Testimony of Ms. Vibeke Damman, Oslo

PRESIDING JUDGE: You have been summoned to appear in this court to give evidence on the request of the plaintiff. You must know that you are liable to tell the truth in court, and that you give evidence on oath.

JACOBSEN: In which period have you been in Scientology?

DAMMAN: I started in October, 1973 and ended in November, 1979.

JACOBSEN: In which period have you been with Guardian's Office?

DAMMAN: From the middle of 1978 until November 1979.

JACOBSEN: In which capacity? What was your position?

DAMMAN: I started as something called project organizer. It is an event which is arranged by Scientologists in various parts of the world, and at that time it was arranged in Copenhagen. It was my job to see to it that it went well.

LEIFER: Couldn't we have it made clear ....

JACOBSEN: I would like not to be interrupted by Mr. Leifer.

LEIFER: Yes, but ...

PRESIDING JUDGE: Your opponent has asked that you do not interrupt this testimony.

LEIFER: Well, but there have been incorrect statements...already.

PRESIDING JUDGE: That may be, but during the cross-examination you will get the opportunity to ask questions about it.

JACOBSEN: What did you end as? In which position did you end?

DAMMAN: I became head of the bureau which is called Social Coordination. I was there until May, 1978 when I became Director of Rehabilitation within the same bureau.

ERIK JENSEN: Now I have to interrupt. I could not hear the witness.

JACOBSEN: Were you "Assistant Guardian"?

DAMMAN: No. Yes, that is Assistant Guardian for Social Coordination.

PRESIDING JUDGE: I understood that you had been there from 1973 till 1979. When was it that you got that position?-

DAMMAN: When I became head of the bureau called Social Coordination, from December, 1976 until May, 1978 when I became Director of Rehabilitation within the same bureau. I had that position until November, 1979. LEIFER: I would like to say that what I was interested in having clarified was where Mrs. Damman worked, because as far as I know she did not work at time of the conversation in question with Mr. Jørgensen at Jernbanegade 6, and she had no connection with Mr. Jørgensen.

PRESIDING JUDGE: Well, but ....

LEIFER: Then it is not very important if she has no connection with him.

JACOBSEN: Time is running. It takes five minutes and then I am not allowed to examine my witnesses.

LEIFER: We must stick to what is important and relevant.

JACOBSEN: You should have thought about that when you examined your witness.

PRESIDING JUDGE: That's enough now.

JACOBSEN: And about time. I would like to ask you: What is the function of Guardian's Office.

DAMMAN: To take care of all outside public, i.e. people who are not already in the Scientology organization. That public is people who are against scientology - it is the press, well, lawsuits - like this one - it is all, how do you put it, "charitable" work in quotes.

LEIFER: Why quotes?

PRESIDING JUDGE: Mr. Leifer, you really must stop now.

DAMMAN: I will get back to that.

JACOBSEN: I would like to ask you: Was it Guardian's Office special job to fight enemies of Scientology?

DAMMAN: Yes, it is especially that they deal with.

JACOBSEN: What's the channel of command? Who is at the head of Guardian's Office? At the end of your time there?

DAMMAN: The Guardian's Office where I worked?

JACOBSEN: In Copenhagen.

DAMMAN: In Copenhagen it is Bob Metzler.

JACOBSEN: Who was his immediate superior?

DAMMAN: Jane Kember.

JACOBSEN: Is it so that the Guardian's Office Denmark cannot do anything important, e.g. bring an action, without the approval of the Guardian's Office World Wide in England?

DAMMAN: Yes.

JACOBSEN: Does that mean that all actions which are brought in this country are brought in accordance with instructions from or conference with Guardian's Office World Wide?

LEIFER: Sorry, but that is a leading question.

JACOBSEN: I am getting very tired of listening to Mr. Leifer's interruptions.

LEIFER: And I am tired of listening to the way you ask questions.

PRESIDING JUDGE: Please leave that to me. There is no reason at all to believe that any problems will arise. It is the party's own witness.

DAMMAN: I don't mind answering. It is correct that any lawsuit which takes place in Copenhagen is first programmed from the Guardian Office, and then it is sent to the Guardian's Office World Wide for approval and revision, and then it is sent back here to be carried out.

JACOBSEN: Are decisions made elsewhere sometimes - not only decisions I mean, but the very decision that anything is to be done at all without anything being said about it from Denmark?

DAMMAN: Sorry, I did not understand the question.

JACOBSEN: Well, it may not be very easy. There has been a libel action against Professor Schulsinger. Do you know anything about it?

DAMMAN: Yes, I have written about it too.

ERIK JENSEN: Now I cannot hear again. Would Mrs. Damman please speak directly to the judge.

JACOBSEN: Tell briefly about who made the decision to bring an action for libel against Professor Schulsinger.

DAMMAN: That decision was made at the Guardian's Office World Wide in England.

ERIK JENSEN: Good, thank you.

PRESIDING JUDGE: We can avoid this confusion if you speak as loud as possible - and if the other side keeps quiet.

DAMMAN: Yes that would be nice.

JACOBSEN: How do you know that?

DAMMAN: I saw the program when it came from the Guardian Office World Wide. It was written at World Wide before it came to Denmark. It came to the place where I worked the Guardian's Office Europe, and then the order was that it was to be carried out at the Guardian's Office Denmark. The suggestion for the program has probably been made from Denmark, but approved in England 'and cannot be carried out in Denmark without approval i.e. in England.

JACOBSEN: What do you mean by "the program"?

DAMMAN: A program is written where you proceed step by step. There are many thing to be done when an action is to be brought. First you have got to find proof and then the whole action is planned in phases in advance before it is carried out, before summons and complaint is issued, or whatever it may be. For instance, in the Schulsinger case the group involved is to - it was the Citizens Commission on Human Rights - that group must receive instructions and training in what they are going to say when they appear in court, etc. All these things are written down in various phases. E.g. Item 1 - Get hold of Ingelise Hooernaert. Item 2: Tell her what to say in court. Item 3 ....

JACOBSEN: Does that in fact mean that a program is prepared for how the Scientologists are to explain in court?

DAMMAN: Yes.

JACOBSEN: A program is made?

DAMMAN: Yes.

JACOBSEN: Is it so that the Scientologists are encouraged to say something other than the truth? I can hardly believe that.

DAMMAN: Yes.

LEIFER: Now I must point out one thing. Earlier today a witness was told that the witness should observe the duty as a witness. This witness should be aware that in all probability the Church will make her responsible for what she says here as perjury.

PRESIDING JUDGE: You know your duty as a witness. I assume that you have fully realized the situation in advance.

LEIFER: I Conducted the case against Schulsinger and won it.

JACOBSEN: So Mr. Leifer has the floor more than I do.

PRESIDING JUDGE: I am doing my best. But on the other hand, I think that it should be granted that Mr. Leifer was right at this time to interrupt and point out that he on his part would warn the witness - in the same manner you warned his witness earlier today. There must be an adequate balance.

JACOBSEN. Yes, it could have been said from the beginning.

You say that you know that instructions have been given that if necessary the Scientologists are to lie in court, and you hold to that under oath?

DAMMAN: Yes.

JACOBSEN: Where have you seen it?

DAMMAN: I have seen it because at one time I was involved in writing' out the program the legal department here sent for approval. Phase by phase is written what witnesses, if any, in a lawsuit which was in Holland were to explain in court, and it included outright lies. I knew that at the time I was writing it out.

LEIFER: Excuse me, Holland ....

PRESIDING JUDGE: Now you stop.

LEIFER: But it was against Schulsinger.

PRESIDING JUDGE: Mr. Leifer, we have always been on good terms with each other. You are the oldest attorney in this city and enjoy great respect.

LEIFER: That is correct, but I was the one who conducted the case against Schulsinger, and it had nothing to do with Holland.

PRESIDING JUDGE: That may be so, but we must have peace now. Otherwise I will not be able to preside in a manner which all can be satisfied with.

JACOBSEN: Have you personally received or carried out orders from the world headquarters?

DAMMAN: Yes.

JACOBSEN: Have you ever received orders to the effect that attempts should be made to annoy a person or institution?

DAMMAN: Yes.

JACOBSEN: Could you give some examples?

DAMMAN: Yes. The National Society for the Welfare of the Mentally Ill (Landsforeningen for Sindslidendes Vel, LSV). As head of the Social Coordination bureau I ran or directed i.e. the group which was called The Citizens Commission on Human Rights. Its object is to annoy psychiatrists. So its declared aim is to have human rights introduced for psychiatric patients, but with regard to the National Society for the Welfare of the Mentally Ill we also got instructions to see to it that LSV was annoyed as much as possible by the things we could come up with.

ERIK JENSEN: Excuse me, what is LSV?

JACOBSEN: The National Society for the Welfare of the Mentally Ill. It has been said several times.

DAMMAN: There were instructions from England that we should take care to go after that society as much as we could. We appeared at meetings and tried to confuse the meetings and were to take care that anything we got to know about the society which could be interpreted. It negatively was spread to the press etc. in an attempt to sort of putting them in a bad light.

JACOBSEN: Can you mention any examples of a person?

DAMMAN: Within the LSV or generally?

JACOBSEN: Yes, I asked you if you had received orders to try to annoy any person or institution.

DAMMAN: Yes, Mr. Finn Jørgensen, psychiatrist at the Sankt Hans hospital for mentally ill.

JACOBSEN: Any other examples?

DAMMAN: Not that I can recall right now.

JACOBSEN: I would like to ask you some general questions.

If a Scientology organization in a country, e.g. Denmark is criticized by persons or organizations, what happens then in your experience?

DAMMAN: Well, let us say that a newspaper has a negative article on Scientology. That article is then translated and sent to the Guardian's Office Europe and then to England and then there are standard instructions how to deal with such a case. First of all it is sought to get a correction in the paper. It means that you try to have a correction of the things which you think are false. Then it is seen to that the person who is responsible for the article - maybe also the paper's editor responsible under the press law - is checked, and then if the case goes on - let us say that the newspaper continues to write negative things about Scientology - then you bring the things that have been found out about that person.

JACOBSEN: What sort of things?

DAMMAN: Well, first of all you look for sexual, criminal things, sexual behaviour because that is' Ron Hubbard's instruction. He thinks most can be found in that field.

JACOBSEN: Am I to understand that if these is an editor of a newspaper who will not toe the line, it is tried to dig up things about his sexual relations to use it against him, to harm him? Is that correct?

DAMMAN: Yes.

JACOBSEN: You have yourself taken part in that?

DAMMAN: Yes. I have seen it.

JACOBSEN: You have not been directly involved, but you have seen it?

DAMMAN: Yes.

JACOBSEN: Is it correct that there are a number of written orders so-called Policy Letters - orders from the world headquarters with standard procedures for how to attack critics?

DAMMAN: Yes, that is correct.

JACOBSEN: Can you tell us what is the authority of such a Policy Letter in relation to local Guardian's Offices? Is it something you are in duty to follow?

DAMMAN: Yes, that is right. It is a Policy Letter, i.e. it is Signed by Ron Hubbard or signed by ....

JACOBSEN: Jane Kember?

DAMMAN: Yes, then it is not a Policy Letter, but then it is policy within Guardian's Offices, and must be observed by those who are in charge of that field of activity.

JACOBSEN: It may e.g. be to the effect that a person is to be annoyed?

DAMMAN: Yes.

JACOBSEN: Have you seen examples of that?

DAMMAN: Yes, I have.

JACOBSEN: What happens if a person, who gets it, and who is responsible in the Guardian's Office, refuses to carry out such an order or carries it out contrary to the instructions? What happens then?

DAMMAN: If you refuse to carry out an order made by World Wide several things may happen. Most often the person in question is made to read the order once more, several times, until he understands it, and that is generally that, because then he does what he is supposed to.

If he still does not do it and the order is still considered to be right, he will be punished, get a disciplinary punishment.

JACOBSEN: What could that be?

DAMMAN: There are several stages. If it is a serious disciplinary punishment you will be isolated. I don't mean locked behind a door, but isolated from communication with your colleagues. You are not allowed to talk to them. You are not allowed to talk to anybody; you must write all the bad things you have done this year and past years. When you have done that for a couple of days you will be taken to the E-meter and asked if you have finished writing. If the E-meter says that you have not finished writing you will be set to write more bad things you have done. At the same time you are set to do rather hard physical work, e.g. wash walls or floors or lifting heavy things. You do all the work that is unpleasant and difficult and heavy. You do that until you are corrected so much or rehabilitated so much that you agree to do what you were first asked to do.

JACOBSEN: Do they have their own courts?

DAMMAN: Yes, there are internal courts.

JACOBSEN: What are they called?

DAMMAN: Committees of Evidence.

JACOBSEN: Have you been before one?

DAMMAN: Yes.

JACOBSEN: Where?

DAMMAN: Here in Denmark and one in England.

JACOBSEN: What was the decision against you?

DAMMAN: Degradation.

JACOBSEN: Do you know about other people present in this court room now, I don't know if you have looked around - I am thinking of Juvonen and Peter Jensen.

DAMMAN: Yes, I know about Allan Juvonen and Per Olof Jørgensen.

JACOBSEN: Why? What happened to Per Olof Jørgensen?

DAMMAN: Per Olof Jørgensen made a mess of an operation once which was published in the newspaper Ekstra Bladet. It was his job to get Jakob Andersen a bad reputation - the way Scientology has tried ever since, well at least from when I joined. It was not very successful. It was discovered at one' time and proclaimed in Ekstra Bladet. He got a disciplinary punishment for that. Not because he did it, but because he did it so badly that it was discovered.

JACOBSEN: From what you said I understood that it was something he was set to do. He himself has explained that it was completely his own idea and nobody had asked him to.

DAMMAN: But that is not correct.

JACOBSEN: Who asked him?

DAMMAN: Well at least he got instructions from Bob Metzler and also he got direction from B1 for Europe and also from World Wide.

PRESIDING JUDGE: Please, let us have this slowly.

DAMMAN: Above Bob Metzler and the Guardian's Office is the information office in Europe.

PRESIDING JUDGE: Where is that?

DAMMAN: At Nordre Fasanvej.

PRESIDING JUDGE: Also in Copenhagen?

DAMMAN: At least until recently. I think they have just moved.

JACOBSEN: May I ask you: Who is head of B1?

DAMMAN: In Europe?

JACOBSEN: Yes.

DAMMAN: Lennart Larsson.

JACOBSEN: Who is B 1?

DAMMAN: They are the ones who deal with people who attack scientology. They deal with difficult employees, their background, and they keep the reports made about it. And then they deal with all non- Scientologists who attack scientology, and make reports and records and make files and microfilms so that it will be kept.

And they deal with extreme cases - the way it was with Jakob now that is Per Olof Jørgensen worked in the office called B1 or information office.

ERIK JENSEN: Excuse me: "Jakob", is that Jakob Andersen?

DAMMAN: Yes.

LEIFER: Do you call him by his Christian name?

DAMMAN: Yes. Don't you?

LEIFER: No. I definitely don't call people by their Christian names except a few whom I have known for more than 50 years.

JACOBSEN: Bu you call him by his Christian name?

DAMMAN: Yes.

JACOBSEN: What was done in his case?

DAMMAN: It was tried to discredit him. It was tried to get rumours or things about him which would discredit him so much that he would probably stop to attack scientology. What was Per Olof Jørgensen set to do.

PRESIDING JUDGE: It was called B1.

DAMMAN: B1, yes. I know of other cases where they have operated in Denmark ....

JACOBSEN: Before you tell us that I want to be dead sure I have not misunderstood you. You said that you knew that Per Olof Jørgensen contacted Hetler after direct orders from Bob Metzler. How do you know?

DAMMAN: I know because I talked with Per Olof Jørgensen after he had finished.

JACOBSEN: He said in this court today that it was his own idea. But he told you the opposite?

DAMMAN: But that is how it is. He was not properly employed yet then, actually. He was just training at that time. True, he had a title for his work, but he was not fully trained at that time so the things he did were to be approved by his superiors. It was a failure - a last desperate attempt, I think - to bring Jakob Andersen into discredit. It had sort of been the main task for that bureau for so many years, and they had not succeeded.

JACOBSEN: Why did he tell you about it?

DAMMAN: That was when he started to work at Guardian's Office Europe at Nordre Fasanvej.

JACOBSEN: About when was than?

DAMMAN: It must have been in the summer 1979.

JACOBSEN: Where did the conversation take place?

DAMMAN: It took place, well, various places. It took place in a room which is next to the course room.

JACOBSEN: At Sendre Fasanvej ?

DAMMAN: Nordre Fasanvej.

JACOBSEN: Number?

DAMMAN: 186.

JACOBSEN: Whose office is it?

DAMMAN: It is not an office. It was a correction division.

JACOBSEN: Who was present.

DAMMAN: I do not remember if there was somebody else.

JACOBSEN: But you are sure he said it?

DAMMAN: Yes.

JACOBSEN: Have you talked with Bob Metzler about it?

DAMMAN: No, not that particular case.

JACOBSEN: Have you discussed it with other people in Scientology?

DAMMAN: Yes.

JACOBSEN: With whom?

DAMMAN: Karna Jensen.

JACOBSEN: Where is she now?

DAMMAN: She is at the Guardian's Office Europe.

JACOBSEN: Where is that?

DAMMAN: Nordre Fasanvej.

JACOBSEN: Karla Jensen?

DAMMAN: Karna Jensen.

JACOBSEN: The reason I am so interested is that I think that it is of utmost importance that we get the details about it. Do you know a man called Per Tennberg?

DAMMAN: Yes.

JACOBSEN: Where did he work?

DAMMAN: When I started at the Guardian's Office Europe in 1975 he worked there, he worked in an office called B1.

JACOBSEN: What do you know about Per Tennberg's work for the Guardian's Office in relation to Jakob Andersen?

DAMMAN: Nothing much but that he was on a special mission, special mission in Denmark, and I understood that it had to do with Jakob Andersen.

JACOBSEN: I see, but you do not know him very well?

DAMMAN: No, because it was a very secret bureau so to speak, and not very many are told what actually takes place there.

JACOBSEN: Is it correct that Jakob Andersen has been described as what is called SP, a Suppressive Person?

DAMMAN: Yes.

JACOBSEN: What sort of person is that?

DAMMAN: Well, it is the lowest mentally you can get, where all you want is to destroy, where you are not all there, and where the right place for you is a mental hospital.

ERIK SENSEN: What does it mean?

DAMMAN: Suppressive Person. In Danish "undertrykkende person".

JACOBSEN: What are the consequences for such a person?

DAMMAN: Well, it means that you are free, sort of, for attacks from the Scientologists.

JACOBSEN: That can be misunderstood.

DAMMAN: You are free for all Scientologists to attack.

JACOBSEN: You are "fair game" so to speak, you may be attacked by anybody.

DAMMAN: The way it is effected by B1. If things from the past can be found which can be used against him, it is seen to that those things are spread to his friends and acquaintances and the press. They are spread so much that the man collapses mentally. That is an aim at any rate.

JACOBSEN: It does not matter whether it is true or false?

DAMMAN: It is relatively unimportant because when a man is a suppressive person it is his declared aim to suppress people, i.e. the Scientologists and the moment all you want is to suppress; all is permitted.

JACOBSEN: Have you got any examples that it has been tried to suppress someone?

DAMMAN: Yes, I have.

JACOBSEN: Any names?

DAMMAN: No, I can't mention any names. That is why I hesitated. As head of Social Coordination Bureau I participated in planning meetings together with the heads of the Guardian's Office Europe. At one time it was mentioned at one of these meetings that B1 had been successful in having a Dutch professor, who had attacked the Scientologists, send to a mental institution?

JACOBSEN: Did they succeed?

DAMMAN: Yes, they succeeded. I mean, he was sent to a mental institution, to hospital, and in the end he was so scared and so confused that he signed a statement which the Scientologists wanted him to sign, that he would not attack Scientology. I can remember that a good time was being had about it. Now they had finally got him down on his knees.

He was so scared that he wet his pants. It was mentioned during the meeting.

JACOBSEN: Do you know anything about how actions were started against Finn Jørgensen. Was he also a SP?

DAMMAN: Yes, it was checked. I was in on it tasking to see to it that he was checked by BI, because he was against The Citizens Commission on Human Rights and against the Scientologists and according to Ron Hubbard something is wrong with you if you are against Scientologists. Therefore it was Bl's job to find something.

JACOBSEN: Was anything found against Finn Jørgensen.

DAMMAN: No, not very much.

JACOBSEN: Jakob has been checked many times in the past years?

DAMMAN: Yes, it has been said with some despair several times that still nothing could be found and that it has still not been possible to really get Jakob Andersen.

JACOBSEN: Have you ever participated in carrying out orders which were against your own conscience or which you have later regretted?

DAMMAN: Yes, which I have regretted. But at that time it was not against my conscience.

JACOBSEN: Why not?

DAMMAN: No, because you get to a point where everything which is said by Ron Hubbard is true. There don't seem to be any questions to ask about it.

JACOBSEN: Even if in the ordinary respectable sense it meant committing a crime, theft or perjury in court you would do it if you thought it was Ron Hubbard's wish.

DAMMAN: Yes. You are so far out that you think that it is in the best interests of humanity what you do, because the only people who know the truth on earth are Scientologists. That is why you have to use any means available.

JACOBSEN: Well, I see.

LEIFER: Since it may be several hours from now, maybe we could adjourn and continue tomorrow.

PRESIDING JUDGE: I don't know.

LEIFER: I understood earlier that Your Honour might not be unwilling to do so.

PRESIDING JUDGE: You know a little about what the future may bring.

JACOBSEN: I would say that it would be possible to get through with the witness. Would you mind if you were to stay here till tomorrow?

DAMMAN: No, that is all right.

JACOBSEN: We on our side would like to be kind - although we are not treated kindly. This was not directed towards the court.

PRESIDING JUDGE: If this can be conducted in a friendly manner that is what we would prefer. We will write that at 3.45 hours p.m. your examination was suspended and that you will return tomorrow at 11 o'clock a.m. for resumed examination. You may stay in court and listen - no, you are still a witness, so you had better leave and return tomorrow at 11 o'clock in the forenoon.

Now it is Mr. Haaest.

[Then there was a discussion between the presiding judge and the attorneys as to whether Mr. Haaest, Editor, was to be examined as a party in his own action or as a witness in the tape case.

The result was that considering the late hour the-court did not want any further witness examinations that day and the case was adjourned until Friday at 11 o'clock in the forenoon.]

Friday, March 14, 1981 at 11 o'clock a.m.

Examination of Mrs. Vibeke Damman continued

JACOBSEN: I have some questions which I would like to pick up from yesterday. You said something about that orders were received from Jane Kember and her substitute in the world headquarters.

DAMMAN: Yes.

JACOBSEN: How were these orders received? Written or oral?

DAMMAN: Written.

JACOBSEN: Have they got any name?

DAMMAN: You mean to whom they were addressed?

JACOBSEN: Did they have a designation, Guardian Order or Guardian Program Order? Is that correct?

DAMMAN: Yes.

JACOBSEN: What's the difference between the two?

DAMMAN: A Guardian Order will normally contain general policy, general guidelines for what to do in certain situations. A Guardian Program' Order is about the phased handling of a specific case.

JACOBSEN: If e.g. an order says that a libel action is to be brought against Professor Schulsinger, will it then be in the form of a Guardian Program Order?

DAMMAN: Yes.

JACOBSEN: You told a little about Jane Kember yesterday. Was there something about some childrens' schools which you were engaged in.

DAMMAN: Yes, I was. Among other things I have been in on starting the school in Denmark which is now called Kerneskolen.

JACOBSEN: Where is that school?

DAMMAN: At Vanløse, Copenhagen.

JACOBSEN: Is that the school which Inge Schirmer has got something to do with?

DAMMAN: Yes.

JACOBSEN: Was it a school which was subsidized by the Danish Treasury in accordance with certain rules in the Education Subsidy Act or the Free School Act?

DAMMAN: Yes, it is supported in accordance with the rules which apply to private schools which are approved by the Ministry of Education. That means that the Treasury grants a 85 per cent subsidy, that is 85 per cent of all costs are covered by the state.

JACOBSEN: I seem to know that Inge Schirmer who was leader of this school was declared to be what we heard yesterday was a Suppressive Person. Is that correct?

DAMMAN: Yes, that's correct. She was at one time. That was at the end of 1979.

LEIFER: Excuse me, but I would like to ask my honoured colleague: What is it that you want to prove by that in this libel action?

JACOBSEN: Don't interrupt me, please.

DAMMAN: There were some problems with Inge Schirmer because she refused to pay money to the Guardian's Office out of the money she got from the pupils or from the state.

JACOBSEN: Does that mean that she passed on money for purposes which had nothing to do with the school?

DAMMAN: Well, she didn't want to do it because she had budget problems. The school only had the income it needed, and it was also a problem about entries in the accounts. She was responsible to the Ministry of Education. It was a problem to get it into the accounts where she paid the money.

JACOBSEN: I understand you this way. What posed the difficulties and what was the reason she was declared a SP was that she would not let government funds pass on for purposes which were not within the scope of the government funds, viz. to the Guardian's Office.

DAMMAN: That was the most important reason, yes.

JACOBSEN: You told us yesterday that you knew about actions carried out against persons who were enemies of Scientology, and you mentioned i.e. as examples the psychiatrist Mr. Finn Jørgensen and Jakob Andersen who is sitting here next to me.

DAMMAN: Yes.

JACOBSEN: Do you know of other cases?

DAMMAN: Yes, Johannes Aagaard.

JACOBSEN: Who withdrew as a witness. What is it about him?

DAMMAN: He has been persecuted for the same reasons as Jakob Andersen.

JACOBSEN: In which way?

DAMMAN: There have been actions. A special action which I can recall was when he was about to start a center at Ebeltoft, Jutland. The Guardian's Office wanted to prevent that. Allan Juvonen was in special charge of that action - planned it with approval from England. Anonymous letters were sent around in the town, and what I especially remember was that the Mayor via letters ....

JACOBSEN: Which town was it?

DAMMAN: Ebeltoft . it was to be convinced that the center which Johannes Aagaard wanted to start was doubtful, that his purposes with it were suspicious. That is that he would use it to keep people imprisoned. It was something called "deprogramming" which was described as something very strong.

JACOBSEN: You mean it was accusations against Johannes Aagaard for doing things resembling criminal actions?

DAMMAN: Yes.

JACOBSEN: And anonymous letter were sent to the Mayor i.e. to get at him?

DAMMAN: Yes.

JACOBSEN: What was the reason?

DAMMAN: To stop that center and to get at Johannes Aagaard personally.

JACOBSEN: Johannes Aagaard had criticized Scientology?

DAMMAN: Yes.

JACOBSEN: Where do know all this from?

DAMMAN: Because it was brought up in a planning meeting and was discussed much at a meeting.

JACOBSEN: Whom have you talked with about it?

DAMMAN: Allan Juvonen.

JACOBSEN: Are there other Scientologists present here today whom you have talked with about it?

DAMMAN: No, because most of those present here today are from the Guardian's Office Denmark, while I was at the Guardian's Office Europe.

JACOBSEN: We have heard that the head of the Guardian's Office apparently disclaims much of the responsibility for what an agent in the field in this instance Per Olof Jørgensen - does in various connections.

Would you consider it possible that an agent under Bob Metzler in a case like that of Jakob Andersen goes out and tries to get material by himself without having discussed it with anybody? Would you consider it possible - with the knowledge you have of the functions of the Guardian's Office,

DAMMAN: No. All actions made by him will be known. He has either been ordered to do it or it would have been accepted by his superiors. JACOBSEN: So you think that if Per Olof Jørgensen has collected material about Jakob Andersen, he has done so in accordance with orders from his superiors?

DAMMAN: Yes.

JACOBSEN: Have you any concrete knowledge of the case in question?

DAMMAN: No, not except what has been written in the Ekstra Bladet.

JACOBSEN: All right, but have you any concrete knowledge about it from Scientology?

DAMMAN: Only what I talked with Per Olof Jørgensen about afterwards.

JACOBSEN: Yes, you explained that yesterday.

DAMMAN: Yes.

JACOBSEN: You don't know anything except what you.explained yesterday? Per Olof Jørgensen himself stated that it was Bob Metzler who had ordered him to do it?

DAMMAN: Yes.

JACOBSEN: Did he say more than you explained yesterday? Now it was a bit of a hurry at the end of yesterday, and it is a very central point in the case.

DAMMAN: No, I can't remember anything specific.

JACOBSEN: But you do remember at any rate that .... Did he say anything about him being happy about it and thought it was all right, or did he actually worry a bit about what he had got mixed up in?

DAMMAN: Yes, his feelings about it was that he was sorry about the whole case and he felt rotten - also because it was discovered.

JACOBSEN: One can feel rotten for several reasons. Because you don't like to be in on it or because it was discovered. Which was it?

Or was it both?

DAMMAN: A mixture of both probably, but rotten mostly because it was discovered, because he felt very inexperienced. He felt that he had not been trained enough to make such actions on his own, but he was sent out in the field to do it. When the whole action started he had not the faintest idea of what he was getting in on and what he was to do, and which consequences and implications it would have for him.

JACOBSEN: But one thing is certain and you can confirm that today as well he said that it was Bob Metzler who had given him the orders to do it?

DAMMAN: Yes.

JACOBSEN: I would like to ask the witness whether she has made any statements on her own case to the press. we have an article, which is in Exhibit bundle VII, and of which, as it is, no decision has. been made for production. I would find it odd if I could not show the witness the article to which she herself has made a statement. It is on page 23 in Exhibit bundle VII. It is an article in a paper called "Vort Land" (Our Country) from July 10, 1980 in Norway.

There is no need to take it out, I will only ask the witness if it is correct that she has made a statement to that paper.

DAMMAN: Yes, that is correct.

JACOBSEN: There is a headline in it: "Ex-Scientologist: We used dirty methods o"

DAMMAN: Yes.

JACOBSEN: You have made a statement to this paper and told about some of the things you are telling in this court today. Is that correct?

DAMMAN: Yes, that is right.

JACOBSEN: I don't think that I will confront you with this article. It is better to question you directly. But it is correct that you have made a statement to the press about it?

DAMMAN: Yes.

JACOBSEN: Have you met any reactions in this connection?

DAMMAN: You mean from Scientology?

JACOBSEN: Yes.

DAMMAN: After the article was published we have had several visits, i.e. one from the office called B1 for Europe, where they tried to make me and my husband stop saying more and kind of asked us what it was we wanted not to do it again. I mean, what it was we tried to obtain.

JACOBSEN: "Wanted". Was the idea that you would get money or other benefits?

DAMMAN: We did not really go much into that, but that is what it sounded like.

JACOBSEN: You refused?

DAMMAN: Yes, we did.

JACOBSEN: Incidentally, what was your salary in Scientology when you were head there?

DAMMAN: The maximum amount I got was 253 Danish Kroner per week. (approx. US$ 38),

JACOBSEN: But did you then get .board and lodging?

DAMMAN: No, the salary would have to cover that.

JACOBSEN: But you cannot live on that?

DAMMAN: No.

JACOBSEN: But it means that that was the payment you got Would you say that it was a vocation more than a job.

DAMMAN: Yes.

JACOBSEN: Do you know if in Scientology there were ever plans of action other than the kind you have mentioned in connection with Jakob Andersen - I mean downright violent actions?

DAMMAN: No, not violent actions.

JACOBSEN: That you have never ....

DAMMAN: That I don't know about.

JACOBSEN: Well. Then I will ask you: Do you know Peter Jensen?

DAMMAN: Yes, I do.

JACOBSEN: Have you worked together with him?

DAMMAN: No, not directly. He worked in the Guardian's Office Denmark. And I was in the Guardian's Office Europe, you know.

JACOBSEN: Has Peter Jensen worked with B1?

DAMMAN: Yes, he had to. I think he has a different job now, but before he was PR Manager for Denmark and there he had to cooperate with B1 in his capacity of PR Manager.

JACOBSEN: Has there been any coordination between the open and the secret work in B1?

DAMMAN: Yes, very much so.

JACOBSEN: How did that take place?

DAMMAN: You know, the PR division looked after the public side, including the press and that sort of things which they must try to handle so they get a positive attitude towards scientology. In such cases where the PR division meet people who are against scientology, people who try to attack or oppose scientology, the names are passed on to B 1 for a check in order that PR may have up its sleeve information about the persons who now attack Scientology, so that if they get into an awkward situation and if the person in question will not stop his attacks, PR can use it against that person.

JACOBSEN: May I ask you: What is a Security Check?

DAMMAN: It is a procedure, a sort of conversation therapy where there is a trained auditor - i.e. a person who is trained in performing various techniques within scientology. He sits with his E-meter and another person is sitting on the other side of the table with those tin-cans in his hands. According to scientology it is possible to register a person's mental condition on the E-meter. Questions are asked. It is called "pre clear".

JACOBSEN: I know what it is. It is for the benefit of the court. I know that Your Honour has heard it many times. It is a person who is not yet clear. Are you asked questions as to whether e.g. you have committed any criminal offences, if you have had any illegal sexual relationships, homosexual relations?

DAMMAN: Yes.

PRESIDING JUDGE: Mr. Jacobsen, I think we should take care not to get too far away from the case proper.

JACOBSEN: Well, it is in connection with what is written in the memo about E-meters.

PRESIDING JUDGE: Good.

JACOBSEN: It is for that purpose only.

LEIFER: It is my opinion that we are far away from the libel case.

PRESIDING JUDGE: You heard that that thought had crossed my mind, but I think that Mr. Jacobsen gave an answer which did that I have put it out of my mind again.

JACOBSEN: Thank you. I would like to show you this Technical Bulletin from 1972. Have you seen anything like this before, Vibeke?

DAMMAN: Yes, I have seen that kind of thing before.

JACOBSEN: Have you personally used E-meters?

DAMMAN: Yes, I have tried it. But I have not participated in asking that kind of specific questions.

JACOBSEN: Do you know if such questions have been asked?

DAMMAN: Yes. I have been asked such questions.

JACOBSEN: You mean that you have been asked questions like that?

DAMMAN: Yes.

JACOBSEN: What was the purpose of that?

DAMMAN: It is scientology's opinion that you remove all things which may be on the person's conscience. An other thing is, and that is also the purpose, that the things you have done and which you should not have done - be it homosexual relations or private things - is something that is recorded.

JACOBSEN: Are homosexual relations forbidden according to scientology?

DAMMAN: Yes, if you do it you are abnormal.

JACOBSEN: It also says whether you have ever been paid money to make false statements. It is also things like that you are asked?

DAMMAN: Yes.

JACOBSEN: Is it correct to say that the E-meter is used to find out if people lie?

DAMMAN: Not quite.

JACOBSEN: I can phrase the question differently. Would it in your opinion be incorrect to describe the E-meter as a primitive lie-detector?

DAMMAN: No.

JACOBSEN: Would it be correct.

DAMMAN: Yes.

JACOBSEN: In your opinion that expression can be used?

DAMMAN: Yes, it can.

JACOBSEN: Have you any examples that staff members have been tested by means of the E-meter with regard to the question of loyalty towards Scientology?

DAMMAN: With regard to what?

JACOBSEN: Their loyalty or lack of same towards Scientology.

DAMMAN: Yes, that is a question which often comes up. If you don't really function in your position within Scientology you will in certain cases be asked whether you have done anything against scientology which you should not have done, whether you have talked with the press or others who have used that knowledge against scientology.

JACOBSEN: Is that to help that person's mental development - or to have a hold on that person?

DAMMAN: It is not to help the person's mental development. It is to get to know the worst so that you can be prepared for it if he should have done such things. If he repents you make him sign that he did not do it or what he did was false or not really what he said or things like that. So Scientology has got that document.

JACOBSEN: Now I would like to turn to something quite different.

On the 1st September, 1979 a settlement was made between the Church of Scientology and Jakob Andersen where Scientology agrees to pay damages to the amount of DKr 140,000 and apologize some statements. Do you know anything about it?

DAMMAN: No.

JACOBSEN: You don't?

DAMMAN: No, I can't say I do.

JACOBSEN: The thing is that shortly afterwards Peter Jensen repeats these things - or makes similar statements at any rate. But you don't know anything about it?

DAMMAN: No.

JACOBSEN: I see. Would you say that Peter Jensen could go to the press about Jakob Andersen without in advance having talked with Bob Metzler about it?

DAMMAN: Yes, in theory he could do that because he has certain general guidelines to observe - for people who are antagonistic towards scientology and it could come under that.

JACOBSEN: What was the reason you broke with scientology?

DAMMAN: It was when I met my present husband ....

JACOBSEN: Where did you meet him?

DAMMAN: At the Guardian's Office. We were both working there.

JACOBSEN: You were both Scientologists and both employed there?

DAMMAN: He is from Norway and was down to be trained in Denmark. At that time a rule had been made - that a person employed at the Guardian's Office Europe must not be together with, have a relationship with, people from other countries. A rule was also made that you were not allowed sexual relationships unless you were married. What we did. was to break both rules because we were together. Then we both got disciplinary punishments. Then We decided to stay together, but stop physical relationship. It did not go very well, then we got together again and both landed up with disciplinary punishments once more.

And after that Odd - my husband - was very quietly taken out by the back door. The Guardian's Office World Wide decided that he was not qualified to be. employed with the Guardian's Office - considering the things that had happened. He was relatively new so he was not a great loss either.

JACOBSEN: What about you then?

DAMMAN: I became more and more isolated. Not physically, but when you are under disciplinary punishment you are not allowed to speak to people who are not under disciplinary punishment. And it was permitted only to walk in certain areas of the Guardian Office Europe at Nordre Fasanvej. There were two rooms I could go to. One was the lavatory and the other the correction room - and then the hallway to get to and fro.

JACOBSEN: Does that mean that if you had both wanted to continue in Scientology you would have had to break up your relationship?

DAMMAN: Yes.

JACOBSEN: And you could have had neither a sexual relationship nor have married?

DAMMAN: No. We were not allowed to marry because he was a student in Norway and had to go back to Norway. Therefore it was against the rules within scientology to marry.

JACOBSEN: Does that mean that you had to choose between going on as Scientologists and get your relationship in order?

DAMMAN: Yes, at that time.

JACOBSEN: Then you both broke with scientology?

DAMMAN: Yes, Odd continued on a course. He got out in October 1979. I stayed on for a while, but it became so hopeless, I mean all the things I was exposed to. At the end I had to start scrubbing walls with a toothbrush and I don't know what.

JACOBSEN: Scrub walls with a ....

DAMMAN: Toothbrush.

JACOBSEN: Who gave you that order?

DAMMAN: One called Palle Johansen. He was Ethics officer - that means that he was responsible for people under disciplinary punishment.

JACOBSEN: It is not a metaphor, is it? It is something you were really made to do?

DAMMAN: It is not a metaphor. It is true. It was a technique that had been invented in order that people who would not toe the line would sort of see things the way the were.

JACOBSEN: You probably understand that it sounds very strange to us.

DAMMAN: It did to me even though I had been there that long. I told them that I would not do it and then I was given the choice: Either I did what I was told ....

JACOBSEN: And then you went to Norway together with Odd?

DAMMAN: Yes.

JACOBSEN: Are you married?

DAMMAN: Yes.

JACOBSEN: Legally married?

DAMMAN: Yes.

JACOBSEN: Any children?

DAMMAN: I have a child by my former husband.

JACOBSEN: Will you very briefly characterize that part of your life you were with Scientology. How do you look on it today? I understand that you have yourself participated in all that you have told us about today. You told that you would use lies and persecution of other people. How do you look on that today?

DAMMAN: How do I look on it? It seems like years I have wasted. Sometimes it's ....

JACOBSEN: Do you regret? Are you sorry?

DAMMAN: That I joined? Yes, I do. Because there are so many things, fundamental qualities in oneself, which have been appreciated, which are destroyed.

JACOBSEN: What is it when you are in a thing like that that makes you agree to such things and blindly obey - without following more personal ethics? It is certainly against ordinary ethics to do the things you have been in on. I suppose it is. right what I am saying?

DAMMAN: Yes. I have read a little about it after I quit Scientology. What is going. on in Scientology is simply brainwash.

JACOBSEN: It is brainwash. You told yesterday how Scientologists who were in the danger zone specially were trained to commit perjury in court. I think you told the court that.

DAMMAN: Yes.

JACOBSEN: Are there actually courses for that sort of thing?

DAMMAN: Yes, it is part of e.g. the PR-course that you learn to stretch the truth and it is something which I have also been trained in.

JACOBSEN: I have here something called "Intelligence Specialist Training Routine, TR-L."

DAMMAN: Well, now you say it. I know what it is.

JACOBSEN: It says here: "Purpose: To train the student to give a false statement with good TR-1. To train the student to outflow false data effectively. Position: Same as TR-1." And then there is an order "Commands: Part 1 "Tell me a lie." Command given by the coach. Part 2 interview type 2 WC by coach." It is a whole instruction in what to do. Here is something e.g.: "The student should be coached on a gradient until he/she can lie facily." A regular instruction in how to lie if you have to.

Have you tried this?

DAMMAN: Not that particular exercise, but there is one in the PR-course where you learn to tell what is described as "white lies" - which are definitely not in accordance with the truth.

JACOBSEN: There one last thing I would like to ask you Vibeke Dean. You probably understand that - to me at any rate, and I take it to the court - it must sound fantastic that things like those you have told us about take place. We know that it happens now and then even though your liability as a witness is very strict, and I draw your attention to the fact that it is, and now you will probably be examined by the other party. I would like to say that if there is anything you think must be withdrawn from what you have said, you must do it now, because if it is found that what you have said in this court is not the full truth you risk a very severe penalty.

Is there anything you wish to withdraw?

DAMMAN: No.

Frederiksberg, March 15, 1981.