STATE OF ILLINOIS SS: COUNTY OF COOK IN THE CIRCUIT COURT OF COOK COUNTY COUNTY DEPARTMENT - LAW DIVISION JONATHAN L. NORDQUIST, Plaintiff, vs. No. 92 L 1447 Judge Nicholson LARRY ZILLIOX, et al., Motion Call B Defendants. Sworn Statement of JONATHAN LEE NORDQUIST taken before CAROL RARER, CSR, Notary Public, pursuant to the Illinois Code of Civil Procedure and the Rules of the Supreme Court pertaining to the taking of depositions for the purpose of discovery, at Suite 800, 321 South Plymouth Court, in the City of Chicago, Cook County, Illinois, commencing at 2:00 o'clock p.m. on the 9th day of June A.D., 1993. APPEARANCES: JOHN M. BEAL, Esq. 321 South Plymouth Court Suite 800 Chicago, Illinois 60604 appeared on behalf of the Defendants. ALSO PRESENT: MS. CYNTHIA KISSER INDEX WITNESS: · PAGE JONATHAN LEE NORDQUIST 3 (Witness sworn.) JONATHAN LEE NORDQUIST, having been called as a witness and having been duly sworn under oath, was examined and testified as follows: EXAMINATION MR. BEAL: This is the statement of Jonathan Lee Nordquist being taken on Wednesday June 9, 1993 in the law office of John Beal. I am going to ask you some questions. If at any time you have any concerns, let me know because you should not feel constrained in any way about any concerns you may have -- about voicing any concerns that you may have. I would like to start with the complaint in the case that was just dismissed and -- MS. KISSER: Do you need a copy of the complaint to look at? Would that help you? THE WITNESS: I haven't looked at anything ever before, so it doesn't matter. BY MR. BEAL: Q· Have you ever seen this complaint? A. Not the amended one. I seen the initial one. Q· You didn't read the amended complaint before? A. I didn't know there was one. Q· Actually you didn't read the First Amended Complaint or the Second Amended Complaint? A. No amendments, period. Q· Who drafted the complaint as far as you know? A. Somebody from the Church of Scientology in Los Angeles. I would assume it is the Bowles & Moxen team. Q. Why do you assume that? A. Because when I was in -- what's his name? -- What was my lawyer's name? Q. Moran? A. -- Moran. I am sorry. When I was in his office, he was looking it over for the first time himself. Q· And how did they come up with the information in the complaint in the case? A. I guess it is basically based on the declaration. I really didn't understand the complaint, though, as far as it fit with the declaration in general. Q· I would like to ask you about some of the statements in the complaint and if you, in fact, agree or disagree with them now that you have a chance to look at them in an open situation. It says here "Plaintiff," meaning you, "believes that CAN" -- which is the Cult Awareness Network -- "CAN's actual activities and purposes are to degrade this establishment and destroy religious organizations with which CAN disagrees." Do you have a view as to whether that is an accurate statement? A. Well, those aren't my words, of course; but basically I hate no views now on any of this, so it is not -- it is not an issue I would really know anything about or want to know anything about. At the time, yes, though. At the time that this was developed, yes. Q· Then it says in paragraph 17 that: "Plaintiff believes that CAN attempted to achieve the destruction of religious organizations, unnamed, by advocating and lending assistance to the forceful kidnapping and deprogramming of members of religious organizations." Do you have any information that CAN itself advocated and lent assistance to the forceful kidnapping and deprogramming of members of religious organizations? A. Okay, there were two things on this. The first part is that we talked about this -- not Moran, but the Scientology and I talked about this very sentence a number of times. I guess it was in the first one as well and other things that they put out. Q· Right. It probably was. A. And it was always a touchy thing. I mean, I wouldn't put my words saying that exactly. How can you destroy a religion by grabbing a person out of it? Q· Well, let me ask you this way then. Do you know of any examples where the Cult Awareness Network itself has been connected with forceful kidnapping and deprogramming of individuals for members of any organization? A. Members of CAN perhaps. But, see, the way this is is it is so manipulative. I have no firsthand direct experience with any CAN official in a CAN capacity saying, "Please, let's do a deprogramming" as a CAN member saying, "This is what we want to do for CAN." No, no. But individuals on their own, yes. Q· Individuals? A. Who are associated with CAN. Q. In what way? A. As members or as local officers and stuff like that. Q· But you are not aware of any instance where they were not acting on their own; is that what you are saying? A. No, no. No, no. Q· Wait a minute. We've got a double negative. A. Yeah, that's true. No, there is no -- I have no experience where like the board or officers of CAN using their positions saying, let's do a deprogramming of this person or that person. No. Q. What instances -- wait, let's take these one step at a time. Now it says here -- it looks like we are talking about the spring of '87 and then it says, "For the next two years, plaintiff received room and board and monetary support from CAN and its agents by agreeing to support CAN and attack the Hare Krishna movement." A. That is not exactly true either. Q· Can you tell me what, in fact, is? A. I don't know if you know much about Scientology, but what they like to do is stretch the facts as far as they can to somehow still resemble a little bit of truth, but stretching it to its extreme limits -- extreme limits. So, that is basically an extreme exaggeration. Q· That is not a fair characterization of the facts? A. No, it is not at all. It is not at all. They take -- it is like, okay, if somebody from CAN paid for a hotel room for me to go onto a talk show or something like that, they consider that as pay. Scientology and those lawyers considered that as payment because the hotel would have cost you 108 bucks. And, you know, they add it all up, and add it all up, et cetera, et cetera, you know. Q· Well, let me ask you this. There is a statement here that plaintiff remained -- "From 1987 through October of 1989, plaintiff remained associated with CAN during which time defendants Kisser, Krone, and CAN, under threats of physical violence and mental duress, forced plaintiff to perform the following acts --" A. Wait a minute. I have never seen or heard that statement before, so that is... Q· I am only asking you about the acts about whether you did them at all; and then whether you did them under threats of physical violence or mental distress. The first one is, "Appear as a speaker at various seminars, conventions, and televised press conferences and falsely state that he" -- being you -- "had been the victim of physical and mental abuse and torture by a cult, the Hare Krishna. This was done to attract publicity and donations A. This is now starting to get me angry because I guess this has actually been completely hidden from me. Anybody who knows that anything what I said while I was at CAN maybe angered some CAN members that I never claimed -- you know, I was never abused in the Hare Krishna movement. I never said that, never would say that. There have been abuse cases, but not with me. And I would have ****?????? A. Yes. Q· Where was that? A. In Los Angeles by Bowles & Moxen. Q· So you showed up and -- A. He talked to Bowles & Moxen on the phone. There was also a time from what I understand from the Scientologists from Mary Anne Ahmad that at one time he tried to drop out of case. He said, "This is not a case." They gave him a vacation to Los Angeles, sent him to Bowles & Moxen. They talked about the case. He was there for a week, and he came back all gung ho and ready to go. BY MS. KISSER: Q. Did you read this complaint before it was filed in the final form? A. This one (indicating), no. Q· The first one? A. The very first one, I scanned it only. Q· So you scanned the first one, but the subsequent complaint -- the First and Second Amended Complaint, you never saw or were shown before they were filed? A. Right. I didn't know they were even doing this. Q· Did Moran ever tell you they were filed after the fact? A. No. Q. So you never had any communication with Moran to the effect that a First or Second Amended Complaint had been filed? A. No, no. We spoke on the phone a couple of times, too, and he never mentioned it. He never mentioned it. Part of that could be my fault because in the beginning when I agreed, okay, we will go with this case was that it wouldn't -- I said two things: It wouldn't cost me nothing; it wouldn't take any of my time; and I don't really want much to do with it. And they said okay for that. So that might partially be my fault that they wouldn't tell me anything. Q· If it didn't cost you much -- A. Anything. Q. -- it didn't cost you anything and it wasn't going to take any of your time, what was the reason why you would bring the suit? A. It was told to me as a First Amendment religious freedom thing, the good guys versus the bad guys; it is your religious freedom against tyranny. You know, the whole thing. And, of course, the case has nothing to do with anything about religious freedom or First Amendment rights or anything like that. BY MR. BEAL: Q· Did they say you would make money? A. Oh, yes. They said I would make some money, but that was like -- I never took that too seriously, you know BY MS. KISSER: Q· So any financial gain you might get would be if and when a jury awarded judgment or an award or something like that? A. Right. Q· Did you receive any payments for doing the case? A. Not for the case, but for the declaration, yes. BY MR. BEAL: Q· You never went out to Los Angeles on the case itself? A. When they were first -- I guess they were actually preparing the case out there when I was there, but that was a year before the case came to effect. They work like that. You know, they are like bookworms, and they are working on things all the time. And the declaration was just a part of that. It was just simply a part of that. BY MS. KISSER: Q. Do you have any idea who paid the fees to Moran? Do you have any idea how money was paid to Moran? A. Scientology. The Church of Scientology and Bowles & Moxen. Q. How do you know that? A. They were raising funds. They were raising funds for the case. They asked me to raise some funds and I never did. And they were actually kind of angry that I wasn't taking much of a role in it. But Virginia Jensen is their legal person here in Chicago and she was the one who actually handled everything. Q. Are you surmising that, or did Moran ever say to you, I received money for my fees from... I mean, do you have any direct knowledge? A. Oh, no. I never saw money change hands. Q· Right. You never saw money change never had Moran explain how his fees were getting paid? This is just your summation based on what you being -- A. What I was told by them that they are paying. Q· "Them" is who specifically? A. Scientologists. Q· But which ones? A. Virginia Jensen, Mary Anne Ahmad. Q· Okay. A. What they were doing is they were keeping the case afloat by giving him money when he needed it. Q. I see. A. And he was going to take his money out if there was a judgment. BY MR. BEAL: Q. And you said there was some fund-raising for the case? A. Right. Q. And Virginia Jensen -- A. Right. She is the legal. Q. How do they fund-raise or something like this? A. They call all the different churches and affiliated people. They doesn't raise funds among Scientologists. They call the Christians and the different groups -- different religious groups that they were helped in the past; calling favors, in other words. Q· To raise money for a project like this? A. Yeah. Q· And they told you that they were doing that with respect to this occasion? A. Right, right. Q. And after the second occasion when you went back and they showed you the complaint and you looked at it, how carefully did you look at it? A. Not very carefully. My name was even spelled wrong, so... Q· You didn't sign the complaint? A. I didn't sign it? Q· I don't believe so. Of course, I don't have the original one here. A. I didn't sign any of the amended ones, of course. No, I think the only thing I signed was a retainer agreement there. Q· Did you ever pay Moran any money? A. No. He started asking me for money though. Q. When? A. I got a nasty letter after - he was trying to contact me for about a month. This is earlier -- way earlier in the year. And I was avoiding his calls Q· This year? A. Yes, this year. And then I go a real curt, short, nasty note to call him immediately about financial matters, it is in my best interest, and all of this stuff, which I never returned his call. Q· After that second time, did you have any communication with him about the case after you went and looked at this real quickly? A. No. We did sit down and talk once. It was in Daley Plaza -- Daley Center, I mean -- whatever. And it was in the cafeteria there. And he just asked me for a basic background of myself, and that was it. He wanted to know what the Hare Krishna were about, and that was it. Q· Was that before or after the case had actually been filed? A. It was right after the case had been filed. And he said there was a court date, and I showed up there. And it was cancelled or something. It was put off. And so I 1eft. And that was the last time I really -- I think that is the last time I saw him, yeah. Q. Okay. BY MS. KISSER: Q. Did Moran ever show you any of the documents that we produced in the case? A. No. Q. Were you aware there were document requests that were put on us? He never showed you told you that or asked you to help in the document request or showed the documents to you or anything like that? A. No. Q· He showed you none of the discovery in the case? A. No. I got faxed to me a list of questions from a deposition -- I guess your deposition. And I never had time to look at the fax. That was a real long list of questions, so... BY MR. BEAL: Q· You were faxed a list of questions they were going to ask Cynthia? A. Yeah, to see if I wanted to add anything. Q. And you didn't respond to that? A. No. I don't think that I even read it really. Q. Okay. Turning to the declaration, ... you more familiar with this version of this? A. That is the one I saw, yeah. I had a copy. I had an original -- . lot thinner copy, which I still have actually. I have one copy that like ten pages of the original. You know, this is all expanded when they pulled me to Los Angeles. Q. Why don't you tell us why how this was reduced? A. Okay. First of all, I was living here in Chicago. And Scientology and Bowles & Moxen's chief investigator, a guy named Gene Ingram, came to Chicago to interview me. And he paid me right on the spot . I mean, you know, he is like a slick talker and all of that kind of staff. He paid me like $300 cash to have lunch with him to talk. Anci ha took notes. He didn't record anything; he just took notes while we talked. Q· Co you remember when this was roughly? A. It would have been about six months before the date of this (indicating). Somewhere in there, six months before. Q. This is dated August -- Now this one has your signature on it? A. Yes, this is when I was in Los Angeles. Q· So this is dated August 26th, 1991? A. Right. Q. So this would have -- A. This would have been about six months before that. Q· Okay. A. Okay. Then that was over with. And I thought, you know, that was quick easy money and I hope he comes back. He did come back about two months later with the declaration for me to sign; not this one. Q. The l0-page one? A. The l0-page one. And it was so -- you know, anybody who would have read it would have known it is not my terminology, not -- I mean, it wasn't me at all. And I signed it anyways. He told me, "Okay, we will edit this, but just sign it here anyways." And he crossed some stuff out on it and he wrote notes on the side and stuff like that, And he paid me again. I don't know how much. It was just.... But he said, "Now, this isn't paying you for the declaration. He insisted it wasn't. It was just for my time. It is the highest paying job I ever had. Then about three or four months later, Scientologists -- I felt I was getting pressured by Scientology to take courses -- big time pressure to take these courses Q· All of that A. Yeah, yeah. I took one course and couldn't really figure it out. And they kept on telling me how much benefit I got out of it, you know. They wanted me to go here and there, here and there I with them and stuff. And I just said, "No way," and I took off and I went back to Berkeley, California and got an old job, that I used to have, back again. About two weeks after I was there, Eugene Ingram locates me there. Which I didn't contact any Scientologists. They know what they were doing. They are kind of slick. And he knocked on my hotel room door. I open up the door. And he said, "Come on, I have an airplane ticket for you." And I was down in Los Angeles to do this. This thing is the result -- it is kind of hard to explain. I know exactly what it means now about sleep deprivation and hunger; not because it was being forced, not because it is being manipulated, but because everybody was working so hard and I was like, "No, this is not this. This is not this." And then finally just -- the result of this was surrender. Q· You went down to Los Angeles and you went to the Scientology building there? A. Yeah, yeah. Q· Where Bowles & Moxen is? A. Yes. BY MS. KISSER: Q· Do you know what the building was, the address? A. It was the old Cedar Sinai Hospital. They have a huge complex there and it is the 5th floor. BY MR. BEAL: Q· And how long were you there? A. I was there for two days. But they put me up in a Hollywood hotel. They just tried to razzle and dazzle me with everything. It was a weird, weird like I was there actually three days, but editing this for two days. Q· And finally you say you surrendered? A. That was the result of surrender. BY MS. KISSER: Q· Is this the document you signed? A. Yes, I did sign that document. Q· So this, however many pages it is MR. BEAL: 35. MS. KISSER: Right . MR. BEAL: He signed both versions. MS. KISSER: Right. BY MS. KISSER: Q· But you believe this to be the document you signed? A. r believe so. But, now, Scientologists do have a blank page with my signature on it just in case there was editing. There's a number of different signatures in there. I agreed to do that. MR. BEAL: They signed Page 2. BY MR. BEAL: Q· So you spent two days. I take it you were there and they had all of these people doing the typing and making the -- A. Right, editing. And every time they wanted to go for a reprint it would take an hour because their laser printer was so weird and they had to go down downstairs to the basement to get a laser print and come back up to the 5th floor. I mean, they are so weirdly organized. Q. So you were telling them as you were going along that certain things were not correct? A. Yes. Q· And they were making changes? A. Right. Q· And finally after two days, what happened? A. After two days of nitpicking and arguing and nitpicking and arguing, I just gave up and said, yeah, yeah, okay, and... Q. You signed it? A. Yeah. Q· And you signed the back and you signed each page? A. I signed each page. BY MS. KISSER: Q· Did you read each page when you signed it? A. No. Q· At that time, did you -- A. At that time, I felt I knew every word of it, though, because -- Q. Okay. All right. At the time that you signed it, did you believe the document in tote to be correct? A. No. Q· Okay. So -- A. I felt bad about signing it. I didn't feel good about signing it. Q· So you cannot say now that everything was true when you signed it? A. Right. Q. Okay. A. I would say it is a manipulation at least, you know. Q· Okay. BY MR. BEAL: Q· Let's -- I think maybe there are a few things in here -- we are not going over the whole thing, but there are a few things in here that we would like to -- A. Clarify, yeah. Q· Clarify, right. A. There is one part in there that is the wildest, but I am sure you will get to it. MS. KISSER: If we don't, let us know. THE WITNESS: Okay. MR. BEAL: This is the first one we want? MS. KISSER: Right. BY MS. KISSER: Q· This one that we are looking at is does cult You say here, "Alev told me that except for Steve Eisenberg in Philadelphia, the Cult Awareness Network didn't have any former Hare Krishna they could use as deprogrammers." Do you ever know of the Cult Awareness Network ever having everybody that was actually a deprogrammer for the Cult Awareness Network? A. No. What that is basically is it is like it would be like saying, you know, does Q· But you don't know -- what I am asking you is do you know anybody that receives a salary or compensation of any kind specifically from the Cult Awareness Network that A. For the purposes of deprogramming? Q· For the purposes of involuntary deprogramming? A. No. Q. Okay. Right. Okay. BY MR. BEAL: Q· And then it says here, "Alev told me --" BY MS. KISSER: Q- "-- that I could earn a great deal of money by helping deprogram members of the Hare Krishna movement and also told me that one day I could probably become a Cult Awareness Network deprogrammer and make even more money." A. No. They inserted that with an automatic key "Cult Awareness Network" in front of- everything whenever they felt like it. Q· So Mr. Alev never told you that you could become a Cult Awareness Network deprogrammer? A. No. He did tell me that I could probably make some good income by being a Hare Krishna, you know -- excuse me, by deprogramming Hare Krishna. Q· Do you know -- A. But not for Cult Awareness Network, no. He didn't say that. He never said that. Q· And when he was talking about it, do you know whether he meant voluntary or involuntary deprogramming? A. That wasn't specified. I am sure it was voluntary because I am a little guy, you know. Q· Okay, at one point you say that you had a telephone conversation with Mary Krone. This says shortly after you made con~act with CAN, you say that you met with Reg Alev and Krone and that then you did a call-in radio show, and this was early on in the contact. And then you say that you became afraid and needed to go into hiding or something to that effect. You say you immediately phoned Krone and told her what had happened. Apparently some people had come by the hotel you were living in shortly after you had contact with CAN? A. Right. Q· All right. And for whatever reason you say you became afraid or concerned -- A. My legitimate concern, I think that I got infected with Mary Krone's paranoia. Q· And you had someone called James Brimhall, B-R-I-M-H-A-L-L, living with you? A. Correct. Q· You say here, "I told her," meaning Krone, "that Brimhall didn't have any money either. Krone indicated to me" -- this was at the time you were afraid shortly after contact with CAN and fe'lt you should move? A. Right. Q· " Krone indicated to me that I shouldn't worry because the Cult Awareness Network would pay for all of our living expenses --" A. That's another macro key. Q· " -- including giving us spending cash while they hid me out." So did CAN ever give or promise you any money of any kind? A. No. No. Q· Okay. "Krone told me the Cult Awareness Network had lots of money to spend these types of things." A. No. That is and out and out [lie] Q· Okay. So CAN had never given you money that would be viewed as income or compensation for services? A. The only time -- you know, see, this is another thing where they hunt and poke and they find things and put it together. The only actual time where I got money from -- that could loosely be said CAN -- was at the Philadelphia CAN meeting. And they took up a collection; and that person -- Q· And who is "they"? A. The CAN members there took up a collection amongst themselves. Q. Where was this? When you say "they," was this in a hotel room or what was it? A. It was in a church basement where they were having a CAN meeting. Q. Okay. So at a CAN meeting that you attended, a local CAN meeting, members gave out of their pockets personally? A. Out of their pockets right there. Q. And they didn't say, "This is from the Cult Awareness Network. These are donations made to CAN and then being given to you"? These were just people who said -- A. Right. Q. Well, you explain it so that I am not leading you. They just A· Right. They took up one person -- you know, I gave a little talk. And I was still on the road basically moving around. And then afterwards, they took up a collection amongst themselves and gave me the money. It wasn't a check. It wasn't a CAN check or anything like that. It didn't come but of CAN funds. BY MR. BEAL: Q· And this was the local affiliate people. BY MS. KISSER: Q. Okay. Then also you say that you appeared on a television show in Minneapolis? A. Right. Q. Then shortly after that, Mary Krone told you "it would be safer if Brimhall and I moved to a different location"? A. That's correct. Q· Okay. "Because she feared that Hare Krishna members would soon locate us"? A. Correct.. Q· Then it says, "During the next few months, Krone moved me and Brimhall to various hotels around the Chicago area." And then you go and say, "We didn't have to work because Krone always gave us sufficient cash to pay for our living expenses and day-to-day purchases such as cigarettes, beer, entertainment, et cetera. Krone frequently reminded me that the cash she gave us came from money donated to the Cult Awareness Network." Do you have A. That is not true. I never said that actually. No, that is not true. Q. Do you have any knowledge that any money was ever donated to the Cult Awareness Network and then given to you as cash? A. To me, no. Q· All right. Fine. A. From what I understand, Cult Awareness Network didn't have any money hardly. You know, it is not that kind of a -- Q· Then you say you later "-- learned from Mary Krone that Karen Pettijohn, an official with the Ohio Chapter of the Cult Awareness Network, had resigned her position because of the way donated money was being handled by Cynthia Kisser. One of the reasons Pettijohn was upset was because of the fact that Kisser changed the financial lines of the Cult Awareness Network. Kisser demanded that all affiliate Cult Awareness Network chapters send all the donations they received, including uncancelled checks, to her at the national office in Illinois. Kisser then cashed the checks, kept the amount of money that she wanted, and then mailed the remaining money back to the affiliate chapters as she saw fit." Is there any section of that that you know to be true? A. From what I understand -- from what I heard directly -- I don't know, see, this is wrong even in the way I would have said it. Krone wouldn't have been the one to tell me. Karen Pettijohn did say there was some kind of a thing that she was upset about a taxing system. Q· Okay. A. And the national office would be a central clearing house for the money. And it would be doled back out as necessary or whatever -- sort of like the federal government -- and that is what she was upset about. All this whole paragraph was like an expansion or, you know, an exaggeration off of that. Q. So you are relating something -- A. That had nothing to do with it. Q· -- that Pettijohn was giving you her impression of something that had to do with an internal procedure at CAN? A. Yeah, this is like fourth hand. Q· Right. Okay. But you don't have any knowledge of any monies coming to me, uncancelled checks coming to me personally -- A. No. I never even heard that term uncancelled checks. Q· -- or anything like that? So do you have any knowledge of any financial irregularities in donations of monies to CAN by any parties? A. Zero. Q· Okay. 46: You relate at one point that you were in Crystal Lake, Illinois, and that there was a hotel called the Happy Family Inn, and that you were staying there and that Krone was -- you say, "Mary Krone originally rented the room in her name. She then on a weekly basis gave me Cult Awareness Network money to pay the rent. All of the cash receipts were in my name." Do you have any knowledge that any monies came from the Cult Awareness Network to pay your rent? A. No. Zero. Q· Then you say that, "Sometime in December of '87 Krone purchased two Amtrak passes for Brimhall and I." Now, do you have any knowledge of when Mary Krone was released from employment with the Cult Awareness Network? A. No. Q· So you do not know if in December of '87 she was or was not employed by the Cult Awareness Network? A. No. Q· Okay. All right. In December of '87 this happened. You say, "Brimhall and I then traveled around the East Coast. I gave speeches at various Cult Awareness Network affiliate meetings. Can you explain what that meant or any part of that A. No, that is not exactly not true. What she did was she was arranging. She was always making calls and arranging things and stuff. She is like that kind of a person. Q· Right. A. And she called like the New York affiliate and the New Jersey people and the Philadelphia people -- that is when I went to Philadelphia -- and all over the place out there to try and get this -- you know, me to talk about the Krishna at these locations. And she figured it was a way to keep me away from the Krishna. So, yeah, that did happen. Q· Do you know where she was making these calls from? A. No. Q· I mean, was it Do you know she made them? A. Yes. Well, because, I mean -- Q· And so you don't know whether she was making them from the CAN office or from her house or where? A. No. I never knew where the CAN office was. Q· So you had never been to the CAN office? A. No. Q· So at least through December of '87, if this is correct, that is what you are saying she was doing? A. Yeah. Q. And where would the money come from for you to go out there or to give the talks or whatever? A. She somehow arranged it. Q· Okay. All right. BY MR. BEAL: Q· Other than Philadelphia, where did you go? A. New York, Long Island; New Jersey; Akron, Ohio; and then out west after that; someplace in Indiana. BY MS. KISSER: Q· But she was giving you money to do these? A. Yes. Q· All right. Fine. A. At one time the money ran out, though, and I had to hitchhike, so... Q. But did she represent it was money coming from the Cult Awareness Network or -- A. In a loose, loose way. It was like CAN people helping out to do this. They wanted me to come around and do the talks. I think a lot of this has to do with her own -- Mary Krone's own way of looking at things, which might not be the way that people normally look at things. Q· I think what I am trying to ask you is do you have any opinion to believe that the Cult Awareness Network was backing the speaking tour in any way -- A. I believe that the affiliates were that the local affiliates of the Cult Awareness Network were, I believe, at the time because I thought they had to give her the money to be there. Q· Okay. So your belief that the affiliates were doing this, did yoU have a clear understanding that the affiliates were working with the national office on this, or did you not know that? A. I didn't know that. That was not something that I would have known. Q· Okay. Fine. BY MR. BEAL: Q· So you dealt with Mary Krone directly rather than with the national office per se? A. Right. I never dealt with the national office. Q· Did you ever deal with me in regard to any speaking tour or any media event or any job or any activity? A. Nope. The only time I can remember anything is when you asked me for my Social Security number for some reason after that Minneapolis TV show. Q· And that would have been -- A. For an airplane ticket or something -- Q· That would have been approximately when? A. Right in the beginning of my contact with CAN, right in the beginning. Q· All right. Now, then you say you say, "With the exception of Michael Lissman, all of the deprogrammers mentioned above told me that they were interested in teaching me how to work with them as a Cult Awareness Network deprogrammer." A. That is the macro key, just throwing Cult Awareness Network in as "a deprogrammer Q· Do you know anyone who claimed to be a Cult Awareness Network deprogrammer, anybody you met, whether they were A. No. They all would clearly disassociate themselves directly with CAN. And if they were a member of CAN or had a position with CAN, they separated the two activities. Q· Do you know what it means to be a member in CAN? I mean, do you know like official definition or what the requirement is? A. Not exactly. But I do know that one deprogrammer --New Mexico. Names are escaping me. Q· Well, it doesn't matter anyway. A. Yeah, okay. -- was also listed as an officer of an affiliate of CAN. Q· For what period do you know that he was listed as an officer? A. During the time of my deprogramming, not my -- when I was involved with the deprogramming of Billy Crockett. Q. So what time period might that have been? A. I don't know. r don't know. The spring of '87? Q. So you think -- well, tell me what -- tell me what position you think that Szimhart held in CAN and what date range you think he might be talking about that he held that position? A. I assume it would have been for a year's term or something at one time, and it was MR. BEAL: Spring of '88? BY THE WITNESS: A. Spring of '88, right. BY MS. KISSER: Q. Do you have any reason to know that at any time that Szimhart had this position A. But he clearly made it very, very clear that his position was a voluntary position within CAN, and that what he does on the side as a deprogrammer is not -- I mean, you know, they all made certain that was clear. Q· Do you have any knowledge that any officer or director of CAN knew that Szimhart was holding a voluntary position with CAN and at the same time had knowledge that he was engaged in any illegal activity? A. That i~ hard for me to say. That is something beyond my --. BY MS. KISSER: Q. Do you know of anybody -- I mean, do you know of anybody that you know that knew that Mr. Szimhart was -- regardless of whether he was or was not doing anything illegal -- that you feel someone might have claimed that they knew? A. I would have felt that everybody would have known what his activities were because he was a famous deprogrammer. Q· But you BY MR. BEAL: Q· Did you have any conversations with anyone who was an officer of CAN about Szimhart? A. No, only Szimhart himself. BY MS. KISSER: Q· So you don't know when Szimhart might have discontinued having a position with CAN or whether there was any simultaneous time period where he held this position and where an officer of CAN might have known he was engaged in -- A. No, I wouldn't know that. I wouldn't know that. Q· All right. Then it also says here that "they, " meaning the programmers -- Oh, yes, here we go. "The deprogrammers confided to me that they got most of their deprogramming referrals from the Cult Awareness Network. They told me that it was common practice to kick back a donation to the Cult Awareness Network for every Cult Awareness Network referral they received that resulted in a successful deprogramming." A. That is a complete -- that there is a statement that they just kept insisting -- that is a Scientology lie. They have to throw the kickback in or this whole thing is worthless. Q· Do you know of anyone who ever claimed that they were making a kickback or had made a kickback to CAN? A. No. Q· For any reason? A. No. Q. For any kind -- A. No. They know that this -- this was all known to be not true when it was written. That is something that they had to put in there, they said. Q· Fine. Then you talk about the Billy Crockett deprogramming, which I understand from reading this that it was an involuntary deprogramming; is that a correct assumption? A. Right. Q. All right. You said you "became sick after Crockett's deprogramming attempt"? A. Right. Q. You say, "As a result, I thought of myself as a hypocrite because I had aided and abetted the other deprogrammers in kidnapping Crockett, and in the subsequent attempts to deprogram him. As a result, I voiced my objection to Cynthia Kisser, the executive director of the national office of the Cult Awareness Network. This turned out to be a big mistake because of the high regard that Kisser and the other members of the Cult Awareness Network had for deprogrammers. Cynthia Kisser told me in no uncertain words that I should keep my comments to myself." Do you have any recall as to such a conversation? A. That is not true. Q. Do you ever recall me telling you -- A. We never spoke about it. That is not Q. Okay. So you have no recall of that? A. No. Q. All right. Then you say here that, "During May of 1990, I received a telephone threat from Larry Zilliox, the security chief for the Cult Awareness Network." Do you know, in fact, that Zilliox was or was not the security chief? A. He had a business card that said that, yes. Q· He had a business card that said he was the security chief for the Cult Awareness Network? A. Security director, yeah. Q· He had such a card? A. Yes. Q· Okay. All right. Then you say, "I asked him --" A. But his address on it was New Jersey, not Chicago. Q· Okay. "I estimate that during the time the Cult Awareness Network hid me and Brimhall from members of the Hare Krishna religion, we were given at least $12,000 in cash. This came from money donated to the Cult Awareness Network. None of this money was ever used for educational or other charitable purposes." A. No. That is not something that I would have said, and that is not something that was true. No. Q· Then you say that "I have learned that Cult Awareness Network is a well-organized and well-funded hate group and it's real purpose is to convince people to give up their chosen religious beliefs." At the end of this paragraph you say, "The money that Cult Awareness Network deprogrammers/counselors kick back for referral fees hidden in the form of donations comprise a large portion of the money earned by the Cult Awareness Network." A. That is not true. Q· You do not know that to be true? A. I would doubt it to be true. I would doubt it. Q· Do you know of anybody who ever said that they gave a kickback to the Cult Awareness Network ior a referral for a deprogramming? A. No. Q. Okay. Those are all my questions. Now, you said there is something in here that you thought was A. That was the $12,000. Q. Okay. These are the documents that were reduced. You have never seen them, but these are he documents that were produced to your attorney in response to information about you. And it is just an assortment of stuff. This is an article that was -- I believe it to be accurate reprint of the article in the New York City Tribune? A. Right. I have a copy of that. Q· In that article Were you interviewed by this paper to your knowledge? A. Yes, yes. Q· In it, it says that -- in talking about Nordquist, "His 'defection' is sure to cause concern among CAN officials, as Nordquist has been paid in the past to act as a spokesman on radio and television shows"; is that true? A. No. Q· Then it says here, "Although CAN has not as yet been implicated or prosecuted in any court case, Nordquist claims that two board members, Robert Brandyberry and Mark Roggeman, have been convicted of kidnapping." Do you know if Robert Brandyberry was ever a board member? A. No. And I don't know who Roggeman is, so.. . Q· So you don't know who Mark Roggeman is. And you say you do not know if Robert Brandyberry was ever a board member? A. Right. Q. Do you know if either one of them was ever convicted of kidnapping? A. I wouldn't know. Q· Nordquist says Daniels -- they are talking about a man named Cliff Daniels -- is one of the main deprogrammers to whom CAN refers distraught parents on the West Coast." Do you know of any relationship that Cult Awareness Network has with Cliff Daniels? A. No. Q. Now, this is a press release that was issued by the Church Universal and Triumphant up in Montana, and it was put out by Erin Prophet. In it Did you ever go up to Montana? A. No. I don't even know any Church of Universal people. Q· Okay. In this press release or whatever you want to call it, news release, it says that "Nordquist, 29, a former deprogrammer and associate of Szimhart --" we are talking about this Mr. Joe Szimhart -- "is very familiar with Szimhart's deprogramming activities. He said that he and Szimhart worked together on a deprogramming, and he stayed in Szimhart's house in San Francisco." Now, did you ever -- looking back at your history of employment for people, would you consider that you did many deprogramming jobs -- meaning whether they are involuntary or voluntary? A. No. The extent of it was the one deprogramming, which was a failure; and then as far as actual -- you know, I mean, that was the only thing I ever got paid for. Q· It says here before becoming a deprogrammer, Nordquist was a member of the Hare Krishna sect for two years and left voluntarily." Would you consider that you did hold a position as a deprogrammer -- A. I was a member of the Krishna for ten years, not two. Q· Okay. They say two. A. Okay. Q· Would you ever say that you held yourself out or that you did, in fact, have employment as a deprogrammer on any kind of a regular basis? A. No. No. Q· So you can recall how many cases you actually received money for deprogramming? A. One. Right. Q· Okay. It says, "The Cult Awareness Network quickly recruited him," meaning Nordquist, "because they wanted to train me to become their Krishna expert." A. Yeah. I think they are getting this stuff based on other -- Q· Right. But I am just trying to take a look at whether any of this is true as presented here. All right. A. That is long. Q· Yeah, it is, but we are not talking too much about it. Okay. "Nordquist also confirmed that Szimhart is associated with CAN and that he receives biweekly referrals from CAN to do deprogrammings, although both CAN and Szimhart try to hide the relationship." Do you have any knowledge of that? A. No. Q· Okay. "There is a document put out by CAN that labels him as the regional coordinator of the southwestern United States for FOCUS, said Nordquist." A. That is the document that Q· But you don't recall when Szimhart might have held that post? A. Oh, no. No. Q· And you don't know whether he held it simultaneously with any allegations of illegal acts? A. No. Q· Okay. "There is a document put out by CAN that labels him as the regional coordinator of the southwestern United States for FOCUS, said Nordquist." A. That is the document that Q· But you don't recall when Szimhart might have held that post? A. Oh, no. No. Q· And you don't know whether he held it simultaneously with any allegations of illegal acts? A. No. Q· You are welcome to look at any of these documents later if you wish. A. I don't really want to. Q· Okay. This is a newspaper article that appeared in a paper called The Chicago Crusader. A. I didn't know that. Q. It is dated March 24th, 1990. "Terrorist group stalks black churches," and you are listed at the end as the person to get more information from. And it says A. Oh, yes. Q· "Jonathon Nordquist at the Religious Freedom Project." A. Yeah. Q· Okay. It says in here that, "In reality, the Cult Awareness Network is a group that acts as a clearing house of religious kidnappers and brainwashers who operate under the euphemism deprogramming or exit counselors." A. Those are Mary Anne Ahmad's words. Q· All right. How do you know this? Do you know who wrote this? A. Yes. Mary Anne Ahmad wrote this for the Chicago Crusader. Q· How do you know that? A. She told me. And I did see a copy of that. Q· Who is Mary Anne Ahmad? A. She is the PR director for Chicago Church of Scientology. Q. And then it says here -- this is a quote from you, Mr. Nordquist, who was visited by the national director Reg Alev -- and I will skip a few words, said, "within weeks I was on the CAN road show travelling across the country at CAN's expense giving talks and appearing on television and radio condemning the despicable cult I had left." Now, did you know -- A. At CAN's expense, no. No -- well, I mean after the fact. Q· Okay. But you did not tell her this for this article; or you did or you did not? A. No. She picked it out from other stuff. Q· Did she tell you before she wrote this that she was putting this in about you? A. No. Q. "According to Mr. Nordquist and other victims of CAN, kidnapping, deprogramming is CAN's cover word for a process of mental coercion and physical and sexual abuse using brainwashing techniques developed by the Communist Chinese." Does this sound like anything that A. Not that I would have said, no. Q· Do you believe that CAN does, in fact, use deprogramming to mean this physical and sexual abuse? A. No. Q· And then at the end you are listed as a resource for the Religious Freedom Project? A. Right. That was a Scientology group that lasted about -- T mean, they may be director of it for a day. Q· I was going to ask you about that later on. All right, this is an article from the Barrington Courier Review dated February 20th, 1992. David Kirkpatrick did that article. In that, it says "Nordquist said he worked for CAN as a deprogrammer in 1988 when he was allegedly recruited by Alev." Do you recall saying something like that to David Kirkpatrick? A. I probably said that, yeah. But, see, in a lot of ways, you can say, you know, working -- I am trying to get the right terminology here because wherever they insert like Cult Awareness Network in something, they are using that in such a broad general way -- not as the entity maybe, but with CAN people. Q· Did you ever work for CAN as a deprogrammer? A. No. No. Q· All right. A. And I wouldn't have said it that way, no. Q· Well, David Kirkpatrick to my knowledge is not a Scientologist? A. He is close with them, though. He is close to them. Q· What do you know about his relationship with them? A. He is very close to Mary Anne Ahmad. Very close. Q· In what way? A. Buddies. Buddies. And with Virginia -- I think that Virginia and him go out sometimes and stuff. I don't know. I mean, they are very close. Q. But do you recall being interviewed by Kirkpatrick? A. Yes. Q· So you do not recall whether you told him or not you had been a deprogrammer for the Cult Awareness Network? A. No. I wouldn't have said that. Q· Okay. So you would not have said it the way it appears here? A. No. Q. "Nordquist said he worked for CAN as a deprogrammer in 1988." A. No. Q· All right. A. But he could have easily been coached, you know. Q· This is something that appears on your signature. Did you ever have stationery like this? A. Not stationery, no. Q· Do you recall ever sending this out? A. I don't remember. Q· That's all right. You don't remember. That is all right. But you don't remember offering yourself as a deprogrammer as a business? A. Oh, yes, I did. Yes, I did. Q· But how many cases did you or -- clients did you have while you did this business? A. Zero. Zero. Q. All right. Then this was a -- there was a lengthy booklet that I think was sent to us in the mail from you, and it included kind of a -- it looked like a compilation interview that you had put together from various interviews that you had had. And in it, you have this page where you listed some of the interviews that you had done and had extrapolated from. You have at the bottom -- First of all, do you remember preparing a document like this? A. Yes. Q· All right. At the bottom -- A. That was the big confusion that I got into all of that trouble with when I was associating with CAN members. Q· Now, it says here, "The statements, opinions, and comments herein do n6t necessarily reflect those of FOCUS, Cult Awareness Network, or its affiliates." Was that true when you prepared this document? A. Correct. Q· So the media engagements that you list here A. It had nothing to do with CAN itself. They weren't sponsored events. Q· So this statement refers to the opinions that were expressed during these media events? A. Right. Every page thereafter, in other words. Q· This is a bulletin board -- this is a download from a bulletin board and it appears to be a bulletin board that shows a communication between Janardana Dasa and Rowan Moonstone? A. Oh, yeah. I know Rowan. Q. Did you communicate with him on a bulletin board? A. That is actually a her. Q. Her. Thank you. All right. This appears to be a download of communication between the two of you? A. Right. Q. It says on here -- talking about CAN here, "There are very few 'ex'Hare Krishna's available to CAN, therefore I became a hot item, a Propaganda tool to be pulled out when and where they wanted. I did their TV talk show circuit, radio shows, newspapers, and spoke at scores of local CAN meetings, and even stood on various CAN committee projects Like the Jonestown Memorial project in San Francisco." Did you speak on behalf of CAN on TV talk shows, circuits, radio shows, newspapers? A. Only one time was there a time when Reg told me to say I was with CAN -- Reg Alev -- and that was during the Milt Rosenberg show on the radio here. Q· So one time A. And working with CAN members for, you know, about two years; I worked with CAN members on projects, but that is different. Q· As a volunteer, not as a spokesperson for CAN? A. Oh, no . Q· For money for CAN? A. No . Q. So not for money for CAN, correct? A. Right: No raising money. Q. Okay. All right. Strictly something that you volunteered on? A. Right . Q. Do you know roughly when that Milt Rosenberg show was that you say you did say -- A. That was my first contact with CAN. It I was about two weeks afterwards. Q· Was I, the director of CAN, there? A. No . Q· Then you say, "CAN orchestrated the kidnapping and deprogramming of William Crockett, a ten-year member of an offshoot of the Krishna movement." A. That is a misrepresentation. Q· Did CAN orchestrate the kidnapping and deprogramming of William Crockett? A. No. Q· Then, do you recall this letter dated April of 1990? It was a mass mailing that several people received and told me about. A. No. Q· I will let you look at it. Do you ever recall that mailing going out? A. That is not even my terminology. Q· So you have never seen this mailing? A. No. I know who wrote it though. Q· Who do you believe wrote it? A. I believe that Randy Kretchmer who is the Scientology chief of investigations here in Chicago. Randy Kretchmer would have written it. Q· Why do you believe he wrote it? A. Because he has got a sense of humor and that is his style. Q· So you don't know for sure? A. Right. Q. Then I have a mailing that is under the banner head of the Religious freedom Project. Actually I have a couple of those. Do you recall doing any mailing -- there are two of them here -- there is actually three of them here. A. I believe I recognize this, but I didn't actually compile it, no. Q· Do you believe you wrote that document? A. I didn't write it, no, but I signed it, I am sure. Q. All right. So you believe you signed it but you didn't write it. Do you believe that you wrote this document? That looks like a personal letter, not a mass mailing. A. No. This doesn't even look -- I don't think I saw this. Q. I believe that did turn into a mass mailing, but I am not positive on it. A. Okay. Q. Do you recall this letter? This goes with it (indicating). You don't recall these mailings? A. Not offhand, no. Q· Do you know that any mailings were going out on your signature? A. Yes, I knew. I knew after the fact because they asked me a long time ago when I wasn't really being so cooperative with them to just give a page of signatures; and I did do that. Q· Okay. So you believe that you might have a lot of your signatures being used -- A. I would have authorized it, yes. Q· But you might not necessarily have seen A. Right. Q· -- might you have not necessarily seen the document? A. I wouldn't have seen it beforehand. Afterhand, yes. Q· Do you have any idea where the mailing list came for this mailing? A. I know that they -- I know some of their tricks. The way they pulled their tricks on how to get mailing. Q· But do you know who -- you don't know anything about this specific mailing list? That's all I am asking. A. No. I wouldn't even have known where it was mailed. Q· Do you have any idea who you talked to about the use of your signature on these mailings? A. Randy Kretchmer. Q· Do you have any idea who paid for the cost of the printing or the mailing? A. That would have been the Church of Scientology. Q· You believe that? A. Yeah, unless he took it out of his pocket personally. I doubt that. Q· Why do you think it was the Church of Scientology that did this mailing -- these mailings? A. Because they were the ones -- they were the Religious Freedom Project. Q· Fine. I was going to talk about that later. Okay. This is bio that was passed out by the Friends of freedom about you. And I just want to ask you about one sentence. It says "Jonathan Nordquist is an ex-deprogrammer and former supporter of the Cult Awareness Network. He has worked with CAN members on CAN sponsored projects such as the Jonestown Memorial Day in 1988 and has represented CAN on television and radio talk shows and interviews." Did you -- and I know this is redundant, but I am just looking at this document represent CAN on television and radio talk shows and interviews on any kind of a regular basis other than that one time that you mention? A. I went on the radio with CAN people a lot. Q· But were you speaking as an agent for CAN? A. No, no. But I would give CAN's telephone number out as a resource. MS. KISSER: This is a press release by the Religious Freedom Project -- a wire release that was put out. And actually let me ask you this other question first and then we can ask him about this project. Let me get the smaller one out of the way first. BY MS. KISSER: Q· Okay. Can I ask you what do you know about the Religious Freedom Project? A. The Religious Freedom Project was the idea of Randy Kretchmer and a couple of other Scientologists. Q· Do you remember who? A. It would have been Mary Anne Ahmad, Carol Brooks, Allen Brooks -- not Virginia really, she wasn't involved in that -- but the whole OSA group -- Office of Special Affairs -- here in Chicago. Q· And do you know whether it included anybody besides the Scientology members? A. Oh, yes. Yes. It was -- the whole idea was to get every other group involved -- every other group that had any contact with CAN in any way involved in the Religious Freedom Project. Q· So who else might have been a participant -- a participating organization? A. On paper, many, many organizations. The Unification Church, the Church of Universal and Triumphant on paper; I mean, in a loose way. Q· Does this mean that these organizations knew that they were affiliated with this? A. Supported it in some way. Q· Right. A. You got a letter saying, you know -- Q· They knew? A. Yes, somehow; but loosely. There was no real association there. Q· Was it incorporated to your knowledge? A. No, it was not. Q· Okay. Do you know if there was any central office for it? A. No, just a mailbox. Q· And do you know if there was any central financial account for it or anything like that? A. No. No bank accounts, nothing. Q· You don't know anything about its financial operations at all? A. No. There was no financial operation far as I knew. Q· Did you have a position with it? A. Director. Q· And did you have receive any compensation for being a director? A. No, no. Q· Do you happen to know what this organization actually did do, any activities that it actually did? A. The most I know about was the mass mailings. Q· Right. A. And then trying -- well, basically, I think Mary Anne Ahmad's job was to try and link these groups together. The Unification Church, that group down in Louisiana or Mississippi. The LaRouches -- not the LaRouches. Alamo? Tony Alamo or something like that. You know, their group was pretty supportive. And Friends of Freedom; George Robertson, he was very supportive. He was actually a very big part of it. Just to link them together to possibly in the future pool resources. I mean, she had an idea that it would actually go somewhere. Q· Did it have any kind of statement or purpose? A. I think they wrote one, yeah. Q· But you did not see it or recall it? A. No. Q· All right. On this review -- A. They made me a director as an annoyance thing. That was all. Q. What do you mean an annoyance? A. just to be annoying. Q· What do you mean to be annoying? A. If my name was on it, it would be an act of harassment. It would harass CAN members in some way, you know. Q· I see. Now, it says on here, "Jonathan Nordquist is --" this is the wire release that went out March 15th, 1990, which I received on March 16th. It says, "Jonathan Nordquist is director of the Religious Freedom Project. He worked for CAN for several years as Cynthia Kisser's assistant." Is that true? A. No, that is not true. Q· "I became a part of CAN's road show, Nordquist said, travelling across the country at CAN's expense, giving talks and appearing on radio TV condemning despicable A. That is just a quote from an old newspaper thing. It is not true too. Q· "From his experiences with CAN, Nordquist believes that they are a threat to religious freedom. He said that as a deprogrammer working for CAN, he participated in kidnapping and deprogramming the members of several religions. Is that true? A. That is not true. Q· Now you mentioned the Friends of Freedom? A. Yes. Q· What do you understand that group to be? A. It is very -- very difficult to figure out. It is George Robertson, who is a minister of some group that is -- he says it is Baptist and he is not really a Baptist. Maryland Bible College. I forget the name of the group that runs that. He runs it. He gets very little funding from his church. He is always broke. And this is his mission in life, basically, is to run this Friends of Freedom. Q· Do you know how it is funded? A. It is funded through his church primarily because he uses the church offices or college offices, he uses church members for secretarial work and stuff like that. And whenever there is a major event that he has to go to like a CAN conference or whatever, he gives the money through them. Q· So as far as you know, you are not real familiar with any contributors to it? A. Scientology contributes to that. Q. How do you know? A. Because they pay for his plane tickets and they pay for him to come to Chicago regularly. when there was something going on in Waukegan, they paid for, you know -- Q· How do you know that, that they paid for it? A. Just through talking with George. George is very candid. Q· I mean, George told you that? A. Yes. Q· George. Do you recall George Robertson telling you that expenses were being paid for specifically by the Church of Scientology? A. Right. And that sometimes he couldn't make it to certain events because Scientology wouldn't cut the check and stuff like that. Q· What was your relationship with the Religious Freedom Project, if any? A. With Friends of Freedom? Q· Excuse me. Friends of Freedom, yes. A. He is very, very careful not to take any members. He has no members in the Friends of Freedom. He has only people who support and volunteer and stuff like that. Q· Do you have any idea is there a board of directors? A. He claims there is, but nobody knows who they are. Q· Did you do any projects that you can recall with him? A. Yes, yes. Q· what type of projects did you do? A. Video events, speaking engagements, that kind of thing. Q· And were you paid for these? A. No. Q· Were you paid your travel? A. My travel was paid for. Q· And do you know who paid the travel? A. He did, but -- which means that the money came through him from Scientology or from his church. Q· Would he give you cash or would he write out checks? A. They would just pay for my tickets. Q· So you would just receive your tickets paid for? A. Yeah, and get some cash for like meals and stuff, you know. Q· Did you ever participate in any events with George Robertson or anybody else with the Friends of Freedom and with other officials or agents from other organizations? A. Yes. Q· For example, can you recall some? A. Voice of Freedom. It is an TV -- a cable TV syndicate which is -- I forget the guy's name, but some reverend has it. It is a cable TV show syndicated nationwide. They linked up for a TV thing. It was four days of interviews on that. The Unification Church, the Hare Krishna. Q· When and where would they come together? A. They would just come together for special events of sorts, like the big press conference in New York at the time of the CAN conference with Billy Crockett there. Well, that was cooperation between the Unification Church, the Hare Krishna movement and Friends of Freedom and Scientology to get that all pulled together. Q· I recall seeing you at some CAN conferences after you had become associated with the Religious Freedom Project? A. Scientology paid, yes Q· Did they pay you directly cash, or how did they pay you? A. They paid for the tickets and they registered my room and stuff like that. Q. How do you know it was Scientology? Do you recall a particular person giving you the ticket or what A. Yeah, they would give me the ticket. Mary Anne Ahmad. Q· Who is they? A. Or -- I think Mary Anne Ahmad gave me the ticket the last time for Oklahoma. Q· So you recall Mary Anne Ahmad giving you airplane tickets for Oklahoma? A. Right. Q· Do you recall any other Scientologists ever giving you tickets or monies or -- A. The only -- see, Scientologists are very, very careful. They think about the future too, and about implications from handing somebody something because they are suspicious people in general. The only money I ever actually received for any of my activities was the money for the statement, which they can easily say it didn't come from them because Gene Ingram is not a member for Scientology. He works -- he has his office in their building, but he is not a member. You know how that works. Another time Mr. Randy Kretchmer -- right in the beginning of my contract with him, he gave me a $1,000 so-called loan that I wouldn't have to pay back. Q· Do you know why he gave it to you? A. To be, you know, just a convenience thing basically. Q. You were not asked to do something in specific in return for it? A. Right, right. Q· You said you know Mary Anne Ahmad? A. Yes. Q· What do you understand her position to be? A. She is the director of -- or I forget her office name. They have all of these abbreviations for everything. She is the PR chief, public relations person for the Office of Special Affairs for Church of Scientology. Q· What about Randy Kretchmer? What do you understand him to be? A. He is the invest -- they say invest officer, investigations officer for the Church of Scientology in Chicago. Q· What does that mean? A. That means he is the spy. He is the one that goes through your garbage. He is the one that goes through and watches CAN -- you know, cars in CAN's parking lot and takes down plate numbers. He is the guy who does all of that. Q. How do you know that he does that? A. I have gone with him. I have gone with him. Q· what specifically have you observed him doing that would fit into that category? A. Just writing all the license plate numbers mostly to see who is tracking -- who is going with who, who is doing what. Q. Can you recall a specific place or event even if you don't remember the date that took -- A. In particular the hunt for the national office. If you knew exactly what went on for that. There was probably -- probably ten cars involved in just hunting and hunting and hunting for your car, looking for your car. Q· Oh, you mean there was a concerted effort by Kretchmer to locate the national office; is that what you are saying? A. Right, yeah. Q· Do you recall anything else that you did with him that would fall in this category of surveillance of either CAN members or CAN officials or anything? A. Not directly, no. He would be careful not to give me that, you know. Q· Do you ever remember him telling you -- A. Oh, yeah. He tells me lots of stories about going through garbage, how he found out about Reg Alev's connections with other veteranaries and his airplane bills or something, and things that I didn't have any knowledge of anyway, so... I didn't know Reg Alev was a veterinarian, so... Q· Did you know Robert Wagner? Do you know who Robert Wagner is? A. No. Q· Do you know Fred Bashaw? A. Yes. Q· What do you know of Fred Bashaw? A. That he is a Scientologist, that he is Oh, Robert Wagner? He is the photographer that goes to all of the CAN meetings and causes trouble. Q· Not to my knowledge, no. The Robert Wagner I am asking about lives in Boston. A. Oh, no, I wouldn't know him. Fred Bashaw, I know, he is a local here, I believe. And he is just -- he is not a member of the Office of Special Affairs, but he guess like a wannabe. And they will use him for certain things. He volunteers for Randy Kretchmer a lot. Q· What about Jim Mayer? Do you know Jim Mayer? A. Mayer, no, I don't believe. I don't know that name. Q· And the last person that I want to ask you about, who is Sue Taylor? A. Oh, Sue Taylor, that is a scary figure. Q· Have you met Sue Taylor? A. Yes. Q. And who is Sue Taylor? A. Sue Taylor is the Chief of Office of Special Affairs, which includes all the departments within it based in Washington. Now, she is not the head of the whole OSA for Scientology, but she is way up there. Q· Has she ever come to Chicago? A. Yes. Q· Have you met her? A. Yes. I met her a couple of times, yes. Q· Under what circumstances did you meet her? A. Planning and interviewing and stuff like that, and plotting and scheming. Q· In regard to what? A. Activities at the CAN conferences. Q- Did you meet her at CAN conferences? A. Yes. Q· And what did you perceive her basically A. Her role was there to surveil and get information. Basically, that is all they really -- For some reason, I mean, they don't even really use the information they get. They have to collect data. That is part of their religion is collecting data. And her thing was -- her goal was to disrupt, but in a very subtle way -- a very, very subtle way. Q· Did you ever see Sue Taylor communicate as an agent for Scientology with other organizations of A. Yes, with George Robertson. BY MR. BEAL: Q· What do you understand her role in Washington to be? A. As director of OSA, as far as I know. Q· What sort of things does OSA do in Washington? A. Office of Special Affairs handles anything that could be perceived as a threat or a bad PR slide or anything like that in relation to Scientology. They are the protection wing around Scientology. They are sort of like the Secret Service around the White House. That is the way they look at themselves. Q· She was the head of the Washington office of that? A. Yes, Washington, D.C. Q· So she would -- what would she deal with? In the Washington context as far as you A. No, she dealt nationally. Q· She was located in Washington, but she was the national head of that? A. Right, right. But, now, she is not the national head of OSA because that is somebody in Los Angeles more than likely. I forget that person's name. One of the uniformed personnel. Q· Okay. So she was the head of the Washington office, but her scope was national? A. Right. Now, she is what they call SEOR (phonetic), which means she is supposed to be wearing a uniform. But because of her position and clout and the way that she has to deal with people on an everyday basis, she doesn't have to wear the uniform. BY MS. KISSER: Q· Do you know of any projects that she was engaged in regard to CAN? A. Yeah, the Oklahoma City Conference project. She was the one that was the whole role in that. Q. What about Gene Ingram? You said you know of him. You have had communication with him? A. Oh, yeah, lots. Q· What do you understand him to be? A. I understand -- well, the way he represented himself to me is an ex-police officer, private investigator licensed under the State of California, and hired by Bowles & Moxen, not a Scientologist. I don't think I believe that. I think he is just being way too slick. He criticizes Scientology way too much in their own offices to be bonafied as far as I was concerned. I didn't believe that statement in other words. Q. Are you aware of any activities directly that you might have participated in or that Mr. Ingram relayed to you in regard to CAN? A. He spent a week here investigating CAN members, going through garbage cans, that kind of stuff, you know. Q. Do you know that because you saw -- you went with him or because he relayed it to you -- A. He told me. I did go with him a couple of places, but not anything like that. MS. KISSER: I don't think there is too much else I wanted to ask him about. BY MS. KISSER: Q. Is there any information that you think we ought to know about in regard to your interactions with any of the parties we have asked you about or in regard to the lawsuit or the declarations or anything you think that we ought to be aware of? A. Not offhand, not that, you know. Q. Do you ever hear any discussion of the litigation against CAN by any person who was actually an agent for Scientology? A. Yes. Q. Okay. Do you recall A. Virginia Jensen is the one who actually for Chicago, she is kind of like shoring up all of the details here. She is a young law clerk. The reason, in fact, that Moran got involved in this is because she used to be his law clerk and she is the one that, you know, recommended him -- Q. What is her position with -- A. She was the head of their legal department. Q. Here? A. -- for OSA. Q· Here in Chicago? A. Just the Chicago, yeah. Q· What was your understanding or your communication with her on? A. She basically develops the strategies here and keeps the lawyers in contact, keeps Bowles & Moxen and Moran and everybody, you know, and keeps all of the cases together. Chicago has grown. The Scientology office here in Chicago has grown big time as a result of all this stuff because CAN is based here in Chicago. Two years ago, the OSA office here was just three little desks in a cramped room. Now it is a whole basement sprawling with carpet and everything. And they have a staff, you know. Q· Do you know where that is? A. Oh, yeah. It is in the basement of 3011 North Lincoln. Q. So do you have any recall of -- as far as litigation, any -- I mean, other than just conversation about lawsuits, do you have any recall of any discussion of the litigation in terms of any part of anything, you know, part of a plan or anything like that? A. Well, yeah, the general way that they wanted to push it. See, it is hard to explain Scientologists. It is kind of baffling. They work Thursday to Thursday. And at the end of one Thursday, they forget what they did the previous week because they are thinking about their points for the next Thursday. And they are very, very disorganized that way. They have to get their reports in and stuff like that. And once they do that, they breathe a sigh of relief and they forget everything they did before. They don't have -- in my opinion and what I really believe -- they don't have a single strategy. They don't have a single cause or purpose in life in any sense. BY MR. BEAL: Q. But it is clear to you, I take it, that all this litigation against the Cult Awareness Network, whether it is in federal court -- I mean here in Chicago -- is all organized and orchestrated by the Church of Scientology, whether it is A. Oh, yeah. It is clearly that. Before the conference in Oklahoma -- you know about Chilocco, Oklahoma? MS. KISSER: Yes BY THE WITNESS: A. It is a big Scientology drug center. MS. KISSER: Right. BY THE WITNESS: A. They sent me down there for Chilocco's grand opening. It was a big PR event and they felt I needed a vacation because I was stressed out about all this kind of stuff. And Hebert Jentcz, who was at that time president of Scientology -- which I had no idea who he was, but he was acting as chauffeur for everybody back and forth to the airport, personally, driving back and forth to the airport. I had no idea that was who he was. And he talked about the whole thing. He was the only one who talked like with a sense of this is where we want to be; this is what we are trying to target. Everybody else is talking what are we going to do before Thursday, and he is talking about the long-term goal. So this was like way predating -- I mean, that is abouta year and a half before the case even came up that he was talking about the case to me directly, and... BY MR. BEAL: Q. What did he say, the best you can recall? A. Well, it was over 100 degrees in the heat and I was about to pass out, so he was driving me back to the hotel I was staying in, which was like a hour's drive away from there. And he philosophied about CAN and about the case and about the Krishna and about everything. Q. But just basically he was telling you the case was a part of their strategy to deal with all of this? A. Yes, yes. An overall strategy too. It has nothing to go with just the ultimate goal, but it is an overall strategy. It is a stepping stone to whatever they want to do. Q. Do you know any of the other plaintiffs, you know, the other individual members of the Church of Scientology who are suing CAN? Have you ever met any of them? A. I might have met the one guy. Q· But not that you have talked to them about the lawsuits? A. No. Q. So you have never talked with any individual member who also has litigation pending? A. As far as the past year has gone, I have been extremely uncooperative with them in general for the past year. And I haven't answered calls or beeps. I have avoided their visits. They have come since this last event -- I mean, you know, that court thing when the case was dismissed, they did go to my house a number of times and I wasn't there and within an hour of each other, you know, to come back to see if they could catch me walking out or something. But other than that, you know, I haven't just haven't had any contact with them hardly. MS. KISSER: I don't have any other questions. MR. BEAL: Thank you. That completes the statement. (Further deponent saith not.) (Signature waived.)