NOTES:

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

2. A "CSW" (completed staff work) is a request to a  senior official for approval or disapproval of proposed action.

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

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

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

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

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

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

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

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

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

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

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

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

15. During the lawful execution of United States Magistrate search warrants upon premises of the Church of Scientology of California known as the Cedars Complex on July 8, 1977 Federal Bureau of Investigation Special Agent Eusebic Benavidez seized a black suitcase containing electronic bugging devices from the office of the defendant Gregory Willardson. These included Exhibits 190 to 194. See photograph marked Government Exhibit No. 217 appended hereto. Federal Bureau of Investigation Agent James O. Davis, assigned to the laboratory at FBI headquarters and an expert on electronic bugging devices, concludes that Government Exhibit No. 190 is an FM radio monitor; Government Exhibit No. 191 is an electronic device in a gold colored box which he found to be “a miniature transmitter primarily used for the surreptitious interception or oral communications”; and Government Exhibit No. 192 is a battery connection which he concluded was a “miniature frequency modulated radio transmitter.” Agent Davis also finds that Exhibit No. 193 is a telephone resonator which he describes as a “transmitter unit from a standard phone handset.” It also allows one to use a standard FM radio to monitor phone conversation. Government Exhibit 194 is a wall receptacle which Agent Davis states is a “miniature frequency modulated radio transmitter concealed in a standard three-plug wall receptacle,” and which would allow the user to employ a standard FM radio for monitoring purposes. Agent Davis concludes that in his opinion all these items are “primarily used for the surreptitious interception of oral communications.”

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

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

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

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

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

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

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

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

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

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

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

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

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

29. The signature “Greg” on page one has been positively identified by handwriting analysis as that of the defendant Willardson. Similarly, the handwritten notation “sent to DC, late May. GW” at the lower right-hand corner of that page has also been positively identified as having been written by the defendant Willardson. Handwriting expert James Miller has concluded that it is “highly probable” that the defendant Richard Weigand wrote the handwritten notation “Greg – What was this? L. Dick” located at the top of the page. Mr. Meisner identifies the handwritten notation “A very good method!” located above the title of the letter, as in the handwriting of Mo Budlong, and the handwritten notation “Dear Greg, This is a really bright idea. Very well done. love Jane” located at the lower portion of the letter, as in the handwriting of Jane Kember. The routine appearing in the upper left-hand side of Government Exhibit No. 14 also shows that the letter was written by the “Br I Dir US Info”, the defendant Gregory Willardson, and sent to the “Guardian WW,” Jane Kember via, among others, the “DG I WW”, Mo Budlong, who initials it on “22/4″ (April 22), the “DG US”, the defendant Henning Heldt, who initials it as well, “DDG US” the defendant Duke Snider, who initials it and dates it “9.4″ (April) and the “DG I US”, the defendant Richard Weigand immediately below the title “Br I Dir US info” at the bottom of the routing is an arrow with the initials “GW” which have been identified by the handwriting expert as probably made by the handwriting of the defendant Willardson.

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

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

31. Government Exhibit No. 15 was seized by Special Agent Smith from Room 4 of the Information bureau at the Cedars Complex. It was inventoried by Special Agent Valencia.

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

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

34. Government Exhibit No. 16 is a "purchase order" dated "14 May 1975," signed by the defendant Gregory Willardson whose signature "Greg W," along with all other handwriting on the first page of that exhibit, is positively identified by the expert handwriting analyst James Miller as being that of the defendant Willardson. In his "purchase order", the defendant Willardson requests $3,141.20 for one week of supplies for GO 1361 documents. He states that his purpose in purchasing the photocopying equipment listed in the attach- ments to Government Exhibit No. 16 is "to get vital data uplines to WW (World Wide) & CS-G [the defendant Mary Sue Hubbard]; and to get it properly x-filed for use by USGO, WW, CS-G.” The page identified by the seizing agent as “3 of 8″ , at its bottom right-hand corner is a form entitled “EPO” (Estimated Purchase Order) dated “12 May 1975″ covering the months of May to June of 1975, requesting that “$6,648.10″ be set aside by the Financial Planning Committee of the United States Guardian’s Office for the purchase of “materials needed” “to eliminate vital info backlogs on GO 1361.” This form is signed “GW” next to the printed entry “originator”. Handwriting analysis has positively identified the defendant Willardson as the writer or the “bulk of the writings” on that page. Mr. Meisner has often used, such Purchase orders as well as Estimated Purchase Order forms during his tenure as an official of the Information Bureau of the Guardian’s Office, and is therefore familiar with the proper format and manner in which such forms are to be completed according to Guardian’s Office procedures. He states that Government Exhibit No. 16 was prepared in accordance with these policies. Government Exhibit No. 16 was seized by Special Agent Smith, from Room 4 of the Information Bureau at the Cedars Complex. It was inventoried by Special Agent Valencia.

35.  Government Exhibit No. 17 was seized by Special Agent Peter J. Flannigan from a file cabinet in room 23 of the Cedars Complex. Government Exhibits 19, 21, 24 and 2830 were seized by Special Agent Bradley N. Maryman from the file cabinet in one of the hallways of the Information Bureau at the Cedars Complex. Government Exhibit No. 20 was seized by Special Agent Stanley R. Currey from a file cabinet located in room 30 (the Archives room) at the Cedars Complex. Govern- ment Exhibits 22, 23 and 27 were seized by Special Agent Edward J. Miller from a file cabinet. located in room 30 at the Cedars Complex. Government exhibit No. 25 was seized by Special Agent Henry Williams from a shelf adjacent to the desk of the defendant Cindy Raymond in room 15 at the Cedars Complex. It was inventoried and initialed by Special Agent Raymond Mislock. Government Exhibit No. 18, which was seized by Special Agent Maryman from a file cabinet in one of the hallways in the Information Bureau at the Cedars Complex, is the folder which contained Government Exhibits Nos. 18, 19, 21, 24 and 28 to 30.

36. Government Exhibits Nos. 17, 19, 25, 27, and 29, 30 all have identical routing. They were sent by Mr. Meisner to the Collection Officer U.S., the defendant Cindy Raymond, via the Assistant Guardian for the District of Columbia Lynn McNeil, and, among others, the Deputy Guardian of the United States, the defendant Heldt, the Deputy Guardian for Informa- tion U.S., the defendant Weigand, and the Information Branch I Director U.S., the defendant Willardson, with a copy to the Commodore Staff Guardian, the defendant Mary Sue Hubbard. Government Exhibit No. 28 added to the routing the Information Branch II Director, U.S. Mr. Meisner identifies the initials in the handwriting of the defendant Heldt as appearing next to his title "DG US" in the routing portion of Government Exhibit Nos. 17, 21, 23, 25, 27 and 29. He also identifies the initials and date appearing on Government Exhibits Nos. 17, 19, 25 and 27, 30 as in the handwriting of the defendant Willardson. Additionally, he identifies the note on Government Exhibits Nos. 28, 30 appearing next to the initials "GW" as in the handwriting of the defendant Willardson. Handwriting expert James Miller positively identified the initials, date and handwritten notes appearing on Government Exhibits Nos. 28, 30 as being in the handwriting of the defendant Willardson. Mr. Meisner further identifies the initials and date appearing next to "Coll Off US" on Government Exhibit No. 17 as having been written by the defendant Cindy Raymond and the printing at the bottom of page one of Government Exhibit No. 27 as the handwriting of the defendant Raymond.

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

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

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

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

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

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

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

44. Handwriting expert James Miller positively concludes that the bulk of the letter is in the handwriting of the defendant Willardson.

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

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

47. The routing in the upper left-hand side of both Government Exhibits Nos. 36 and 38A conforms to the required routing procedure of the Guardian's Office and are identical in form. In Government Exhibit No. 38A, Mr. Meisner identifies the initials next to his title "DG US" as the handwriting of the defendant Heldt; both the initials next to the title "Info Br I Dir US" and the handwritten notation immediately beneath it as the handwriting of the defendant Willardson. Mr. Meisner also identifies as the defendant Willardson's handwriting the notation that "sent to WW [World Wide]“, which indicates that it was forwarded to the Guardian’s Office in England.

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

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

50.Government Exhibits Nos. 41 and 42 were seized by Special Agent Smith from Room 4 at the Cedars Complex.

51. They are respectively identified in the routing as the Deputy Deputy Guardian U.S. and Deputy Guardian for Information U.S.

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

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

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

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

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

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.

59. Mr. Meisner identifies handwriting of the defendant Raymond 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.

61. They are summarized as follows: Government Exhibit 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.

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

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

64. 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 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.

 

 

 

 

 

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. 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.

68. The other operating targets under GPgmO 158 include moving existing of agents in the District Attorney's Office 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 subpeona. 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.)

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.

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

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 Goverment 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.

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 positively identifies the fourteen-line handwritten notation as well as the initials "CR, 28 March 76" on the Hermann lettcr 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 signiture 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.

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
Extiibit 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."

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.

7. See Govovernment Exhibit No. 57, a letter dated 3 Febuary 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 refered to the Alverzo forced entries into IRS as well as subsequent areas entered by the defendant Wolfe.

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 Coursel, 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.

80. 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 Wiilardson.

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

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

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

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.

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.

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

Warning

Issued for identification of holder. Improper use, possesion, 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.

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 .1o:;eph 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".

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, Cincinatti, 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".

91. Government Exhibit No. 66 was seized by Special Agent Gilberto Valencia from Room 4 in the Infomation 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 .lo. 65 wa.-3 :-,(-,ized by Agent Valencia from Room 4 in the Information Bureau at the Cedars Complex.

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

95. Mr. Meisner and Ms. Hirsch state thate 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.

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

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 protion 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 Ccdars Complex.

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.

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 recognzes 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.

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

103. Government Exhibit No. 78 was seized by Special Agent Harold Brunson from a file cabinet immediately ouside 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 wsa inventor- ied and initialed by Special Agent Napier.

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.

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.

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

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

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.

110. 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 seperate 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.

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.

112. Government Exhibits No. 87 was seized by Special Agent Blade R. Johnson from a file cainet in the Information Bureau at the Cedars Complex. Government Exhibits Nos. 88-92 were seized by Special Agent William A. Cohendet froom 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" 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 Governnent 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 preposed  draft bill relating to Interpol. (Government Exhibit No. 94.) Government Exhibit Nos. 93 and 94 were seized by  Special Agent Martin A. Gonzeles from a file cabinet in the defandant Raymond's office at the Cedars Complex.

115. "Pages 1a and 2a" were retyped by Mr. Meinser 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.

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.

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.

119. "JUDY action" was a referance 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.

120. Handwriting ecpert 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 regognizes the signature as  being in the handwriting of the defendant Weigand.

121. See Government Exhibit No. 2, supra.

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.

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.

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

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.

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

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 initialling 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 conlusions 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 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 signtures 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.

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.

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 differant methods of a substitution code - "digital" and "word or phrase". The "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. SeeGovernnent 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.

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.

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.

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.

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.

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.

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

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.

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.

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.

145. Handwriting expert James Miller concludes that it is "probable" that the signature "Dick" was written by the defendant Weigand, and that the initials next to the title "DG US" on the August 30 and September 2 letters were written by the defendant Heldt. Mr. Meisner recognizes the signature of the defendant Weigand and the initial of the defendant Heldt.

146. Government Exhibit No. 125 was seized by Special Agent Brunson from a file cabinet outside the office of the defendant Raymond in Room 15 at the Cedars Complex. Mr. Meisner was ordered to change his appearance so as to create "the image of an aging guy wanting to look hip as a means of regaining his youth a bit," to wear a "mod wardrobe," to shave his head, to wear contact lenses, to have a tooth capped, to lose or gain some weight, and to wear earth shoes to change his posture.

147. Government Exhibit No. 126 was seized by Special Agent Brunson from a file cabinet outside the defendant Rayinond's office at the Cedars Complex.

148. Mr. Meisner identifies the handwritten notations on the lower half of this letter as having been written by the defendant Hermann/Cooper.

149. The defendant Weigand's perception in this regard was, of course, erroneous.

150. Government Exhibit No. 127 was seized by Special Agent Brunson from a file cabinet outside the defendant Raymond's office at the Cedars Complex. Mr. Meisner identifies the initials next to the words "Info" and "Return" as having been written by the defendant Heldt.

151. Government Exhibit No. 128 was seized by Special Agent Brunson from a file cabinet located outside the defendant Raymond's office at the Cedars Complex. Mr. Meisner identifies the handwriting around the caption of the September 21, 1976 letter, from the defendant Hermann/Cooper to the defendant Weigand, as that of the defendant Hermann/Cooper.

152. See also Government Exhibit No. 129. Handwriting expert James Miller is "positive" that all of the handwriting on the Snider letter marked Government Exhibit No. 129A is in the handwriting of the defendant Snider. He is "positive" that the handwritten notation signed "Duke" on Government Exhibit No. 129B is in defendant Snider's handwriting. He also concludes that the handwritten notation signed "Love Cindy", as well as the initials and date next to the "natl sec" entry on Government Exhibit No. 129, are positively in the handwriting of the defendant Raymond. Government Exhibit No. 129 was also seized by Special Agent Brunson from a file cabinet outside the defendant Raymond's office at the Cedars Complex. In fact, Special Agent Christine Hansen requested the FBI Field Office in San Diego, California, to question police lieutenant Warren Young, and follow the lead, given by him, that Mr. Meisner was in that city. This false lead diverted the resources of the FBI in the instant investigation to yet another city.

153. Government Exhibit No. 131 was seized by Special Agent Henry L. Williams from the desk of the defendant Cindy Raymond at the Cedars Complex. It was inventoried and initialed by Special Agent Raymond Mislock.

154. Government Exhibit No. 132 was seized by Special Agent Raymond Mislock from a file cabinet located in Room 30 of the Information Bureau at the Cedars Complex.

155. The other buildings listed in that letter include the Post Office, the Labor Department's National Office, the Federal Trade Commission, the Department of the Treasury, the U.S. Customs Building, the Drug Enforcement Administration, the American Medical Association's law firm offices in Washington D.C., and the offices of the law firm representing the St. Petersburg Times, also in Washington, D.C. Handwriting expert James Miller concludes that it is "highly probable" that the signature "Dick" at the end of the October 8 letter was written by the defendant Weigand. Mr. Meisner, himself, recognizes that signature as in the handwriting of defendant Weigand, and explains that the initials "DW/jf" to the left of the signature are those of the defendant Weigand and his communicator (secretary) Janet Finn.

156. For another series of letters to the defendant Mary Sue Hubbard discussing the District of Columbia incident and the Wolfe/Meisner situation, see Government Exhibit No. 130, which includes a "CSW" from Mr. Meisner to the defendant Hubbard as well as memoranda from the defendant Hermann/Cooper to the defendant Hubbard. Mr. Meisner states that the defendant Hcrmann/Cooper's handwriting appear in the following locations: the word "secret" at the top of page one, and the signature on the last page. Government Exhibit No. 130 was seized by Special Agent Brunson from a file cabinet outside the defendant Raymond's offices.

157. Government Exhibits Nos. 133 and 134 were seized by Special Agent Brunson from a file cabinet in room 10 at the Cedars Complex.

158. Handwriting expert James Miller concludes that it is "probable" that the handwritten initials next to the words "mission approved" on page one of Government Exhibit No. 134 were written by the defendants Heldt and Weigand. Similarly, Mr. Miller finds it "probable" that the initials and date next to the title "DG Info US" on page one are in the hand- writing of the defendant Weigand, and the initial next to item 2 (vital targets) on page two is probably in the handwriting of the defendant Heldt. Mr. Meisner identifies those initials as in the handwriting of the defendants Weigand and Heldt respectively, as he does all of the handwriting on page three as that of the defendant Hermann/Cooper. Mr. Meisner also identifies the signature "Mike" at page one of Government Exhibit No. 134 and the handwriting on pages three and five of Government Exhibit No. 133 as that of the defendant Hermann/Cooper.

159. Government Exhibit No. 137 was seized by Special Agent Brunson from a file cabinet located outside the office of the defendant Raymond.

160. Government Exhibit No. 135 was seized by Special Agent Brunson from a file cabinet in Room 10 in the Information Bureau at the Cedars Complex. Mr. Meisner identi- fies the handprinting on that letter above the typewritten words as being in the handwriting of the defendant Raymond. He further recognizes the initial next to the title "DG US" as having been written by the defendant Heldt.

161. Government Exhibit No. 136 was seized by Special Agent John C. Kammerman from Room 15 in the Information Bureau at the Cedars Complex. It was inventoried and initialed by Special Agent Michael Ray Napier.

162. Government Exhibit No. 138 was seized by Special Agent Kammerman from a file cabinet in Room 15 in the Information Bureau at the Cedars Complex. It was initialed by Special Agent Napier.

163. Government Exhibit No. 139 was seized by Special Agent Kammerman from a file cabinet in Room 15 in the Information Bureau at the Cedars Complex. It was initialed by Special Agent Napier. At that time, the defendant Raymond held the position of National Secretary for the Information Bureau in the United States. Mr. Meisner identifies the handwritten word "Secret" at the top of page one as having been written by the defendant Hermann/Cooper. During this time Mr. Meisner was undergoing regular auditing pursuant to the directive of the defendant Heldt. See Government Exhibit No. 140. Handwriting expert James Miller concludes as follows: "positive" that the word "handroute" at the top of page one and the notation "cc: DDGUS . . . ." in the routing portion also on page one were in the handwriting of the defendant Raymond; "positive" that the handwritten notation in the upper right-hand portion of page two, the 28 November 1976 letter from the defendant Heldt, as well as the signature on that page were written by the defendants Raymond and Heldt respectively; "positive" that the notation to "Cindy" in the upper part of page three was written by the defendant Heldt; "positive" that the notation "(enemy formula)" at the bottom of page six was written by the defendant Raymond; "positive" that the notation "CR: note no folders . . . ." two-thirds down on the eleventh page was written by the defendant Raymond; "positive" that the notations in the left margin were written by the defendant Raymond; "positive" that the handwritten routing on the reverse of page seventeen and the notation at the top of page eighteen were written by the defendant Raymond. Government Exhibit No. 140 was seized by Special Agent Brunson from a file cabinet in Room 10 of the Cedars Complex.

164. Government Exhibit No. 141 was seized by Special Agent Brunson from a file cabinet outside Room 15 at the Information Bureau at the Cedars Complex. It was inven- toried and initialed by Special Agent Napier.

165. Handwriting expert James Miller concludes that it is "highly probable" that the writing "Love, Dick" at the end of that letter is that of the defendant Weigand. Government Exhibit No. 142 was seized by Special Agent Brunson from a file cabinet outside Room 15 in the Cedars Complex. It was inventoried and initialed by Special Agent Napier.

166. As mentioned _supra_, at page 212, a previous Grand Jury of that Court had, in October, issued a subpoena directing the Church of Scientology to surrender the personnel records and exemplars of Michael Meisner's known handwriting. See also Government Exhibit No. 214 for the Grand Jury docket entry reflecting Agent Hansen's appearance.

167. See page five of Government Exhibit No. 143 and compare to Government Exhibit No. 141 at page 2 et seq. Handwriting expert James Miller concludes that it is "highly probable" that the signature "Love, Mike" at page four was written by the defendant Hermann/Cooper. Mr. Meisner identi- fies that signature, as well as the one on page six, and the handwriting in the routing portion of page one as having been written by the defendant Hermann/Cooper. A copy of Government Exhibit No. 143 was sent to the "CSG", defendant Mary Sue Hubbard, and to the defendant Raymond. Government Exhibit No. 143 was seized by Speical Agent Kammerman in a file cabinet In Room 15 of the Cedars Complex. It was inventoried and initialed by Special Agent Napier.

168. Handwriting expert James Miller has reached the following conclusions: "positive" that the notation "Cindy's copy" on page one, the entire fourteen-line handwritten notation on page two, and the notations in the right- hand margins of pages three, four and seven, are all in the handwriting of the defendant Raymond. Mr. Meisner also identifies the notation in the left-hand margin of page one as having been written by the defendant Raymond, and the notation in the upper portion of page 5 as having been written by the defendant Hermann/Cooper. Government Exhibit No. 144 was seized by Special Agent Kammerman from a file cabinet in Room 15 in the Inform-ation Bureau in the Cedars Complex. It was inventoried and initialed by Special Agent Napier.

169. During the same period the defendant Hermann/Cooper requested Paul Klopper the Lecal Branch II Director U.S., to research whether the United States Attorney's Office could still conduct a grand jury investigation if the defendant Wolfe entered a guilty plea. (Government Exhibit No. 145.) Govern- ment Exhibit No. 145 was seized by Special Agent Aldrich from a file cabinet in the office of the defendant Willardson at the Cedars Complex. Government Exhibit No. 146 was seized by Special Agent Kammerman from a file cabinet in Room 15 of the Information Bureau at that complex. The latter document was inventoried and initialed by Special Agent Napier. Mr. James Miller, the handwriting analyst, concludes that it is "probable" that the signature "Mike" on Government Exhibit No. 146 was written by the defendant Hermann/Cooper. Mr. Meisner identifies that signature as that of the defendant Hermann/Cooper.

170. Rule 4(a)(1) of the _Rules of the United States District Court for the District of Columbia_ provides that indictments are to be returned within forty-five days of any arrest which occurred prior to July 1, 1976.

171. See Government Exhibit No. 147 at page three where the defendant Raymond indicated that the defendant Hermann/ Cooper "was badly suppressing the lines and giving no or false information, keeping both Legal and BI in a confusion as to exactly what to do." Government Exhibit No. 147 was seized by Special Agent Brunson from a file cabinet outside Room 15 of the Cedars Complex. It was inventoried and initialed by Special Agent Napier.

172. During the few months prior to March 1977, the defendant Raymond had shown Mr. Meisner much of the correspondence within the Guardian's Office concerning ongoing research for the cover-up. See, e.g., Government Exhibits Nos. 147A and 147B. Handwriting expert James Miller positively identifies the handwriting of the defendant Raymond on the following pages: page one - the notation "A Rush"; page two - the three- line handwritten notation in the middle of the first line; pages four, five and six - the handwritten notations; page nine - the handwriting at the bottom of the page; page thirteen - all writings in both margins; page seventeen - the handwritten notation in the upper portion of the right margin. Mr. Miller also positively identifies the initials and date next to the title "DG I US" in the routing portion of page one as being in the handwriting of the defend- ant Weigand. Moreover, Mr. Meisner identifies the initials next to the title "DG US" on that same routing as being in the handwriting of the defendant Heldt.

173. Government Exhibit No. 148 was seized by Special Agent Brunson from a file cabinet located outside Room 15 in the Information Bureau at the Cedars Complex. It was initialed and inventoried by Special Agent Napier. Handwriting expert James Miller positively identifies the defendant Heldt as the writer of the entire handwritten letter beginning at page six of this exhibit.

174. Government Exhibit No. 149 was seized by Special Agent Aldrich from a file cabinet in the defendant Willardson's office in the Cedars Complex.

175. By memorandum dated 12 April 1977, Brian Andrus informed the defendant Weigand that Mr. Meisner (Herb) had inquired about the delay in receiving a response from the defendant Weigand to his letter of 7 April 1977. (Government Exhibit No. 150.) In a handwritten note on that memorandum, the defendant Weigand responded that he had not as yet read Mr. Meisner's letter, and that he wished to receive Andrus' and Raymond's proposals before responding. The handwriting analyst, Mr. James Miller, concludes that it is "probable" that that notation was written by the defendant Weigand. Mr. Meisner identifies that notation, and the initials next to the title "DG I US", as having been written by the defendant Weigand. He also recognizes the signature on the memorandum as that of Mr. Andrus. Government Exhibit No. 150 was seized by Special Agent Henry Williams in the defendant Raymond's desk at the Ccdars Complex. It was inventoried and initialed by Special Agent Mislock.

176. Government Exhibit No. 151 was seized by Special Agent Henry Williams fron the defendant Raymond's desk at the Cedars Complex. It was inventoried and initialed by Special Agent Mislock.

177. Government Exhibit No. 152 was seized by Special Agent William R. Stovall from the defendant Heldt's desk at the Fifield Manor. Mr. Meinner identifies the whole letter as being in the handwriting of Ms. Kember.

178. Handwriting expert James Miller positively concludes that the defendant Heldt was the writer of the two letters to Mr. Andrus contained in Government Exhibit No. 153. That exhibit was seized by Special Agent Williams from Room 15 in the Information Bureau at the Cedars Complex. It was inventoried and initialed by Special Agent Mislock.

179. Government Exhibit No. 154 was seized by Special Agent William R. Stovall from defendant Heldt’s desk at the Fifield Manor. Mr. Meisner identifies the signature on page five as having been written by Mr. Andrus.  On April 28, Mr. Andrus spoke to the defendant Wolfe and was informed that it was impossible to withdraw the waiver of the rule requiring an indictment within 45 days of arrest. (Government Exhibit No. 155.) That exhibit was also seized by Special Agent Stovil from the defendant Heldt’s desk.

180. Government Exhibit No. 156 was seized by Special Agent Stovall from the defendant Heldt’s desk. Mr. Meisner recognizes Ms. Rezzonico’s signature at page three of that letter.

181. Handwriting expert James Miller concludes that the entire letter was written in the defendant Heldt's handwriting. The letter was seized by Special Agent Stovall from the defendant Heldt's desk at the Fifield Manor.

182. Government Exhibit No. 158 was seized by Special Agent Hillman from Room 15 in the Information Bureau at the Cedars Complex. It was inventoried and initialed by Special Agent Gonzales.

183. Government Exhibit No. 159 was seized by Special Agent Daniel P. LeVine from the defendant Heldt's desk at the Fifield Manor.

184. For a detailed report of that meeting, see Govern- ment Exhibit No. 160. That exhibit was seized by Special Agent Frederick S. Hillman from a file cabinet in the defendant Raymond's office. It was inventoried and initialed by Special Agent Martin A. Gonzalez.

185. See Government Exhibits Nos. 161 and 162 at pages four. The second document is a coded version of the first one. They were both seized by Special Agent Aldrich from the defendant Willardson’s office. Mr. Meisner identifies the signature “Brian” on pages four and eight as having been written by Mr. Brian Andrus.

186. This incident is detailed by the defendant Weigand in a 2 May 1977 letter, to Mr. Budlong (Government Exhibits Nos. 161 and 162.) The routing on that letter indicates that copies of it were sent to the defendants Mary Sue Hubbard and Henning Heldt, and to GWW Jane Kember.

187. In that "CSW", the defendant Raymond requested $202.48 for Mr. Meisner's guards' expenses, including food, and a fine for one of the guard's car, which had been towed. Handwriting expert James Miller positively identifies the handwritten note at the top of page one next to the title "DG US" as having been written by the defendant Raymond. Mr. Miller further identifies the initial next to Mr. Heldt's title and next to the word "approved" on page two as probably having been written by the defendant Heldt. Mr. Meisner identifies that initial as having been written by the defendant Heldt. He also recognizes the signature at the bottom of page two and the handwriting on that page as that of the defendant Raymond. Mr. Miller also positively identifies the following handwriting on the envelope appended to the end of the exhibit: ."A Rush" - positively written by the defendant Raymond; "Good - disp rec'd. Love H." - positively written by the defendant Heldt; the initial next to the title "DG US" - probably made by the defendant Heldt. Government Exhibit No. 163 was seized by Special Agent Hillman from the defendant Raymond's office at the Cedars Complex. It was inventoried and initialed by Special Agent Gonzalez. An additional request for funding for Mr. Meisner's guards was made by Acting Collections Officer Jim Douglass to the defendant Heldt on May 13, 1977. (Government Exhibit No. 166.) That request included money for food, gas, and a battery that was stolen from one of the guard's jeeps. Government Exhibit No. 166 was seized by Special Agent Hillman from Room 15 at the Cedars Complex. It was initialed by Special Agent Gonzales.

188. See Government Exhibit No. 164 at P. 3 et seq. That exhibit was seized by Special Agent Aldrich from the defendant Willardson's office at the Cedars Complex.

189. Meisner’s account of the events of the first days in May is corroborated by the defendant Weigand in a letter to Mr. Budlong, by Mr. Andrus in a letter to the defendant Heldt, (see Government Exhibit No. 164), and by the defendant Weigand in a letter, dated May 8, 1977 to the defendant Heldt. (See Government Exhibit No. 165.) According to Mr. Miller, the handwritten letter signed “H” and addressed to “Herb”, located at page six and seven of Government Exhibit No. 164, was written in its entirety by the defendant Heldt. Mr. Meisner concurs in that finding. Handwriting expert Miller, concludes that the defendant Heldt wrote the note to Brian Andrus on the 5 May 1977 letter appended to the Government Exhibit No. 165. Mr. Miller also finds that it is “probable” that the defendant Heldt wrote the initial next to the title “DG US” on that letter. Mr. Meisner identifies that initial as having been written by the defendant Heldt. Furthermore, he recognizes the signature at the end of that letter as having been written by Mr. Brian Andrus.

190. In a letter dated 13 May, the defendant Willardson instructed the defendant Raymond to take control of the guards. He complained that they could not involve any more Information Bureau personnel in this matter. See Government Exhibit No. 167. Page four of that exhibit included a weekend guard schedule for “Herbert” (Mr. Meisner). It listed the following individuals as guards: Jim Douglass, Chuck Reese, Peeter Alvet, John Lake, George Pilat, and Gary Lawrence. Handwriting expert James Miller concludes as follows: “positive” that the first two pages were handwritten by the defendant Willardson; “positive” that the notation on the third page from “Cindy” to “Greg” was written by the defendant Raymond; and “positive” that the handwritten notation on the last page addressed “Dear Cindy” was written by the defendant Willardson. Government Exhibit No. 167 was seized by Special Agent Hillman from Room 15 at the Cedars Complex. It was inventoried and initialed by Special Agent Gonzales.

191. The defendant Raymond immediately notified her new superior, Temporary Deputy Guardian for Information US (T/DG I US) Brian Andrus, of Mr. Meisner’s telephone call to her and of the defendant Heldt’s telephone discussion with Mr. Meisner that evening. She concluded that “[t]he only thing I can think of is that we work a _cover_story_ that he is trying to blackmail the Church for money by pretending that the Church harbored him for the last months making the Church a party to the crime.” (Emphasis added.) (Government, Exhibit No. 168.) That same day, the defendant Raymond sent Ms. Mary Rezzonico (DG L US) a letter requesting her to brief the thirteen people who had had contact with Mr. Meisner and who knew he had been harbored by Scientology. ( See Government Exhibit No. 169.) Both documents were seized by Special Agent Williams from a desk in Room 15 in the Information Bureau in the Cedars Complex. They were inventoried and initialed by Special Agent Mislock. Handwriting Expert James Miller positively identifies the handwriting on pages three and five of Government Exhibit No. 168 as having been written by the defendant Raymond.

192. Government Exhibit No. 170 was seized by Special Agent Williams from a desk in Room 15 at the Cedars Complex. It was inventoried and initialed by Special Agent Mislock. Mr. Meisner identifies the handwriting notation “changed by verbal order” as having been written by the defendant Raymond, and the signature “Brian” as having been written by Mr. Andrus.

193. United States District Court Clerk James F. Davey states that the records of that court reveal that the October 1976 Grand Jury had been sworn in on October 13, 1976, and was authorized to conduct investigations and hear evidence on behalf of the Court on June 10, 1977. Its term did not expire until April 1978.

194. The underscored portions of the declarations of the defendant Wolfe were material to the Grand Jury and the Indictment charges that the Defendant Wolfe “then and there well knew, were false.”

195. The complete transcript of Mr. Wolfe’s Grand Jury testimony is submitted to the Court as evidence, and is incorporated as part of this record. See Government Exhibit No. 215.

196. Government Exhibit No. 173 was seized by Special Agent William R. Stovill from the defendant Heldt’s desk at the Fifield manor.

197. Mr. Meisner identifies the handwriting of the defendant Raymond at page five, the margins at page ten, eleven, thirteen, twenty-one through twenty-four and at the bottom of page twenty-six.

198. Government Exhibit No. 173 was seized by Special Agent Levine from the defendant Heldt's desk at the Fifield manor.

199. Appended to the Wolfe Grand Jury debrief were two newspaper clippings from the Washington Post and Washington Star, regarding Wolfe’s sentencing.

200. Handwriting Expert James Miller has positively identified the defendant Heldt as the writer of the entire letter marked Government Exhibit No. 171.

201. Government Exhibit No. 172 was seized by Special Agent Williams from a desk in room 15 of the Information Bureau in the Cedars Complex. It was inventoried and initialed by Special Agent Mislock. Mr. Meisner identifies the signature at the end of that letter as that of Mr. Andrus.

202. Government Exhibit No. 174 was seized by Special Agent Williams from a desk in Room 15 in the Information Bureau in the Cedars Complex. It was inventoried and initialed by Special Agent Mislock.

203. Government Exhibit No. 175 was seized by Special Agent Aldrich from the defendant Willardson’s office in the Cedars Complex. Handwriting Expert James Miller concludes that it is “probable” that the signature “Greg” is in the handwriting of the defendant Willardson. Mr. Meisner identi- fied that signature as being in the handwriting of the defendant Willardson.

204. Government Exhibits Nos. 176 an 177 are identical. However, they were seized by the FBI from two different locations. Government Exhibit No. 176 was seized by Special Agent Levine from the defendant Heldt’s desk at the Fifield Manor; Government Exhibit No. 177 was seized by Special Agent Williams from the desk in Room 15 in the Information Bureau it the Cedars Complex. The later document was inven- toried and initialed by Special Agent Mislock.

205. Government Exhibit No. 177 was seized by Special Agent Aldrich from a file cabinet in the defendant Willardson's office at the Cedars Complex.

206. Brian Andrus, in a letter dated 22 June, 1977, informed the defendant Willardson that he had contacted Mr Meisner’s wife on June 21 and briefed her about her husband’s unauthorized departure from his apartment. She was ordered to notify Andrus immediately upon being contacted by Mr. Meisner. She was directed “not to take any instructions from him, but to simply ack[nowledge] him and contact me.” See Government Exhibit No. 132 seized by Special Agent Williams from a desk in Room 15 of the Information Bureau at the Cedars Complex. It was inventoried and initialed by Special Agent Mislock.

207. Government Exhibit No. 219 is the directive regarding "Red Box". It orders that "[a]ll the Red Box material from you areas must be centrally located, together in a movable container (ideally a briefcase), locked, and marked.” Appended to that document is the “Red Box Data Information Sheet” which defines “what is a Red Box?” Under that definition, “Red Box” includes:

a) Proof that a Scnist is involved in criminal activities.
b) Anything illegal that implicates MSH, LRH.
c) Large amount of non-FOI docs.
d) Operations against any government group or persons.
e) All operations that contain illegal activities.
f) Evidence of incriminating activities.
g) Names and details of confidential financial accts.

Government Exhibit No. 219 was seized by Special Agent Aldrich from the defendant Willardson's office in the Cedars Complex.

208. Government Exhibit No. 179 was seized by Special Agent Aldrich from a file cabinet in the defendant Willardson's office in the Cedars Complex. Handwriting expert James Miller positively concludes that the signature on that letter was written by the defendant Hubbard.

209. Handwriting expert James concludes positively that the notation on the lower part of that letter "Mary, Could you please clarify this? GW" was written by the defendant Willardson. Mr. Meisner identifies the four-lines of text signed "M" as having been written by Ms. Rezzonico.

210. Handwriting expert James Miller concludes that he is “positive” that the telex was written by the defendant Willardson. He also identifies the initials and letters “OK’d” next to the title “DG US” on the envelope appended to the telex as probably in the handwriting of the defendant Heldt. Mr. Meisner identifies the initials and letters as having been written by the defendant Heldt. Government Exhibit No. 180 was seized by Special Agent Aldrich from a file cabinet in the defendant Willardson’s office in the Cedars Complex.

211. Government Exhibit No. 181 was seized by Special Agent Williams from a desk in Room 15 of the Information Bureau in the Cedars Complex. It was inventoried and initiated by Special Agent Mislock.

212. Handwriting expert James Miller concludes that he is “positive” that the signature “Mary Sue” on the June 21 letter was written by the defendant Hubbard. He also stated that it is “probable” that the signature “Greg” on the June 22 letter was written by the defendant Willardson. Mr Meisner identifies both signatures as those of the defendants Hubbard and Willardson respectively. Government Exhibit No. 183 was seized by Special Agent Aldrich from a file cabinet in the defendant Willardson’s office at the Cedars Complex.

213. Government Exhibit No. 184 was seized by Special Agent Aldrich from a file cabinet in defendant Willardson’s office at the Cedars Complex

214. Government Exhibit No. 185 was seized by Special Agent LeVine in the defendant Heldt’s desk at the Fifield Manor. Mr. Meisner identifies the signature on that letter as having been written by the defendant Willardson.

215. Handwriting expert James Miller states that he is “positive” that the bulk of the letter was written by the defendant Hubbard.

216. Handwriting expert James Miller is “positive” that the entire letter was written by the defendant Heldt. Additionally, Mr. Miller finds that the envelope on page one of the series of letters was handwritten by the defendant Hubbard (”To: DG US, Frm: CSG”).