II Organizational Structure of the Guardian's Office

As a result of his intensive training in the Guardian's Office as well as having held high positions within the Information Bureau Mr. Meisner became thoroughly familiar with the organizational structure of the Guardians Office and its bureaus, both nationally and internationally.

Government Exhibit No. 1A  is a chart showing the organizational structure of both the World-Wide and United States Guardian's offices. At all times material to the indictment, the Guardiian's Office had World-Wide headquarters at St. Hill Manor in East Grinstead, Sussex, England; United States headquarters in Los Angeles, California; and a local office in the District of Columbia and some thirty other cities throughout the United States (including: New York City; Philadelphia, Clearwater, Florida; Miami; Chicago; Detroit; St. Louis; Houston; Denver; Seattle; San Diego; San Francisco; Sacramento, California; Hawaii; I.as Vegas; Los Angeles; Advanced Organization of Los Angeles; American Saint Hill Organization (Los Angeles); Portland, Oregon; Mexico City (which is under the jurisdiction of the United States Guardian's Office).

Each of the Guardian's Offices was composed of five bureaus: Information (prior to July 1973 known as the Intelligence Bureau), Public Relations, Legal, Finance, and Social Coordination. A sixth bureau not shown on Government Exhibit No. 1A was known as the Services Bureau. Each bureau was headed both at the World-Wide and national level by a Deputy Guardian. At the local level each bureau was headed by an Assistant Guardian.

At all times material to the indictment, L. Ron Hubbard was, by virtue of his role as the founder and leader or Scientology, overall supervisor of the Guardian's Office.

His wife, the defendant Mary Sue Hubbard, held the titles of "Controller" and "Commodore Staff Guardian" (CSG) and, as the second person in the hierarchy of Scientology, had duties which included supervision of the Guardian's Office.

Jane Kember held the title of "Guardian World-Wide" (GWW) and headed the daily operations of all Guardian's Offices, reporting directly to the defendant Mary Sue Hubbard who in turn reported directly to L. Ron Hubbard.

The Deputy Guardian for Information World-Wide (DG I WW) was Morris Budlong, also known as Mo Budlong (hereafter Mo Budlong). He supervised all Information Bureaus around the world and reported to Jane Kember.

The defendant Henning Heldt was the Deputy Guardian for the United States (DG US) supervising all Guardian's Offices in the United States. He reported directly to Jane Kember.

Government Exhibit No. 1B is an organizational chart of the Information Bureau in the United States from November 1973 until January 1976 when it was reorganized.

The defendant Duke Snider was Deputy Guardian for Information in the United States (DG I US) from March 1974 until January 1975, a position thereafter held by the defendant Richard Weigand. Beginning in January 1975 and at all other relevant times charged in the indictment, the defendant Snider was Deputy Deputy Guardian for the United States (DDG US) and in that capacity was the defendant Heldt's top assistant.

In October 1975, the defendant Gregory Willardson became the Deputy Deputy Guardian for Information U.S. (DDG I US). Prior to that date he had held the position of Branch I Director U.S. (BR I DIR US).

The defendant Cindy Raymond was the Collections Officer for the United States (COLL OFF US). She was responsible for the overt, and covert data collection for the Information Bureau.

Government Exhibit 1C is an organization chart of the Information Bureau in the United States after its reorganization in January 1976.

Following the removal of the defendant Richard Weigand from the position of Deputy Guardian for Information U.S. on approximately May 15, 1977, that position was assumed by Brian Andrus until June 16, 1977, and thereafter by the defendant Gregory Willardson.

From January 1976 until May 1977, Mr. Willardson held the position of Deputy Deputy Guardian Information U.S. (DDG I US). For the period  January 1976 to June 1976, Mr. Willardson also held the position of National Secretary for the Information Bureau U.S. (NATL SEC US). [

That was commonly referred to in Scientology as a position "held from above" or "HFA" both of which appear on the routing portion of certain documents and which connotes that an individual ia assuring the responsibilities of more than one position at the same time.] 

From June 1976 until August 1976 the position of National Secretary was held by Michael Meisner, who was succeeded in September 1976 by the defendant Cindy Raymond.

Government Exhibit No. 1D is an organizational chart of the Information Bureau in the District of Columbia. From January 1974 until June 1976, Mr. Meisner held the position of Assistant Guardian for Information in the District of Columbia (AG I DC). Immediately under him was the defendant Hermann who held the position of Information Branch I Director from January 1974 until March 1975. The defendant Hermann, using the alias "Mike Cooper," subsequently held the position of Southeast U.S. Secretary (SEUS SEC) from January 1976 until March 1977 when he was succeeded by Brian Andrus. (See Government Exhibit No. 1C, supra.)

The routing on each document prepared within the Guardian's Office of the Church of Scientology, and its underlying bureaus, tracks the organizational charts. (Government Exhibits Nos. IA -- ID.) Thus, in the routing portion of each document is the abbreviation of each of the positions held by the Persons who were to receive the particular documents, as well as that of the author of the document. (See, e.g. Government Exhibit 14, discussed at page 48, infra.)

From January 1974 when Mr. Meisner joined the Guardian's Office until he left the Church of Scientology in June 1977, Mr. Meisner had extensive person to person contacts with the defendants Henning Heldt, Duke Snider, Richard Weigand, Gregory Willardson, Cindy Raymond, Mitchell Hermann, Gerald Bennett Wolfe and Sharon Thomas.

During some of the periods charged in each conspiracy, the latter four defendants were in fact, subordinates of Mr. Meisner. Mr. Meisner repeatedly met with each of these eight defendants. He exchanged many written communication with them, especially the first six named defendants as well, as the defendant Mary Sue Hubbard.

He became intimately familiar, with the handwriting and signature of the defendants, and thus is able to identify their writings and signature wherever it appears on the documents appended to the instant record as Government Exhibits. Indeed he witnessed most of the defendants write and sign their names in his presence.

Part III of the Stipulation of Evidence