"Q...... do you have any personal knowledge of conspiracies to murder and suicide with regard to the Church of Scientology?"

A. Yes, I do.

"Q. And what is that personal knowledge briefly? As I say, we will get into it later. "

A. Through a -- through several conversations by phone, also in a personal meeting in November of 1991 and in a meeting in December of '91 at the Church of Scientology Saint Hill organization building, where the Office of Special Affairs and Bowles & Moxon is actually located, I was directed, one, to go to Chicago, Illinois and to murder Cynthia Kisser, Cynthia Kisser being the Executive Director of the Cult Awareness Network, by a staged car accident.

"The suggested method was cutting her brake lines but it was later talked about that because Cynthia Kisser drives a Ford Bronco that it might not be possible to cut a brake line, so therefore, I could release brake fluid and tamper with the vehicle in such a way that it would render it out of control at which time I would be in a vehicle behind it. I would run her off the road, hopefully running her into a ditch or into a tree. And then making sure she did not survive the accident.

"So the suggested ways of following up was to take a pillow and smothering her to death. Another method was dragging her out of the vehicle and drowning her. It was also discussed including her young daughter and killing her in the accident.

"Q. Mr. Scarff, Are you okay to continue?"

A. I didn't know she had a young daughter at the time.

"Q. Would you like to take a break?

= = = "Q. What was said at that meeting by whom?"

A. First David Butterworth recalled my meeting with him. Just prior to that it was like two and a half weeks prior to that when I first met him at the Cult Awareness Network conference in Oklahoma City and he recalled our conversation where I asked him if I was doing all I could to meet their conditions of amending my past where I was not obedient and where I had cursed the Church of Scientology and where I had made up lies to hurt the Church of Scientology when I was angry at the world and he said there was one more thing that they wanted to do. And it was something that would ultimately bring down the Cult Awareness Network.

"They said that up to that point that everything they had tried to do was not successful and that they wanted to get rid of Cynthia Kisser once and for all because she was the whole reason that the Cult Awareness Network existed. She was the glue that held it together and if they could get rid of Cynthia Kisser once and for all that there would be no one there competent enough to replace her. And it was Eugene Ingram that said that Priscilla Coates might step in but that the "old broad" was "not intelligent enough or didn't have enough time on her hands or something to that effect that she would be able to walk in and take over for Cynthia Kisser.

"So in order to destroy the Cult Awareness Network all we had to do was destroy Cynthia Kisser. And I assumed when he said this that he meant simply attacking her credibility as they have done in the past but doing it with much more vigor than they have done so in the past.

"Q. What else was said at that conversation, at that meeting?"

A. Only that they talked to me about the specific operation where, if I performed this operation that if L. Ron was still alive he would be honored to have me at his side and that Mr. Ingram informed me that David Miscavige was personally aware of this operation and considered it an honorable role on my behalf, would welcome me with open arms if I was to perform this operation, and then we got into the specifics of what they wanted me to do.

"Q. And were the specifics what you testified about with regard to Cynthia Kisser just before the break -- let me withdraw the question.

"Q. What were the specifics of the operation very briefly?

A. The specifics of the operation was for me to fly to Chicago O'Hare Airport, rent a vehicle with the information provided to me by the Office of Special Affairs in Los Angeles and the OSA in Chicago particularly with the tools provided to me by Randy Kretchmar, who is an official of the OSA in Chicago, to follow Cynthia Kisser home, run her off the road and take all steps necessary to render Cynthia Kisser dead.

"It was also discussed for a greater impact in these events that if someone within the Cult Awareness Network got smart enough to replace Cynthia with someone else, and that if Cynthia Kisser had her daughter with her, it would be an added benefit to kill Cynthia Kisser and to kill her daughter as well, because when a child dies it carries a greater impact in the ; minds of the public than if simply an adult dies, and that would send a message to the Cult Awareness Network that it was time to end their hatred toward whom they perceived to be }cults.

Q. Now, was Gene Ingram present at that meeting?"

A. He was present, yes.

Q. did he say anything at that meeting?

A. Yes, he did. He told me that there was absolutely no way that I could be held accountable if I -- there is no way I could be caught -- first of all, that immediately after I did it I was to fly back to Los Angeles and that Mr. Ingram would be responsible for putting me into to a safe house and if need be, he could ferret me out of the country to Brazil or Mexico City or one of the other places that they have established safe houses at. And that they would keep me there until the steam blew off or until Bowles & Moxon was successful enough in impeding any type of legal investigation towards me and that I would be held not accountable for these crimes, and it was specifically discussed that they would put me into hiding and that any type of criminal investigation that was pending towards me, any type of legal investigation that may have started as a result of this murder, that Bowles & Moxon would step in and throw so many legal maneuvers at the courts that there is no way that I would be eventually prosecuted for this crime. And Eugene laughed and said that --he said, 'Trust me. I mean the court dockets are so overloaded right now, if Bowles & Moxon was to throw all these legal maneuvers at the courts there do be absolutely no way that prosecutors would find the time to want to prosecute you for something like this.

"Q. Now, I think you said that there was some discussion with Mr. Ingram as to how he could hide you after killing Cynthia Kisser?"

A. Yes. He said, like I said before, he said he had relatives in Brazil. He could get me to Brazil. I told him that I didn't have a passport because the only places that I have been out of the country was Mexico and Canada and they didn't require passports. He said he could provide me a passport. I wouldn't even have to go down to the Post Office and apply for it. That he could give me one right away.

"And he also said that he had a son in Colorado going to college and that there were places in around the Denver & Boulder, Colorado areas which could be used as safe houses where they could hide me.t (Deposition of Garry L. Scarff, at p. 34_, In. 4 - p. 365, in. 9.)

"Q. Now, there is the word "Moxon" in the word Bowlers & Moxon. Do you know who Moxon refers to?

"A. Yes. That refers to attorney Kendrick Moxon.

"Q. And have you met attorney Kendrick Moxon?

A. Yes, I have.

"Q. And during the worst of your meetings with Kendrick Moxon, have you obtained any understanding as to part of his background?"

A. Yes, I have.

"Q. And what is that understanding you have as to earlier significant events in his background?"

A. In both conversations with Mr. Moxon himself, he seems pretty proud of the fact, and in conversations with Eugene Ingram, David Butterworth and Sue Taylor, who is the Director of Public Affairs, Church of Scientology in Washington, D.C., Mr. Moxon was one of the original coconspirators involved in Operation Snow White against the FBI and the Internal Revenue Service which resulted in the arrest and conviction of 11 high-ranking members of the Church of Scientology in Washington, D.C. which also included the imprisonment of L. Ron Hubbard's wife, Mary Sue Hubbard.

"Mr. Moxon is very proud of the fact that he was intimately involved in that whole unlawful affair and the FBI never caught him. He is proud of fact that he got away with doing unlawful stuff and he never got arrested or convicted for it.

"Q. Have you had any conversations with Mr. Moxon in which you gave he that impression?"

A. Yes. I did. When I spoke to Moxon my serious concerns about being caught and prosecuted for killing both Cynthia Kisser and killing Ford Greene, he mentioned this Snow White operation in which he was a part of and he tried to assure me there was absolutely nothing to worry about because I could trust him and I could trust the other legals to help me get away with this. He claimed there was no way anyone was going to find out.

(Deposition of Garry L. Scarff, at p. 378, in. 18 - p. 380, in. 13.)

Q. Before we proceed with a discussion of the meeting regarding the conspiracy to murder Ford Greene, I would like to return briefly to the meeting you testified to regarding the conspiracy to murder Cynthia Kisser.

"Now, did there come a time that weekend or at the end of that weekend when you left Los Angeles?"

A. Yes, I did. I left on Monday.

"Q. And before you left Los Angeles did you have any further meetings at the Church of Scientology? "

A. Yes, I did.

"Q. And with whom did you have any such further meetings? "

A. Eugene Ingrarn took me upstairs to the offices of Bowles & Moxon because he said that Tim and Kendrick wanted to say good-bye to me because they had not had the chance to speak with me before. And I said good-bye to Tim but Kendrick was in a depo or a session of some sort according to Eugene so I didn't get to see him. But Tim greeted me very warmly and said that he knew that I was there for the weekend but he was busy with stuff and hadn't had the chance to talk with me, and that was it.

"Q. By 'Tim and Kendrick' who do you mean? "

A. I'm talking about Timothy Bowles and Kendrick Moxon, who are attorneys for Bowles & Moxon, the in-house law firm for Scientology.

"Q. Now, did you have any understanding as to their knowledge, if any, of the meeting you had had regarding the conspiracy to murder Cynthia Kisser? "

A. I presumed from my knowledge and my experience within the Church of Scientology and the policies that are strictly adhered to within the Church of Scientology that one does not speak on behalf of another, and that when Mr. Ingram and Mr. Butterworth were advising me that once the murder had been committed that we would have Bowles & Moxon intervene on my behalf on a legal basis, I was confident then that Tim Bowles and Kendrick Moxon knew exactly about the conspiracy because Ingram -- particularly David Butterworth, who is a Scientology member, in the face of being punished with RPF would not compromise his high- ranking position in the Church of Scientology by saying something with regards to Bowles and Moxon unless Bowles & Moxon was specifically aware of the statement that was being made to me.

"And so it was my confident feeling that Timothy Bowles given the fact of the way that he greeted me, said that he knew that I was in L.A., that Timothy Bowles was very knowledgeable about the plan for me to go to Chicago and kill Cynthia Kisser and her daughter."

(Deposition of Garry L. Scarff, at p. 382, in. 15 - p. 384, in. 21.)

c.

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