From The Auditor Magazine, Issue #157, page 15,
published March 1979:

"Clear 10,702 Rhea Smith"

++++++++++++++++++++++++++++++++++++++++++++++++++ Date: Sun, 06 Jul 1997 09:30:19 GMT
Message-ID: <33c06500.169055015@snews.zippo.com>

[...]

DEPOSITION OF WARREN MCSHANE
TUESDAY, MAY 22, 1997

[...]

Grady [Ward]: Thank you very much. What individuals monitor the internet currently for infringements of Advanced Technology -- potential infringement?

Hogan [cult lawyer Thomas]: Let me object tot the question on the grounds that it assumes facts not in evidence, it's ambiguous and it's compound.

Grady: I'll withdraw that question. Does RTC monitor the Internet for copyright infringements for RTC's intellectual property?

Hogan: Let me object to the question on the grounds it's ambiguous.

Witness [McShane]: I have the Internet monitored.

Grady: Who does the monitoring?

A: Employees of the office of Special Affairs.

Grady: Now we briefly touched on the Office of Special Affairs awhile back. Is that a division within -- what is that entity?

Hogan: Object. It's been asked and answered.

Witness: I believe I stated before that it was part of CSI.

Grady: Who are the individuals that report to you?

Hogan: Let me object to the question on the grounds it's ambiguous and overly broad and relevance. Are you talking about -- are you talking about the monitoring of the internet now?

Grady: That's correct. Of the individuals in the OSA that monitor the internet for you, what are they identifying currently?

A: The main person is a woman named Rhea Smith, I believe.

Grady: Are there other people that report to you?

Hogan: Object to the form of the question. I think what you're looking for is people that monitor the internet; among these people, is there anybody other that Rhea Smith.

Grady: Yes.

(top of page)

Witness: Rhea has a couple of people under her who assist her. I don't really recall their names, but Rhea's the one who reports to me.

Grady: Since January of 1995, has Rhea Smith been monitoring the Internet for you?

A: Yes.

Grady: Are you familiar with the technical means she uses to monitor the internet?

Hogan: Object to the form of the question as ambiguous.

Witness: I think so.

Grady: Would you describe to me -- the machines that she uses to monitor the internet?

Hogan: Object to the form of the question as ambiguous.

Witness: Forgive me for not being a computer expert but -- I mean, she uses some form of computer hookups to the internet, and she uses various search engines. I'm not sure how they work, but they monitor various news groups and things like that.

Grady: Since you majored in electrical engineering, I expect more than the normal knowledge of computers from you.

(top of page) ?: Equipment, you mean his personal equipment or the RTC equipment?

Grady: One that you use such as RTC on your own. Assume it's RTC. It would belong to RTC typically.

Hogan: What's the Question?

Grady: Have you since January of 1995 monitored the internet personally?

A: That's a different question than your other question.

Grady: Have you monitored it personally for any corporate reason?

A: Well again the difficulty is what do you mean by monitor?

Grady: For example, read, for example, ARS. Use the search engine that is described for Rhea Smith.

A: I have not personally used the search engines. I have watched her do it. I have sat with her when she has done it. I have not personally logged on myself and done searches.

Grady: Do you have an e-mail account?

A: No I do not.

Grady: You testified, I believe, that Rhea Smith and the people that work with her or the subordinates are members of OSA, employees of CSI? (62)

(top of page) Hogan: Object to the form of the question. It assumes facts not in evidence. I believe the record will speak for itself.

Witness: I believe what I testified to is that they are employees of the OSA which is part of the -- part of the church of scientology international.

Grady: In addition to that monitoring by Rhea Smith and her associates, does RTC do monitoring of the internet?

Hogan: Object to the form of the question; assumes facts not in evidence, and it's ambiguous.

Witness: No

Grady: Has it been your regular practice, then, to -- for Rhea Smith and her associates to monitor the internet for copyright infringements?

Hogan: Object to the form of the question as ambiguous.

Witness: It's not limited to copyright infringements. We've monitored the Internet since, I believe, the ARS was fraudulently set up. I think it was in '94. Maybe even before that. Yeah.

Grady: So to your knowledge, has the internet been (63)

(top of page) Witness: The best I can explain without getting any detail would be the various aspects and-- the workings of the internet and the various aspects of the internet.

Grady: To your knowledge, are those outside experts regularly employed or just occasionally employed to help out sporadically?

Hogan: I object. It does invade the attorney-client privilege and instruct the witness not to answer.

Grady: Now as far as the Rhea Smith monitoring using those search engines, HotBot, AltaVista and so on, can you tell me how they search for the topics that you're interested in?

Hogan: Object to the form of the question. It's ambiguous, assumes facts not in evidence.

Witness: My understanding is that they search certain key words that I've given to them basically.

Grady: Are those key words -- do you write those key words down to give them?

A: No. (69) (8)
?: Allan Cartwright and to counsel.

Grady: So approximately four copies, but you don't -- I don't want you to speculate. If you don't know--

Hogan: Object to the form of the question and does at least in part invade the attorney-client privilege.

Grady: I'll withdraw that question. Other than making copies -- a copy for you, does Rhea Smith keep magnetic images of what has been captured?

Hogan: Ambiguous, assumes facts not in evidence.

Witness: I don't know.

Grady: Does Rhea Smith keep -- to your knowledge, keep a log of what is downloaded when -- Does Rhea Smith keep any kind of auxiliary log of the materials she downloads and prints and sends to you?

Hogan: Object to the form of the question; assume facts not in evidence. It's compound and ambiguous.

Witness: I don't believe she does. The print off has usually the date and who it's from and access provider and all stuff that usually appears on stuff.

[...]

++++++++++++++++++++++++++++++++++++++++++++++++++

RELIGIOUS TECHNOLOGY CENTER, a Scientology Corporation, Plaintiff, v. GRADY WARD, an individual, an individual, Defendant. NO. C-96-20207 RMW

DECLARATION OF GRADY WARD IN SUPPORT OF MOTION FOR ORDER TO SHOW CAUSE WHY WARREN MCSHANE AND HELENA KOBRIN SHOULD NOT BE FOUND IN CIVIL AND CRIMINAL CONTEMPT

[...]

8. The attached Exhibit 7 are excerpts from the deposition of Warren McShane conducted under penalty of perjury on May 22, 1997. Exhibit 7 at page 59, McShane falsely conceals the existence of Jean Carnahan and falsely identifies Rhea Smith as the monitor since January, 1995. This is the first mention of Rhea Smith in this litigation. Exhibit 7 at page 63 McShane admits that no other monitoring of the Internet is done other than Smith and associates. At Exhibit 7 at page 73 McShane falsely says that "he doesn't know" is magnetic copies of the Internet monitoring are kept, despite his and later Carnahan's testimony that he and Kobrin were the sole supervisors of such monitoring since January of 1995. He testifies falsely later on this page that "he doesn't believe" that Smith keeps any kind of auxiliary log of the downloads, once again, in contradiction to the later testimony of Carnahan and Smith. Exhibit 7 at page 85 and 86, McShane falsely says that he is the monitor of the Internet, once again actively concealing the existence of Carnahan and Smith. Exhibit 7 at page 95 he admits to getting reports on the monitoring virtually every day. Exhibit 7 at page 134 he once again conceals the scope and identity of the monitoring. He knows ver well he could answer the question about the Internet by consulting the vast data horde as collected and maintained by Carnahan and Smith. Exhibits 7 at page 164 and 165 show that McShane actually obtains postings from many different sources other than the Carnahan and Smith, or else he is still trying to actively conceal their data compilation.

9. The attached Exhibit 8 is the deposition under penalty of perjury of Jean Carnahan conducted April 16, 1998. Exhibit 8 at page 10 she admits to be the custodian of records to the Internet monitoring. Exhibit 8 at page 11 she admits that she has done this monitoring from February 20, 1995 through December, 1995. Exhibit 8 at page 13 and 14 she admits that her supervisors for this monitoring were Warren McShane and Helena Kobrin. A third party, Linda Hamel only had the role of confirming that she carries out McShane's instructions. Exhibit 8 at page 15 she admits paramilitary rank in a scientology organiztion. Exhibit 8 at page 19 she admits maintaining all Internet records of alt.religion.scientology. Exhibit 8 at page 20 she admits to keeping all magnetic records of her monitoring. Exhibit 8 at page 49 she explicitly admits using the personal Internet account of Helena K. Kobrin "HKK" for her monitoring. Exhibit 8 at page 52, she admits to obtaining use of the account after consulting personally with Helena K. Kobrin. Exhibit 8 at page 55 through 57 she admits that McShane supervised her and frequently consulted with her during her period of monitoring. Exhibit 8 at page 106 and 107 she admits to keeping other written records, which were not disclosed by the plaintiff.

10. The attached Exhibit 9 is the deposition under penalty of perjury of Rhea Smith conducted April 16, 1998. Exhibit 9 at page 7 and 8 she admits to monitoring the Internet from the very end of December 1995 to the present. Exhibit 9 at page 10 she admits to downloading "everything" from the relevant Internet newsgroups. Exhibit 9 at page 12 and 13 she admits that McShane personally supervised her work "two to three times a week" also on 9 at page 13 she admits to keeping a full magnetic record of such downloads. Exhibit 9 at page 27 she admits to sending reports directly to Helena K. Kobrin. Exhibit 9 at page 28 she admits that no one else is doing this monitoring work for RTC. Exhibit 9 at page 30 and 31 she admits to making paper copies of about 25% of alt.religion.scientology postings. Exhibit 9 at page 35 admits that another data compilation resides with Allan Cartwright. Exhibit 9 at page 51 she admits to keeping additional undisclosed logs of her monitoring.

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