Ray Jeffrey

Ray Jeffrey Files Petition to Depose Mark & Monique Rathbun on their Finances

July 24, 2017: As reported today by Tony Ortega, attorney Ray Jeffrey has filed a petition with the District Court of Bexar County, Texas to examine the financial records Mark & Monique Rathbun. This is a matter arising from Monique Rathbun’s sudden and unexpected firing of her legal team and dropping her legal case against David Miscavige et. al.

The poster TX Lawyer commented on the Underground Bunker today:

Just to put this in context, this is what’s known in Texas civil litigation as a Rule 202 petition, which allows a potential plaintiff to obtain a court order to take a deposition even where a lawsuit is not pending, so long as you are doing it to investigate a potential claim or suit (or to preserve the witness’s testimony for use in an anticipated suit). They’re a pretty common procedure here in Texas, and most judges routinely grant them when requested. I do note that those document requests are awfully broad, so I would not be surprised if the judge pares them back if the Rathbuns object.

Tony is right that the Bexar County courts use a rotating docket for motions hearings, so you rarely know who’s going to decide your motion before you show up for the 9 am cattle call. And the 15 days referenced in the motion is the minimum amount of notice you have to give to the prospective witness, after the petition has been served on them, before the hearing can be held. It’s unclear whether the Rathbuns have been served yet, but you would ordinarily expect service to have happened by now. So whoever’s watching the docket sheet should look out for return of service and any notice of hearing.

As a practical matter, no halfway competent attorney would ever sue a client on an unpaid contingency fee unless they had a pretty good idea that some kind of payment or exchange was made. If the Church did make any kind of payment to Marty, either as a settlement or for his recent propaganda services, it’s going to be found pretty readily.

And here’s something to keep an eye on: If and when the Rathbuns respond to the 202 petition, who is their lawyer going to be?

Related documents:

1. Document posted by Tony Ortega:

Marty1.4

2. Copy of online documents from the Bexar County Court portal:

Marty1D

How Dare You Call Captain Miscavige “Captain Miscavige!”

Recr3The Church of Scientology is managed and controlled by the Scientology paramilitary group known as the Sea Organization, or simply the “Sea Org” as it is called in the Church.

Founded in 1967 by L. Ron Hubbard, Sea Org members sign a one-billion year contract to serve Scientology lifetime after endless lifetime. During his lifetime. Hubbard appointed himself Commodore of the Sea Org. Hubbard is often referred to in the Church as “the Commodore.”

As a paramilitary group, Sea Org members have ranks and wear naval uniforms. These uniforms include medals, ribbons, gold braid, and regulation caps. Sea Org life is brutal and includes 100 hour work weeks; low or no pay; sleep deprivation; verbal abuse; physical abuse; and even a form of imprisonment and manual labor called the RPF.

Dr. Stephen Kent’s paper on the RPF offers a rare scholarly insight into Scientology’s gulag.

For very serious legal reasons, Church of Scientology leader Captain David Miscavige wants to distance himself as far as possible from his Sea Org rank and title.

To this end, Captain Miscavige and his attorney are arguing that the “Sea Org” is an essentially non-existent unincorporated membership association whose ranks mean nothing. As we will see in the deposition below, Captain Miscavige’s attorney does not want anybody to call his client “Captain Miscavige.”

For this reason alone the entire world should — as befitting a leader of his rank — call Captain David Miscavige by his rightful title: Captain David Miscavige.

*****

From the November 20, 2013 deposition of Ensign Allan Cartwright, Director of Legal Affairs, Office of Special Affairs, Church of Scientology in Rathbun v. Miscavige et. al.

We direct the reader’s attention to the section in which Rathbun’s attorney Ray Jeffrey mentions Captain David Miscavige to Sea Org member Ensign Allan Cartwright:

…Q. (By Mr. Jeffrey) Item No. 2 is related in — it’s the same sort of category, but it relates to Captain David Miscavige instead of just RTC. Do you see that?

A. I see that. I object to the fact that you’re calling him Captain David Miscavige. I don’t know him as such.

Q. Is he a captain?

A. I’m an ensign. I’m not called Ensign Allan Cartwright when I walk — when I’m — when I’m in my office, and so it’s — it’s not correct to say Captain David Miscavige. He’s Mr. David Miscavige, Chairman of the Board RTC.

Q. I realize you have a reason for wanting that to be, but he does carry the rank captain, and therefore, may be referred to as captain.

A. The only person that refers to him as captain is yourself, Mr. Jeffrey. No one else in the church refers to him as captain.

Q. Is that because the Office of Special Affairs, in its dealing with external matters, like lawsuits and investigations, wants to de-emphasize the role of the Sea Org within the church organization?

MR. STRIEBER: Objection, form.

THE WITNESS: I don’t — can’t even — I don’t know how to even answer that question. It’s not true, whatever you’re saying.

Q. (By Mr. Jeffrey) Whatever it is I’m saying, it’s not true?
A. What — what you’re saying is incorrect because there’s no de-emphasizing. The Sea Org is what the Sea Org is.

CDM.1Q. Okay. Do you have knowledge of Captain Miscavige’s contacts with the State of Texas and the allegations in his special appearance?

MR. STRIEBER: Objection, form.

THE WITNESS: I have knowledge of Mr. Miscavige’s whatever contacts — the contacts — contacts there are in the State of Texas.

CDM.3

 

Q. (By Mr. Jeffrey) Okay. How often do you meet with Captain Miscavige?

A. I haven’t met with Mr. Miscavige for — not that often. It’s not that often. He deals with matters concerning orthodox and religion, I deal with external affairs. There’s not really an activity that creates meetings.

Q. And you’re working in Los Angeles, and he’s often not even in the same city as you; is that fair?

A. I don’t keep track of where he is.

CDM.4

Captain David Miscavige is the leader of Scientology’s secretive paramilitary Sea Organization. The Sea Org reportedly has 5,000 members.

Q. Okay. So, how would you know what his contacts are with the State of Texas if you’re not in his presence by his side on a daily basis?
A. I know with regards to — I’ve gathered knowledge with regards to CSI’s knowledge as to his contacts in the State of Texas.

Q. And what — what have you gathered?

A. Well, I know he attended a — the church opening in Dallas, that’s what I’ve gathered.

Q. Okay. But, if he’s on the phone every day for two hours a day dealing with matters related to the State of Texas, you have no knowledge one way or the other, do you?

A. No, nor would any other person from CSI.

Captain David Miscavige in his Scientology War Room

Captain David Miscavige in what appears to be his Scientology War Room. We note the keyboard and microphone on the glass table. Does the Captain gives orders to his global forces from this microphone?

Q. What sort of reporting flows from OSA to Captain Miscavige?

(Scientology Money Project Note: MR. JEFFERSON next speaks. He is Lamont Jefferson, David Miscavige’s attorney. Lamont Jefferson’s brother is Wallace Jefferson, the former Chief Justice of the Texas Supreme Court. Justice Jefferson retired and is now representing Captain David Miscavige and the Church in this Texas case. Scientology always hires the best and most expensive lawyers. Former insiders report that Scientology spends millions of dollars per month on legal expenses.)

Lamont Jefferson, Esq of Haynesboone, San Antonio, Texas

Lamont Jefferson, Esq of Haynesboone, San Antonio, Texas

MR. JEFFERSON: Is it too much to ask that you not refer to him in that manner?

MR. JEFFREY: Yes.

MR. JEFFERSON: Well, it’s my client and I’m going to ask that you not, as a matter of courtesy. The witness has told you no one referred to him like that but you. It’s harassment, it’s argumentative, so I’m going to ask that you not do it. Are you going to —

MR. JEFFREY: I will continue to refer to him as Captain Miscavige.

MR. JEFFERSON: Why is it — what is it that you’re going to do that, Mr. Jeffrey?

MR. JEFFREY: Because — because we have laid this out in our pleadings and in declarations. His authority within the Church of Scientology to control every last aspect of the church comes from his rank as captain.

MR. JEFFERSON: You can refer to him in a manner that is respectful and civil and not one that serves your own ends.

MR. JEFFREY: Well —

soMR. JEFFERSON: And if you continue to do it, I will continue to object and I will speak up.

MR. JEFFREY: Okay. You may have a running objection, if you like.

MR. JEFFERSON: No, I will speak up.

MR. JEFFREY: Okay. That’s fine. I’ve lost my — what was my last question?

MR. DUNAGAN: That you were through.

MR. JEFFREY: I think I — I think I said that — that concludes the deposition.

MR. DUNAGAN: Yes.

MR. JEFFREY: Okay. I have it.

Q. (By Mr. Jeffrey) What sort of reporting flows from OSA to Captain Miscavige himself?
A. Again, I’m just going to tell you, his name is not Captain Miscavige, it’s Mr. Miscavige, or you can call him COB RTC, which is what I know him as.

Q. You know him as COB, don’t you?
A. That’s correct.

Q. And what’s a COB order?
A. What’s a COB order?

Q. Yes.
A. I don’t know what a COB order is. Sorry, I don’t know.

Q. Have you ever received a COB order?
A. No.

Q. Have you ever filed or responded with a compliance report?
A. No.

Q. You’ve never heard, in your 30-year career with the Church of Scientology, of a COB order?
A. No.

Q. Does Captain Miscavige regularly issue orders to personnel that are delivered in writing, and then the personnel must respond to the order with what’s called a compliance report?
A. I’m, again, going to say that his name is not Captain Miscavige.

MR. JEFFERSON: I’m going to — I’m going to join in that objection. He is not referred to as Captain Miscavige by anybody but you. You’re using it in a derisive manner to serve your own needs, to serve your own purposes in this deposition, and I’m going to speak up every time you do, okay?
MR. JEFFREY: Okay.

MR. JEFFERSON: If you can point to one other place in the public where Mr. Miscavige is referred to as Captain, I’ll —

MR. JEFFREY: In the public?
MR. JEFFERSON: Any — any other public forum where Mr. Miscavige is referred to as captain, bring it, let’s take a look at it. Otherwise, it is you being insulting and for no other purpose, and it is improper in this deposition.

MR. JEFFREY: It is insulting to refer to someone by his rank, which is the highest rank within the organization?
MR. JEFFERSON: It is improper to refer to somebody in a manner in which they do not wish to be referred. It’s not your call. You can’t just call him devil Miscavige, or any other name that is insulting or is — or is derogatory.

MR. JEFFREY: It is derogatory —

MR. JEFFERSON: In your — in your — MR. JEFFREY: — to call him Captain?

MR. JEFFERSON: Or that is not in your interest.

MR. JEFFREY: I don’t understand how it’s insulting or derogatory to call someone by the highest rank within a multinational organization from which he derives his authority.

MR. JEFFERSON: Totally depends upon your intent in using the term, doesn’t it?

MR. JEFFREY: That is my intent, to communicate the real authority.
MR. JEFFERSON: Your intent is to argue, your intent to is to use the term to argue your position. That is not how he’s referred to by anybody
but you. And I’m not going to allow it without speaking up. I’m going to speak up every time.

MR. JEFFREY: Well, we will demonstrate very clearly in the case from numerous witnesses that he is referred to as Captain Miscavige, so I have no qualms whatsoever about referring to him as Captain Miscavige and —

MR. JEFFERSON: I’m asking that you not —

MR. JEFFREY: — it’s nothing out of order.

MR. JEFFERSON: — refer to my client in that manner and every time that you do, I will interrupt.

MR. JEFFREY: Okay. Well, we’ll — if you’re going to persist in interrupting, then we’ll just have to shut down the deposition and go get a ruling from the court.
MR. JEFFERSON: That’s your choice.

Q. (By Mr. Jeffrey) So, I did ask a question, and you haven’t answered the question other than to argue with me over the use of captain. So, would you answer the question?
A. I don’t remember the question.

Q. Reports flowing from OSA to Miscavige.
MR. STRIEBER: Is that a question? That sounds like a statement, an incomplete statement. What is your question?

MR. JEFFREY: I’ve asked the question twice. He just wanted a reminder. I gave him a reminder.

Q. (By Mr. Jeffrey) Do you remember the question now?
A. No. Could you repeat —

Q. Okay.
A. — repeat the question, please?

Q. What reports flow from OSA to Captain Miscavige?

MR. JEFFERSON: I’m sorry, I’m going to interrupt. You’ve used the term “captain” again for your own purposes, not for any others. There is not a — you’ve not presented a single document, either within the organization or from outside of the organization, any organization related to scientology, that refers to Mr. Miscavige as captain. You use the
term for your own purposes and in a manner solely to advance your argument about his position, and I object to your use — your continued use of the term. You can ask this witness question after question without using that term and you can get through the deposition. That is all I’m asking of you, Mr. Jeffrey.

Q. (By Mr. Jeffrey) Okay. Is David Miscavige captain of the Sea Organization?
A. No.

Q. What — does he have a rank within the Sea Organization?
A. He has a rank, just like I have a rank.

Q. And what is his rank?
A. From what I understand, he has a rank of captain.

Q. Okay. Is that an insulting term?
A. I don’t know about being insulting, it’s just an incorrect term.

Q. According to you?
A. Insulting?

Q. Yeah, that it’s — no, you said it’s incorrect. It’s incorrect according to you.
A. What I said to you was I don’t know him as Captain David Miscavige. I’ve never heard that being used.

Q. Have you ever seen him in his captain’s uniform?
A. I’ve seen him in his Sea Org uniform.

Q. And is it a captain’s uniform with captain’s rank?
A. You know, I’m not sure.

Q. Do you have a uniform?
A. Yes.

Q. And so, what you’re saying is that everyone within this group called the Sea Organization has a rank, but the ranks are meaningless?
A. Ranks — these — you have to understand what the Sea Org is. It’s a religious order, and these are — these are honorary positions that are given to someone because of longevity and what they’ve done for the religion. That’s all it is.

Q. Is there any chain of authority from rank to rank? Does a captain have authority in connection with an ensign?
A. No.

Q. There’s no authority that derives from that?

A. None whatsoever. Just to give you an example, I’m an ensign, Linda Hamel is a midshipman, I have a senior rank to her.

Q. And both of those ranks are beneath captain?

A. In the levels of ranks, yes.

Q. But, you are saying that the ranks are meaningless in terms of authority?
A. Totally.

Q. What is command intention?
A. It’s what is wanted to be done, the — the — it’s the prime intention, the important intention to get done.

Q. And command intention, that’s a term from the Sea Organization, isn’t it?
A. It is a term that’s used, yes.

Q. And it has the word “command,” and is someone within the Sea Organization required to respond appropriately to command intention?
A. Well, it’s — I guess so, yes.

Q. We’ve been going for almost an hour, let’s take a little break.
A. Okay.
VIDEOGRAPHER: All right. We’re off the record at 10:22 a.m.
(Recess from 10:22 to 10:35.)
VIDEOGRAPHER: We’re back on the record at 10:35 a.m.

Q. (By Mr. Jeffrey) Mr. Cartwright, I’m going to hand you my trusty iPad and show you something and ask you to scroll through that for me, please. Tell us what it is.
A. It’s — well, it says: Inspector general network bulletin No. 44. All scientologists, Chairman of the Board, Religious Technology Center.

Q. Okay.
A. Dated 11 September 2001. Q. So 9/11 of — of 2001?
A. Right.

Q. Momentous day.
A. Yes.
Q. What is — what is an inspector general bulletin?
A. It’s a bulletin that’s been put out by the inspector general network.

Q. By the inspector general network?
A. That’s what it says.

Q. And it’s addressed to all scientologists. Is that all scientologists in the world?
A. Well, it says “all scientologists,” so it would include the world.

Q. Do you know how to scan down on the page with your finger on the screen?
A. I’m not sure. Sorry. Okay.

Q. Just go to the end, please.

MR. STRIEBER: Do you want to go to the very last page of the document?

MR. JEFFREY: Yes. Where it’s signed off, the message ends.

THE WITNESS: I don’t know. Now I’m into something else.

MR. STRIEBER: You’re good.

THE WITNESS: It says — oops. Okay.

Q. (By Mr. Jeffrey) How does Mr. Miscavige, as you say he’s to be called, how does he sign off that report to all scientologists in the world?
A. On that particular issue?

Q. Yes.

MR. STRIEBER: Objection, form.

THE WITNESS: Okay. On that particular issue, it says Captain David Miscavige, Chairman of the Board, Religious Technology Center.

Q. (By Mr. Jeffrey) Okay. There’s nothing insulting or derogatory about him calling himself Captain David Miscavige, is there?

A. I never said.

Q. Okay. Well, the attorney for RTC said that.
A. Okay.

MR. JEFFERSON: I said —

Q. (By Mr. Jeffrey) Is there anything insulting or derogatory about that?
MR. JEFFERSON: If you’ll allow me because I am the one that said it and you brought that up for me, your use of the term is what is insulting and wrong, your use of the term —

MR. JEFFREY: And you asked me if — MR. JEFFERSON: — in this context.
MR. JEFFREY: — if I could show you one public forum in which —

MR. JEFFERSON: Someone else referred to him as Captain Miscavige.
MR. JEFFREY: Oh, he can refer to himself as Captain Miscavige —

MR. JEFFERSON: As we’ve discussed —
MR. JEFFREY: — but no one else may refer to him in that way?

MR. JEFFERSON: As we’ve discussed, he holds the rank within the religion.

Q. (By Mr. Jeffrey) Is it your testimony, Mr. Cartwright, that no one in the Church of
Scientology, in any of its many organizations, has ever referred to David Miscavige as Captain Miscavige?

A. Based on my knowledge, yes.

Q. Well, you would have no personal knowledge, would you, as to whether or not any of the thousands of other scientologists have ever responded to him as Captain Miscavige?
A. All I can say is every communication I’ve seen, every discussion I’ve had with — with public or other staff members, Sea Org members, I’ve never heard that being used, ever.

Q. Except as we’ve seen here, on his very own reports, to all scientologists in the world, he calls himself Captain David Miscavige, correct?
A. You asked me a different question. You asked me a question about what — how other people refer him to — refer him as, and I answered you. I said nobody refers to him as Captain David Miscavige.

Q. To your knowledge?
A. As I said, to my knowledge.

Q. Yes?
A. Right.

Q. But, he does refer to himself as Captain David Miscavige?
A. He put out an issue.

Q. An issue?
A. Yes.

Q. There aren’t many, many issues with him signing off as Captain David Miscavige?
A. I really don’t know.

Q. You would have received this, wouldn’t you?
A. I received that, yes.

Q. Would you think there was anything peculiar about his signing off as Captain David Miscavige?
A. I didn’t even notice it.

Q. When was the last time you were in the personal presence of Captain Miscavige?

MR. JEFFERSON: I’m going to, again, ask that you not refer to him in that manner. We can argue, and I understand we’re going to disagree. He’s my client and I’m — it doesn’t impede your examination of this witness at all to avoid referring to him in that manner. I’m going to ask that you not do it.

MR. JEFFREY: And I’m going to refuse.

MR. JEFFERSON: Well, and the only reason that you will refuse is so that we can have this back and forth every time you do it because we will.

MR. JEFFREY: You’re the one choosing to have the back and forth.

MR. JEFFERSON: You’re the one choosing by using the term. I’m not impeding you from examining this witness in any manner that you wish other than referring to Mr. Miscavige as Captain Miscavige, which you’re insisting to do to win — to win the argument at the moment, and we’re not — you’re not going to win the argument. We’re going — we’re going to have this same — this same conversation every time, or you can proceed with your examination of this witness, save the argument for later, tell the judge — tell the judge
that I’m being obstreperous because I don’t like you referring to my client in that manner in this deposition. There’s no reason why you have to use that term to competently examine this witness about everything you need to examine him on in this deposition.

MR. JEFFREY: Calling an individual by his rank, which is the highest rank in the organization in question, is not in any way derogatory or insulting, and what you’re trying to do is to argue your case, which is that his rank as captain in the Sea Organization is meaningless, and that we must refer to him as Mr. Miscavige, when he himself, as I have just demonstrated, communicates to all scientologists in the world as Captain David Miscavige. So, it is completely inappropriate for you to tell me what — it would be like in a — in a case, if a fellow has a Ph.D. or a doctorate of some sort and I’m calling him doctor, and everyone else refers to him as mister, and I’m not allowed to call him doctor. It’s ridiculous.

MR. JEFFERSON: There is no question –

MR. JEFFREY: It’s ridiculous.

MR. JEFFERSON: Mr. Jeffrey, there is no question that Mr. Miscavige is the ecclesiastical leader, the leader, the religious authority, the highest authority in the — in the Church of Scientology, the highest person that holds that position. Isn’t that enough? You don’t —

MR. JEFFREY: What you’re trying to hide is that he is the highest authority in the one organization that runs through all of the church corporations, and that’s the reality of this case and —

MR. JEFFERSON: I’m not hiding anything.
MR. JEFFREY: Yes, you are.

MR. JEFFERSON: You’re the one using –
MR. JEFFREY: Yes, you are.

MR. JEFFERSON: — the term in a manner that I’ve objected to.
MR. JEFFREY: Okay.

MR. JEFFERSON: I’m asking that you — you proceed with the deposition, avoid using the term, indulge me. You can get everything that you want from this witness without using that term.

MR. JEFFREY: If I was using a term that was in any way derogatory, I would more than indulge you, I wouldn’t use the term. I’m using a term which is in no way derogatory and is, in fact, reflective of reality, and just if you want to refer to him as Mr. Miscavige, you’re entitled to. If I want to refer to him as Captain Miscavige — and by the way, there
will be many other witnesses in this case who will refer to him as —

MR. JEFFERSON: You’ve said so.

MR. JEFFREY: — Captain Miscavige.

MR. JEFFERSON: You’ve said so. Avoid it for now and we don’t have to have this conversation every time.

MR. JEFFREY: Will note.

MR. STRIEBER: I would like to add an objection on behalf of CSI in that your use of the term “captain” is misconstruing the facts, and so you’re assuming certain facts not in evidence. And it’s you that actually, by the use of the term “captain,” are ignoring this witness’s prior testimony that that particular name captain confers upon Mr. Miscavige no authority whatsoever. And your purpose in using the term “captain” is an attempt by you to put into evidence, in every question that you ask, an argument on your behalf that that term “captain” confers authority over my client CSI, which it does not.

MR. JEFFREY: We have evidence in this case —
MR. STRIEBER: I don’t want to hear what evidence you have.

MR. JEFFREY: — that COB —
MR. STRIEBER: I don’t need to know what evidence you have. Go get your evidence and put it in the record. Quit saying you have witnesses that say that. You’re — you’re making a record that’s probably, over our objection, going to find its way to the media, and you’re putting things in this record that’s going to find its way to the media by saying I have witnesses that do this, I have documents that say that. Take a proper deposition, confront this witness with the evidence you have, and ask him questions about it assuming, of course, it’s within this course and scope. But, I object to form to the use of the term “captain,” and if you’ll give me a running objection for the purposes —

MR. JEFFREY: I’ll be glad to give that to you.

MR. STRIEBER: — of which —
MR. JEFFREY: I’d be glad to give that to any –

MR. STRIEBER: — on behalf of CSI.

MR. JEFFREY: — everybody in the room, if you want it, you can have it. You know, we could go on a neutral basis, but I hesitate to do it because to me it sounds insulting. We could refer to him as Miscavige. I would not normally do that because that does not sound polite.

MR. JEFFERSON: You can’t say Mr. Miscavige?
MR. JEFFREY: No, I can — I can say Captain Miscavige.

MR. JEFFERSON: Why — why doesn’t mister work?

MR. JEFFREY: Why doesn’t captain work?

MR. JEFFERSON: Because that is — because you’re imbuing the term with meaning that doesn’t apply here. Call him Mr. Miscavige. Let’s say call him David Miscavige if you don’t think he rises to the term of mister.

MR. WIEGAND: Lamont, he refers to himself in written communications —

MR. JEFFERSON: We’ve discussed that, Marc, you were out of the room.

MR. WIEGAND: — as Captain Miscavige.

Q. (By Mr. Jeffrey) What reporting flows from the Office of Special Affairs to David Miscavige in wherever he may be located at any given time?
A. I don’t know what you mean by what reporting.

Q. Yes.
A. I don’t know what you mean by that.

Q. You understand the word “what”?
A. What, sorry?

Q. You understand what the word “what” means, don’t you?
A. What reporting, I said.

Q. Yes.
A. What is — what do you mean by reporting?

Q. I don’t know. What would you mean by reporting?
A. That’s what I’m asking you.

MR. STRIEBER: Objection, form.

Q. (By Mr. Jeffrey) I’m asking you in the broadest sense and then we can narrow it down. If there are 100 different kinds of reports that go to David Miscavige from OSA, I would want to know those, and I’d expect you to list them. But, there’s nothing confusing about asking you what reports go from the Office of Special Affairs to David Miscavige.
A. No reports go.

Q. Okay. Have there ever been reports that have gone from the Office of Special Affairs to David Miscavige?
A. Well, information has gone to him.

Q. I’m talking about reports.
A. I know, that’s what I told you. I already answered, no reports go to him.

Q. And then I followed up with the question: Have there ever been reports made to David Miscavige from the Office of Special Affairs?
A. Since, I mean, from the beginning of time?

Q. Sure. If you were aware of them.
A. Well, I thought the terms of this search was,
I was looking for anything from 2009 on, so aren’t we going from 2009 on?

Q. Well, one of the topics of your deposition notice is David Miscavige’s authority over and interaction with the Office of Special Affairs. I’m just trying to understand. Was there a time when a daily report went from the Office of Special Affairs to David Miscavige and then that was terminated? If so, tell me about that. If your testimony is there’s never been reporting that’s gone from the Office of Special Affairs to David Miscavige, then I need to know that.
A. No daily report was sent to Mr. Miscavige.

Q. And how would you know that?
A. Because I’ve been around for many years.

Q. Have you — now, I know that you read everything ever written by Mark “Marty” Rathbun, don’t you?
A. No.

Q. Your declarations indicate otherwise. Don’t you have notebooks and notebooks of all of his writing, and you’ve reviewed them and summarized them, and all those sorts of things?

MR. STRIEBER: Objection, form. THE WITNESS: Not all of his writings,
no.

Q. (By Mr. Jeffrey) Okay. Well, as the Director of Legal Affairs for the Office of Special Affairs, have you read Mr. Rathbun’s affidavit from this very case?

A. That, I have.

Q. Okay. Did you read his description of the daily reporting that he delivered from the Office of Special Affairs to David Miscavige personally? Did you read about that?
A. Yes.

Q. Were you ever there at any of those times described in his affidavit?

MR. STRIEBER: Objection, form. THE WITNESS: I mean, I have a big….