Judge Weissbrodt limited interrogatories to the parties and told me to
cut the introduction section
He also limited the number of questions to 25 but allowed all question and sub parts to total 50.
I have not yet counted the sub parts, they may be over limit, but I wanted to get this out where people could make suggestions.
If you don't know the background I kind of doubt you could catch up in time to be much help.
Thanks in advance,
Keith Henson
PROPOUNDING PARTY: DEBTOR H. KEITH HENSON 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 SET NO: ONE (NUMBERS 1-25)(snip instructions)
SPECIAL INTERROGATORY NO. 1: List the last 5 positions you have held in Scientology organizations and the approximate dates you held these positions. Include time in the RPF as a "position." _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ SPECIAL INTERROGATORY NO. 2: If you have been in the RPF previously to the above, what dates? _______________________________ SPECIAL INTERROGATORY NO. 3: 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.
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If you have been trained on courses using this or similar material, what dates? ______________________________ Were you coached for your testimony against debtor? Yes_____ No_____ SPECIAL INTERROGATORY NO. 4 Debtor picketed Scientology's operation at Gilman Springs January 6, 1998. After that picket you sued debtor to prevent further picketing at Gilman Springs in the Riverside courts. The case was assigned to Judge Cunnison and dismissed at the first hearing on a non-suit motion. Who paid the legal bills for that case? _______________________________ SPECIAL INTERROGATORY NO. 5 At the hearing in the above case, you testified for several pagesthen Judge Cunnison question one of your attorneys, Kendrick Moxon:
THE COURT: Uh-huh. Okay. And they were posted to the internet, correct?
MR. MOXON: Yes, Your Honor.
THE COURT: That was the way they were disseminated?
MR. MOXON: Yes. They were posted to the internet, a discussion group called alt dot religion dot scientology.
THE COURT: Okay.
MR. MOXON: Which is a group frequented by Mr. Hoden and some others.
At the debtor's criminal trial in 2001, you testified as follows: Q: For the jury's benefit, what do you mean by "posting"?
A: I'm sorry. Written materials that were put on the internet, and then they were just printed off. In other words, different types of -- I'm not a computer expert, but just certain things where you can send e-mail to one another, different people send it, and there's little news boards where you can put postings, or where you can write and other people can look at it and add various things to it. And a number of these things were on there, and they're there for the whole world to see. In other words, anybody who logs in, I guess, can take a look at these things. And those were printed off and sent to me, a number of those regarding Mr. Henson. There was other material, other documents sent to me regarding Mr. Henson.
"Frequented" would indicate participating or at least reading on line but the above testimony indicates you only read printouts. Please explain this inconsistency. _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ SPECIAL INTERROGATORY NO. 5: 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. 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______ Were you involved at all in the decision to move this equipment after dark? Yes_____ No_______ Whether or not you made the decision, did you face discipline for that decision? Yes_____ No_______ SPECIAL INTERROGATORY NO. 6: On May 23, 2000 debtor discussed on private "net chat" picketing Gold Base over Ashlee Shaner's death. On May 24, 2000 Scientology attorney Alan E. Oberstein met with the Riverside County District Attorney Trask regarding possible legal actions the county could take against the debtor. Were the two above events connected? Yes_____ No_______ If not and you know, why did Alan E. Oberstein meet with the Riverside County District Attorney Trask in regard to debtor? _____________________________________________ SPECIAL INTERROGATORY NO. 7: May 25, 2000, debtor announced on alt.religion.scientology he would be picketing the Gilman Springs location over the death of Ashlee Shaner.
May 26, 2000 debtor picketed the Gilman Springs location over the death of Ashlee Shaner. The location seemed to be deserted. Where did the order to stay out of view come from? ________________________________________________________________________ SPECIAL INTERROGATORY NO. 8: 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____ If no, how were you warned and by whom?
SPECIAL INTERROGATORY NO. 9: About three weeks before June 25, 2000, a ground squirrel got into the wires in a transformer vault and was exploded, knocking out power to part of Golden Era. Did the affected buildings include a home, office or other facility used by David Miscavige? Yes____ No______ Were any reports or policies written on preventing a reoccurrence? Yes____ No______ Were you involved in any way with such reports or policies? Yes____ No______ Was a policy of regular inspections of the vaults instituted? Yes____ No______ Was Stacy Moxon Meyer assigned to the group responsible for inspection? Yes____ No______ What was the name of the chief electrician on June 25, 2000? _________________________________________________________________
SPECIAL INTERROGATORY NO. 10: June 25, 2000 (Sunday morning), within minutes after Stacy Moxon Meyer was electrocuted while apparently inspecting a transformer vault, you and woman PR person approached Barbara Graham and David Rice, who were picketing, and tried to get them away from the gate by inviting them to breakfast. This is, by ordinary standards, unusual behavior. Please explain. _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ SPECIAL INTERROGATORY NO. 11: Were you held responsible in any way for the electrocution death of Stacy Moxon Meyer? Yes____ No______ Was anyone else held responsible? Yes____ No______ SPECIAL INTERROGATORY NO. 12: 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. Debtor had to jump into the roadway and get motorists to call the police to escape their aggression. What is the name and address of the second person? (If licensed, provide also the state and license number.) _________________________________________________________________ SPECIAL INTERROGATORY NO. 13: That second person was caught on tape August 14, 2000 (transcript posted August 18, 2000) threatening debtor's daughter. What instructions were Edwin Richardson and that other person (above) given in regard to debtor.
_________________________________________________________________ SPECIAL INTERROGATORY NO. 14: 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. 15: 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. 16: At that time, what were their positions at Golden Era? ___________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ SPECIAL INTERROGATORY NO. 17: 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. 18: 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?
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 was fired not by a critic of Scientology but 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_____ Do you now regret your perjury under oath? Yes_____ No_____ 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. 19: 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. 20: What do you know about the hiring of private investigators in Canada to "investigate" the debtor? ________________________________________________________________
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