marked as Exhibit No. 47, as of this date.)

MR. FLYNN:

The next witness is an individual named Robert Dardano, and he'll give a statement. And after that, we'll read portions of the Affidavit of Tonja Burden.

MR. LeCHER:

Would you have Mr. Dardano sworn in, please.

Madame Clerk, swear the witness.

ROBERT DARDANO, a witness herein, having first been duly sworn by a Clerk for the City of Clearwater, was examined and testified as follows:

MR. LeCHER:

Mr. Dardano, I want to ask you the same five questions: Are you appearing here today and testifying under oath voluntarily?

MR. DARDANO:

Yes, I am.

MR. LeCHER:

Have you been paid by anyone for your testimony, other than expenses for coming to the City of Clearwater?

MR. DARDANO:

No, sir.

MR. LeCHER:

Do you have a lawsuit against the Church of Scientology?

MR. DARDANO:

No.

MR. LeCHER:

Does the Church of Scientology have a lawsuit against you?

MR. DARDANO:

No, sir.

MR. LeCHER:

Has anyone suggested to you that you should state anything but the truth or has anyone suggested that you change your testimony for any reason?

MR. DARDANO:

No.

MR. LeCHER:

Thank you.

Proceed however you want. Do you have a statement to read or do you have an outline or whatever?

MR. DARDANO:

I'm working from an outline.

I became a member of the Church of Scientology in '71, and was on staff as a staff member from '71 to '73. In '73, I left the Church because of family problems. And my mother had attacked the Church through the Better Business Bureau, so I was immediately taken off staff because of her legal threat to the Church.

During the summer of '73, I was working in Worcester, and I was shortly — in August of '73, I was contacted by a member of the Guardian's Office and asked to do covert data collections.

MR. SHOEMAKER:

Did you say "overt" or "covert"?

MR. DARDANO:

Covert.

MR. SHOEMAKER:

Covert.

MR. DARDANO:

This was happening in Boston, Massachusetts.

The group that I joined was seven people. We were all assigned — we all got our orders from the Boston Church, directly from the Guardian's Office. And we had people in the Boston Public Library that would collect information and data on individuals that were attacking the Church. That would be the overt data collections.

The covert data collections consisted of doing surveillances on people, such as newspaper reporters, other individuals that were attacking the Church at the time.

The covert data collections had made placements in various government offices, such as the Attorney General's Office, the Better Business Bureau, the Consumer's Council, and the Law Assistance — LEAA, Law Assistance — Law Enforcement Assistance Association.

During the year that we operated together, we were able to pull off quite a few operations on different people; some of them were successful. One of the more successful operations was stealing Paulette Cooper's medical files from her doctor's office in Belmont, Massachusetts.

Along with this, we also were to — were able to interrupt the correspondence between the Boston Globe and the attorney's office. The law office was Bingham, Dana & Gould, and we placed an agent in the building to clean the law offices at night, and he was able to review the files daily to see what correspondence was going on between the Globe and the Scientologists. That was 1974.

We also worked with letter-writing campaigns to smear people, individuals, who worked on Project Freak-Out, Operation Snow White. This was some of the programs given to — the programs that were national and worldwide programs developed by the Guardian's Office for the protection of Scientology.

Paulette Cooper's file was — we were able to find out what doctors she was seeing and locate the office that the files were in, and it was just a matter of walking in, taking it, xeroxing it, and bringing it back in, putting it back in the file. There was a mistake made that we kept the file out of the office for a longer length of time than we should have. Other than that, the file probably would have never been missed.

The group of people that I was with — there were seven people, and we rented a house about thirty miles north of Boston. We operated like a — like the Church would operate under the Church policies. Our deadline — our week ended on Thursday at two o'clock, as the Church did. We all kept statistics on particular products that we were supposed to produce. Our products were connections and instances.

For instance, if there was someone who was attacking the Church, we would try and find as many connections they had to other individuals, other groups, what they did on a daily basis. And those would all be counted as statistics and sent, first, into Boston and then up lines, eventually, to Flag.

The file was — Paulette Cooper's file was stolen on a Saturday afternoon. It was just a matter of driving down to the office. A couple of people got out of the van, went into the office. They were able to jump over a small partition wall and get into the office and look her name up in the file, pull the file, and just walk out of the building. There was no great security.

Most of the files and most of — in fact, just being in these offices, it's very easy to pull anything you want out of this office. It's security — people don't realize what Scientologists are after or why they may be after it in the first place. And it's very easy just to walk into most places and get any information that they want because it's not considered valuable and it's not very well protected.

David Grace was the agent who was placed at the cleaning company at the lawyers' — the Boston lawyers' office. He was in the lawyers' office at Bingham, Dana & Gould, and he was able to go in the file, take the information that he wanted, use their Xerox machine, xerox it, bring it back in the morning, and we could send it up lines to the GO in the Boston Church.

Any money that we needed for things that needed to be done, such as xeroxing or traveling expenses, the Church would give us to use what we had to.

The people that were in the Better Business Bureau would interrupt complaints coming from public people about the Church. And, basically, it was turned right around and sent right back to the public with no satisfaction, although the public felt they were being satisfied because they had reached someone in the Better Business Bureau.

The Attorney General's Office agent was — he had uncovered a couple of attacks coming from public people. And his cover was finally blown by the fact that he requested information on the Church from the Justice Department. This — Mr. Mayer mentioned Bill Foster's name before. Bill Foster was the head of this — he was the captain of this particular group, and he had been there since 1971. He was operating the overt data/covert data collections from '71 to '76 in Boston. And it wasn't until George Bristol's cover was blown at the Attorney General's Office that the line was disbanded and the group of seven people were sent to different parts of the country.

Nancy and Bill Foster went to New York; George Bristol went to Canada; two other people went out to California; and a couple of others, David Grace and his wife, Nancy Grace, went to the Sea Org. in LA. So, the Church has just an ability to move people around very quickly to get them out of sight.

We used code names and our reports were written in code names, normally. It could have been at the point where we were or where we were coming from.

The letters that were written in the smear campaigns — the typewriters were stolen and usually used just for a short time and then the typewriters were destroyed and new typewriters were gotten. Everything was done with plastic gloves so that there wouldn't be any fingerprints or things like this.

My position on the line was — initially, it was — I was the head of the overt data collections and I handled, roughly, five people in the Boston Public Library. We'd use all different sources to gather information on public officials, senators, whoever the Church — we would get a list from the GO's office of who we had to investigate that particular week, and we would go ahead and get as much information as we could on those people.

Shortly after that, the rest of the people in overt data collections understood the — what they were doing, so I was able to train someone and they took over that particular post. And I moved into covert data collections.

From the covert data collections — this is where I would handle people like George Bristol, who was in the Attorney General's Office, Nancy Foster, Consumer Affairs, Nancy Grace was in the Better Business Bureau. And each week then people would file reports of what went on on a daily basis in each one of these offices.

The — it was very difficult for a public person in Boston to make a complaint about the Church and have it go anywhere. We had all the bases covered. They couldn't — if they called the Attorney General's Office, George Bristol was sitting there and he's handling all Scientology cases. So, it was just "Fine, ma'am, we'll take care of it," and it wouldn't go anywhere from there.

Anything that was even a hint or a mention of Scientology was brought out, as much information as — we would immediately look into that individual that brought up the issue of Scientology and he was completely investigated to find out what he did. We put people under surveillance to find out where they were going and what they would do.

MR. FLYNN:

Oh, incidentally, I think I said this before, but it's rather an amusing anecdote from my point of view: My old law firm was Bingham, Dana & Gould — and it was burglarized, and my present law firm has just surrendered some eight thousand documents to the same organization.

MR. DARDANO:

The one thing about scientologists is that they are there because they think they are buying themselves spiritual freedom, and they are totally committed to the organization and to their goals. It takes an individual a long time after he's left the Church to be able to have the freedom to believe that he's going to be okay without Scientology.

You've got to — as a Commission, you are going to have a tough job in trying to decide what to do with this group.

That's about all I have to say.

MR. LeCHER:

In the interest of time, I'll only ask you one question: Do you feel that there is now in the City of Clearwater, or has there been, a smear or cover up, either of any civil officials — city officials or by any city officials with respect to Scientology?

MR. DARDANO:

A cover up by a city official or —

MR. LeCHER:

By city or county or state or any local officials, if you know of any?

MR. DARDANO:

No, I don't know of anything like that. But Scientology operates standardly with every org. and every mission, and it's certainly going on; it's just that it hasn't been uncovered.

MR. LeCHER:

Well —

MR. DARDANO:

There are probably undercover agents here now from the Church.

MR. LeCHER:

Since you had your — you had every act — your act covered in Boston, I wonder if the act is covered here, too.

MR. DARDANO:

There's a good possibility, but it's very hard to tell.

MR. LeCHER:

I will — again, because of time, I will yield to the next Commissioner. Is that Mr. Hatchett?

MR. HATCHETT:

I haven't any questions.

MR. LeCHER:

Do you have any questions, Mr. Shoemaker?

MR. SHOEMAKER:

Mr. Dardano, how did you leave the — or what made you decide to come to Florida to testify?

MR. DARDANO:

Well, I had been — I have been in contact with Mr. Flynn for almost two years now, so it was just a matter of knowing that.

MR. SHOEMAKER:

Why did he come to see — why did you go to see Mr. Flynn?

MR. DARDANO:

I wanted some way out of the — that I was really trapped and not being able to live my life freely the way that I had been before I got into Scientology. You're brainwashed. A Scientologist is a person that's been brainwashed.

It was very difficult to get back into the mainstream of life, and there's usually a lot of things that bother the individual just as far as our own personal life is concerned.

MR. SHOEMAKER:

Did they attempt to use the information that you were involved in covert activities against you to try to keep you in the organization or to keep you quiet or —

MR. DARDANO:

No.

They — I had to sign — as all Scientologists, if you're causing any sort of flap, you have to sign documents saying that you will not attack the Church in any way.

MR. SHOEMAKER:

Have they interfered since you've left with your life in any way that you're aware of?

MR. DARDANO:

No, not that I'm aware of.

MR. SHOEMAKER:

To be clear on this: What, in fact, you're stating is that you have firsthand knowledge of criminal activities occurring in the City of Boston against various people; is that correct?

MR. DARDANO:

Yes, sir, that's correct.

MR. SHOEMAKER:

And you — so, you actually saw it; it's not something that somebody told you about —

MR. DARDANO:

We did it —

MR. SHOEMAKER:

— on that basis.

MR. DARDANO:

— as a group. We were a conspiracy formed by the Church against the Boston Globe, the Attorney General's Office, the Better Business Bureau. We considered every — anyone and everyone an enemy of the Church. And Paulette Cooper.

Paulette Cooper was a major — a major task to work on for a long time. Beside — just — not just the fact that we had stolen her medical files, but a lot of other types of operations were done against Mrs. Cooper.

MR. SHOEMAKER:

You had indicated that the captain of the group was Foster, Bill Foster —

MR. DARDANO:

Yes.

MR. SHOEMAKER:

— who had been alluded to earlier.

Who was over him?

MR. DARDANO:

He was run by Deac Finn, who was head of B 1, Bureau 1.

MR. SHOEMAKER:

Bureau 1.

And could you explain what you know of Bureau 1 to be?

MR. DARDANO:

Right.

Bureau 1 is — B 1, it's the collections — the Information Bureau of the Guardian's Office.

MR. SHOEMAKER:

And who was over that person?

MR. DARDANO:

That would be the AG in Boston, the Assistant Guardian.

MR. SHOEMAKER:

And do you know where they went after they left Boston?

MR. DARDANO:

The individuals?

MR. SHOEMAKER:

Yes.

MR. DARDANO:

You're going to love this. Deac is down here working in Florida. I don't — he's not in Clearwater, but he's within one of the missions close by.

MR. SHOEMAKER:

He's here in Florida —

MR. DARDANO:

Yes.

MR. SHOEMAKER:

— someplace?

MR. DARDANO:

I believe he's working in the group called WISE.

MR. BERFIELD:

What was that name, again?

MR. SHOEMAKER:

Called what?

MR. DARDANO:

WISE.

MR. SHOEMAKER:

Wise, W-i-s-e?

MR. CALDERBANK:

That's a business, business community of Scientologists.

MR. DARDANO:

It's the World Institute of Scientology Enterprises. It's a group that sells Scientology technology to businessmen. You get the businessmen to use Scientology data and technology in their business.

MR. SHOEMAKER:

Are you aware, Mr. Dardano, at any time of confidential information from auditing files or something such as that being used against individuals?

MR. DARDANO:

Yes, I'm — well, it's just the — it's one of the major lies of Scientology. The auditing files — they're passed around the org. all the time. It doesn't make any difference who you are. Just about anyone can get information out of the auditing file.

MR. SHOEMAKER:

Did you personally ever —

MR. DARDANO:

And I —

MR. SHOEMAKER:

— see anyone else go in the file?

MR. DARDANO:

No. I never had anything to do with it.

MR. SHOEMAKER:

Thank you.

MR. LeCHER:

Okay.

Mr. Calderbank, again, I'd like —

MR. CALDERBANK:

Three brief questions.

Where did you learn your burglary skills?

MR. DARDANO:

Mostly from books and practicing.

MR. CALDERBANK:

Where did you get the practice and the books?

MR. DARDANO:

Just around the house that we were living in, the lock picking; we'd get practice lock picking.

MR. CALDERBANK:

Scientology taught you and supplied you with the information you needed to help train you?

MR. DARDANO:

Yes, sir.

MR. CALDERBANK:

Is that a policy of the Church to do that or —

MR. DARDANO:

Yes, they're very specific: intelligence packets that are — intelligence are trained specifically on how to do breaking and entering, how to lock pick.

MR. CALDERBANK:

And this is supported by the policy of Scientology?

MR. DARDANO:

Yes.

Nothing we did — we had quite a few — we would go in and look for information under the guise of students doing research or — basically, lying to get information, using cover stories to get information about people or places.

MR. CALDERBANK:

Is this a policy that's done worldwide in the Scientology organization or utilized worldwide?

MR. DARDANO:

Yes. It's done under the training of Bureau 1 in the G — in the Guardian's Office.

MR. CALDERBANK:

Any information or communication, while you were in Boston engaged in these activities, come from or go to Clearwater?

MR DARDANO:

Yes, it did because all — Clearwater is Flag, Flag Land Base.

MR. CALDERBANK:

So, in —

MR. DARDANO:

Virtually all information across the planet comes to Clearwater.

MR. CALDERBANK:

So, we control these type of criminal activities all over the world from Flag here, Clearwater?

MR. DARDANO:

Yes, sir.

MR. CALDERBANK:

Okay.

The person that ran the criminal practices — what's his name, Deac —

MR. DARDANO:

Deac Finn.

MR. CALDERBANK:

Deac Finn is now, to the best of your knowledge, here in Clearwater in a local mission running the WISE —

MR. DARDANO:

WISE — just — I'm not sure what city it is; it's not Clearwater.

MR. CALDERBANK:

But it's in Florida somewhere?

MR. DARDANO:

In Florida, somewhere within an hour to an hour and-a-half from Clearwater.

MR. CALDERBANK:

Working with W-I-S-E —

MR. DARDANO:

Yes.

MR. CALDERBANK:

— which is selling Scientology technology to private industries, private businesses?

MR. DARDANO:

Yes.

MR. CALDERBANK:

That's all.

MR. LeCHER:

All right.

Mr. Berfield.

MR. BERFIELD:

Just a couple of quick ones: You said you had a lawsuit against the Scientologists?

MR. DARDANO:

No, I don't —

MR. BERFIELD:

Do they have one against you?

MR. DARDANO:

No, sir.

MR. BERFIELD:

Can you tell us just very briefly what made you come down here today?

MR. DARDANO:

Just for the fact that I know it's important. Scientology has been putting the screws to a lot of people for a long time. And I spent six years and fifteen thousand dollars.

The kids — the people that are being indoctrinated into the Church are — they're being duped into it. Most of them are just swallowed up by the Church. They're not allowed to think for themselves. You go into the Church and you're immediately fed with L. Ron Hubbard's data. You're not allowed to use any of your own information and experiences to evaluate the present situation. You're completely isolated from society.

You think you're doing the best thing in the world. You think you're going to help tie world. And you become so dedicated and ingrained in the doctrine of L. Ron Hubbard.

MR. BERFIELD:

How would you describe the practice of Scientology?

MR. DARDANO:

How would I describe it?

MR. BERFIELD:

Yes.

Are they honest, deceptive —

MR. DARDANO:

They're just — money making; that's all they want to do, just make a buck.

MR LeCHER:

Okay.

Mrs. Garvey, any questions?

MRS. GARVEY:

Yes.

Just — sir, why did you leave? What finally was the break point?

MR. DARDANO:

I was — after the line was broken up because of the out security and George Bristol's cover being blown in the attorney General's Office, I went down to FOLO, Flag liaison office in New York. And I was trained there for — to become a missioner. But Deac Finn and I had several personality conflicts. He had called me back to Boston and I was security checked for about six hours.

And after that — security checking is — it can get pretty brutal at times, and I had just had enough and decided to leave.

MRS. GARVEY:

Why — what was your justification for your burglarizing and stealing of files?

MR. DARDANO:

I thought Scientology was going to save the planet and free the world and we were right and everyone else was wrong.

MRS. GARVEY:

Did you see — did you receive detailed reports that you had to follow on your —

MR. DARDANO:

No. Our reports were all typed and handwritten. We didn't receive any written information from the higher sources. It was all given verbally or it was given in written form, but all of the written form was destroyed immediately after it was received.

MRS. GARVEY:

That's it.

MR. LeCHER:

One just quick question for the record: You mentioned someone recruited you into the dirty tricks movement from the Guardian's Office.

Would you like to give me that name of that person who recruited you?

MR. DARDANO:

Yes. It was Gary Brown.

MR. LeCHER:

Gary?

MR. DARDANO:

Gary —

MR. LeCHER:

Gary Brown.

MR. DARDANO:

— Brown.

MR. LeCHER:

Okay.

Again, because of the time constraints we're under, we're going — that's all the questions we have.

MR. CALDERBANK:

I've got just one question.

So, your beliefs in Scientology, L. Ron Hubbard, and the policies that come from that organization induced you into criminal activities in Boston?

MR. DARDANO:

Yes, sir.

Mr. Flynn has asked me to clarify: At the time that I was involved in these activities, Flag was not located at Clearwater; Flag was still on board the Apollo, because these activities ended in — well, as far as I was concerned, they ended in early '76.

MR. LeCHER:

Okay. Thank you very much.

MR. FLYNN:

I'd like to see if we can clarify that date.

What's your best memory as to when — whatever your best memory is —

MR. DARDANO:

I believe it in 1976.

MR. LeCHER:

Thank you.

Do you have a witness, Mr. Flynn?

MR. FLYNN:

I do. The next witness is going to be Paulette Cooper.

I'd like to put a couple of documents quickly on the overhead projector, if I could.

MR. LeCHER:

How many documents do you have, Mr. Flynn?

MR. FLYNN:

We'll put —

MR. LeCHER:

Approximately?

MR. FLYNN:

We'll put about five or six on.

Kevin, why don't we start with Project Owl.

This — in interest of time, we're going to really narrow this down. We're going to put the entire exhibit into evidence. Some of the exhibits involve the Ops Checksheets on clay demoing things, like Mr. Mayer was talking about: how they do it, the documents they have to read. Some of the documents involve how to commit a burglary, the various steps; discussions and lessons on lock-picking devices, how to use them, with descriptions.

Some of the documents involve things like making an evaluation of what has been a successful and an unsuccessful action. And they include things like: burglarizing, larceny, smearing, covert third-partying, launching anti-press campaigns, tracing individual reporters, various types of harassment, and things like that.

It's a — they're multi-page documents, and I'm not sure we have the time to go into them. The Commission will have them all at their disposal.

For instance, one of the documents is lists of agencies across the country that the organization is going to burglarize to steal documents from, and it contains the name of just about every national agency that you could probably think of.

The first exhibit on the projector is an operation called Project Owl. And in that operations, I would refer you to the second page — well, you see under — there's an example up there, a major target. To handle the — to handle the attack being generated on Wise refund cycle, both with Wise and his attorney and at the Suffolk County DA's Office, and then it goes through various primary targets. And there's names: "Deac, Gary B., Kathy B.," all of which the witness could give direct testimony on, if we took the time.

If you go over to the second page, you'll see a heading under "Vital Targets," and then going down to "Operating Targets," you see: "ODC and time tracks done on the following" — that's overt data collections — "Stanley Cath, Attorney John Lynch, John Wise, John Wise's father, Reverend Steves," and then there's some others penciled in there, including "Thomas Dwyer," who happens to be a colleague of mine from law school, who was then in the Assistant District Attorney's Office.

Then, number two, you will see: "Obtain Cath's files on" — then in parentheses — "(by FSM" — which is field staff member — "or other means as appropriate)" — of which there's been testimony — "a, John Wise, b, Scientology." And Dr. Cath is a medical doctor from Boston or Belmont, Massachusetts upon which Miss Cooper will testify because it was her doctor. And then number c is: "others as needed" — parentheses — "(including Paulette Cooper material not previously obtained)," which would suggest that they had already gone in before then.

"Cliff Stanton files, Cath personal files, material on deprogramming, Mrs. Elaine Lieberman, Van Roeschmann, International Foundation for Individual Freedom" — IFIT — IFIF — "Return to Personal Choice, Dr. Taylor and Ted Backer. Do CDC" — that's covert data collections — "on Cath for data on his book, fish for leads that Cath knows Wise and/or Stanton, use Cath to establish lines to other areas for CDC," et cetera.

What the Commission needs to be aware of in the context of all of this information is that this is just one project of which we're getting a little more specific. And that entire project will go in as the next exhibit.

(A copy of Project Owl was marked as Exhibit No. 48, as of this date.)

MR. FLYNN:

Operation Freakout is a multi-page exhibit, which the Commission can read with regard to very specific instructions as to who was to do what in order to carry out this operation, which — the reading of which is rather remarkable.

The first item of attention is — under "Major Target," right at the top, "To get PC incarcerated in a mental institution or jail, or at least to hit her so hard that she drops her attack."

I would suggest to you that the Project Owl was a part of Freakout when they attempted to obtain Miss Cooper's psychiatric files from Dr. Cath in order to put her in a mental institution or in jail, of which she will testify.

And I would also — I would also direct the Commission's attention — we'll have to go back to Owl and put the last page of Owl on the transparency. And as you can see, there's all kinds — there's very specific instructions on what they do, when they do it, et cetera, et cetera.

But going down to the bottom, you'll see a name at the bottom, "Mike Cooper." Mike Cooper is Mitchell Hermann, who is one of the individuals who has been convicted and is now in jail, and he was the Guardian of the Southeast U.S. Sect, during this period of time, which was Clearwater. And this particular project originated in your city.

MR. CALDERBANK:

Mike, these people seem to have an affinity for infiltrating district attorneys' offices. Would you give any information or any documentation — I've seen some — as to the information or infiltration that was either gained or the office infiltrated for our State Attorney General, Mr. Russell, or for the local office? Was it ever targeted, or do you have documentation to that effect, Clearwater documents?

MR. FLYNN:

Yes. There — as I said, we've got a whole separate package just on Clearwater, which is two or three inches thick, which is, I would suggest to you, just a mere sampling of some of the documents. All of the Red Box data was never received. Another seventy or eighty thousand documents are up in the Clerk's Office in Washington, D.C. under seal. These documents are not under seal. And the documents that have been under seal have never been viewed by my office — and I don't know who else they've been viewed by — but I would suggest that there may be other documents pertaining to Clearwater.

MR. CALDERBANK:

I'd just like the people to know that our DA offices, also, are a target — or at least in a document — a projected target for infiltration.

MR. FLYNN:

Oh, yes. The exhibits that are in the Clearwater packet start right at the beginning with Operation Normandy to take over the City of Clearwater, outlining all of the offices that are going to be infiltrated and documents are going to be stolen from, people are going to be planted in. There's probably thirty or thirty-five such offices. We'll reach that at another point in time. But they're all laid out very clearly in Operation Normandy. And you might remember that Normandy was a beachhead for — in World War II, and Clearwater was a beachhead for Mr. Hubbard.

Okay. We'll now go forward with Paulette Cooper. I will have these other documents marked on how to commit burglaries, evaluations of which types of covert operations are successful and unsuccessful, as well as the drills that one goes through, such as Mr. Mayer, Mr. Dardano, Mrs. Peterson, Mr. Walters, and others have described as to how you're trained to do very specific things.

(A copy of Operation Freakout was marked as Exhibit No. 49, as of this date;

Documents on how to commit burglaries, evaluations of covert operations, and drills were marked as Exhibit Nos. 50, 51, and 52, as of this date.)

MR. LeCHER:

Would you like to call your next witness, now?

MR. FLYNN:

Miss Cooper, please.

MR. LeCHER:

Miss Cooper, will you be sworn in, please?