[the following was typed in by Arnie Lerma from a xerox copy, the top of each page typed in says in 9 point full caps type REPRODUCED AT THE NATIONAL ARCHIVES]

 

REPRODUCED AT THE NATIONAL ARCHIVES

FILED IN OPEN COURT

AUG 15 1978

James F. Davey, Clerk

UNTED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

 

UNITED STATES OF AMERICA

v.

MARY SUE HUBBARD
JANE KEMBER
MORRIS BUDLONG, also known as MO BUDLONG
HENNING HELDT
DUKE SNIDER
GREGORY WILLARDSON
RICHARD WEIGAND
MITCHELL HERMANN, also known as MIKE COOPER
CINDY RAYMOND
GERALD BENNET WOLFE
SHARON THOMAS

Criminal Case No. 78-00401
Grand Jury Original

Violations:

18 U.S.C. 2, 371,
641, 1503, 1623
2511 (1) (a) (Conspiracy,
Theft of Government
Property, Aiding and
Abetting, Obstruction of Justice,
False Declaration Before
A Grand Jury,
Interception of OralvCommunication)
22 D.C. Code 105,
1801(b) (Burglary,
Aiding and Abeting)

The Grand Jury charges:

INTRODUCTION

At all times material herein, the Church of Scientology (Scientology)
had offices in various cities in the United States and elsewhere
within Scientology, a department known as the "Guardian’s Office" had
responsibility to promote the interests of Scientology by covertly identi-
fying, locating, and obtaining all Scientology-related information in
the possession of various individuals, government agencies and private
organizations.

At all times material herein,. The Guardian’s Office had world-
wide headquarters (Guardian’s Office WW) at Saint Hill Manor, East Grin-
stead, Sussex, England. It had United States headquarters (Guardian’s
Office US) in Los Angeles, California. It had a local office in the
District of Columbia (Guardian’s Office DC) and other cities throughout
the United States.. Each of the Guardian Offices was composed of
five bureaus including the Information Bureau which was assigned the
responsibility for the conduct of covert operations including the collect-
tion of data and documents of interest to Scientology.

At all times material herein, L. RON HUBBARD, who held the
title "Commodore", by virtue of his role as founder and leader of
Scientology exercised overall supervision of the Guardian’s Office.

At all times material herein, MARY SUE HUBBARD held the titles
of Controller" and "Commodore Staff Guardian" (CSG) and as the second
person in the hierarchy of Scientology had duties, under her husband
L.RON HUBBARD, which included supervision of the Guardian’s Office.

At all times material herein, JANE KEMBER had the title of
"Guardian World-Wide" (GWW) and headed the daily operation of all Guar-
dian’s Offices, reporting directly to L RON HUBBARD and MARY SUE HUBBARD.

At all times material herein, MORRIS BUDLONG, a/k/a MO BUDLONG
(hereinafter MO BUDLONG), held the title "Deputy Guardian for Information
World-Wide" (DG I WW), supervised all Information Bureaus around the
World and reported directly to JANE KEMBER.

During the approximate periods listed below in the column en-
titled "Approximate Periods the individuals listed below in the column
entitled "Individuals" held the positions, in the Guardian’s Office US,
listed below in the column "Positions":

INDIVIDUALS APPROXIMATE PERIODS POSITIONS

HENNING HELDT Nov. 21, 1973 – June 20, 1977 Deputy Guardian US

(DG US)

DUKE SNIDER March 1974 – Dec. 1, 1974 Deputy Guardian –

Information US

(DG I US)

Dec. 1, 1974 – June 20, 1977 Deputy-Deputy

Guardian US

(DDG US)

RICHARD WEIGAND Dec. 1, 1974 – May 15, 1977 Deputy Guardian –

Information US

(DG I US)

-3-

INDIVIDUALS APPROXIMATE PERIODS POSITIONS

GREGORY WILLARDSON Sometime in 1974 – Jan. 1, 1976 Information Bureau

Branch I Director US

Jan. 1, 1976 – June 16, 1977 Deputy Deputy

Guardian Information US

(DDG I US)

June 16, 1977 – June 20, 1977 Deputy Guardian

Information US

(DG I US)

MITCHELL HERMANN Jan. 1, 1974 – March 1, 1975 Branch I Director

a/k/a MIKE COOPER Guardian’s Office US

Jan. 1, 1976 – March 1, 1977 Southeast US Secretary

Guardian’s Office US

(SEUS SEC.)

CINDY RAYMOND June 1, 1974 – Jan 1 1976 Information Bureau

Collections Officer US

Jan 1, 1976 – Sept 1, 1976 Information Bureau

Branch I Director US

Sept 1, 1976 – June 20, 1977 Information Bureau

National Secretary US

 

From on or about January 1, 1974 until on or about June 11, 1976,
MICHAEL J. MEISNER, also known as John M. Foster, Jeff Murphy, and "Herbert,"
held the title "Assistant Guardian for Information – DC (AG I DC). As
such, he supervised the Information Bureau in the District of Columbia, and
reported to the Southeast US Secretary and the Deputy Guardian for Infor-
mation US. From on or about July 1, 1976 until on or about August 30,
1976, he held the title "National Secretary – US " in Los Angeles,
California. As such he supervised the operation and formulation of Information
Bureau programs of national scope.

At all times material herein, GERALD BENNET WOLFE, also known
as "Silver" and "Kelly", was an agent of Scientology. As such, from on or about
November 18, 1974 until on or about June 30, 1976, he was a covert
operative for the Guardian’s Office employed as a clerk at the Internal
Revenue Service of the United States Department of the Treasury (herein-
after IRS) in the District of Columbia.

At all times material herein, SHARON THOMAS, also known as
"Judy," was an agent of Scientology. As such, from on or about February
19, 1976 until on or about November 5, 1976, she was a covert operative
for the Guardian’s Office employed as a secretary at the United States
Department of Justice in the District of Columbia.

 

 

COUNT ONE

THE CONSPIRACY, ITS OBJECT AND MEANS

  1. Beginning on or about November 21, 1973, and continuing until
    on or about May 27, 1977, within the District of Columbia and elsewhere,
    the defendants MARY SUE HUBBARD, JANE KEMBER, MO BUDLONG,
    HENNING HELDT, DUKE SNIDER, RICHARD WEIGAND, GREGORY
    WILLARDSON, MITCHELL HERMANN, a/k/a MIKE COOPER, CINDY
    RAYMOND and SHARON THOMAS, together with unindicted
    co-conspirators Gerald Bennet Wolfe and Michael J. Meisner, and other
    unindicted coonspirators both known and unknown to the Grand Jury,
    willfully and knowingly did conspire, confederate, combine, and agree
    together and with each other, to commit offenses against the
    United States of America, that is, by various illegal and unlawful means
    which are known to the Grand Jury that were used or attempted to be used
    by the defendants and the unindicted co-conspirators were as follows:
  1. To willfully and knowling steal, purloin and convert
    to their own use records and things of value of the United
    States and departments and agencies thereof, that is, documents
    and photocopies thereof which were the property of the IRS,
    the United States Department of Justice, and the Office of the
    United States Attorney for the District of Columbia, in violation
    of Title 18, United States Code, Section 641;
    To willfully intercept and procure other personas to
    intercept oral communications made during a meeting of agents
    and employees of the IRS held at IRS headquarters
    in the District of Columbia, in violation of Title 18, United
    States Code, Section 2511(1) (a)

    c. To falsely make and forge passes and permits
    issued by and under the authority of the United States, that
    is, false indentification cards bearing the seal of the IRS,
    for the purpose, among others, of gaining entry to various
    government buildings, in violation of Title 18, United States
    Code, Section 499;

  1. To enter rooms of various employees of the IRS, the
    United States Department of Justice, and the Office of the
    United States Attorney for the District of Columbia, with
    intent to steal documents contained therein, which were the
    property of the United States, in the care, custody and
    control of said agencies and their employees, in violation of
    Title 22, District of Columbia Code, Section 1801(b);
    To recruit agents of Scientology to infiltrate various
    agencies and departments of the United States.
    To place these agents in various positions within
    these agencies

    To use bogus credentials to gain access to various
    agencies and departments;

    To utilize electronic surveillance devices;

    To gain access to areas within these agencies which
    contained documents and information of value to Scientology.

 

OVERT ACTS

To effect the objects and means of this conspiracy, the
defendants, together with the unindicted co-conspirators, committed
various overt acts within the District of Columbia and elsewhere,
including but not limited to the following:

(1) On or about November 21, 1973, JANE KEMBER issued
a directive to HENING HELDT ordering him and his staff to
obtain all INTERPOL (the international police organization)
documents relating to Scientology and connecting its founder,
L Ron Hubbard, to criminal activity.

(2) On or about July 1, 1974, DUKE SNIDER directed
Michael J. Meisner to implement JANE KEMBER’s directive
described in the preceding subparagraph by obtaining all
INTERPOL documents relating to Scientology from the INTERPOL
office then locating in the United States Department of the Treasury.

(3) On or about August 15, 1974, CINDY RAYMOND informed
Michael J. Meisner that he was to assist her in recruiting a
loyal Scientology agent for placement as an employee at the
IRS in the District of Columbia.

(4) On or about September 15, 1974, CINDY RAYMOND notified
Michael J. Meisner that she had selected Gerald Bennet Wolfe to be
the Scientology agent at the IRS in the District of Columbia and that
Meisner was to help him obtain a position there as soon as possible.

(5) On or about October 21, 1974, JANE KEMBER issued Guardian
Program Order 1361 addressed to HENNIG HELDT, DUKE SNIDER
and RICHARD WEIGAND, directing, among other things, the
infiltration of the District of Columbia offices of the IRS and of the
Tax Division of the United States Department of Justice for the purpose
of obtaining all files on Scientology, its founder L. Ron Hubbard, and
the internal memoranda of attorneys representing the government in
Scientology initiated lawsuits.

(6) On or about October 31, 1974, a Scientology agent transported
an electronic listening device from Los Angeles, California, to the
District of the Columbia.

(7) On or about November 1, 1974, within the District of Columbia
MITCHELL HERMANN, a/k/a MIKE COOPER, and two other
Scientology agents, placed an electronic listening device in an IRS
conference room and recorded an IRS meeting concerning
Scientology’s application for tax exempt status and related matters.

(8) Between on or about November 10, 1074, and on or about
November 14, 1974, MO BUDLONG, HENNING HELDT, DUKE
SNIDER and Michael J. Meisner sent numerous telexes relating
to the placement of a Scientology agent at the IRS in the District of Columbia.

(9) On or about November 18, 1974, Gerald Bennet Wolfe began
employment as a clerk typist at the IRS in the District of Columbia.

(10) On or about December 4, 1974, DUKE SNIDER sent a
telex to MO BUDLONG, informing him that the first shipment
of stolen IRS documents had been received in Los Angeles.

(11) On or about December 5, 1974, MO BUDLONG sent a telex
to DUKE SNIDER acknowledging receipt of the information
regarding stolen IRS documents.

(12) On or about December 30, 1974, within the District of Columbia,
Gerald Bennet Wolfe stole documents from the office of Barbara Byrd
of the Chief Counsel’s office of the IRS.

(13) On or about December 30, 1974, within the District of
Columbia, Michael J. Meisner, having received a package of stolen
documents referred to in the preceding subparagraph from Gerald
Bennet Wolfe, forwarded said package to Los Angeles for distribution to
the defendants and unindicted co-conspirators.

(14) Between on or about May 2, 1975 and on or about May 17, 1975,
within the District of Columbia, Gerald Bennet Wolfe illegally entered on
three occasions the offices of various United States Department of Justice
Tax Division staff attorneys assigned the defense of Scientology-initiated
law suits and stole documents located therein.

(15) Between on or about May 3, 1975 and on or about May 17, 1975,
within the District of Columbia, Michael J. Meisner, having received
three packages of stolen documents referred to in the preceding
subparagraph from Gerald Bennet Wolfe, forwarded said packages
to Los Angeles for distribution to the defendants and unindicted co-conspirators.

(16) On or about May 27, 1975, MARY SUE HUBBARD instructed
JANE KEMBER and HENNING HELDT to "use any method at our disposal
to win the battle and gain our non-profit [tax] status."

(17) On or about June 18. 1975, HENNING HELDT wrote a letter to
MARY SUE HUBBARD and JANE KEMBER informing them that
HUBBARD’s order referred to in the preceding sub-paragraph had been relayed
to the Information Bureau with instructions to complete within two to three
months the collection of documents from the IRS and the Tax Division of the
United States Department of Justice.

(18) On or about June 4, 1975, GREGORY WILLARDSON wrote a letter to
Michael J. Meisner directing him to prepare a plan to obtain by August 30, 1975
all documents of interest to Scientology which were in the possession of the IRS
Office of International Operations, Intelligence Division, and the Special Services
Division.

(19) On or about June 11, 1975, within the District of Columbia, Michael J. Meisner
wrote a letter in response to the letter of GERGORY WILLARDSON described in
the preceding subparagaph and attached the requested plan.

(20) On or about June 30, 1975, GREGORY WILLARDSON wrote a letter to
Michael J. Meisner approving the plan described in the preceding subparagaph

(21) On or about June 21, 1975, within the District of Columbia,
Gerald Bennet Wolfe stole documents from the office of Lewis Hubbard of the
Chief Counsel’s Office of the IRS.

(22) On or about June 21, 1975, within the District of Columbia, Michael J. Meisner
having received from Gerald Bennett Wolfe a package of stolen documents
referred to in the preceding sub-paragraph, forwarded said package to Los Angeles for
distribution to the defendants and inindicted co-conspirators.

(23) On or about June 27, 1975, JANE KEMBER and MO BUDLONG
issued Guardian Program Order 9 directing that all INTERPOL documents
relating to Scientology and its founder L Ron Hubbard be obtained through
infiltration of, or the placing of "clandestine agents" in, the INTERPOL
offices at the United States Department of the Treasury.

(24) On or about July 2, 1975, DUKE SNIDER wrote a letter to RICHARD
WEIGAND directing him to obtain by August 20, 1975, all Scientology-
related documents in possession of the IRS in the District of Columbia
and thereafter to obtain all Scientology-related documents from the possession
of the Tax Division of the United States Department of Justice.

(25) On or about July 28, 1975, within the District of Columbia,
Gerald Bennet Wolfe stole documents from the Disclosure Division
of the Chief Counsel’s Office of the IRS.

(26) On or about July 28, 1975, within the District of Columbia,
Michael J. Meisner, having received from Gerald Bennet Wolfe,
a package of stolen documents referred to in the preceding
subparagraph, forwarded said package to Los Angeles for
distribution to the defendants and unindicted co-conspirators.

(27) Between on or about September 21, 1975 and on or
about September 20, 1975, within the District of Columbia,
Gerald Bennet Wolfe on two occasions stole documents
pertaining to Scientology from the Disclosure Division of the
Chief Counsel’s Office of the IRS.

(28) Between on or about September 24, 1975 and on or about
September 30, 1975, within the District of Columbia,
Michael J. Meisner, having received from Gerald Bennet Wolfe
two packages of stolen documents referred to in the preceding
subparagraph, forwarded said packages to Los Angeles for
distribution to the defendants and unindicted co-conspirators.

(29) On or about December 5, 1975, HENNING HELDT and
RICHARD WEIGAND issued on behalf of JANE KEMBER Guardian
Program Order 158 ("Early Warning System") which was designed to
protect the "personal security" of Scientology’s founder L. Ron Hubbard.
The order called for the infiltration of government agencies which had
the power to subpeona or bring suits against Hubbard or which would
possess advance warning of such subpeonas or suits.

(30) On or about December 10, 1975, CINDY RAYMOND directed
Michael J. Meisner to implement Guardian Program Orders 9
(referred to in subparagraph 23 above) and 158 (referred to in
the preceding paragaph), as well as JANE KEMBER’s order
of November 21, 1973 to obtain all INTERPOL documents
on Scientology, by placing a Scientology agent in the
United States Department of Justice.

(31) On or about December 15, 1975, within the District of
Columbia, Michael J Meisner, having selected SHARON THOMAS
to become Scientology’s agent within the United States Department
of Justice, requested approval of his choice from RICHARD WEIGAND

(32) On or about December 20, 1975, RICHARD WEIGAND sent
a telex to Michael J. Meisner approving the selection an placement
of SHARON THOMAS as Scientology’s agent at the
United States Department of Justice.

(33) On or about January 18, 1976, within the District
of Columbia, Michael J. Meisner, Gerald Bennet Wolfe, and
a Scientology agent sent from Los Angeles, entered the office
of Lewis Hubbard of the Chief Counsel’s Office of the IRS and
stole documents located therein.

(34) On or about January 21, 1976, RICHARD WEIGAND wrote
a letter to HENNING HELDT informing him that the IRS office
of Lewis Hubbard in the District of Columbia had been
entered by Scientology agents and that numerous IRS documents
had been stolen therefrom.

(35) Between on or about February 1, 1976 and February 15, 1976,
HENNING HELDT, RICHARD WEIGAND, GREGORY WILLARDSON,
Michael J. Meisner and other Guardian’s Office officials met in various
groups on several occasions in Los Angeles, California, to discuss
the burglaries and the infiltration of United States government agencies
in the District of Columbia and the documents which has been
stolen from those agencies.

(36) On or about February 11, 1976, RICHARD WEIGAND wrote
a letter to JANE KEMBER, informing her that all
IRS documents sought pursuant to Scientology’s Guardian
Program Order 1361 had been obtained through Scientology
infiltration of the IRS.

(37) On or about February 29, 1976, SHARON THOMAS began
employment as a secretary as the United States Department
of Justice in the District of Columbia for the purpose of
obtaining documents and information of interest to Scientology.

(38) On or about March 4, 1976, within the District of Columbia,
Gerald Bennet Wolfe stole documents from the office of
Joseph Tedesco of the Exempt Organization Division of the IRS.

(39) On or about March 4, 1976, within the District of Columbia
Michael J. Meisner, having received from Gerald Bennet Wolfe
a package of stolen documents referred to in the preceding
subparagraph, forwarded said package to Los Angeles for
distribution to the defendants and unindicted co-conspirators.

(40) On or about March 10, 1976, within the District of Columbia,
Gerald Bennet Wolfe stole documents from the office of
Jeanne Gessay, of the Exempt Organization Division of
the IRS.

(41) On or about March 10, 1976, within the District of Columbia,
Michael J. Meisner, having received from Gerald Bennet Wolfe
a package of stolen documents referred to in the preceding
subparagraph, forwarded said package to Los Angeles for
distribution to the defendants and unindicted co-conspirators.

(42) On or about March 15, 1976, within the District of Columbia,
Michael J. Meisner, and Gerald Bennet Wolfe entered the
indentification equipment room at the IRS and falsely made
for themselves forged official IRS credentials bearing
false names.

(43) On or about March 22, 1976, within the District of Columbia,
Gerald Bennet Wolfe stole documents from the office of the
Assistant Commissioner Alvin Lurie of the IRS.

(44) On or about March 22, 1976 within the District of Columbia,
Michael J. Meisner, having received from Gerald Bennet Wolfe
a package of stolen documents referred to in the preceding
subparagraph, forwarded said package to Los Angeles for
distribution to the defendants and unindicted co-conspirators.

(45)Between on or about March 22, 1976 and April 26, 1976
within the District of Columbia, SHARON THOMAS on a
number of occassions stole documents from the office of
United States Department of Justice Attorney Paul Figley.

(45) Between on or about March 22, 1976 and April 26, 1976,
within the District of Columbia, Michael J. Meisner,
having received from SHARON THOMAS,
packages of stolen documents referred to in the preceding
subparagraph, forwarded said package to Los Angeles for
distribution to the defendants and unindicted co-conspirators.

(46) On or about March 27, 1976, MARY SUE HUBBARD,
JANE KEMBER, MO BUDLONG, HENNING HELDT,
RICHARD WEIGNAD, GREGORY WILLARDSON approved
Guardian Program Order 302 which was written by CINDY
RAYMOND. The order directed the infiltration
of all government agencies for the purpose of illegally
obtaining those documents related to Scientology which had been
withheld by these agencies pursuant to provisions of the
Freedom of Information Act.

(47) On or about April 9, 1976, within the District of
Columbia, Michael J. Meisner and Gerald Bennet Wolfe
entered the office of Associate Attorney General Togo G. West, Jr
at the United States Department of Justice, stole documents located
therein, and forwarded them to Los Angeles for distribution
to the defendants and unindicted co-conspirators.

(48) Between on or about April 14, 1976 and on or about
May 17, 1976, within the District of Columbia,
Michael J. Meisner and Gerald Bennet Wolfe on at least two
occassions entered the Offices of International Operations of
the IRS, stole documents contained therein, and forwarded
them to Los Angeles for distribution
to the defendants and unindicted co-conspirators.

(49) On or about April 27, 1976, RICHARD WEIGAND wrote
an order to MITCHELL HERMANN, a/k/a MIKE COOPER,
directing him to impliment burglaries of the office of
Assistant united States Attorney Nathan Dodell in the
District of Columbia and obtain any documents containing
any prediction on any potential subpeona or deposition
of L Ron Hubbard.

(50) Between on or about April 30, 1976 and May 17, 1976,
within the District of Columbia, SHARON THOMAS and
Michael J. Meisner, on two occassions, burglarized the office
of Special Assistant to the Assistant Attorney General
for Administration John F. Shaw at the United States Department
of Justice and stole documents found therein. Meisner then
forwarded these documents to Los Angeles for distribution
to the defendants and unindicted co-conspirators.

(51) On or about May 1, 1976, within the District of
Columbia, Michael J. Meisner and Gerald Bennet Wolfe
entered the United States Courthouse in order to locate
the office of Assistant United States Attorney
Nathan Dodell.

(52) On or about May 4, 1976, within the District of Columbia
Gerald Bennet Wolfe stole from the United States Courthouse
keys to the office of Assistant United States Attorney Nathan Dodell
for the purpose of having them duplicated.

(53) On or about May 21, 1976, within the District of Columbia
Michael J. Meisner and Gerald Bennet Wolfe entered
the office of Assistant United States Attorney Nathan Dodell
in the United States Courthouse and stole documents located
therein. Meisner then reported to RICHARD WEIGAND
details of the entry and forwarded the stolen
documents to Los Angeles for distribution
to the defendants and unindicted co-conspirators.

(54) On or about May 28, 1976, within the District of Columbia
Michael J. Meisner and Gerald Bennet Wolfe again entered
the office of Assistant United States Attorney Nathan Dodell
in the United States Courthouse and stole documents located
therein. Meisner then reported the details of the entry to
to his superiors in Los Angeles and forwarded the stolen
documents to Los Angeles for distribution
to the defendants and unindicted co-conspirators.

(55) On or about June 11, 1976, within the District of
Columbia, Michael J. Meisner and Gerald Bennet Wolfe
entered the United States Courthouse for the purpose of burglarizing
and stealing documents from the office of Assistant
United States Attorney Nathan Dodell and were
confronted by agents of the Federal Bureau of Investigation.

(56) On or about December 18, 1976, MITCHELL HERMANN,
a/k/a MIKE COOPER, wrote a letter to HENNING HELDT and
RICHARD WEIGAND explaining the attached "Project Troy"
which called for placing of a permanent electronic surveillance
in the IRS Chief Counsel’s Office in the District of Columbia
so that Scientology would remain informed of all IRS discussions
relating to Scientology’s request to be exempted from taxation.

(57) On or about December 20, 1976, HENNING HELDT
approved "Project Troy" described in the preceding paragraph.

(58) On or about May 27, 1977, HENNING HELDT, GREGORY
WILLARDSON and MO BUDLONG issued on behalf of
JANE KEMBER Guardian Order 158R ("Early Warning System") which
called once again for the infiltration of the Office of the
United States Attorney for the District of Columbia for the purpose
of obtaining information about any potential legal action
against L Ron.Hubbard.

 


End of part ONE (pages 1 through 16) of 42 pages total

 

 

COUNT TWO

On or about November 1, 1974, within the District of Columbia, the defendants MARY SUE HUBBARD, JANE KEMBER, MO BUDLONG, HENNING HELDT, DUKE SNIDER, RICHARD WEIGAND, GREGORY WILLARDSON, and MITCHELL HERMAN, a/k/a MIKE COOPER, and CINDY RAYMOND did willfully intercept and procure other persons to intercept oral communication, that is, oral communications made during a meeting of agents and employees of the Internal Revenue Service of the United States Department of the Treasury, held at the IRS headquarters in the District of Columbia.

(Violation of 18 U.S. Code 2511(1)(a), 2)

COUNTS THREE TO EIGHT

On or about the dates for each count listed below in the column

entitled "Dates", MARY SUE HUBBARD, JANE KEMBER, MO BUDLONG, HENNING HELDT, DUKE SNIDER, RICHARD WEIGAND, GREGORY WILLARDSON, and MITCHELL HERMAN, a/k/a MIKE COOPER, and CINDY RAYMOND and GERALD BENNET WOLFE entered a room consisting of the offices of individual listed below in the column entitled "Office of" with intent to steal property of another, that is, documents and photocopies thereof, located therein, which were the property of the United States of America, in the care, custody and control of the   individual listed below in the column entitled "Individual":

COUNT DATES OFFICE OF INDIVIDUAL

3 January 18,1976           Lewis J. Hubbard            Lewis J. Hubbard
                                           IRS, Office of Chief
                                           Counsel, 1111 Consti-
                                           tution Avenue, Northwest

 

4 March 4, 1976           Joseph A. Tedesco             Joseph A. Tedesco
                                           IRS, Exempt Organization
                                           Division, 1111 Consti-
                                           tution Avenue, Northwest

5 March 10, 1976           Jeanne Gessay                      Jeanne Gessay
                                           IRS, Exempt Organization
                                           Division, 1111 Consti-
                                           tution Avenue, Northwest

6. March 15, 1976           IRS Identification Room     Agents and Employees
                                           1111 Constitution                    of the IRS
                                           Avenue, Northwest

 

7. April 8, 176          Associate Deputy Attorney      Togo G. West, Jr.
                                          General, Togo G. West, Jr.
                                          United States Department
                                          of Justice
                                          Constitution Avenue and
                                          Ninth Street, Northwest

9. April 14, 1976          IRS Office of International       Howard J. Rosen
                                          Operations, Howard J. Rosen
                                          1325 K Street, Northwest

 

                            (Violations of 22 D.C. Code 1801(b), 105)

 

COUNTS NINE-THIRTEEN

On or about the dates for each count listed below in the column
entitled "Dates". within the District of Columbia, the defendants
MARY SUE HUBBARD, JANE KEMBER, MO BUDLONG, HENNING HELDT, DUKE SNIDER,
RICHARD WEIGAND, GREGORY WILLARDSON, MITCHELL HERMANN, a/k/a MIKE
COOPER, CINDY RAYMOND and GERALD BENNET WOLFE did willfully and
knowingly steal, purloin and convert to their own use records and
things of value of the United States and of a department and agency
thereof, that is, a package of documents and photocopies thereof, the
property of the department and agency listed below in the column entitled
"Department and agency," in the care, custody and control of the
individual listed below in the column entitled "Individual":

COUNT DATE DEPARTMENT AND AGENCY INDIVIDUAL

9 June 21, 1975 IRS, Office of Chief Counsel Lewis J. Hubbard

10 March 4, 1976 IRS, Exempt Organization Division Joseph A. Tedesco

11 March 10, 1976 United States Department of Justice Jeanne Gessay

12 April 9, 1976 United States Department of Justice Togo G. West Jr.

 

13 April 14, 1976 IRS, Office of International Operations Howard J. Rosen

(Violation of 18 U.S. Code 641, 2 )

COUNTS FOURTEEN-FIFTEEN

On or about the dates for each count listed below in the column
entitled "Dates". within the District of Columbia, the defendants
MARY SUE HUBBARD, JANE KEMBER, MO BUDLONG, HENNING HELDT, DUKE SNIDER,
RICHARD WEIGAND, GREGORY WILLARDSON, MITCHELL HERMANN, a/k/a MIKE
COOPER, CINDY RAYMOND and SHARON THOMAS entered a room consisting of the
office of John P. Shaw, Special Assistant to the Assistant Attorney General for
Administration, United States Department of Justice, Constitution Avenue
and Ninth Street, Northwest, with intent to steal property of another,
that is, documents and photocopies thereof, located therein, which were
the property of the United States of America, in the care, custody and
control of John F. Shaw:

 

COUNT DATE

  1. April 29, 1976
  2. May 17, 1976

 

(Violation of 22 D.C. Code 1801(b), 105)

 

COUNTS SIXTEEN-EIGHTEEN

On or about the dates for each count listed below in the column
entitled "Dates". within the District of Columbia, the defendants
MARY SUE HUBBARD, JANE KEMBER, MO BUDLONG, HENNING HELDT, DUKE SNIDER,
RICHARD WEIGAND, GREGORY WILLARDSON, MITCHELL HERMANN, a/k/a MIKE
COOPER, CINDY RAYMOND and SHARON THOMAS did willfully and knowingly steal,
purloin and convert to their own use records and things of value of the United States
and a department and agency thereof, that is, a package of documents
and photocopies thereof, the property of the department and agency
listed below in the column entitles "Department and Agency,"
in the care, custody and control of the individual listed below
in the column entitled "individual":

COUNT DATE DEPARTMENT AND AGENCY INDIVIDUAL

16 April 26, 1976 United States Department of Justice’ Paul Figley

 

17 April 29, 1976 United States Department of Justice’ John F. Shaw

 

18 May 17, 1976 United States Department of Justice’ John F. Shaw

 

(Violations of U.S. Code 641, 2)

COUNTS NINETEEN-TWENTY

On or about the dates for each count, listed below in the column
entitled "Dates". within the District of Columbia, the defendants
MARY SUE HUBBARD, JANE KEMBER, MO BUDLONG, HENNING HELDT, DUKE SNIDER,
RICHARD WEIGAND, GREGORY WILLARDSON, MITCHELL HERMANN, a/k/a MIKE
COOPER, and CINDY RAYMOND entered the office of Assistant United States
Attorney Nathan Dodell, located in the United States Courthouse,
Constitution Avenue and John Marshall Place, Northwest, with intent to
steal property of another, that is, documents and photocopies thereof,
located therein, which were the property of the United States of America, in
the care custody and control of Nathan Dodell.

COUNT DATE

  1. May 21, 1976
  2. May 28, 1976

 

(Violation of 22 D.C. Code 1801(b), 105)

COUNTS TWENTY ONE- TWENTY TWO

On or about the dates for each count, listed below in the column
entitled "Dates". within the District of Columbia, the defendants
MARY SUE HUBBARD, JANE KEMBER, MO BUDLONG, HENNING HELDT, DUKE SNIDER,
RICHARD WEIGAND, GREGORY WILLARDSON, MITCHELL HERMANN, a/k/a MIKE
COOPER, and CINDY RAYMOND did willfully and knowingly steal,
purloin and convert to their own use records and things of value of the United States
and a department and agency thereof, that is, a package of documents
and photocopies thereof, the property of the Office of the United States Attorney
for the District of Columbia, in the care, custody and control of
Assistant United States Attorney Nathan Dodell.

COUNT DATE

  1. May 21, 1976
  2. May 28, 1976

(Violation of 18 U.S. Code 641, 2)

COUNT TWENTY-THREE

1. Between on or about May 21, 1976 and on or about June 11, 1976,
within the District of Columbia, GERALD BENNET WOLFE and Michael J.
Meisner, on three occasions, entered the United States Courthouse for
the purpose of burglarizing and stealing documents from the office of
the Assistant United States Attorney. On each occasion, Meisner, and on
one occasion WOLFE, gained entry fraudulently, through the use of forged
IRS credentials bearing false names.

2. On or about June 11, 1976, during the third of these entries,
GERALD BENNET WOLFE and Michael J. Meisner were confronted and questioned
by agents of the Federal Bureau of Investigation (FBI)

3. Beginning on or about June 11, 1976 and continuing up to and
including on or about July 8, 1977, as a result of the confrontation
referred to in the preceding paragraph, the FBI and the Office of the
United States Attorney for the District of Columbia were conducting an
investigation which was continued in conjunction with a Grand Jury of
the United States District Court for the District of Columbia.
duly empaneled and sworn on or about October 12, 1976, to determine
whether violations of statutes of the United States and of the District
of Columbia had been committed in the District of Columbia and
elsewhere, and to identify the individuals who had committed such violations.

4. On or about June 30, 1976, within the District of Columbia,
GERALD BENNET WOLFE was arrested by agents of the FBI and charged with
the use and possession of a forged official government pass in violation
of 18 U.S. Code 499.

5. On or about August 5, 1976, within the District of Columbia,
a United States Magistrate Arrest Warrant was issued for Michael J.
Meisner charging him with the use and possession of a forged official
government pass in violation of 18 U.S. Code 499.

6. On or about May 13, 1977, an information was filed in the
United States District Court for the District of Columbia in criminal Case
No. 77-283 charging GERALD BENNET WOLFE with the wrongful use
of the government seal in violation of 18 U.S. Code 1017. That
same day. WOLFE entered a plea of guilty to that charge.

7. On or about June 10, 1977, , within the District of Columbia,
GERALD BENNET WOLFE was sentenced in Criminal Case No. 77-283
by United States District Judge Thomas A, Flannery. That same day, WOLFE
testified, pursuant to a subpoena, before the Grand Jury described in
paragraph three (3) above.

THE CONSPIRACY

8. Beginning on or about June 11, 1976, and continuing at least
until on or about July 8, 1977, within the District of Columbia and
elsewhere, the defendants
MARY SUE HUBBARD, JANE KEMBER, MO BUDLONG, HENNING HELDT, DUKE SNIDER,
RICHARD WEIGAND, GREGORY WILLARDSON, MITCHELL HERMANN, a/k/a MIKE
COOPER, and CINDY RAYMOND and GERALD BENNET WOLFE,
together with unindicted co-conspirator Michael J. Meisner,
and other unindicted co-conspirators both known and unknown to the Grand
Jury, willfully and knowingly did conspire, confederate, combine, and
agree together and with each other, to commit offenses against the
United States of America, to wit:

  1. to obstruct justice in violation of Title 18,
    United States Code, Section 1503;
  2. to obstruct a criminal investigation in
    violation of Title 18, United States Code, Section 1510;
  3. to harbor and conceal a fugitive from arrest
    in violation of Title 18, United States Code, Section 1071;
  4. to make false declarations in violation of
    Title 18, United States Code, Section 1623;

all in violation of Title 16, United States Code, Section 371.

OBJECT AND MEANS

9. It was an object of said conspiracy to corruptly influence,
obstruct and impede, and corruptly endeavor to influence, obstruct and
impede, the due administration of justice in connection with the investgation
referred to in paragraph three (3) above, and in connection with
the case of United States v Gerald Bennet Wolfe, Criminal Case
No. 77-283, referred to in paragraphs six and seven (6 and 7) above, for
the purpose of concealing and causing to be concealed the identities of the
persons who were responsible for, participated in, and had knowledge of (a)
the activities which were the subject of the above-mentioned investigation
and judicial proceedings, and (b) other illegal and improper activities.

10. It was further an object of said conspiracy, for the purposes
stated in paragraph nine (9) above, willfully to endeavor by means
of misrepresentation, intimidation, and force and threats thereof to
obstruct, delay, and prevent the communication of information relating
to a violation of a criminal statute of the United States by a person to
a criminal investigator.

Michael J. Meisner, would and did plan, direct, order, and assist in his
initial concealment, and later in his forcible removal
to secure hiding places where he was kept under guard.

11. It was further an object of said conspiracy, for the purposes
stated in paragraph nine (9) above, that the defendants and
unindicted co-conspirators, having received notice and acquired
knowledge of the fact that an arrest warrant for Michael J. Meisner
had been issued under provisions of law of the United States, would
and did harbor and conceal him, so as to prevent his discovery and
arrest.

12. It was further an object of said conspiracy, for the purposes
stated in paragraph nine (9) above, that the defendants and
unindicted co-conspirators, knowingly made and caused to be made
false material declarations under oath in proceedings before a Grand
Jury of the United States.

13. Among the means by which the defendants and the unindicted
co-conspirators would and did carry out the aforesaid objects of the
conspiracy were the following:

 

(a) The defendants and the unindicted co-conspirators would and did
plan, solicit, assist and facilitate the giving of false, deceptive,
evasive and misleading statements and testimony;

(b) The defendants and the unindicted co-conspirators would and
did give false, misleading, evasive and deceptive statements and testimony;

(c) The defendants and the unindicted co-conspirators, in order to
limit the investigation by exposing only GERALD BENNETT WOLFE
and Michael J. Meisner to criminal prosecution and in order to
prevent the uncovering of the true facts regarding the scope of
their illegal activities, would and did plan, solicit, order, assist,
encourage and facilitate the entry of a plea of guilty by Wolfe;

(d) The defendants and the unindicted co-conspirators, in an
effort to harbor and conceal unindicted co-conspirator

 

OVERT ACTS

14. To effect the objects and means of this conspiracy, the defendants,
together with the unindicted co-conspirators, did commit various overt
acts within the District of Columbia and elsewhere,
including but not limited to the following:

 

(1) On or about June 11, 1976, after Michael J.
Meisner notified MITCHELL HERMANN, a/k/a MIKE COOPER,
that he had been confronted by the FBI in the United States
Courthouse in the District of Columbia, HERMANN, after
discussing the matter with RICHARD WEIGAND, directed Meisner
to stay in a hotel overnight, prepare a memorandum detailing
what had occurred in the Courthouse that evening, and leave
for Los Angeles the next morning for further meetings.

(2) On or about June 11, 1976, RICHARD WEIGAND wrote a
letter to MO BUDLONG, notifying him of the events which had
transpired in the United States Courthouse in the District of Columbia,
and of the cover plans which he and his superiors in the
Guardian's Office - US proposed to implement.

(3) On or about June 12, 1976, RICHARD WEIGAND,
GREGORY WILLARDSON and Michael J. Meisner had a meeting
in Los Angeles, to discuss Meisner's report
on his confrontation with the FBI the previous day, and
to formulate the Guardian's Office's strategy in response
to the anticipated federal investigation into the Courthouse
entry in the District of Columbia.

(4) On or about June 12, 1976, RICHARD WEIGAND ordered
Michael J. Meisner to stay at a nearby hotel in Los Angeles under a false name.

(5) On or about June 13, 1976, HENNING HELDT, DUKE SNIDER,
RICHARD WEIGAND, and Michael J. Meisner had a meeting in Los
Angeles to discuss the alternative cover up plans prepared the previous
day by WEIGAND, GREGORY WILLARDSON and Meisner
and decided that a further plan should be considered.

(6) On or about June 13, 1976, RICHARD WEIGAND, GREGORY
WILLARDSON, MITCHELL HERMANN, a/k/a MIKE COOPER, and
Michael J. Meisner had a meeting in Los Angeles to discuss yet another cover up plan.

(7) On or about June 13, 1976, HENNING HELDT, DUKE SNIDER
and RICHARD WEIGAND had a meeting in Los Angeles to discuss
the cover up plan referred to in the preceding subparagraph. At the
conclusion of the meeting, HELDT approved the cover up plan pursuant
to which GERALD BENNETT WOLFE would be told to continue
working at the IRS until he was arrested, give the agreed upon cover
story to the federal authorities, plead guilty, and Michael J. Meisner
would then surrender, give the same cover story, and plead guilty.

(8) On or about June 14, 1976, pursuant to the directions of his superiors,
Michael J. Meisner changed his physical appearance to avoid arrest.

(9) On or about June 14, 1976, GERALD BENNETT WOLFE,
RICHARD WEIGAND, GREGORY WILLARDSON and Michael J.
Meisner had a meeting in Los Angeles, at which WOLFE was
briefed on the previously agreed upon cover story, and pursuant to
the agreed upon plan, was directed to return to the District of
Columbia, await arrest, give that cover story to the federal authorities and plead guilty.

(10) On or about June 14, 1976, MITCHELL HERMANN,
a/k/a MIKE COOPER, travelled to the District of Columbia to
supervise the execution of the cover up plan in the ,District of Columbia.

(11) On or about July 1, 1976, the defendants and unindicted co-conspirators
arranged for Michael J. Meisner to stay away from the District of Columbia,
remain in Los Angeles by appointing him National Secretary - US
and directing him to use the alias "Jeff Murphy."

(12) On or about June 30, 1976, MITCHELL HERMANN,
a/k/a MIKE COOPER, wrote a letter to RICHARD WEIGAND
which notified him of GERALD BENNETT WOLFE's arrest by
the FBI that same day in the District of Columbia, and of the steps
which were being taken as a result thereof, including the
destruction of evidence linking Meisner and WOLFE to Scientology.

(13) Beginning on or about July 1, 1976, and continuing until on or
about July 13, 1976, MARY SUE HUBBARD, MO BUDLONG,
and RICHARD WEIGAND discussed in various correspondence
the arrest of GERALD BENNETT WOLFE, the cover story to be
used by him and Michael J. Meisner and the destruction of all
evidence linking Meisner to the Guardian's Office and Scientology.

(14) On or about August 30, 1976, within the District of Columbia,
the Assistant Guardian for Legal Affairs - DC wrote a letter to the
Deputy Guardian for Legal Affairs - US which informed her that FBI
Agents had visited the Church of Scientology and had advised them
(1) that a warrant had been issued for the arrest ofMichael J. Meisner, and
(2) that the law prohibited the harboring of fugitives.

(15) On or about August 30, 1976, RICHARD WEIGAND wrote a
letter to MARY SUE HUBBARD which informed her that a warrant
had been issued for the arrest of Michael J. Meisner and that he had
ordered the removal of Meisner from all official Guardian's Office
positions, ordered Meisner to further alter his physical appearance,
and decided to send Meisner out of the country so he could not be
located by the authorities.

(16) Sometime after on or about August 30, 1976, MARY SUE
HUBBARD wrote a letter to RICHARD WEIGAND, responding to
his letter referred to in the preceding subparagraph, telling him that
instead of sending Meisner out of the country, it was preferable to
have him disappear within the United States.

(17) On or about September 2, 1976, RICHARD WEIGAND wrote a
letter to MARY SUE HUBBARD which notified her that under the
plans in effect Michael J. Meisner would not surrender until the
Guardian's Office determined it was in its best interest for him to do so.

(18) On or about September 3, 1976, RICHARD WEIGAND and
HENNING HELDT wrote a letter to MITCHELL HERMANN, a/k/a
MIKE COOPER, which directed him to hide Meisner in the Los Angeles,
California,area.

(19) On or about September 26, 1976, Michael J. Meisner wrote a
letter to MARY SUE HUBBARD which discussed the previously
approved cover up plans for the District of Columbia situation and
some alternative proposals he was submitting for her approval.

(20) On or about September 30, 1976, MARY SUE HUBBARD
wrote a letter to RICHARD WEIGAND which directed him to prepare
for her a list of all buildings which Michael J. Meisner had illegally entered.

(21) On or about October 8, 1976, RICHARD WEIGAND responded
to the letter of MARY SUE HUBBARD described in the preceding
subparagraph and informed her of all the government agencies and
private organizations which GERALD BENNETT WOLFE,
Michael J. Meisner and other Guardians Office operatives had illegally
entered, the number of illegal incursions made, and the
false names used on each occasion.

(22) On or about October 18, 1976, CINDY RAYMOND wrote a letter
to RICHARD WEIGAND informing him that she was in the process
of complying with his order to create false leads for the FBI
in their WOLFE-Meisner investigation.

(23) On or about October 31, 1976, MARY SUE HUBBARD wrote a
letter to RICHARD WEIGAND in which she discussed a further
aspect of the cover story which could be used by GERALD BENNETT
WOLFE and Michael J. Meisner in the District of Columbia.

(24) On or about November 1, 1976, HENNING HELDT wrote a
letter to GREGORY WILLARDSON in which he told him to order
GERALD BENNETT WOLFE to have his attorney resolve the case -
pending against him more speedily.

(25) On or about November 4, 1976, DUKE SNIDER wrote a
letter to HENNING HELDT which informed him that, pursuant
to the previously agreed cover up plans, all Guardian's Office files
were being purged of all references to Michael J. Meisner and
his activities on behalf of Scientology.

(26) On or about November 26, 1976, Michael J. Meisner wrote a
letter to MARY SUE HUBBARD which reviewed the events
surrounding the preparation of the cover story and cover up plans
by the other defendants and unindicted co-conspirators.

(27) On or about November 30, 1976, MITCHELL HERMANN,
a/k/a MIKE COOPER., wrote a report summarizing the events
leading up to the illegal entry and burglary of the United States
Courthouse in the District of Columbia and the preparation of
the subsequent cover up plans.

(28) On or about December 9, 1976, RICHARD WEIGAND sent to
MARY SUE HUBBARD the complete agreed upon cover up plan
for the handling of the investigation of the illegal entry and burglary
of the United States Courthouse in the District of Columbia.

(29) On or about December 9, 1976, RICHARD WEIGAND sent to
MO BUDLONG, a copy of the complete agreed upon cover up
plan referred to in the preceding subparagraph.

(30) On or about January 7, 1977, MITCHELL HERMANN, a/k/a
MIKE COOPER, wrote a letter to HENNING HELDT informing
him of the particulars of a meeting between GERALD BENNETT
WOLFE, his attorney, and the Office of the United States Attorney
for the District of Columbia.

(31) On or about January 23, 1977, MITCHELL HERMANN,
a/k/a MIKE COOPER, wrote a memorandum to HENNING HELDT
and RICHARD WEIGAND, informing them of a meeting which
GERALD BENNETT WOLFE was scheduled to have with the
Office of the United States Attorney for the District of Columbia
which should "serve as a means of presenting further cover story
to them as a possible means of forestalling a possible grand jury."

(32) On or about March 23, 1977, CINDY RAYMOND wrote a letter
and report to HENNING HELDT and RICHARD WEIGAND suggesting
to them that GERALD BENNETT WOLFE should be encouraged to
plead guilty to the charges pending against him in the District of
Columbia so that he could not be questioned by the grand jury.

(33) On or about April 20, 1977, JANE KEMBER wrote a letter to
HENNING HELDT informing him of the strategy to be implemented
by the Guardian's Office in Los Angeles, including: WOLFE
giving the United States Attorney's Office in the District of Columbia
the already prepared cover story, waiving indictment, and pleading
guilty, followed by Meisner surrendering, giving the same cover
story and also pleading guilty.

(34) On or about April 22, 1977, MARY SUE HUBBARD wrote
a letter to RICHARD WEIGAND directing him to complete the
cover story to be used by Michael J. Meisner, including a false
story about his having been a fugitive in Canada during the time
he was in Los Angeles.

(35) On or about April 27, 1977, the Information Bureau's Southeast
US Secretary wrote a letter to RICHARD WEIGAND informing
him that Michael J. Meisner wanted to surrender to the authorities
in the District of Columbia.

(36) Sometime after on or about April 27, 1977, HENNING HELDT
wrote a letter to MARY SUE HUBBARD informing her that
Michael J. Meisner was threatening to return to the District of
Columbia on his own and that plans were underway to "restrain"
him and "prevent him from leaving."

(37) On or about April 29, 1977, HENNING HELDT wrote a letter
to RICHARD WEIGAND and to the Deputy Guardian for Legal
Affairs US, directing them to restrain Michael J. Meisner, if
necessary, to prevent him from leaving his hiding place, and to
complete Meisner's cover story -- to "overcome ,all barriers and do it."

(38) On or about April 29, 1977, HENNING HELDT wrote a
letter to MARY SUE HUBBARD informing her that a more
isolated hiding place would be found for Michael J. Meisner,
that more bodyguards would be assigned to restrain him, and
that RICHARD WEIGAND and GREG WILLARDSON had
been directed to "get control over" Meisner.

(39) Between on or about April 28, 1977, and on or about
May 3, 1977, RICHARD WEIGAND, GREGORY WILLARDSON,
the Deputy Guardian for Legal Affairs US, and the Information
Bureau's Southeast US Secretary met at various times and in various
combinations with Michael J. Meisner, ordered him not to
surrender himself to the FBI in the District of Columbia ,
and warned him that he would be placed under guard.

(40) On or about May 2, 1977, HENNING HELDT approved a list of
expenses submitted to him by CINDY RAYMOND for guarding Michael J. Meisner.

(41) On or about May 3, 1977, RICHARD WEIGAND wrote to
MO BUDLONG, informing him that Michael J. Meisner had
threatened to return to the District of Columbia., that he had been
physically removed to another hiding place, and that a "crew"
had been "organized" to handle the worst eventualities by force
if necessary ("i.e. .gag, handcuff, etc.").

(42) On or about June 10, 1977, within the District of Columbia,
GERALD BENNETT WOLFE, testified falsely before a Grand Jury
of the United States District Court investigating the illegal entries
into the United States Courthouse. WOLFE then reported to the
Guardian's Office - DC where he was fully debriefed regarding his
testimony before the grand jury. A copy of that debriefing was sent
to the defendants and unindicted co-conspirators in Los Angeles and elsewhere.

(43) On or about June 15, 1977, Michael J. Meisner, pursuant
to the direction of MARY SUE HUBBARD and HENNING HELDT,
read a summary of the grand jury testimony of GERALD BENNETT
WOLFE in order to conform his own cover story to that of WOLFE.

(44) From on or about June 20, 1977 to on or about June 22, 1977,
MARY SUE HUBBARD, MO BUDLONG, HENNING HELDT,
GREGORY WILLARDSON and the Deputy Guardian for Legal Affairs - US,
in various correspondence were informed of the disappearance of
Michael J. Meisner and discussed various efforts to locate him.

(45) on or about July 3, 1977, MARY SUE HUBBARD wrote a
letter to HENNING HELDT directing him to "utilize resources to
figure out a way to defuse him [Meisner] should he turn traitor."
HELDT thereupon directed GREGORY WILLARDSON to carry
out HUBBARD's order.

(Violation of 18 U.S. Code 371)

COUNT TWENTY-FOUR

1 . Between on or about May 21, 1976 and on or about June 11, 1976,
within the District of Columbia, GERALD BENNETT WOLFE and
Michael J. Meisner, on three occasions, entered the United States Courthouse
for the purpose of burglarizing and stealing documents from the
office of an Assistant United States Attorney. On each occasion,
Meisner, and on one occasion WOLFE, gained entry fraudulently,
through the use of forged IRS credentials bearing false names.

2. On or about June 11, 1976, during the third of these entries,
GERALD BENNETT WOLFE and Michael J. Meisner were confronted
and Questioned by agents of the Federal Bureau of Investigation (FBI) .


3. Beginning on or about June 11, 1976 and continuing up to and
including on or about July 8, 1977, as a result of the confrontation
referred to in the preceding paragraph, the FBI and the Office of
the United States Attorney for the District of Columbia were
conducting an investigation which was continued in conjunction
with a Grand Jury of the United States District Court for the
District of Columbia, which was duly empaneled and sworn on
or about October 13, 1976, to determine whether violations of
statutes of the United States and of the District of Columbia
had been committed in the District of Columbia and elsewhere,
and to identify the individuals who had committed such violations.

4. Beginning on or about December 15, 1976, and continuing until at
least on or about June 19, 1977, within the District of Columbia
and elsewhere, the defendants MARY SUE HUBBARD, JANE KEMBER,
MO BUDLONG, HENNING HELDT, DUKE SNIDER, RICHARD WEIGAND, GREGORY
WILLARDSON., MITCHELL HERMANNY a/k/a MIKE COOPER,
CINDY RAYMOND, and GERALD BENNETT WOLFE, willfully
and knowingly, would and did corruptly influence, obstruct and
impede and would and did corruptly endeavor to influence, obstruct a
nd impede the due administration of justice in connection with the
Investigation referred to in paragraph three (3) of this Count, by
preparing and assisting in the giving of false and misleading statements
and information, for the purpose of concealing and causing to be
concealed the identities of the persons who were responsible for,
participated in, and had knowledge of (a) the activities which were
the subject of the said investigation and judicial proceedings, and
(b) other illegal and improper activities.

(Violation of 18 U.S. Code 1503)

 

COUNT TWENTY-FIVE

1. On or about June 10, 1977, within the District of Columbia, the defendant GERALD BENNETT WOLFE, having duly taken an oath that he would testify truthfully, and while testifying in a proceeding before a Grand Jury of the United States, duly empaneled and sworn in the United States District Court for the District of Columbia on October 13, 1976, did knowingly make a false material declaration as hereinafter set forth.

2. At the time and place alleged in paragraph one (1) of this Count, the Grand Jury was conducting an investigation to determine whether violations of statutes of the United States and the District of Columbia -- particularly Title 18, United States Code, Sections 499, falsely making an official pass; 641, theft of government property; 1017, wrongfully using the government seal, and Title 22, District of Columbia Code, Section 1801, burglary -- been committed in the District of Columbia, and to identify the individuals, besides the defendant, who had committed, caused the commission of, and conspired to commit such violations.

3. It was material to the said Grand Jury investigation to determine the reasons for the presence on May 21, 28 and June 11, 1976 of the defendant GERALD BENNETT WOLFE and one John M. Foster in the United States Courthouse for the District of Columbia, and the reasons for WOLFE's use on May 28, 1976 of an identification card bearing the last name of Hoake and his use on June 11, 1976 of falsely made IRS credentials bearing the name of Thomas J. Blake.

4. It was further material to the said Grand Jury investigation to determine whether while in the said United States Courthouse the defendant GERALD BENNETT WOLFE and the individual using the name John M. Foster had entered the office of any Assistant United States Attorney for the District of Columbia, and-whether they had unlawfully taken any documents or files located therein.

5. It was further material to the said Grand Jury investigation to determine whether the defendant GERALD BENNETT WOLFE and the individual using the name John M. Foster had photocopied any document which was the property of the Office of the United States Attorney for the District of Columbia on the photocopying machines belonging to said office.

6. It was further material to the said Grand Jury investigation to determine whether the defendant GERALD BENNETT WOLFE knew the true identity of the individual who had entered the United States Courthouse in the District of Columbia using the name John M. Foster.

7. It was further material to the said Grand Jury investigation to determine how the defendant GERALD BENNETT WOLFE and the individual using the name of John M. Foster had obtained the counterfeit and forged IRS credentials which they had used to enter the United States Courthouse on the dates mentioned in Paragraph three (3) of this Count.

8. It was further material to the said Grand Jury investigation to determine whether any other individual in the District of Columbia or elsewhere had conspired with, or aided and abetted, the defendant GERALD BENNETT WOLFE in obtaining his counterfeit and forged IRS credentials, and in entering the United States Courthouse for the District of Columbia. 9. At the time and place aforesaid, GERALD BENNETT WOLFE, appearing as a witness under oath before said Grand Jury, would and did knowingly make a declaration with respect to the aforesaid material matter as follows:

Q. When did you first come to know that the D.C. Bar Association had a library on the third floor of this building? A. I don't remember exactly the date. Q. Why did you want to come to this library? A. To study. Q. To study what? A. To learn how to do legal research.

Q. Why did you want to learn to do legal research?

A. Well, I was planning on going back to Minneapolis to complete or further my studies in music and I thought that in addition to clerical skills that I had that if I could learn to do some legal research that I could perhaps get a better paying, more interesting job to help pay for my school. Q. Where would you find that job? A. In Minneapolis, I presume. Q. Who would hire you in Minneapolis? A. I don't know. A law firm, perhaps.

Q. Did you embark on this program to learn how to do legal research with the idea in mind of presenting yourself to a Minneapolis law firm and saying, "I can do legal research for you"? A. Yeah, I think so. Q. You don't know? A. That's what I had in mind.

I Q. How did you propose to learn to do legal research in the D.C. Bar library? A. Someone was going to teach me. Q. Who was that someone? A. John Foster.

10. The underscored portions of the declarations of GERALD BENNETT WOLFE, quoted in paragraph nine (9) of this Count, were material to the said investigation and, as he then and there well knew, were false.

(Violation of 18 U.S. Code 1623)

COUNT TWENTY-SIX

1. The Grand Jury realleges and herein incorporates by reference paragraphs one (1) through eight (8) of Count TwentyFive (25) of this indictment. 2. At the time and place aforesaid, GERALD BENNETT WOLFE, appearing as a witness under oath before said Grand Jury, would and did knowingly make a declaration with respect to the aforesaid material matter as follows:

Q. Now, the first night that you were here in the courthouse, did you xerox anything?

A. I don't think so but I don't recall exactly, you know, which night.

Q. How long were you here on that first occasion? A. I don't remember how long exactly. Q. Approximately.

A. I don't know. Guessing, I'd say maybe an hour.

Q. Did you go anywhere else but the library that night?

I A. I don't know. I do know that one or more of the times here I did go to the men's room. Now, whether it was the first night or not that I couldn't recall exactly.

Q. Did you have to leave the library to go to .the men's room? A. Yes.

Q. Apart from going to the men's room, did you go anywhere else in the courthouse that night? A. I don't think so.

Q. From the first to the third floor library and back onto the first floor and out? A. Right.

3. The underscored portions of the declarations of GERALD BENNETT WOLFE, quoted in paragraph two (2) of this Count, was material to the said investigation and, as he then and there well knew, was false.

(Violation of 18 U.S. Code 1623)

COUNT TWENTY-SEVEN

1. The Grand Jury realleges and herein incorporates by reference paragraphs one (1) through eight (8) of Count TwentyFive (25) of this indictment. 2. At the time and place aforesaid, GERALD BENNETT WOLFE, appearing as a witness under oath before said Grand Jury, would and did knowingly make a declaration with respect to the aforesaid material matter as follows:

Q. Do you recall ever doing any xeroxing on the third floor of this building on any of the three occasions? A. Yes.

Q. What did you xerox?

A. Case histories.

Q. Case histories? What's a case history?

A. Well, a case out of a law book which contains cases.

Q. Did you bring the books from the library to the xerox machines?

A. Myself, yes, some of them.

Q. Did Mr. Foster carry books?

A. Yes.

Q. How many did you carry?

A. Approximately five.

Q. And how many did he carry?

A. Approximately the same.

Q. Were they the same type of books?

A. You mean as mine? Yes, I think so.

Q. And how long did you use the xerox machines?

A. Approximately fifteen minutes to a half hour.

Q. No longer than half an hour?

A. I don't think so.

Q. And what did you do when you left?

A. Brought the books back to the library and just left.

3. The underscored portions of the declarations of GERALD

BENNETT WOLFE quoted in paragraph two (2) of this Count, were material

to the said investigation and, as he then and there well knew, were

false.

(Violation of 18 U.S. Code 1623)

COUNT TWENTY-EIGHT

1. The Grand Jury realleges and herein incorporates by reference paragraphs one (1) through eight (8) of Count TwentyFive (25) of this indictment. 2. At the time and place aforesaid, GERALD BENNETT WOLFE, appearing as a witness under oath before said Grand Jury, would and did knowingly make a declaration with respect to the aforesaid material matter as follows:

MR. STARK: Let me inform you, however, that

the grand jury and the U.S. Attorney's Office

have a joint responsibility to investigate criminality

that occurs within the District of Columbia.

Now, you may have made your plea of guilty in this case and been sentenced today but Mr. Foster has not. Now, we are investigating Mr. Foster's involvement in this and there may come a time when Mr. Foster is sitting either in that chair or in the defendant's chair before a petit jury.

And your version of what happened on these three occasions will aid this grand jury in its determination of what if anything to charge Mr. Foster with. Do you understand that?

Q. Now, did you know Mr. Foster by any other name? A. No, I didn't. Q. You only knew him by John Foster? A. Right.

3. The underscored portions of the declarations of GERALD BENNETT WOLFE, quoted in paragraph two (2) of this Count, were material to the said investigation and, as he then and there well knew, were false.

(Violation of 18 U.S. Code 1623)

 

ATTORNEY OF THE UNITED STATES

IN AND FOR THE DISTRICT OF COLUMBIA

 

A TRUE BILL:

Foreperson