Hana Whitfield about Lisa's "missing" PC files: http://www.whyaretheydead.net/lisa_mcpherson/bob/A-023-071602-Whitfield-V1.html (Read also elsewhere on that URL about Hana telling about her credit history being requested by "someone")
4 BY MR. DANDAR: 5 Q Did you find other documents of the PC folders 6 missing? 7 A Yes. There were a number of them missing. And I 8 think I made a sheet for you on missing contents. 9 All of her L10, L11 and L12 auditing sessions were 10 missing. I corroborated that by looking at the folder 11 summary entries and the folder error summary entries and the 12 program sheets to make sure she had had all those sessions. 13 And she had. And they were missing. 14 There were a number of sessions missing from -- 15 THE COURT: I'm sorry, that doesn't mean 16 anything to me, L10 through L12? 17 THE WITNESS: Oh, your Honor, those are 18 upper-level auditing processes that are -- 19 Scientology calls major case boosters. They can be 20 done almost at any point in the auditing bridge. 21 THE COURT: The file reflected she had had 22 those sessions? 23 THE WITNESS: Yes, the summaries -- her 24 auditing summaries reflected she had had those 25 sessions but they weren't in her folders.
1 THE COURT: The -- 2 THE WITNESS: The preclear. 3 THE COURT: Well, I understand what preclears 4 are. But there was indication she had had those, 5 but the actual paperwork that would go along with 6 those auditing sessions were missing? 7 THE WITNESS: Right. That is correct. 8 THE COURT: What would the L10 through L12 be? 9 What would those auditing programs be? 10 THE WITNESS: They are confidential auditing 11 levels. I do not know the content of them. 12 THE COURT: No, no, I mean, is it like -- is it 13 on any particular thing? Or is it just upper-level 14 auditing? 15 THE WITNESS: It is upper-level auditing which 16 is designed to find areas the individual still has 17 negative emotions or upsets on and address those and 18 get them resolved. 19 THE COURT: Okay. 20 BY MR. DANDAR: 21 Q Now -- 22 A Oh, you asked me if introspection rundown -- there 23 was some sessions missing out of her introspection rundown 24 rundown, that period. And there were other sessions missing 25 in and around the times that Lisa was doing the worst. And
1 that is scattered throughout the year. Again, I would have 2 to go back to find exactly in which month and week that 3 occurred. 4 But repeatedly throughout the folders there were 5 sessions missing in and around those times. And there were 6 often in and around those times there were case supervisor 7 orders missing, order to report to the case supervisor 8 missing, as well as the actual auditing session reports. 9 Q Do you recall reviewing any documents of Lisa 10 McPherson that showed that Int Management was involved in 11 1995? 12 MR. MOXON: Your Honor, before she answers this 13 I just want to reaffirm, not for this question, I 14 want it understood before Mr. Dandar asks his next 15 question, this sort of demonstrates she did file an 16 affidavit at one point. And we wanted to 17 cross-examine her as to these allegations of missing 18 documents. In fact, there are no documents. 19 But a lot of the things she said are just 20 absolutely not true. And it would be very easy to 21 show through a detailed cross-examination with all 22 of the records here. We had no idea what she would 23 be testifying about today. But this is why the 24 ambush sort of -- 25 THE COURT: It is not an ambush, Counsel. This
1 is a motion hearing. If you need time to get the 2 records here, ask for them, you can go get them 3 here, take as long as you want. 4 MR. MOXON: All right. 5 THE WITNESS: If I may explain a little about 6 that, your Honor, it might help. 7 I did make one error in an affidavit I wrote 8 for Mr. Dandar in which I stated that a large number 9 of records between these pages and these pages were 10 missing. In my subsequent affidavit I mentioned 11 that was a mistake, and I made that mistake because 12 the auditing folders were -- they were numbered 13 correctly by Bates number, they were in Bates number 14 order, but they were not in date order. And when I 15 put them into date order so I could follow what 16 happened to Lisa, I got confused by the Bates 17 numbers because they were all out of order. 18 So in my subsequent affidavit I explained that 19 and corrected the session reports that really were 20 missing and were definitely missing. 21 BY MR. DANDAR: 22 Q Is it -- how does Scientology view -- with your 23 understanding as an auditor -- missing records from a PC 24 folder? 25 A Well, I think --
1 MR. MOXON: Objection to her -- excuse me, 2 object to her asserting what, quote, Scientology 3 views something. 4 THE COURT: I'm sorry, I didn't hear the 5 question. What was the question again? 6 BY MR. DANDAR: 7 Q Within your experience as a Scientologist and as 8 an auditor, what is the -- how does Scientology -- how does 9 the Church of Scientology view missing records from a PC 10 folder? 11 MR. MOXON: I would object to that, the way it 12 is framed. 13 THE COURT: Well, from your experience, what do 14 you -- she was an auditor, she was there. I think 15 by saying Scientology that is awfully broad. 16 MR. DANDAR: It is. 17 THE COURT: What do you -- what does it mean to 18 you that something was missing from an auditing 19 folder? 20 THE WITNESS: It's a very serious omission. 21 And I think it is currently categorized as a high 22 crime in Scientology. I'm not totally sure of that 23 but I think it is. 24 BY MR. DANDAR: 25 Q Of course you don't know why these documents are
1 missing, do you? 2 A No. 3 Q Now, in the process of getting auditing -- 4 THE COURT: If you were an auditor in the 5 Church of Scientology and in the process of auditing 6 a person, I take it when you were done you would do 7 whatever you needed to do and put it with the folder 8 and send it on to the person who is going to be -- 9 THE WITNESS: The case supervisor. 10 THE COURT: -- the case supervisor? All right. 11 If when it got to the case supervisor, the report, 12 whatever it is you had done, was not there and you 13 couldn't find it, what would happen to you? 14 THE WITNESS: Oh, there would be serious -- 15 serious trouble. There would be an investigation to 16 find out whether I had done something with those 17 reports or someone who had carried that folder to 18 the case supervisor had done something with them, or 19 if the case supervisor -- someone would have been 20 responsible and that someone would be hunted down. 21 It was very serious. 22 THE COURT: And what would happen to that 23 someone? 24 THE WITNESS: That someone would be penalized, 25 would be assigned ethics conditions.
1 THE COURT: In other words, this is not 2 acceptable -- 3 THE WITNESS: Absolutely not -- 4 THE COURT: -- for an auditing session to 5 simply be missing. 6 THE WITNESS: Absolutely not, your Honor. 7 Mr. Hubbard wrote extensive bulletins on the need 8 for preclear folders to be complete down to the last 9 crossed T and dotted I. He said that a case 10 supervisor had no hope of resolving case 11 difficulties if he had incomplete information, and 12 an auditor had no hope of helping his or her 13 preclear if he didn't have a complete auditing 14 record going back in time. He had extensive 15 bulletins written on this. 16 BY MR. DANDAR: 17 Q Is there -- 18 THE COURT: You indicated that information from 19 Lisa's file was missing when she was doing the work. 20 Are you talking now about when she was on the last 21 introspection rundown and died? Or are you talking 22 about before that? 23 THE WITNESS: Before that, your Honor. I'm 24 talking about from February 1995 all of the way 25 through to November 1995. Because those --
1 THE COURT: Before the last -- 2 THE WITNESS: Before that, yes. 3 THE COURT: Before the last where she was taken 4 from the hospital and put in the Ft. Harrison 5 Hotel -- 6 THE WITNESS: Right. 7 THE COURT: -- for the final watch? 8 THE WITNESS: Yes. 9 THE COURT: From what periods of time? 10 THE WITNESS: From February of 1995 through 11 October/November 1995. I think some of the latest 12 watch reports I saw were actually December. So it 13 would have been from February through December 1995. 14 BY MR. DANDAR: 15 Q And then November, December of 1995, I think I 16 already asked you this, but just to clarify, did you find 17 missing documents? 18 A Yes, I did. 19 Q I mean, did you see that some documents were 20 missing? 21 A Auditing, any auditing records, attempts to audit 22 Lisa. You asked me about an introspection rundown at that 23 point. There was no introspection rundown checklist in her 24 preclear folder. 25 Q And --
1 A And -- 2 Q When is that checklist prepared? 3 A Additionally, there were no -- excuse me -- there 4 were no entries on Lisa's folder summary that an 5 introspection rundown had been done in November or December, 6 or attempted. 7 And there was also no entries on her folder error 8 summary that such had been done or attempted. 9 Q And that is required? 10 A Absolutely. If they're done or attempted, yes, 11 that is required. So that is why I presumed they were in 12 another folder which you hadn't been given. 13 THE COURT: Are you talking about the error 14 summary? 15 THE WITNESS: Folder error summary. 16 THE COURT: Okay. 17 THE WITNESS: That is a summary that is done in 18 the preclear folder to detect all auditing. And the 19 supervisor -- and it is kept with the current 20 preclear folder. 21 BY MR. DANDAR: 22 Q Are you familiar with routing forms? 23 A Yes. 24 Q Was a routing form required for a rundown? 25 A When a preclear stops a rundown, yes.
1 Q What does that routing form do -- what is the 2 function of the routing form for a rundown? 3 A The routing form routes the person through a 4 number of people to ensure that the service is paid for, 5 that the person has ethics clearance, that everything is in 6 order. So -- and then to the guidance center to get 7 auditing. So there are points on the routing form to check 8 off by each of these people. 9 Q And do you recall seeing a routing form for the 10 introspection rundown or anything happening at the hotel in 11 November, December of '95? 12 A No, there wasn't anything. 13 THE COURT: Should there have been? 14 THE WITNESS: Yes, there should have been, your 15 Honor. If such had been attempted. 16 BY MR. DANDAR: 17 Q Okay. Was there any evidence at all that there 18 was an attempt at an introspection rundown in November and 19 December of '95? 20 A Not that I could find in her preclear folders or 21 in any other notes that I saw. 22 THE COURT: Did you see the workers -- I'll 23 call them workers, I don't know what the technical 24 term is -- but the folks who were taking care of 25 Lisa during the last seventeen days?
1 THE WITNESS: Yes. 2 THE COURT: There were some summaries written 3 by them that were apparently in the PC folders. Did 4 you see those? 5 THE WITNESS: I did see -- I don't think I saw 6 all of them, your Honor, but I saw a large number. 7 THE COURT: There are apparently some that are 8 missing. But there are some that are there. 9 THE WITNESS: Yes. 10 THE COURT: And in these -- it's been a while 11 since I looked at them myself -- but my recollection 12 is at least in some of them, they talk about the 13 fact that they understood they were not to speak, 14 and they didn't speak, some of the things that would 15 be part of an introspection rundown? 16 THE WITNESS: That is correct. 17 THE COURT: They spoke about -- I don't know if 18 you read any of their depositions or their sworn 19 statements or what have you -- but they clearly 20 testified that they were called in and said, "You're 21 going to go help on an introspection rundown," they 22 were told what that was and told about the muzzled 23 speech. Did you read that? 24 THE WITNESS: Absolutely, your Honor. That is 25 very clear.
1 THE COURT: So when you say there is nothing in 2 the PC folder indicating there is an introspection 3 rundown, the summaries would indicate that at least, 4 as far as workers, they felt they were participating 5 in an introspection rundown. 6 THE WITNESS: Yes, but there were no routing -- 7 there was no routing form routing Lisa onto the 8 introspection rundown. There were no session 9 reports. There was no case supervisor order to 10 start the introspection rundown. 11 THE COURT: Do you know whether or not, in a 12 situation where the person has not yet reached the 13 stage where they can receive auditing -- in other 14 words, I sound like I know something, I really 15 don't, but I know enough to ask these questions -- 16 THE WITNESS: You know a lot. 17 THE COURT: If somebody is in that stage, what 18 they call introspection rundown stage 0 to 00, where 19 they are receiving rest, vitamins, all of the things 20 to hopefully prepare them for the rundown session, 21 the auditing session accompanying the introspection 22 rundown -- 23 THE WITNESS: Right? 24 THE COURT: -- well, if they don't ever get out 25 of that stage, which apparently according to the
1 testimony Lisa did not -- 2 THE WITNESS: Yes. 3 THE COURT: -- there really wouldn't be 4 anything much to route because there wouldn't be 5 any -- she was still there and not receiving any 6 auditing or any of this. 7 THE WITNESS: However, I believe the watchers 8 were instructed not to speak to her because she was 9 going to be on the introspection rundown. 10 THE COURT: Right. 11 THE WITNESS: If they were told that, there 12 should have been evidence in her folder that that 13 rundown had been started because that is one of the 14 first steps. 15 THE COURT: So it is your testimony that this 16 checklist for the introspection rundown would go in 17 the PC folder when the person was in the 0, 00 18 stage? 19 THE WITNESS: Yes, your Honor. That is 20 correct. 21 THE COURT: And -- 22 THE WITNESS: Because that -- 23 THE COURT: And there is some notation from the 24 case supervisor that this is what was happening? 25 THE WITNESS: And a program from the case
1 supervisor saying, "Go to do the introspection 2 rundown, and make sure Lisa is on step 0, 00, et 3 cetera, and make sure the watchers are muzzled, they 4 don't talk to her," all of those points technically, 5 according to Mr. Hubbard's bulletins, should have 6 been in a case supervisor program in Lisa's auditing 7 folder. 8 THE COURT: Okay. 9 THE WITNESS: When that happened. 10 THE COURT: Now, let me ask you this. Let's 11 say that someone went and attempted to see whether 12 or not Lisa was ready for auditing, the rundown -- 13 THE WITNESS: Yes? 14 THE COURT: -- and they went and -- she was 15 not -- in other words, that I heard testimony, that 16 I have read somewhere, that she threw the cans and 17 was still in a very psychotic state, was not capable 18 of being audited. 19 THE WITNESS: Right. 20 THE COURT: Was that in the folder? 21 THE WITNESS: No, it wasn't. 22 THE COURT: That attempt at auditing, would 23 that be something you as an auditor would put in the 24 folder? 25 THE WITNESS: Absolutely, your Honor. The
1 auditor that went to do that -- I forgot her name 2 right now, it is on the tip of my tongue -- she 3 would have made a report of the proceedings during 4 her interchange with Lisa, she would have written 5 down what happened in the room with Lisa, and when 6 she determined that she could not audit Lisa she 7 would have ended the session or left it, made up her 8 cover sheet report to the case supervisor and sent 9 the folder to the case supervisor saying, "Lisa is 10 not auditable at this time." 11 THE COURT: And the case supervisor would have 12 checked that to see whether or not he believed that 13 person was correct or not? 14 THE WITNESS: He might have checked it. He 15 might have accepted the auditors, because auditors 16 are normally considered very trustworthy, and all of 17 the auditors I know are ED, honest, ethical 18 trustworthy people. 19 THE COURT: But -- I read so much that I don't 20 know whether this is even accurate so you tell me if 21 it is not. Isn't there something that says that an 22 auditor is checked to see if they performed the 23 procedure correctly, if there is any error in their 24 handling of the situation and -- 25 THE WITNESS: Oh, that happens if a preclear
1 has actually had a session successfully. If he has 2 been audited and the session has ended, he then goes 3 to the preclear examiner for a quality control 4 check. 5 THE COURT: But if the person has not been 6 audited, which obviously in this case Lisa was 7 not -- 8 THE WITNESS: There was not -- 9 THE COURT: -- then there would not necessarily 10 be a follow-up sheet from Mr. Kartuzinski saying he 11 had checked and as far as he was concerned that this 12 was correct that she was still to be in step 0, 00, 13 because she couldn't receive auditing? 14 THE WITNESS: Right, your Honor. But he may 15 have written a further order at that point to the 16 watchers or to the auditor -- I'm surmising at this 17 point -- to make sure that the -- at this point to 18 make sure her treatment was going well at 0, 00 on 19 assists.
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