UNITED STATES DISTRICT COURT __CENTRAL DISTRICT OF CALIF. No. CV 76-2055-F(FX) CHURCH OF SCIENTOLOGY OF CALIFORNIA NON-PROFIT CORP. PLAINTIFF VS. PAULETTE COOPER DEFENDENT DEPOSITION OF IDA MAE J. CAMBURN, TAKEN ON BEHALF OF PLAINTIFF AND COUNTER-DEFENDANT AT 2029 CENTURY PARK, SUITE 500, LOS ANGELES CALIFORNIAN COMMENCING AT 10:00 A.M., Monday January 8, l979 pursuant to notice VX CHURCH OF SCIENTOLOGY OF CALIF. A NON-PROFIT CORP. Reported by: COUNTER DEFENDANT JULIE COOPER, CSR 33610 Notary public WEBSTER REPORTERS 1545 Wilshire Blvd. Suite 500 Los Angeles, CA. 90007 213-413-1950 APPEARANCE OF COUNSEL: FOR PLAINTIFF AND COUNTER DEFENDANT GARFIELD, TEPPER AND ASHWORTH BY FRANKLIN R. GARFIELD, ESQ 2029 CENTURY PARK EAST SUITE 500 LOS ANGELES, CALIF. 90067 FOR DEFENDANT AND COUNTER CLAIMANT: MORGON WENZEL AND MC NICHOLAS BY ROY A. GOTO ESQ. 1545 WILSHIRE BLVD. LOS ANGELES, CA. 90017 FOR IDAMAE J. CAMBURN DONOVAN AND SOMERS BY DENNIS F. DONOVAN ESQ. 445 SOUTH FIGUEROA ST. SUITE 1310 LOS ANGELES, CALIF. 90017 ALSO PRESENT: .LYDIA STEIN REBECCA CHAMBERS PAGE 2 IDAMAE J. CAMBURN HAVING BEEN FIRST DULY SWORN, WAS EXAMINED AND TESTIFIED AS FOLLOWS : EXAMINATION BY MR. GARFIELD Q. MRS CAMBURN, WOULD YOU STATE YOUR FULL NAME FOR THE RECORD, PLEASE A. IDAMAE J. CAMBURN Q. ARE YOU MARRIED A. YES MR. DONOVAN: EXCUSE ME COUNSEL SINCE IT APPEARS THAT THERE ARE MORE OF PEOPLE HERE THAT ARE NOT INVOLVED IN THE PROCEEDING AND THEY ARE NOT PARTIES, COULD WE HAVE THEM ALL IDENTIFIED, PLEASE; MR. GARFIELD: CERTAINLY MS. CHAMBERS: I AM REBECCA CHAMBERS MR. GARFIELD: MS. CHAMBERS IS A REPRESENTATIVE OF THE PLAINTIFF IN THE ACTION MS STEIN; I AM LYDIA STEIN: I AM A FRIEND OF IDA CAMBURN MR DONOVAN COUNSEL, YOUR NAME AGAIN MR. GOTO: I AM APPEARING ON BEHALF OF PAULETTE COPPER, ROY A. GOTTO FROM MORGAN , WENZEL AND MC NICHOLAS MR. GARFIELD: THE RECORD ALREADY REFLECTS YOUR PRESENCE. MR. DONOVAN, VERY GOOD. I HAVE GIVEN THE REPORTER MY CARD. Mr. Garfield: Q. What is your residence address: A. l085 Tasmine Drive no. 449 Sunnyvale Q. what is the phone number A. 744-0339 code 408 Q. Are you employed , Mrs. Camburn A. No. Q. Have you ever had your deposition taken before: A. no Q. have you had an opportunity to discuss with your attorney what a deposition involves? A. yes Q. You understand that even though we are in the relatively informal surroundings of my office, Your deposition has the same force and effect as if it were being given as testimony in a courtroom. A. yes , I do q You understand you have been sworn as a witness to tell the truth and the whole truth A. yes. Q. I am going to ask you a series of questions, as your attorney has undoubtedly told you , about the subject matter of the lawsuit entitled the Church of Scientology Vs. Paulette Cooper pending in the central district of the united states district court. Your answers to my question and the questions will be typed up by the court reporter after the deposition. You will have an opportunity before being asked to sign the booklet which will be prepared to review your answers and make any changes or corrections what you believe are in order. Do you understand that? A. yes Q. I want to caution you that although you will be free at the time the depositions I presented to you to make any changes or corrections, that I or any other counsel in the case will be able to comment on those changes and corrections, if indeed any are made at the time of trial. Do you understand that? A. yes Q. On that basis I would urge you to listen very carefully to my questions, to think about your answers so that we do not have an y misunderstandings about what I am asking. If you do not understand a question, if it is unclear to you or for any reasons you would like the question repeated, fell free to ask me to repeat it and I will be gld to do that. I want to emphasize to you that I am not here to trick you in any wy. I tend to make my questions as straightforward as possible. Again, if any questions is unclear to you for any reason, feel free to say so. A. good. Q. Mrs. Camber, are you aware of any reason why you cannot have your deposition taken today and testify in this proceeding? A. what do you mean by that? Q. As i recall, there has been a medical problem, and while I do not want to pry into the details of your personal life, I do want to know why if that medical problem still exists ifit would interfere with your ability to participate in this deposition as a witness? A. I am on medication. Q. what medication are you taking? A. I am taking inderal Q. could you spell that? A. Inderal I believe. I think that is the proper spelling Mr. Donovan: I think it is endral and I think it is a potent cardia-vascular prescription. Drug used in various types of arterial problem. MR. Garfield: A. Are there side effects to the drug? A. there can be Q. Are you experience any side effects: A. Not great ones. Q. How long have you been taking the drug ? A. I cannot remember. I have been taking it a long time Q. a matter of months? A. oh, longer Q. years? A. yes Q. Does it cause drowsiness or fuzziness of any kind A. Not the dosage I am taking at the present time. It has, but I feel all right, I think I believe I feel all right today . I also take valium. Q. valium? A. yes. Q. When was the last time you took valium? A. This morning Q. At what time? A. 8:00 I believe Q. How many milligrams? A. five Q. what color was the tablet? A. It is a yellow tablet q Are you taking any other prescription medications or any medications besides the two you have just described to me? A. I take one at night Q. one what? A. adapin, adapin I believe Q. Are there side effects to that drug? A. I only take it at night Q. Is it to assist you in falling asleep? A. I take it at 8:00 at night and I go to sleep when I go to bed ordinarily Q. Is that the purpose of the rug? A. I do not believe it is a sleeping pill Q. Do you have any idea why you take it. A. The doctors prescribed it for me Q. Did the doctors tell you what they prescribed it for , what its purpose was? A. It is an anti-stress drug, I believe. Q. aside from the three drugs you have just described to me, are there an other medications that you are currently on? A. No. Q. Do you know Paulette Cooper A. I have never met Paulette cooper Q. Have you spoken to Paulette Cooper on the telephone? A, Yes Q. When did you first speak to Paulette Cooper on the telephone? A. I cannot remember the date. It has been a long time ago. Q. What was the year A. I believe to the nearest of my recollection it was in l976. Q. Do you remember the season? A. I believe it was in September. I believe I might have been Q. Why do you believe it might have been in September? A. Because I was on vacation. I was in the east. Q. Were you working at that time? A. No. Q. Did you call her or did she call you ? A. I called her Q. What was the purpose of the call. A. I had read her book Q. What book are you referring to? A. The Scandal of Scientology. . Q. What was the purpose of your call? A. My son had become involved in Scientology Q. When you say "involved," what do you mean A. He joined Q. He became a Scientologist? A. yes. Q. When did he become a Scientologist? A. I have no idea, he never told me Q. In September of l976 you were aware that he had become a Scientologist? A. yes, he was well he was in. I knew by that time. Q. Where was your son at that time A. He was at the ASHO Foundation Q. Where is that located? A. Here in Los Angeles Q. That is a Scientology Organization A. It is a Scientology org., I believe they call it Q. I am not familiar with that term , So I will use English MR. Goto: Could you spell the name of the Foundation? The witness A- S-H-O Mr. Garfield: Q. What is your son's name? A .Ronald Richard Watson Q. What is his birthday? A. He was born July 4, l94l Q. To the best of your Knowledge is your son still a Scientologist? A. Yes Q. Where is he located at this time A. I believe he still lives in Canoga Park. Q. When you called miss Cooper about September of l976, what did you say to her? A. It has been so long. I told her I had a son in Scientology Q. What did she say to you ? A. I cannot recall her answer. Q. Did you ask for anything from Miss Cooper? A. Well I said I was disturbed that my son was a Scientologist Q. Did you tell her that you would like assistance from her of some kind? A.No, I think I just, I do not know what assistance I would have asked of her. Mr. Donovan: Excuse me. If you cannot recall or you dot remember, do not guess, Just say that you cannot recall. The Witness: I cannot . I cannot remember other than telling her. Mr. Garfield: Q. Mrs. Camburn, certainly if it is the case that you cannot remember something you are free to tell me that, but since I am interested in getting as much information as I can in connection with the lawsuit, I am going to continue to work with you to try to refresh your recollection. Right now what I am interested in finding out is whether there is a reason that you called Miss Cooper aside from just saying to her, "My son is a Scientologist and I am concerned and what her response was. A. yes Q. You have indicated to me that you did not ask her assistance for any reason? A. no. Q. What was the purpose of the call? A. I guess just because I was disturbed. Q. Do you remember anything that she said to you during that conversation? A. no. Q. When was the next time that you had any contact with Miss Cooper ? A. I called her following the date that I was served the subpoenA. Q. From September of l976 until September of 1978 which is I recall when the subpoena was served. A. I believe that is the date Q. that is close enough . Did you ever speak to Miss Cooper during that prior of two years on the telephone. A. Not that I can remember Q. Did you correspond with Miss Cooper? A. Never Q. Did you receive any correspondence from her? A. never Q. After you were served with the subpoena in this case you indicated you called her. A. yes Q. at her home? A. yes Q. What did you say to her A. I could not see why -I did not understand why I would be called with regard to a case that she was involved in. I mean I could not understand my name even being on the subpoena. Q. What did she say to you A. she said she did not know other than she had thought she had seen my name in some papers she had. Q. Did she describe the papers to you? A. no. Was she referring to court papers? A. I do not know. I did not ask her. Q. Did she say anything else to you during that conversation? A. I cannot remember. It was a short conversation. Q. Did you ask her what it was all about A. She did mention she was being sued. Q, Did you ask her what it was all about? A. Other than why was my name on the paper that is the only thing that I had a reason to ask her. Q. Did she tell you what to do about it? A. No Q. She did not give you advice of any kind? A. No not that I recall. Q. You indicated earlier that you had read the book, The Scandal of Scientology A. Yes Q. Do you still have our copy of the Book? A.I have a copy Q. Do you have more than one? A. No. Q. have you ever had more than one copoy? A. yes Q. How many copies have you had? A .Fourteen Q. When did you acquire those copies? A. Oh, it has been a long time. I cannot remember when I got them Q. Did you have them before or after you talked to Miss Cooper in Sept. f l976? A. Yes, I had read it, So I had it before I called her. Q. You had your copy, Do you remember when you got the l4 additional copies? A. They were not additional. I only had l4 copies. Q. Do you recall when you got the l3 additional copies, whether it was before or after your conversation with Miss Cooper. A. I got them all at the same time Q. Do you recall if you got the l3 additional copies before or after you conversation with Miss Cooper or if after? A. I had to have them before Q. Why is that A. Because I had read the book. Q. You had read one copy? A. yes Q. Then you got l3 others Mr> Donovan: Excuse me counsel. She indicated she bought those all at the same time. Mr. Garfield: Counsel I do not agree wit your characterization of her testimony and I appreciate not having your assistance. The Witness: I got l4 copies all at the same time. Mr.:Garfield: Now I understand did you buy them? A. yes Q. from whom? A. a news Agency Q. Do you recall the name of the News agency A. yes Q. What is the name of the New Agency? A. Drown Q. Could you spell it please? A. I believe it is Drown. There my be an "e" on it. I do not know. Q. Where is Drown News Located? A. Westminister Q. Calif. A. Yes Q. Did you purchase the book A. Yes Q. Why did you purchase l4 copies? A. I wanted all they had Q. Why was that A. I figured they were a good buy Q. Did you feel they were going to appreciate in value A. I did not give that any thought Q. What is it that made them a good buy? A. I had a son in Scientology Q. I understand that , but you can only read a book once. Why did you want l4 copies? A .I was going to give them as gifts. Q. Di you give them as gifts? A. Yes Q. To who did you give them? A. oh , family Q. Why don't you give the names of some of the people you gave them to. A. I cannot recall . I gave one to a brother Q. what is his name? A. Morris Jennison Q. Could you spell that? A. Jennison Q. Where does he reside A. New Mexico Q. What City A. Lovington. Q. Thank you who else did you give a copy to? A. I cannot remember Q. Did you send a copy to your son? A. No. Q. Did you give a copy to anyone is not family? A. I may have. I cannot recall Q. Is it fair to say that your testimony is that you acquired l4 copies of this book all at the same time to give as gifts to family members and perhaps people who were not family members? A. I would say that is fair. Q. There was no other purpose to buying l4 copies? A. No. Q. have you ever bought that number of copies of a book before any other book? A. I have bought, I cannot remember any specific number, but I have bought more than one book at a time Q. Do you remember any of the books you looked so well that you bought that many copies? A. Oh , years ago, I cannot remember , Collegiate dictionaries. Q. Do you know a man named Ron Enroth ? A. The name sounds familiar. I cannot remember. It does not ring a bell q, You do not remember knowing anyone named Ron Enroth or Ronald Enroth A. I cannot remember . It sounds familiar but I cannot associate it. I cannot remember Q. Do you know a woman named Amy Majors? A. yes Q. who is Amy Majors A. A young woman Mr. Donovan: Pardon? The Witness: : she was a young woman ‘ Mr Garfield What is her occupation? A. I do not know what her occupation is Q. How is it that you came to know her? A. I met her at a parent meeting? Q. what kind of parent meeting? A. A parent meeting with people involved in various groups Q. What was the purpose of the parent meeting A. A get together q When you say "A parent meeting with people involved in various groups are you referring to a particular kind of group::? A. Yes Q. What kind of Groups A. Unification Q. Do you mean the Unification Church? A. Yes, yes, Various–I don't know all different groups Q. Scientology? A. I do not know if there were any Scientology parents there Q. except yourself? A. Me Q. Was the meeting composed of parents who had children who had joined religious or other groups that they disapproved of? A. yes Q. Who called the meeting: A. I do not know Q. Do you remember who resided at the meeting? A. I cannot remember who presided Q. When was the meeting? A. I do not remember Q. Where was the meeting? A. Berkeley Q. Does Amy Majors live in Berkeley A. I do not know Q. Was Amy majors at the meeting? A. She was at a meeting Q Was she at that meeting? A. yes Q. Is she a parent of a child who is a member of a religious organization that she disapproves of? A. Not that I know of. Q. What was her reason for being at the meeting? A. She was there Q. You do not have any idea why Amy Majors was at the meeting for parents of children who had joined religious groups? A. No She was there. Q. Did you have a conversation with her that night? A. Not that I can recall Q. Did she speak at the meeting that night? A. Not that I can recall Q. Do you have any idea why she would have been at the meeting? A. I do not know Q. What was the purpose of the meeting aside from getting together A. A get together Q. Maybe I am not making myself clear. Did you get together to exchange ideas about your respective situations? Did you get together to raise money ? Did you get together to commiserate with each other. I am trying to understand what the purpose was.. A. I believe my purpose for being there was to gain understanding. Q. Understanding of what : A. How to cope Q. How to cope with what? A. With having a loved one in a group Q are you referring to your son? A. that is right Q. Why did that disturb you so much Mr. Donovan: Counsel That is getting pretty personal Mr. Garfield I think given the nature of the case and what I believe to be a pattern of Mr.Donovan: I do not think her thought process are Mr. Garfield: It is a fair question I am not aware that thought process are exempt from questioning Q. Why did it bother you ? Mr. Donovan: Certainly thought processes are exempt That was established in a most recent case about a reporters thought process and they were exempt. I have no objections at all to your asking her what happened, when where so on , but as to her personal thought processes– MR. Garfield: I do not want to characterize it as her "Person thought processes" let me state the question again for the record let me also reference the federal rule The number of which escapes me, which dictates the question shall be answered, and if counsel wants to object or instruct the witness not to answer that is up to him. (There was discussion off the record) Mr. Garfield: q.. Mrs. Camburn, Do you consider yourself an antagonist of the church of Scientology, Hostile to the Church of Scientology ? A. I do not like the church of Scientology q What is it that the church hs done that makes you dislike it? A. I has changed my son's life Q. How has your son's life changed? A. In all ways Q. Prior to joining the church of Scientoogy was your son employed A. He had his own business Q. What was that Business? A. a computer business. Q. He serviced them, sold them programmed them A. He had a systems business and had an interest in another systems Q. Is your son employed now? A. I do not know Q. Do you maintain contact with your son A. I have not heard for some time Q. A matter of weeks, months? A. Months. Q. Can you be more specific about the was in which your son has changed that has upset you ? A. This is very disturbing Q. I am very sorry to disturb you . That is not my intention and we can take it s slow as you would like. If you would like to take a recess, I will be glad to have a recess. A. No I cannot explain it. It is too deep Q. What is the nature, and I am talking now about the recent past of your activities vis a vis the Church of Scientology " A. explain Q You indicated that you were hostile to the church. You did not like the change that had occurred in your son which you believe to have occurred as a result of his church membership: Is that correct? A. yes Q. Have you engaged i activities to express that hostility toward the church A. What do you mean by activities? Q. Do you meet with people regularly or irregularly who are hostile to the church? A. I see few people that are hostile to the church Q. who do you see who is hostile to the church A. I have not been to any meetings with anyone for a long time Q. What do you mean you say a long time? A Months and months Q. A year? A. Less than a year Q. six months? A. Longer than that I believe Q. Before the summer? A. yes Q. Leaving aside meetings for the moment have you gotten together with or spoken to people who are share hostility toward the church in the past six months or year/ A. my daughter in law Q. This is your son's wife A. ex wife Q. Have you written letters to people expression your hostility to the church? A. I do not know if I have ever I have not written letters for along time Q Maybe a General question will assist us both. You are telling me that for the past six months to nine months you have had no activity that is directed against or to the Church of Scientology. Mr. Donovan: Only if you can remember The witness: I cannot remember the time when I have met and I do not really understand your question as to expressing hostility. Mr. Garfield: Q. Let me see if I can clarify it. There are many people in this world who live and go about their lives in businesses without giving the Church of Scientology , The Catholic Church, the Presbyterian Church any thought at all. It is just not a factor in their lives A. I am sures that is so Q. The Church of Scientology was and is because of this family situation you described a factor in your life. I want to know what you do about it. If it just saddens you that your son is a member of the Church of Scientology , and over the years you have come to accept that with some resignation and regret, that is a perfectly acceptable answer . If, on the other hand you have decided that you will do whatever you can to try to change the situation or to expose the church as whatever you consider it to be , or to enlist the aid of other people in doing something about your concerns, then I would l ike to know what it sis you are doing and saying. Does that make it clear what I am after? A. I think so Q. In which of those categories would you say fall A. Today ? Q. Why don't we take that First A. I have done nothing Q. I realize you have done nothing as we sit here, but let's say for the last six to nine months . To who have you written letters" A. Congressmen Q. Have you written letters to Leo Ryan before his death ? A. Yes I have written to Leo Ryan Q. Do you keep copies of your letters? A. I am very careless Q. Do you remember anyone else you have written? I cannot remember specifically . I have written to other, I believe congressmen. Q. Do you recall writing in the last six or nine months to anyone other than Congressmen? A. Not that I remember Q. Do you know a gentleman named Howard Fuller A. I have met Mr. Fuller Q. Who is Mr. Fuller A. He is a minister Q. Of what faith " A. I did not ask him Q. Did you initiate the meeting with Mr. Fuller? A. No Q. Did he initiate the meeting with you ? A, He was at a parent meeting Q. A parent meeting of the sort you have described earlier? A. Yes I believe he had a son or daughter I do not know which involved in the Moonies Q. Did you have contact with Mr. Fuller as to the concerned parents? A. What do you mean by that? Q. Is that the nature of your interaction , two parents who were concerned about children who had joined groups that they disapproved of? A. I believe you could put it that way . Q. Did you give Mr. Fuller a copy of the Scandal of Scient ology A. Not that I can remember Q. Do you remember when the meeting was? A. that has been a long time ago. Q. Before Jan l, l978, more than a year ago? A. I met him more than a year ago Q. Have you had contact with him since in person or by phone or by correspondence. IA. I cannot remember if I have or not. Q. Do you recall meeting Mr.a nd Mrs. Lebowitz A. No. Q. Those names do not ring a bell? A. what was the last name? Q. Lebowitz. A. no Q. Have you ever had in your possession a document consisting of excerpts from the book the scandal of Scientology a.Not that I can recall Q. Havce you ever had a xerox copy of selected portions or various passages of the book in your possession A. Not that I can remember Q. Have you ever had a document in your possession called, "One Tenth of One Percent Which I believe is written by L. Ron Hubbard , Jr.? A.What was the name of it? Q. One Tenth of One Percent a, I have never heard of that that I can remember Q. You have never read it? A.not that I can remember Q. have you ever read any thing written by L. Ron Hubbard Jr.? A. I cannot remember I do not I cannot remember ever reading any thing of Jr. Q. Yes L. Ron Hubbard, JR. A. Not that I recall Q. Do you maintain files on the Church of Scientology and the related activities that we have been describing, parent meetings and so on. A. I get the newsletter Q. what newsletter? A. from the parent meeting Q. What is the name of the group that published and sends you the newsletter? A. Berkeley parent group Q. Berkeley Parent Group A. I believe that is what is, Berkeley parents. A. I do not get it any more I believe it was a monthly thing. Q. Do you knw why you do not get it any more? A. I just have not been getting it. I do not knwo why Q. Do you know a woman Alma Hall? A. I have never met Alma Hall Q. Have you ever talked to Alma Hall on the Telephone? A. I cannot recall talking to her on the phone. Alma? Q. A.l.m.a. A. I cannot recall Q. Do you know who she is? A. The name rings a bell but I cannot recall talking with her Q. Do you recall corresponding with her or receiving correspondence from her? A. I cannot remember Q. Do you know someone named J. Roylance? A. No. Roylance Q. yes A. No. Q. Do you know an individual named Mary Weeks? A I have never met Mary Weeks that I can recall. Q. Have you talked to Mary Weeks on the telephone? A. I cannot remember Q. Have you exchanged correspondence with Mary Weeks? A. I cannot remember if I have or not. The name rings a bell too–I cannot remember. Q. Do you have any idea of who Mary weeks is? A. She may be a parent I cannot remember I have heard her name Q. Do you recall where you heard her name? A. No I cannot remember Q. I realize that I am asking questions that cover a period of some time do you maintain files of your correspondence? A. I keep them awhile and then throw them out Q. You keep them or you throw them out A. I keep them awhile. Then - I am careless with files. Q Do you maintain a file of information about Scientology ? A. I have no great file on Scientology Q. In addition to the book, The Scandal of Scientology , do you have other material about Scientology ? A. I have other books Q. What are the names of those books? Q. Road to Total Freedom , Dianetics and I cannot remember any others specifically but I hae got a couple of other books. Is there something called something about "work"? Q. I do not know A. by L.Ron Hubbard Q. There may be A. I think I have that one Q. Do you have in your possession the literature wich is not necessarily in book form, but is critical of Scientology? A. I do not know if you would call it "critical" I hae the L.A. Times print out, whatever you call it. Q. who sent that to you A. My daughter in law Q. Your x daughter in law or a different daughter in law A. My x daughter in law. I never her call her my x daughter in law She will never be my x daughter in law Q. I am sorry I was just trying to A. She will never be my ex daughter in law Q. are you familiar with a document entitled Narconon an in-depth study A. no Q. Have you ever seen such a document? A. no. Q. Have you ever discussed such a document A. Not that I can remember Q. Do you know what Narconon is A. I have read what Narconon is Q. Where have you read that? A. My son sent me literature Q. other than what your son sent you have you read nothing about Narconon A. I cannot recall Q. Have you eer had discussion s about Narcon on with anyone. A. My son Q. Anyone else? A yes q who A. I do not know their names Q. What was the occasion A. Q. what was the occasion for having the discussion A. he brought two people to my home Q. He bein g who? A. my son Q. and you discussed Narconon A. he said one of them was from Narconon Q. Do you recall the discussion A. No Q. When did this take place A. It is over two years ago It must have been in 77 Q. have you had occasion to discuss or mention correspondence Narconon with anyone Congressman or state legislator? A. I m ay have I cannot recall Q. Have you ever had occasion to discuss or correspond about Narconon with any employee of the State of Calif? A. What do you mean by "employee? Q. Soemone employed by the State of Calif. and acaating in his capacity as an employee when he discussed the subject with you . A. I cannot recal Q. But you could have A. Not that I recall Q. When you say "Not that I can recall" do you mean I don't know whether I did or didn't or No, to the best of my recollection A. I cannot remember Q. Right now as we are sitting in this room and you and I are talking to each other , when I ask you a question you say Not that I can recall. A. I cannot remember Q. You mean that you cannot remember you could have, you may have, you may not have, and you just can't remember. A. I cannot remember Mr. Garfield We have been going on an hour lets take a minute break if that is agreeable. There was a brief recess Mr: Garfield Q. Did you ever xerox the book the Scandal of Scientology? A. No Q. Did you ever have it xeroxed A. No Q. Di you ever see a xerox copy? A. No Q. Were you ever asked to xerox it? A. Xerox the book? Q. yes A. No Q. Or copy it in any other way? A. No. Q. Did you ever provide a bound copy of the book A. It is a paper back Q. I have never seen it . Did you ever provide a book to the Dept of Public Health or any employer at the Dept. of Public Health of the state of Calif. A. Not that I know of Q. you mentioned two phone calls to Paulette Cooper one in Sept. L976 and one in Sept. of l978 have you had any other contact with her except for those two phone calls. A. not that I can recalls Q. You testified you have never met her and there have been no other phone calls A. not that I can remember Q. Q. Did you ever send her a letter? A. I have never written a letter to Paulette Cooper q Have you ever received a letter from her? A. I have never received a letter from Paulette Cooper. Q. Drown News is located in Westminster A. That is true Q. I s that owned or operated by a member of your family A. A member of my family works there Q. Which member of your family ? A. a brother Q. What is his name A. John Jennison Q. Is he the person to whom you gave a copy of the Scandal of Scientolgoy A. No I gave my brother Morris a copy . I may have given John a copy--I do not know if I did or not to tell you the truth Q. Do you know a woman named Margaret Singer A. I met Margaret Singer Q. Who is she A. I believe she is a doctor or a teacher I believe at Berkeley Q. What was the occasion of your meeting? A. she was at a parent meeting Q. how many of these meetings did you go to? A. not very many Q. 2 or 3 A. It is a long way from my home. I cannot remember how many I went to . It is very difficult to get there because I no longer drive in heavy traffic. Q. Do you recall a conversation with Margaret Singer A. I merely met Margaret Singer and I do not believe we talked a minute or two but I've never had a lengthy conversation with Margaret Singer .I think I just met her and that was about it. WE met in the Coffee–she was pouring coffee at the same time I was having Coffee and that was the extent of it. Q. Do you know a woman named Henrietta Crampton A. yes Q. Who is she A. She is a friend Q. a friend of yours A. yes q .Is she hostile to Scientology A, Her child is in the Love Family or something I cannot remember which. Love Family I think Q. She is another parent A.. That is right Q. Did you become friends because of your common situation or did you know each other before A.. I never knew her before Q. Where did you meet her A.. here in Los Angeles . Q, She lives in Los Angeles? A I think she lives in Redondo I I recall in Redondo Beach Q. Do you know if Henrietta Crampton is a communication with Paulette Cooper A. I do not know Q. Is Henrietta Crampton in the anti-religous cult movement A. I do not like that word Anti religious Q. I do not like the way it came out much either A. It was nasty Q. What is the nature of contact with Henrietta Crampton A. I would say we communicate . We understand each other , I imagine I mean we have the same, Can I call it " heartache". Q. Is she more active now in distributing literature and writing letters and making telephone calls than you are or do you have any way of knowing A. I do not know Q. You do not communicate with her except in personal times about your own heartache A. That is mostly the extent of it Mr. Garfield : thank you , I have nothing further Mr. Gotto I have no questions Mr. Donvan I have no questions Mr. Garfield I would stipulate that the deposition signed under penalty of perjury and the original may be released to Mr. Donovan. Is that satisfactory Mr. Gotto So Stipulated Mr. Donovan So stipulated