4-158 short witness who's going to make a statement about one thing. We're not going to go into her background; it's very extensive and she could say a lot of things about the entire subject matter. She's going to be called for one specific purpose, and her testimony will probably take a minute or two minutes, and you can ask her, as always, whatever you like. And then, we're going to seek to corroborate that testimony at a later date, the day that it's going to be sent to the Commission.

We just recently learned about the information, and I'd just like to get it on the record. It's hearsay, but this is an investigative proceeding, so it could lead to these affidavits from other individuals who could not be here today. So, I'm just going to put her on for two minutes for that MR. LeCHER: Should all the witnesses still be sworn in?

MR. FLYNN: Absolutely.

MR. LeCHER: All right.

Will you bring in your witness, Mr. Flynn?

MR. FLYNN: Sharon McKee, please.

SHARON McKEE, a witness-herein, having first been duly sworn by a Clerk for the City of

4-159

Clearwater, was examined and testified as follows:

MR. LeCHER: Mrs. McKee?

MRS. McKEE: Yes, Sharon McKee; I'm from Connecticut.

MR. LeCHER: You're from Connecticut.

Mrs. McKee, I must ask you the same standard questions that I've asked every other witness.

N,,.:,T,ber one: Are you appearing here to day to testify under oath voluntarlv?

'MRS. McKEE: Yes, I am.

LeCHER: you been paid by anyone -for your testimony, other than the expenses for coming to Clearwater?

MRS. McKEE: No, I haven't.

MR. LeCHER: Do you have a lawsuit against the "Church" of Scientology?

MRS. McKEE: No, I do not.

MR. LeCHER: Does the "Church" of Scientology have a lawsuit against you?

MRS. McKEE: No.

MRi LeCHER: Has anyone suggested to you that you should state anything but the truth or has anyone suggested that you change your testimony for any reason?

MRS. McKEE: Absolutely not.



4-160 MR. LeCHER: Thank you.

Mr. Flynn.

MR. FLYNN: Go ahead.

MRS. McKEE: This would be in the end the end of the summer or the beginning of the fall of 1981. A friend of mine - his name was Gordon Karas - had recently come home from Los Angeles, He'd been on his advanced courses, and out there he met a lady named Elaine Segal and they just had become friends.

Elaine Segal works for Branch 1 of the Guardian's Office, the Investigative Bureau in Boston. My friend went up to Boston, I think, just to visit and stopped into the "Church" there and saw her and they started chatting. What she said to him is that she would like him to move up to Boston for the purpose of not actually becoming a student, but Elaine would provide documents in a local college to prove that he was - give him a background, a cover story - that he was actually a student in a Boston college, and she wanted Gordon to go out with Michael Flynn's secretary.

I don't know that-she specifically said to gather data or not, but Gordon is a very personable, handsome young man and she wanted him to start dating this woman. and get to know Michael-Flynn's secretary, hopefully to 

4-161 become involved.

MR. FLYNN: That's all at this point. And at that time I was working with the city in preparation of the report to this Commission, the period of time in which she testified about. And at a later point in time we'll try to tie the information together for you.

MR. LeCHEA: Apparently, you're trying to establish a pattern with this?

MR. FLYNN: That's correct.

I have - this is hearsay information - I have had information for some that the "Church" of Scientology had the report to this Commission sometime in advance of its public presentation.

MR. LeCHER:. Thank you very much.

Is there anything -- I guess that's it, then.

MR. CALDERBANK: Mr. Flynn, did the "Church" have any documents or any other thing in its possession at any time since we or since you first made contact with the city that would show that they have been collecting data or looking into the city's activities with respect to this?

MR. FLYNN: The "Church", pursuant to a variety of legal proceedings in which we are involved, produced, pursuant to court order, some eight thousand documents 

4-162 of which the "Church" -- which are directly from the files in my office. The "Church" claims they were taken from a dumpster, which is on a locked compound - a locked condominium compound - with a twenty-four-hour security guard on -- in my office compound.

That matter is now in litigation. And at some point it could become a subject of investigation by the appropriate authorities in Pinellas County, because some of the documents pertained to correspondence and communication with members of this Commission, the City Council, the City Manager, the City Attorney.

And some of the documents pertain directly to my work with this city and some documents pertain directly to contact that I had with the -- Mr. Russell's office, the Pinellas County State's Attorney.

MR. CALDERBANK: So, they were confidential?

MR. FLYNN: Absolutely. And they were in possession of -some eight thousand of them were in the possession of the "Church" when the court ordered them to be turned over.