The Armstrong Op

Scientology's fair game on Gerry Armstrong

Introduction 

  • about the Armstrong Op
  • The Documents
    • Legal documents
    • IRS
    • FBI
    • Media articles
    • Cult documents
    • Correspondence
    • Other writings
  • The Loyalist Program
    • The Illegal Videos
  • Check Forgery Frame
    • Michael J. Flynn
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Mark Rathbun: The Juggernaut (May 28, 2013)

May 28, 2013 by Clerk1

 

Chapter Twenty-One

THE JUGGERNAUT  1 2

Juggernaut:   in colloquial English usage is a literal or metaphorical force regarded as mercilessly destructive and unstoppable.   – Wikipedia

For all of his alleged faults, L. Ron Hubbard was a keen observer and writer on the human condition. He once noted that “the bank follows the line of attack.”   “Bank” is Scientologese for the reactive mind, the stimulus-response portion of the mind that seeks destruction of others for survival of self.   With the devastating strike upon Ron and Scientology delivered in Los Angeles, all roads to L. Ron Hubbard’s bunker led through Flynn and Armstrong. It seemed that anyone with a score to settle was drawn like a magnet to the duo. Those combined forces took on the appearance of an overwhelming juggernaut.

The DOJ duplicated Flynn’s latest legal tactic: ask courts in Scientology litigation to order the church to produce L. Ron Hubbard as the “managing agent” of the mother church. Flynn assisted the DOJ to procure sworn declarations from his growing stable of former high-level official witnesses in support of the move.

David Mayo, the expelled former auditor to L. Ron Hubbard and erstwhile top technical authority in Scientology, had created a thriving Scientology splinter operation in Santa Barbara, California. Former high-level messengers – including two former Commanding Officers of CMO Int (Commodore’s Messenger Organization International) served as executives of his operation.   Until the Armstrong affair, they had steered clear of the L. Ron Hubbard-bashing Flynn/ FAMCO circles. But by 1984 they were supplying declarations to the DOJ and Flynn in support of their motions to compel Hubbard into depositions in lawsuits across the country.

Breckenridge’s Armstrong case decision, bolstered by a dozen declarations by former Hubbard messengers and aides, made the allegation of Hubbard’s “managing agent” status virtually uncontestable. Miscavige and Broeker were clearly established as the last links to Hubbard, but they could not provide countering declarations because it would subject them to depositions – which would lead Hubbard’s enemies directly to him.

Worse, the Breckenridge decision destroyed any chance of winning, in courts across the U.S., our vast array of pending motions to dismiss Flynn’s lawsuits on the basis of First Amendment rights to freedom of religion. The twenty-one-page Breckenridge indictment was devastating to our three years of expensive efforts at positioning much of the Flynn litigation for pre-trial dismissal.

Worse still, the decision pumped new life into what we thought by then to be criminal investigations losing steam. The Internal Revenue Service’s Criminal Investigation Division (CID) had been actively investigating the church, as well as LRH, Pat and Ann Broeker, David Miscavige and other church officials as named targets for criminal charges. Until the Breckenridge decision we had kept the CID somewhat at bay through litigation combatting their summons power, and a team of lawyers attempting to negotiate with IRS counsel and DOJ officials. But our intelligence lines were reporting that the LA-based CID group was once again gearing up to indict Hubbard and his aides.

The Ontario Provincial Police had, after their March, 1983 raid, steered clear of targeting Hubbard. Now they were reconsidering, in light of the outcome of the Armstrong case.

Our intelligence network reported that Gerry Armstrong was feeling drunk with power, given the sudden attention he’d received and his new importance in the anti-Scientology community. It seemed Armstrong and Flynn had worked their way up to being the axle to which all anti-Scientology spokes were linked. Per reports, Armstrong was talking of bringing all Scientology’s enemies together in a concerted effort to take over the church. The man who had prevailed in his case because of his alleged “fear for his life” was beating his chest and promising to take the very life of our church, and convert all its assets to outside control.

Our only shot at staving off indictments against LRH across North America, and of keeping him out of the couple of dozen pending lawsuits was to take out the axle and so depower its spokes. It was this desperate state of affairs that drew me directly into the shadowy world of intelligence. Throughout his litigation Armstrong had remained in periodic communication with a Scientologist who knew a thing or two about intelligence. Dan Sherman had published a number of spy novels, and had struck up an acquaintance with Armstrong. Armstrong looked up to Sherman and envied his literary success and intelligence acumen. Armstrong believed that Sherman – like so many other Scientologists during the tumultuous early eighties – was disaffected with the church and no longer considered himself a member. In fact, Sherman was cultivating a friendship with Armstrong in order to glean intelligence from him about the enemy camp. Up through the trial their communications were infrequent and mundane.   All that changed when Armstrong became an overnight anti-Scientology sensation. Because of Armstrong’s newly won stardom, Sherman began giving him more face time. Armstrong began sharing some of the details of his activities as a coordination point for all camps inimical to the church, from the Ontario Provincial Police, to the IRS CID, to the DOJ, to the Mayo splinter movement. Armstrong asked Sherman to see whether he could locate some church insiders who might aid in a take-over coup inside the church.

Gene Ingram and I concocted a rather elaborate game plan.   Gene would tap one of his old LAPD comrades to obtain written permission to covertly video record conversations with Gerry Armstrong. Technically, it was a lawfully given permission since we had a witness attesting that Armstrong was suggesting taking over and destroying the church by questionable means.

Gene obtained a recreational vehicle which had a wide rear window with reflective coating, making it one-way vision. A high-powered camera could record what was going on outside without being seen. We planned to record meetings with Armstrong to obtain evidence showing that not only was he not afraid for his life, he in fact was a well-backed aggressor and an operative of government agencies out to get Scientology. After taking circuitous routes to lose any possible tails, Sherman and I met Ingram in the RV in Long Beach. We worked out every detail of Sherman’s cover. We would bring in a former GO operative and have Sherman introduce him to Armstrong as a church insider, plotting the overthrow of the Miscavige regime and willing to play ball with Armstrong, Flynn and their government allies. That would hopefully prompt Armstrong to repeat and elaborate on some of the provocative takeover and take-down ideas he had alluded to in earlier conversations.

The chosen venue for the meetings was Griffith Park, inside LAPD jurisdiction and with plenty of opportunities for positioning the RV to capture the action. Sherman met with Armstrong and whetted his appetite. He told him he had made contact with an ally who had a number of well-placed contacts, currently on staff in the church. He told Armstrong he could only be identified by his first name, Joey, for security purposes. Joey was formerly of the Guardian’s Office and was connected to a number of former GO people who were bitter about being ousted by Miscavige, and sympathetic to Armstrong and the Mayo splinter movement.   Armstrong was visibly overjoyed at this opportunity gratuitously falling into his lap.

Sherman arranged a meeting between Armstrong and Joey to take place on a park bench in Griffith Park. Joey wore an audio wire which transmitted the conversation back to the RV, parked a hundred yards away and video recording the event. Armstrong and Joey both wore sunglasses; both attempted to look as nonchalant as could be, as they introduced themselves.

Joey explained that there was serious disaffection within the church, and a forming cabal of veteran staff ready to take out Miscavige and the current management. He called this cell the Loyalists. Armstrong was clearly excited, and believed Joey’s cover – no doubt because of Sherman’s story-telling skills and credibility with Armstrong.

Armstrong shared with Joey the master plan, which he represented as his brainchild, along with Michael Flynn. He explained that the plan was backed by the Ontario Provincial Police, the DOJ and the IRS. Flynn would prepare a lawsuit on behalf of the Loyalists, asking the Attorney General of California to take the church into receivership on their behalf. The DOJ, FBI, and IRS would conduct a raid on church premises to get fresh evidence of illegalities, in support of the Loyalist action. The raid would be coordinated to coincide with the filing of the receivership action.   The public relations fallout and the possible arrests of leaders would all but cripple the church.

Joey played his role well, feigning fear and nervousness that Armstrong could make good on the government back-up. In order to prove his representations, Armstrong opened a notebook and started naming his government contacts, representing that each was briefed, coordinated and ready to roll with the plan. He cited the following agents as close personal friends and in constant contact and coordination with him and with Flynn:

Al Ristuccia – Los Angeles office of the IRS Criminal Investigation Division

Al Lipkin –  Los Angeles office of the IRS Criminal Investigation Division

Richard Greenberg – U.S. Department of Justice, lead counsel in defending civil litigation brought by the church against DOJ, FBI and IRS

Tom Doughty – DOJ associate of Greenberg

Al Ciampini – Ontario Provincial Police

Armstrong provided Joey with phone numbers for each, including home numbers for some – and urged Joey to get in touch with his team members from these agencies.

Over time, Armstrong told Joey that the IRS CID was the most active government participant, and served as the main coordination point between agencies. He told Joey the CID agents had been briefed about Joey and the Loyalists, and were excited and supportive. The CID would grant them informant status, offer immunity for any crimes they might commit in assisting the government, and had even talked of providing safe houses for insiders. Armstrong then asked   Joey to get his contacts to go into church files and find evidence of illegalities, so that the IRS and DOJ would know where to search. Joey then brought into the mix someone whom Gerry had known from his Sea Org days.   Mike Rinder was a Commodore’s Messenger who had once worked directly with Ron.   He was then heading up the U.S. branch of the Office of Special Affairs.   Joey introduced Mike to Gerry.   Mike reported to Gerry that the files were relatively clean – there were no big smoking-gun documents being created after the 1977 FBI raids. At this point Armstrong’s macho bravado provided what would be our greatest defense against the indictments being issued against Hubbard, Miscavige, et al.   Armstrong suggested that the Loyalists create evidence of illegalities and plant them in church files for the IRS and DOJ to find in a raid, and use against church officials.

All of Armstrong’s representations about government conspiracies to take down church leadership and close down the operation were duly recorded.

David Miscavige was ecstatic with the results. He had me make a presentation of the evidence to a team of criminal lawyers, assembled to represent L. Ron Hubbard, Miscavige, Pat Broker and Lyman Spurlock (Hubbard’s accountant at ASI) to prevent IRS CID indictments and convictions – the potential charges we took most seriously. These attorneys – most from white-shoe Washington, D.C. law firms – were scaring the hell out of Miscavige. They were suggesting the IRS CID case was so serious that they recommended working a deal with the IRS for Miscavige and Spurlock to do time in halfway houses, so as to prevent indictment of Hubbard.   At the root of the IRS CID case was the evidence of millions of dollars of church monies being funneled to Hubbard through fraudulent means. And at the heart of the case would be the infamous MCCS taped conference in which church attorneys and staff acknowledged the fraudulent nature of the transfers.

My presentation horrified the team of criminal attorneys. They were hired because of their conservative, Reagan administration contacts. They did not want anything to do with such an aggressive investigative move.   They were concerned about the propriety of the means Ingram and I had utilized to obtain the evidence, and thought it would reflect badly on their own reputations. One attorney who represented Miscavige personally took me aside, though. He said he did not know how to use it at the moment, but that the evidence I had obtained would ultimately save the day for Hubbard, Miscavige and the church.   Gerald Feffer was the former Assistant Deputy Attorney General for taxation during the Carter administration. He was becoming a dean of white-collar criminal case dismissal prior to indictment. He would become a senior partner in the venerable D.C. law firm Williams & Connally.   Gerry told me to work with some of our more aggressive civil counsel to figure out a way to make the information public, and he would use it to make the IRS criminal case go away.

Another disclosure from the Griffith Park meetings cut to the quick with both Miscavige and me. Armstrong had told Joey that another Department of Justice player was in on the grand plan to close down Scientology: Bracket Deniston III. Armstrong said that Deniston was not investigating to find out who attempted to pass Hubbard’s check, and he was not investigating the evidence we had provided to him.   Instead Deniston was out to nail our investigator, Gene Ingram. Deniston had represented to Armstrong that he was setting traps to nail Ingram and the church for attempting to frame Flynn with purchased evidence.

This was particularly disconcerting, given events in the check investigation while all this Armstrong business was going down.   After I had been ordered out of Boston by Deniston, I had been lured back in by a man being prosecuted by his office. Larry Reservitz had been charged in a case very similar to the one involving LRH’s check. One of Reservitz’s connections who had access to Bank of New England records had used his access to fraudulently transfer money from random accounts to Reservitz. While under indictment, Reservitz reached out to me for the $ 10,000 reward we had previously advertised in the New York Times, claiming he had inside information on the Hubbard case and could identify the inside man at BNE. We had a number of phone calls and several meetings attempting to negotiate the deal. The jockeying was due to my suspicion that Reservitz was shaking us down, and I was searching for facts that would indicate he knew what he was talking about. Reservitz was continually attempting to characterize my questioning as an attempt to make the deal an exchange of cash for handing us Flynn.

In the meantime, Robert Mueller, Denniston’s superior and head of the Boston U.S. DOJ office fraud division, had flown to Italy to visit Ala Tamimi. He bought Tamimi’s retraction of his original statement in exchange for dropping a number of outstanding indictments the DOJ had pending against Tamimi for a variety of fraudulent schemes he had previously executed. I attempted to confront Mueller with what we had learned, but he refused to meet with me. Deniston outright denied that any visit or deal had been carried out by Mueller. In either event, Tamimi’s retraction caused Miscavige to turn up the heat to get me to turn up fresh evidence of Flynn’s involvement in the crime.

I was caught between a rock and a hard spot. Miscavige wanted Flynn at any cost.   Yet I felt that Reservitz might be attempting to frame me for attempting to frame Flynn.   I walked a tight rope between pursuing the investigation to Miscavige’s required degree of aggressiveness, and not stepping over the line with Reservitz. I even visited the Boston FBI agent in charge of the Hubbard check investigation, Jim Burleigh.   I pointedly accused Burleigh of having covertly made a deal with Reservitz to attempt to sting me.   Burleigh brought in another FBI agent to witness his categorical denial that the FBI or DOJ had made a deal with Reservitz: “We would never cooperate with the likes of Larry Reservitz.” Deniston likewise denied that Reservitz was working for the DOJ.   Still, I had my suspicions, particularly when we learned Deniston had become pals with Armstrong and Flynn.

With the sharks circling in and our waning confidence in our civil lawyers (having their heads handed to them in the Armstrong case) and criminal lawyers (advising Miscavige that he resign himself to doing time, at least in a halfway house), Miscavige ordered I find a new breed of lawyer. He wanted someone tough as nails, not some nervous Nellie.   He wanted someone who could figuratively kick Flynn’s butt in court, and scare the hell out of his DOJ and IRS backers. After an exhaustive nationwide search and many candidates eliminated, I thought we had finally found our man – in, of all places, Boston.

Earle Cooley was bigger than life.   He was a big, red-haired knock-off of L. Ron Hubbard himself. His gravelly voice was commanding. His wit was sharp. He was perennially listed in The Best Trial Lawyers in America.   He could spin a yarn that charmed judges and juries and took easy, great pleasure in viciously destroying witnesses on cross examination.   After I had interviewed Earle and reported to Miscavige, I arranged for us to watch Earle in action.   Miscavige and I flew out to Boston to see Earle perform in a high-profile art theft trial. We saw him decimate a seasoned criminal government informant so thoroughly on cross examination that the fellow, in a trademark Cooley expression, “didn’t know whether to shit or wind his watch.” Earle’s client – whom the government had dead to rights, and who was as unsympathetic a defendant as could be – was acquitted by the jury.   We had found the horse for the course.

Earle was like a breath of fresh air to Miscavige.   He took a similar black-and-white view of matters – we are right and good, the enemy is wrong and bad. Miscavige had long since lost his patience and his tolerance for our teams of civil lawyers and the civil-rights-experienced civil-rights-experienced opinion leaders among them. He referred to them as the “pointy heads,” short for “pointy-headed intellectuals.”   To him, our only problem was our counsels’ timid, second-guessing, defensive frames of mind.   And Earle reinforced that view.   Cooley attended a few civil litigation conferences with our other counsel. He ruffled their feathers by readily agreeing with Miscavige’s simplistic sum-up of what was wrong and the solution to it, aggression. The existing lawyers’ nervous objections and eye-rolling reactions to Earle’s sermons only reinforced Miscavige’s view.   “They are nothing but a pack of pussies,” he regularly groused to me; “what we need is for Earle to sink his teeth into those Flynn witnesses and that’ll be the end of this nonsense.”

Miscavige was nothing if not resilient. While never giving a hint that the overridingly important goal was the attainment of All Clear, by late 1984 it was quite evident to all involved that we were fighting an entirely different battle now. It was a fight for survival. We were desperately staving off the barbarians storming the walls of whatever compound L. Ron Hubbard might reside behind. It was evident too that Hubbard himself might have quit fighting – we no longer received any dispatches from him about the legal front. He was only sporadically sending ASI advices concerning his personal business, and to the church about Scientology matters. Miscavige had a team feverishly marketing Hubbard’s new science fiction books, the Mission Earth series. He was putting just as much pressure on church marketing folks to market Dianetics: The Modern Science of Mental Health, the broad public re-release of the 1950 book that had launched the entire movement.   All titles were making it back onto the New York Times bestseller lists.   So the incongruity created another level of cognitive dissonance. How could government officials across the continent be so feverishly pursuing a man who was so wildly popular with the public at large?   It would be years before I would find out that the sales were given a mighty boost by teams of Scientologists sent out to bookstores to buy them in bulk.   In the meantime, Miscavige was adept at keeping me and the troops motivated, inferring that we were buying Ron time to bail out the church’s disastrous public image and to complete his final researches at the highest levels of Scientology.

With Miscavige’s solving of the “why” behind our failures to attain an All Clear – i.e., the outside lawyers’ blatant counter-intention to Hubbard’s advices on using the enemies’ tactics against them, only more cleverly and more aggressively – our defeat-battered hopes were rehabilitated. Earle Cooley, the great Scientology hope, would soon be unleashed.

Notes

  1. Rathbun, Mark (2013-05-28). Memoirs of a Scientology Warrior (pp. 255-64). ↩
  2. GA: I mentioned Rathbun’s Chapter 21, which he titles “The Juggernaut,” in a recent letter to Dan Sherman. http://gerryarmstrong.ca/archives/1082 The whole chapter is Rathbun’s spin on the Armstrong Op, or more specifically the 1984 Griffith Park videotaping part of the op. The operation, which was clearly concocted to use or misuse the videos for nefarious purposes after the videotaping, still continues. Rathbun’s book shows the op continues by continuing it. Even though he calls it a memoir, and recounts different events or incidents in his Scientology career that appear unrelated to the op, the whole book is his spin on it. The book is also a fantastic late act, one more contemptuous fair game nastiness in the same old sick op.

    Most importantly at this time, Rathbun’s spin, and his facts propelling it, are virtually identical to the spin and facts the Miscavige Scientologists give to their description of these events in their black propaganda publications, in their filings in their legal proceedings, in their submissions to the IRS, or to governments and people around the world. The difference is that Rathbun says Miscavige ran and runs it all, and Miscavige and his corporate underlings either do not say or say the same thing. ↩

Filed Under: Cult documents Tagged With: Al Ciampini, Al Lipkin, Al Ristuccia, Ala Fadili Al Tamimi, Brackett B. Denniston III, Christofferson v. Scientology, David Kluge, David Miscavige, Earle C. Cooley, FBI, Gerald Feffer, Gerry Armstrong, IRS, IRS CID, Jim Burleigh, L. Ron Hubbard, Larry J. Reservitz, Loyalist Program, Loyalists, Lyman Spurlock, Mark C. Rathbun, MCCS, Michael J. Flynn, Michael J. Rinder, Pat Broeker, Richard Greenberg, Robert Mueller

Mark Rathbun: on the Check Forgery Frame Ads (May 28, 2013)

May 28, 2013 by Clerk1

When the DOJ utilized the Flynn tactic of seeking L. Ron Hubbard’s deposition and then asking to win by default when the church failed to produce him, it only reinforced our view that Flynn and the DOJ were in league. When I met with the Boston DOJ office attorney responsible for the check investigation, our suspicions of a grand conspiracy became virtually irrefutable fact, in our minds. Bracket Badger Denniston III was the Assistant US Attorney
in the fraud division who was assigned the case. Denniston was a snooty, thirty-something, conservative blue-blood. He treated me with cool disdain. Denniston never shared a single detail of his own alleged investigation. He listened to the results of our investigation with disinterest, and when I detailed Flynn or DOJ connections with the Bank of New England he merely smirked condescendingly.

When we had exhausted all leads and run into a stone wall with the DOJ, mild-mannered Geoff Shervell came up with an audacious idea. We would place a full page ad in the New York Times, offering a ten-thousand-dollar reward for information leading to the conviction of the masterminds behind the attempted passing of the forged $ 2 million L. Ron Hubbard check. Miscavige loved the idea and green-lighted the project. Within days of the ad’s publication, Ingram, the contact point named in the ad, received a call from a woman in Boston.1

Notes

  1. Rathbun, Mark (2013-05-28). Memoirs of a Scientology Warrior (p. 222). Amazon Books. Kindle Edition. ↩

Filed Under: Other writings Tagged With: Brackett B. Denniston III, Check Forgery Frame, DOJ, Eugene M. Ingram, Geoffrey Shervell, L. Ron Hubbard, Mark C. Rathbun, Michael J. Flynn, Michael J. Rinder

Michael Flynn v. CSI (August 28, 1986)

August 28, 1986 by Clerk1

 

Michael FLYNN, Plaintiff,
v.
CHURCH OF SCIENTOLOGY INTERNATIONAL, et al., Defendants.
MBD No. 86-109.
United States District Court,
D. Massachusetts.
Aug. 28, 1986.
1

Defendant in civil action sought to compel deposition testimony of three persons and answers to deposition questions propounded to fourth person. The District Court, Joyce London Alexander, United States Magistrate, held that:

(1) plaintiff’s attorney and his wife, who was law office employee, were entitled to protection of attorney-client and work-product privileges, and any questions relating to their personal, fiduciary, and client financial records would be irrelevant, so deposition subpoena would be quashed and protective order granted; (2) assistant United States attorney assigned to ongoing criminal investigation and working with grand jury also could not be compelled to give deposition testimony and was protected under privilege for law enforcement investigative information and by criminal rule prohibiting disclosure of matters occuring before grand jury; and (3) member of law firm representing plaintiff had properly refused to answer deposition questions on grounds of lack of relevance and attorney-client and work-product privileges.

Ordered accordingly.

[1] WITNESSES
One who consults lawyer with view to obtaining professional legal services from him is regarded as client, for purposes of attorney-client privilege.

[2] WITNESSES
Communications from client to attorney are ordinarily privileged if they are legally related and have expectation of confidentiality.

[2] WITNESSES
Communications from client to attorney are ordinarily privileged if they are legally related and have expectation of confidentiality.

[3] FEDERAL CIVIL PROCEDURE
Attorney’s work-product privilege protects against disclosure of his mental impressions, conclusion, opinions, or legal theories.

[4] FEDERAL CIVIL PROCEDURE
Party seeking discovery of lawyer’s work product must establish adequate reasons to justify such production; when desired material can be obtained elsewhere, burden of showing such special circumstances has not been met.

[5] FEDERAL CIVIL PROCEDURE
Attorney and his wife, who was his law office employee, were entitled to protection of attorney-client and work-product privileges in regard to deposition subpoena; discovery sought could be obtained by less intrusive sources, and even though defendants asserted that deposition focused on questions relating to attorney’s personal, fiduciary, and client financial records, those matters were irrelevant. Fed.Rules Civ.Proc.Rule 26, 28 U.S.C.A.

[6] FEDERAL CIVIL PROCEDURE
Attorney fees for motion to quash deposition subpoena would not be awarded, absent evidence that opposition to that motion or subpoena itself was motivated by bad faith. Fed.Rules Civ.Proc.Rule 37(a)(4), 28 U.S.C.A.

[7] FEDERAL CIVIL PROCEDURE
Assistant United States attorney assigned to ongoing criminal investigation and working with grand jury could not be compelled to give deposition testimony in civil suit regarding matters that were subject of that investigation; possibility of disclosure of confidential information and sources in and of itself satisfied burden of showing applicability of privilege for law enforcement investigative information, and assertion of privilege against disclosure of matters before grand jury on question-by-question basis would involve possibility of risk of disclosure. Fed.Rules Cr.Proc.Rule 6(e)(2), 18 U.S.C.A.; Fed.Rules Civ.Proc.Rule 26, 28 U.S.C.A.

[8] FEDERAL CIVIL PROCEDURE
Plaintiff’s attorney and another member of his law firm could refuse to answer deposition questions on grounds of lack of relevance and attorney-client and work-product privileges. Fed.Rules Civ.Proc.Rule 26, 28 U.S.C.A.
*2 Roger Geller, Geller & Weinberg, Boston, Mass., for plaintiff.

Ada Rose Bitterbaum, Flynn & Joyce, Boston, Mass., for defendants.

ORDER ON WITNESS WAYNE B. HOLLINGSWORTH AND JUNE L. HOLLINGSWORTH’S MOTION TO QUASH DEPOSITION SUBPOENAS, FOR PROTECTIVE ORDER AND FOR COSTS (# 21); BRACKETT B. DENNISTON’S MOTION TO QUASH SUBPOENA (# 32); AND MOTION TO COMPEL ANSWERS TO DEPOSITION QUESTIONS PROPOUNDED TO DAVID BANASH

JOYCE LONDON ALEXANDER, United States Magistrate.

The present motions arise from an action in which plaintiff, Michael Flynn, seeks damages for emotional and economic injuries based on acts of the defendants. Plaintiff alleges that defendants published information concerning his alleged involvement in the unsuccessful attempt to pass a forged $2,000,000.00 check. [FN1]

FN1. Defendants’ Opposition to Motion of Deposition Witnesses Wayne B. Hollingsworth and June Hollingsworth to Quash Subpoenas and Protective Orders and Costs (# 26), p. 1-2.

Defendants, Church of Scientology (Scientology), seek to compel the deposition testimony of Wayne B. Hollingsworth, June L. Hollingsworth, Brackett Denniston III and the answers to deposition questions propounded to David Banash.

WAYNE AND JUNE HOLLINGSWORTH
Defendants subpoenaed Wayne and June Hollingsworth commanding them to provide deposition testimony. [FN2] Witnesses, Wayne B. Hollingsworth (Hollingsworth) and June L. Hollingsworth move to quash these deposition subpoenas. [FN3] They also seek protective orders and costs, including reasonable attorney’s fees.[FN4]

FN2. Witness, June L. Hollingsworth, was not served in hand with her deposition subpoena pursuant to Fed.R.Civ.P. 45. Witness Wayne B. Hollingsworth and June L. Hollingsworth’s Motion to Quash Deposition Subpoenas for Protective Orders and For Costs (# 21), p. 1.

FN3. Id., (# 21), p. 1.

FN4. Id., (# 21), p. 1.

Hollingsworth is an attorney and since 1981 has represented the plaintiff against various individuals and entities related to Scientology. [FN5] As such, he asserts that the deposition subpoena should be quashed and protective order granted, because any information he has received concerning Scientology matters is covered by the attorney-client privilege or work product immunity within the meaning of Fed.R.Civ.P. 26. [FN6]

FN5. Defendants’ Opposition to Motion of Deposition Witness Wayne B. Hollingsworth and June L. Hollingsworth to Quash Subpoenas for Protective Orders and Costs (# 26), p. 1.

FN6. Witness Wayne B. Hollingsworth and June L. Hollingsworth’s Motion to Quash Deposition Subpoenas for Protective Orders and for Costs (# 21), p. 2.

Defendants state that although Hollingsworth represented Flynn in litigation against Scientology, this is an insufficient basis to quash the deposition subpoena or grant a protective order. [FN7] Defendants further assert that they had no intention of questioning Hollingsworth on his actual representation of Flynn. Rather, the deposition will focus on areas for which no attorney-client privilege exists, such as Flynn’s physical appearance, non-legal *3 business affairs with deponent, or amount and sources of fees paid. [FN8]

FN7. Defendants’ Opposition to Motion of Deposition Witnesses Wayne B. Hollingsworth and June Hollingsworth to Quash Subpoenas and Protective Orders and Costs (# 26), p. 3.

FN8. Defendants’ Opposition to Motion of Deposition Witnesses Wayne B. Hollingsworth and June Hollingsworth to Quash Subpoenas and Protective Orders and Costs (# 26), p. 4.

Hollingsworth, who has represented the plaintiff in litigation against Scientology, [FN9] states that Scientology’s deposition subpoena is motivated by bad faith. He asserts that it is the defendant’s latest attempt to harass attorneys who represent or have represented the plaintiff by seeking privileged information from them. [FN10] Hollingsworth further asserts that defendants seek “irrelevant and first amendment privileged information” such as Hollingsworth’s personal, fiduciary and client financial records, that cannot lead to the discovery of admissible evidence. [FN11]

FN9. Defendant’s Opposition to Motion of Deposition Witnesses Wayne B. Hollingsworth and June Hollingsworth to Quash Subpoenas and Protective Orders and Costs (# 26), p. 1.

FN10. Hollingsworth provides that: Martin O’Malley, Paul Jenkins, Gary Pappas, Daniel Lenzo, Thomas Green and William Weld are other attorneys who were deposed. Witness Wayne B. Hollingsworth and June L.  Hollingsworth’s Motion to Quash Deposition Subpoenas, for Protective Order and for Costs (# 21), p. 2.

FN11. Id., (# 21), p. 2.

Defendants allege that there has been no showing of harassment, and the material sought is relevant and crucial to defendant’s defense. [FN12]

FN12. Defendants’ Opposition to Motion of Deposition Witnesses Wayne B. Hollingsworth and June Hollingsworth to Quash Subpoenas and for Protective Orders and Costs (# 25), p. 5.

[1][2] Cases show that one who consults a lawyer with a view to obtaining professional legal services from him is regarded as a client for purposes of the attorney-client privilege. [FN13] Federal Practice & Procedure, Wright and Miller, Vol. 8, p. 135. Communications from a client to his attorney are ordinarily privileged if legally related and have an expectation of confidentiality. Duplan Corporation v. Deering Milliken, Inc., 370 F.Supp. 761, 768 (D.S.C.1972). “The attorney-client privilege is the oldest of the privileges for confidential communications known to the common law. Its purpose is to encourage full and frank communication between attorneys and their clients and thereby promote broader public interests in the observance of law and administration of justice. The privilege recognizes that sound legal advice or advocacy serves public ends and that such advice or advocacy depends upon the lawyer’s being fully informed by the client.” Upjohn Co. v. United States, 449 U.S. 383, 389, 101 S.Ct. 677, 682, 66 L.Ed.2d 584 (1981).

FN13. “The privilege applies only if (1) the asserted holder of the privilege is or sought to become a client; (2) the person to whom the Communication was made (a) is a member of the bar of a court, or his subordinate and (b) in connection with this communication is acting as a lawyer; (3) the communication relates to a fact of which the attorney was informed (a) by his client (b) without the presence of strangers (c) for the purpose of securing primarily either (i) an opinion on law or (ii) legal services or (iii) assistance in some legal proceeding, and not (d) for the purpose of committing a crime or tort; and (4) the privilege has been (a) claimed and (b) not waived by client.” United States v. United Shoe Machinery Corp., 89 F.Supp. 357, 358-359 (D.Mass.1950).

[3][4] An attorney’s work product privilege protects against the disclosure of his mental impressions, conclusions, opinions or legal theories. Mervin v. Federal Trade Commission, 591 F.2d 821, 825 (D.C.Cir.1978). The party seeking discovery of the lawyer’s “work-product” must establish adequate reasons to justify such production. When the desired material can be obtained elsewhere, the burden of showing such special circumstances has not been met. Hickman v. Taylor, 329 U.S. 495, 511-513, 67 S.Ct. 385, 393-394, 91 L.Ed. 451 (1946). It is axiomatic that Fed.R.Civ.P. 26(b) provides that only relevant matter may be the subject of discovery. “[W]here the relevance of information sought in discovery proceedings is questionable … discovery of the requested information will be denied.” Moore Federal Practice, Vol. 4, p. 26-431. *4 [5] The Court concludes that information concerning  Scientology matters which Hollingsworth has received is entitled to the protection of the attorney-client and work product privileges as a result of his representation of the plaintiff. The Court further concludes that discovery sought by defendants may be obtained by less intrusive sources than the intrusion of Hollingsworth’s work product.

In addition, the Court cannot find the requisite relevance of questions relating to Hollingsworth’s personal, fiduciary and client financial records to the case sub judice. As such, the Court concludes that such information cannot lead to the discovery of relevant evidence. Witness June L. Hollingsworth is the wife of Wayne B. Hollingsworth. [FN14] Mrs. Hollingsworth asserts that since 1981 she was employed by her husband’s law firm. [FN15] She submits that her deposition should be quashed and a protective order granted in that she has no knowledge of any relevant facts that are not privileged. [FN16]

FN14. Witness Wayne B. Hollingsworth and June L. Hollingsworth’s Motion to Quash Deposition Subpoenas for Protective Order and for Costs (# 21), p. 3.

FN15. Id., (# 21), p. 3.

FN16. Id., (# 21), p. 3.

Defendants state that the deposition testimony of Mrs. Hollingsworth, as an employee of Hollingsworth’s law office, is calculated to lead to the discovery of relevant evidence. [FN17]

FN17. Defendant’s Opposition to Motion of Deposition Witnesses Wayne B. Hollingsworth and June Hollingsworth to Quash Subpoena and for Protective Orders and for Costs (# 26), p. 1.

The Court has concluded that Mr. Hollingsworth has properly asserted both attorney-client and work product privileges. [FN18] “[C]onfidences imputed to the attorney are presumed shared among his partners and employees associated with him….” State of Arkansas v. Dean Foods Products Company, 605 F.2d 380, 385 (8th Cir.1979).

FN18. Witness Wayne B. Hollingsworth and June Hollingsworth’s Motion to Quash Deposition Subpoenas, for Protective Order and for Costs (# 21), p. 2.

This Court finds that as an employee of the law firm which represented the plaintiff, any privileges asserted by Mr. Hollingsworth extend to June Hollingsworth, and any relevant information she may have acquired is protected. Consonant with the foregoing, Wayne B. Hollingsworth and June Hollingsworth’s Motions to quash and for protective orders are hereby ALLOWED.

[6] Wayne and June Hollingsworth also seek costs including reasonable attorney’s fees as a part of their motion before the Court. Fed.R.Civ.P. 37(a)(4) provides:

“If the motion is granted, the court shall … require the party or deponent whose conduct necessitated the motion … to pay to the moving party the reasonable expenses incurred in obtaining the order, including attorney’s fees, unless the court finds that the opposition to the motion was substantially justified or that other circumstances make an award of expenses unjust.” The Court cannot conclude that defendants’ opposition to Wayne and June Hollingsworth’s motions to quash were substantially unjustified or motivated by bad faith. Nor can this Court find that Wayne Hollingsworth has provided sufficient information to substantiate his claim that the deposition subpoena was motivated by bad faith. Accordingly, the Court denies the Hollingsworth’s request for attorney’s fees and costs.

BRACKETT DENNISTON III
[7] On April 9, 1986, defendants subpoenaed Brackett B. Denniston III (Denniston), commanding him to appear and give deposition testimony. [FN19] Denniston now moves to quash the subpoena. [FN20]

FN19. Motion to Quash Subpoena (# 32), p. 1.

FN20. Motion to Quash Subpoena (# 32), p. 1.

*5 Denniston, an Assistant United States Attorney, states that he is assigned to an ongoing criminal investigation of matters about which Scientology seeks to take his deposition. He is also working with a Grand Jury on these matters. [FN21]

FN21. Bracket Denniston is Chief of the Major Frauds Unit of the United States Attorney’s Office for the District of Massachusetts. Memorandum in Support of Motion to Quash Subpoena (# 33), p. 1.

Denniston asserts that the subpoena should be quashed because his testimony is not authorized by the Department of Justice. Denniston submits that federal regulations prohibit him, as an employee of the Department of Justice, from disclosing information based on material contained in the files of the Department, without prior approval of the proper Department official. [FN22]

FN22. Memorandum in Support of Motion to Quash Subpoena (# 33), p. 3. 28 C.F.R. s 16.22(a) General prohibition of production or disclosure in Federal and State proceedings in which the United States is not a party, provides:

“In any federal or state case or matter in which the United States is not a party, no employee or former employee of the Department of Justice shall, in response to a demand, produce any material contained in the files of the Department, or disclose any information relating to or based upon material contained in the files of the Department, or disclose any information or produce any material acquired as part of the performance of that person’s official status without prior approval of the proper Department official….”

At the hearing, it was stated that after discussing this matter with U.S. Attorney Weld, Denniston was denied authority to testify. Denniston states that such denial was proper. [FN23]

FN23. Denniston submits that compliance with a subpoena will not be allowed if disclosure would reveal a confidential source or informant or would interfere with enforcement proceedings. Denniston asserts that compulsion of his testimony would seriously compromise the ongoing criminal investigation and would reveal confidential sources of information, and thus the denial of authorization was proper. Memorandum in Support of Motion to Quash Subpoena (# 33), p. 4.

Defendants stated at the hearing that the U.S. Attorney’s denial of Denniston’s authorization to testify is not a final determination. Rather, the decision is reviewable by the Court. The Court concludes that the U.S. Attorney’s denial of Denniston’s authorization to testify was proper. [FN24]

FN24. Memorandum in Support of Motion to Quash Subpoena (# 33), p. 3.

Denniston submits that the subpoena calls for privileged matter from an ongoing criminal investigation. [FN25] Denniston states that any information he has stems solely from his criminal investigation on behalf of the U.S. Attorney’s Office. Such information is protected under the privilege for law enforcement investigative information. [FN26]

FN25. Memorandum in Support of Motion to Quash Subpoena (# 33), p. 4.

FN26. Memorandum in Support of Motion to Quash Subpoena (# 33), p. 4.

Defendants submit that the government has the burden of demonstrating the applicability of its asserted privilege, and the government has not met its burden of showing how the deposition will impede the ongoing criminal investigation. [FN27]

FN27. Defendant’s Memorandum in Support of Motion to Compel Attendance of Witness at Deposition and Opposition to Motion to Quash Subpoena of Brackett B. Denniston III (# 38), p. 13-14.

The Court notes that “there is indeed a public interest in minimizing disclosure of documents that would tend to reveal law enforcement investigative techniques or sources.” Black v. Sheraton Corporation of America, 564 F.2d 531, 545 (D.C.Cir.1977). “It is well established that the government has a qualified privilege to prevent public disclosure of investigative files and related material prepared in the course of an ongoing criminal investigation.” Jabara v. Kelley, 75 F.R.D. 475, 493 (E.D.Mich.1977). The Court finds that the possibility of disclosure of confidential information and sources is enough in and of itself to satisfy Denniston’s burden of showing the applicability of the privilege asserted.

Denniston further submits that compelling his testimony would violate Fed.R. *6 Crim.P. 6(e), which prohibits disclosure of matters before the Grand Jury. [FN28]

FN28. Memorandum in Support of Motion to Quash Subpoena (# 33), p. 5-6.

Defendants assert that they do not seek to question Denniston about grand jury testimony, and further, such information may be protected by Denniston’s opportunity to assert the privilege if necessary. [FN29]

FN29. Defendants’ Memorandum in Support of Motion to Compel Attendance of Witness at Deposition and Opposition to Motion to Quash Subpoena of Bracket B. Denniston III (# 38), p. 21.

Fed.R.Crim.P. 6(e)(2) provides that, “… an attorney for the government, or any person to whom disclosure is made … shall not disclose matters occurring before the grand jury….”

The Court finds that allowing the privilege to be asserted on a question-by-question basis involves the possibility of the risk of disclosure. As such, to assure the secrecy and nondisclosure of the investigation before the grand jury the Court concludes that Denniston’s assertion of Fed.R.Crim.P. 6(e)(2) is proper.

For the reasons stated above, Brackett B. Denniston III’s Motion to Quash Subpoena is hereby ALLOWED.

DAVID BANASH
[8] Defendants move to compel David Banash (Banash) to answer certain deposition questions propounded to him which he refused to answer during his deposition on March 12, 1986. [FN30]

FN30. Banash’s refusal to answer certain deposition questions was based on three grounds: a) lack of relevance; b) attorney-client privilege; and c) attorney work product. Motion to Compel Answers to Deposition Questions Propounded to David Banash, p. 1-3.

In support of their motion to compel, the defendants make the following proffers:

First, defendants state that Banash’s objections based on the grounds of relevancy are without merit. They assert that all information sought is relevant and reasonably calculated to lead to the discovery of admissible evidence and should thus be provided. [FN31]

FN31. Motion to Compel Answers to Deposition Questions Propounded to David Banash, p. 5.

Next, defendants assert that Banash’s objections based on the attorney-client privilege are also without merit, in that Banash has failed to meet his burden in demonstrating how the questions propounded interfere with his attorney-client relationship. [FN32]

FN32. Motion to Compel Answers to Deposition Questions Propounded to David Banash, p. 10.

Finally, defendants submit that Banash’s failure to answer questions on Hollingsworth’s “physical and emotional demeanor” is without merit, because physical appearance is not a privileged matter. [FN33]

FN33. Id., p. 14.

As to the first contention, Banash submits that his refusal to answer certain questions on the grounds of relevancy was proper. [FN34] At hearing, counsel for Banash asserted that defendants were asking for broad and irrelevant discovery of Mr. Hollingsworth, who is not even a party in this case. [FN35]

FN34. Plaintiff and Deponent’s Memorandum in Opposition to Defendant’s Motion to Compel Answers to Deposition Questions Propounded to David Banash, p. 4.

FN35. Counsel for Banash stated that questions such as: How Hollingsworth billed his clients; questions relating to Hollingsworth’s personal finances, personal habits, friendships and relations, have no relevance to the allegations about the plaintiff in the case. Plaintiff and Deponent’s Memorandum in Opposition to Defendants’ Motion to Compel Answers to Deposition Questions Propounded to David Banash, p. 6.

Banash next states that he is an attorney and was not only a member of Hollingsworth’s law firm, but he has also represented both the plaintiff and Mr. Hollingsworth. [FN36] Banash states that he has also provided legal advice to Mr. Hollingsworth and advised him regarding his rights *7 against Scientology. [FN37] At hearing, counsel for Banash asserted that Banash has represented Hollingsworth and the plaintiff during the relevant time periods for which defendant’s seek Banash’s deposition. Counsel stated that this is enough in itself to show that Banash has met the burden of demonstrating an interference with his attorney-client relationship if compelled to answer
questions which may relate to this representation. As such, Banash asserts that his objections based on the attorney-client privilege were proper. [FN38]

FN36. Plaintiff and Deponent’s Memorandum in Opposition to Defendants’ Motion to Compel Answers to Deposition Questions Propounded to David Banash, p. 2.

FN37. Id.

FN38. Plaintiff and Deponent’s Memorandum in Opposition to Defendants’ Motion to Compel Answers to Deposition Questions Propounded to David Banash, p. 3.

Finally, Banash asserts that the information sought based on his observations and impressions of Hollingsworth were properly refused and are protected by his work product privilege. [FN39] At hearing, counsel for Banash submitted that there is a distinction between the objective physical observation, which defendants are entitled to, such as information based on a client’s height, weight, clothes, and the subjective physical observation, such as information related to the clients distress, which is clearly protected. [FN40] Banash further states that information protected by the work product doctrine may only be reached where there is inability to obtain it otherwise. [FN41]

FN39. Banash states that the work product doctrine is reflected in Fed.R.Civ.P. 26(b)(3) and it protects an attorney’s mental impressions, thought processes and personal beliefs concerning a case. Plaintiff and Deponent’s Memorandum in Opposition to Defendant’s Motion to Compel Answers to Deposition Questions Propounded to David Banash, p. 14-15.

FN40. Counsel stated that an attorney’s subjective physical observation of his client is impossible to distinguish from the privileged work product mental impressions that an attorney uses to decide how to handle a case, and thus, subjective physical observation is clearly protected.

FN41. Banash submits that there are numerous sources from which defendants can obtain information about the plaintiff’s damages without requiring an attorney to reveal his work product. This includes: plaintiff’s family; non-lawyer colleagues; friends; and the deposing of the plaintiff himself. Plaintiff’s and deponent’s Memorandum in Opposition to Defendant’s Motion to Compel Answers to Deposition Questions Propounded to David Banash, p. 17.

Fed.R.Civ.P. 26(b) provides that only relevant matter may be the subject of discovery. “[W]here the relevance of information sought in discovery proceedings is questionable and the request is overly broad, or compliance with such a request would be unduly burdensome, discovery of the requested information will be denied.” Moore’s Federal Practice, Vol. 4, p. 26-431. Under a generous reading of the defendant’s memoranda, this Court is unable to find the relevance of the information sought. [FN42] Accordingly, the Court finds that Banash’s refusal to answer deposition questions on the grounds of relevancy was proper.

FN42. The Court may deny motion to compel further deposition questioning when the Court determines questions are irrelevant. Commercial Union Insurance Co. v. Westrope, 730 F.2d 729, 732 (11th Cir.1984).

The Court also finds that Banash’s refusal to answer deposition questions on the grounds of attorney-client and work product privileges were proper. The Court concludes this based on the same reasoning as cited above in the Hollingsworth order.

Consonant with the foregoing, Defendant’s Motion to Compel Answers to Deposition Questions Propounded to David Banash is hereby DENIED.

SO ORDERED.

Notes

  1. Retrieved on September 27, 2014 from http://www.xenu.net/archive/CourtFiles/occf124.html. ↩

Filed Under: Legal Tagged With: Brackett B. Denniston III, Check Forgery Frame, David Banash, June L. Hollingsworth, Michael Flynn v. Scientology, Michael J. Flynn, Wayne B. Hollingsworth

The Boston Globe: Ex-lawyer, N.H. man charged in plan to bilk Church of Scientology (May 29, 1986)

May 29, 1986 by Clerk1

Ex-lawyer, N.H. man charged in plan to bilk Church of Scientology1

FBI agents yesterday arrested a New Hampshire man and a disbarred lawyer on charges of extorting $33,000 from the Church of Scientology by offering false information about a scheme to steal $2 million from the church.

George T. Kattar, 67, of Meredith, N.H., formerly of Methuen, was held without bail pending a detention hearing tomorrow. Harvey Brower, 49, of Swampscott, a former lawyer turned writer, was released on $50,000 bail.

According to an indictment issued by a federal grand jury in Boston, Kattar and Brower obtained the money from church officials by offering to provide them with information about a forged $2 million check drawn on an account of L. Ron Hubbard, the church founder.

Kattar and Brower allegedly offered the information — which proved to be false — in return for a $100,000 fee, one-third of which was to be paid in advance.

The indictment does not specify what information was allegedly supplied by the defendants in return for the $33,000.

Kattar and Brower, according to the indictment, used threats of violence. The scheme allegedly occurred between September and December 1984.

In January 1984, full-page advertisements were placed in The Boston Globe, The New York Times and other publications offering a $100,000 reward for information that would help determine who presented the forged check to the Bank of New England in June 1982. A teller questioned the check’s validity and it was not cashed.

Harry L. Manion 3d, a lawyer for the church, said yesterday the indictment is only “the tip of the Iceberg.”

He said “the church believes this is the beginning of the unraveling of the circumstances surrounding the forgery.”

Argued against bail

In arguing that Kattar be denied bail, Assistant US Attorney Brackett B. Denniston 3d said that releasing him before trial would pose a danger to witnesses and the community in general.

Denniston said Kattar “put out a contract on a cooperating witness in the case,” and, in conversations that were secretly tape-recorded, he discussed killing witnesses in other cases.

The prosecutor said one church official was told by Kattar: “Pay up or I’ll drop your name in a hat.”

The tapes were reportedly made by another disbarred lawyer, Larry Reservitz, who has cooperated with federal investigators in several cases following his conviction on drug charges.

Besides extortion, the indictment charged Kattar and Brower with three counts of wire fraud and one count of receiving stolen funds.

They pleaded innocent to all the charges at a hearing before US District Magistrate Lawrence P. Cohen. Their trial was scheduled for July 16.

Seized 131 guns

During an unrelated raid on Kattar’s home last month, FBI agents seized 131 guns and military supplies. The armaments included three homemade explosive devices, a number of machine guns, an Israeli submachine gun, automatic weapons, shotguns, rifles and handguns.

Also found in the raid, the FBI said, was the name of an individual who lives in Lebanon. Investigators said they planned to trace the origin of the weapons and attempt to determine if any of the guns were intended for shipment to Beirut.

Kattar has been a real estate developer and trucking company executive for the past 20 years.

Brower, a lawyer for 17 years with offices in Lawrence, was disbarred in August 1979 for cheating a client of $15,000.

Brower has represented the late Raymond L.S. Patriarca and several other high-level figures in organized crime. He served six months in prison in 1979 for conspiring to help a client jump bail in Louisiana and escape to Mexico. In 1982, Brower was fined $3,000 for conspiring to operate a bookie syndicate.

Notes

  1. This document in PDF format. Retrieved on September 24, 2014 from http://xenu-directory.net/news/library-item.php?iid=3021 ↩

Filed Under: Media articles Tagged With: Brackett B. Denniston III, Check Forgery Frame, George T. Kattar, Harry L. Manion III, Harvey Brower, Larry J. Reservitz

Freedom: (May 1985)

May 1, 1985 by Clerk1

freedom-1985-05-1-255x300
Freedom (May 1985)
  • IRS Strategic Plan Exposed1
  • Videotapes of Federal Informant Reveal Bizarre Plot to Destroy Church
  • Agencies in Turmoil As Conspiracy Exposed: Freedom’s expose of the Armstrong videotapes has created an uproar in a number of government agencies and departments

Notes

  1. This document in image format. This document in PDF format. ↩

Filed Under: Cult documents, Media articles Tagged With: Al Ciampini, Al Lipkin, Al Ristuccia, Andy Lenarcic, Brackett B. Denniston III, Cointelpro, Freedom, Gerry Armstrong, IRS, Kathy Gorgon, L. Fletcher Prouty, Los Angeles Police Chief Daryl Gates, Michael J. Flynn, Richard Greenberg, Roscoe Egger, Stacy Young, Thomas Doughty, Thomas G. Whittle

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