Grand Jury Original - Criminal Case No. 78-00401 -
[the following was typed in by Arnie Lerma from a xerox copy, the top of each
page typed in says in 9 point full caps type REPRODUCED AT THE NATIONAL
ARCHIVES]
REPRODUCED AT THE NATIONAL ARCHIVES
FILED IN OPEN COURT
UNTED STATES DISTRICT COURT
UNITED STATES OF AMERICA
v.
MARY SUE HUBBARD
Criminal Case No. 78-00401
Grand Jury Original
Violations:
18 U.S.C. §§ 2, 371,
641, 1503, 1623
2511 (1) (a) (Conspiracy,
Theft of Government
Property, Aiding and
Abetting, Obstruction of Justice,
False Declaration Before
A Grand Jury,
Interception of Oral
Communication)
22 D.C. Code §§ 105,
1801(b) (Burglary,
Aiding and Abeting)
The Grand Jury charges:
INTRODUCTION
1. At all times material herein, the Church of Scientology (Scientology)
had offices in various cities in the United States and elsewhere.
Within Scientology, a department known as the “Guardian’s Office” had
responsibility to promote the interests of Scientology by covertly identi-
fying, locating, and obtaining all Scientology-related information in
the possession of various individuals, government agencies and private
organizations.
2. At all times material herein,. The Guardian’s Office had world-
wide headquarters (Guardian’s Office WW) at Saint Hill Manor, East Grin-
stead, Sussex, England. It had United States headquarters (Guardian’s
Office US) in Los Angeles, California. It had a local office in the
District of Columbia (Guardian’s Office DC) and other cities throughout
the United States.. Each of the Guardian Offices was composed of
five bureaus including the Information Bureau which was assigned the
responsibility for the conduct of covert operations including the collect-
-2-
tion of data and documents of interest to Scientology.
3. At all times material herein, L. RON HUBBARD, who held the
title “Commodore”, by virtue of his role as founder and leader of
Scientology exercised overall supervision of the Guardian’s Office.
4. At all times material herein, 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, under her husband
L.RON HUBBARD, which included supervision of the Guardian’s Office.
5. At all times material herein, JANE KEMBER had the title of
“Guardian World-Wide” (GWW) and headed the daily operation of all Guar-
dian’s Offices, reporting directly to L RON HUBBARD and MARY SUE HUBBARD.
6. At all times material herein, MORRIS BUDLONG, a/k/a MO BUDLONG
(hereinafter MO BUDLONG), held the title “Deputy Guardian for Information
World-Wide” (DG I WW), supervised all Information Bureaus around the
World and reported directly to JANE KEMBER.
7. During the approximate periods listed below in the column en-
titled “Approximate Periods the individuals listed below in the column
entitled “Individuals” held the positions, in the Guardian’s Office US,
listed below in the column “Positions”:
INDIVIDUALS APPROXIMATE PERIODS POSITIONS
HENNING HELDT Nov. 21, 1973 – June 20, 1977 Deputy Guardian US
(DG US)
DUKE SNIDER March 1974 – Dec. 1, 1974 Deputy Guardian –
Information US
(DG I US)
Dec. 1, 1974 – June 20, 1977 Deputy-Deputy
Guardian US
(DDG US)
RICHARD WEIGAND Dec. 1, 1974 – May 15, 1977 Deputy Guardian –
Information US
(DG I US)
-3-
INDIVIDUALS APPROXIMATE PERIODS POSITIONS
GREGORY WILLARDSON Sometime in 1974 – Jan. 1, 1976 Information Bureau
Branch I Director US
Jan. 1, 1976 – June 16, 1977 Deputy Deputy
Guardian Information US
(DDG I US)
June 16, 1977 – June 20, 1977 Deputy Guardian
Information US
(DG I US)
MITCHELL HERMANN Jan. 1, 1974 – March 1, 1975 Branch I Director
a/k/a MIKE COOPER Guardian’s Office US
Jan. 1, 1976 – March 1, 1977 Southeast US Secretary
Guardian’s Office US
(SEUS SEC.)
CINDY RAYMOND June 1, 1974 – Jan 1 1976 Information Bureau
Collections Officer US
Jan 1, 1976 – Sept 1, 1976 Information Bureau
Branch I Director US
Sept 1, 1976 – June 20, 1977 Information Bureau
National Secretary US
8. From on or about January 1, 1974 until on or about June 11, 1976,
MICHAEL J. MEISNER, also known as John M. Foster, Jeff Murphy, and “Herbert,”
held the title “Assistant Guardian for Information – DC (AG I DC). As
such, he supervised the Information Bureau in the District of Columbia, and
reported to the Southeast US Secretary and the Deputy Guardian for Infor-
mation US. From on or about July 1, 1976 until on or about August 30,
1976, he held the title “National Secretary – US “ in Los Angeles,
California. As such he supervised the operation and formulation of Information
Bureau programs of national scope.
9. At all times material herein, GERALD BENNET WOLFE, also known
as “Silver” and “Kelly”, was an agent of Scientology. As such, from on or about
November 18, 1974 until on or about June 30, 1976, he was a covert
operative for the Guardian’s Office employed as a clerk at the Internal
Revenue Service of the United States Department of the Treasury (herein-
after IRS) in the District of Columbia.
10. At all times material herein, SHARON THOMAS, also known as
“Judy,” was an agent of Scientology. As such, from on or about February
19, 1976 until on or about November 5, 1976, she was a covert operative
for the Guardian’s Office employed as a secretary at the United States
Department of Justice in the District of Columbia.
COUNT ONE
THE CONSPIRACY, ITS OBJECT AND MEANS
1. Beginning on or about November 21, 1973, and continuing until
on or about May 27, 1977, within the District of Columbia and elsewhere,
the defendants MARY SUE HUBBARD, JANE KEMBER, MO BUDLONG,
HENNING HELDT, DUKE SNIDER, RICHARD WEIGAND, GREGORY
WILLARDSON, MITCHELL HERMANN, a/k/a MIKE COOPER, CINDY
RAYMOND and SHARON THOMAS, together with unindicted
co-conspirators Gerald Bennet Wolfe and Michael J. Meisner, and other
unindicted coonspirators both known and unknown to the Grand Jury,
willfully and knowingly did conspire, confederate, combine, and agree
together and with each other, to commit offenses against the
United States of America, that is, by various illegal and unlawful means
which are known to the Grand Jury that were used or attempted to be used
by the defendants and the unindicted co-conspirators were as follows:
a. To willfully and knowling steal, purloin and convert
to their own use records and things of value of the United
States and departments and agencies thereof, that is, documents
and photocopies thereof which were the property of the IRS,
the United States Department of Justice, and the Office of the
United States Attorney for the District of Columbia, in violation
of Title 18, United States Code, Section 641;
b. To willfully intercept and procure other personas to
intercept oral communications made during a meeting of agents
and employees of the IRS held at IRS headquarters
in the District of Columbia, in violation of Title 18, United
States Code, Section 2511(1) (a)
c. To falsely make and forge passes and permits
issued by and under the authority of the United States, that
is, false indentification cards bearing the seal of the IRS,
for the purpose, among others, of gaining entry to various
government buildings, in violation of Title 18, United States
Code, Section 499;
d. To enter rooms of various employees of the IRS, the
United States Department of Justice, and the Office of the
United States Attorney for the District of Columbia, with
intent to steal documents contained therein, which were the
property of the United States, in the care, custody and
control of said agencies and their employees, in violation of
Title 22, District of Columbia Code, Section 1801(b);
e. To recruit agents of Scientology to infiltrate various
agencies and departments of the United States.
f. To place these agents in various positions within
these agencies;
g. To use bogus credentials to gain access to various
agencies and departments;
h. To utilize electronic surveillance devices;
i. To gain access to areas within these agencies which
contained documents and information of value to Scientology.
OVERT ACTS
2. To effect the objects and means of this conspiracy, the
defendants, together with the unindicted co-conspirators, committed
various overt acts within the District of Columbia and elsewhere,
including but not limited to the following:
(1) On or about November 21, 1973, JANE KEMBER issued
a directive to HENING HELDT ordering him and his staff to
obtain all INTERPOL (the international police organization)
documents relating to Scientology and connecting its founder,
L Ron Hubbard, to criminal activity.
(2) On or about July 1, 1974, DUKE SNIDER directed
Michael J. Meisner to implement JANE KEMBER’s directive
described in the preceding subparagraph by obtaining all
INTERPOL documents relating to Scientology from the INTERPOL
office then locating in the United States Department of the Treasury.
(3) On or about August 15, 1974, CINDY RAYMOND informed
Michael J. Meisner that he was to assist her in recruiting a
loyal Scientology agent for placement as an employee at the
IRS in the District of Columbia.
(4) On or about September 15, 1974, CINDY RAYMOND notified
Michael J. Meisner that she had selected Gerald Bennet Wolfe to be
the Scientology agent at the IRS in the District of Columbia and that
Meisner was to help him obtain a position there as soon as possible.
(5) On or about October 21, 1974, JANE KEMBER issued Guardian
Program Order 1361 addressed to HENNIG HELDT, DUKE SNIDER
and RICHARD WEIGAND, directing, among other things, the
infiltration of the District of Columbia offices of the IRS and of the
Tax Division of the United States Department of Justice for the purpose
of obtaining all files on Scientology, its founder L. Ron Hubbard, and
the internal memoranda of attorneys representing the government in
Scientology initiated lawsuits.
(6) On or about October 31, 1974, a Scientology agent transported
an electronic listening device from Los Angeles, California, to the
District of the Columbia.
(7) On or about November 1, 1974, within the District of Columbia
MITCHELL HERMANN, a/k/a MIKE COOPER, and two other
Scientology agents, placed an electronic listening device in an IRS
conference room and recorded an IRS meeting concerning
Scientology’s application for tax exempt status and related matters.
(8) Between on or about November 10, 1074, and on or about
November 14, 1974, MO BUDLONG, HENNING HELDT, DUKE
SNIDER and Michael J. Meisner sent numerous telexes relating
to the placement of a Scientology agent at the IRS in the
District of Columbia.
(9) On or about November 18, 1974, Gerald Bennet Wolfe began
employment as a clerk typist at the IRS in the District of Columbia.
(10) On or about December 4, 1974, DUKE SNIDER sent a
telex to MO BUDLONG, informing him that the first shipment
of stolen IRS documents had been received in Los Angeles.
(11) On or about December 5, 1974, MO BUDLONG sent a telex
to DUKE SNIDER acknowledging receipt of the information
regarding stolen IRS documents.
(12) On or about December 30, 1974, within the District of Columbia,
Gerald Bennet Wolfe stole documents from the office of Barbara Byrd
of the Chief Counsel’s office of the IRS.
(13) On or about December 30, 1974, within the District of
Columbia, Michael J. Meisner, having received a package of stolen
documents referred to in the preceding subparagraph from Gerald
Bennet Wolfe, forwarded said package to Los Angeles for distribution to
the defendants and unindicted co-conspirators.
(14) Between on or about May 2, 1975 and on or about May 17, 1975,
within the District of Columbia, Gerald Bennet Wolfe illegally entered on
three occasions the offices of various United States Department of Justice
Tax Division staff attorneys assigned the defense of Scientology-initiated
law suits and stole documents located therein.
(15) Between on or about May 3, 1975 and on or about May 17, 1975,
within the District of Columbia, Michael J. Meisner, having received
three packages of stolen documents referred to in the preceding
subparagraph from Gerald Bennet Wolfe, forwarded said packages
to Los Angeles for distribution to the defendants and unindicted
co-conspirators.
(16) On or about May 27, 1975, MARY SUE HUBBARD instructed
JANE KEMBER and HENNING HELDT to “use any method at our disposal
to win the battle and gain our non-profit [tax] status.”
(17) On or about June 18. 1975, HENNING HELDT wrote a letter to
MARY SUE HUBBARD and JANE KEMBER informing them that
HUBBARD’s order referred to in the preceding sub-paragraph had been relayed
to the Information Bureau with instructions to complete within two to three
months the collection of documents from the IRS and the Tax Division of the
United States Department of Justice.
(18) On or about June 4, 1975, GREGORY WILLARDSON wrote a letter to
Michael J. Meisner directing him to prepare a plan to obtain by August 30, 1975
all documents of interest to Scientology which were in the possession of the IRS
Office of International Operations, Intelligence Division, and the Special
Services
Division.
(19) On or about June 11, 1975, within the District of Columbia, Michael J.
Meisner
wrote a letter in response to the letter of GERGORY WILLARDSON described in
the preceding subparagaph and attached the requested plan.
(20) On or about June 30, 1975, GREGORY WILLARDSON wrote a letter to
Michael J. Meisner approving the plan described in
the preceding subparagaph
(21) On or about June 21, 1975, within the District of Columbia,
Gerald Bennet Wolfe stole documents from the office of Lewis Hubbard of the
Chief Counsel’s Office of the IRS.
(22) On or about June 21, 1975, within the District of Columbia, Michael J.
Meisner
having received from Gerald Bennett Wolfe a package of stolen documents
referred to in the preceding sub-paragraph, forwarded said package to Los
Angeles for
distribution to the defendants and inindicted co-conspirators.
(23) On or about June 27, 1975, JANE KEMBER and MO BUDLONG
issued Guardian Program Order 9 directing that all INTERPOL documents
relating to Scientology and its founder L Ron Hubbard be obtained through
infiltration of, or the placing of “clandestine agents” in, the INTERPOL
offices at the United States Department of the Treasury.
(24) On or about July 2, 1975, DUKE SNIDER wrote a letter to RICHARD
WEIGAND directing him to obtain by August 20, 1975, all Scientology-
related documents in possession of the IRS in the District of Columbia
and thereafter to obtain all Scientology-related documents from the possession
of the Tax Division of the United States Department of Justice.
(25) On or about July 28, 1975, within the District of Columbia,
Gerald Bennet Wolfe stole documents from the Disclosure Division
of the Chief Counsel’s Office of the IRS.
(26) On or about July 28, 1975, within the District of Columbia,
Michael J. Meisner, having received from Gerald Bennet Wolfe,
a package of stolen documents referred to in the preceding
subparagraph, forwarded said package to Los Angeles for
distribution to the defendants and unindicted co-conspirators.
(27) Between on or about Seperember 21, 1975 and on or
about Sepetember 20, 1975, within the District of Columbia,
Gerald Bennet Wolfe on two occasions stole documents
pertaining to Scientology from the Disclosure Division of the
Chief Counsel’s Office of the IRS.
(28) Between on or about September 24, 1975 and on or about
September 30, 1975, within the District of Columbia,
Michael J. Meisner, having received from Gerald Bennet Wolfe
two packages of stolen documents referred to in the preceding
subparagraph, forwarded said packages to Los Angeles for
distribution to the defendants and unindicted co-conspirators.
(29) On or about December 5, 1975, HENNING HELDT and
RICHARD WEIGAND issued on behalf of JANE KEMBER Guardian
Program Order 158 (“Early Warning System”) which was designed to
protect the “personal security” of Scientology’s founder L. Ron Hubbard.
The order called for the infiltration of government agencies which had
the power to subpeona or bring suits against Hubbard or which would
possess advance warning of such subpeonas or suits.
(30) On or about December 10, 1975, CINDY RAYMOND directed
Michael J. Meisner to implement Guardian Program Orders 9
(referred to in subparagraph 23 above) and 158 (referred to in
the preceding paragaph), as well as JANE KEMBER’s order
of November 21, 1973 to obtain all INTERPOL documents
on Scientology, by placing a Scientology agent in the
United States Department of Justice.
(31) On or about December 15, 1975, within the District of
Columbia, Michael J Meisner, having selected SHARON THOMAS
to become Scientology’s agent within the United States Department
of Justice, requested approval of his choice from RICHARD WEIGAND
(32) On or about December 20, 1975, RICHARD WEIGAND sent
a telex to Michael J. Meisner approving the selection an placement
of SHARON THOMAS as Scientology’s agent at the
United States Department of Justice.
(33) On or about January 18, 1976, within the District
of Columbia, Michael J. Meisner, Gerald Bennet Wolfe, and
a Scientology agent sent from Los Angeles, entered the office
of Lewis Hubbard of the Chief Counsel’s Office of the IRS and
stole documents located therein.
(34) On or about January 21, 1976, RICHARD WEIGAND wrote
a letter to HENNING HELDT informing him that the IRS office
of Lewis Hubbard in the District of Columbia had been
entered by Scientology agents and that numerous IRS documents
had been stolen therefrom.
(35) Between on or about February 1, 1976 and February 15, 1976,
HENNING HELDT, RICHARD WEIGAND, GREGORY WILLARDSON,
Michael J. Meisner and other Guardian’s Office officials met in various
groups on several occasions in Los Angeles, California, to discuss
the burglaries and the infiltration of United States government agencies
in the District of Columbia and the documents which has been
stolen from those agencies.
(36) On or about February 11, 1976, RICHARD WEIGAND wrote
a letter to JANE KEMBER, informing her that all
IRS documents sought pursuant to Scientology’s Guardian
Program Order 1361 had been obtained through Scientology
infiltration of the IRS.
(37) On or about February 29, 1976, SHARON THOMAS began
employment as a secretary as the United States Department
of Justice in the District of Columbia for the purpose of
obtaining documents and information of interest to Scientology.
(38) On or about March 4, 1976, within the District of Columbia,
Gerald Bennet Wolfe stole documents from the office of
Joseph Tedesco of the Exempt Organization Division of the IRS.
(39) On or about March 4, 1976, within the District of Columbia
Michael J. Meisner, having received from Gerald Bennet Wolfe
a package of stolen documents referred to in the preceding
subparagraph, forwarded said package to Los Angeles for
distribution to the defendants and unindicted co-conspirators.
(40) On or about March 10, 1976, within the District of Columbia,
Gerald Bennet Wolfe stole documents from the office of
Jeanne Gessay, of the Exempt Organization Division of
the IRS.
(41) On or about March 10, 1976, within the District of Columbia,
Michael J. Meisner, having received from Gerald Bennet Wolfe
a package of stolen documents referred to in the preceding
subparagraph, forwarded said package to Los Angeles for
distribution to the defendants and unindicted co-conspirators.
(42) On or about March 15, 1976, within the District of Columbia,
Michael J. Meisner, and Gerald Bennet Wolfe entered the
indentification equipment room at the IRS and falsely made
for themselves forged official IRS credentials bearing
false names.
(43) On or about March 22, 1976, within the District of Columbia,
Gerald Bennet Wolfe stole documents from the office of the
Assistant Commissioner Alvin Lurie of the IRS.
(44) On or about March 22, 1976 within the District of Columbia,
Michael J. Meisner, having received from Gerald Bennet Wolfe
a package of stolen documents referred to in the preceding
subparagraph, forwarded said package to Los Angeles for
distribution to the defendants and unindicted co-conspirators.
(45) Between on or about March 22, 1976 and April 26, 1976
within the District of Columbia, SHARON THOMAS on a
number of occassions stole documents from the office of
United States Department of Justice Attorney Paul Figley.
(46) Between on or about March 22, 1976 and April 26, 1976,
within the District of Columbia, Michael J. Meisner,
having received from SHARON THOMAS,
packages of stolen documents referred to in the preceding
subparagraph, forwarded said package to Los Angeles for
distribution to the defendants and unindicted co-conspirators.
(47) On or about March 27, 1976, MARY SUE HUBBARD,
JANE KEMBER, MO BUDLONG, HENNING HELDT,
RICHARD WEIGNAD, GREGORY WILLARDSON approved
Guradian Program Order 302 which was written by CINDY
RAYMOND. The order directed the infiltration
of all government agencies for the purpose of illegally
obtaining those documents related to Scientology which had been
withheld by these agencies pursuant to provisions of the
Freedom of Information Act.
(48) On or about April 9, 1976, within the District of
Columbia, Michael J. Meisner and Gerald Bennet Wolfe
entered the office of Associate Attorney General Togo G. West, Jr
at the United States Department of Justice, stole documents located
therein, and forwarded them to Los Angeles for distribution
to the defendants and unindicted co-conspirators.
(49) Between on or about April 14, 1976 and on or about
May 17, 1976, within the District of Columbia,
Michael J. Meisner and Gerald Bennet Wolfe on at least two
occassions entered the Offices of International Operations of
the IRS, stole documents contained therein, and forwarded
them to Los Angeles for distribution
to the defendants and unindicted co-conspirators.
(50) On or about April 27, 1976, RICHARD WEIGAND wrote
an order to MITCHELL HERMANN, a/k/a MIKE COOPER,
directing him to impliment burglaries of the office of
Assistant united States Attorney Nathan Dodell in the
District of Columbia and obtain any documents containing
any prediction on any potential subpeona or deposition
of L Ron Hubbard.
(51) Between on or about April 30, 1976 and May 17, 1976,
within the District of Columbia, SHARON THOMAS and
Michael J. Meisner, on two occassions, burglarized the office
of Special Assistant to the Assistant Attorney General
for Administration John F. Shaw at the United States Department
of Justice and stole documents found therein. Meisner then
forwarded these documents to Los Angeles for distribution
to the defendants and unindicted co-conspirators.
(52) On or about May 1, 1976, within the District of
Columbia, Michael J. Meisner and Gerald Bennet Wolfe
entered the United States Courthouse in order to locate
the office of Assistant United States Attorney
Nathan Dodell.
(53) On or about May 4, 1976, within the District of Columbia
Gerald Bennet Wolfe stole from the United States Courthouse
keys to the office of Assistant United States Attorney Nathan Dodell
for the purpose of having them duplicated.
(54) On or about May 21, 1976, within the District of Columbia
Michael J. Meisner and Gerald Bennet Wolfe entered
the office of Assistant United States Attorney Nathan Dodell
in the United States Courthouse and stole documents located
therein. Meisner then reported to RICHARD WEIGAND
details of the entry and forwarded the stolen
documents to Los Angeles for distribution
to the defendants and unindicted co-conspirators.
(55) On or about May 28, 1976, within the District of Columbia
Michael J. Meisner and Gerald Bennet Wolfe again entered
the office of Assistant United States Attorney Nathan Dodell
in the United States Courthouse and stole documents located
therein. Meisner then reported the details of the entry to
to his superiors in Los Angeles and forwarded the stolen
documents to Los Angeles for distribution
to the defendants and unindicted co-conspirators.
(56) On or about June 11, 1976, within the District of
Columbia, Michael J. Meisner and Gerald Bennet Wolfe
entered the United States Courthouse for the purpose of burglarizing
and stealing documents from the office of Assistant
United States Attorney Nathan Dodell and were
confronted by agents of the Federal Bureau of Investigation.
(57) On or about December 18, 1976, MITCHELL HERMANN,
a/k/a MIKE COOPER, wrote a letter to HENNING HELDT and
RICHARD WEIGAND explaining the attached “Project Troy”
which called for placing of a permanent electronic surveillance
in the IRS Chief Counsel’s Office in the District of Columbia
so that Scientology would remain informed of all IRS discussions
relating to Scientology’s request to be exempted from taxation.
(58) On or about December 20, 1976, HENNING HELDT
approved “Project Troy” described in the preceding paragraph.
(59) On or about May 27, 1977, HENNING HELDT, GREGORY
WILLARDSON and MO BUDLONG issued on behalf of
JANE KEMBER Guardian Order 158R (“Early Warning System”) which
called once again for the infiltration of the Office of the
United States Attorney for the District of Columbia for the purpose
of obtaining information about any potential legal action
against L Ron.Hubbard.
End of part ONE (pages 1 through 16) of 42 pages total
next part is COUNT TWO…
I'd prefer to die speaking my mind than live fearing to speak.
The only thing that always works in scientology are its lawyers
The internet is the liberty tree of the 90's
http://www.lermanet.com - mentioned
4 January 2000 in The Washington Post's - 'Reliable Source' column
re "Scientologist with no HEAD"
Return to The Skeptic Tank's main Index page.
US vs MSH et al Part 1 of 3
Arnie Lerma <www.lermanet.com> <Arnie_member@newsguy.com>
19 Mar 2000
AUG 15 1978
James F. Davey, Clerk
FOR THE DISTRICT OF COLUMBIA
JANE KEMBER
MORRIS BUDLONG, also known as MO BUDLONG
HENNING HELDT
DUKE SNIDER
GREGORY WILLARDSON
RICHARD WEIGAND
MITCHELL HERMANN, also known as MIKE COOPER
CINDY RAYMOND
GERALD BENNET WOLFE
SHARON THOMAS
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