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

					83

	  Zuravin had obtained from other IRS offices in order to
	  respond to the scientology FOIA suit. Following each entry,
	  the defendant Wolfe gave Mr. Meisner the documents which he
	  had stolen. 57/ Mr. Meisner summarized each set of documents
	  in a memorandum which he sent to his superiors in Los Angeles,
	  California.  Government Exhibits Nos. 44, 47, 48 and 50  58/
	  are memoranda prepared by Mr. Meisner for that purpose.
	  Each of these exhibits followed the format of previous memo-

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

	      57/ The defendant Wolfe told Mr. Meisner that he followed
	  the same procedure each time he entered the IRS offices in
	  order to steal documents. After taking the documents out
	  out of a particular individual's office, he photocopied them
	  on a United States Government photocopying machine using
	  United States Government equipment and paper and then returned
	  them to their proper location, and took the copies of documents
	  out of the building. Of course, all this was done without
	  permission.

	       58/  Government Exhibit No. 44 was seized by Special
	  Agent Frederick Hillman, Government Exhibit No. 147 was seized
	  by Special Agent Roger L. Lehman, and Government Exhibit No. 
	  50 was seized by Special Agent Edward J. Miller. They were
	  each seized from a different file cabinets in Room 30 of the 
	  Information Bureau at the Cedars Complex. Government Exhibit
	  No. 118 was seized by Special Agent Smith from Room 4 in that
	  same building.

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

					84
		    
	randa written by Mr. Meisner. 59/ However, beginning with
	Government Exhibit No. 45, 60/ the memorandum dated 30
	September 1975, the routing was changed for security purposes.
	Whereas before September 30, 1975 the memoranda and appended
	documents were routed through a number of Information Bureau
	officials, following that date, the memoranda were routed
	directly from Mr. Meisner to the defendant Raymond.  The
	defendant Raymond was then responsible for the distribution
	of the memoranda and documents to the other officials of the
	information Bureau and Guardian's Office who previously

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

	59/  Mr. Meisner identifies handwriting of the
	defendant Raynond on the following documents: Government
	Exhibits Nos. 44 and 45, the handwritten notations next to the
	entry "Dear Cindy"; Government Exhibit No. 45, the entry "Sent
	to WW" on the upper right-hand corner of page one; Government
	Exhibit No. 47, the handwritten notation on the upper left-
	hand margin and in the upper right-hand of page one "CIC copy";
	Government Exhibit No. 48A, the handwritten notation above
	"Coll Off US" and the initials and date next to that title
	as well as the handwritten notation below the title of the 
	document; and Government Exhibit No. 50 the initials and
	date next to the title "Coll Off US" in the routing. Mr.
	Meisner also identifies on Government Exhibit No. 44 the
	initials in the handwriting of the defendant Heldt next to
	the title "DG US" in the routing portion of the document.

	60/ Government Exhibit No. 45 was seized by Special
	Agent Lehman from a file cabinet in Room 30 of the Cedars
	Complex.

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

				       85

	received them, namely, the defendants Heldt, Weigand and
	Willardson. A copy, however, was still sent to the CSG, the
	defendant Mary Sue Hubbard, as indicated by the routing in
	the upper right-hand corner of each memorandum.
	     Government Exhibits Nos. 46A-D are copies of IRS documents
	stolen from Mr. Zuravin's office by the defendant Wolfe and
	given to Mr. Meisner. Each of those documents is summarized
	in the Meisner memorandum of 30 September 1975 (Government
	Exhibit No. 45). 61/ Each of the four documents has numbers
	placed by Mr. Meisner at its lower right-hand corner, and
	concerns either, "the IRS National Office Intelligence files"
	or the "SSS" [Special Services Staff] files", which were
	specifically called for by GO 1361, Target 10. In the memo-
	randum of 24 September 1975 (Government Exhibit No. 44), Mr.
	Meisner summarized documents regarding the "IRS/Hawaii
	Intelligence Files". The memorandum of 10 October 1975
	     
- ----------------------------

	61/ They are summarized as follows: Government Ex-
	hibit No. 46A in Government Exhibit No 45 at page four
	paragraph two; Government Exhibit No. 46B at page four, 
	paragraphs five and six; Government Exhibit No. 46C at page
	two, paragraphs two and three; and Government Exhibit No.
	46D at page three, paragraphs one and two.

- ---------------------------------------------------------------
					
					86

	(Government Exhibit No. 47) excerpts "IRS Intelligence Files -
	1972-1974". Mr. Meisner's 13 October 1975 memorandum (Govern-
	ment Exhibit No. 48a) deals with the transcript of an inter-
	view between former, Scientologist Gene Allard, and California
	Deputy Attorney General Lawrence Tapper. A copy or that
	transcript had been given to the IRS. Mr. Meisner's memorandum
	was subsequently transmitted by the defendant Cindy Raymond
	to the other Guardian's Office officials who previously had
	been included in Mr. Meisner's routing.  Thus, in a letter
	dated 21 October 1975 (Government, Exhibit No. 48), the defnd-
	ant Raymond 62/ transmitted the appended Meisner memorandum
	of 13 October 1975 and the appended stolen documents to
	Michael Taylor, the US Directorate Secretary B-I World-Wide,
	via the defendants Heldt, Weigand, and Willardson, as well
	as Jane Kember and Mo Budlong.  The letter further indicated
	that a copy had already been sent to the "CSG", the defendant

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

	62/ Handwriting expert James Miller positively identifies
	the signature "Cindy" on that letter having been written by
	the defendant Raymond.

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

					   87

	Mary Sue Hubbard, by "AG I DC" Meisner.
	     By early October 1975, Charles Zuravin had completed an
	FOIA index regarding all IRS documents relating to Scientology,
	and had given it to Scientology attorneys. Prior to preparing
	the FOIA index, Mr. Zuravin had numbered each document so as
	to facilitate locating them. Within the next few days, the
	defendant Raymond sent Mr. Meisner a copy of that index with
	a directive to obtain all documents which Mr.  Zuravin had
	concluded were exempted from the FOIA. Mr. Meisner, prepared
	a list of those "excempted" documents by IRS number and gave
	it to the defendant Wolfe who was instructed to obtain them
	Then, in a letter dated 10 November 1975 (Government Exhibit
	No. 49) 63/ to the defendant Cindy Raymond, Mr. Meisner 
	enclosed a copy of the list of withheld documents which he
	had given to the defendant Wolfe. Mr. Meisner explained to
	her that he had prepared that list from the FOIA index which
	she had sent him. He told the defendant Raymond that "Silver",
	the defendant Wolfe, had been given a copy of that list and

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

	63/ Government Exhibit No. 49 was seized by Special
	Agent Smith from Room 4 in the Information Bureau at the
	Cedar's Complex.

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

					88

	"is methodically making Copies of all documents listed." He
	told the defendant Raymond that the defendant Wolfe, over the
	previous weekend, had taken "a foot of material"   (stolen
	documents) from the IRS and was already through the third
	column of numbers on the index list. Mr. Meisner estimated
	that an additional two weekends would be needed to acquire all
	remaining documents from the IRS. 64/  
	    Upon receipt from Mr. Meisner of the list of withheld
	documents, the defendant Wolfe entered the offices of Mr.
	Zuravin at the IRS on or about November 20, 1975 and obtained
	documents located on that list. 65/ Thus, the title of Mr. 

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

	614/ Handwriting expert James Miller identifies the
	defendant Raymond as the writer of the eleven line notation in
	the left margin; the note "This ia an FOI IRS index of all
	withheld documents in IRS FOI action" on the right-hand side
	of the document and the nine line notation beginning "Note I am
	double checking . . ." on page two or Government Exhibit No. 49.
	Mr. Miller concludes that the handwritten notation "GW 14
	Nov" in the upper left-hand corner of the front page is
	probably in the handwriting of the defendant Willardson.
	Mr. Meisner identifies the note as being in the handwriting 
	of the defendant Willardson.

	65/ In a 4 November 1975 memorandum regarding the state 
	of the District of Columbia Guardian's Office actions on tar-
	gets 10 and 17 of GO 1361, which she received from Peggy
	Tyson, the Programs Officer U.S, the defendant Raymond, in a
		(footnote continued on next page.)

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

					      89

	Meisner's 20 November 1975 memorandum (Government Exhibit
	No. 50); "Re: Withheld IRS FOI Documents #108-141." However,
	within a few days after that entry, the IRS moved all
	Scientology-related documents from Mr. Zuravin's office to
	a file room which had previously been the office of Helen
	Bumbry, located across the hall and which had a more secure
	lock. Consequently, the defendant Wolfe was unable to continue
	to obtain the remaining documents until sometime in January
	1976 when, with the assistance of Mr. Don Alverzo, that office
	was forced open with lock-picking equipment. (See page 100,
	_infra_.)
	     Mr. Zuravin states that all the documents summarized in
	the Meisner memoranda described above were in his files from
	July to November 1975. Furthermore, he states that he neither

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

	handwritten note, stated that Mr. Meisner was verifying "what
	more is needed to comply to tgt 10", and had received a copy
	of a list of all documents withheld by the IRS under the FOIA.
	(Government Exhibit No. 56B). Handwriting expert James
	Miller positively concludes that all the writing up to the 
	signature "Cindy" is that of the defendant Raymond.

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

					     90

	gave permission to the defendant Wolfe nor any other represent-
	ative of the Guardian's Office of the Church of Scientology
	to enter his office and take copies of the documents located
	therein, nor had he given these documents to the Church of
	Scientology pursuant to the Freedom of Information Act.


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

	     In early December 1975, Mr. Meisner went to Los Angeles
	California, for briefings with his superiors in the Guardian's
	Office. During one of those meetings the defendant Richard
	Weigand showed Mr. Meisner the newly issued Guardian Program
	Order 158 (GPgmO 158) -- Early Warning System. That Guardian
	Program Order was issued on December 5, 1975 by the Guardian
	World Wide Jane Kember after having been written by the
	defendants Henning Heldt and Richard Weigand. (Government
	Exhibit No. 53) 66/ GpgmO 158 states that it'd purpose is to

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

	66/ Mr. Meisner and Ms. Hirsch state that the GPgmO 
	158 was issued in accordance with established Guardian Office
	procedure for the issuance of Guardian Program Orders.
		 (footnote continued on next page.)

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

						91

	"[m]aintain an Alerting EARLY WARNING SYSTEM throughout the GO
	[Guardian's Office] network so that any situation concerning
	governments or courts by reason of suits is known in adequate
	time to take defensive actions to suddenly raise the level on
	LRH Personal Security very high" 67/ Thus, the purpose of
	GPgmO 158 was to identify any potential lawsuit against, or
	subpoena for, "LRH [L. Ron Hubbard] or MSH [the defendant
	Mary Sue Hubbard] from a government agency or individual
	litigation or from any source whatever" (vital target 3)

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

	The names appearing at the bottom of page 3 indicate that the
	order was written by the defendants Heldt and Weigand and
	approved and issued by Guardian World Wide Jane Kember. Ms.
	Hirsch also states that the initials "LM" which appear to the
	left of Ms. Kember's name are in the handwriting of Ms.
	Kember's communicator (secretary). Government Exhibit No. 53
	was seized by Special Agent Robert Claudius from a file
	cabinet in the defendant Willardson's Office at the Cedars
	Complex.

	67/  GPgmO 158 was issued pursuant to target 1 of GO
	261175 which was originally issued by L. Ron Hubbard. An
	identical Guardian Program Order, 158 R was reissued on May 27,
	1977 by the defendants Weigand and Heldt. (Government 
	Exhibit No. 111.) Government Exhibit No. 111 was seized by
	Special Agent Gary Aldrich from the office of the defendant
	Willardson at the Cedars Complex.

- ---------------------------------------------------------------
					    
					    92
	
	"before activation" (vital target 2).
	    Specifically, Guardian Program Order 158 directed the
	following:

		      1.  Place an agent into the US Attorney's
		Office DC as a first action as this office
		should cover all Federal agencies that we are in
		litigation with or may be in litigation with. AG I DC

		      2. Obtain data on their intended actions
		toward Scientology, LRH/MSH. AG I DC

		      3. Get an agent into the US Attorney's
		rffice [sic] LA as a simultaneous action .  .  .  .

		      4. Obtain data on their intended actions
		toward Scientology, LRH/MSH. BR 1 DIR US

		       5.  Place a separate agent into the IRS
		Office of International Operations (OIO) (as
		this office has a case preparation or investi-
		gative action going on LRH personally for income
		tax invasion or something similar). AG I DC

		       6.  Obtain their files on LRH/MSH and
		Scientology and monitor the line continuously
		of other actions against LRH/MSH. AG I DC

		       7.  Continue to monitor tightly the DEA DC,
		IRS DC and LA, the Coast Guard (soon to go to
		Immigration and Naturalization) DC. Get any
		present time data on LRH/MSH. BR I DIR US 68/

- ---------------------
		 
	68/ The other operating targets under GPgmO 158 include
	moving existing of agents in the District Attorney's Office
		  (footnote continued on next page.)

- ---------------------------------------------------------------
					       
				       93
	    After reviewing Guardian Program Order (GPgmO) 158 with
	the defendant Weigand, Mr. Meisner suggested that it would
	b@ more advantageous to the Hubbards, Scientology, and the
	Guardian's Office to place a covert Scientology agent at the
	United States Department of Justice in Washington, D.C.,
	rather than in the United States Attorney's Office in that
	city. Mr. Meisner observed that Freedom of Information Act
	suits were, generally, handled by the Justice Department.
	Mr. Meisner also discussed this matter with the defendant
	Cindy Raymond. Both the defendants Weigand and Raymond
	approved Mr. Meisner's suggestion and directed him to prepare
	a "CSW" for their approval.

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

	   in Los Angeles and the Attorney General's Office of California
	   "into position to obtain advance warning" (Target 8); "[g]et
	   Intell coming from Paulette Cooper, Robert Kaufman, Bernie
	   Green, and John Sefferrn to obtain intelligence data on
	   intended attack. AG I New York" (Target 14); "[p]lace a
	   very secure agent into the AMA Chicago headquarters in the
	   best position possible to obtain data on their intended
	   actions towards us" (Target 16); "[d]etermine what agency 
	   near LRH would serve any Federal governmental subpoena.
	   This could be the local US Marshall's [sic] Office" (Target
	   19). (L. Ron Hubbard and Mary Sue Hubbard were living outside
	   of Clearwater, Florida, at the time Kember issued GpgmO 158.)

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

					      94

	     Following his return to the District of Columbia in the
	second week of December 1975, Mr. Meisner sent a "CSW," out-
	lining his suggestion, to the defendant Weigand, routed
	through the defendant Raymond.  The "CSW" called for placement
	or the defendant Sharon Thomas as Scientology's covert operative
	within the Department of Justice instead of the Immigration
	and Naturalization Service where she had been earlier scheduled
	to infiltrate for Scientology. See GPgmO 158, Operating Target 7.
	The defendant Weigand immediately approved Mr. Meisner's
	"CSW", first by telex, then by letter. Mr. Meisner after
	having discussed the matter with the defendant Thomas, directed
	her, during a meeting at a "Three Chef's" restaurant in nearby
	Arlington, Virginia, to obtain employment at the Information
	and Privacy Unit of the Civil Division of the Department of
	Justice, which handled all FOIA requests and lawsuits. Ms.
	Thomas, however, was unable to begin employment at the Depart-
	ment of Justice until February 29, 1976. 69/ (Government
	Exhibit No. 206).
		   
- -----------------

	69/  Ms. Thomas resigned her position with the United
	States Coast Guard on February 28, 1976. She had begun employ-
	ment there on January 13, 1975.

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

				     95

	Prior to Ms. Thomas' employment at the Department of
	Justice, Mr. Meisner, the defendant Wolfe and other Guardian's
	office officials committed a series or burglaries of the main
	Justice Department building, located at 9th and Pennsylvania
	Avenue, in Washington, D.C. The initial two entries
	were made in December, 1975 by Mr. Meisner and the defendant
	Wolfe in order to obtain documents from the office of Justice
	Department attorneys Paul Figley and Jeffrey Axelrad, both of
	the Civil Division's Information and Privacy Unit. The
	defendant Raymond had previously informed Mr. Meisner that
	the Legal Bureau of the Guardian's Office had learned that
	Mr. Figley had been assigned the FOIA cases initiated by
	Scientology. According to Raymond, Mr. Figley also coordinated
	other FOIA cases involving Scientology. Another reason for
	entering Mr. Figley's office was to gain information pursuant
	to GPgmO 158. They also were seeking Interpol documents in
	compliance with Guardian World-Wide Jane Kember's long out-
	standing order of November 21, 1973, as reissued by the
	defendant Heldt on April 25, 1975 (see Government Exhibit
	No. 2), and Guardian Program Order 9 (see Government Exhibit
	Exhibit No. 63, at page 142, infra).

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

					96

	    On both occasions that Mr. Meisner and the defendant
	Wolfe burglarized Mr. Paul Figley's office, they entered the
	main Department of Justice building prior to 5:30 p.m. by
	using the defendant Wolfe's IRS identification card. They
	waited in the main library, until after working hours, when
	they proceeded to Figley's office, which they unlawfully
	entered, through a closed but unlocked door. Mr. Meisner
	observed files relating to Scientology on Figley's desk,
	on his window ledge, and in his file cabinets. During the
	first entry, Mr. Meisner skimmed through all of the files
	and then took four files which were located in open areas in
	Mr. Figley's office. Using photocopying machines, facilities,
	equipment and paper located on the fourth floor of the building
	Mr. Meisner and the defendant Wolfe photocopied the files,
	returned them to Mr. Figley's office, and stole copies of
	the documents for the use of the Guardian's Office of the
	Church of Scientology. Both times, Mr. Meisner and the
	defendant Wolfe were in the building until approximately
	10:00 P.M. On neither occasion, did Mr. Meisner or the

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

					97

	defendant Wolfe have permission to enter the office of Mr.
	Figley, take his files, photocopy the documents, and take
	those photocopies. They, thus, deprived Mr. Figley and the
	Department of Justice of sole possession of these documents.
	Following the theft of the copies of documents, Mr. Meisner
	summarized their contents in two memoranda dated 17 December
	1975 (Government Exhibit No. 54) and 18 December, 1975
	(Government Exhibit No. 55). 70/ Each memorandum was sent
	to the defendant Raymond who at that time still held the 
	position of Collections Officer U.S. A copy was sent to
	the "CSG", defendant Mary Sue Hubbard. Appended to each
	memorandum were the stolen copies of the documents.
	    Government Exhibit No. 54 is entitled "Re: Justice 
	Department, FOI Suits -- Figley"; and Government Exhibit No.

- ------------------------
		 
	70/ Government Exhibits Nos. 54 and 55 were seized by 
	the FBI from a file cabinet in the Information Bureau at the
	Cedars Complex.

- ---------------------------------------------------------------
							    
						98
	
	55 71/ is entitled "Re: DEA FOI Case -- D of J Data --
	Figley". Both memoranda were received by the defendant
	Cindy Raymond, who initialed and dated the documents next to
	her title on their routing portion. 72/ prior to the defendant
	Thomas' employment at the Department of Justice, additional
	burglaries of, and theft of copies of documents from, Mr.
	Figlay's office were committed by the defendant Wolfe together

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

	71/ Mr. Paul Figley states that in 1975 and 1976 he was
	a trial attorney in the Information and Privacy Unit of
	the Civil Division of the United States Department of Justice
	at 9th & Pennsylvania Avenue, N.W. in Washington, D.C.
	During the years covered by the indictment in the instant
	case, Mr. Figley was assigned to the processing of FOIA cases
	involving the Central Intelligence Agency (CIA), the Drug
	Enforcement Administration (DEA), the U.S. Customs Service,
	the Defense Communications Agency, the Department of the
	Army, the Energy  Research and Development Administration
	(ERDA), the U.S. Postal Service and Interpol. In his care,
	custody and control, as a result of his duties as a Justice
	Department attorney, were numerous documents from these
	agencies relating to Scientology.  Mr. Figley has reviewed
	the Meisner memoranda marked Government Exhibits Nos. 54 and
	55 and states that the documents summarized therein were in
	his possession in December 1975. He further states that he
	did not give permission to the defendant Wolfe or Mr. Meisner
	to enter his office, take documents, photocopy them and
	take copies of the documents for the use of Scientology.

	72/ Handwriting expert James Miller concludes that it 
	is "highly probable" that these handwritten entries as well as
	the entries "non FOI" and the "Justice Dept" notation on
	Government Exhibit No. 55 were made by the defendant Raymond.

- ------------------------------------------------------------------
						      
				       99

	with Joseph Alesi, the Collections Officer in the District
	of Columbia's Information Bureau, and Richard Kimmel, the
	Information Branch I Director in the District of Columbia.
	On each of those occasions, the stolen copies of documents
	were personally given to Mr. Meisner by either Messrs. Alesi
	or Kimmel. They also told Mr. Meisner that they had taken
	the documents from Mr. Figley's office, photocopied then on
	photocopying machines located within the Department of Justice,
	using United States Government property equipment, and supplies,
	and stole the resulting copies of documents. 73/


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

	73/ Soon after she began her employment for the
	Information and Privacy Unit of the Civil Division at the
	Department of Justice, the defendant Thomas began to steal
	documents and photocopies thereof. Thus, on or about March
	22, 1976, she entered Mr. Figley's office after regular
	working hours, and, without permission, took some thirty pages
	of documents relating to Scientology which Mr. Figley was
	receiving as part of FOIA suits against the CIA, ERDA, FDA,
	Army and Defense Departments. She photocopied the documents
	using United States Government equipment and supplies and gave
	copies of these documents to Mr. Meisner. Mr Meisner summar-
	ized these documents in a memorandum dated March 22, 1976
	which he sent with the documents to the defendant Hermann
	(a/k/a Cooper.) (Government Exhibit No. 64). He also sent a
	copy to the "CSG", defendant Hubbard. The defendant Hermann 
	forwarded Meisner's memorandum and documents to World-Wide.
	Handwriting expert James Miller
			  (footnote continued on next page.)

- ---------------------------------------------------------------
				       
				       100
				       
		     H.   The Los Angeles Guardian's Office
			  Sends Help to the District Of
			  Columbia Guardian's Office
				  
	     In November 1975, the Office Of Messrs. Charles Zuravin
	and Lewis Hubbard were placed within a "red seal" or high
	security area inside the main IRS building in Washington
	D.C. Consequently, the doors were both locked at all times.
	As a result of those moves, Mr. Meisner and the defendant
	Wolfe were unable to gain entry in these areas and lost the
	ability to monitor those areas. Both defendants Weigand and
	Raymond, by phone and letter, repeatedly urged Mr. Meisner
	to continue to surveil the offices of Messrs. Hubbard and
	Zuravin in order to obtain all recent documents relating to

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

	positively identifies the fourteen-line handwritten notation
	as well as the initials "CR, 28 March 76" on the Hermann
	letter as having been made by the defendant Raymond. He
	also concludes that it is "highly probable" that the initials
	"GW" and "BID Natl CIC" were made by the defendant Willardson;
	and "probable that the signature "Mike C" was made by the
	defendant Hermann/Cooper. Moreover, Mr. Meisner identifies
	that signature as well as the entry "(sent by DC)" next to
	"CSG" as having been made by the defendant Hermann/Cooper;
	and the initials "GW" as those of the defendant Willardson.
	Government Exhibit No. 64 was seized by the FBI from a file
	cabinet within the Information Bureau at the Cedars Complex.

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

						101
	
	Scientology, especially those in Mr. Hubbard's possession
	dealing with the current status of the Church of Scientology
	of California audit. Mr. Meisner informed them that it had
	become impossible to gain access to those offices. Thus, in
	mid-January 1976, the defendant Hermann, the Southeast U.S.
	Secretary for the Information Bureau under its reorganiza-
	tion, notified Mr. Meisner by phone that the defendants
	Heldt and Weigand had approved "mission orders" to send Don
	Alverzo to Washington, D.C. to gain access to these two
	offices.  Alverzo arrived in Washington, D.C., on Saturday,
	January 17, 1976, and met Mr. Meisner at the Church of Scien-
	tology at 2125 S Street, N.W., Washington, D.C. Mr Alverzo
	showed Mr. Meisner a copy of his "mission orders" and informed
	him that they were to go into the IRS building with the
	defendant Wolfe the next day to pick the looks on the doors
	of Messrs. Hubbard and Zuravin. Mr. Alverzo also showed
	Mr. Meisner the lock-picking equipment he had brought 
	with him and instructed Meisner on how to use such equipment.
	Mr. Meisner identifies Government Exhibit No. 203 as equipment
	identical to the equipment which Alverzo brought with him to

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

					102

	the District of Columbia. (See photograph of these exhibits,
	Government Exhibit No. 218.) 74/
	     On Sunday, January 18, 1976, the defendant Wolfe, together
	with Messrs. Meisner and Don Alverzo, entered the main IRS
	building located at 1111 Constitution Avenue, N.W., in
	Washington, D.C., between 7:00 and 8:00 p.m. The defendant
	Wolfe signed all three individuals into the building using
	his IRS identification card. They proceeded to the third
	floor area where Mr. Zuravin's file office and Mr. Hubbard's
	office were located some three to four doors apart.

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

	74/ Government Exhibits Nos. 195 - 203 were located in
	a black suitcase seized by Special Agent Eusebio Benavidez
	from the office of the defendant Willardson at the Cedars
	Complex.  These exhibits were examined by FBI Special Agent
	James O. Davis of the FBI laboratory, who identifies them as
	follows:

		  Exhibits 195-201, "seven spring steel shims",
		  Exhibit 202, a key "micrometer", and
		  Exhibit 203, a "H.B.C. Inc. lockpicking kit."

	As a result of his examination of these items, Agent Davis
	concludes that Government Exhibits Nos. 195 - 201 are "commonly
	used for making picks and tension tools used in picking
	locks," Government Exhibit No. 202 is "used to measure the 
	depth of cuts in keys," and Exhibit 203 "is a pick set . . .
	[and] the tools it contains are used for picking locks."

- ---------------------------------------------------------------
						
						103     

	While the defendant Wolfe stood guard at the end of the
	hallway, Mr. Alverzo attempted to pick the lock on Mr.
	Hubbard's door, and Mr. Meisner worked on Mr. Zuravin's
	door. After having been unsuccessful in opening these
	doors for approximately one to one and one-half hours, Mr.
	Meisner, in exasperation, hit with his fist the top of
	Zuravin's door, forcing it to pop open. All three indivi-
	duals entered and took, without permission, the remaining
	Scientology-related documents which had been withheld by the
	IRS in FOIA litigation. They then went to another floor
	where all three began to photocopy these documents using
	United States Government equipment and resources. After
	a while, the defendant Wolfe took over the photocopying,
	while Messrs. Meisner and Alverzo returned to the third
	floor in a further attempt to open Mr. Hubbard's office
	Finally, Mr. Alverzo, using a piece of cardboard, was able
	to force that door open. Then, with the assistance of the
	defendant Wolfe, they reviewed all Scientology-related
	material in Mr. Hubbard's office, and took those documents

- ---------------------------------------------------------------
					 
					 104

	which had not been previously stolen. They then photocopied
	the documents, using the same IRS photocopying equipment and
	material and returned all documents to their respective
	locations. At approximately 2:00 a.m., all three men left
	the IRS building with a one foot high stack of stolen copies
	of documents. Messrs. Meisner and Alverzo proceeded to the
	Information Bureau offices at 2125 S Street, N.W., where they
	placed the documents in a secure location. Alverzo left
	Washington, D.C. to return to Los Angeles, California, on
	January 19, 1976.
	     Government Exhibit No. 56D 75/ is a "mission
	report", dated January 22, 1976, from the defendant Mitchell
	Hermann, now using his alias Mike Cooper, to Michael Taylor,
	the U.S. Secretary for, B-1 World-Wide, regarding this three-day
	mission of Don Alverzo to the District of Columbia. 76/ In

- ----------------------
				  
	75/ Government Exhibit No. 56 was seized by Special 
	Agent from Room 4 in the Information Bureau at the
	Cedars Complex.

	76/ Handwriting Expert James Miller concludes that the
	signature "Mike C" on Government Exhibit No 56D is probably
	the handwriting of the defendant Hermann. Moreover, Mr.
	Meisner identifies the signature to be in the handwriting
	of the defendant Hermann.

- ---------------------------------------------------------------
					     
					     105

	it, the defendant Hermann informed Mr. Taylor that on January
	17, 1976, Mr. Alverzo had been sent to Washington, D.C. to
	acquire "additional and more recent 1361 tgt 10 data." He
	adds that the "missionaire [Alverzo] was briefed by AG I DC
	[Meisner] and was accompanied by AG I DC and an FSM [Wolfe]
	on the mission." He further stated that the mission had
	been successful, and that "a pile of documents approximately
	10" thick" had been seized. He detailed that Mr. Alverzo
	instructed Mr. Meisner and the defendant Wolfe on "how to
	obtain future access" to these areas. The defendant Hermann
	concluded that as a result of that entry the remaining
	documents withheld under the FOIA were stolen from the IRS.
	    In a "compliance report" dated 21 January, 1976
	(Government Exhibit No. 56C), the defendant Weigand responded
	to a request from the defendant Heldt regarding the mission
	of Mr. Alverzo so that Heldt could respond to a dispatch from
	the defendant Mary Sue Hubbard. The defendant Weigand appended
	to his letter the report of Acting Southeast U.S. Secretary
	Hermann (a/k/a Cooper). The defendant Weigand explained


- ---------------------------------------------------------------------------
					 
					 106

	that he authorized the Alverzo mission because of the need to
	get current documents regarding Scientology, and that the
	District of Columbia Guardian's Office personnel was not
	trained to pick locks. 77/


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

	    At the beginning of February 1976, Mr. Meisner went to
	Los Angeles, California, both for auditing and for briefing
	regarding his Guardian Office assignments. While in Los
	Angeles, Mr. Meisner had numerous meetings with his immediate
	superiors, as well as other officials of the Guardian's
	Office. During the first week of February, Mr. Meisner
	attended a meeting with the defendants Henning Heldt and
	Richard Weigand in Mr. Heldt's office on the sixth floor of

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

	77/    See Government Exhibit No. 57, a letter dated 3
	February 1976 from the defendant Weigand to the CSG Assistant 
	for Information, Jimmy Mulligan, responding to Mulligan's
	request for information concerning the status of the IRS
	document collection under GO 1361. That letter referred to
	the Alverzo forced entries into IRS as well as subsequent
	areas entered by the defendant Wolfe.

- ---------------------------------------------------------------------------
					   
					   107

	Fifield Manor. Also present at that meeting were the Deputy
	Guardian for Finance Mary Heldt, the Deputy Guardian for the
	Legal Bureau Mary Rezzonico, and the CPA (Certified Public
	Accountant) US Martin Greenberg, an official in the Finance
	Bureau.  The defendant Weigand, at the defendant Heldt's
	request told Mr. Meisner to attend the meeting. Its purpose
	was to discuss and analyze the current IRS strategic as revealed
	in the stolen documents regarding the pending Church of
	Scientology of California audit.  Each person present at that.
	meeting expressed full knowledge that the documents in question
	had been stolen from the IRS offices. That same day, Mr.
	Meisner attended another meeting with Mary Rezzonico and the
	defendant Gregory Willardson in the defendant Weigand's office.
	During that meeting, Ms. Rezzonico, directed Mr. Meisner to
	instruct the covert agents in the District of Columbia to
	be alert to any IRS documents regarding a Scientology front
	organization known as the Religious Research foundation (RRF).
	She was also seeking any information disclosing knowledge by 
	the IRS of any financial dealings and relationship between
	RRF and the Church of Scientology of California.
	
- ---------------------------------------------------------------------------

					108

	    During the time that he was in Los Angeles, Mr. Meisner
	also met with the defendants Weigand and Willardson in
	defendant Weigand's office at the Fifield Manor to discuss
	the Information Bureau's access to current documents in the
	possession of IRS. The participants discussed a telex which
	had been received from the CSG Assistant for Information, Jimmy
	Mulligan, regarding the access to current information in the
	office of Mr. Lewis Hubbard of the IRS. The defendant Weigand
	instructed Mr. Meisner to prepare a report outlining what
	he had done in that respect and to respond to Mr. Mulligan's
	telex.
	    As a result of that directive, Mr. Meisner prepared
	Government Exhibit No. 46B which begins at page eight of
	Government Exhibit No. 46. It includes a telex in the name
	or Richard Weigand responding to Mulligan's inquiry. Mr.
	Meisner gave that telex directly to the defendant Weigand
	who approved it in his presence and directed that it be sent
	to Mr. Mulligan, whose offices were near Clearwater, Florida.
	Mr. Meisner also prepared a three-page handwritten letter to

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


					      109
	
	the defendant Weigand dated 3 February 1976. In it, Mr.
	Meisner outlined the events which had recently taken place
	in the District of Columbia, including the forced entry made
	by Don Alverzo into Mr. Hubbard's office at the IRS. He also
	detailed how Wolfe gained access to attorney Stephen Friedberg's
	office in the Chief Counsel's Office by unlocking one of his
	office doors during the daytime. Mr. Meisner informed the
	defendant Weigand that Mr. Friedberg had documents relating
	to the California Church of Scientology audit dated as recently
	as January 26, 1976. Mr. Meisner handed that report to Mr.
	Weigand upon its completion.
	    In a "compliance report" dated 11 February 1976, from
	the defendant Weigand to Guardian World-Wide Jane Kember,
	the defendant Weigand reviewed the achievements of the Infor-
	mation Bureau pursuant to GO 1361 Target 10 and reported
	compliance with that target. He informed Ms. Kember that
	all documents withheld by IRS under the FOIA for the period
	up to March 1975 had been stolen from the IRS. These included
	documents from the offices of Barbara Bird, Lewis Hubbard,

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


					110

	Stephen Friedberg, the Chief Counsel's office, the Office Of,
	International Operations, the Intelligence Division, and the
	Special Services Staff. The defendant Weigand also stated
	that documents turned over by the IRS to the Department of
	Justice Tax Division and staff attorney Michael Sanders had
	also been obtained. Mr. Meisner identifies the signature
	"Dick" appearing on page two of Government Exhibit No. 46 is
	that or the defendant Weigand. 78/
	    Government Exhibit No. 58 79/ is identical to the two-

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

	    78/   Appended to Government Exhibit 46 is a 5 February
	1976 report from Mitchell Hermann who signs it "Mike C.", to
	the defendant Weigand, stating that numerous documents withheld
	by the IRS pursuant to the FOIA were taken by the Information
	Bureau in Washington, D.C. He added that documents regarding
	Scientology were taken from many IRS offices including the
	Audit Division, Intelligence Division, Office of Inter-
	national Operations, Exempt Organization, Individual Income
	Tax Division, Office of the Chief Counsel, Disclosure Division,
	Special Services Staff, as well as other offices. Mr. Meisner
	identifies the signature "Mike C." as that of the defendant
	Hermann. Handwriting expert Miller concludes that it is
	"probable " that the defendant Hermann wrote that signature.
	The defendant Hermann's report is appended to the 11 February
	1976 letter from  the defendant Weigand to Ms. Kember on
	evidence that target 10 of GO 1361 had indeed been complied to.

	    79/ Government Exhibit No. 58 was seized by Special
	Agent Smith from Room 4 at the Cedars Complex.

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

				111

	page letter from the defendant Weigand to Ms. Kember dated 11
	February 1976 (Government Exhibit No. 116).  However, Government
	Exhibit No. 58 is the copy received and reviewed by Jane
	Kember. Indeed, she notes on the right-hand side of the
	first page "Dear Dick [Weigand], This is very well done
	indeed. Thank you for your excellent compliance. Much
	love, Jane." Following Ms. Kember's review of the document
	it was received by the defendants Willardson and Weigand who
	initiated it next to its routing session. 80/
	   Prior to his return to the District of Columbia in the
	third week of February 1976, Mr. Meisner met with the defendant
	Willardson in the defendant Weigand's office. During the meet-
	ing, Mr. Meisner showed the defendant Willardson how he and
	the defendant Wolfe had gained access to locked offices in
	the IRS building in Washington, D.C., by using a shaped
	metal device. During subsequent meetings in Los Angeles,

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

	    8O/  Mr. Meisner and Ms. Hirsch identify the handwritten
	notation signed "Jane" as having been written by Jane Kember.
	Mr. Meisner additionally identifies the initials of the 
	defendants Willardson and Weigand in the routing portion of
	the document. Moreover, handwriting expert Miller has con-
	eluded that it Is "highly probable" that the notation "GW 9
	Mar" in the routing section was written by the defendant
	Willardson.

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

					112

	California, Mr. Meisner's superiors instructed him that,
	upon his return to the District of Columbia, he was to obtain
	IRS documents from the offices of Joseph Tedesco, Jeanne
	Gessay and Muriel Moritz of the Exempt Organizations Division,
	Assistant Commissioner for Employee Plans and Exempt Organiza-
	tions Alvin Lurie, Special Assistants to Lurie Charles Rurpli
	and Howard Schoenfeld. Mr. Meisner was ordered to obtain all
	current information at the IRS regarding the Church of Scien-
	tology of California audit.  His superiors wanted to receive
	sufficient notice of any adverse IRS ruling prior to it's
	finalization so that they could intervene through their
	legal representatives and apply whatever necessary pressure
	to change the ruling.

			   
			   J.  Mr. Meisner Returns to
			       the District of Columbia
		 
	    Upon his return to the District of Columbia, Mr. Meisner
	directed the defendant Wolfe to enter the offices of Joseph
	Tedesco, Jeanne Gessay and Muriel Maritz and take all documents
	in their possession regarding the Church of Scientology of

- ---------------------------------------------------------------------------
					  
					  113

	  California audit. On or about March 4, 1976, the defendant
	  Gerald Bennett Wolfe entered the office of Joseph Tedesco
	  during the daytime and removed the door knob to one of the
	  doors leading to Tedesco's suite of offices. During the
	  nighttime, after working hours, the defendant Wolfe returned
	  to Mr. Tedesco's office and entered it through the door from
	  which the door knob had earlier been removed. Once inside,
	  the defendant Wolfe took all documents related to Scientology
	  from Mr. Tedesco's files, photocopied them using IRS photo-
	  copying equipment and supplies and returned the documents to 
	  the office of Mr. Tedesco. He stole the copies of those
	  documents and gave them to Mr. Meisner at a previously sched-
	  uled weekly meeting at a pool hall located in nearby Arlington,
	  Virginia. Mr. Meisner summarized the stolen documents in a
	  memorandum dated 4 March 1976, addressed to the defendant
	  Mitchell Hermann, under his alias Mike Cooper.  The document
	  entitled "Re: Joseph Tedesco - Current IRS Situation" stated
	  that "[t]he attached concerns Joseph Tedesco's area (Director
	  of the Exempt Organizations Division . . . IRS National

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

					       114

	office) and includes the totality of Scientology correspondence
	in his area." Appended to the memorandum were five pages of
	the stolen documents. (See Government Exhibit No. 59.) 81/
	Mr. Meisner then forwarded the memorandum and attached stolen
	documents to the defendant Hermann, who as Southeast U.S.
	Secretary, was now receiving all such correspondence. A
	copy of the memorandum and stolen documents was sent to the
	CSG, defendant Mary Sue Hubbard, as reflected in the routing
	portion or the document. 82/
	    The offices of Mr. Tedesco of the Exempt
	Organizations Division of the IRS, were located at the main IRS

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

	    81/ Government Exhibit No. 59 was seized by Special
	Agent Robert H. Wood from a cardboard box in the Information
	Bureau at the Cedars Complex.

	    82/   This is further illustrated by the transmittal
	memorandum from the defendant Hermann dated March 22, 1976,
	to Michael Taylor at World-Wide, which states that "[a]ttached
	are a set of docs concerning Tedesco's area and include the
	totality of Scientology correspondence in his area." Next to
	the entry "CC: CSG" in the routing portion of that trans-
	mittal memorandum is a handwritten notation identified by
	Meisner as written by the defendant Hermann. That notation
	indicated that that copy was already "(sent by DC)". Mr.
	Meisner also identifies the signature on that letter as that
	of the defendant Hermann.
	
- ---------------------------------------------------------------------------

					    115

	building at 1111 Constitution Avenue, N.W. in March 1976.
	Mr. Tedesco has reviewed the March 4, 1976 memorandum of Mr.
	Meisner and has located the documents referred to in that
	memorandum in his files. Tedesco states that these
	documents were in his care, custody and control on or about
	March 4, 1976. He further states that he did not give per-
	mission to the defendant Wolfe to enter his office and take
	the documents referred to in Government Exhibit No. 59 or
	make photocopies of those documents.
	On or about March 10, 1976, the defendant Gerald Bennett
	Wolfe entered the office of Jeanne Gessay of the IRS, without
	permission, and took documents related to the then-pending
	audit of the Church of Scientology of California. He stated
	to Mr. Meisner that after taking the documents he photocopied
	them on an IRS photocopying machine, using equipment and sup-
	plies which were the property of the United States of America.
	He then returned the original documents to Ms. Gessay's
	office and removed the copies of the documents out of the
	IRS main building and gave them to Mr. Meisner for the use

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

					116

	of Scientology. The defendant Wolfe did not have authority
	to enter the office of Ms. Gessay. In fact, he did not have
	authority to even enter the offices of Mr. Tedesco according
	to defendant Wolfe's supervisor, Leon Kennedy. Upon receipt
	of the stolen documents, Mr. Meisner summarized them in a
	memorandum dated 10 March 1976 entitled "Re: Current IRS
	Situation - Jeanne Gassay [sic] Material". Mr. Meisner
	appended to that memorandum the stolen documents and forwarded
	them to Southeast U.S. Secretary Hermann (a/k/a
	Mike Cooper), and sent a copy to the CSG, the defendant Mary Sue
	Hubbard. (Government Exhibit No. 60). 83/ By a transmittal
	memorandum dated March 24, 1976 the defendant Herman (Mike
	Cooper) , forwarded Mr. Meisner's memorandum and supporting
	documents to World-Wide stating that "[a]ttached is a set of
	handwritten notes in Jeanne Gessay's area". That memorandum
	stated, next to the entry "CC: CSG" in the routing portion,
	"(Sent by DC)". Mr. Meisner identifies the handwriting
	
- -------------------

	    83/ Government Exhibit No. 60 was seized by Special
	Agent Wood from the Information Bureau at the Cedars Complex.

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

				      117

	of that notation as well as the notation next to it as having
	been written by the defendant Hermann. Additionally, Mr.
	Meisner identifies the initials next to the "DG US" title as
	having been written by the defendant Heldt.
	     On March 10 1976, Ms. Gessay was the chief of Ruling
	Section I of the Exempt Organizations Division. Her section
	had been assigned to give its "technical" opinion regarding
	certain issues related to the audit of the Church of Scientology
	of California. Thus she states that in March 1976, she had
	in her files the documents summarized in the Meisner memorandum
	of 10 March 1976. Indeed, she has checked her files and the 
	same documents are still located therein. 84/ Ms. Gessay
	states that she did not give permission to the defendant
	Wolfe to enter her offices on March 10, 1976, take documents
	from her files, photocopy them and turn over the photocopies

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

	84/ She has turned over the originals to the Federal
	Bureau of Investigation.

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

			      118
	
	to the Guardian's office of the Church of Scientology. 85/
	      In recognition of Mr. Meisner's accomplishments with
	respect to GO 1361 target 10, the defendant Mitchell Hermann,
	in his capacity as Southeast U.S. Secretary, recommended to
	Guardian World-Wide Jane Kember that Mr. Meisner be issued an
	award. (Government Exhibit No. 68.) 86/  In his "CSW" to
	Kember, the defendant Hermann stated. that during the previous
	year and a half "10-12 feet of material was obtained from

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

	    85/ On or about March 22, 1976, the defendant Wolfe
	also entered the office of Assistant Commissioner for Employee
	Plans and Exempt Organizations Alvin Lurie which were located
	in the IRS building at 1111 Constitution Avenue, Northwest,
	in Washington, D.C. The defendant Wolfe told Mr. Meisner
	that he took documents related to the American Medical Asso-
	ciation and its tax exempt status from Mr. Lurie's office,
	photocopied them using IRS equipment and supplies, then
	returned the documents to their original location. The
	defendant Wolfe then stole the copies of the documents and
	gave then to Mr. Meisner. Mr. Meisner summarized them in a
	memorandum dated March 22, 1976, entitled "Re: House Ways and
	Means Subcommittee Meeting  on AMA" and sent it with the
	documents to the defendant Hermann (Mike Cooper,) with a copy
	to the "CSG", defendant Mary Sue Hubbard. (Government Exhibit
	No. 62).  The defendant Hermann forwarded the Meisner memo-
	randum and appended stolen documents  to the World-Wide Guardian's
	Office. Mr. Meisner identifies the initials next to "DG US"
	in the routing of Government Exhibit No. 62 as having been 
	written the defendant Heldt.  He also recognizes the hand-
	writing "(Sent by DC)" next to "CSG" as having been written by
	the defendant Hermann.

	86/ Government Exhibit No. 68 wan seized by Special
	Agent Smith from Room 11 in the Information Bureau at the
	Cedars Complex.

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

					   119

	1361 agency from a late number of different areas. The
	material provides the most extensive set of files on Scientology
	which I know of obtained by this means in the US." He pointed
	out that the collection of data "included various forms of
	"CDC" [covert data collection]." He explained that Mr. Meisner
	had "overall responsibility" for the theft and maintenance of
	the "steady stream of data out this area and to provide data
	needed for prediction on the future actions of this agency."
	The IRS was the agency covered by GO 1361 target 10. The
	defendant Hermann requested that  Mr. Meisner be given an
	award in the form of three advanced auditing courses, and
	appended a proposed award letter for the signature of L. Ron
	Hubbard. 87/
	    


		      K. The Entry into the IRS Identification
			  Room and the Making of Counterfeit
			  Identification Cards

	     In the early part of March 1976, the defendant Mitchell
	Hermann directed Mr. Meisner to obtain IRS identification
	
- -------------

	   87/  Mr. Meisner identifies the defendant Hermann's 
	signature on Government Exhibit No. 68. Handwriting expert
	James Miller concludes that it is "probable" that the defendant
	Hermann signed the "CSW" to Ms. Kember.

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

							       120
	
	cards for himself, which he could use to enter the IRS building,
	as well as in other operations pursuant to that directive,
	on or about March 15, 1976, the defendant Wolfe and Mr.
	Meisner entered the IRS building at 1111 Constitution Avenue,
	Northwest, using the defendant Wolfe's IRS identification
	card. They proceeded to the IRS identification room which
	was located on the first floor of that building, where Mr.
	Wolfe had been two weeks earlier in order to obtain a legitimate
	identification card for himself. Mr. Meisner and the defendant
	Wolfe forced the door open by using a metal sheet device, and
	then entered the darkened room using a small flashlight.
	Once inside, Mr. Meisner located a booklet giving instructions
	on the use of the photographing equipment. Mr. Wolfe took
	blank identification cards and typed in two fictitious names
	for himself, as well as two fictitious names for Mr. Meisner
	The defendant Wolfe typed the name "Thomas Blake" on one of
	his identification card blanks and the name "John M. Foster"
	on one of Mr. Meisner's identification card blanks. Mr.
	Meisner then placed the defendant Wolfe's false identification

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

				    121

	card blanks into the photographing Equipment and took photo-
	graphs of the defendant Wolfe. Then Wolfe placed the Meisner
	cards into the photographing machine and took photographs of
	Mr. Meisner. Mr. Meisner obtained the badge number which was
	placed on the identification card blanks from a book which
	was maintained by the IRS identification room and which listed
	all cards which were issued by them. Mr. Meisner selected
	those numbers from numbers which had previously been issued
	by the internal Revenue Service. On the "Foster," identifi-
	cation card of Mr. Meisner, was typed the date of issue
	"3-15-76", (See Government Exhibit No. 61), and on the "Blake"
	identification card of the defendant Wolfe "3-17-76" was typed
	as the date of issue. 88/ Mr. Meisner and the defendant

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

	88/ On the reverse of the identification cards the
	following entry appears:

			Warning

			Issued for identification of holder. Improper
			use, possession, alteration, reproduction or                                                         
			counterfeiting will make offender liable to
			penalties under Sections 499 and 701, Title 18,
			U.S. Code.

			      Property of U.S. Government.

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

				      122

	Wolfe then left the IRS building, taking with them the false 
	and fraudulent IRS cards which they had made. Neither Mr.
	Meisner nor the defendant Wolfe had permission or authority
	to make those identification cards or be in possession of
	them. 89/ Mr. Meisner took the defendant Wolfe's identifi-
	cation cards in order to place on them the required clear
	plastic covering because he was unable to use the machine in
	the identification room. After doing this, Mr. Meisner

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

	89/      Between early April and late June 1976, four other
	Guardian's Office officials and one Scientology covert agent
	entered the IRS identification room and made counterfeit IRS
	identification cards for themselves. In April, the defendant
	Wolfe and Mr. Meisner took into the main IRS building
	Information Bureau investigators Patty Pease and Jay Armstrong
	and made for them counterfeit IRS identification error. The    
	defendant Wolfe, on three other occasions, entered the main IRS
	building with the defendant Hermann, and Messrs. Joseph Alesi
	and Michael Baum, where he made similar false IRS credentials
	for them. Mr. Meisner saw the counterfeit credentials made
	for those five individuals. All the identification cards
	were in false names. In mid-May, Mr. Meisner took the defend-
	ant Weigand on a tour of the main IRS building in Washington,
	D.C. , and showed him the offices which had been burglarized 
	and from which stolen documents had been taken. They were
	unsuccessful, however, in gaining entry into the identification
	room and were, therefore, unable to make a false identification
	card for the defendant Weigand. Mr. Meisner and the defendant
	Weigand entered the building using Mr. Meisner's counterfeit
	IRS credentials in the name of "Foster".

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

					    123

	returned them to the defendant Wolfe. John Probst, Chief of
	the Space and Protective Management Division in March 1976,
	states that the identification room was always kept locked
	and that at no time were Mr. Meisner or the defendant Wolfe
	given permission to either enter that room while locked or
	to make any identification cards. 90/


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

	     On March  2, 1976, the defendant Cindy Raymond wrote a
	"CSW" to the defendant Mary Sue Hubbard requesting her approval
	for a proposed new Guardian Program Order to be issued pur-
	suant to the overall Snow White Program. (Government Exhibit

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

	90/   During a confrontation in the United States Court-
	house for the District of Columbia, on June 11, 1976, FBI
	Special Agent Christine Hansen seized the "John M. Foster"
	identification card from Mr. Meisner.  Ms. Helen R. Pesta,
	Chief of the IRS Digest Unit, states that she holds a lawful
	IRS identification card bearing badge number 800-00413, the
	number which appears on the counterfeit identification card
	in the name of "John M. Foster". Mr. William T. Lyons,
	Cincinnati, Ohio, IRS Regional Counsel, states that he holds
	a lawful IRS identification card bearing badge number 800-
	00487, the number of which appears on the counterfeit identi-
	fication card in the name of "Thomas Blake".

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

					   124

	No. 66). 91/ The defendant Raymond suggested a Bureau I
	program "to obtain non-FOI 92/ data to parallel and back-up
	the Snow White Pgm." She explained that Bureau I "over the
	past year, has been obtaining data that is not FOI" pursuant
	to, among others, GO 1361. This illegally obtained data had
	been valuable to understand 'the behind the scenes' activity
	or the enemy." The defendant Raymond attached to her letter
	the actual proposed Guardian Program Order which she had
	entitled "Snow White Subprogram Hunter, Hunter X". (Government
	Exhibit No. 65). 93/ Its targets included the obtaining of
	all desired files in government agencies by "job penetration"
	and other types of infiltration. The "CSW" was processed
	through, and approved by, all the high officials of the Informa-
		  
- ----------------

	91/ Government Exhibit No. 66 was seized by Special
	Agent Gilberto Valencia from Room 4 in the Information
	Bureau at the Cedars Complex.

	92/ "Non-FOI", used in this context, refers to documents
	obtained by covert means or Scientology internal memoranda
	discussing such illegally obtained documents.

	93/ Government Exhibit No. 65 was seized by Special 
	Agent Valencia from Room 4 in the Information Bureau at the
	Cedars Complex.

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

						  125

	tion Bureau, both in the United States and at World-Wide
	headquarters in England, who initialed it. In the case of a
	"CSW" whenever an official initialed the document it indicated
	his approval or the actions proposed by the "CSW".
	     Mr. Meisner recognizes the handwriting of the following
	persons next to their titles: the defendant Willardson ("GW
	2 Mar OK"), the defendant Weigand ("D OK 3/3"), the defendant
	Heldt (his initial), and the Deputy Guardian for Information
	World-Wide Mo Budlong ("MB 17/3/76"). Handwriting expert
	James Miller positively identifies the handwritten notation
	"Dear Cindy--Approved--this aligns with what Bur I. has been 
	doing beautifully. Love, Mary Sue", as having been written
	by the defendant Mary Sue Hubbard. Mr. Meisner also identifies
	the defendant Hubbard as the writer of both that notation
	and the signature "MS Hubbard Mar. 27, 76", and Ms. Kember as
	the writer of the signature  "JKember" next to the word
	"approved" on page two. Mr. Miller also positively identifies
	the signature of the defendant Hubbard next to the word
	"approved" as being in the defendant Hubbard's handwriting,

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

				       126

	and the signature or the defendant Raymond at the end of
	page two as in her handwriting.
	     On the same day that the defendant Hubbard approved the
	"CSW" of the defendant Raymond, Guardian Program Order 302 was
	issued in its final form by Guardian World-Wide Jane Kember.
	(Government Exhibit No. 67). 94/  In its final form GPO 302
	directed that all those assigned to execute it


		     [U]se all possible lines of approach to
		     obtain the files on Scientology, LRH,
		     Dianetics (and other Scn names) that
		     cannot be obtained on FOI lines] ie.
		     job penetration; janitor penetration;
		     suitable guises utilizing covers, etc. . . .

	   (Vital target I and major target).
	    
	    The order also directed that covert agents ("FSMs"), be
	recruited for the project and that nothing be done in such a
	
- -----------------

	94/ Government Exhibit No. 67 was seized by Special
	Agent Raymond Mislock from a file cabinet in the office of
	the defendant Raymond at the Cedars Complex.

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

				  127

	manner as "to reflect back on the Church." 95/ The defendant
	Raymond designated Mr. Meisner to carry out vital targets I
	through 4 as part of his duties in the District of Columbia. /96


		  M.       Entries into the Suite Of Offices
			   of the Deputy Attorney General of
			   the United States

	     In early April 1976, the defendant Cindy Raymond ordered
	 Mr. Meisner to obtain internal Department of Justice files
	 regarding proposed amendments to the FOIA which the Department

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

	95/ Mr. Meisner and Ms. Hirsch state that GPgmO 302 was
	issued in accordance with established Guardian's Office pro-
	cedure. The initials "LM" next to the name June Kember are
	those of her communicator (secretary). Government Exhibit
	No. 67 was seized by Special Agent Raymond A. Mislock from a
	file cabinet in the office or the defendant Cindy Raymond in
	the Information Bureau at the Cedars Complex.

	96/ In a "compliance report" to GPgmO 302, target 5,
	dated 31 July 1976, the defendant Raymond sent the defendant
	Weigand a list of priorities for the "penetration" of National
	Agencies". (Government Exhibit No.  109). She appended to
	her "CSW" a list of 136 government agencies which were to be 
	infiltrated.  These included:  the Administrative Office of
	the U.S. Courts, the CIA, The Executive Office of the U.S.
	Attorneys, the FBI, and many other agencies. Also included
	were a number of U.S. Embassies and consulates abroad.
	    Government Exhibit No. 109 was seized by Special Agent
	Gilberto Valencia from Room 4 in the Information Bureau at
	the Cedars Complex.

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

					   128
	
	of Justice was about to send to Congress. Meisner learned 
	through his own research, that such proposals would normally
	be made by the Deputy Attorney General of the United States
	and his staff. Therefore, in early April 1976, the defendant
	Wolfe and Mr. Meisner entered the United States Department
	of Justice at 9th and Pennsylvania Avenue, N.W. , in Washington,
	D.C., to locate the documents wanted by the defendant Raymond.
	Mr. Meisner used his false IRS identification card in the
	name of "John M. Foster" and the defendant Wolfe used his
	own IRS identification card.  They both then burglarized 
	the fourth floor suite of offices of Deputy Attorney General
	Harold R. Tyler Jr., where by rummaging throuh the files,
	they located a series of memoranda which the Department of
	Justice was about to send to Congress outlining it's position
	on proposed amendments to the FOIA. The two men forced
	open the door to these offices by using a metal sheet to
	slip the lock latch. The defendant Wolfe and Mr. Meisner
	photocopied these documents using Justice Department photo-
	copying equipment and supplies, returning the documents to
								  
- ----------------------------------------------------------

				       129

	the files, and stole the copies. Mr. Meisner, sent these
	stolen documents with memoranda summarizing them to his
	superiors in Los Angeles as well as to the "CSG", defendant
	Mary Sue Hubbard. In the process of looking for the FOIA
	memoranda within the Deputy Attorney General's suite, Mr.
	Meisner and the defendant Wolfe had seen but did not steal
	the so-called "DeFeo Report" -- an investigation of the Drug
	Enforcement Administration conducted by the Department of
	Justice.
	    Coincidentally, a few days after the Justice Department
	entry, the defendant Cindy Raymond wrote Mr. Meisner that
	she had learned that the Justice Department had conducted an
	investigation of the Drug Enforcement Administration, which
	she directed him to get. The defendant Raymond explained
	that the Church of Scientology had just lost an FOIA case which
	it had initiated against DEA, and that it intended to appeal
	the lower court's decision. In that context, the Guardian's
	Office wanted to obtain the DEA investigation report and
	covertly leak the report to the press to create an adverse

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

				       130
	
	campaign against DEA which might aid Scientology in its FOIA
	appeal.  Therefore, on or about April 9, 1976, the defendant
	Wolfe and Mr. Meisner once again entered the Department of
	Justice building located at 9th and Pennsylvania Avenue,
	N.W., with Mr. Meisner using his counterfeit IRS identification
	card.  They forced the door to the suite of offices of the
	Deputy Attorney General in the same manner that they had
	previously done, and eventually entered the offices of
	Associate Deputy Attorney General Togo D. West, Jr. Mr.
	Meisner, recalling where he had previously seen the "DeFeo
	Report", took it from a file cabinet Mr. West's secretary's
	office. The report was in two parts with an additional
	file of supporting raw data. The defendant Wolfe and Mr. 
	Meisner photocopied all three parts using equipment and
	supplies of the United States Government located within the
	Department of Justice, returned the documents to Mr. West's
	office, and stole the copies. Mr. Meisner then summarized
	each file in a series of three memoranda, dated 9 April
	1976, which he forwarded to "Br I Dir Nat'l", the defendant

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

				   131
	
	Raymond, via "SE US Sec", the defendant Hermann/Cooper with
	a copy to the "CSG", defendant Hubbard (Government Exhibits
	Nos. 69, 70 and 71). 91/ Following his established practice,
	Mr. Meisner, numbered each page of the stolen documents in
	the lower right-hand corner of the document.
	    Mr. Togo D. West, Jr. was employed as Associate Deputy
	Attorney General of the United States until April 23, 1976.
	In that capacity, he received the DeFeo Report in early 1976.
	He recalls that there was only one copy of that report and
	supporting raw data in the Office of the Deputy Attorney
	General.  West did not give permission to Mr. Meisner or
	the defendant Wolfe to take copies of the DeFeo Report.
	Indeed its distribution was severely limited.
	    Two weeks following the entry into the Department of
	Justice's Office of the Deputy Attorney General, Bruce
	Raymond, the National Operations Officer of the Information
	Bureau in the United States, directed Mr. Meisner to release

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

	97/   Government Exhibit Nos. 69, 70 and 71 were seized 
	by Special Agent Michael T. Repucci from Room 14 in the
	Information Bureau of the Cedars Complex.

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

					       132

	the stolen DeFeo Report to the _Village_Voice_ Newspaper in
	Now York under the cover of a disaffected Department of
	Justice employee. To that end, Mr. Meisner went to New York,
	where he telephoned a reporter for the Village Voice. Mr.
	Meisner, as ordered, identified himself as a disaffected
	Department of Justice employee who was offering the reporter
	a confidential report on an investigation of DEA conducted
	by the Justice Department. Mr. Meisner mailed to the reporter
	half or the DeFeo Report but never completed the operation
	because of the Courthouse incident which was to occur on
	June 11, 1976.  See page 172, _infra_ 98/

- ---------

	98/ In a letter dated 28 June 1976, Deputy Guardian for
	Information World-Wide Mo Budlong, requested that the defendant
	Weigand obtain a copy or the DeFeo Report which he stated
	"was classified by Executive Order and is not available on
	overt lines."  In a response dated 6 July 1976 the defendant
	Weigand informed Mr. Budlong that the DeFeo report had indeed
	already been stolen by Guardian's Office operatives and that
	he was appending excerpted copied of the report. The defendant
	Weigand also explained that as part of "Op [Operation] Chaos        
	Leak" a portion of the report had been leaked to the press
	but that the operation had to be dropped because of the current
	complications in the United States Courthouse in the District
	of Columbia. (Government Exhibit No. 72)
	     Government Exhibit No. 72 was seized by Special Agent
	Michael T. Repucci in Room 14 of the Information Bureau at
	the Cedars Complex.
		  (footnote continued on next page.)

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

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

	     During the second week of April 1976, the defendant
	Hermann sent a written order to Mr. Meisner directing him
	to obtain all files on L. Ron Hubbard and the defendant Mary
	Sue Hubbard from the Office of International Operations of
	the IRS.  Appended to the defendant Hermann's order was a
	report from "CPA US" Martin Greenberg of the Finance Bureau
	stating that he had received notice from the IRS that the
	income tax return of the Hubbards was being audited. Mr.                       a ti
	Greenberg also indicated that Mr. Thomas Crate of OIO was
	the tax auditor assigned to the Hubbard case. Inasmuch as
	all materials which dealt with L. Ron Hubbard and Mary Sue

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

		 (footnote continued from preceding page.)

	   Mr. Meisner identifies the signature "MB" at the end of
	the 28 June 1976 letter as having been written by Mo Budlong.
	He also states that the initials "GW" and the handwriting
	immediately preceding it were made by the defendant Willardson.
	Handwriting expert James Miller concludes that it is "probable"
	that the notation "Sec Off Nat GW" is in the handwriting of 
	the defendant Willardson.

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

				      134

	Hubbard personally, received top priority within the Guardian's
	office, Mr. Meisner soon located the office of Mr. Crate by
	using a recent IRS directory obtained by the defendant Wolfe.
	On or about April 14, 1976, at approximately 7 00 p.m., the
	defendant Wolfe and Mr. Meisner, proffering his false "Foster"
	IRS identification card, entered the building housing the
	Office of International Operations at 1325 T. Street, N.W., in
	Washington, D.C. They proceeded to the tenth floor where,
	according to the IRS directory, Mr. Crate's office was located
	but were unable to enter it because the door was locked. A
	cleaning lady who noticed the defendant Wolfe and Mr. Meisner
	acting in a suspicious manner notified the security guard
	who confronted Meisner and Wolfe. The security guard was
	satisfied by Mr. Meisner's false IRS credentials and the
	defendant Wolfe's genuine IRS identification card. The
	cleaning lady thereupon opened the door to the office of
	Mr. Crate. Since the room contained so man desks, it took
	nearly thirty minutes to find Mr. Crate's desk. Once they
	did, Mr. Meisner took all documents relating to the Hubbard

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

					 135

	audit.  Meisner then discovered that Mr. Crate's superior
	was Howard Rosen and proceeded to check his desk as well.
	Inside one of the drawers he found a key to Rosen's file
	cabinets. In them Mr. Meisner found several thick files on
	the Hubbards and Scientology. They took all the files;
	however, they could not find a photocopying machine within
	that building. Mr. Meisner decided to take the files to
	the main IRS building in order to photocopy them. Thus, the
	defendant Wolfe and Mr. Meisner went into the IRS building.
	where Mr. Meisner again used his false IRS identification
	card to gain entry. Inside the main IRS building, Mr. Meisner        
	and the defendant Wolfe photocopied all OIO documents using
	United States government property and supplies. They then
	returned the documents to OIO, once again, signing the false
	name of "John M. Foster."  After replacing the files in Mr.
	Rosen's file cabinet and Mr. Crate's desk, they stole copies
	of the documents for the use of Scientology. The operation
	was completed around 11 p.m.
	    On or about May 15, 1976, the defendant Wolfe and Mr.
	Meisner again entered the Rosen-Crate area in order to obtain

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

					  136

	all recent documents regarding the Hubbard's audit. Such docu-
	ments were found only in the desk of Thomas Crate, although
	Rosen's files were also rechecked. This time Mr. Meisner 
	and the defendant Wolfe entered the office of Mr. Crate
	with the assistance of the cleaning lady who recognized
	Mr. Meisner.  The two men made a third and final entry at
	the end of July, but no more recent documents on the audit
	were found. That time as well, the defendant Wolfe and Mr.
	Meisner entered the building using Mr. Meisner's counterfeit
	IRS identification card, and regained entry to the office 
	with the assistance of a cleaning lady. On neither occasion,
	did Mr. Meisner or the defendant Wolfe have permission to
	enter the OIO building or the office of Messrs. Crate or,
	Rosen, take documents from their files out of the building,
	photocopy the files using United States Government property
	and permanently deprive the IRS and OIO of the copies of the
	documents. Following each of the first two entries, Mr.
	Meisner summarized the stolen documents in memoranda addressed
	to the defendant Mitchell Hermann/Mike Cooper, with a copy of

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

					  137

	the memorandum and stolen documents sent to the "CSG",
	defendant Mary Sue Hubbard. The documents obtained during
	the first entry were summarized in four memoranda - one of 
	which was dated 15 April 1976 (Government Exhibit No. 73),
	and three dated 19 April 1976 (Government Exhibits Nos.
	74-76). 99/ Government Exhibit No. 73 was entitled "'Re:
	OIO LRH File-Current Data".  Government Exhibit No. 74 covered
	"OIO File On LRH-January, 1974 - April, 1974" Government
	Exhibit No. 75 covered the period April 1974 to March 1976.
	Government Exhibit No. 76 dealt with those documents prior
	to December, 1973. The documents obtained during the second
	entry were summarized in a 17 May 1976 memorandum by Mr.
	Meisner entitled "Re: Update On IRS OIO Activity On
	LRH/MSH". 100/ (Government Exhibit No.77.) 101/

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

	99/ Government Exhibit Nos. 73-76 were seized by
	Special Agent James R. Kramarsic from the office of the
	defendant Heldt at the Fifield Manor.

	100/ Mr. Meisner recognizes the handwriting of the
	following defendants on Government Exhibits Nos. 73 to 76: 
	the initials of the defendant Heldt and Willardson on Govern-
	ment Exhibit No. 73) the initials of the defendant Heldt on
	Government Exhibit Nos. 74-76.

	101/ Government Exhibit No. 77 was also seized by
	Special Agent Kramarsic from the defendant Heldt's office.

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

				      138

	     In April and May 1976, Mr. Howard Rosen was a group
	manager at the Office of International Operations of the IRS.
	He had under his care, custody and control all the files
	relating to the audit of L. Ron Hubbard and the defendant
	Mary Sue Hubbard. Mr. Rosen himself supervised the Hubbard's
	audit from July 1973 to October 1973 when the case was
	assigned to Mr. Jeffrey Tobin also of that office. In January
	1976, Mr. Rosen returned to OIO and the case was reassigned
	to him. The Hubbard audit case for the years 1971 and 1972
	was not closed until June 1976 when Mr. Hubbard paid an
	adjustment tax. The individual within Mr. Rosen's group who
	worked on the audit was Thomas R. Crate. In April and May
	1976, Mr. Rosen kept all his files in a file cabinet located
	near his desk. The file cabinet was kept locked at all
	times, and he had the only key to those cabinets. He kept
	that key in his desk drawer. Mr. Rosen reviewed the Meisner
	memoranda marked Government Exhibits Nos. 73-77, and concludes
	that all documents summarized therein were then, and still
	are in his care, custody and control.

- ----------------------------------------------------------
								
					139
					
		     O. Burglaries and Thefts of Documents
			From the Department of Justice in
			Washington, D.C.

			1.  Office of Paul Figley

	    The defendant Sharon Thomas began her employment at the
	Department of Justice in Washington, D.C., on February 29, 1976.
	She was assigned as a secretary to two trial attorneys in the
	Information and Privacy Unit or the Civil Division.  Soon after
	her employment, she stole documents from that Unit which were
	the basis for a number of pending Scientology-initiated FOIA
	lawsuits. She took all those documents after working hours
	or on weekends. The defendant Thomas met on a weekly basis,
	on either a Monday or a Tuesday, with Mr. Meisner at one
	of several locations in nearby Arlington, Virginia. The
	locations included the Lum's and Three Chefs Restaurants as
	well as at her own apartment. Mr. Meisner instructed her to
	obtain all files on Scientology from the office of Department
	of Justice attorney Paul Figley who was supervising the
	Freedom of Information Act cases within the Department. After

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

					   140

	collecting all the documents within Mr. Figley's office,
	she was to monitor his office and take any new documents
	placed in his files. The defendant Thomas was also directed
	to be attentive to Mr. Figley in the hopes that she might
	become his secretary and have immediate access to all his
	files. 102/ She was also instructed to overhear all the
	phone and office conversations and make notes of any matter
	relevant to Scientology.
	    On or about April 26, 1976, the defendant Thomas entered,
	without permission, the office of Mr. Figley and took from his
	files numerous documents which were the source of a pending
	FOIA lawsuit brought by Scientology against the Energy
	Research and Development Administration (ERDA), which had
	been assigned to Mr. Figley. She then photocopied the docu-
	ments on a photocopying machine within the Justice Department
	main building using United States Government supplies and
	equipment after replacing the documents in Mr. Figley's
	office, she stole the photocopies and gave them to Mr. Meisner

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

	102/ Indeed, in June 1976, the defendant Thomas succeeded
	in becoming the secretary of Mr. Paul Figley.

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

					       141

	at their next regularly scheduled meeting. On 26 April 1976,
	Mr. Meisner sent a memorandum to the defendant Hermann/Cooper
	which summarized the documents, and to which were appended
	the stolen documents themselves. He also sent a copy to the
	"CSG". defendant, Mary Sue Hubbard (Government Exhibit No.
	78) 103/ One of the documents which Mr. Meisner appended
	to his memorandum to the defendant Hermann was an April 6,
	1976, letter from ERDA Assistant General Counsel for Litigation
	and Legislation Guy H. Cunningham, III, to Paul Figley
	regarding the United States' position in the pending Scientology
	initiated FOIA civil action. (Government Exhibit No. 79). 104/
	That document is summarized in Meisner's memorandum (Government
	Exhibit No. 78, page 1, paragraphs 1-4). At the lower right-
	
- --------------                 
						
	103/ Government Exhibit No. 78 was seized by Special Agent
	Harold Brunson from a file cabinet immediately outside the
	main office of the defendant Raymond at the Cedars Complex.
	It was inventoried and initialed by Special Agent Michael
	Ray Napier.

	104/ Government Exhibit No. 79 was seized by Special
	Agent Brunson from a file cabinet outside the main office of
	the defendant Raymond at the Cedars Complex. It was inventor-
	ied and initialed by Special Agent Napier.

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

				      142

	hand corner of Government Exhibit No. 79 are the Meisner
	handwritten numerals "1" and "2"  which he placed thereon
	upon receipt of the documents from Ms. Thomas. All underlinings
	and numerals placed in the left-hand margin of the documents were
	made by Mr. Meisner.

			2. Interpol Liaison Office at
			    the Department of Justice

	    The defendants Raymond and Hermann along with Tom Reitze,
	the Information Bureau Snow White Program In-Charge, repeatedly
	reminded Mr. Meisner of the high priority of the orders re-
	garding the collection of data and documents from Interpol.
	Nine months earlier, Guardian World-Wide Jane Kember had issued
	Guardian Program Order 9 (GPgmO 9) which specifically addressed
	itself to Interpol. GpgmO 99, entitled "Snow White Confidential"
	ordered that the Guardian's Office must:

		    Through infiltrators or clandestine agents
	       obtain all details of any reports of requests for
	       data on LRH, Scientology, OTC [Operations and
	       Transport Company], 105/ Apollo, etc. from US
	       
- ---------------

	105/ "OTC" or Operations and Transport Company was
	a Panamanian Corporation set up by L. Ron Hubbard which
	owned the ship Apollo on which L. Ron Hubbard lived and
	which was used as the flagship of the Sea organization of
	Scientology.

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

					   143
	
		police and/or US NCB [National Central Bureau
		of Interpol) to IP [Interpol] International or
		any other NCB or from IP International or any
		other NCB to US Police and/or US NCB.

	    (Target 10).

	    GPgmO 9, which was issued on June 27, 1975, (Government
	Exhibit No. 63) was written by Deputy Guardian for Information
	World-Wide Mo Budlong. Government Exhibit No. 63 shows that
	target 10 which had been assigned to Branch I Director,
	the defendant Willardson, and "SW I/C" (Snow White in Charge)
	Reitze was completed on 3 June 1976 with the burglaries of
	Assistant United States Attorney Nathan Dodell's office. 106/
	     Nancy Douglass, Scientology's covert operative at the
	Drug Enforcement Administration, informed Mr. Meisner that
	an Interpol Liaison Office had been newly created at the
	Department of Justice. That Office was to be the first step
	in the eventual transfer or the Interpol National Central
	Bureau for the United States from the Department of the

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

	106/ Mr. Meisner and Ms. Hirsch state that GPgmO 9 was
	issued in accordance with established Guardian Office procedure
	for the issuance of Guardian Program Orders. Ms. Hirsch
	states that the initials "LR" to the left of the name Jane
	Kember are those of Ms. Kember's communicator (secretary)
	Lexie Ramirez.

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

					       144
	
	Treasury to the Department of Justice. Ms. Douglass had
	attempted unsuccessfully to obtain employment at the Interpol
	Liaison Office.  Thus, it became necessary for Mr. Meisner to
	obtain the documents from that office through other means.
	Beginning in April 1976, and continuing until late May 1976,
	Mr. Meisner and other Scientology operatives made a number of
	entries into the Interpol Liaison Office to obtain the
	documents regarding Scientology. The first entry was made
	in early April by the defendant Wolfe and Mr. Meisner. They
	entered the main Justice Department Building located at 9th
	and Pennsylvania Avenue, Northwest, in Washington, D.C., shortly
	before 5:30 p.m., using Mr. Meisner's false IRS identification
	card. They waited until all personnel had left the Interpol
	Liaison Office on the sixth floor, then entered, without
	permission, that office. They found a number of locked
	file cabinets, as well as two locked safes. Then, thirty minutes
	later, after having searched in vain throughout the entire
	suite of offices for keys to the file cabinets,
	the defendant Wolfe and Mr. Meisner left the building. One
	week later, they made a second entry into the Justice Depart-

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

					  145

	ment, once again using the Meisner fake identification to
	gain entry.  Mr. Meisner brought a variety of lock-picking
	tools to open the file cabinets within the Interpol Liaison
	office. Once again he was unsuccessful and they left the
	building. On a third occasion, in mid-April, the defendant
	Sharon Thomas entered the Justice Department Building with
	Mr. Meisner; this time they looked through the office for a
	combination to the safes and eventually found it in a file
	card box on a secretary's desk. After opening one of the
	two safes, they found the keys to the file cabinets and
	gained access to the documents. They took some three to
	four inches of documents out of the sixth floor Interpol
	offices to the fourth floor photocopying machine where they
	made copies or all the documents with United States Government
	equipment and supplies. Some two hours later, the defendant
	Thomas and Mr. Meisner left that building with stolen
	copies of the documents.
	     Mr. Meisner made one more entry into the Interpol Liaison
	Office with the defendant Sharon Thomas and Scientology covert
	
	- ----------------------------------------------------------

					 146
	
	operative Michael Baun, through the use of Mr. Meisner's
	counterfeit IRS identification card. Because the Guardian's
	office officials wanted _all_ Interpol documents whether re-
	lated to Scientology or not, Mr. Meisner, not only took some
	documents on this occasion but also directed the defendant
	Thomas and Mr. Baum to make weekly entries into that office
	where they were to methodically examine each file cabinet for
	any Interpol documents. The documents taken on this occasion
	were photocopied using the fourth floor Justice Department
	photocopying equipment as well as United States Government 
	supplies.  The documents were returned to their original loca-
	tion and the copies wore stolen. Mr. Meisner then summarized
	the stolen documents in two separate memoranda dated 28 April
	1976 which he sent to the defendant Raymond, who, as Branch I
	Director National, had supervision over Interpol matters.
	(Government Exhibit No. 80). 107/ The memoranda with attached
	stolen documents were forwarded via Southeast U.S. Secretary,
	the defendant Hermann/Cooper. The stolen documents related to

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

	107/ Government Exhibit No. 80 was seized by Special Agent
	Glade B. Johnson from a file cabinet within the Information
	Bureau at Cedars Complex.

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

					   147

	to a symposium for the heads of police colleges which Interpol
	was to hold in September 1976, Interpol's history, and
	terrorism.  Upon receipt of the Meisner memoranda, the
	defendant Raymond forwarded them and the documents to World-
	Wide. 108/
		Over the next month the defendant Thomas and Mr. Baum
	burglarized the Interpol Liaison Office at the Justice Depart-
	ment on at least three occasions. Those raids netted some
	three feet of copies of Interpol documents. On each occasion
	they used the photocopying equipment and supplies located on
	the fourth floor of the Department of Justice main building and
	stole the copies. The documents were given to Mr. Meisner
	who in each instance excerpted the documents in memoranda
	identical to Government Exhibit No. 80. (See Government Exhibits

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

	108/ Mr. Meisner identifies the initials next to the
	routing portion of the document as those of the defendant
	Raymond.

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

					     148
								 
	Nos. 85 and 86.) 109/ Government Exhibit No. 81 is a
	3 May 1976 Meisner memorandum summarizing stolen Justice
	Department correspondence on Interpol for the period October
	1957 to May 1969. Appended to that memorandum, among others,
	were Government Exhibits Nos. 82-84, which have Mr. Meisner's
	handwritten numerals in their lower-right hand corner as
	well as other Meisner underlinings and notations. 110/

- -----------------------
			 
	109/ Government Exhibits Nos. 81 and 85 were seized
	by Special Agent Glade R. Johnson from a file cabinet located
	within the Information Bureau at the Cedars Complex. Govern-
	ment Exhibit No. 56 was seized by Special Agent Michael T.
	Repucci from room 14 also within the Information Bureau at
	the Cedars Complex.

	l10/ Government Exhibit No. 82 is summarized in Government
	Exhibit No. 81 at p. one, paragraphs two to six. Government
	Exhibits Nos. 83 and 84 are identical stolen letters from the
	Assistant Secretary of the Treasury David Kendall to Deputy
	Attorney General William P. Roger.  They are excerpted in
	Government Exhibit No. 81 at page one, paragraph seven. After
	they were received by the Guardian's office in Los Angeles,
	those letters were cross-filed into two separate individual's
	folders. Government Exhibit No. 83 was placed in a folder
	on Deputy Attorney General William P. Rogers and Government
	Exhibit No. 84 was placed in a folder on David Kendall.
	(See left-hand margin of the exhibits.) All three exhibits
	were seized by Special Agent William G. Ryan, Jr., from Room
	13 of the Information Bureau at the Cedars Complex. Mr. 
	Meisner identifies the initials of Cindy Raymond next to
	her title on the upper left-hand portion of his 3 May 1976
	memorandum.

- ----------------------------------------------------------
					
						149

	Government Exhibit No. 85 contains two 17 May 1976 memoranda
	and one 12 May 1976 memorandum by Mr. Meisner to the
	defendant Raymond summarizing other Justice Department Interpol
	documents. Similarly, Government Exhibit No. 86 is a 28 May
	1976 Meisner memorandum to the defendant Raymond summarizing
	nine pages or appended Interpol Liaison Office documents
	regarding a General Accounting Office (GAO) audit. Each of
	those memoranda were forwarded by the defendant Raymond to
	World-Wide. 111/ Neither the defendant Thomas nor Mr. Meisner
	had permission to enter the Interpol Liaison Office, take
	the documents out of that office, or steal the photocopies for
	the use of Scientology.

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

	111/   Mr. Meisner identifies the initials and/or hand-
	writing of the defendant Raymond on each of his memorandum
	in the routing section next to the title. Mr. Meisner also
	recognizes Ms. Raymond's handwritten notation on the first
	page of Government Exhibit No. 86 next to the Snow White
	"highest priority" stamp. Each of the defendants appended to 
	Government Exhibit No. 86 have Mr. Meisner's excerpts of,
	underlinings, and numerals.

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

					   150
				
		       3. Offices of Special Assistant to
			  Assistant Attorney General for
			  Administration John F. Shaw
			    
	During the year 1975, a Senate Committee had conducted
	hearings concerning Interpol. In 1976, the Guardian's office
	of the Church of Scientology was strongly advocating the re-
	opening of such hearings to dispute the United States' con-
	tinued participation in that organization. In this regard,
	Hugh Wilhere, an official of the Public Relations Bureau
	of the District of Columbia's Guardian's Office, informed
	Mr. Meisner that he had met with Special Assistant to Assistant
	Attorney General for Administration, John F. Shaw, whom he had
	learned was supervising the transfer of Interpol from the
	Treasury Department to the Department of Justice. Based on
	this information, and pursuant to the order contained in
	"GpgmO 9", Mr. Meisner began monitoring Mr. Shaw's office
	for Interpol related documents. On three occasions, on or
	about April 29, May 8 and May 17, 1976, the defendant Sharon
	Thomas and Mr. Meisner entered the Department of Justice
	Building after 5:30 p.m using the defendant Thomas' Department

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

						151
	 
	of Justice identification card, in order to steal copies of
	documents from Mr. Shaw's office. On each occasion, the
	defendant Thomas met Mr. Meisner outside the Justice Depart-
	ment building.
	      On or about, April 29, 1976, following their entry into
	the main Department of Justice building, located at 9th and
	Pennsylvania Avenue, N.W., in Washington, D.C., they proceeded
	to the first floor office of Mr. Shaw. Mr. Meisner forced
	open the locked door to the Shaw suite of offices by inserting
	a plastic sheet the size of a credit card to slip the latch.
	Once inside the suite, they went through a secretary's office
	which led into Mr. Shaw's personal office. On his desk
	was a five to six inch high stack of documents, all related to
	Interpol. Mr. Meisner placed these documents in his briefcase
	and, together with the defendant Thomas, went to the fourth
	floor where they both photocopied the documents using
	Department of Justice photocopying equipment and supplies
	located nearby. Thereafter, they returned the documents to
	Mr. Shaw's desk. The copies of the documents were then taken,

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

					   152

	without permission, in Mr. Meisner's briefcase to the
	Guardian's Office of the Church of Scientology at 2125 S
	Street N.W., Washington, D.C. Mr. Meisner excerpted one
	hundred and twenty four pages of some eight hundred pages
	of stolen documents in a memorandum to the defendant Raymond,
	dated 30 April 1976, entitled "Re: Current Feud Between
	Justice and Treasury - Justice Takeover of Interpol NCB"
	(Government Exhibit No. 87).  The documents, which Mr. Meisner
	appended to his memorandum, each contain both his handwritten
	numerals in their lower right-hand corner as well as his
	underlining and notations in the left-hand margin. (Govern-
	ment Exhibits Nos. 88-92). 112/ Upon receipt of that
	memorandum, the defendant Raymond forwarded it, and the documents
	appended thereto to World-Wide stating that "the data is
	really fascinating." 113/

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

	112/ Government Exhibits No. 87 was seized by Special Agent
	Blade R. Johnson from a file cabinet in the Information Bureau
	at the Cedars Complex. Government Exhibits Nos. 88-92 were
	seized by Special Agent William A. Cohendet from Room 14 in
	the Information Bureau at the Cedars Complex. Mr. Meisner
	identifies the initials and date "4 May 76" in the routing of
	his memorandum as those of the defendant Raymond.

	113/  The defendant Raymond's 4 May 1976 memorandum to
	World-Wide is entitled "IP Data Non-SCN non-FOI Confidential"
		 (footnote continued on next page.)
	
- ---------------------------------------------------------------------                                                                                                                 

					153

	     On or about May 17, 1976, 114/ the defendant Sharon
	Thomas and Mr. Meisner entered for the third time, after
	working hours, the Department or justice, this time by
	displaying the identification card of Ms. Thomas. They
	proceeded to the first floor offices of Mr. Shaw which they
	entered by again forcing open the door using a credit card
	like device. They there took from Mr. Shaw's office current

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

	and is routed via the defendants Heldt, Weigand, and Willardson
	and Mr. Budlong. Mr. Meisner identifies the signature on
	that memorandum as having been written by the defendant
	Raymond.

	114/ The defendant Thomas and Mr. Meisner also burglarized
	the suite of offices of Mr. John F. Shaw on or about May 8, 
	1976.  Mr. Shaw's door was once again forced open, and recent
	Interpol documents were taken, photocopied using United States
	property, and the copies stolen.  Mr. Meisner excerpted
	these documents in a memorandum dated 8 May 1976, addressed
	to the defendant Raymond via the defendant Hermann/Cooper.
	See Government Exhibit No. 93. Mr. Meisner identifies his own
	handwriting ("WW copy"). In the upper left-hand corner of the
	first page. One of the stolen documents excerpted on page
	one, paragraph three of the memorandum was a letter from
	Treasury Department Acting Secretary Stephen S. Gardner to
	Speaker of the house Carl Albert transmitting a proposed 
	draft bill relating to Interpol. (Government Exhibit No.
	94.)  Government Exhibit Nos. 93 and 94 were seized by 
	Special Agent Martin A. Gonzales from a file cabinet in the
	defendant Raymond's office at the Cedars Complex.

- ---------------------------------------------------------------------                                                                                      
						
						154

	data which Mr. Shaw had received regarding Interpol in general
	and, in particular, a an audit which was then being conducted
	by the General Accounting Office.  All of these documents
	had been classified for "Limited Official Use". The defendant
	Thomas and Mr. Meisner photocopied these documents in the
	same manner as they had on April 28, and May 8, 1976. Just
	as on the prior two dates, they removed from the building the
	stolen copies. Mr. Meisner then summarized the documents
	in a 17 May 1976 memorandum to the defendant Raymond which
	was sent via the defendant Hermann/Cooper. The appended
	stolen documents bear Mr. Meisner's handwritten numerals in 
	the lower right-hand corner. 115/
	     In April and May 1976, Mr.  John F. Shaw was, in fact, the
	Special Assistant to Assistant Attorney General for Administra-
	tion Glenn Pommerening, Jr.  Mr. Shaw's offices were located
	In Room 1103 on the first floor of the main Department of 

- ---------------------                   
		   
	115/ "Pages 1a and 2a" were retyped by Mr. Meisner
	himself as pages "1" and "2" were not sufficiently
	legible. (Government Exhibit No. 95). Government Exhibit 
	No. 95 was seized by Special Agent Repucci from a file cabinet
	in the defendant Raymond's office in the Cedars Complex.

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

					155

	Justice building at 9th Street and Constitution Avenue,
	Northwest, In Washington, D.C. In that capacity he was the
	main coordinator of the Justice Department's internal review
	concerning the transfer of Interpol from the Department of 
	the Treasury to the Department of Justice. He maintained
	all his files on Interpol on shelves in an unlocked closet
	behind his desk. He has reviewed the Meisner memoranda
	referred to herein and the documents appended thereto and,
	states that they were in his office on the dates of the
	memoranda. Indeed, they still are in his files. Many of 
	these documents contain his handwritten notations while
	others are specifically addressed to him. He did not at any
	time give permission to the defendant Thomas or Mr. Meisner
	to enter his offices, take these documents, photocopy them,
	or take the copies for the use of Scientology.
					     
			P.  Burglaries and Thefts of Documents 
			    from Assistant United States Attorney
			    Nathan Dodell's Office, Located in
			    the United States Courthouse for the
			    District of Columbia

	     On April 14, 1976, during a Scientology FOIA case
	chambers hearing, United States District Judge George L.

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

					      156

	Hart, Jr. queried Assistant United States Attorney Nathan
	Dodell on the record and in the presence of Walter G. Birkel,
	Jr., Esquire, counsel representing the Church of Scientology,
	whether the United States had considered taking a deposition
	of L. Ron Hubbard. Mr. Dodell responded that it was an
	"interesting thought". which he would discuss with the Depart-
	ment of Justice. 116/ (Government Exhibit 96 at P. 3). 117/

- --------------------                 
		 
		 116/ See Founding Church of Scientology v. Paschall,
	   et al., Civil No. 75-1397 (April 14, 1976 Tr. at 2, 4). The
	   official court transcript reveals the following colloquy:

			THE COURT: Have you all considered
		   taking Hubbard's deposition?

			MR. DODELL: It is an interesting
		   thought, Judge Hart . . . .

			THE COURT: Why don't you take his
		   deposition?

			MR. DODELL: Well, let me say, I consult
		  with people at the Justice Department handling
		  these cases because there are so many, we
		  obviously coordinate and I will certainly relay
		  that suggestion to them with the fact that you
		  have reiterated here. Tr. at 2, 4.
	    
	117/ Government Exhibit No. 96 was seized by Special
	Agent, Jack C. Thorpe from Room 4 in the Information Bureau
	at the Cedars Complex.

- ---------------------------------------------------------------------
					      
					      157

	On April 20, Paul Klopper, the Branch II Director for the Legal
	Bureau in the United States, notified by memorandum the
	defendant Richard Weigand about this colloquy in Judge Hart's
	courtroom and suggested an investigation be initiated. In
	a letter dated 27 April 1976, and entitled "Re: LRH Safety",
	the defendant Weigand wrote the defendant Hermann/Cooper
	appending to the letter the Klopper memorandum. In his
	letter, the defendant Weigand ordered that the following
	actions be "done on a very high priority and as fast as 
	possible:"

		    A.   A complete ODC [Overt Data Collection]
			 and CDC [Covert Data Collection] on
			 Judge Hart. (this can fall under the
			 targets of GPgmO 301 but must be done
			 very fast)
				       
		    B.   Get a line in the JUDY area 118/
			 for immediate feedback of any proposed
			 intention to deposition LRH. Telex all
			 data found. You should also check out
			 the flow line on which this type of 
			 deposition would travel and keep a daily
			 monitor of the line.

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

	118/   "JUDY area" was a code name for the covert operation
	which was being carried out by Scientology agents within the
	United States Department of Justice,
		    
- ---------------------------------------------------------------------

					158
		    
		       C.    Get some type of line into Dodell
			     (similar to the successful suitable
			     guise line you had when you were in
			     DC) and keep tabs on what his
			     intentions are in the area of depo-
			     sition of LRH.
			     
		       D.    Also see if we can do some type of
			     JUDY action 119/ in Dodell's area to
			     get data predicting any action to
			     deposition.
			     

	The defendant Weigand instructed that in conducting the
	investigation on Judge Hart, the defendant Hermann/Cooper
	should "Be sure to look for any data legal could use to get
	him removed from the cases". On the same day, the defendant
	Weigand informed the defendant Raymond of the directive he
	had issued to the defendant Hermann/Cooper (Government
	Exhibit No. 96 at p. 4).
		In late April, the defendant Hermann/Cooper directed
	Meisner, in writing, to execute the order contained in the
	letter of the defendant Weigand of 27 April 1976. Appended

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

	119/  "JUDY action" was a reference within the Informa-
	tion Burau to the burglaries and thefts of documents which
	had taken place at the Department of Justice. It was also
	later used as a euphemism for burglaries in general.

- ---------------------------------------------------------------------
					    
					    159

	to the defendant Hermann/Cooper's directive were the Weigand
	and Klopper letters in Government Exhibit No. 96. 120/ Mr.
	Meisner immediately notified the defendant Thomas to be alert
	to any possible decision to subpoena L. Ron Hubbard. Mr. 
	Meisner then directed his own attention to Assistant United
	States Attorney Nathan Dodell.
		On or about May 7, 1976, the defendant Gerald Bennett
	Wolfe and Mr. Meisner entered the United States Courthouse
	for the District or Columbia located at 3rd Street and John
	Marshall Place, N.W., in Washington, D.C., around 4:00 P.M.
	and went to the 3rd floor which housed the United States
	Attorney's Office. Their purpose was to reconnoiter the
	area and locate the offices of Mr. Dodell. They proceeded
	directly to the third floor District of Columbia Bar Asso-
	ciation Library, and from there went to the area housing
	
- --------------

	120/  Handwriting expert James Miller concludes that it 
	is "probable" that the signatures "Dick" on pages two and four
	of Government Exhibit No. 96 were written by the defendant 
	Weigand. Moreover, Mr. Meisner recognizes the signature as 
	being in the handwriting of the defendant Weigand.

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

					   160

	Civil Division of the United States Attorney's Office.
	Eventually, they located Mr. Dodell's office in the back
	part of the Civil Division area, off of a hallway near a
	key-operated elevator and the rear door of the D.C. Bar
	Association Library. They then searched for a photocopying
	machine, and found one coin operated machine in that library,
	and two other larger machines within the United States
	Attorney's Office next to the Fraud Division.  At 5:30 p.m.,
	they returned to Mr. Dodell's office and found the door
	locked. After trying unsuccessfully to force the open the door
	with a metal sheet, they left the building.
		Mr. Meisner instructed the defendant Wolfe to return to
	the Courthouse in the daytime and inspect the latch on Mr. 
	Dodell's door to determine how to gain access. A few days
	later, the defendant Wolfe telephoned Mr. Meisner at his
	office at the Church of Scientology at 2125 S Street, N.W.,
	Washington, D.C. and told him that he was calling from Mr.
	Dodell's office. The defendant Wolfe informed Mr. Meisner
	that Mr. Dodell's secretary had apparently left her keys on

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

					161
								
	  her desk. Mr. Meisner directed the defendant Wolfe to take the
	  keys and meet him on John Marshall Place, N.W. Half an hour
	  later, the defendant Wolfe and Mr. Meisner located a locksmith
	  at Seventeenth Street and Columbia Road, N.W., where they
	  obtained duplicates of some of the keys. They then both returned
	  to the United States Courthouse, and Mr. Meisner
	  dropped the keys in the hallway adjacent to Mr. Dodell's
	  office.  Both men then left the Courthouse.
	      On May 21, 1976, at approximately 6:30 to 7:00 p.m., the
	  defendant Wolfe and Mr. Meisner entered the Courthouse
	  building at 1111 Constitution Avenue, N.W. They drove from
	  there to the United States Courthouse. Mr. Meisner entered
	  the building using his IRS credentials and signed in
	  using the name "John M. Foster". They informed the General
	  Services Administration (GSA) security guard that they were
	  going to the District of Columbia Bar Association Library
	  to do legal research. The guard called the Bar library and
	  inquired whether they would be permitted to enter. Having
	  been informed that they could use the library, the security

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

						162
								     
	   Guard issued Mr. Meisner an elevator key. The defendant
	   Wolfe and Mr. Meisner then proceeded to the Bar library on
	   the third floor, where the defendant Wolfe and Mr. Meisner
	   signed the library log using the names "J. Wolfe" and "John
	   Foster", respectively. (See Government Exhibit No. 97.)
	   They walked to the back of the library where they removed
	   some legal books from the shelves, placed them on a table
	   and pretended that they were doing research. A few
	   minutes thereafter, the defendant Wolfe and Mr. Meisner
	   passed through the back door of of the library onto the hallway
	   off of which Mr. Dodell's office was located. Using the 
	   duplicate keys, they forced open the door to Mr. Dodell's
	   office and entered the office without permission. The defend-
	   ant Wolfe and Mr. Meisner examined Mr. Dodell's unlit office
	   by flashlight and found a current file on Scientology. Mr.
	   Meisner took that file as well as a number of other files
	   from one of Dodell's file cabinets. They walked through
	   the third floor hallways to the Offices of the United States
	   Attorney for the District of Columbia and the two photocopy

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

					    163

	    machines which they had located on May 7. They there photo-
	    copied approximately six inches of documents on Scientology
	    and Interpol using United States Government supplies and
	    equipment.  They returned the documents to Mr. Dodell's files
	    and the copies were placed in Mr. Meisner's briefcase. The
	    defendant Wolfe and Mr. Meisner left the Courthouse at
	    approximately 11:00 p.m., and returned to the parking lot at
	    the main IRS building on Constitution Avenue, N.W. Mr.
	    Meisner then returned to his office at 2125 S Street, N. W.,
	    and immediately telephoned the defendant Weigand to inform
	    him that he and the defendant Wolfe had burglarized Dodell's
	    office and stolen copies of the Interpol documents located
	    therein. These were the documents which the United States
	    Guardian's Office had been ordered to obtain by Guardian
	    World-Wide Jane Kember in November 1973 121/ as well as
	    the documents targeted both by GPgmO 9, and a subproject
	    written by the defendant Raymond pursuant to GPgmO 302. The
	    defendant Weigand congratulated Mr. Meisner on his successful
	    mission.

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

		  121/ See Government Exhibit No. 2, supra.

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

					    164
		  
		Mr. Meisner reviewed the documents which had been stolen
	   from Mr. Dodell's office and summarized some or them in two memo-
	   randa dated May 24 and May 27, 1976. (Government Exhibits No. 98
	   and 100.) 122/ Government Exhibit No. 98 contained two Meisner
	   memoranda dated 24 May 1976 addressed to the defendant Raymond
	   via the defendant Hermann/Cooper. They are entitled "US
	   Interpol NCB Documents on Scientology Withheld in Entirety
	   Under FOIA" and "US Interpol NCB Documents on Scientology
	   Partially Withheld Under FOIA". Appended to these memoranda
	   were at least eighty-six of the approximately one thousand
	   pages of documents stolen from Mr. Dodell. Each document
	   summarized therein contained a numeral handwritten by Mr.
	   Meisner in its lower right-hand corner as well as some other
	   excerptions and notes. (See, e.g. Government Exhibit No.

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

	   122/ Government Exhibit No. 98 was seized by Special
	   Agent Kramarsic from a file cabinet in the defendant
	   office at the Fifield Manor, and Government Exhibit No. 100
	   was seized by Special Agent Kramarsic from Room 14 in the
	   Information Bureau at the Cedars Complex.

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

					    165

	99.)  123/  Government Exhibit No. 100 contained a May 25,
	1976 Meisner memorandum from Mr. Meisner entitled "Nathan
	Dodell, Current Information on Scientology's Harassment of
	the Government on Legal Lines" which summarized documents
	stolen from Mr. Dodell's office. That memorandum, and a
	second one of the same date entitled "Significance of Dodell
	Material Enclosed", was sent by Mr. Meisner to the defendant
	Hermann/Cooper. Appended to it are copies of numerous documents
	stolen from Mr. Dodell. Many or these documents contained the
	handwriting of Assistant United States Attorney Nathan Dodell.
	124/ On May 27, the defendant Hermann/Cooper forwarded

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

	123/ Government Exhibit No. 99 contains a few of the
	documents summarized in Government Exhibit No. 98. Sec,
	e.g., Government Exhibit No. 99 marked by Mr. Meisner as page
	"24" and compare to Government Exhibit No. 98, Meisner, page 24
	May 1976 memo at page three, paragraph two. Government Exhibit 
	No. 99 was seized by Special Agent Ryan from Room No. 13
	within the Information bureau at the Cedars Complex.

	124/  See, for example, the documents containing Mr.
	Meisner's handwritten numerals Nos. 1, 6, 7, 12, 13, etc.
	Mr. Dodell has reviewed these documents and states that they
	were in his files in May 1976, and indeed still remain in his
	files.

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

					  166

	the Meisner memorandum and appended stolen documents to
	World-Wide with a cover memorandum outlining the content of
	the package. A copy or that material was sent to the Deputy
	Guardian for the United States, the defendant Heldt, and the
	Deputy Guardian for Information in the United States, the
	defendant Weigand. 125/
	      On May 28 1976, the defendant Wolfe and Mr. Meisner met
	once again outside the main IRS building in Washington, D.C.
	at approximately 6:30 p.m., and after parking one of the cars
	nearby, proceeded to the United States Courthouse, at Third
	Street and John Marshall Place, N.W. In the Courthouse Mr.
	Meisner signed in as "John M. Foster," using his false IRS
	identification card. The defendant Wolfe signed-in as "T.
	Haake" using a D.C. Bar Association library card which he
	had borrowed from another IRS employee.  United States Court-
	house logs maintained by the GSA security guards indicate
	that the two men entered the Courthouse at 7:30 p.m. and
	remained until 9:55 p.m. The entry logs further show that

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

	125/   Mr. Meisner identifies the initials "GW" in the
	routing on the Hermann/Cooper letter as having been written
	by the defendant Willardson.

- ---------------------------------------------------------------------
					  
					  167

	they were going to the "Library". (Government Exhibit No. 101.)
	Once again they borrowed an elevator key and proceeded
	to the third floor of the United States Courthouse and entered
	the Library of the District of Columbia Bar Association
	through the back door without first signing in. A few minutes
	later, finding the area clear, they went to Dodell's office
	and opened the door with the key which they had previously
	duplicated. This time they took approximately one foot of
	documents related to Scientology, and more specifically to
	the District of Columbia Police Department and the federal
	Food and Drug Administration. These documents were photocopied
	on the United States Attorney's Office photocopying machines
	using Government owned supplies located nearby. As the defend-
	ant Wolfe and Mr. Meisner were returning to Mr. Dodell's office
	through the library, they were stopped by night librarian
	Charles Johnson who inquired as to whether they had signed-
	in.  When he was told that they had not, he required them to
	sign-in (See Government Exhibit No. 102.) Mr. Meisner
	signed-in as "J. Foster" and Mr. Wolfe as "W. Haake". They

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

					168
					
	placed as a reference telephone number, 964-4483. The night
	librarian informed them that they were not to return to the
	library unless they had specific authorization from the
	regular librarian. The defendant Wolfe and Mr. Meisner
	immediately left the library, returned the documents to Mr.
	Dodell's office and left the Courthouse with copies of the
	documents in Mr. Meisner's briefcase. After leaving the
	defendant Wolfe at the IRS building, Mr. Meisner returned to
	the Guardian's Office.
	     In two memoranda dated 1 June and 2 June 1076 (Government
	Exhibits Nos. 103 and 104, respectively), 126/ Mr. Meisner
	summarized the more important of the documents which he and
	the defendant Wolfe had stolen from Mr. Dodell's office. Both
	memoranda are addressed to the defendant Hermann/Cooper. 127/
	Upon receiving the June 2, 1976 memorandum and attached stolen
	documents, the defendant Hermann/Cooper forwarded them to

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

	126/ Government Exhibits Nos. 103 and 104 were seized 
	by Special Agent William Cohendet from Room 14 in the
	Information Bureau at the Cedars Complex.

	127/ Mr. Meisner identifies on Government Exhibit No.
	103 a handwritten notation in the defendant Hermann/Cooper's
	handwriting.

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

					      169

	World-Wide in a June 6, 1976 letter entitled "Re: DC US
	Attorney Nathan Dodell".
	     Mr. Dodell was, in 1976, and still is an Assistant United
	States Attorney for the District of Columbia assigned to the
	Civil Division of the United States Attorney's Office. His
	personal office was located, in May and June 1976, on the
	third floor of the United States Courthouse for the District
	of Columbia, immediately behind the Library of the District
	of Columbia Bar Association. He has reviewed copies of the
	documents appended to the Meisner memoranda refered to
	above, and concludes that they were in his files on the
	dates on which the memoranda were written. In fact they
	remain in his files to this date. Many of the documents
	contain, or are written in, his own handwriting. Mr. Dodell
	did not give permission to either the defendant Wolfe or
	Meisner to enter his offices, take documents which were in
	his care, custody and control, photocopy them, or steal
	copies thereof.
	     On May 31, 1976, the night librarian, Charles Johnson, and
	the GSA Security Guard notified the United States Attorney's

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

					    170

	office that two individuals who had identified themselves as
	IRS employees and who had in their possession IRS identifica-
	tion cards had been seen using the photocopying machines of
	the United States Attorney's Office on the previous Friday
	evening. Both Mr. Johnson and the guard were instructed to
	immediately contact the FBI if those two individuals returned
	to the Courthouse.
	      During that same time Mr. Meisner contacted the chief
	D.C. Bar Association librarian, requested, and obtained from
	her, a letter permitting him to use the facilities of the
	D.C. Bar library. On June 8, 1976, Deputy Guardian for
	Information, the defendant Weigand, Deputy Guardian for Legal
	Bureau Mary Rezzonico, and Deputy Guardian for Public Relations
	Arthur Maren, approved a "Project: Target Dodell" (Goverment
	Exhibit No. 105). 128/ Its purpose was to "render Dodell harm-
	less" because of his aggressive representation of the United
	States of America as counsel in the Scientology FOIA legal
	actions. A few days prior to June 11, 1976, the defendant
	Hermann/Cooper telephoned Mr. Meisner and directed him to

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

	128/ Government Exhibit No. 105 was seized by Special
	Agent Jack C. Thorpe from Room 4 in the Information Bureau at
	the Cedars Complex.

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

					   171

	to return to Mr. Dodell's office and steal Dodell's personal
	files in order to devise and formulate a covert operation to
	remove him as an Assistant United States Attorney for the
	District of Columbia. To that end, the defendant Wolfe and
	Mr. Meisner met on June 11, 1976, once again, outside the
	main IRS building in Washington, D.C., and proceeded to the
	United States Courthouse in that same city. They entered the
	United States Courthouse at approximately 7:00 p.m., Mr.
	Meisner signing-in as "John M. Foster" and the defendant
	Wolfe using the name "Thomas Blake", both using their counter-
	feit IRS identification cards. They proceeded to the Bar
	Association Library where they signed in using the names
	indicated above. (Government Exhibit No. 106). Mr. Meisner
	also showed the night librarian, Charles Johnson, the written
	permission which he had earlier secured from the head librarian.
	The defendant Wolfe and Mr. Meisner them proceeded through the
	back of the library to Mr. Dodell's office where they observed
	cleaning ladies still working in that office. They returned
	to the library and waited there until the cleanup crew had

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

					  172

	   left Mr. Dodell's Office. In the meantime, night librarian
	   Johnson contacted the FBI regarding the presence of the
	   defendant Wolfe and Mr. Meisner. Shortly thereafter FBI
	   Special Agents Christine Hansen and Dan Hodges confronted
	   tho defendant Wolfe and Mr. Meisner at one of the back tables
	   within the Bar Association Library, and demanded to see their
	   identification cards. Mr. Meisner presented his IRS identi-
	   fication card to the FBI agents and informed them that he
	   had since resigned from the IRS. While FBI Agent Hansen
	   continued questioning the defendant Wolfe and Mr. Meisner, FBI
	   Agent Hodges left to contact an Assistant United States
	   Attorney.  Mr. Meisner informed Agent Hansen that he and the
	   defendant Wolfe had been in the Courthouse to do legal research,
	   and that they had used the United States Attorney's Office
	   photocopying machine to photocopy legal books and cases. He
	   gave her as his home address an address a few doors away
	   from his actual residence. Neither individual mentioned
	   either's association with the Church of Scientology, or the
	   true purpose for which they were in the United States Court-

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

				   173

	house. After fifteen minutes of questioning Mr. Meisner
	inquired if they were under arrest. When Agent Hansen
	responded that they were not, Mr. Meisner told Wolfe that
	they were leaving. As they were leaving the library, Agent
	Hodges called to the defendant Wolfe and Mr. Meisner but
	was told by Mr. Meisner that Agent Hansen had permitted
	them to leave. 129/

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

	129/ On December 18, 1976, the defendant Hermann/Cooper
	sent "Project Troy" to the defendants Heldt and Weigand
	pursuant to the request of the defendant Weigand. Weigand
	had directed Hermann/Cooper to write "a project to get
	prediction on future IRS actions." The attached "Project
	Troy" called for the placement of a permanent bugging device
	in the office or the IRS Chief Counsel. Thus, the Guardian's
	Office would be able to monitor all "IRS planned actions as
	regards the C of S of C [Church of Scientology of California]
	exemption so that Legal can be briefed to take effective
	action." (Government Exhibit No. 110 at pp. 2-4.) A "CSW"
	from the defendant Weigand to the defendant Heldt dated
	December 20, 1976, requests that "Project Troy" be approved
	as soon as possible. The defendant Heldt approved the project
	by initialing the line entitled "OK". (Government Exhibit
	No. 110 at p. 1.). Handwriting Expert James Miller concludes 
	that it is "probable" that that initial belongs to the defend-
	ant Heldt. Mr. Meisner identifies it as the writing of the
	defendant Heldt. Other conclusions of Mr. Miller: the hand-
	written note "I need to see Dick [Weigand] on this after his
	Session" and initial -- "positive" in the defendant Heldt's
	handwriting; the word "secret" on the upper portion of the
		   (footnote continued on next page.)

- ---------------------------------------------------------------------
	
					     174

	     Upon leaving the United States Courthouse, Mr. Meisner
	and the defendant Wolfe walked a number of blocks to make
	sure that they were not being followed and then took a
	taxicab to Martin's Tavern Restaurant on Wisconsin Avenue and
	N-Street, N.W. in-Washington, D.C. Mr. Meisner then telephoned
	the defendant Hermann/Cooper in Los Angeles, California to
	inform him in a circumspect manner that they had been confronted
	by the FBI. The defendant Hermann/Cooper told Mr. Meisner
	to call him back at a public telephone. A few minutes later
	
- ------------------------              
		(footnote continued from preceding page.)

	first page -- "highly probable" in the defendant Weigand's
	handwriting; the signature "Mike" on page two and the ending
	"Love Mike" on page four -- "probable"  by the defendant
	Hermann/Cooper. Mr. Meisner identifies those two signatures
	and the entry "Phoned into DC 12/21/76" in the upper right-
	hand corner of page one as in the handwriting of the defendant
	Hermann/Cooper. Government Exhibit No. 110 was seized by
	Special Agent William J. Pettit from a file cabinet in the
	Information Bureau of the Cedars Complex.
	      In a letter dated 3 June 1977, the United States Secretary
	at World-Wide Hermann Brendel sent the defendant Gregory
	Willardson, who had been elevated to the post of Deputy
	Guardian for Information U.S., "a list of the vital products
	needed from B1 [Information Bureau] US." He states that 
	these were "taken from CSG [Mary Sue Hubbard] and GWW [Guardian
	World-Wide Jane Kember] orders". (Government Exhibit No. 112).
	    Government Exhibit No. 112 was seized on July 8, 1977,
	by Special Agent Eusebio Benavidez from the pending basket on
	the defendant Willardson's desk at the Cedars Complex.

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

					 175

	   Mr. Meisner once again contacted the defendant Hermann, and
	   this time informed him of the details of his confrontation
	   with the FBI in the United States Courthouse for the District of
	   Columbia. The defendant Hermann/Cooper instructed Mr. Meisner
	   to remain at the restaurant and told him that he would contact
	   the defendant Weigand and further instruct Mr. Meisner at that
	   time as to what course of action to follow. He also directed
	   Meisner to begin writing a report on what had actually
	   occurred in the United States Courthouse. Mr. Meisner was
	   to call him back within one hour. Mr. Meisner then contacted
	   Joseph Alesi, the Branch I Director for the District of
	   Columbia. Mr. Meisner directed Mr. Alesi to proceed to the
	   United States Courthouse and pick up the defendant Wolfe's
	   car which had been left there and bring it to Martin's Tavern
	   Restaurant. Mr. Meisner, also instructed Mr. Alesi to call
	   Mrs. Meisner and ask her to pick up his car, which he had
	   left in the main IRS building parking lot.
	       One hour later, Mr. Meisner called the defendant Hermann/
	   Cooper in Los Angeles, California, to receive further

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

					    176

	instructions, The defendant Hermann/Cooper informed Mr.
	Meisner that he had discussed their FBI confrontation with
	the defendant Weigand and that the latter wanted him to come
	immediately to Los Angeles, California. Mr. Meisner stated
	that he would leave the next morning for Los Angeles. Mr.
	Meisner and his wife stayed that night at the Quality Inn
	Motel on Courthouse Road and Route 50 in Arlington, Virginia.
	(Government Exhibit No. 113).
	     Mr. Meisner then called Bruce Ullman, the Information
	Branch II Director for the District of Columbia, and directed
	him to obtain money from the Guardian's Office funds and
	bring it to him the next morning, when he was to pick him up
	at an Arlington motel and take him to the National Airport
	for his trip to Los Angeles.

					 IV.

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

		     A.  The preparation of the Cover-Up Story
	     
	     On June 12, 1976 Mr. Meisner was met at the Quality
	Inn Motel, in Arlington, Virginia by Mr. Bruce Ullman who
							      
- ---------------------------------------------------------------------

					177

	gave him money for a round trip flight to Los Angeles. Mr.
	Ullman drove Mr. Meisner to National Airport where Mr. Meisner
	took a United Airlines flight to Los Angeles. On the plane,
	Mr. Meisner completed his detailed report of the Courthouse
	incident as he had been directed to, the night before, by the
	defendant Weigand through the defendant Hermann/Cooper. Mr.
	Meisner arrived in Los Angeles at approximately noon, and
	went directly to the defendant Weigand's office on the seventh
	floor of the Fifield Manor. Defendant Weigand reviewed Mr. Meisner's
	handwritten report and then asked him to type it.
	Mr. Meisner typed it at defendant Weigand's desk. (Government
	Exhibit No. 114.) 130/  When he had finished, Mr. Meisner
	showed the typed report to defendants Weigand and Willardson,
	both of whom read it.  Defendant Weigand remarked that he
	would take it to the defendant Heldt's office on the sixth
	floor. He did this and returned approximately fifteen minutes

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

	130/  Government Exhibit No. 114 was seized and initialed
	by Special. Agent Henry L. Williams from the office of the
	defendant Raymond at the Cedars Complex.  The document was
	inventoried and also initialed by Special Agent Raymond Mislock.

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

					178

	later. The defendants Weigand and Willardson then, together
	with Mr. Meisner, analyzed the crisis to determine what
	leads the FBI had and how they could contain or stop the
	investigation. The three men decided to devise a cover
	story for use by the defendant Wolfe if he were arrested.
	The plan contemplated further that defendant Wolfe would, if
	captured, enter a guilty plea, after which Mr. Meisner would
	surrender to the FBI and give the same story to them as Wolfe
	had. An alternative plan had both the defendant Wolfe and
	Mr. Meisner surrendering immediately and giving the same
	cover story. All parties recognized that the highest priority
	lay in stopping the FBI investigation before it could connect
	the defendant Wolfe and Mr. Meisner to the Church of Scientology
	and thereby expose other officials of the Guardian's office
	who had been involved in the burglaries, thefts, and buggings,
	described in the  first conspiracy, _supra_. After a full
	afternoon of discussions, the defendants Weigand and Willardson
	drove Mr. Meisner to a Holiday Inn located near Hollywood
	Boulevard in Los Angeles, California, where Mr. Meisner

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

					     179

	registered under a false name.  That evening he had dinner
	together at the motel prior to leaving Mr. Meisner for the
	evening

- ---------------
								  
	131/ On June 11, 1976 the defendant Richard Weigand had
	written a lengthy report to Deputy Guardian for Information
	World-Wide Mo Budlong, outlining the events which had taken
	place In the United States Courthouse in the District of
	Columbia.  The defendant Weigand also explained the manner in
	which the defendant Wolfe and Mr. Meisner could be traced to
	the Church of Scientology, as well as the story to be given
	to law enforcement investigators. See Government Exhibit No.
	116.  A copy of that report was sent to the "CS-G", defendant
	Mary Sue Hubbard.  That report was written in code. It was
	seized by Federal Bureau of Investigation Special Agent
	Harold R. Brunson from the area immediately outside the
	office of the defendant Raymond at the Cedars Complex. It
	was inventoried and initiated by Special Agent Michael Ray
	Napier. Government Exhibit No. 185 (Code ISIS) was seized
	by Special Agent Eusebio Bonavidez from a file cabinet in
	the defendant Willardson's office at the Cedars Complex.
	Code ISIS had an attached cover letter from Mr. Mo Budlong
	to the then Deputy Guardian for Information, the defendant Duke
	Snider, in which Mr. Budlong directed that Code ISIS was to be
	used only for dispatches between the United States Guardian's
	Office and the World-Wide Guardian's Office.  Mr. Meisner
	identifies the handwriting at the top of that page as that 
	or the defendant Snider, and the signature and handwriting
	the bottom of the page as that of Mr. Budlong. Special
	Agent Arthur R. Eberhardt, a cryptanalysis expert with the 
	Federal Bureau of Investigation in Washington, D.C., has
	examined Government Exhibit No. 116 and Code ISIS (Government
	Exhibit No. 188). He concludes that the coded text within
	Government Exhibit No. 116 used two different methods of a
	substitution code - "digital" and "word or phrase". The
		     (footnote continued on next page.)

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

					180                             

	     On Sunday, June 13, 1976, the defendant Willardson met
	Mr. Meisner at his motel room and drove him to the defendant
	Weigand's office, where all three met to finalize the outline
	of the plan, which they had discussed the day before, in order
	to present it to the defendants Heldt and Snider. Soon there-
	after, the defendant Weigand and Mr. Meisner met with the
	defendants Heldt and Snider in the defendant Heldt's sixth
	floor offices at the Fifield Manor.  The defendants Heldt and

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

	"digital" code substitutes digits 10 through 99 for the
	various letters of the alphabet. The "word and phrase" code
	substitutes a word or phrase for a plaintext word or phrase.
	He also finds that Code ISIS (Government Exhibit No. 188) is
	the code which was used to encode Government Exhibit No. 116.
	Thus, using Code ISIS he decoded that Government Exhibit No.
	116 by placing the decoded letters and words above the coded
	ones.  See Government Exhibit No. 212.
		On June 21, 1976 the defendant Weigand sent the same
	report to CS-G Assistant for Information Jimmy Mulligan.  See
	Government Exhibit No. 115 which was seized by Special Agent
	James R. Kramarsic from a file cabinet located in a closet in
	the defendant Heldt's inner office at the Fifield Manor.
	Handwriting expert James Miller concludes that it is "probable"
	that the defendant Heldt wrote his initials next to his title
	in the routing portion of the cover letter, and that it is
	"probable" that the defendant Weigand wrote the signature
	"Dick" on that letter. Mr. Meisner recognizes both the
	initial and the signature as those of the defendants Heldt
	and Weigand, respectively.

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

				    181

	Snider each indicated that they had already read Mr. Meisner's
	report (Government Exhibit No. 114) and were fully conversant
	with the matters discussed in it. All present concluded
	that the FBI could readily trace already existing leads back
	to the Church of Scientology. With this in mind, the defend-
	ants Heldt and Snider suggested an alternative plan which
	they had formulated on their own earlier that day. That
	plan called for the defendant Wolfe and Mr. Meisner to be
	withdrawn from the District of Columbia and sent out of the
	United States. The defendant Heldt stated that as long as
	there were no bodies, the FBI would have nothing to investigate.
	The defendant Weigand, however, countered that if no bodies
	were found then the FBI would look even more deeply and find
	the connection between the defendant Wolfe and Mr. Meisner
	and the Church of Scientology organization. The defendant
	Weigand explained that Mr. Meisner had given the FBI an
	address close to his real residence where, by canvas, the
	FBI might find someone who could identify him by the photograph
	on his counterfeit IRS credentials. It was also pointed out

- ---------------------------------------------------------------------
					    
					    182

	   that the FBI not only had Mr. Meisner's and the defendant
	   Wolfe's handwriting on the Courthouse and library logs, but
	   also Mr. Meisner's fingerprints on his false IRS identification
	   card. Thus, the defendant Weigand suggested that if the
	   defendant Wolfe allowed himself to be arrested and gave the
	   proper cover story, then the investigation could be contained.
	   Then, following the defendant Wolfe's plea of guilty, Mr.
	   Meisner would surrender, give the same cover story as the
	   defendant Wolfe, and enter a guilty plea. This, he posited,
	   would terminate the investigation with little or no connection
	   to Scientology. The defendant Heldt directed the defendant
	   Weigand and Mr. Meisner to discuss both plans, and detail
	   one of them and present it to him for his final approval.
		The defendant Weigand and Mr. Meisner returned to the
	   defendant Weigand's office where the defendant Willardson
	   joined them to implement the defendant Heldt's orders. During
	   that meeting, the defendant Hermann/Cooper informed them
	   that the defendant Wolfe had left the District of Columbia
	   and was to arrive in Los Angeles later that evening. The
	   defendant Hermann then joined the meeting for a short period

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

				    183

	    of time. The three men drafted defendant Weigand's ideas in
	    proposal format. The defendant Weigand himself actually wrote
	    out the proposal for the defendant Heldt's approval, typed
	    it, and took it to the defendant Heldt.  Some fifteen minutes
	    later, the defendant Weigand returned to his office and stated
	    to the defendant Willardson and Mr. Meisner that the defendant
	    Heldt had approved that plan.  They decided to meet again the
	    next morning to prepare the cover story with the defendant
	    Wolfe. The defendant Weigand directed Mr. Meisner to change
	    his appearance with the assistance of Weigand's secretary,
	    Janet Finn.  The defendant Willardson and Mr. Meisner then had
	    dinner, after which Mr. Meisner was returned to the Holiday
	    Inn motel.
		 On Monday, June 14, the defendant Weigand's communicator
	    (secretary), Janet Finn, met Mr. Meisner at approximately
	    9:00 a.m. at his motel room. She cut his hair, then dyed it
	    red. Mr. Meisner then shaved his mustache. Establishment
	    Officer (Esto Off) Peeter Alvet met Mr. Meisner and gave him
	    approximately $200 to obtain contact lenses. Mr. Meisner

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

					    184

	then went to an optometrist on Hollywood Boulevard where he
	purchased soft contact lenses. 132/
		At approximately 1:00 p.m. the defendants Weigand,
	Willardson and Wolfe arrived at the Holiday Inn to create the
	cover story to be given by Wolfe to the FBI. The defendant
	Weigand informed Mr. Meisner that the defendant Hermann/Cooper
	was on a plane on his way to the District of Columbia where
	he was to assume temporarily the position of Assistant Guardian
	for Information until Richard Kimmel could be brought back
	from England where he had been undergoing training at World-
	Wide for that position. 133/
		During the next hour the following cover story was
	prepared:  The defendant Wolfe and Mr. Meisner were to have
	met in February 1976 in a District of Columbia bar, which
	was to be selected later, and struck up a friendship. Mr.
	
- -----------------

	132/ Dr. Gerald Nankin, an optometrist with offices on
	Hollywood Boulevard in Los Angeles, California, sold a pair
	of contact lenses to Mr. Meisner on June 14, 1976.

	133/ Mr. Kimmel had been selected to replace Mr. Meisner,
	who during his meetings in Los Angeles in February 1976, had
	been slated to become National Secretary for the United States.

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

					  185
	   
	   Meisner was to have introduced himself as "John Foster".  Mr.
	   Mr. Meisner was to have told the defendant Wolfe that he was
	   a law student attending Georgetown University School of Law.
	   The defendant Wolfe was to have informed Mr. Meisner that he
	   worked at the IRS.  The two individuals were to have met on a
	   number of occasions. Then in mid-March 1976, after having
	   drunk heavily at a few different bars, Mr. Meisner was to have
	   mentioned that he had never been to the IRS, and Wolfe was to
	   have offered to take him on a tour of that building. The
	   defendant Wolfe was to have taken Mr. Meisner to the IRS,
	   signed him in, and taken him on a tour of the first floor.
	   Inadvertently, according to the story, they stumbled upon
	   the identification room which had an open door. They went
	   in and as a lark decided to make identification cards for
	   themselves. The defendant Wolfe was to have made Mr. Meisner
	   an identification card and typed in the name "John Foster"
	   upon it. Mr. Meisner was then to have made an identification
	   card for the defendant Wolfe who had decided to use the name
	   "Thomas Blake". On a subsequent occasion, the defendant Wolfe

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

					 186.

	   and Mr. Meisner were to have met at a bar and after a few
	   drinks the defendant Wolfe asked Mr. Meisner to teach him
	   how to do legal research so that he might be able to obtain a
	   better job.  Mr. Meisner agreed to do so if Wolfe would, as a
	   return favor, look up some information for him at the IRS for
	   a paper which Mr. Meisner was writing on section 501 (c)(6)
	   of the IRS Code (the section dealing with exempt organizations).
	   They decided that the District of Columbia Bar Association
	   Library in the United States Courthouse in the District of
	   Columbia was the most convenient for them. Thus, on May 21,
	   28 and June 11, they went to the Courthouse to use the D.C.
	   Bar Association Library where Mr. Meisner taught the defendant
	   Wolfe legal research.  While there, they were directed by the
	   cleaning personnel to the photocopying machines within the
	   United States Attorney's Office.  Specifically, they used
	   those machines to photocopy cases in law books and their own
	   notes from those books.  However, they had no idea that they
	   were within the United States Attorney's Office. After the
	   confrontation with the FBI agents, the defendant Wolfe and

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

				     187
		   
	Mr. Meisner were so upset that they forgot to set up a
	further meeting. Since the defendant Wolfe did not know
	where Mr. Meisner lived, he could not contact Mr. Meisner
	again, and therefore, could not give the FBI his location.
	     After the defendants Weigand, Willardson, Wolfe and Mr.
	Meisner had outlined the cover story, the defendant Weigand
	instructed them to write out "mission orders" for the defend-
	ant Hermann in the District of Columbia, write out the cover
	story, and drill the defendant Wolfe on it. The defendant
	Weigand then left the Holiday Inn Motel.
	     The defendant Wolfe called his office at the IRS in
	Washington, D.C., to determine through a friend whether anyone,
	such as the FBI, had made any inquiries regarding him. In
	the process, he requested his friend to notify his supervisor
	that he would not be at work the next day. 134/ After that
	phone call, the three individuals prepared written "mission

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

	134/   Mr. Keith Shelton, Chief of the National Office
	Branch of the IRS and custodian of the time and attendance
	records, states that the defendant Wolfe used eight hours of
	sick leave on June 14, 1976, and six hours of sick leave and
	two hours of annual leave on June 15, 1976.

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

					188
			     
	  orders" for the defendant Hermann/Cooper. Those orders
	  required Hermann/Cooper to: (1) keep in constant contact with
	  the defendant Wolfe; (2) locate an attorney for the defendant
	  Wolfe so that he could test the plausibility of the concocted
	  story on someone other than the FBI; and (3) supervise the
	  defendant Wolfe pending his arrest. They then wrote out the
	  cover story, gave a copy to the defendant Wolfe and drilled
	  him on that story.
	       At approximately 7:00 p.m. Mr. Meisner checked out of
	  his motel room, and, together with the defendant Willardson,
	  drove the defendant Wolfe to the airport where Wolfe took a
	  night flight to Baltimore-Washington International Airport.
	  Mr. Meisner stayed that night at the defendant Willardson's
	  home on Roxbury Drive in Beverly Hills.
	       On June 15, 1976, in Washington, D.C., the defendants
	  Hermann/Cooper and Wolfe met, discussed the cover plan,
	  story and the attorney who was to be selected for Wolfe.  The
	  defendant Wolfe then met with his attorney and presented him
	  with the cover story which had been prepared the previous
	  day.

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

					  189

	     In Los Angeles, Mr. Meisner, who began to use the alias
	"Jeff Murphy", moved to the defendant Weigand's house on
	Westmoreland Street, near Wilshire Boulevard, where he stayed
	for the remainder of the summer. The defendant Weigand
	directed Mr. Meisner to prepare a complete report on his
	activities as Assistant Guardian for Information in the
	District of Columbia and on all pending activities there as
	required by Guardian's Office procedures when an official
	leaves a post. For the next few days, Mr. Meisner, working
	in the defendant Weigand's office, prepared the report as
	directed. On June 18, 1976, that completed report was typed
	by Mr. Meisner and presented to the defendant Weigand.
	(Government Exhibit No. 108.) 135/  In his report, Mr.

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

	135/ Government Exhibit No. 108 was seized by Special
	Agent Gary Aldrich from the office of the defendant Willardson
	at the Cedars Complex. Handwriting expert James Miller
	positively identifies the notation "G.  I'll read it later.
	L.D." located on the front page of that report as the
	handwriting of the defendant Weigand. Mr. Meisner also
	identifies the initials "GW" in the upper portion of the
	front page as having been made by the defendant Willardson.

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

					    190

	Meisner explained how he had burglarized government offices,
	including the manner in which he had forcibly opened doors,
	and supervised covert operatives. He identified the current
	covert operatives who were still operating and itemized what
	remained for them to accomplish. He also described his duties
	as Assistant Guardian for Information. Within a few days
	thereafter, the defendant Willardson issued "mission orders"
	to Mr. Meisner which had been approved by the defendants
	Weigand and Heldt. These orders directed Mr. Meisner to go
	to Dallas, Texas, to attend the American Medical Association
	Convention, and then to New York to resolve a local Guardian's
	Office matter. Upon his return to Los Angeles, on July 7,
	Mr. Meisner was appointed National Secretary for the United
	States by Guardian World-Wide Jane Kember.
		     
		     
		     B. The Defendant Gerald Bennett Wolfe
			 is Arrested in Washington D.C. by
			 the Federal Bureau of Investigation

	      On June 30, the defendant Wolfe was arrested in the main
	IRS building by FBI Special Agent Christine Hansen. He was
	charged with the use and possession of a forged official pass
	of tho United States, in violation of 18 U.S. Code, Section 499,

- ---------------------------------------------------------------------
 
					191
	
	and arraigned before United States Magistrate Henry H. Kennedy,
	Jr. (U.S. Mag.  No. 76-930 M (Cr)).  On that same day, Assistant
	Guardian for Information in the District of Columbia Richard
	"Rick" Kimmel notified the defendant Hermann/Cooper of the
	defendant Wolfe's arrest.  The defendant Hermann/Cooper then
	informed the defendant Weigand that at 2:30 p.m. Wolfe had
	been arrested by the FBI, that he had been arraigned, and
	released on his own recognizance pending a preliminary hearing.
	As a condition of his release, the defendant Wolfe was to submit
	handwriting exemplars to the FBI. (Government Exhibit No.
	117.) 136/ The defendant Hermann/Cooper told the defendant
	Weigand that all covert activities in the District of Columbia
	had been ordered "shut down", that "sensitive material" had
	been moved to another office, and that "Kelly" (another
	covert name for the defendant Wolfe) "has been briefed to
	carry out his part".  He also told the defendant Weigand that
	all data on "Jeff" (Mr.  Meisner's alias at the time) had
		
- ---------------------                

	136/ Government Exhibit No. 117 was seized by Special
	Agent Brunson from the area immediately outside the main
	office of the defendant Raymond at the Cedars Complex. It
	was inventoried and initialed by Special Agent Napier.

- ---------------------------------------------------------------------
				     
				       192
				     
	been taken out of the organization. 137/ On July 1, the
	defendant Weigand wrote a letter to Deputy Guardian for
	Information World-Wide Mo Budlong informing him of the arrest
	of the defendant Wolfe and the information brought to his
	attention the previous day by the defendant Hermann/Cooper.
	(Government Exhibit No. 118.) 138/
	    In a letter dated July 1, 1976, and entitled "Re: Mike
	and the FSM", the defendant Mary Sue Hubbard stated to the

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

	      137/ Located above some of the more incriminating words
	  on Government Exhibit No. 117 are the coded words which were
	  to be substituted later.  These words are identical to those
	  in code ISIS (Government Exhibit No. 188). Mr Meisner
	  recognizes the initials next to the title "DG Info US" as
	  having been written by the defendant Weigand, and the signature
	  on that document as that of the defendant Hermann/Cooper.

	       138/ Government Exhibit No. 118 is also in code.
	  Special Agent Eberhardt of the Cryptanalysis Section of the
	  FBI Laboratory, decoded that document using code ISIS (Govern-
	  ment Exhibit No. 188).  See Government Exhibit No. 216 for the
	  decoded version of the instant document. That document was
	  seized by Special Agent Brunson from the area outside the
	  defendant Raymond's office at the Cedars Complex.  Handwriting
	  expert James Miller concludes that it is "probable" that the
	  defendant Weigand signed this letter. Moreover, Mr. Meisner
	  identifies that signature as having been written by the defend-
	  ant Weigand.  The initials "DW:jf" are those of the defendant
	  Weigand and his secretary Janet Finn.

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

					     193 

	defendant Weigand that "[from an investigative point of view
	it was really too easy for the opposition. All they had to
	do was to trace the common enrty [sic] points of the log back for
	both Mike and the FSM [Wolfe] until they arrived at the point
	where the FSM used his correct ID card." She urged the
	defendant Weigand to keep her informed of what has happened
	to the FSM, the defendant Wolfe. (Government Exhibit No. 119
	at p. 2.) Handwriting expert James Miller is "positive" that
	the signature on that document was written by the defendant
	Mary Sue Hubbard. 139/ The defendant Weigand responded to
	the defendant Hubbard's inquiry in two separate letters, both
	dated July 2, 1976. He informed her that the defendant Wolfe
	(Silver) was about to submit his resignation to the IRS to
	avoid being suspended. He also wrote that the prosecutor in
	the case had been told that Wolfe had obtained his identifica-
	tion card as part of "[a] lark gone sour".  He added that an
	additional $800 would be needed to "cover the balance of the
	retainer" of Wolfe's attorney. (Government Exhibit No. 119 at

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

	139/ Government Exhibit No. 119. was seized by Special
	Agent Brunson from the area outside the defendant Raymond's
	office at the Cedars Complex.

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

					  194

	   P. 3-4.)   He also stated that the defendant Wolfe was
	   "instructed . . . [to] go nowhere near the org [Church of
	   Scientology] and . . .   have no personal contact with the
	   case officer [Kimmel] either."  He concluded that it was still
	   possible that the defendant Wolfe would be "given minimal
	   punishment" and that the matter would terminate without any
	   connection to the Church of Scientology. (Government Exhibit
	   No. 119 at p. 1.) 140/  In the other letter of 2 July
	   1976 regarding "Silver", the defendant Weigand updated for
	   Mr. Budlong the information regarding the defendant Wolfe's
	   arrest. (Government Exhibit No. 120.) That coded letter was
	   decoded by a cryptanalyst, Special Agent Arthur Eberhardt.
	   (Government Exhibit No. 213.) In the letter, the defendant
	   Weigand reiterated the information which he had given on

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

	140/ Handwriting expert James Miller concludes that
	it is "probable" that the defendant Weigand wrote the signature
	"Dick" on pages one and four of the document, and that the
	initial next to the title "DG US" on the first letter was
	written by the defendant Heldt. Mr. Meisner recognizes both
	signatures as having been written by the defendant Weigand,
	and the initial in question as having been written by the
	defendant Heldt.

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

					   195
					
	that same date to the defendant Hubbard. 141/  On July
	2, 1976, the defendant Hermann/Cooper inquired of the defendant
	Weigand whether the defendant Hubbard in her letter of July
	1, 1976 "is looking toward Silver [Wolfe] denying the use of
	the false ID card and then it not being able to be proven
	that he had actually used one." (Government Exhibit No.
	121.) 142/   The defendant Hermann/Cooper recommended that
	"we go ahead with the worked out cover story".

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

	141/ See Government Exhibit No. 119 at pp. 1, 3-4. A
	copy of Government Exhibit No. 120 was sent to CSG Assistant
	for Information Jimmy Mulligan who, on July 6, 1976, requested
	the defendant Weigand to provide him with translations of the
	Code. The defendant Weigand responded in a letter dated July
	13, 1976.  See Government Exhibit No. 122.  Government Exhibits
	Nos. 119, 120, and 122 were seized by Special Agent Brunson
	from the area outside the defendant Raymond's office at the
	Cedars Complex.  Mr. Meisner identifies the signature "Jimmy"
	On the 6 July letter as having been written by Mr. Mulligan.

	142/ Government Exhibit No. 121 was seized by Special
	Agent Brunson from the office of the defendant Raymond at the
	Cedars Complex.  Mr. Meisner identifies the signature on the
	July 2 letter as having been written by the defendant Hermann/
	Cooper.

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

				196


			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.
		
		On July 28, 1976, the defendant Wolfe appeared with his
	   attorney, Lawrence Speiser, Esquire, before United States
	   Magistrate Henry H. Kennedy, Jr. for a preliminary hearing.
	   Following that hearing, United States Magistrate Kennedy
	   found that probable cause existed, and ordered the case "bound
	   over for the action of the Grand Jury".  A few days later, on
	   August 5, 1976, Magistrate Kennedy issued a sealed warrant
	   for the arrest of Michael Meisner for the use of a forged
	   official pass of the United States, in violation of 18 U.S.
	   Code, Section 499.  (U.S. Mag. No. 1101-76M(Cr)).  In mid-
	   August, CSG Assistant for Information Jimmy Mulligan informed
	   Mr. Meisner that the defendant Thomas had overheard a
	   conversation in Mr. Paul Figley's office at the Department of
	   Justice in which it was stated that a sealed arrest warrant
	   had been issued in the District of Columbia.  On August
	   30l FBI Special Agents Joseph Jackson and John Pavlansky went

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

					    197

	    to the offices of the Church of Scientology at 2125 S Street,
	    N.W., in Washington, D.C., to attempt to locate Mr. Meisner.
	    They were met there by Assistant Guardian for Legal Bureau
	    Kendrick "Rick" Moxon.  They explained to Mr. Moxon that they
	    were acting on behalf of the Office of the United States
	    Attorney for the District of Columbia and were attempting to
	    locate Mr. Meisner because an arrest warrant had been issued
	    for him on August 5, 1976, charging him with forgery of United
	    States Government identification cards.  They told Mr. Moxon
	    that they wanted to inform him and all others concerned of
	    Mr. Meisner's status so that they could notify him and help
	    him "avoid putting himself in a fugitive status". They
	    warned Mr. Moxon that anyone who aided Mr. Meisner in remain-
	    ing a fugitive "would be guilty of a criminal act under the
	    harboring of criminals statute."  Mr. Moxon informed the
	    agents that he did not know where Mr. Meisner was. Mr.
	    Moxon immediately notified his superior, Mary Rezzonico, the
	    Deputy Guardian for the Legal Bureau in the United States, and
	    appended to that letter the harboring of fugitives statute,
	    emphasizing that it provided for a penalty of 15 year sentence

- ---------------------------------------------------------------------
					     
					     198
	    
	    and $2,000 maximum fine" (Government Exhibit No. 123.) 143/


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


	     On August 30, 1976,  the same day that he received
	notification that an arrest warrant had been issued for Mr.
	Meisner, the defendant Weigand notified the defendant Mary
	Sue Hubbard that he has "Just received word that Mike [Meisnerl
	had a warrant out for his arrest." He added that "[tlhe plan
	at this time is to hide Mike out.  It appears that the safest
	place to do this is in Europe somewhere." (Government Exhibit
	No. 124.) 144/ The defendant Weigand added:

		       My actions are as follows:

- --------------------
		      
	143/ Government Exhibit No. 123 was seized by Special
	Agent Brunson from a file cabinet in Room 10 at the Cedars
	Complex. Mr. Meisner identifies the signature on that exhibit
	as that of Mr. Moxon with whom he had worked closely for two
	years. He also recognizes the initials of the defendant
	Weigand in the routing portion of the letter.

	144/  Government Exhibit No. 124 was seized by Special
	Agent Brunson from a file cabinet in Room 10 in the Information
	Bureau at the Cedars Complex.

- ---------------------------------------------------------------------
					
				    199
				       
		    1. Immediately remove M [Meisnerl from
		    all GO connected spaces and get him into
		    a motel.

		    2. Further alter his appearance.

		    3. Get with legal for legal opinion
		    to include what the statue [sic] of
		    limitations is on this offence.

		    4. Work out how to obtain M the neces-
		    sary papers to get him out of the country.

		    5. Obtain the papers.

		    6. Get him out of the country.

	The defendant Mary Sue Hubbard responded to the defendant
	Weigand's letter as follows:


		    Wonder how they got a lead onto him?
		    
		    On getting him abroad, unless you have
		    good ID for him different than his own,
		    it might be dangerous.  _He would better
		    be "lost" in some large city where it
		    would be difficlut [sic] to find him_.

		    What a shame. (Emphasis added.)

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

	(Government Exhibit No. 124 at p. 2.)    On September 2, the
	defendant Weigand responded to the defendant Hubbard's inquiry
