Affidavit of Robert Dardano, in Cooper v Scientology case
Ron Newman
I found the following affidavit in the files of the court case
_Paulette Cooper v. Scientology et al._, docket number 81-681
in the U.S. Federal District Court in Boston. These files are
stored at the Federal Records Center in Waltham, Massachusetts.
The affidavit is undated but has an official stamp "DOCKETED, United States
District Court, Filed in Clerk's Office, Jul 1 1981, Mass. Dist."
Perhaps after reading this, some of you will have more understanding
of what Paulette Cooper has gone through.
AFFIDAVIT OF ROBERT DARDANO
I, Robert Dardano, hereby depose and state under the pains penalties [sic]
of perjury:
1. I have personal knowledge of the facts sworn to herein and if called
as a witness to testify thereto could do so of my own personal knowledge.
2. I became involved with the Church of Scientology in Boston in
early 1974.
3. In August, 1974 I began working for the Guardian's Office (G.O.)
which is the secret police arm of Scientology.
4. My first assignment was for a group in the G.O. called "O.D.C.",
Overt Data Collections. Four to five people worked in O.D.C. Our
responsibility included collecting information and data on various people
and interest groups including Mayor Kevin White, the heads of various banks
in Boston, members of Congress, the Massachusetts Senate, owners and
operators of radio and T.V. stations, lawyers, judges, etc.
5. After working in the O.D.C. for a short period which is part of
the B-1 Bureau of the G.O., I was moved into the covert operations area
of the B-1 Bureau called the C.D.C.
6. The agents in our group were installed in jobs at the Boston Globe
as a security guard (Jeff Fahey), the Federal Reserve Bank (Kathy Brown),
Consumer's Council (Nancy Foster), the Lindemann Mental Health Center
(George Bristol), Better Business Bureau (Kathy Grace), the Consumer
Protection Division of the Attorney General's office (George Bristol),
the Law Enforcement Assistance Administration (Susan Heffle) and other
places where data could be collected.
7. In February - March 1975, the B1 Bureau placed an agent named David
Grace with a cleaning company that was cleaning the law offices of Bingham,
Dana, and Gould. The purpose of placing Grace at the cleaning company
was to burglarize the offices of James McHugh, the attorney for the
Boston Globe. The G.O. wanted all of the files of McHugh in order to
find any damaging information that could be used against the Globe in
law suits and also to block publication of a forthcoming article about
Scientology by a Globe reporter named John Wood. The B-1 Bureau also
believed that Paulette Cooper may have corresponded with Wood and was
seeking to obtain that correspondence.
8. Grace stole the correspondence file of McHugh with the Globe
and it was brought to the G.O. office where I examined it and then
sent it "up lines" to the G.O. for the entire country headed by Mary Sue
Hubbard.
9. At the same time, the B-1 Bureau placed Wood under surveillance
with an agent named Peter Marquez.
10. The B-1 Bureau held a meeting and discussed a plan to place a
revolver in the van of Wood, but the plan was never executed.
11. In February - March 1975, Gary Brown, Peter Marquez, Bill Foster
and I were assigned to break into the offices of Stanley Cath, M.D.
in Belmont, Massachusetts, for the purpose of stealing Paulette
Cooper's medical records. Foster and I waited in a nearby restaurant
while Brown and Marquez went in and stole the file.
Article Unavailable
Diane Richardson
The following deposition was entered into evidence in Cooper v. Church
of Scientology of Boston, Inc., et al.
UNITED STATES DISTRICT COURT
FOR
THE DISTRICT OF MASSACHUSETTS
PAULETTE COOPER
VS.
CHURCH OF SCIENTOLOGY of BOSTON, Inc., et al.
Civil Action
No. 81-681-Mc
DEPOSITION of ROBERT DARDMIO, taken on behalf of the Defendant
pursuant to notice, before Jeffrey Gatriel, Notary Public in and for
the
Commonwealth of Massachusetts, at the Offices of Roger Geller,
Esquire,
100 Boylston Street, Boston, Massachusetts, commencing at 10:30 a.m.,
on Wednesday, September 16, 1981.
APPEARANCES:
Thomas Green, Esquire,
representing the Plaintiff.
Paul J. Jenkins, Esquire,
representing the Plaintiff.
Roger Geller, Esquire,
representing the Church of Scientology of Boston.
Elizabeth Lunt, Esquire,
representing the Church of Scientology of
California.
Christopher C. Henes, Esquire,
representing the witness.
2
I N D E X
Witness: Direct Recross
ROBERT DARDANO 4
E X H I B I T S
No. page
1 45
2 49
3 57
3
MR. GELLER: For the record, would you state your name?
MR. JENKINS: My name is Paul J. Jenkins, 12 Union Wharf,
Boston, Massachusetts. I am here for the Plaintiff.
MR. DARDANO: My name is Rolert Dardano.
MR. HENES: My name is Christopher C. Henes 11 Beacon
Street, Boston. I am here with Mr. Dardano.
MR. GREEN: I am Thomas Green. I represent Paulette Cooper.
MS. LUNT: I am Elizabeth Lunt. I represent the Church of
Scientology in California.
MR. REILY: My name is Scott Reily. I am here with the Church
of Scientology of California.
MR. GELLER: My name is Roger Geller. I represent the Church
of Scientology of Boston.
MR. GREEN: Mr. Reily, are you with Mr. Zalkind's firm or Mr.
Geller's firm?
MR. REILY: I am not counsel. I am here as a representative of
the Church.
MR. GREEN: Of California?
MR. REILY: Yes.
4
STIPULATIONS
It is hereby stipulated and agreed by and between counsel for
the respective parties that the deposition will be read and signed
before any Notary.
It is further stipulated with respect to questions that all
objections except as to the form and privilege of questions
and motions to strike are reserved until the time of trial.
ROBERT DARDAN0, Sworn
DIRECT EXAMINATION
BY MR. GELLER:
Q Would you state your full name?
A Robert Louis Dardano.
Q What is your present address?
A 14 Trescott Street, Dorchester.
Q How long have you resided at that address?
A Easter of this year.
Q Where did you reside prior to that?
A Grove Street, Newton.
Q Is there a street number on Grove Street?
A 49, Apartment 7.
Q What were the dates that you resided at Grove Street?
[page 5 is missing from the scanned document.]
6
A To save time, I will write it out and give it to you later.
I will do it during a break.
Q That is fine. Tell me what you do for a living, sir?
A Carpentry and wood burning stove installations.
Q Are you self employed?
A Yes.
Q How long have you been so employed?
A Since 1976. There have been some instances where
I have worked with companies directly rather than being
self employed.
Q By and large, since 1976 you have been self employed?
A Yes.
Q Do you have a business name?
A I am registered as doing business as Robert Dardano,
Canton, Massachusetts.
Q You filed a D/B/A Certificate in the Town hall in Canton?
A Yes.
Q When did you do that?
A Last spring.
Q Did you have any other D/B/As filed prior to the spring
of 1981?
A No.
7
For whom do you install wood-burning stoves?
A Bow and Arrow Stove Company. Hearth and Eagle
Stove Company. Cambridge Alternative Power company.
Q Are you a representative of these companies?
A I am considered a subcontractor. People who purchase
the stove will call me and I will give them an estimate of the
cost of installing it.
Q Were you formerly a member of the Church of Scientology
of Boston?
A Yes.
Q When did you become a memler of the Church of Scientology
of Boston?
A 1972.
Q When did you leave the Church of Scientology?
A The spring of 1975.
Q Would you describe or amplify what you mean by, you left the
Church of Scientology? What did you do to actually leave?
A I did not follow the Church's procedure or policy for leaving.
I just left.
Q Did you announce to anybody that you left the Church?
A There were a few individuals that knew I left the Church. The
people I was dealing with. There was
8
Deac Finn.
Q Anybody else besides Mr. Finn who knew you left the
Church?
A Bob Johnson.
Q Anybody else?
A Other staff members knew I left the Church.
Q Do you know their namres?
A There are several. I don't know exactly what they knew or
didn't know. All of them didn't know- what is special to my
case.
Q Other peonle besides the two that you mentioned were aware
that you were no longer practicing scientology?
A Yes.
Q What did you do when you left the Church?
A I don't really understand. What do you mean, what did I do
when I left the Church?
MR. HENES: Break that down.
Q Why don't you describe what you mean when you left
the Church in 1975?
A When I left the Church, I stopped going into the
Church and stopped performing the duties that I was doing
before or while I was in the Church.
Q Did you practice any of the technology of scientology
9
on your own?
A Yes.
Q What month was this in 1975 that you left?
A Spring.
Q After the spring of 1975, you practiced the scientology on
your own?
MR. GREEN: I don't know if I understand your
question.
MR. HENES: What do you mean by the technology
of scientology?
Q There is a certain technology that goes along with
those beliefs, is that right?
A Yes.
Q You practiced that technology after you left the
Church in the spring of 1975?
A Yes, from time to time.
Q Did you adhere to the ethics of the Church of
Scientology after you left the Church in the spring
of 1975?
A No.
Q Is it the ethics of the Church of Scientology that
an individual member will not do drugs?
A Yes.
Q Did you do drugs after 1975 in the spring?
10
MR. GREEN: I object.
MR. HENES: I object.
MR. GELLER: What is the basis?
MR. HENES: Irrelevant.
MR. GELLER: I don't believe that is irrele vant at all.
MR. HENES: This potentially raises a Fifth
Amendment question. He is not going to answer
the question.
MR. GELLER: What is the basis for him not answering
the question?
MR. HENES: I don't want him to answer the question.
MR. GELLER: Are you instructing him not to
answer the question?
MR. HENES: Yes.
MR. GELLER: What is the basis?
MR. HENES: I am instructing him not to answer the
question.
MR. GELLER: You don't want to put any basis on
the record?
MR. HENES: Not at this point.
MR. GELLER: I would like to have the question certified.
To be continued.