Q. WHAT COMMUNICATIONS DID YOU RECEIVE.

MR. HERTZBERG: ALL RIGHT.

MR. LIEBERMAN: SUBJECT TO LIMITATIONS.

MR. HERTZBERG: NOW, I'M GOING TO INSTRUCT MR. MISCAVIGE THAT HE MAY ANSWER THAT QUESTION SUBJECT TO THE LIMITATIONS OF THE FOUR CATEGORIES WHICH HAVE ALREADY BEEN STATED ON THE RECORD.

MS. PLEVIN: HE CAN DO SO, BUT I WILL RESERVE MY RIGHT TO COMPEL AS TO FURTHER ANSWERS.

Q. LET'S TAKE THE FOUR CATEGORIES FIRST, THAT'S BENT CORYDON.

A. NO.

Q. SQUIRRELS.

A. NO.

Q. THE MISSIONS.

A. NO.

Q. AND YOURSELF AND YOUR POTENTIAL POWER IN THE FUTURE.

A. NO, AND I UNDERSTAND ALL OF THOSE ARE REFERENCING COMMUNICATIONS REGARDING THE GUARDIAN'S OFFICE --

Q. RIGHT.

A. -- IN THOSE FOUR CATEGORIES.

Q. RIGHT. TO CLARIFY, AND MAYBE WE SHOULD -- PERHAPS YOU HAVE ASSUMED THIS ALREADY. WHEN I SAY, "BENT CORYDON," I'M ALSO REFERRING TO THE BOOK "L.R. HUBBARD, MESSIAH OR MADMAN"; NOW, THAT HASN'T BEEN MADE EXPRESS. SO PERHAPS WE SHOULD FOR THE FUTURE. MR. DRESCHER: WELL, I'LL OBJECT TO THAT BEFORE THERE'S ANY RESPONSE FROM ANYBODY; THAT'S A LEAP OF FAITH.

MS. PLEVIN: OH, I --

MR. DRESCHER: AND THAT'S ONE THAT COULDN'T POSSIBLY BE ASSUMED BY ANYONE THINKING LOGICALLY IN A DEPOSITION.

MS. PLEVIN: I'M NOT GOING TO -- THAT'S PRECISELY WHY I MENTIONED IT, I --

MR. HERTZBERG: DO YOU MEAN HENCEFORTH?

MS. PLEVIN: I WILL NOT HARKEN TO THAT. I MEAN HENCEFORTH.

MR. HERTZBERG: OKAY.

MS. PLEVIN: I MEAN, HE MAY HAVE LUMPED THE TWO TOGETHER. I'M NOT ATTEMPTING TO, YOU KNOW, BACKTRACK.

MR. HERTZBERG: OKAY. FINE. SO HENCEFORTH, WHEN WE SAY "BENT CORYDON," WE WILL UNDERSTAND THAT TO INCLUDE BENT CORYDON'S BOOK, WHICH, OF COURSE, CAME OUT AFTER MR. HUBBARD WAS DEAD, BUT SO IT WOULD BE A LITTLE HARD FOR MR. MISCAVIGE TO HAVE COMMUNICATED IN

WAY WITH MR. HUBBARD ABOUT A BOOK THAT CAME OUT AFTER MR. HUBBARD WAS DEAD, BUT WE'LL KEEP THAT IN MIND.

MS. PLEVIN: ALL RIGHT.

Q. NOW, WITH RESPECT TO THE GUARDIAN -- WE'RE ON -(ATTORNEY-CLIENT DISCUSSION HELD OFF THE RECORD.) MR. HERTZBERG: ALL RIGHT.

BY MS. PLEVIN:

Q. SO WITH RESPECT TO THE GUARDIAN'S OFFICE, YOU DIDN'T RECEIVE ANY COMMUNICATIONS ON ANY OF THOSE FOUR AREAS?

A. AS ANSWERED, THAT'S RIGHT.

MS. PLEVIN: ALL RIGHT. I WILL REPEAT FOR THE RECORD THAT MY QUESTION IS BROADER THAN THAT AND RESERVE A RIGHT COMPEL AS TO THAT.

Q. DID YOU RECEIVE ANY COMMUNICATIONS FROM MR. HUBBARD EITHER IN PERSON, IN WRITING OR THROUGH AN INTERMEDIARY FROM THE TIME YOU MOVED TO GILMAN HOT SPRINGS UNTIL THE TIME OF MR. HUBBARD'S DEATH REGARDING WISE, THE WORLD INSTITUTE OF SCIENTOLOGY ENTERPRISES, OR THE ESTABLISHMENT OF WISE AND ITS PURPOSE?

MR. HERTZBERG: I WANT TO INTERJECT AN ADDITIONAL INQUIRY HERE. HOW IS WISE RELEVANT? THEY'RE NOT A DEFENDANT IN THIS CASE; CORRECT? MS. PLEVIN: YOU CAN INSTRUCT HIM NOT TO ANSWER. I'M NOT GOING TO GO INTO IT.

MR. HELLER: WELL, MAKE A PROFFER OF RELEVANCE --

MR. HERTZBERG: YOU KNOW --

MR. HELLER: -- FOR US.

MR. HERTZBERG: WE'RE BACK TO THESE COMPLETELY ANCILLARY INQUIRIES.

MS. PLEVIN: ALL RIGHT.

MR. HERTZBERG: ARE YOU NOT STATING FOR THE RECORD WHY YOU'RE ASKING MR. MISCAVIGE ABOUT AN ENTITY THAT IS NOT A PARTY TO THIS LITIGATION AND THAT MR. CORYDON DOES NOT CLAIM DID ANYTHING TO HIM?

MS. PLEVIN: WELL, TO THE SAME EXTENT THAT THE ALTER EGO THEORY EMBRACES ANY OF THE ENTITIES ON THE SCIENTOLOGY COMMAND CHART, WHETHER OR NOT THEY'RE DEFENDANTS IN THIS CASE, THAT IS MY REASON FOR ASKING THE QUESTION.

MR. HERTZBERG: I'M GOING TO MAKE AN OBSERVATION FOR THE RECORD, THEN. I'M GOING TO ALLOW HIM TO ANSWER SUBJECT TO LIMITATIONS. I NOW THINK THAT I UNDERSTAND WHY YOU THINK ALL THESE BROAD AND IRRELEVANT QUESTIONS CAN BE ASKED. IT APPEARS TO ME THAT YOU THINK THAT BECAUSE YOU PUT A BOILERPLATE ALLEGATION IN A COMPLAINT WITH THE MAGIC WORDS "ALTER EGO" IN THEM THAT YOU CAN ASK ABOUT ANY ENTITY WHATSOEVER ABOUT THE CHURCH OF SCIENTOLOGY REGARDLESS OF WHETHER THAT ENTITY IS MENTIONED IN THE COMPLAINT OR NOT. WE'LL SEE WHERE THAT ONE COMES OUT. MR. MISCAVIGE, YOU MAY ANSWER THE PENDING QUESTION SUBJECT TO THE LIMITATION ON THE FOUR CATEGORIES.

MR. LIEBERMAN: WELL, THE QUESTION IS WHETHER HE RECEIVED --

MR. HERTZBERG: WHETHER HE RECEIVED ANY; THAT'S A "YES" OR "NO." MS. PLEVIN: DO YOU WANT THE QUESTION READ BACK?

THE WITNESS: COULD YOU, PLEASE?

(RECORD READ AS FOLLOWS: "QUESTION: DID YOU RECEIVE ANY COMMUNICATIONS FROM MR. HUBBARD EITHER IN PERSON, IN WRITING OR THROUGH AN INTERMEDIARY FROM THE TIME YOU MOVED TO GILMAN HOT SPRINGS UNTIL THE TIME OF MR. HUBBARD'S DEATH REGARDING WISE, THE WORLD INSTITUTE OF SCIENTOLOGY ENTERPRISES, OR THE ESTABLISHMENT OF WISE AND ITS PURPOSE?")

MR. HERTZBERG: YES OR NO.

THE WITNESS: NO, I DON'T -- IS THIS SUBJECT TO THESE FOUR CATEGORIES? MS. PLEVIN: WELL, FIRST IF YOU DID AND THEN --

MR. HERTZBERG: DID YOU RECEIVE?

THE WITNESS: I DON'T KNOW WHAT "RECEIVE" MEANS. WHAT DOES THAT MEAN, DID I RECEIVE? DID HE WRITE TO ME ABOUT THIS; IS THAT WHAT YOU'RE ASKING ME? MR. HERTZBERG: THAT'S WHAT SHE'S ASKING YOU.

(ATTORNEY-CLIENT DISCUSSION HELD OFF THE RECORD.)

MR. HERTZBERG: I THINK HE UNDERSTANDS YOUR QUESTION.

THE WITNESS: NO.

MR. HERTZBERG: THE ANSWER IS NO.

THE WITNESS: NO.

BY MS. PLEVIN:

Q. YOU DIDN'T RECEIVE ANY?

MR. HERTZBERG: THE ANSWER IS NO.

MS. PLEVIN: OKAY.

Q. DID YOU RECEIVE ANY WRITTEN COMMUNICATION BY TELEX OR IN WRITING OR TYPED --

MR. LIEBERMAN: THIS IS DIRECTED TO MR. MISCAVIGE?

BY MS. PLEVIN:

Q. -- DIRECTED TO MR. MISCAVIGE IN PERSON OR THROUGH AN INTERMEDIARY FROM L. RON HUBBARD FROM THE TIME YOU MOVED TO GILMAN HOT SPRINGS TO THE TIME OF MR. HUBBARD'S DEATH REGARDING AUTHORS SERVICES, INC.? A. CAN I CLARIFY THIS OR ASK YOU A QUESTION? YOU KEEP REFERRING TO SOMETHING, FROM THE TIME I MOVED TO GILMAN HOT SPRINGS. HOW DO YOU WANT ME TO CATEGORIZE THAT?

Q. AH, WELL, BASED ON YOUR TESTIMONY YESTERDAY --

A. I MEAN, I TAKE THAT THAT YOU -- YOU KNOW -- BASED ON MY TESTIMONY -- GO AHEAD, I'M SORRY.

Q. BASED ON YOUR TESTIMONY YESTERDAY, YOU PUT THAT AT APPROXIMATELY 1980 OR THE END OF '79.

A. SO THAT'S WHAT YOU'RE ASKING ME.

Q. YES.

A. OKAY. ALL RIGHT. REGARDING AUTHORS SERVICES?

Q. YES.

A. OF COURSE.

Q. WHAT COMMUNICATIONS DID YOU RECEIVE?

MR. HERTZBERG: ALL RIGHT. HE MAY ANSWER THAT QUESTION SUBJECT TO THE LIMITATION OF THE FOUR CATEGORIES.

MISS PLEVIN, I ASSUME THAT WE CAN AGREE NOW FROM THE PRIOR RECORD, WHEN I SAY, "THE FOUR CATEGORIES," THAT EVERYBODY IN THIS ROOM UNDERSTANDS WHAT THE FOUR CATEGORIES ARE.

MS. PLEVIN: AS LONG AS MR. MISCAVIGE DOES, OF COURSE, I DO --

MR. HERTZBERG: ALL RIGHT.

MS. PLEVIN: THE RECORD WILL REFLECT THAT.

THE WITNESS: REGARDING MISSIONS, BENT CORYDON, MY POWER.

MS. PLEVIN: SQUIRRELS.

THE WITNESS: OR SQUIRRELS?

MS. PLEVIN: YES.

THE WITNESS: ABOUT ASI, NO.

MS. PLEVIN: OKAY. AND NOTING FOR THE RECORD THAT I AM NOT STIPULATING TO ACCEPT THOSE LIMITATIONS AND RESERVING MY RIGHT TO COMPEL AS TO FURTHER RESPONSE.

MR. HELLER: NOTING FOR THE RECORD THAT YESTERDAY YOU DID.

MR. LIEBERMAN: YES.

MR. HELLER: AND NOTING FURTHER, BY THE WAY, THAT YOU --

MS. PLEVIN: NO.

MR. HELLER: -- THAT WHAT YOU'RE DEALING WITH HERE IS A COMPANY WHICH HAS BEEN MY CLIENT WHICH HAS BEEN PUT TOGETHER IN ORDER TO, AMONG OTHER THINGS, MANAGE THE LITERARY AFFAIRS OF MR. HUBBARD. YOU'RE TALKING ABOUT -- NOW, YOU'RE GOING TO MOVE TO COMPEL ALL COMMUNICATIONS AT THE TIME THE CHAIRMAN OF THE BOARD OF THAT CORPORATION -- ALL COMMUNICATIONS, NOW, YOU'RE SAYING YOU'RE GOING TO MOVE TO COMPEL FROM MR. HUBBARD CONCERNING HIS LITERARY AFFAIRS TO THE PERSON WHO WAS RUNNING THE CORPORATION OR HAD SOMETHING TO DO WITH THE CORPORATION CONCERNING HIS LITERARY AFFAIRS; FINE. GO AHEAD AND DO THAT. THAT SHOWS THE LUDICROUSNESS OF THIS WHOLE LINE OF YOU SAYING THAT UNDER THIS ALTER EGO BOILERPLATE YOU CAN GET ANYTHING THAT YOU WANT.

BY MS. PLEVIN:

Q. DID YOU RECEIVE ANY COMMUNICATIONS FROM MR. HUBBARD, EITHER IN PERSON, IN WRITING, OR THROUGH AN INTERMEDIARY FROM THE TIME YOU MOVED TO GILMAN HOT SPRINGS REGARDING THE FORMATION OF ASI, AUTHORS SERVICES, INC.? MR. HERTZBERG: YOU MAY ANSWER TO THE EXTENT THAT SUCH COMMUNICATIONS DEALT WITH THE FOUR AREAS THAT WE HAVE IDENTIFIED.

THE WITNESS: WELL, NO, OF COURSE NOT.

MS. PLEVIN: OKAY.

Q. DID YOU RECEIVE ANY COMMUNICATIONS FROM MR. HUBBARD, EITHER IN PERSON, IN WRITING, OR THROUGH AN INTERMEDIARY, FROM THE TIME YOU MOVED TO GILMAN HOT SPRINGS UNTIL THE TIME OF MR. HUBBARD'S DEATH REGARDING THE SEA ORG? MR. LIEBERMAN: THIS IS AGAIN DIRECTED TO MR. MISCAVIGE?

MS. PLEVIN: THAT'S RIGHT.

MR. LIEBERMAN: THAT'S "YES" OR "NO."

THE WITNESS: REGARDING SEA ORG? I CAN'T RECALL THAT NOW.

MS. PLEVIN: OKAY.

Q. GOING BACK FOR A MOMENT TO THE TAPE YOU REFERRED TO AS "THE PROOF" --

A. NO, IT'S CALLED "TODAY AND TOMORROW," COLON, "THE PROOF."

Q. OKAY, THANK YOU.

A. I BELIEVE THAT'S THE TITLE OF IT. IT'S "RON'S JOURNAL 38."

Q. DO YOU RECALL APPROXIMATELY WHEN YOU RECEIVED THAT, WHAT YEAR?

A. LET'S SEE. WHEN WAS THAT? I BELIEVE IT CAME OUT FOR NEW YEARS, 1984. SO SOMETIME BEFORE THAT.

Q. AND WAS THAT, IN ESSENCE, MR. HUBBARD'S NEW YEARS ANNOUNCEMENT OR NEW YEARS GREETINGS?

MR. HERTZBERG: I DON'T UNDERSTAND THE QUESTION.

MR. DRESCHER: I DON'T EITHER.

MR. HERTZBERG: YOU MEAN YOU WANT HIM TO GUESS WHETHER THAT WAS A GREETING -- THAT WAS MR. HUBBARD'S GREETING?

MS. PLEVIN: I DON'T WANT HIM TO GUESS, MR. HERTZBERG.

MR. HERTZBERG: I DON'T KNOW. YOU'RE ASKING HIM TO DETERMINE THE OPERATION OF MR. HUBBARD'S MIND --

MR. HELLER: IT CALLS FOR SPECULATION.

MR. HERTZBERG: -- WITH RESPECT TO NEW YEARS.

MS. PLEVIN: I'LL WITHDRAW IT.

Q. HOW DID YOU -- WHO DID YOU DIRECT TO COPY THE TAPE AND DISTRIBUTE IT?

A. WHAT DO YOU MEAN BY THE WORD "DIRECT"?

Q. WELL, TO WHOM DID YOU TURN OR TO WHAT ENTITY DID YOU TURN TO FOLLOW OUT THE REQUEST OF MR. HUBBARD? I ASSUME YOU DIDN'T DO THE MANIPULATION OF COPYING THE TAPES YOURSELF.

A. THAT'S CORRECT. I MEAN, MY ROLE IN IT WAS JUST SIMPLY TO LISTEN TO THE COPIES TO MAKE SURE THEY'RE GOOD COPIES COMPARED TO THE ORIGINAL.

WHO DID I DIRECT? WELL, THE TAPE WAS COPIED BY GOLDEN ERA PRODUCTIONS. YOU ASKED ME WHO DID I DIRECT. IF I USE YOUR WORD -- AND JUST SO I CAN CLARIFY WHAT YOU MEAN BY "DIRECT," I TAKE IT YOU MEAN BY DIRECT, LIKE I WENT AROUND AND "YOU DO THIS. YOU DO THIS. YOU DO THIS. YOU DO THIS." I WOULD HAVE TO ANSWER NOBODY. I GAVE THE TAPE TO THESE PEOPLE WHO DEAL WITH THAT EVERY SINGLE DAY, AND THEY KNOW ALL ABOUT THAT.

Q. OKAY.

(DISCUSSION HELD OFF THE RECORD.)

BY MS. PLEVIN:

Q. ARE YOU AN OFFICER OF GOLDEN ERA? A. NO.

Q. WERE YOU AN OFFICER OF GOLDEN ERA AT THE TIME YOU RECEIVED THE TAPE? A. NO.

Q. WERE YOU ON THE BOARD OF GOLDEN ERA AT THE TIME YOU RECEIVED THE TAPE? A. THE BOARD?

Q. THE BOARD OF DIRECTORS.

(ATTORNEY-CLIENT DISCUSSION HELD OFF THE RECORD.)

THE WITNESS: NO.

MR. HERTZBERG: AND THAT'S ASSUMING, MISS PLEVIN -- BECAUSE I DON'T THINK THERE'S A FOUNDATION FOR THIS -- THAT THERE IS A BOARD. BY MS. PLEVIN:

Q. DO YOU KNOW IF THERE'S A BOARD?

A. DO I KNOW IF THERE'S A BOARD?

Q. A BOARD OF DIRECTORS.

A. NO, I DON'T KNOW.

Q. ARE YOU ON THE ORG BOARD OF GOLDEN ERA?

A. NO.

Q. WERE YOU THEN?

A. NO.

Q. AT ANY TIME FOLLOWING YOUR MOVING TO GILMAN HOT SPRINGS, DID YOU RECEIVE ANY COMMUNICATION FROM MR. HUBBARD, EITHER IN PERSON, IN WRITING, VIA TELEX OR TYPEWRITTEN COMMUNICATION OR THROUGH AN INTERMEDIARY REGARDING THE BOOK I CAMPAIGN? MR. LIEBERMAN: ONCE AGAIN THIS IS DIRECTED TO MR. MISCAVIGE?

MS. PLEVIN: THAT'S RIGHT.

MR. HERTZBERG: "YES" OR "NO."

THE WITNESS: JUST TO CLARIFY, YOU ASKED ME ABOUT THE BOOK I CAMPAIGN?

MS. PLEVIN: CORRECT.

THE WITNESS: ABOUT THE BOOK I CAMPAIGN? YOU'LL HAVE TO DESCRIBE TO ME WHAT YOU MEAN BY THAT. DO YOU MEAN JUST BOOK I; IS THAT WHAT --

MR. HERTZBERG: ASK HER TO CLARIFY. DON'T SUGGEST.

THE WITNESS: ALL RIGHT.

qq


go to part 15