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From: martinottmann@yahoo.com (Martin Ottmann)
Newsgroups: alt.religion.scientology
Subject: Affidavit of Theodore Heisig, Jr. - November 1st, 1991
Date: 8 Jan 2003 13:54:01 -0800
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AFFIDAVIT

I, Theodore Heisig, Jr., state:

1. I am a resident of Orange County, California.

2. I am a licensed private investigator in the State of California. My
license number is # 13793.

3. I was engaged by or on behalf of the Church of Scientology or its
related organizations ("Scientology") to undertake private
investigations during the period 1989 through 1991. During that period
the payments I received for investigative activities on behalf of
Scientology accounted for more than 80% of my total income from
private investigation work.

4. Beginning in 1989, one of my assignments for Scientology was to
perform an investigation of Werner Erhard ("Erhard") and his
organizations, "EST" and "Werner Erhard & Associates" (WE&A), as part
of a project designated by Scientology as the "EST Project". My
assignment was to get damaging information on Erhard, to monitor
current litigation against Erhard and to conduct interviews.

5. I commenced my investigation of Erhard as part of the EST Project
in October, 1989,including a trip to San Francisco area to interview
people. My instructions included, but were not limited to, the
following: do legal checks on Erhard to see if there were criminal
cases in other states, check with the Board of Psychiatric Examiners
for any complaints against Erhard of WE&A, interview Erhard's ex-maid
Dawn Damas about his alleged drug abuse and get names of drug dealers
that associated with him, contact disaffected EST employees and
members, do surveillance on Erhard's boat in Sausalito where he lived
and worked to determine his activities, contact reporters that did
critical articles on EST, contact and interview Erhard's ex-wife,
Ellen Erhard, contact parties suing Erhard or EST to obtain
information concerning Erhard's alleged illegal activities, and
contact Vic Krohn in the Sacramento Scientology office regarding
information on Erhard's IRS tax case 1n Washington, DC.

6. In furtherance of the EST Project, I received written instructions
dated November 27, 1989 and titled "Additional Targets for EST
Project" from David Butterworth, my case officer and the head of the
Office of Special Affairs for the Pacific Region of Scientology. I
understood that David Butterworth's superior, Doug Jacobsen, a SEA org
investigation officer, was the person who re-initiated the current
activity against Erhard.

7. These written instructions described above were for me to:
recontract Paul Gutfreund and arrange the exchange of documents, to
re-contact Erhard's ex-maid Dawn Damas and ask her to find out if
Ellen Erhard would be willing to meet with me to help me expose any
possible criminal activities of Erhard's, and if not, then could Ms.
Damas get further data from Ellen Erhard to get to me. In addition,
the instructions included contacting new "targets" for the purpose of
obtaining information regarding illegal or criminal activity of Erhard
as well as a list of "undone targets" from previous instructions. I
was to contact any new leads from the named targets. I was also
instructed to stay on the main line investigation of ferreting out and
documenting crimes so that Scientology would have actual documents and
affidavits in hand.

8. Pursuant to such instructions, I made several trips to the San
Francisco area during the period between November 1989 and February
1990.

9. In November, 1989, I spoke with Landon Carter, a former EST
trainer, and identified myself as a private investigator working for
clients who were interested in exposing any criminal activities that
Erhard might be engaged in. I informed Mr. Carter that I knew people
who believed that Erhard had cocaine stored in a warehouse in
Sausalito. Mr. Carter responded that when he worked for EST, he knew
what was going on and there was no such activity or any other criminal
activities conducted by Erhard or in which Erhard was involved. Mr.
Carter went on to say that since he left he hadn't heard of anything
illegal, and there is enough of a network of talk about Erhard that he
would have heard something. I had no further conversations with Mr.
Carter.

10. On or about December 2, 1989, I went to the residence of Pia
Smith, a former EST employee, in Sausalito, California. I identified
myself as a private investigator and said that I wanted to speak with
her about Erhard. She declined to open the door of her residence and
instructed me to contact her by phone. I made no further contact with
Ms. Smith.

11. On or about December 2, 1989, I spoke with William Clements, a
former EST employee, and said that I was a private investigator
investigating allegations of criminal conduct by Erhard. Mr. Clements
questioned how a private investigator could conduct a criminal
investigation. I responded that I wasn't actually conducting an
investigation of criminal activities and that I represented clients
from Los Angeles who were former EST people looking for someone to
cooperate with them in their effort to discredit Erhard. I told Mr.
Clements that I was looking for someone to sign an affidavit. Mr.
Clements said he knew of no criminal activities on Erhard's part and
that he was not interested in helping me. I had my last contact with
Mr. Clements shortly after the 60 Minutes program aired in March 1991
when I again asked for information on Mr. Erhard. After that I had no
further conversations with Mr.
Clements.

12. I spoke several times with Ms. Dawn Damas, a former employee in
Erhard's home, who made statements regarding sexual molestation and
physical abuse by Erhard of family members, that Erhard disowned his
son and that Erhard's daughters were scared to death of him. Ms. Damas
told me that Ellen Erhard wanted her to write a negative book about
Erhard and it was my impression that Ellen Erhard was giving
information to Dawn Damas for that book and for me. Ms. Damas made it
clear that she had no personal knowledge or proof of these statements.
Ms. Damas told me that I should speak to people who had been around
Erhard: Becky and Landon Carter, Raz and Liza Ingrasci, Bill and Carla
Clements, Wendy and Vincent Drucker. I informed Ms. Damas that I'd
gotten her name from them, and they hadn't told me anything. I
informed Ms. Damas that I had been given information that a warehouse
in Sausalito was a drug front. She replied that she didn't know
anything about that, but she knew that fine art was kept there. I also
informed Ms. Damas that I had gone to Ellen Erhard's home, knocked on
the door, that a young girl came to the door and suddenly ran upstairs
without talking to me.

13. During November 1989 - March 1991, I also spoke with the following
persons:

(a) Vincent Drucker - I spoke with Mr. Drucker, a former EST employee,
who suggested that a satire on self-deception should be done on
Erhard.

(b) John Toth - I spoke with Mr. Toth, an electrician who had
performed work in the Franklin House, a building in which Mr. Erhard
had worked. Mr. Toth said that he had heard that one or more rooms in
the Franklin House was bugged and that in one instance, a recording
was made of Erhard and a female employee. Mr. Toth further said that
when Erhard later learned of this, he ordered that room debugged.

(c) Mari Sharkey - I spoke with MB. Sharkey, a former food server at
the Franklin House. Ms. Sharkey indicated that Erhard most likely
furnished cocaine to Landon Carter and his wife in 1978.

(d) Carol Farland - I spoke with Ms. Farland, who had previously
performed work at the Franklin house. Ms. Farland spoke very highly of
Erhard.

(e) Bob Curtis - I spoke with Mr. Curtis shortly after the 60 Minutes
program aired in March 1991. He declined to give me information on
Erhard.

14. During November - December 1989, I also attempted unsuccessfully
to contact several other persons regarding Erhard. These included
Ellen Erhard, his former wife, and Arnold Siegel, a former associate.

15. One of the targets whom I was to contact in my original
instructions as well as in follow-up instructions, was Paul Gutfreund
("Gutfreund"), a resident of Sausalito, California. I was in regular
communication with Gutfreund from October 1989 through the summer of
1991, including lengthy telephone conversations on or about October 29
and November 21, 1989; I had initially contacted him in view of his
pending lawsuit against Erhard in San Francisco. I was to obtain
documents that Gutfreund had on Erhard and EST in exchange for
documents I had on Erhard and EST. Since November, 1989, I have had
several telephone conversations with Gutfreund and I met with him
several times in Marin County, California on or about April 24, 1990.

16. During the period since October, 1989, Gutfreund provided me with
the names (and in some instances the telephone numbers) of individuals
to contact regarding possible damaging information about Erhard. These
individuals included, but were not limited to, Dawn Damas, John Toth,
Margaret Singer, Arnold Siegel and Sharon Billings. I provided
Gutfreund with the names of individuals for him to contact regarding
damaging information about Erhard. These individuals included, but
were not limited to, Mari Sharkey and Charlene Afremow. Gutfreund and
I also discussed the content of conversations which he or I had with
individuals regarding Erhard. These individuals included, but were not
limited to Landon Carter, Dawn Damas, John Toth, Vincent Drucker,
Ellen Erhard, Charlene Afremow and Audrey Tanzer.

17. During the period since October, 1989, Gutfreund also sent me a
number of documents that he thought contained information that was
damaging to Erhard. The documents included a 15-page Table of Contents
prepared by Gutfreund reflecting approximately 500 pages of backup
documentation which Gutfreund had regarding Erhard and his activities
as well as those of the organizations with which Erhard is involved.
Included in the documentation which was sent to me by Gutfreund were
copies of the following.

(a) Declarations signed by Vincent Drucker and several other
individuals that were filed with the Superior Court in San Francisco
on behalf of Charlene Afremow in her then pending lawsuit against
Erhard. The copies of the Declarations which I received from Gutfreund
in March, 1990 did not bear the court stamp showing they had been
filed with the Court. The Declarations contained allegations by
Drucker and the other individuals that were damaging to Erhard.

(b) Letter dated June 6, 1989 purported to be written by an unnamed
employee of Erhard's company, Werner Erhard and Associates, together
with documents relating to emotional upsets of participants in the EST
Training and also to financial information with respect to Erhard. The
letter was not signed and the party to whom it was addressed was
blackened out.

(c) Gutfreund's Table of Contents included references to Erhard's
"personality disorders" and to Erhard's possible "connections with
neo-Nazism."

(d) Media articles critical of Erhard and his organization. All of the
materials that I received from Mr. Gutfreund were turned over by me to
the representatives of Scientology.

18. During the period since October, 1989, I sent or gave to Gutfreund
documents regarding Erhard and his organization in exchange for the
material he provided to me. The documents I gave to Gutfreund included
materials pertaining to the lawsuit filed by Erhard against
Congressman Cox in Orange County, California, and copies of several
letters written to the San Francisco Chronicle in response to their
April 3, 1990 article on the Afremow lawsuit.

19. During the course of my telephone conversations with Mr. Gutfreund
and my meetings with him on or about April 24, 1990, Mr. Gutfreund
verbally made the following statements regarding Erhard:

(a) Erhard is a profoundly evil man.

(b) Erhard is a gross pathological liar.

(c) Erhard is paranoid.

(d) Erhard has a fascist organization and it is a cult.

(e) Gutfreund contacted 60 Minutes regarding an involvement between
Erhard and the CIA.

(f) Erhard stole all the material he started with in EST.

(g) Erhard was definitely a neo-Nazi in the 1970's.

(h) Erhard has a criminal mind.

I transmitted all of this information that I was told by Mr. Gutfreund
to the representatives of Scientology.

20. During our conversations, Gutfreund made the following additional
statements relating to matters pertaining to past, current and pending
lawsuits involving Erhard:

(a) Gutfreund received the documents, consisting of the purported
letter from an employee of Werner Erhard and Associates and the
attachments relating to emotional upsets and to Erhard's financial
information, from Margaret Singer.

(b) Gutfreund said that the Declarations in the Afremow lawsuit which
he sent me in March, 1990 could not be made public for the time being,
since he promised the lawyer that these documents were sent back or
that nobody did anything with them for the time being. He said that
the lawyer didn't want the judge to get upset because these documents
got out since that would mess up his case.

(c) Gutfreund had provided audio tapes and other material on Erhard
and his organization to Randy Loftin, the man who lives with Charlene
Afremow who had a pending lawsuit against Erhard in San Francisco.

(d) Gutfreund had a telephone conversations with Gerald Ragland, the
attorney in another lawsuit (Slee) pending against Erhard in
Connecticut.

(e) Gutfreund supplied numerous members of the media with material in
an attempt to get the stories he wanted published. He specifically
supplied the Chronicle both with material connected to the Afremow
lawsuit, which included declarations without the seal of the court,
that he obtained by various means, and with material I supplied him
from Scientology. On several occasions Gutfreund contacted reporters
on the staff of the San Francisco Chronicle which led to the two
articles published in January and April, 1990 on the Afremow lawsuit
which were critical of Erhard and his organization. Gutfreund was in
regular and sometimes daily communication with Don Lattin, one of the
Chronicle reporters.

(f) Gutfreund spoke with a reported for KGO-TV in San Francisco
regarding Erhard on or about April 5, 1990, several days after
publication of the article on the Afremow lawsuit in the San Francisco
Chronicle.

(g) Gutfreund informed me that he has 4 or 5 reports [sic, reporters?]
interested in getting into the sealed divorce case.

(h) Gutfreund told me that he is working with the IRS against Erhard.

(i) He was in contact with former EST members now in Scientology who
were working with him against EST to prove their worth to the church.
Both Gutfreund and Scientology disseminate the information they obtain
on people to the Cult Awareness Network.

(j) Gutfreund things [sic] that Erhard paid off Ford Greene, his
attorney in his case against Erhard.

(k) Gutfreund was also in regular communication with Richard Behar, a
reporter published in Time Magazine.

21. Gutfreund had been in communication with several individuals who
were to be witnesses for Afremow in the trial of her lawsuit against
Erhard. These included Randy Loftin and Sharon Billings with whom
Gutfreund has been in regular communication.

22. Roger Stodola, from the San Francisco Office of Scientology, sent
material to Gutfreund as well as distributed it to the media through
his own media contacts.

(a) Stodola was in direct contact with Jessie Kornbluth of the Vanity
Fair who wrote a negative piece on Erhard in the fall of 1990 that
didn't get published and a piece in New Times magazine that did get
published in the mid 70's.

(b) Stodola fed information through his media contacts to John Hubner
of the San Jose Mercury News who wrote and had published several
negative articles on Erhard.

(c) Stodola fed information to Jonathan Littman, an author who wrote a
negative article in PC Magazine about Bill Millard, a former associate
of Erhard's, and who is now reportedly doing a negative piece on
Erhard.

(d) Stodola told me at one point that Randy Loftin informed him that
there was going to be an expose in the Marin Independent Journal.

(e) Stodola sent a packet to Gutfreund that contained among other
items, documents from Erhard's IRS tax case, the Slee vs. Erhard case,
and an anonymous letter from Erhard's office with the address whiten
out.

(f) It is my impression that Roger Stodola, San Francisco Office of
Scientology, has someone in Erhard's organization. Scientology is too
confident, they know too much about what is going on in Erhard's
office. Gutfreund definitely has someone who is working inside the
organization and is protecting them.

(g) Roger Stodola stated to me that in April of 1990 they had received
a call from someone they suspected as Gutfreund. This person offered
to sell "explosive material" regarding Erhard to Scientology for $1
million.

23. During all of my contacts with non-Scientology individuals
described above, I did not identify myself as having been engaged by
or on behalf of Scientology. I generally described myself as a private
investigator working for an attorney representing a group of
disaffected former "EST people" based in Los Angeles. I specifically
told Gutfreund that the objective of this group was to document
Erhard's criminal activities and then to notify the proper
authorities.

24. I am aware of other private investigators who had been engaged by
or on behalf of Scientology to perform investigations of Erhard and
his organization as part of the EST Project.

(a) One such person is Seth Derish, a licensed private investigator in
San Francisco, who was engaged by or on behalf of Scientology on or
about July, 1989 to obtain financial information regarding Erhard and
his organization. Mr. Derish did obtain such financial information and
he transmitted it to the representatives of Scientology. I saw the
financial reports that Mr. Derish submitted. In the information I saw
in the files that Scientology has on Werner Erhard, I saw information
that Scientology believes Erhard has a Swiss bank account and that
they have the account number.

(b) Another person was Alan Clow, a licensed private investigator.
Although I never met him, Mr. Clow also started an investigation on
behalf of Scientology. Mr. Clow identified himself to these people in
the same manner that I did, namely as representing former EST people.
Paul Gutfreund informed me that Alan Clow asked him questions about
Erhard sometime during 1990.

26. Scientology has five (5) full filing cabinets of information on
Erhard and EST and the material goes back to 1943. It includes in it
their actions and activity against Erhard going back to approximately
the last 20 years. Apparently Scientology had some problem with Erhard
and have been attempting to put him out of business for some time.
From the material in these cabinets it was evident Scientology was
compiling a media blitz against Erhard and that Scientology was behind
the 60 Minutes program and a national disinformation campaign to get
Erhard.

I declare under penalty of perjury under the laws of the State of
California that the foregoing statements are true and correct. This
Declaration is executed on this 1st day of November, 1991 in the City
of Tustin, County of Orange, California.

[Signature]
Theodore Heisig, Jr.