SHERIFF COURT, ABERDEEN
LETTERS OF REQUEST
to examine a witness
RELIGIOUS TECHNOLOGY CENTER Plaintiffs
ROBIN SCOTT and OTHERS Defendants
Examination of Robin Scott by Mr. Watt
[excerpts from the deposition]
Question: "Did any of David Mayo, John Nelson, Harvey Haber, Dede Reisdorf, Jon Zegel, Vivian Zegel or anyone connected with the CNC, Santa Barbara, ever participate in the actual removal of any materials from the Advanced Organization in Denmark in December 1983?"
Answer: "Absolutely not, they knew nothing about it and had nothing to do with it."
Question: "Were any of these people involved in the conspiracy to remove the documents from an Advanced Organization in Denmark?"
Answer: "Well now, I have already explained that Morag Bellmaine, Ron Lawley, Steve Bisbey and to a lesser extent my wife, Adrienne Scott, were involved with me in the removal of the materials from the Church. I can categorically state that none of the other people knew anything about our plans or in any way had anything to do with this alleged conspiracy."
Question: "On Page 29 of the document, you state that David Mayo is the prime target. What are your reasons for stating this and what other evidence do you have to substantiate this?
Answer: "Well, I will try and be brief in my answer to this question, but I feel it is a very important question and it is very central to the whole dispute that we are all involved in. This particular Affidavit is perhaps the best evidence of the case that the Church is trying to make, not only against myself but against all the other people named here. This Affidavit was presented to my lawyer while I was in prison facing a possible four year sentence. I was in a foreign country, with my wife and children at home, without me. I was under, as you can imagine, a considerable amount of stress, confronted with an organization with millions of dollars of reserves stacked against me, and a stated policy of using legal procedure to harass, bankrupt and financially ruin anybody who dared to speak up against the management of the Church. I can substantiate all of these remarks. Now, what I want you to understand is the degree of duress that was placed on me at that time, and the deal was that if I was willing to sign this document, they would drop charges. The document itself is almost laughable in the ludicrousy of its allegations, that some of these people - some of them I have never even met - had been involved in my actions, is just ridiculous.
"What the Church was trying to achieve with this document was two things. One was to try and incriminate David Mayo specifically. If you look at that Paragraph 20, you will see that he is a prime target, that they wanted him specifically named as somebody who I had given a pack of materials to. What they were basically trying to do with this Affidavit was put me under enormous amount of emotional pressure to sign, in effect, a pack of lies in order to get myself off the hook and to give the Church spurious evidence with which to try and harass and cause problems for the other people who had also had the integrity and moral courage to speak up against the activities of the Church.
"Now, the reason why David Mayo is a specific target is that he is, of course, the most competent and highly-trained person probably in Scientology worldwide. He had the reputation, for many many years, as being Ron Hubbard's most trusted technical adviser, and he was the most highly qualified man. He had been in that position for many years until he was removed in very unpleasant circumstances. He then set up as an independent centre, as I did, and he posed a very serious threat to the Church, both in terms of the credibility of what he was doing, and in purely financial terms, because by setting up these independent centres, we, and David Mayo particularly, broke this fraudulent monopoly which the Church had exercised and with which it has extorted thousands of dollars from vulnerable people. So, the Church has been very very adamant and very very hard working in trying, basically, to nail David Mayo particularly, because he was their adversary who had the greatest credibility. I hope that answers your question.
SHERIFF BELL: "Could I just have the question again, to see whether it has been answered.
MR. WATT: The question was, on Page 29 of this document, you state that David Mayo is the prime target. What are your reasons for stating it and what other evidence do you have to substantiate this.
SHERIFF BELL: "Thank you."
EXAMINATION CONTINUED BY MR. WATT: "What terms did the representatives of the Church of Scientology offer you if you agreed to sign this document?"
ROBIN SCOTT: "Well, it is very interesting to note that this was not the only time that the Church basically offered me or my associates some sort of deal in an attempt - in fact, I have been offered a deal within the last week, and it is probably the tenth or twelfth time I have been offered a similar sort of deal. Now, what they want from me is to sign an Affidavit similar to this one. Similar offers were made to my wife by a Private Investigator acting an behalf of the Church, that if we returned the materials, all charges against me would be dropped. Similarly, this was put to Ron Lawley, that if he returned the materials, I would be released from the prison in Denmark. Neither of those offers were honoured. This Affidavit, to answer the specific question, this Affidavit was presented to me under considerable duress, in prison, in the hope that I would sign this, thus incriminating all sorts of innocent people in crimes which they had nothing to do with, and that would save my bacon, they would then effect my release and drop the charges against me. Subsequently, the Church has on at least three or four, or maybe five occasions that I can recall, made a similar offer to me. They have threatened me with expensive litigation and legal proceedings in exchange for releasing me from this duress and they have asked me to sign these spurious Affidavits incriminating innocent people."
Question: "Do I understand from that then that the terms offered you, if you signed that, were your release from custody in Denmark?
Question: Those were the terms?"
Question: "What consequences were stated if you did not sign the document?"
Answer: "Well, the consequences were not specifically stated, but were implicit in their offer, that I would go, possibly, to jail for an unspecified amount of time, which obviously would cause me considerable distress and hardship, and to my family as well. Also, there was the implicit threat of continued expensive litigation against me, a private individual, by a very wealthy international organization. I knew fine well that the Church had several explicit policies which dictate that anybody who is opposed to the Church in the way I have been, should be hounded until bankrupted and ruined. So I knew fine well, by taking on the Church, that if I didn't accept this view with them, they would do everything to cripple me financially.
Question: "What was your understanding of the purpose of this offer by the Church of Scientology?"
Answer: "Well, my understanding was that what they really wanted was evidence that they could use in court, and the other people that you have mentioned, that you have asked me about, but specifically David Mayo. I have attempted - saw earlier a document where I attempted, on my own initiative, to reach an amicable settlement with the Church, and it became very clear to me that their purpose in making such offers was not in fact at all to effect a settlement. They don't want to settle. They merely want to string me along with the promise of getting off the hook and persuade me by these false promises to incriminate innocent people in crimes which they did not commit. So, what they really want is the dirt on other people. They don't genuinely and honestly want to settle, that is merely a false apparency."
Question: "Did you sign the document?"
Answer: "Of course not, it was laughable."
Question: "The next question is, why not?"
Answer: "Well, in the first place, it is completely untrue. I would have been perjuring myself if I had signed it. In the second place, I had no inclination to be intimidated by the Church and to capitulate. I was quite willing to go to prison if I had to. I was not about to compromise my own integrity in a misguided attempt to save my own bacon."
Question: "Would you look please now at two documents each of which bear the identification Exhibit 120. Is one identified as A and one B?
Answer: "They both seem to be numbered 120."
Question: "I think one document, which appears to be a declaration by Adrienne Scott, is identified as No. 120A?"
Answer: "That is correct."
Question: "And the other appears to be a declaration by Gaye Allen and is identified as 120B?"
Answer: "That is correct."
Question: "Can you identify the document?"
Answer: "Yes. Let us take Exhibit A first. This is a statement which was written in her own hand by my wife on the 22nd March 1984. It was witnessed by two people at Candacraig at that time. During the time that I was in prison, my wife was subject to a considerable degree of intimidation and harassment from the Church - - bearing in mind she was the mother of three small children, that her husband had just been imprisoned in a foreign country and she was obviously under considerable strain and stress. It simply lists out some of the dirty tricks that the Church used to try to put pressure on her in order to get their way. But the other is a document from a girl called Julie Allen, and I think this is a good example of the sort of dirty tricks that I have just been talking about. She has signed the Declaration, a statutory Declaration, in front of a solicitor in, I believe, East Grinstead in Sussex, on the 11th April 1984. It simply states that a man called Ian Hepplewhite had told her that the Church of Scientology had really nailed Robin Scott. He said that he had personally found out the name of Robin Scott's building society and had given that to a staff member in the Church. He said that the building society had been rung and told that Robin Scott was in jail in Holland and he would be in prison for at least two years and more like four years and would not be able to pay the mortgage. He said that the mortgage company was taking back the property. Apart from the fact that Ian Hepplewhite actually phoned the wrong building society, this report is extremely accurate. But, it does give the court, I think, a good taste of the sort of tricks that the Church of Scientology used in trying to intimidate and harass individuals who speak out against it. My wife, of course, will be able to provide you with first-hand details of several other incidents that occurred during that time, and subsequently."
Question: "The next one is, to the best of your knowledge, what were the circumstances leading up to the writing of these documents?"
Answer: "Well, I think I have largely answered that and I suggest, really it would be better for my wife to elaborate on this particular aspect of the case, because I feel it is a very important aspect of the case and it should not be neglected by the court."
Question: "What reasons did the Church give you to offer you leniency in exchange for implicating David Mayo?"
Answer: "Well, there has been a consistent thread in the approaches I have received from the Church. The Affidavit I received while I was in prison was only the first such approach from the Church. I was subsequently approached in 1985 on several occasions by a man called Andy Hutton and a Kurt Weiland whom I have already mentioned. They were acting on behalf of the Church. They approached me. Later, Kurt Weiland and Jessie Prince whom I have already mentioned, contacted me on two occasions during 1985. I have subsequently been approached this year, through my solicitors, by Mr. Moffat, who is present today, I believe with yet another supposed offer of settlement. So, I think that makes at least five or six occasions on which I have been approached by the Church with an offer of leniency in exchange for implicating David Mayo. I think it is important for me to try and describe the actual contents of the Church's approaches, because what is stressed in all of my meetings with representatives from the Church is that the Church is an immensely wealthy organization which is capable of sustaining prolonged litigation against an individual. I mean, I currently have no less than, I think there are six lawsuits against me, which the Church has brought against me in different countries. I am defending six lawsuits around the world. The argument that the Church uses is to insinuate that if I don't agree to their terms then they will continue with this expensive litigation, and the implication is that, of course, as a private individual, I am quite unable to sustain that level of litigation, and they will ruin me. When I bear in mind that the stated policy of the Church is to bankrupt anybody who speaks against it, then, to answer your specific questions, the real reasons the Church gives to offer me leniency is simply so that they can frighten me into implicating David Mayo in something that he never did. The reasons that they suggest for my accepting their offer is that it makes good sense financially for me to get myself off the hook at David Mayo's expense. That is, in essence, shall we say, the undercurrent of all their approaches."
Question: "Did you ever meet, or talk with Mr. Ingram or anyone else from his agency, and if so, when, and what was said?"
Answer: "I have never talked to Mr. Ingram. I believe that he approached my wife on several occasions while I was in Denmark, and you would have to find out from her what was said at that time...
EXAMINATION CONTINUED BY MR. WATT: Did you have personal knowledge of anyone else who has been approached with any offers by the Church if they would implicate David Mayo in the taking or receipt of documents from the Church of Scientology in Denmark --
BY THE COURT: "Personal knowledge? - Yes, Mr. Ron Lawley, I know, has been approached with a similar offer and also, I believe, Steve Bisbey."
Question: "Do you know from them personally?" -
Answer: "Yes, from them personally, they have talked to me and told me that they have had similar offers - Steve Bisbey and Morag Bellmaine."
[end of excerpts]