Hoden Interrogatory

Hoden Interrogatory
Scientology

From: hkhenson@rogers.com (Keith Henson)
Subject: Hoden Interrogatory
Date: Fri, 12 Aug 2005 15:35:33 GMT
Message-ID: <42fcb972.153259167@nntp.broadband.rogers.com>

This is *draft*

I may need to stick in explanations as to why the questions about the two women killed at scientology's operation that year are relevant to the criminal trial, which underlies the civil trial, which David Cook brought into the bankruptcy case provided this amazing opportunity.

I would like to get this out in the next day or two, so please post or email the comments as soon as you can.

And a very public thanks for the help both public and private I have been getting.

Keith Henson

PROPOUNDING PARTY: DEBTOR H. KEITH HENSON RESPONDING PARTY: Ken Hoden, served through his attorney DAVID J. COOK, ESQ. (State Bar # 060859), COOK, PERKISS & LEW, A PROFESSIONAL LAW CORPORATION 333 Pine Street, Suite 300, San Francisco, California 94104

snip boilerplate

SPECIAL INTERROGATORY NO. 1: List your education starting with High School, years, include institutions and whether applicable majors and degree(s) were granted. _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________

SPECIAL INTERROGATORY NO. 2: List the titles you have held in Scientology and the approximate dates you held these positions. _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________

SPECIAL INTERROGATORY NO. 3: List the training courses you have taken in Scientology. _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ [NOTE. Is there a list I can stick in here with check boxes?]

SPECIAL INTERROGATORY NO. 4: When did you first become aware of debtor? _________________________________________________________________

SPECIAL INTERROGATORY NO. 5: Debtor picketed Scientology's operation at Gilman Springs in the spring of 1998. Describe that picket from your viewpoint. _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________

SPECIAL INTERROGATORY NO. 6: In 1998 you sued debtor. Why did you sue debtor and in what court? _________________________________________________________________

SPECIAL INTERROGATORY NO. 7: What was the outcome of the suit? _________________________________________________________________

SPECIAL INTERROGATORY NO. 8: On May 17, 2000, construction machinery (a paver with no lights) was moved off the property at Gilman Springs on a public road after dark, accompanied by a front loader. Ashlee Shaner's car ran into the blade of the front loader about 9:15 pm, decapitating her almost in front of her mother. Were you involved at all in the decision to move this equipment after dark? Yes_____ No_______

SPECIAL INTERROGATORY NO. 9: The next day, May 18, 2000, was a Thursday, "stats" day (when "production" statistics must be turned in to supervisors). Did the decision to move this equipment after dark have anything to do with the next day's being "stats day"? Yes____ No______

SPECIAL INTERROGATORY NO. 10: May 26, 2000, debtor picketed the Gilman Springs property over the death of Ashlee Shaner. There were only two people visible on Golden Era property. How were you warned? ________________________________________________________________________

SPECIAL INTERROGATORY NO. 11: May 30, 2000, debtor picketed again, coming upon a chaotic scene of construction people hurriedly leaving after just starting work. Debtor speculated at the time that he had been tailed all the way to Tucson and back. If you know, was he? Yes___ No____

SPECIAL INTERROGATORY NO. 12: If the answer to the above question is no, how were you warned and by whom? _________________________________________________________________

SPECIAL INTERROGATORY NO. 13: June 25, 2000 (Sunday morning), within minutes after Stacy Moxon Meyer was electrocuted in a transformer vault you approached Barbara Graham and David Rice, who were picketing, and tried to get them away from the gate. Why? _________________________________________________________________

SPECIAL INTERROGATORY NO. 14: Related to the above question, you did not mention the tragic death that had occurred minutes before to the picketers, but instead invited them to breakfast. This is, by ordinary standards, unusual behavior. Is it mandatory in Scientology to attempt to hide information that may lead to bad public relations? Yes___ No____ (Expand on this answer if you wish) _________________________________________________________________

_________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________

SPECIAL INTERROGATORY NO. 15: If the answer to the previous question is no, why was it done this time? _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________

SPECIAL INTERROGATORY NO. 16: Three weeks before Stacy Moxon Meyer was electrocuted in the transformer vault, a ground squirrel got into the wires in the vault and was exploded, knocking out power to part of the base. Which buildings were affected? _________________________________________________________________ _________________________________________________________________ _________________________________________________________________

SPECIAL INTERROGATORY NO. 17: Did the affected buildings include a home or office used by David Miscavige? Yes____ No______

SPECIAL INTERROGATORY NO. 18: Were any reports or policies written on preventing a reoccurrence? Yes____ No______

SPECIAL INTERROGATORY NO. 19: Were you involved in any way with such reports or policies? Yes____ No______

SPECIAL INTERROGATORY NO. 20: Was a policy of regular inspections of the vaults instituted? Yes____ No______

SPECIAL INTERROGATORY NO. 21: What was the name of the chief electrician on June 25, 2000? _________________________________________________________________

SPECIAL INTERROGATORY NO. 22: July 3, 2000, debtor was accosted on the road that runs through the Gilman Springs property by private investigator Edwin Richardson and another person who might have been another private investigator. What is the name and address of the second person? (If licensed, provide also the state and license number.) _________________________________________________________________

SPECIAL INTERROGATORY NO. 23: That second person was caught on tape August 14, 2000 (transcript posted August 18, 2000) threatening debtor's daughter. Did you authorize that second person to make threats? Yes____ No______

SPECIAL INTERROGATORY NO. 24: What instructions were Edwin Richardson and that other person (above) given regarding the debtor? _________________________________________________________________

SPECIAL INTERROGATORY NO. 25: Debtor was arrested late on July 19, 2000, as a "citizen's arrest" and then released because you, the complainant, would not sign the arrest papers. Explain why you would not sign and the circumstances around this event. ___________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________

SPECIAL INTERROGATORY NO. 26: In debtor's original indictment, Bruce Wagoner, Hilary Dezotell, Michael Gilchrist, Dana Reid and Muriel Dufresne are named. How were these 5 picked from the 735 people you stated worked at the Gilman Springs property? ___________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________

SPECIAL INTERROGATORY NO. 27: At that time, what were their positions at Golden Era? ___________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________

SPECIAL INTERROGATORY NO. 28: Shortly before debtor's criminal trial, the last three were removed and you were substituted as a "victim." If you know, explain why the substitution and who directed that it be done? ___________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________

SPECIAL INTERROGATORY NO. 29: Friday, April 20, 2001, following testimony about your hunting down debtor's patents, Internet postings, and mention in a work of biographical fiction, you testified under oath at debtor's criminal trial:

Q: Thank you. Now, the last question that I have for you is this: Why did you -- why did you go through all the trouble of doing that?

A: Well, I didn't want to make the same mistake again.

Q: What mistake is that?

A: Well, we had an earlier situation where we had what might appear to be silly or foolish or joking type threats. And as a result somebody got killed. Somebody got shot. And I didn't want that to happen again. And I was not going to make that mistake again, and I was determined not to make it again.

Q: What are you referring to?

A: Referring to the fact that a man one time took a little tiny tank and wound it up like this, and put a little sign on it and said, "Next time it will be real." And it chugged through the front door of our church, of one of our churches.

Q: Where?

A: Portland, Oregon.

Q: Then what happened?

A: All right. We took it to the police, explained to them that this is a threat. They said there was nothing they could do, looked like just a joke. He walked in later, shot Helen, who I've known for 25 years, shot Helen, bullet went through her shoulder, through her baby's head in her womb . . . ."

Were you aware (at that time) that the bullet fired by a disgruntled Scientologist, Jerius, Godeka, (later judged insane) did not go through the baby's head? (" . . . [T]he fetus was unharmed," The Oregonian, September 26, 1996.) Yes_____ No_____

SPECIAL INTERROGATORY NO. 31: Do you now regret your perjury under oath? Yes_____ No_____

SPECIAL INTERROGATORY NO. 32: Were you aware at that time that debtor could not refute your testimony (which he knew to be wrong) because he had been denied witnesses and was forbidden to speak in his defense? Yes_____ No_____

SPECIAL INTERROGATORY NO. 33: The following document was recovered in the FBI raid of July 8, 1977 on the Church of Scientology:

INTELLIGENCE SPECIALIST TRAINING ROUTINE - TR L

Purpose: To train the student to give a false statement with good TR-1. To train the student to outflow false data effectively.

Position: Same as TR-1

Commands: Part 1 "Tell me a lie". Command given by coach. Part 2 interview type 2 WC by coach.

Training Stress: In Part 1 coach gives command, student originates a falsehood. Coach flunks for out TR 1 or TR 0. In Part 2 coach asks questions of the student on his background or a subject. Student gives untrue data of a plausible sort that the student backs up with further explanatory data upon the coach's further questions. The coach flunks for out TR 0 and TR 1, and for student fumbling on question answers. The student should be coached on a gradient until he/she can lie facily.

Have you been trained on this course or similarly coached for your testimony against debtor? Yes_____ No_____

SPECIAL INTERROGATORY NO. 34: Did any of the events of the year 2000--deaths, pickets, or related--result in "ethics" actions against you? Yes_____ No_____

SPECIAL INTERROGATORY NO. 35: List your times in the "Rehibilitation Project Force." _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________

<p><hr><p> From: mpattinson@gmail.com
Subject: Re: Hoden Interrogatory
Date: 12 Aug 2005 11:16:02 -0700
Message-ID: <1123870562.085935.249790@g14g2000cwa.googlegroups.com>
<42e82bfe.32974775@nntp.broadband.rogers.com> <42ee0ef9.95723726@nntp.broadband.rogers.com> <42fa4097.68838031@nntp.broadband.rogers.com> <42faac88.18860952@nntp.broadband.rogers.com> <qgAKe.8807$6d4.1177015@news20.bellglobal.com> <11fn702blg2p707@corp.supernews.com> <42fcd6c5.95220622@nntp.broadband.rogers.com> <mike-F0F800.23443711082005@optonline.svc.highwinds-media.com> <11fodun577be828@corp.supernews.com> <42fcb972.153259167@nntp.broadband.rogers.com> In-Reply-To: <42fcb972.153259167@nntp.broadband.rogers.com> Complaints-To: groups-abuse@google.com Injection-Info: g14g2000cwa.googlegroups.com; posting-host=24.55.10.162; posting-account=XeTMrA0AAADsUgJJgnjrrN2CRl8c7dTH

Keith, what a wonderful list!

it is insighful and incisive as it laser-targets the Truth.

I look forward to reading Hoden's answers.

I just hope the criminals in the Base don't assign him to transformer repair duty before he can answer the questions. MP

<p><hr><p> From: hkhenson@rogers.com (Keith Henson)
Subject: Re: Hoden Interrogatory
Date: Mon, 15 Aug 2005 06:11:10 GMT
Message-ID: <430030de.12732958@nntp.broadband.rogers.com>
X-DMCA-Complaints-To: abuse@rogers.com X-Abuse-and-DMCA-Info: Please be sure to forward a copy of ALL headers X-Abuse-and-DMCA-Info: Otherwise we will be unable to process your complaint properly X-Postfilter: 1.3.32

On Fri, 12 Aug 2005 18:54:30 GMT, hkhenson@rogers.com (Keith Henson) wrote: snip

>If anyone has a list of the courses Hoden could have taken, including
>the internal ones for "hatting" people for OSA work it would be really
>useful. Just give him a yes/no checklist and "any others?" at the
>bottom.

Sorry, I just had to get these out. The list is still important, especially for the ones he is known to have taken.

I posted the boilerplate, this is just the meat. Faxed them off so posting them here doesn't help the cult a bit.

RESPONDING PARTY: Ken Hoden, served through his attorney of record, DAVID J. COOK, ESQ. (State Bar # 060859), COOK, PERKISS & LEW, A PROFESSIONAL LAW CORPORATION 333 Pine Street, Suite 300, San Francisco, California 94104

SPECIAL INTERROGATORY NO. 1: List your education starting with high school, years, include institutions and whether applicable majors and degree(s) were g ranted. _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ SPECIAL INTERROGATORY NO. 2: List the positions you have held in Scientology organizations and the approximate dates you held these positions. Include time in the RPF as a "position." Attach extra pages if needed. _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ SPECIAL INTERROGATORY NO. 3: List the courses you have taken in Scientology. Attach extra pages if needed _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ SPECIAL INTERROGATORY NO. 4: Debtor's first picket at Gilman Springs was May 20, 1997. List the first 5 times you were aware of debtor at Gilman Springs. _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ SPECIAL INTERROGATORY NO. 5: Debtor picketed Scientology's operation at Gilman Springs January 6, 1998. Describe that picket from your viewpoint. Attach extra pages if needed _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ SPECIAL INTERROGATORY NO. 6: In 1998 you sued debtor. Who induced you to sue debtor? _________________________________________________________________ SPECIAL INTERROGATORY NO. 7: Who paid the legal bills for that case? _________________________________________________________________ SPECIAL INTERROGATORY NO. 8: On May 17, 2000, construction machinery (a paver with no lights) was moved off the property at Gilman Springs on a public road after dark, accompanied by a front loader. Ashlee Shaner's car ran into the blade of the front loader about 9:15 pm, decapitating her almost in front of her mother. Were you involved at all in the decision to move this equipment after dark? Yes_____ No_______ SPECIAL INTERROGATORY NO. 9: The next day, May 18, 2000, was a Thursday, "stats" day (when "production" statistics must be turned in to supervisors). Did the decision to move this equipment after dark have anything to do with the next day's being "stats day"? Yes____ No______ SPECIAL INTERROGATORY NO. 10: May 26, 2000, debtor picketed the Gilman Springs property over the death of Ashlee Shaner. There were only two people visible on Golden Era property. Who warned you that the debtor was coming and how did they know? ________________________________________________________________________ SPECIAL INTERROGATORY NO. 11: May 30, 2000, debtor picketed again, coming upon a chaotic scene of construction, with people hurriedly leaving after just starting work. Debtor speculated at the time that he had been tailed all the way to Tucson and back. If you know, was he? Yes___ No____ SPECIAL INTERROGATORY NO. 12: If the answer to the above question is no, how were you warned and by whom? _________________________________________________________________ SPECIAL INTERROGATORY NO. 13: June 25, 2000 (Sunday morning), within minutes after Stacy Moxon Meyer was electrocuted in a transformer vault, you approached Barbara Graham and David Rice, who were picketing, and tried to get them away from the gate. Why? _________________________________________________________________ SPECIAL INTERROGATORY NO. 14: Related to the above question, you did not mention the tragic death that had occurred minutes before to the picketers, but instead invited them to breakfast. This is, by ordinary standards, unusual behavior. Is it mandatory in Scientology to attempt to hide information that may lead to bad public relations? Yes___ No____ (Expand on this answer if you wish) _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ SPECIAL INTERROGATORY NO. 15: If the answer to the previous question is no, why was it done this time? _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ SPECIAL INTERROGATORY NO. 16: Three weeks before Stacy Moxon Meyer was electrocuted in the transformer vault, a ground squirrel got into the wires in the vault and was exploded, knocking out power to part of Golden Era. Which buildings were affected? _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ SPECIAL INTERROGATORY NO. 17: Did the affected buildings include a home, office or other facility used by David Miscavige? Yes____ No______ SPECIAL INTERROGATORY NO. 18: Were any reports or policies written on preventing a reoccurrence? Yes____ No______ SPECIAL INTERROGATORY NO. 19: Were you involved in any way with such reports or policies? Yes____ No______ SPECIAL INTERROGATORY NO. 20: Was a policy of regular inspections of the vaults instituted? Yes____ No______ SPECIAL INTERROGATORY NO. 21: What was the name of the chief electrician on June 25, 2000? _________________________________________________________________ SPECIAL INTERROGATORY NO. 22: July 3, 2000, debtor was accosted on the road that runs through the Gilman Springs property by private investigator Edwin Richardson and another person who might have been another private investigator. What is the name and address of the second person? (If licensed, provide also the state and license number.) _________________________________________________________________ SPECIAL INTERROGATORY NO. 23: That second person was caught on tape August 14, 2000 (transcript posted August 18, 2000) threatening debtor's daughter. Did you authorize that second person to make threats? Yes____ No______ SPECIAL INTERROGATORY NO. 24: What instructions were Edwin Richardson and that other person (above) given regarding the debtor? _________________________________________________________________ SPECIAL INTERROGATORY NO. 25: Debtor was arrested late on July 19, 2000, as a "citizen's arrest" and then "un-arrested" because you, the complainant, would not sign the arrest papers. Explain why you would not sign and the circumstances around this event. ___________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ SPECIAL INTERROGATORY NO. 26: In debtor's original indictment, Bruce Wagoner, Hilary Dezotell, Michael Gilchrist, Dana Reid and Muriel Dufresne are named. Why were these 5 picked from the 735 people you stated worked at the Gilman Springs property? ___________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ SPECIAL INTERROGATORY NO. 27: At that time, what were their positions at Golden Era? ___________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ SPECIAL INTERROGATORY NO. 28: Shortly before debtor's criminal trial, the last three were removed and you were substituted as a "victim." If you know, explain why the substitution and who directed that it be done? ___________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ SPECIAL INTERROGATORY NO. 29: Friday, April 20, 2001, following testimony about your hunting down debtor's patents, Internet postings, and mention in a multi-person biographical sketch, you testified under oath at debtor's criminal trial: Q: Thank you. Now, the last question that I have for you is this: Why did you -- why did you go through all the trouble of doing that?

A: Well, I didn't want to make the same mistake again.

Q: What mistake is that?

Q: What are you referring to?

Q: Where?

A: Portland, Oregon.

Q: Then what happened?

Were you aware (at that time) that the bullet was fired by a disgruntled, refund-seeking Scientologist, Jerius Godeka, and that the bullet did not go through the baby's head? (" . . . [T]he fetus was unharmed," The Oregonian, September 26, 1996.) Yes_____ No_____

SPECIAL INTERROGATORY NO. 31: Do you now regret your perjury under oath? Yes_____ No_____ SPECIAL INTERROGATORY NO. 32: Were you aware at that time that debtor could not refute your testimony (which he knew to be wrong) because he had been denied witnesses and was forbidden to speak in his defense? Yes_____ No_____ SPECIAL INTERROGATORY NO. 33: The following document was recovered in the FBI raid of July 8, 1977 on the Church of Scientology: INTELLIGENCE SPECIALIST TRAINING ROUTINE - TR L

Purpose: To train the student to give a false statement with good TR-1. To train the student to outflow false data effectively.

Position: Same as TR-1

Commands: Part 1 "Tell me a lie". Command given by coach. Part 2 interview type 2 WC by coach.

The student should be coached on a gradient until he/she can lie facily.

Have you been trained on this course or similarly coached for your testimony against debtor? Yes_____ No_____

SPECIAL INTERROGATORY NO. 34: Did any of the events of the years 2000 or 2001--deaths, pickets, trial or related--result in "ethics" actions against you? Yes_____ No_____ SPECIAL INTERROGATORY NO. 35: What do you know about the hiring of private investigators in Canada to "investigate" the debtor? ________________________________________________________________

________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________

Dated Aug. 14, 2005 H. Keith Henson, pro se, (Acting under the July 26, 2005 order of Federal Bankruptcy Judge Arthur S. Weissbrodt)

RESPONDING PARTY: DAVID J. COOK, ESQ. (State Bar # 060859), COOK, PERKISS & LEW, A PROFESSIONAL LAW CORPORATION 333 Pine Street, Suite 300, San Francisco, California 94104

SPECIAL INTERROGATORY NO. 1: Were you the person the OPP officer spoke to about this matter? Yes_____ No_____ SPECIAL INTERROGATORY NO. 2: Do you know who did speak to the OPP officer named above? Yes_____ No_____ SPECIAL INTERROGATORY NO. 3: If the answer to SPECIAL INTERROGATORY NO 2 is yes, who was it? _____________________________ SPECIAL INTERROGATORY NO. 4: Do you know who hired the Canadian private investigators? Yes_____ No_____ SPECIAL INTERROGATORY NO. 5: If the answer to SPECIAL INTERROGATORY NO. 4 is yes, who was it? ______________________ SPECIAL INTERROGATORY NO. 6: Do you know anything about the hiring of a Canadian agency in regard to this case or the debtor other than what you have learned from the debtor? ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ SPECIAL INTERROGATORY NO. 7: Your firm usually takes only a percentage of the recovery from cases it takes. Was that the arrangement for this case? Yes_____ No_____ SPECIAL INTERROGATORY NO. 8: If the answer to the above question was no, then what additional payment or other consideration was required? ______________________ SPECIAL INTERROGATORY NO. 9: If payment or other consideration was required per above, the creditors you represent are known to be without funds. What party is responsible for payment or other consideration? _______________________ Dated Aug. 14, 2005 H. Keith Henson, pro se, (Acting under the July 26, 2005 order of Federal Bankruptcy Judge Arthur S. Weissbrodt)