------------------------------------------------------------------- F.A.C.T.Net, Inc. (Fight Against Coercive Tactics Network, Incorporated) a non-profit computer bulletin board and electronic library 601 16th St. #C-217 Golden, Colorado 80401 USA BBS 303 530-1942 FAX 303 530-2950 Office 303 473-0111 This document is part of an electronic lending library and preservational electronic archive. F.A.C.T.Net does not sell documents, it only lends them according to the terms of your library cardholder agreement with F.A.C.T.Net, Inc. ===================================================================== SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES LARRY WOLLERSHEIM, ) GRc,.F. NE.' Plaintiff, ) ) vs. ) No. C332027 ) CHURCH OF SCIENTOLOGY OF CALIFORNIA, ) a corporation; CHURCH OF SCIENTOLOGY ) OF FLORIDA, a corporation; L. RON ) HUBBARD, an individual; CHURCH OF ) SCIENTOLOGY, a corporation; DOES ) 1 through 200, inclusive, ) ) Defendants. ) ) VOLUME 2 DEPOSITION OF ELEANORE FRANCES WOLLERSHEIM, taken by the defendants on Friday, March 30, 1984, at 10:15 a.m., at 1122 Wilshire Boulevard, Los Angeles, CA 90017, before Kery Gillet, CSR No. 3352, notary public for the State of California, pursuant to stipulation. KEDY GILLET, CQ,%D NO. 3~5~ (A Shorthand Reporting Sen/ice) 818 Oneonta Drive IIIIIIIIII II II ~ 213 ~56-4684 INDEX: 2 EXAMINATION BY: PAGE 3 Mr. Kropp 67,1' Ms Schlosser 92 5 6 7 8 EXHIBITS: 9 [No exhibits were marked. ] 10 11 ~12 13 1~ ~ 15 15 17 ~ 18 ORIGINAL TRANSCRIPT OF PROCEEDINGS HELD BY COURT REPORTER 79 I 20 r 21 22 ~ 23 2~ ~25 KERY GILLET. CSR No. 3352 ~:~.1~ IIIIIIIIII ~ s~o~,~ ~o.,~ s~,~ IIII 45 ~ ,,. ~ I APPEARANCES: M 2 3 FOR THE PLAINTIFF: GREENE, O'REILLY, AGNEW & BROILLET BY: LETA SCHLOSSER, ATTORNEY AT LAW I 5 1122 Wilshire Boulevard Los Angeles, CA 90017 I 7 FOR THE DEFENDANTS: 8 ~ TAYLOR, ROTH & NUNT 9 BY: ROBERT KROPP, JR., ATTORNEY AT LA~q 617 South Olive Street, Suite 1100 i 10 Los Angeles, CA 90014 (213) 623-8000 THE WITNESS: ~3 ELEANORE FRANCES WOLLERSHEIM ;5 I ALSO PRESENT: LEE HOLZINGER I .~7 LAWRENCE WOLLERSHEIM, SR. 18 I2O I 22 23 2Z KERY GI LLET. CSR No. 3~52 67 I EXAMINATION (CONTINUED) 2 BY MR. KROPP: 3 Q Mrs. Wollersheim, in the interest -- I'm sorry. ~ Eleanore, in the interest of time, I'm not going to go 5 over all of the discussion we had at the beginning of 6 the deposition where I explained the deposition procedure. 7 Let me just indicate that you're still under oath as you 8 were yesterday; and the same procedures apply. 9 If there's any problem with the way the depositi, 10 goes or my questions go, again, just ask me; and we'll 11 try and clarify it. Okay? 12 A FSne. ;3 Q Have you taken any medication today before the 1~ deposition? ;5 A I've taken my blood-pressure pill at 9:00. 16 Q Okay. Which medication is the blood-pressure 17 pill? 18 A The Diaside. 19 Q Do you know what the dosage is of that medication 20 A No, I do not. 21 Q Are you taking any other medication today? 22 A Not at all. 23 Q Do you know if your son was ever a member of 2~ the armed forces? 25 A No, he wasn't. 68 ~ Q Do you know whether your son ever received 2 a 4F draft classification? 3 MS SCHLOSSER: Objection. Foundation. If he received ~ any draft classification that she's aware of. 5 Q BY MR. KROPP: You don't know what draft c]assifica- 6 tion, if any, he had? 7 A No, I don't. 8 Q Did you ever discuss with your son at any time 9 his view, his opinion, of the draft? ~0 A Yes, I did. ~ Q Do you remember roughly what period of time ~2 that discussion took place in? 13 A No, I don't. ;~ Q Do you know if a discussion took place while ;5 he was attending the university? / A No, I don't. Q Do you remember the essence of the discussion ;8 you had with your son about the draft? I ;9 A Yes, ! do. i 20 Q And what was that? 21 A I -- I 22 MS SCHLOSSER: Object to the use of the word "the 23 draft." I don't know whether you're talking about military I 2~ service or just the specific aspect of military service 25 I that drafts young men. I KERY G[ LLET, CSR No. 3352 Illlllllllt~ s.o.~ ~ .....i~ s .....~ IIII I ~ 69 ; MR. KROPP: Let's see what the answer to the question ~ 2 is; and we'll clarify it if need be. ~ 3 THE WITNESS: He objected to going in. He didn't ~ feel that he wanted to kill. ~ 5 Q BY MR. KROPP: And when he mentioned that to 6 you, did you have any reaction to it? ~ 7 A I had a reaction because my husband was in the 8 service and told him he could have chosen some other - 9 - or talked and chosen something else where he didn't ~0 have to go in and kill. l~ Q Did your son discuss with you any plans or strategy 12 for keeping out of the a~med forces? ~3 MS SCHLOSSER: Objection. You are alluding to facts ;~ that are not on the record. ~5 MR. KROPP: I'm asking a foundational question. 16 MS SCHLOSSER: But you're assuming the facts in the 17 foundational question. ~8 MR. KROPP: I'm not assuming anything. ~9 MS SCHLOSSER: That's my objection. 20 You may answer, Mrs. Wollersheim. 21 THE WITNESS: No. I22 Q BY MR. KROPP: Did your son ever discuss with 23 you any activities he intended to undert'ake to help keep I 2~ him from going into the armed forces? 25 IMS SCHLOSSER: Vague and amgibuous as to time. I KERY GILLET. CSR No. 3352 IIIIIIIIII ~ s.o~,~ ~.~o.,.~ a .....~ I I 7O ; MR. KROPP: At any time. I 2 'PHE WITNESS: No. 3 Q Are you aware of whether your son at any time ~ ran naked through an armed forces induction center? I 5 A Yes. 6 MS SCHLOSSER: Objection. It assumes facts not in J 7 evidence. 8 THE WITNESS: Yes. i 9 Q BY MR. KROPP: And what information do you b I ;0 about that? ~l A From Edie Wollersheim. I12 Q What did Edie Wollersheim tell you? 13 A She and Larry planned this to get him out of I 1~ the draft. I 15 Q What was it she told you that they had planned? ~5 A They were going to do everything in their power I ~7 to convince -- 78 MS SCHLOSSER: No. Mrs. Wollersheim, listen to the ~ 19 question carefully. It's asking for specifically what ~ 20 they planned. 21 Q BY MR. KROPP: I'm asking -- ~ 22 A To avoid the draft. 23 Q And what was it that Edie told you she and Larry I 2Z had planned with regard to Larry and the draft? 25 A I don't know. KERY GILLET. CSR No. 3352 I ~ Q Did she mention so you an!.., plan of Larry's to I 2 run naked through an armed forces induction center? 3 MS SCHLOSSER: Objection. Vague and ambiguous as I ~ to time. I 5 THE WITNESS: i don't know. 5 Q BY MR. KROPP: Did Edie discuss with you any 7 plan that Larry had of running naked in front of a mental 8 health facility? ~ 9 MS SCHLOSSER: Objection. Vague and ambiguous as ~ ~0 to time. ll THE WITNESS: No. Q Did Edie or Lakry ever tell you at any time 13 that Larry had in fact, your son Larry, had in fact run ~ ;Z naked through an armed forces induction center? i 75 MS SCHLOSSER: Objection. Vague and ambiguous as ~5 to time. ~ 17 THE WITNESS: No. 18 Q BY MR. KROPP: Did your son or Edie ever tell ~ 19 you that your son had run naked past a mental health insti- ~ 20 tution at any time? 2~ MS SCHLOSSER: Objection. Vague and ambiguous as ~ 22 to time. 23 THE WITNESS: No. ~ 2~ Q BY MR. KROPP: Do you have any information that ~ S your son ever ran naked past a mental health facility I KERY GILLET. CSR No. 3352 I 72 I at any time? I 2 A No. i 3 Q To your knowledge, has your son ever been arrested? ~ MS SCHLOSSER: Objection. Irrelevant. I 5 THE WITNESS: Not that I recall. 6 Q BY MR. KROPP: Do you have any knowledge that I 7 your son has ever been in a mental institution for any 8 period of time? I 9 MS SCHLOSSER: Objection. Vague and ambiguous ase~ I l0 to what you mean by mental institution and what you mean ~l by any length of time. I 12 THE WITNESS: Hospital. ~3 Q BY MR. KROPP: What information do you have I ;~ about your son being in the hospital? I ~5 A Not any information. 15 Q Has your son ever been in the hospital, to your I17 knowledge? ;8 MS SCHLOSSER: Other than for visits? You're talking I ;9 about his own -- i 20 MR. KROPP: Any hospital at any time. 2~ THE WITNESS: Birth. I 22 Q BY MR. KROPP: Has he ever been admitted to 23 the hospital at any time after he was born? I 2~ A Not that I recall. i 25 Q To your knowledge, did your son ever live at 73 anyplace he called a commune? 2 MS SCHLOSSER: Objection. Vague and ambiguous as 3 to "commune." ~ THE WITNESS: In Scientology. I 5 Q BY MR. KROPP: What Scientology commune did 6 your son live on? 7 MS SCHLOSSER: Same objection. 8 THE WITNESS: Groups of people. I 9 Q BY MR. KROPP: Where? ;0 A California. ~l Q When? ~2 A I don't recall'the date. ~3 Q And did your son at any other time ever tell I ;~ you that he had lived in a living arrangement called a i 15 commune? ~5 A No. I~7 Q Do you have any information that your son ever 78 resided at a location called Children of Aquarius? I ~9 A Yes. I 20 Q What was, to your knowledge, Children of Aquarius? 2~ A A home where he made candles. I 22 Q Was that the farm we'd spoken about earlier? 23 A That's correct. I 24 Q To your knowledge, did your son ever live on 25 a farm in Vermont? J K EI~ Cl LLI~T, Co%E2 No. ]55"2 74 7 A Not to my knowledge. 2 Q Now, yesterday I asked you about occasions on 3 which you had seen you~ son in between the time you visited ~ him for his wedding in Los Angeles and the time that he 5 reEurned home to Milwaukee after leaving the church in 6 about 1979. 7 Now, what's your recollection of how many occasions 8 you saw your son in that time period? 9 MS SCHLOSSER: May I have the question read back. 70 [The last question is read.] ~l THE WITNESS: I don't recall how many times. 72 Q BY MR. KROPP: -Do you know if you saw him on 13 more than one occasion? ;~ A I'm sure I did. ~5 Q Did you see him on any occasion in that time ~6 period at anyplace other than in Milwaukee? 17 A No. 18 Q Do you know at the present time the reason why 19 he was in Milwaukee on the occasions that you saw ~im 20 in this time period? 2; MS SCHLOSSER: Objection. Speculation, foundation. 22 THE WITNESS: I don't remember. 23 Q BY MR. KROPP: Do you recall if he indicated 2~ to you that he was passing through on business? 25 A No, I do not remember. KERY GI LLET. CSR No. 3352 75 m ; Q Do you know if you saw your son in Milwaukee q 2 on more than five occasions in this time period? I 3 A I couldn't give you an honest answer. ~ MS SCHLOSSER: I'd like to interpose an objection. ~ 5 Vague and ambiguous. 6 Are you talking about five occasions at one 7 time or five occasions during the course of those years, 8 or perhaps that he could have visited at two or three I 9 days at a time and would have seen him multiple times 70 during the visit? II MR. KROPP: Five occasions is five occasions, seeing 12 him five times. It seems to me pointless to continue 73 on your purported clarification if the witness can't tell 7~ me anything about how many times she saw him. 75 MR. SCHLOSSER: I'd like to keep the record clear, ~6 Mr. Kropp. My objection is it's vague and ambiguous for I 17 the reason I have explained. And you've just answered ~8 the question in such a way as to make it obvious that I 79 my objection was well taken. I 20 Q BY MR. KROPP: On any of the occasions when 2; you saw your son in this time period we're talking about, I 22 did you and he ever talk about Scientology? 23 A Not that I recall. I 2~ Q At any time after your son left Scientology 25 iand returned to live with you in Milwaukee, did you and I KERY GI LLET. CSR No. 3352 76 your son ever talk about Scientology? I A Yt:~s-, we did. ~ 2 Q Do 'you remember anything that your son said about 3 ~ Scientolog3' on those occasions? 4 MS SCHLOSSER: You're Talking about after he left ~ 5 or broke with the Church of Scientoiogy? 6 MR. KROPP: That's what my question was. That's ~ 7 correct. 8 ~ THE WITNESS: That he finally made me very happy 9 about. getting out. 10 Q Is there anything else your son told you about If his experiences with Scientology while he was involved 12 in Scientology after he'd left? 13 MS SCHLOSSER: Objection. You're asking the witness 14 to distill something that occurred over the course of 15 time a number of years ago. 16 MR. KROPP: That's correct. 17 MS SCHLOSSER: If you asked her specific questions 18 about it, I think you'd get a much more accurate picture 19 of what she recalled. 20 THE WITNESS: I don't remember. 21 ~ 22 Q BY MR. KROPP: You don't remember anything that your son told you about his experiences with Scientology 23 ~ after he had left Scientology; is that your testimony? 2~ 25 MS SCHLOSSER: Please interpose my same objection. ~[~ KERYGILLET. CSRNo, 3352 IIIIIIIIII r~s .......~,~,,,o,,,.~s ...... IIII I THE WITNESS: Ne was unhappy with it. 2 O BY HA. KROPP: Why did he say he was unhappy ~ 3 with Scientology? ~ A He found the life wasn't as good as he expected I 5 it to be. 6 Q What did he find about the life that wasn't 7 as good as he expected it to be? 8 A I don't know. I 9 Q Did he say an}7thing about why the life wasn't I 70 the way he expected it to be to you? II A No, he didn't. I12 Q Is there anything else your son said to you ;3 about his experiences in Scientology after he left Scientology [ ;~ that you can recall today? [ ~5 MS SCHLOSSER: You're changing the question. You ~6 spoke about him originally coming back to Milwaukee after he broke with Scientology, in that time period. You're ~8 now making it a broader time period? [ 79 MR. KROPP: Would you p16ase go back and reread my ~ 20 last four questions. 2~ [The record is read.] 22 MS SCHLOSSER: I'd like to state for the record that 23 you prefaced this line of questioning with the conversation 2~ or directing the witness to the time period directly after ~ the plaintiff left Scientology and returned to Milwaukee. KERY GILLET. CSR No. 3352 IIIIIIIIII ,~ s~o,,~.~ '~o,,,~ s ..... ~ I 78 I And you have changed the ambit of your question to a much 2 broader time period now. And i'm not sure that is totally i 3 clear on the record or totally clear to the witness. ~ MR. KROPP: I'm glad ~hat you finally have understood I 5 that I broadened the ambit of my question and that I will 5 repeat the last question I asked to the witness. ~ 7 MS SCHLOSSER: Well, it's not going to cure the defect ~ 8 in the record or make it any clearer. 9 MR. KROPP: Counsel, there's no defect, I believe, I ;0 in the record. There is perhaps a defect in your understanding II and recall of the line of questioning. But I think the I ;2 record speaks for itselF. 13 MS SCHLOSSER: I'd also like to object at this time I 1~ to the fact that the witness told me yesterday after the I 15 conclusion of yesterday's session of this deposition that 16 she found your jumping around in time periods confusing. I17 And again you're going to have to make a more complete 78 statement about a particular time period instead of jumping [ 19 back and forth as you did yesterday through about five ~ 20 " t~me periods within a very short number of minutes. 27 You're going to have a very unclear record. ~ 22 But that's -- 23 MR. KROPP: You've made your statement for the record. [ 2~ Q I will repeat to you, Eleanore, that if any [ ~ question I ask of you is unclear, I am requesting that KEPY GI LLET. Cc$17 NO. 3352 I 77 ~ you ask me to rephrase the question. I have no desire 2 to get an answer which doesn't fit with the question that 3 I asked; and I have no desire to confuse you. L As you can see, your son's counsel has no reluctance 5 to intercede objections and to make comment on my questions. 6 And you should feel no greater reluctance than she does 7 to indicate if there's any problem with the question that 8 I've asked you. 9 Now, could we go back to the last question I ;0 asked before we began this interchange. ~l [The question at Page 14, Line 12 ;2 is read.] ;3 MS SCHLOSSER: That question goes to any time after ;L Larry, Jr., left Scientology. 15 Q BY MR. KROPP: That was exactly the question; ~6 that's right. 77 A He was very unhappy with it. 78 Q What did he say to you about why he was unhappy 79 about his time in Scientology? 20 A It was not what he had expected of Scientology. 21 Q Did he indicate to you what he had expected 22 of Scientology? 23 A That it would do all the things that they told 2~ him it would do for him. 25 Q Did your son tell you what Scientology had told KEPY GILLET. C&I:2 No. 3352 I ~ him it would do for him? ~ 2 MS SCHLOSSER: Objection. You already went through 3 some testimony yesterday. Other than what she testified I ~ to yesterday? B 5 MR. KROPP: Anything. 6 THE WITNESS: Success. Better person. B 7 Q BY MR. KROPP: Is there anything else that your a son told you Scientology would do for him aside from giving I 9 him success and making him a better person that he felt I 10 Scientology had not accomplished for him? 11 MS SCHLOSSER: Again, including what she mentioned I~2 yesterday, where she sp'oke about IQ points and specific 13 representations yesterday? I 1~ THE WITNESS: No. I 15 Q BY MR. KROPP: Is there anything else that your ;6 son mentioned to you after he left Scientology about his I 17 experiences with Scientology that made him unhappy? 18 A No. I 79 Q Can you describe for me what-your son's personality i 2D was like when he returned to your house in Milwaukee immedi- 21 ately after leaving Scientology? I 22 MS SCHLOSSER: Objection. Assumes facts not in evidence. 23 THE WITNESS: Cold. I 2~ Q BY MR. KROPP: Anything else you can describe i about him? KERY GI LLET. CSR No. 3352 81 I A Not caring. 2 Q Anything else? 2 A No. ~ Q Has your son at any time ever spoken with you 5 about a business called Beautiful Pictures, Beautiful 5 Gifts? 7 A Not that I recall. 8 Q You don't recall ever at any time having any 9 discussion with your son about Beautiful Pictures, Beautiful r 10 Gifts? 1; A I knew that he was in the business. 12 Q How did you know he was in the business? ~ 13 A Well, he -- he talked about going into that 1L business. ~ 15 Q Did he talk to you about the business after 15 he was in the business? p 17 A That's correct. 18 Q What did he say to you about the business after 19 it was in operation? 20 A That it was going to be a very successful and 21 a good business. 22 Q What sort of a business was ~eautiful Pictures, 23 Beautiful Gifts? 2Z A Sold pictures to various people, companies. 25 Q Did your son ever tell you anything else about KERY GILLET, CSR No. 3352 I 82 I Beautiful Pictures, Beautiful Gifts aside from what you've I 2 told me now? 3 A blot that I know of. I ~ Q Do you know if in the late spring, early summer I 5 of 1976 there was a family reunion in Milwaukee for your 6 mother? 7 A We had many family reunions. I don't recall 8 any specific one. I 9 Q Was there any specific reumion that you recall I ;0 for your mother's 80th birthday? 11 A That I recall. 12 Q Do you recall what month your mother's 80th 13 birthday was in? I~ A Yes, I do. i 15 Q What month was that? 16 A July. 17' Q And was your mother's 80th birthday in 19767 18 A Let's see. I have to think. I 19 Q Okay.,. i 20 A That would be the year. 21 Q Do you recall what day in July of 1976 to '80 22 the birthday reunion was? 23 A July 6th. 2~ Q Do you recall if your son was present at the 25 reunion? KERY GILLET. CSR No. 3352 IIIIIIIIII ~ sno~,~ ~o~.~ s ...... II II I 7 A He was the only one that wasn't present. i 2 Q Do you recall if at any time before the reunion i 3 took place you in any way communicated to your son that 4 a reunion was going to be taking place? I 5 A I did. 6 Q How did you communicate that to him? I7 A I wanted him to make his grandmother's 80th 8 birthday. I 9 Q What vehicle of communication did you use? I 70 Did you tell him in person, telephone, letter? 11 A I wanted him to come to my mother's birthday I12 because I knew she was ikl. 13 Q You want to take a break for just a minute, I 14 Eleanore? I 15 A I would like to. 16 MS SCHLOSSER: Let the record reflect that Mrs. I 17 Wollersheim is quite upset, on the verge of tears. 18 [A brief recess is taken.] I 19 [The question at Line 9 is read.] I 20 Q BY MR. KROPP: Let me ask a new question. 21 I'll move to strike the last two responses to my last ~ 22 two questions as being nonresponsive. I'll ask a new 23 question. ~ 2~ Eleanore, how did you communicate to your son 25 your interest in having him come to your mother's 80th KERY GILLET, CSR No. 3352 IIIIIIIIII ,~ s.o.,~.~ ~o,,,.~ s ..... ~ IIII I I I birthday reunion? 2 A I didn't. My thusband communicated with him. 3 Q Do you know how your husband communicated with ~ your son on that? 5 A Telephone. 5 Q Were you present when the telephone call took 7 place? 8 A No, I was not. 9 Q Did your husband tell you the result of that 10 telephone conversation or what Larry's response was to 11 that telephone conversation? 12 A He said that he would try to get to Grandma's 13 reunion -- I mean birthday party. 1~ Q Did your son at any time ever give you any indication 15_ of why he didn't come to the birthday party reunion? 16 A No, he didn't. 17 Q Have you ever read a publication called The 18 Scandal of Scientology? 19 A No, I haven't. 20 Q Have you ever heard of that book? 21 A No, I haven't. 22 Q Have you ever heard of an individual named Eddie 23 Waltors? 2~ A No, I haven't. 25 Q Have you ever heard of an individual named Dr. KERY GI LLET, CSR No. 3352 85 ; David Hutchison? 2 A No, I haven't. 3 Q Have you ever heard of an attorney named Michael ~ Flynn? 5 A No, I haven't. 6 Q What understanding do you have at the present 7 time, if any, regarding the beliefs and practices of Scien- 8 tology? 9 MS SCHLOSSER: Objection. Overbroad, vague and ambi- 10 guous. Lack of foundation. 71 THE WITNESS: I don't know. ;2 Q BY MR. KROPP: As you sit here today, do you ~3 have any knowledge of any practice or belief of Scientology? ;~ MS SCHLOSSER: Same objections. You're asking her ~5 to distill a course of many years. You're not giving 16 her any specific references. ~7 MR. KROPP: That's correct. ~8 THE WITNESS: I don't know. ~9 Q BY MR. KROPP: Do you have any knowledge of 2O any statements made to your son at any time that Scientology 21 would make him a more stable, confident, healthy, or pro- 22 ductlye member of society? 23 MS SCHLOSSER: Objection. Compound. Foundation. 2~ THE WITNESS: Yes. Q BY MR. KROPP: Okay. What information do you KERY GI LLET, CSR No. 3352 86 ~ I have regarding that? I 2 A That he -- that they would do that. ~ 3 Q Your son told you that someone had made such ~ a representation to him? ~ 5 A Uh-huh. 6 Q Was that yes? ~ 7 A Yes. 8 Q When did your son tell you that? ~ 9 A I don't recall. 10 Q Did your son tell you who had made such represen- 11 tations to him? 12 A No, he didn't_. 13 Q Did your son tell you where he was when such I~ representations were made to him? 15 A No, he didn't. 16 Q Did.your son ever tell you that he had ever 17 been told that Scientology would speed the recovery from 18 diseases? 19 A I don't recall. 20 Q Do you recall if your son ever told you that 21 he was ever told that Scientotogy would cause the decline 22 of body disfunctions such as pain? 23 A I don't recall. 2~ Q Just so you're clear on what I'm asking you, 25 I'm asking you if you recall your son telling you that KERY GI LLET. CSR No. 3352 87 ; he was told this by someone else. 2 A I understand fully. 3 Q Okay. Good. ~ Has your son, to your knowledge, ever referred 5 to a Scientology term of Level 17 5 A I don't recall. 7 MS SCHLOSSER: I'd like to interpose an objection. 8 Assumes facts not in evidence. I move to strike the answe: 9 to do so. ~O Q B~/MR. KROPP: Now, earlier you testified that 7~ your son told you he was unhappy about Scientology because 12 he was told that Scientol'ogy could raise his IQ or that ~3 Scientology could make him a success. ~ Did your son ever tell you how he came to learn 15 that these representations were untrue? 15 MS SCHLOSSER: Objection. Argumentative. f7 THE WITNESS: I don't know. ~8 Q BY MR. KROPP: Did your son at any time ever ~9 tell you that anything happened to him in September or 20 October of 1979 that affected his view of his involvement 2~ in Scientology? 22 MS SCHLOSSER: Objection. Vague and ambiguous. 23 THE WITNESS: No, he didn't. 2~ Q BY MR. KROPP: Did your son at any time ever 75 tell you that he believed that Scientology counselling, KERY GI LLET, CSR No. 3352 IIIIIIIIII ~ s~o,,~.~ r~o,,,.~ s ..... I auditing, or programming were dangerous? 2 A He kept a lot of Ehings away from me because 3 of my physical health. ~ Q' Do you have any recollection of your son ever 5 telling you that he believed that Scientology counselling, 6 auditing, or programming were dangerous? 7 A I don't recall. 8 Q Did your son ever use a term that he indicated 9 was a Scientology term known as disconnect? 10 A I'm not familiar. 11 Q Did your son ever tell you that he was told 12 by anyone to disconnect With you? 13 A No. ;~ Q Did your son ever tell you that he was told 15 by anyone to disconnect with your husband? 15 A No. 17 Q Did your son ever tell you that he was told 18 by anyone else to disconnect from Edie? 19 MS SCHLOSSER: Object to the last few questions. 20 You continually use the term instead of the meaning behind 21 the term even though she indicates no particular knowledge 22 of the term. 23 MR. KROPP: I'm using the term because that's precisely 2Z what I want to do. 25 MS SCHLOSSER: That's your choice, Mr. Kropp. KERY GI LLET, CSR No. 3352 s9 MR. KROPP: 'Phat's correct. 2 'PHE WITNESS: No. 3 Q BY MR. KROPP: Did your son at any time ever I ~ tell you that he t~ad been told by anyone not to have any 5 further dealings with you? 6 A Not that I recall. 7 Q Did your son at any time ever tell you that 8 he had been told by anyone else to have no further dealings 9 and to cut himself off from his father? 70 A Not that I recall. ;~ O Did your son ever tell you at any time that 72 he had been told by anyone else to have no further contact ~ 13 with Edie and to cut himself off from Edie? . ;~ A My son didn't tell me, but Edie told me. 75 Q What did Edie tell you? 16 A That they separated the two of them when they 7Z were in California. ;8 Q That who had separated the two of them? ~9 A Scientology did. 2Z2 Q And did Edie ever tell you if she was told why 2~ the two of them were separated? 22 MS SCHLOSSER: Objection. Vague and ambiguous as 23 to time and foundation. 2~ THE WITNESS: She told me that they didn't like people 2~ being married. K ERY GI LLET. CSR No. 3352 90 ~ I Q BY MR. KROPP: Did Edie ever tell you who told ~ 2 her this? 3 A I don't recall. W~ Q' Has your son at any conversation he's ever had I 5 with you referred to something called Fair Game Doctrine? 5 A I don't recall. 7 Q In any conversation you-ever had with your son, 8 has he ever referred to a term suppresslye person, to 9 your knowledge and recollection at the present time? 10 A I don't recall. 11 Q Did your son ever tell you that Scientology 12 ever destroyed any business of your son's? 13 A Not that I recall. lZ. Q Did your son ever tell you that Scientology 15 o~ any Scientologist had ever adversely or negatively ~6 affected any business of you~ son's? 17 A Not that I recall. 18 MR. KROPP: Let me go off the record for a minute 19 or two. 20 [A brief recess is taken.] 21 MR. KROPP: Okay. Back on the record. I 22 Q To your knowledge, has your son ever sought 23 the assistance of any psychiatrist? I 2Z MS SCHLOSSER: Objection. Foundation. I 25 THE WITNESS: Not that I recall. I KEI~'~' GILLET. C~I~ No. 335V. 91 7 Q BY MR. KROPp: To your knowledge, has your son 2 ever sought the assistance of any psychologist? 3 MS SCHLOSSER: Same objection. ~ THE WITNESS: Not that I recall. 5 Q BY MR. KP, OPP: To your knowledge, has your 6 son ever used the services of any mental health professional? 7 MS SCHLOSSER: Objection. Vague and ambiguous -- 8 THE WITNESS: I don't know. 9 MS SCHLOSSER: -- as to mental health -- 10 What was the term that you used? Mental health...? 11 MR. KROPP: Professional. 12 MS SCHLOSSER: Professional. 13 And foundation. 1~ THE WITNESS: I don't know. 15 Q BY MR. KROPP: Do you have within your possession, ~6 not at the present time, but in Milwaukee, any letters your son has ever written to you? MS SCHLOSSER: Objection. You asked for a specific 19 place; and I thought you weren't going to do that. 2O MR. KROPP: That was just one location where I asked 21 where something might be. 22 MS SCHLOSSE~: Well, why don't you remove that. 23 MR. K~OPP: Okay. That's fine. Let me rephrase 2~ the question. Q Do you have anywhere in your possession, custody, KERY GI LLET. CSR No. 3352 1111111111 ~A s~o,,~.~ ~o,,,~ I I or control any letters that your son has ever written I 2 to you? m 3 MS SCHLOSSER: Objection. Calls for a legal conclusion. ~ THE WITNESS: A lot of cards and a lot of letters. i 5 Q BY MR. KROPP: Do you have any cards and letters 6 that your son wrote to you in the period of 1970 to 19797 I 7 A I'm sure I have. i 8 Q Now, I'm not sure if this is something you and 9 I went over at the beginning of the deposition; but one I 10 of the agreements that your son's counsel made with my 11 office in taking your deposition was that I was not at I 12 any time going to ask you where you lived. 13 You were made available here at your son's counsel's I 14 office for this deposition. And I'm not going to ask I 15 you where you live. 16 However, what I do want to ask y, ou-is: The I 17 cards and letters that you believe you 'have from your 18 son, would those cards and letters be at your house? I 19 A I'm sure they are. i 20 Q Okay. 21 I have no further questions. ~ 22 23 EXMINATION ~ 2~ BY MS SCHLOSSER: ~ 25 Q Mrs. Wollersheim, at some point in time, were KERY GI LLET. CSR No. 3352 I 93 you asked by your son to undergo auditing? 2 A Uh-huh. 3 Q And you understand auditing is a Scientology m ~ term of a type of programming -- I 5 A Uh-huh. 5 Q -- that they engage in? I 7 A Uh-huh. 8 Q Where did you undergo that auditing? I 9 A Curiosity. I 70 Q Not why. Where. 77 A In California. I72 Q In Los Angeles? 73 A Uh-huh. I I~ Q Which one of the Scientology centers do you I 75 recall going to? 75 A I don't recall. I 77 Q For how long had Larry been after you to undergo 18 the auditing? I 79 MR. KROPP: Objection. Mischaracterizes the witness's i 20 testimony that Larry had ever been after her to undergo 21 auditing. I 22 THE WITNESS: When we went out to the wedding. 23 Q BY MS SCHLOSSER: Did your son ask you numerous I 2~ times to undergo that auditing on that occasion when you ~ 25 came out to Los Angeles for the ceremony? KEI~Y CI LLET. Ce%l~ No. 94 I A He did. 2 Q Would you say that he pushed you toward auditing? 3 A Yes, I would. I ~ Q Would you say that he was wrapped up in Scientology I 5 at the time -- 6 MR. KROPP: Objection. Vague and ambiguous as to I7 what's meant by "wrapped up." 8 Q BY MS SCHLOSSER: -- that he repeatedly asked I 9 you to undergo the auditing? I 10 A He did. 11 Q Did Scientology and the auditing process used I12 in Scientology at the time you came out to Los Angeles 13 for this ceremony occupy a great deal of his conversation? I I~ A No. I 15 Q Would you describe the way he looked and acted 16 when he spoke about you undergoing the auditing. I 17 A He wanted me to go to -- into auditing to find 18 out what it was all about. I ;9 MR. KROPP: Objection. Motion to strike as nonresponsive. i 20 Q BY MS SCHLOSSER: Can you describe the way he 21 looked and acted about the whole subject of you undergoing 22 auditing. 23 A Very serious. 24 Q Did you find him staring at you a great deal 25 at the time you came out to that ceremony in Los Angeles? KERY GILLET. CSR No. 3352 I 95 A Yes, he did. 2 Q Did that make yolJ uncomfortable? 3 A Vet}, uncomfortable. I Z O For how long had he engaged in that staring 5 behavior with you before you came out to the wedding? 6 MR. KROPP: Objection. Vague and ambiguous as to I7 what's meant by staring behavior. 8 THE WITNESS: Many times. I 9 Q BY MS SCHLOSSER: Can you describe his staring I 70 at you any more specifically than staring at you a great ;1 deal? I12 A Not really. ~3 Q So you're comfortable with my use of that? I ;~ A Uh-huh. i ~5 Q Had you noticed him staring at any other indivi- ~5 duals at that time or before that time? I ~7 A His wife. ;8 Q Edie? I 19 A Correct. ~ 20 Q Anyone else? 27 A His father. ~ 22 Q Was there something unusual about the staring? 23 A It wasn't my son. ~ 2~ Q At the time did you attribute it to Scientology 25 and Scientology's influence on him? KERY GI LLET, CSR No. 3352 fi 96 ; MR. KROPP: Objection. Vague as to when. This apparently fi 2 was a course of conduct which existed over a course of 3 time. fi ~ THE WITNESS: Yes, I did. fi 5 Q BY MS SCHLOSSER: And for how long before you 6 came out to Los Angeles for that ceremony had you attributed fi 7 this unusual staring behavior pattern of Larry's to his 8 involvement with Scientology? fi 9 A I don't recall that. ~ ;0 Q Did you find your auditing experience with Scientology 1; upsetting? ~ ;2 A Very. 13 Q You mentioned earlier that they asked you questions I 1~ about your childhood and about your family life and your i 15 relationships with the people who are most intimate to 15 you. I 17 MR. KROPP: Objection. Vague and ambiguous as to 18 what's meant by "they." I 19 Q BY MS SCHLOSSER: You mentioned earlier that 20 the Scientologist who was conducting the auditing that O 21 you underwent on this one occasion asked you numerous I 22 questions about your early childhood and your relationship 23 with the people who were most intimate to you. I 2~ Did they repeatedly ask the same question about 25 those intimate areas of your life? KERY GILLET. CSR No. 3352 I | 97 ~ MR. KROPP: Objection. Vague and ambiguous since t 2 you're referring to a single auditor; and now you've gone 3 back to referring to they. I ~ THE WITNESS: Over and over. I 5 Q BY MS SCHLOSSER: Was it one individual who 6 questioned you? I7 A One individual. 8 {} When you say over and over, did they repeat I 9 the same question over and over? I ;0 A Correct. ;~ Q How did the individual act toward you while I ~2 questioning you? 73 A Puzzled. 7~ Q A puzzled look on the person's face? ~5 A Uh-huh. ~6 Q Is that a yes? 77 A Yes. ;8 Q Were they searching your face for a response? ;9 A I'm sure. ~ Q Do you remember the person looking at you very 2~ intensely? 22 A Staring. 23 Q Was it a similar stare to the way Larry stared? 2~ A Yes, it was. ~ E Q Did you feel that you were being interrogated? KERY GI LLET, CSR No. 3352 4. ~ m 98 ; A Yes. I 2 Q Since you had that experience, have you thought 3 of it many times? ~ A' Yes, I have. 5 Q Has it upset you when you thought of it? 5 A Yes, i't has. I 7 MR. KROPP: I would object to this line of inquiry 8 as not being calculated to lead to the discovery of admissible i 9 evidence. i 10 MS SCHLOSSER: I thought you were interested 11 in what information she had about Sciento!ogy, Mr. Kropp. I 12 MR. KROPP: Indeed t am, but I don't understand any ;3 relation between the witness's emotional reactions to I I~ an experience and the allegations in the second amended I 15 Complaint. 16 MS SCHLOSSER: Yesterday you were interested in personal I;7 knowledge of Mr. Wollersheim. I'm surprised you didn't 18 ask about the personal knowledge of Mrs. Wollersheim in I 19 this regard. i 20 Q At the time you underwent this experience and 21 when you thought about it since, was it your belief and I 22 still your belief that they were attempting to find a 23 handle on you during that auditing? ~ 2Z MR. KROPP: Objection. Vague as to when -- ~ 25 THE WITNESS: Yes. KE1)YGILLET. C&R No. 3352 I 99 MR. KROPP: -- and what is meant by "handle." 2 Q BY MS SCHLOSSER: When I use the term "a handle 3 on you," can you explain how you understand that. ~ ~ A- I would take that as unhappiness and control ~ 5 with the family. 6 Q It was you~ understanding that the auditor dealing ~ 7 with you was attempting to find an area of your life which 8 would give him. control? 9 A Uh-huh. 10 Q Is that a yes? 11 A Yes. 12 Q And is that still your opinion today? 13 A Yes, it is. I~ Q And you base that opinion on the fact of the 15 way he behaved with you? 15 A Yes,. 17 Q On the fact of the type of questions he asked? 18 A Yes. 19 Q On the way he continually repeated the same 20 questions? 2~ A Yes. ~ 22 Q And the fact that he was dealing in intimate 23 areas of your life? 24 A Correct. 25 Q Anything else? I KERY GI LLET. CSR No. ~352 IIIIIIIIII,A s~ ......~ ,~.,,o~,,.~ s ....., IIII . ~ 100 I A No. ~ 2 Q Have you ever had auditing done again? 3 A Never. ~ ~ Q' Have you made any effort to have auditing again? ~ 5 A No, I haven't. 6 Q When was the last time you saw Larry? ~ 7 A A month ago. 8 Q Could you describe his personality for us a i 9 month ago. I ;0 A Beautiful. Warm, back to the family. 11 Q Was he energetic? I12 A Very. 13 Q Enthusiastic? I 1~ A Very. I 15 Q Looking to the future? 15 A Very much so. I 17 Q Was he compassionate about family members? 18 A Very much so. I 19 Q Did he engage in any of the staring behavior i 20 that you mentioned earlier? 21 A None at all. I 22 Q You just mentioned that you considered him to 23 be back tothe family; however, he does not live in the I 2~ same town as you and his father live, does he? i 25 A No, he doesn't. I KEDY Gl LLET, Cc~D No. 3352 101 7 Q You meant that in a psychological sense? 2 A That's correct. 2 Q From your experience in auditing, is it your opinic ~ that Scientotogy is dangerous? 5 MR. KROPP: Objection. Lack of foundation, this 6 witness has any ability from one experience to draw any 7 conclusions as to whether any technique is dangerous or 8 not. 9 THE WITNESS: Very dangerous. 10 Q BY MS SCHLOSSER: Why do you say that based 11 upon your own experience? 12 MR. KROPP: Same-objection. 13 THE WITNESS: Because they dwell into personal families 1~ and are seeking for things that are unhappy in your life. 15 Q BY MS SCHLOSSER: And in your opinion, why are 15 they seeking things that are unhappy in your life? 17 A Because they can probably -- my analysis, that 18 they would be able to make your life a lot better in being i 19 in Scientology. 20 Q I'[n sorry. I don't think that was clear, Mrs. 2V Wollersheim. Could you explain to us why you think they ~ 22 are looking for a means of controlling an individual through 23 the auditing -- 2~ MR. KROPP: Objection. Calls for speculation. 25 Q BY MS SCHLOSSER: -- from your experience, now? KERY GI LLET, CSR No. 3352 102 ~ MR. KROPP: Same objection. Calls for speculation. 2 THE WITNESS: I don't know that. 3 MS SCHLOSSER: Could I have my next-to-the-last qu~stic 4 read back. 5 [The question at Page 101, Line 15 6 is read.] 7 THE WITNESS: I really don't know why they're seeking 8 that. 9 Q BY MS SCHLOSSER: But you felt that they were l0 probing into areas of your life that were intimate looking II for some sort of a handle on you? 12 A Uh-huh. ~3 Q Is that a yes? ;4 A Yes. ;5 Q When I use the term "looking for a handle on ;6 you," do you understand that I mean looking for a means ~7 to control? ~8 A Uh-huh. ;9 Q Yes? A Yes. 21 MS SCHLOSSER: For the record, the reason I'm saying 22 "yes" is because Mrs. Wollersheim has just responded severaS 23 times withan uh-huh. 2~ MR. KROPP: It's not the way we're used to talking 25 in everyday life. KERY GILLET, CSR No, 3352 I 103 I Q BY MS SCHLOSSER: At some point in time, did ~ 2 you and your husband take into your home Edie Wollersheim 3 and her son? M 4 A' Yes, I did. I 5 Q Was there a particular purpose in your taking 6 the two of them in? 7 A They were bottn physically and mentally ill. 8 MR. KROPP: Objection. Move to strike the response. I 9 The question calls for a yes or no response. ~ 10 Q BY MS SCHLOSSER: There was a purpose behind 11 taking them in? A That's correct-, 13 Q And the purpose behind taking them in was they ~ ;~ both needed your help because they were physically and I 15 mentally ill? 16 A That's correct. ~ 17 Q And for how long did Edie and Buff live with 18 you? 19 A Between nine months to.a year. 20 Q And where did the two of them come from b~~nre 21 ~~ I 22 A California. 23 Q -- living with you? I 2~ A L.A. I 25 Q Did Edie mention to you what they were doing I KERY GI LLET, CSR No. 3352 IIIIIIIIII r~ s~o~,~ ~.,,o,,,.~ s ..... I 104 I in Los Angeles just before they came? 2 A She was in the hospital. 2 Q Did she mention to you where Buff was directly ~ before'them coming out to you? 5 A Some home for children. 6 Q Was it a Scientology home? 7 A That's correct. 8 MR. KROPP: Let me interpose my objection that it's 9 vague and ambiguous as to what's meant by. a Scientology ~ 10 home. ~1 Q BY MS SCHLOSSER: Did Edie tell you when she 12 came to live with you that she and her son had been living 13 in a Scientology house or community house just before 1~ she went into the hospital? 15 A Correct. 15 Q And will you understand from this point on that 17 my Use of Scientology house is meant to refer to that 18 building that Edie told you about when she came to live 19 with you and your husband? 20 A Yes. 21 Q Why did Edie say that she had been in the hospital 22 directly before coming out to stay with you? 23 MR. KROPP: Since I anticipate it'~ going to'be a' m 2Z. long line of questionihg, let me just at this point make 25 what will be a continuing objection as to this line of K ERY GI LLET. CSR No. 3352 IIIIIIIIII ~ s ....... ~ ~o~,,.~ s 105 ; inquiry being beyond tbe scope of direct examination and 2 not calculated to lead to the discovery of admissible 3 evidence. ~ MS SCHLOSSER: Could ! have the question read back 5 and if there was an answer. [The question at Page 104, Line 21 i7 is read.] 8 THE WITNESS: Burned. m 9 Q BY MS SCHLOSSER: Was she badly burned? i 10 A Very badly burned. 11 Q Were you able to see the results of her burns 12 yourself when she got there? 13 A Yes, I was-. ~ 1~ Q Did Edie tell you that, while she was in Los ~ 15 Angeles, that all the time that she was out here with ;6 your grandson that she had lived at the Scientology house ~ 17 and had worked for the Chu'rch. of Scientology? ;8 A Yes. ~ 19 Q Did she mention to you that she had worked for 20 the Church of Scientology of California? ~ 21 A Yes, she did. ~ 22 Q Did she tellyou that, between the time of the 23 ceremony that you and your husband came out for in Los ~ 2~ Angeles and the time that she was burned, that Larry no 25 m longer lived at the Scientology house with she and Buff? KERY GI LLET. CSR No. 3352 Illlllllll r~ s~ ......d ~,~o~,,~ s ...... II II ~ 106 I A Correct. ~ 2 Q Now, when I use the term "she told you after ~ 3 she came out to live with you and your husband," what 4 I'm speaking of is just that nine-months-to-one-year time. ~ 5 A That's correct. 6 Q Do you have a recollection of that nine-months- ~ 7 to-One-year time that you and your husband took her into 8 your home with your grandson being in 19747 ~ 9 A I would say around that time. l0 Q Did she tell you then that she had been badly ~ burned on the premises of the Scientology house? ~ 12 A She did. ~3 Q Did she tell you that Larry had been living I ~ on a Scientology boat for the last -- I ~5 A A ship. ~6 Q -- three weeks To a month before she was burned? I~7 MR. KROPP: Objection. Vague and ambiguous as to 18 what's meant by a Scientology boat. I ;9 THE WITNESS: Ship. i 20 MS SCHLOSSER: Ship. Okay. 2V Q Did she tell you that it was a ship that belonged I 22 to the Church of Scientology? 23 A She did. ~ 2~ Q When you got to see her and Buff when they arrived ~ 25 back in Milwaukee, can you describe Buff's physical appearance. i i 107 A Pale, thin, unkept. 2 Q Did he have any boils or scabs or anything unusual 3 or his skin? 4 A' Scabs all over his mouth, sores on his rectum. 5 Q Anything else? 6 A Are you referring to Edie? 7 Q No. Just to Buff right now. 8 A That was about all. 9 Q Did he seem to be nervous to you? ~0 A I would say he was nervous. ~ Q Emotionally upset? 12 A Emotionally [nods head]. And he clung onto ! 13 his mother. ~ Q He was about three years old at the start of ~5 this period, wasn't he? ~6 A Or two and a half. ~7 Q Was there any medical treatment given to Buff? 18 A Yes, there was. 19 Q What was that? 20 A Edie's doctor prescribed something for his sores. 2; Q Some sort of ointment or salve? 22 A Or some medication. I don't recall. 23 Q And did you take care of him yourself? 2~ A Yes, I did. 25 Q How long did it take before his condition cleared KERY GI LLET, CSR No. 3352 ~ 108 1 up, if it did? ~ 2 A Oh, about two weeks. 3 Q Did the doctor tell you what had caused the ~ ~ sores and the scabs on your grandson? I 5 A I didn't communicate with the doctor. Edie 6 did. I don't know. I7 Q Did Edie describe to you, then, when she was 8 living with you that it was difficult for her to get Buff I 9 out of the Scientology house to bring him to Milwaukee? I ;0 A She did. II Q Could you describe to us what she told you. I;2 A She had to get-either a sheriff or a policeman ;3 to go with her to get him out of the house. I 1~ Q Did she describe why it was necessaryto do i 15 that? 16 A No, she didn't. She needed help. I 17 Q Did she describe why she needed help? 18 A No, she didn't. I ;9 Q Did she tell you that Scientology people at 20 the house would not release Buff? I 2~ A She did. ~ 22 Q And that was why she needed the local Los Angeles 23 authorities to get Buff back? ~ 2~ A Uh-huh. And fear. 25 Q Did she describe her financial condition to KERY GILLET. CSR No. 3352 109 1 you at the time of the burn incident? 2 A Yes, she did. 3 Q And what did she say? ~ A' She had some money hid somewhere in the commune 5 and was able to make all the calls, the necessary calls, 6 because she had no money at all. 7 Q Necessary calls for what? 8 A Calls to the hospital to talk to the nurse and 9 calls to the sheriff's department or the police department. 10 I don't recall which one it was but either one of them. Q And that she had to make these calls once she ;2 made the decision to come to Milwaukee? 13 A Correct. I ;~ Q In the course of your conversations with her I ~5 during the time she lived with you and your husband, did 15 she tell you how much an hour she had been making with m 17 the Church of Scientology of California? 18 A My recollection was 25 cents an hour. 19 Q And in exchange for the 25 cents an hour she 2D worked -- 2~ A She was to get board and room.' 22 Q At the Scientology house? 23 A At the Scientology house. ~ 2~ Q Anything else? Did she get services from them 25 m such as auditing? KERY GILLET. CSR No. 3352 IIIIIIIIIIr~, s~o,,~ ~.~o,,,.~ s ...... ~ ~s~.~ ~ 110 I A I don't recall that. I think she paid for the I 2 auditing. 3 Q How did you first learn about the burn incident? ~ z A The call from L.A. The nurse called my husband. I 5 Q There was a nurse? 5 A At the hospital. They called my husband direct. 7 Q Was that County USC Medical Center? 8 A I don't recall because they talked to Larry. I 9 Q And the nurse asked you to take Edie into your I ~0 home? ~ A Correct. ~2 Q Did you speak fo Edie directly at that time? 13 A No, I didn't. 14 Q Did your husband that you're aware of? 15 A Not that I recall. ;6 Q So your dealings were through the nurse at that ~7 time? ;8 A He dealt mostly with the nurse. ;9 Q Did the nurse tell you that Edie was listed 20 as a charity case at the hospital? 2; A Not that I recall. 22 Q Did she tell you that no one in Los Angeles 23 would take Edie in for her care? 24 MR. KROPP: Objection. Lack of foundation. The 25 witness hasn't testified that she talked to the nurse. KERY GI LLET. CSR No. 3352 I 111 I Q BY MS SCHLOSSER: I'm sorry. Did your husband I 2 relate to you that the nurse s~id that no one would take i 3 Edie in in Los Angeles? ~ A' I don't recall. I 5 Q Was it your understanding when Edie came out 5 to Milwaukee that she had no one in Los Angeles who would I 7 take her in? i 8 A Yes. That was my understanding. 9 MR. KROPP: Objection. Calls for speculation. B 10 Q BY MS SCHLOSSE]~: And where did you get that 11 understanding? A From my husband: 13 Q What did he say? ~ 1~ A He thought we had to help her. She needed help. ~ 15 Q But he also told you that no one in Los Angeles 16 would take her in? ~ 17 A Correct. 18 Q Did you get a firsthand look at the burns that 19 Edie had when she lived with you? 20 A Yes, I did. 21 Q were you primarily the person who was taking ~' 22 care of her? 23 A Yes, I was. 2~ Q Did you change her bandages every day? 25 A Yes, I did. KERY Gl LLET. CSR No. ~52 ~ 112 I Q Could you describe for us how much of her body ~ 2 was burned and where. 3 A The upper part of her chest and around 28% of 4 her body was burned. ~ 5 Q Was that a third-degree burn? 6 A First, second, and third degree. 7 Q For how long did she require continuous care 8 from you? I 9 A I don't recall, but it was several months; several I 10 months. 11 Q She also had trips to the hospital? I12 A Twice a week, 13 Q And what treatment did she receive at the hospital? I 1~ MR, KROPP: Objection, Lack of foundation, Calls I 15 for speculation as to whether this witness has any knowledge 16 about what treatment was received at the hospital., I 17 Q BY MS SCHLOSSER: Do you know what treatment 18 she received at the hospital? ~ lg A No. They changed her bandages and put their i 20 medication on it. 21 Q How do you know that? I 22 MR. KROPP: Motion to strike as nonresponsive. 23 THE WITNESS: Edie conveyed that to me. I 2~ Q Edie told you that, when she went to the hospital 25 twice a week, that they changed her bandages and the dressing K ERY GI LLET, CSR No. 3352 I 113 ; on the bandages? 2 A Uh-huh. 3 Q Were those markings that she had on her upper ~ torso,'did they go around to the back as well? 5 A Partially. 6 Q Did they also involve both arms? 7 A Correct. 8 Q How much of the arms? 9 A Up to the elbow. l0 Q So basically the burns went from her waist to l; her neck? 12 A From the top of her breast to the upper part 13 of her arms around this area [indicating]. I ;z Q Did you watch the burn marks healings? I 75 A Yes, I did. T6 Q They left scars? I ~7 A Very badly. ~8 Q Could you describe the way her skin looked after I 19 the healing was over. 20 A Large indentations in her arm, almost holes I 2V in her arm. ~ 22 Q And also bubbly? 23 A Yes. 2~ Q Did you ever have a description from any medical 25 person of what her condition was called? KERYG~LLET. CSRNo. 3352 IIIIIIIIII ,~s~o~,~o.~o~o,..~.~,~ Illl 114 I A Well, not medically. 2 Q Did you hear anyone describe it? 3 A No. ~ Q Are you familiar with the term keloiding? 5 A Yes, I am. 6 Q Did it appear -- 7 A She had large keloids all over her body. 8 Q And they have been permanent ever since? 9 A That's correct. 10 Q I'm going to go on to a little bit of a delicate 11 area. 12 You tell me if it gets too sensitive for you; 13 all right? 1/-. A Yes. 15 Q Being a person who changed her bandages on a 16 daily basis, can you describe for us what Edie's reaction 17 was to being touched. 18 A Painful, very painful. 19 Q She visibly winced? 20 A Cried. 21 Q So it was difficult to change her bandages? 22 A It was. 23 Q And you had to be extremely tender in doing 2~ it? 25 A She had to soak in the tub for approximately KERY GILLET. CSR N~. 3352 115 ~ half an hour. And I had to remove them very gently. 2 It was difficult. 3 Q And how long did this process take very day? ~ A' I changed them twice a day when she -- other 5 than when she went to the hospital at about 1:00 o'clock 5 and then when I got home from work at about 7:00 every 7 day. 8 Q And this was very difficult on you? 9 A It was difficult for me because of the pain ;0 that she endured while I was doing it. ;l Q Would you like to take a little break? ~2 A I would. 13 MS SCHLOSSER: Let the record reflect again that ;~ Mrs. Wollersheim is on the verge of tears; and I'm going ~5 to call a break. 16 [A b~ief recess is taken.] ;7 Q BY MS SCHLOSSER: Did Edie describe to you that, 18 after she initially went into the hospital, that she went back to the Scientology house for some care? ~ 20 A Yes, she did. 2~ Q Did she describe to you what happened while 22 she was there for care? 23 A Yes, she did. 2~ Q Did she tell you when she lived with you and 25 your husband that she received poor care at the Scientology 'l ,~ KEDY GI LLET, CSR No. 3352 IIIIIIIIII ~ s.o.,~..~ ~..o,,,~ s.,~,~ IIII 1 house? ~ 2 A She did. 3 Q And the care was so poor that she had to sign ~ ~ herself back into the hospital? I 5 A Correct. 6 Q And that she had a fear of being hurt at the I 7 Scientology house? 8 A Yes, she did. I 9 Q Did she mention to you how long she was at the I 10 Scientology house in between visits to the hospital? 11 A I don't recall. I 12 Q Did she tell you the name of the individual 13 who was given the job of' caring for her at the Scientology I 1~ house? I 15 MR. KROPP: Objection. Lack of foundation that any 15 individual had such a job. I 17 THE WITNESS: I don't recall. 18 Q BY MS SCHLOSSER: Did she mention to you whether I 19 it was a man or a woman who took care of her at the Scien- i 20 tology house? 21 A I don't recall. I 22 Q Did she tell you that, instead of tenderness 23 and physically caring for her, that she received bad treatment I 2~ at the Scientology house? t 25 A She did. I KERY GI LLET. CSR No. 3352 117 ~ Q Did she specifically describe to you that her 2 bandages had been ripped off of her painful burns by an 3 individual at the Scientology house? ~ A She said that they weren't careful in removing 5 her bandages. 5 Q Did she use any words such as "ripped off," 7 "pulled off," or indicate to you that the bandages were 8 not being properly removed? 9 A They weren't properly removed. ;0 Q And that it was extremely painful to her -- ~l A Very painful. ;2 Q -- that treatment they were -- ~3 Let me finish the question. I know again it's ;~ a sensitive area. And it's very natural that you would 15 answer as you are, but the record won't be clear -- ~5 A All right. 17 Q -- if we don't wait until each other finishes. 18 Did she describe to you that their treatment 19 of her specifically -- strike that. 20 Did she describe to you that the Scientologists' 2/ house treatment of her burns was particularly painful 22 to her? 23 MR. KROPP: Objection. Asked and answered. 2~ THE WITNESS: Yes, she did. 25 Q BY MS SCHLOSSER: And it was particularly painful KERY GILLET, CSR No. 3352 4s .~ I 118 I because the bandages were improperly removed with roughness? I 2 A Correct. i 3 Q Did she describe to you that, while the bandages ~ were being roughly removed, that she was told that such I 5 an accident would not have occurred to her if she was 6 a good person? ~ 7 A Yes, she did. 8 Q Did she say anything else about being told that? ~ 9 A No, not that I recall. ~ ;0 Q Did she use the word "pulled in" in describing I; what the Scientologist person caring for her had said? A I don't recall._ 13 Q Do you recognize the statement that you pull ~ 1~ in what you deserve as a Scientologist statement? ~ 15 A I don't recall. 16 Q Did she relate to you while she was being treated i 17 at the Scientologists' house, if I can use that word loosely, 18 that they continually told her what a bad person she was? 19 A Yes, she did. 20 MR. KROPP: Objection: Vague as to what period of 2V time we're talking about and who "they" are. 22 MS SCHLOSSER: I think the period of time is clear. 23 But let me go over it once again. 2~ Q What we're talking about here and what was told 25 to her about being a bad person occurred in the time between KERY GI LLET. CSR No. 3352 119 the hospital visits after the burn incident? I A Yes. 2 Q And she related to you that the persons who 3 were telling her what a bad person she must be or this whole burn incident would not have happened to her were 5 Sciento!ogists at the Scientology house? 6 A Yes. 7 MR. KROPP: Objection. Mischaracterizes the testimony '~ 8 in that I don't believe the witness has testified that 9 more than one individual made such a statement to her. l0 Q BY MS SCHLOSSER: Did Edie relate to you that II a number of people had made this statement to her at that ;2 time? 73 A No. ;~ Q Did she relate one individual in particular? 75 A Yes. ;6 ~7 Q And that was the same individual who had been 78 taking care of her at the -- ~9 A Correct. 0 -- Did she relate to you that the reason that Larry 2~ 22 was not living at the Scientology house at the time of 23 the burn incident was because he had been separated from her by Scientology? 2~ 25 A Correct. KERY GILLET. CSR No. 3352 IIIIIIIIII ~A s~,or,,,.,,,,~ ,:,e~,or,,,,g Se,,,,ce~ IIII 4s~ 120 ; Q Did she relate to you that the Church of Scientology 2 was deliberately separating Larry from her in an attempt 3 to break up their relationship? ~ MR. KROPP: Objection. What's meant by deliberately; 5 what's meant by deliberately separating them; and 6 objection, calls for speculation as to motivation of any 7 conduct engaged in by any persons; and it's also vague 8 and ambiguous as to what's meant by Scientology, who did 9 whatever it is the question is seeking information about. ;0 THE WITNESS: That's what she thought. 11 Q BY MS SCHLOSSER: Did she relate to you that 12 Scientology was separating her from Larry because she 13 was not a good Scientology believer? 1~ A Correct. 15 Q Did she relate to you that she had questioned 16 the beliefs or doctrines of Scientology before Larry and 17 she were separated? 18 A She did. ~ 19 Q Did she relate to you that she had been told 20 by people at the Scientology house that she was not a ~ i~ good Scientologist? ~ 22 A No. I don't recall. 23 Q Did she relate to you that she had been abused ~ 2~ by the Scientologists at the Scientology house for her 25 questioning of Scientology? ~ KERY GI LLET, CSR No. 3352 IIIIIIIIII ~,~ s~o~,~ ~o.,,',~ a .....~ 121 7 MR. KROPP: Objection. Lack of foundation. This 2 whole line of quest'ioning has been, "Did she relate to 3 you that/'which infers that a foundation has been laid ~ for this line of questioning rather than a question which 5 says "Did she relate to you whether something happened," 6 which doesn't infer that an' event had in fact occurred. 7 MS SCHLOSSER: Could you read the question back to 8 us, please. 9 [The last question is read.] 70 THE WITNESS: I don't recall 77 Q BY MS SCHLOSSER: However, from the time that 72 Larry was quartered at the Scientology ship through the 73 present day, she and he have never been together again 7~ in a husband-wife relationship? 75 A Correct. 76 Q Did she describe to you that or whether she 77 had problems in accepting auditing which is part of Scien- 78 tology? 79 A Yes, she did. 20 Q And what did she say? 27 A She was unhappy with it. 22 Q Do you recall her mentioning that she fell asleep 23 during auditing? 2~ A Yes, I do. 25 Q Do you recall her saying that she never progressed 122 ; very far in the auditing levels because she found it boring? 2 A She found it boring. 3 Q Did she say those things to you before she left ~ Milwaukee to go out to Los Angeles? 5 A No. 6 Q She said those things to you -- 7 A After. 8 Q -- after when she came to live with you and 9 your husband? 10 A When ! took care of her. 11 Q At your house? 12 A At my home. 13 Q Do you recall Larry before they left for Los I~ Angeles to live out here to be with Scientology telling 15 you that Edie had problems in auditing? 16 A I don't recall. 17 Q Did Edie tell you whether Larry visited with 78 her in the hospital after the burn incident? 19 A Yes, she did. 20 Q And what did she tell you about that? 2V A She told me that he visited her once and that 22 he did not believe she was ill. 23 Q He said Ito her he did not believe she was ill? 2~ A Correct. 25 Q Did she mention to you that, on that visit, KERY GILLET. CSR No. 3352 ~ 123 ~ that he failed to show any compassion for her? ~ 2 A None whatsoever. ~ 3 Q He was cold? ~ A Very cold. ~ 5 Q That he specifically asked her not to sue the 6 Church of Scientology over the burn incident? ~ 7 MR. KROPP: Objection. Lack of foundation. 8 THE WITNESS: He did. ~ 9 Q BY MSSCHLOSSER: And that he was told by Scientologiststhat ~ l0 if he allowed her to sue the Church of Scientology over II the burn incident, that he would be thrown out of Scientology? ~ 12 MR. KROPP: Objection. Lack of foundation. And objectio~ ~3 What is meant by Scientologists. I ;~ Eleanore, when I interpose an objection, we're I 75 going to have a difficult record if we both talk at the ;6 same time. I understand the question's being asked of I ;7 you. But in the interest of a clear record, I need to 78 interpose an objection. And since I'm across the table, I 19 I can't put my hand on your arm as counsel did and ask i 20 you to wait until I finish. 2V MS SCHLOSSER: Objection. I haven't touched Mrs. I 22 Wollersheim's arm. In fact, I'm three or four feet away 23 from her. ~ 2~ MR. KROPP: That's right. You have not done that ~ 25 during cross-examination. But during the direct examination KEllY Gl LLET. C&D No. 3352 I 124 I on several occasions, when Mrs. Wollersheim was asked a 2 question, counsel would put her arm on yours as a suggestion 3 that you wait until the objection was made. ~ MS SCHLOSSER: I object to what you're saying. I 5 object to your characterization unless you're a mind reader, ~ 6 Mr. Kropp. 7 MR. KROPP': Let me indicate, nonetheless, that I 8 observed that there were hand gestures given to you which 9 aided you in not -- 10 MS SCHLOSSER: Now we're going into the signal corps, 11 Mr. Kropp? 12 MR. KROPP: Mrs. Wollersheim, did counsel ever put 13 her arm on your arm when'I asked you a question as an ~ indication that perhaps you should wait until the objection ~5 as made before you answered my question? ~6 MS SCHLOSSER: Objection, Mr. Kropp. Again you're F ~7 asking a question that requires Mrs. Wollersheim to read ;8 my mind. You're indicating physical events that I don't ;9 recall occurring. 20 MR. KROPP: Okay. MS SCHLOSSER: And you're also taking up my questioning b 22 time. '~ 23 MR. KROPP: I'm sorry that you don't recall. But 2~ I'm going to nonetheless ask that, if I make an objection, 25 So the record is clear, to wait until I finish making ~ KERY GI LLET. CSR No. 3352 IIIIIIIIII ~ s .........o~or,,ng s .....~ II II ~ 125 I the objection. Then once you begin answering, I won't' ~ 2 interrupt you either. Okay? 3 THE WITNESS: I'll try. ~ ~ MR. KROPP: Okay. ~ 5 Q BY MS SCHLOSSER: Did she tell you that Larry 6 had asked how she was feeling on this one hospital visit? 7 A He didn't =sk. 8 MR. KROPP: Objection. Motion to strike as nonrespon- ~ 9 sive. ~ ;0 Q BY MS SCHLOSSER: She related to you that Larry 11 had not even asked how she was feeling at the hospital ~ 12 visit? 73 A Correct. ~ 7~ Q Did she tell you that he did not take her in ~ 75 when she needed treatment -- 16 MR. KROPP: Objection. Vague and ambiguous -- ~ 17 Q BY MS SCHLOSSER: -- following the burn incident? 78 MR. KROPP: I apologize, counsel. 19 Objection. Vague and ambiguous as to what's ~ 20 meant by "taking her in." 21 THE WITNESS: She did. ~ 22 MS SCHLOSSER: Can I have the question read back, 23 please. ~ 2~ [The last two questions are read.] 15 Q BY MS SCHLOSSER: Can you answer the question? KERY GILLET, CSR No. 3352 ~ 126 7 A Yes. ~ 2 Q And she specifically told you that he refused 3 to take her in or to give her any treatment? ~ ~ MR. KROPP: I'll renew my objection as being vague ~ 5 and ambiguous. 6 THE WITNESS: That he didn't ask about any care other 7 than the care that she had received in the hospital. 8 Q BY MS SCHLOSSER: During the time that she lived ~ 9 with you and your husband, did she speak about couples ~ ;0 being deliberately broken up by Scientology? ;l A She did. ~ ;2 Q Did she state that it was her opinion that that ;3 was a Scientology policy? ~ ;~ A She did. 15 Q Did she state to you, while she lived with you 16 and your husband, that Scientology deliberately broke I 17 up these couples when one of the couples questioned the 18 worth of Scientology? I 19 MR. KROPP: Objection. Vague and ambiguous as to 20 what's meant by breaking up couples and what's meant by ~ 2V questioning Scientology. ~ 22 THE WITNESS: She did. 23 Q BY MS SCHLOSSER: Did she relate to you that ~ 2~ these couples were deliberately separated by Scientology 25 when one of the parties to the relationship had doubts J KER~' Cl LLET, CSR No. 3352 127 I or questions about Scientology? 2 MR. KROPP: Objection. Vague and ambiguous as to 3 what's meant by Scientology undertaking an action since ~ Scientology is a system of beliefs and not an individual. 5 MS SCHLOSSER: Could I have the question read 6 back, please. 7 [The last question is read.] 8 THE WITNESS: She did. 9 Q Did she mention any instances of that happening 10 other than her own relationship with Larry? 11 A No. 12 Q After she obtained treatment in Milwaukee for 13 her burns, did she undergo any other therapy for her burns? It A She had physical therapy on her arm. She didn't 15 have the movement of one of her arms, and she did go through 16 therapy. 17 Q And you were aware of her going through therapy 18 while she lived with you and your husband? 19