UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA

V Criminal No. 78-401

MARY SUE HUBBARD, et al.

STIPULATION OF EVIDENCE

The United States of America, through its attorneys, United States Attorney Carl S. Rauh, Assistant United States Attorneys Raymond Banoun, Timothy J. Reardon, III, and Steven C. Tabackman, and the attorneys for the defendants: Leonard B. Boudin, Esquire, and Michael L. Hertzberg, Esquire, for the defendant Mary Sue Hubbard; Phillip J. Hirschkop, Esquire, for the defendants Henning Heldt and Duke Snider; Rcger Zukerman, Esquire, and Roger Spaeder, Esquire, for the defendants, Richard Weigand and Gregory Willardson; Michael Nussbaum, Esquire, and Earl C. Dudley, Esquire, for the defendants Cindy Raymond and Mitchell Hermann, also known as Mike Cooper; John Kenneth Zwerling, Esquire, for the defendants Gerald Bennet Wolfe; and Leonard J. Koenickp Esquire for the defendant Sharon Thomas; as well as the above-mentioned defendants themselves , agree and stipulate that the evidence as to all the defendants is as follows:

TABLE OF CONTENTS

I. The Witness Michael J. Meisner

II. Organizational Structure of the Guardian's Office

111. The Conspiracy to Intercept Oral Communications, Burglarize and Steal, and the Substantive Acts Committed Pursuant Thereto

A. The Order to infiltrate the Internal Revenue Service in Washington, D.C. 

B. The Bugging of the IRS Chief Counsel's Conference Room on November 1, 1974

C. The First Infiltration of the IRS in the District of Columbia Pursuant to GO 1361

D. Infiltration of the Tax Division of the United States Department of Justice

E. The Guardian's Office Awards its GO 1361 Workers

F. The Theft of IRS Documents Exempted from Disclosure Under the Freedom of Information Act 

G. The Guardian Program Order Instituting An "Early Warning System" to Detect Possible Legal Actions Against L. Ron Hubbard and Mary Sue Hubbard 

H. The Los Angeles Guardian's Office Sends Help to the District of Columbia Guardian's Office

I. The Guardian's Office Orders Mr. Meisner to Los Angeles for Debriefing and Auditing

J. Mr. Meisner Returns to the District of Columbia

K. The Entry Into the IRS identification Room and the Making of Counterfeit Identification Cards

L. Guardian Program Order 302 and the Theft of Documents Withheld by the United States Under the FOIA

M. Burglaries of the Suite of Offices of the Deputy Attorney General of the United States

N. Burglaries of the Office of International Operations of the Internal Revenue Service and Theft of Documents Therefrom

O. Burglaries and Thefts or Documents From the Department of Justice in Washington, D.C. 139

1. Office of Paul Figley

2. Interpol Liaison Office at the Department of Justice

3. Offices of Special Assistant to Assistant Attorney General for Administration John F. Shaw

P. Burglaries and Thefts or Documents from Assistant United States Attorney Nathan Dodell's Office, Located in the United States Courthouse for the District of Columbia

IV. The Conspiracy to Obstruct Justice, to Obstruct an Investigation, to Harbor a Fugitive and to Make False Declarations Before the Grand Jury

A. The Preparation or the Cover-up Story

B. The Defendant Gerald Bennett Wolfe is Arrested in Washington, D.C., by the Federal Bureau of Investigation

C. The United States Case Against the Defendant Gerald Bennett Wolfe is Referred to the Grand Jury, and an Arrest Warrant is Issued for Michael Meisner

D. The Guardian's Office Harbors and Conceals Fugitive From Justice Michael Meisner

E. The Guardian's Office Gives the FBI and the Grand Jury False Handwriting Exemplars

F. The Guardian's Office Refines its Cover-up Plans

G. The Federal Grand Jury Investigation in the District of Columbia Continues

H. The Guardian's Office Cover-up Moves Into its Final Phase

1, The Guardian's Office Restrains and Guards Michael Meisner

J. Michael Meisner's First Escape from His Guards

K. The Defendant Wolfe's Sentencing and Subsequent Testimony Before the Grand Jury in the District of Columbia 

L. The Defendant Wolfe is Debriefed by the Guardian's Office After his Grand Jury Appearance

M. Michael Meisner Surrenders to the Federal Bureau of Investigation

Exhibit of Evidence Attached to the Stipulation