Ethics Section FSO
Cc: Denise Licciardi
CC: Bryan Zwan
Cc: RTC Flag
Cc: Solo NOTS C/S for Eligibility

Chuck Anderson

January 12, 1998



I am the Manufacturing Manager at Digital Lightwave (the equivialent of D of P). Denise Licciardi is the Vice President of Administration (the equivalent of the HES). We are not a WISE licensed company. We are simply a public corporation with a CEO who is a Scientologist and several Scientologists working there and we aer located in Clearwater, FL. I started working at Digital Lightwave Inc. on October 2, 1995. I am about the 10th oldest employee at the company that now has almost 250 employees. Denise has been at Digital Lightwave, Inc. for about a year. I started in September 1996, been here for a year and a half.

The first incident with Denise occured shortly after she started working at the company where there was a problem with a demo unit (demonstration for potential sales). Bryan Zwan, the CEO, had apparently asked her to investigate what had gone wrong on the cycle and the first time my boss, Tom Williams (a non-Scientologist) th VP Manufacturing (equivalent of the Tech Sec) and I heard of it was when we got a communication from Denise stating that a junior of mine named Adam Lauver be put on probation because of what happened. Though Tom and I had the correct data on what had occured, neither he nor I were consulted on the matter nor Adam had nothing to do with the situation. Adam was also one of my most upstat and reliable juniors. Tom had to go straighten it out wiht Denise and we never told Adam what had happened because he would have caved in. The truth here is that I was sent to get the data so that the truth could be operated on as opposed to an outpoint react. The data was gotten and because Adam was/is an upstat no action was taken, I never communicated that I was putting him on probation. The fact is I heavily promoted the fact throughout the organization in Engineering in hopes of assisting him in his career, that Adam was getting his degree in Electrical Engineering and was instrumental iin helping him get his current position in Production. I have no idea where you got the idea that I was going to put Adam on probation. That is false.

Denise never did a non-e with either Tom or I to find out what was needed or wanted from us and thereby did what was neither needed nor wanted and she has little KRC for Manufacturing Technology or understanding of our org board. These things became apparent when she started coming into the Manufacturing area in September of last year until the present. This is what I am going to cover. The fact is I ran a Manufacturing operation for over 8 years either as VP Manufacturing or as Service Product Officer. I have a great deal of knowledge about being a Product Officer and fully applied Non-E with my senior and with Tom Williams. This may be unknown to you. On the time frame you mention the first time I was asked to check something in Manufacturing was in the second quarter of last year. (April through June 97) Prior to that there had been materiel (sic) issues being worked on on the procurement lines. I had been asked to check on various particulars by the CEO, my senior. As the VP Admin - Department Three does inspections - it is not off hat to go and LOOK in an area.

Until Denise came on the line, our area was pretty HE&R free. Tom Williams had a direct comm line with Bryan Zwan and the entire Manufacturing Division was held in th highest esteem by Bryan. This changed after Denise got on the line. Chuck never cimmunicated to me that I created HER either last year or in the present. My roll had prevuously been that of a cheerleader - the one who got or approved raises - who went in and helped out. I was friendly worth (sic) the employees and at times worked side by side with them. The communication I had received from others in the area was appreciation and friendliness. This statement is a broad generality - and as Chuck lays out

The next experience I had with Denise was some months later when I wanted to get into comm with her about getting WISE into the company among other things. This was sometime last sumer. I have a good comm line with Sue Mueller, ED of WISE College, and she'd been trying to get a comm line into Digital Lightwave. Denise told me the main consideration on getting WISE into the company was trying to keep the association of Scientology with a publicly traded company on the stock market. Sue had told me previously that this could be worked around. I relayed this information to Denise. She was very emphatic on the use of admin tech and said to have Sue Mueller call her which I did. The next time I talked to Sue some weeks later, she told me that she was unable to reach Denise afte trying several times. I wrote Denise and email reminding her who Sue was so she knew who was trying to get a hold of her and left her Sue's number in case she wanted to call her back. I ran into Sue a couple of months agoa nd she has yet to reach Denise or get any call back from her. This was at least five months after my initial contact with Denise on the matter. Sue told me she'd tried repeated times to get a hold of her. I have not ever spoken to Sue Mueller this is true. For the record in the past 15 years I have single handedly put in those points required to get the Admin Know How Award. Both at RealWorld Corp and at NewLink Communications a company that was run by Sam and myself. DLI Admin Know How Awards Chuck has received for getting LRH Admin Tech into a company.

The third quarter of 1997 (July 1 - September 30) was a difficult quarter for Manufacturing. Manufacturing creates the end product of Digital Lightwave, Inc. The materials were late arriving because Engineering was late with the plans by several weeks and the P.Os for materials were held up on the line. The P.O.s are processed outside of Manufacturing. The P.O.s left Manufacturing as soon as the planes were released from Engineering (this is handled by the Manufacturing Service Manager, Vince Bourne, a non-Scientologist - equivalent of a DTS). Concurrently, there was a national shortage of electronic components which extended some lead times from 6 weeks to 16 weeks. The electronic circuit boards (PC boards) arrived only two weeks before the end of the quarter. This was really too late for the amount of testing and assembly that had to be done to meet the quota. Additionally, the board supplier was running out overt products. This made the situation even worse. I was actively working on getting this board manufacturer more closely scrutinized with the VP Quality Control. Tom Williams appeared to me to have a blind spot on that manufacturer which I later reported to Denise. The production quotas were not met adn sales were madde of 129 units more than were produced. I have found in recent times that the materiel handling is in fact a non-contront on those procurement lines to make it go right. I could get the data on what exactly occured here however it is true that we had a vendor who was not reliable and who produced overt products. This vendor was not one of my choosing rather that of the VP Manufacturing. Neither the VP of Manufacturing nor the Manufacturing Manager effected a proper handling of this vendor in the time required. Additional data: Second half fiscal year production schedule meeting was held throughout July with Dr. Zwan, the VP of Engineering - Jerry Gentile, Tom Williams, Vince Bourne, James Pritchett and Denise Licciardi to determine revision on production plan due to release of finished ATM product, new engineering features related to penalty clause in MFS contract along with release of new main board revision requested by MCI and general fixing of production schedule based on Q2 results. Additionally, the Q4 production targets coupled with demand forecast for upgrades and in-house demo and engineering units were determined. The results of this meeting were captured in a production memo from Denise and approved by Dr. Bryan Zwan [attached.]

The solution that Denise came up with for the problem was something called Ship in Place. The half built, half-tested products were put into boxes and stored in a warehouse to give the impression that the production was done. There is a way to ship products, which is when the customers do not have a specific address for these to be shipped to. They basically commit to the purchase and say keep it there until we know how we are going to deploy this. This is an accounting acceptable way to ship products. Tom, Vince and I participated in this project that we were told Bryan Zwan knew about. I do not know why Chuck says that Dr. Zwan knew about this - I'm no sure what "this" is. In this particular case the letter from this customer was not specific in what configuration they had wanted and has an open ndd path to upgrades and getting further options. It involved us working on September 30 from 6:00 AM and not returning home until about 5:00 AM on October 1. This marked the beginning of a downward spiral in the Manufacturing area that has gone on to present. During second quarter, 3 months earlier we had received a similar order from the customer and had only been able to fill a certain portion of this. This order was also Ship in Placee .Again this is an industry-accepted method of booking revenues. I do not know why Chuck does not recall this - however we booked the portion that was done and only that. To say that I was the cause of the "downward spiral" of manufacturing is a huge generality and simply untrue. The only two periods of time I was actually in the production facility was to help move to the St. Petersburg office on September xx, and during the last week of the quarter to assist in the completion of the Q3 targets in manufacturing. Had the officers of production executed their duties and worn their hats the significant shorfall of actual production would not have occurred.

Since the 129 units were counted in the third quarter of 1997, the production that we actually did on them in the fourth quarter couldn't be counted. Additionally, we were battling several pieces of dev-t. One was, that the overt products that we had received from our board vendor were really hutting us trying to get these 129 units done. This vendor had been on line for about a year at this point and had not been properly handled by others. The VP of manufacturing assured us that the competition of the Q3 targets could be accomplished easily during the month of October as their capacity for new unit production was in excess of 50 units per week with the staff at that time. As part of the MITs for Q4 the VP of Manufacturing was instructed to bring on-line a second shift to accomidate (sic) the upside production anticipated with ASA business and the RAA product currently in development. After repeated requests for a planned production staff requirements from the VP of Manufacturing this MIT went unserviced. On xx, the Sr. Vice President of Operations offered a suggestion to Tom as a possible staffing plan. This again went unserviced with the net result of a serious shortage of personnel for competition of Q4 targets. On December 11th, a memo was received from James Pritchett, Director of Operations. James had been assigned to manufacturing as a result of a report from Sam Licciardi and the ASA Quality Improvement tiger team that analyzed serious production quality problems in manufacturing. This memo, the product of Tom, James, Vince and Chuck highlighted that the current target of producing 530 units in Q4 could not be met with the current first pass yields experienced along with shortfall of staff. This memo indicated at the time that only 175 +/- 20% additional ASAs could be produced. Note that at this time the Q3 production was still incomplete as over one third of the ASA's were still in troubleshoot. The current Q4 production to that point was less than 100 units although material was in house to produce. Also in this memo was a request for temporary personnel. After a phone call with James to go over the report I instructed Debbie to bring in those persons required immediately. Within 3 days all of those persons were on board producing product. As additional data, th manufacturing staff had already increased from 19 to 28 from Q2 to Q4 and an additional 5 in November. Also, there were 17 temporary employees brought in during this period (Q4). They just wouldn't go through the line. A major shortcoming of moving units through the line has been determined to be lack of training and understanding of how the ASA works. Countless mis-diagnosis of troubles were observed resulting in a continual cycle between board repair, rebuild, retest stations with the net result of no output. Subsequently many of the boards from these units were replaced with boards from the new vendor. We couldn't track these units with the rest of production because they were already off the books and the serial numbers were already assigned so we couldn't substitute units. We were also getting little back up from personnel (under Denise's charge). This is a broad generality and simply false data. The actual stats for new employees to this area in the third and fourth quarter are stated above because we were very short on assemblers and technicians to manufacture the product. Also we were being plagued by several engineering bugs that started at the end of the third quarter which Engineering never took responsibility for. This is not true as engineering had assigned two engineers to production for root cause analysis of production issues for the entire fourth quarter. In addition to this, the Vice President of Advanced Products and original designer of the ASA - Ted Myers was assigned to production along with troubleshooting cycles executed by the Sr. VP of Operations Jerry Gentile acting as Sr. Troubleshoot technician and James Pritchett, Director of Operations assisting with other engineering and process deficiencies in an effort to boost the product yields. Countless other days with various engineers were also done to support production. ALso, the company, under the direction of Dr. Bryan Zwan and recommendations by Joe Fuchs, VP of Qualifications, a plan was put in place to vibration stress all of the products before placing them in stores as final products. This plan proved to be an efficient "weeding out" program designed to eliminate intermittant or latent product defects due to poor solder quality and power supply failures experienced in high percentage by end users. All of this occured while the VP of Manufacturing walked off the job in non support of the effort required. We were fighting an uphill battle and none of our production was showing up anywhere on any of our reports. When drill down by Jerry and I occurred it was apparent that Chuck, and Tom were not in control of the operation to the point where all the sub products could be seen, measured or stated so as to uncover production breakdowns. This started fuelling a new concept that Manufacturing wasn't doing anything. There is no idea that manufacturing isn't doing anything - that fact is the week given off to production, despite the amount of by-ass that needed to be done on the simple management tools of targeting products instead of hours (see e-mail of Nov. 24) and debugging of material shortages - was recommended by my self and Jerry Gentile (Snr. VP Operations) to Bryan as an ack. The bonuses, Temporay help and time off was all originated by myself and or Jerry. The point is we worked very hard a rewarding 4 each and every staff member and worked side by side to set a good example. Working hard byt not producing a final product is in effect doing nothing. When the incentive program was conceived it was to undo the notion that workers had to work "60 hours per week", it was to re-focus the entire team into producing the valuable final products and meeting needed daily targets.

Second weekend after the new quarter started (October 1997), Denise and Jerry Gentile - Jerry was the V.P. Engineering (a non-Scientologist) when the new board plans were late getting to Manufacturing from Engineering and later was promoted to the equivalent of an OES (can't remember his title) and now also over Manufacturing - went down to the wareouse to pull out the half-built units so further work could be done on them. The fact is that we found out that a part was bad on the boards and these had to be repaired, we found out latein the day from the VP Manufacturing who had taken off to go on vacation despite the hill 10 - and we worked it out with the vendors to handle and fix asap so it would not impact thrid (sic) quarter production. This was a situation dumped up lines with no solution and was thew (sic) sole reason we went to warehouse to get these units so that a prt could be repaired. The bad component was an oscillator that was improperly sealed and could possibly fail over a long period of time due to corrosion. Jerry worked countless cycles with Q1 and the VP of Engineering at the crystal vendor and develop a strategy for repair and replacement of this device so as to guarantee that the product procduced was of DLI high standards. All current WIP that was in stores or warehoused was disassembled to effect this change. This was actually a three-day weekend (Columbus Day) and Tom was on his way to Georgia for some R&R and I was relaxing at home (we found out my wife was pregnant in September and I was getting my first chance to be with her. Tom had called me the night before asking me to get a crew together for the next day (this was Friday night and we had NEVER done something so last minute before and especially not after the longest quarter ever - if we worked Saturday, it was always determined by Friday at the latest). I told Tom that I wouldn't send anyone down to work on Saturday, since it was already Friday night and the second week of the quarter and my guys had already made plans for the holiday weekend. Finally I agreed to call them in, but not go down myself which my boss didn't expect me to do. The only time we ever asked anyone to work on a holiday weekend before was when it fell on the end of a quarter. This is complete abdication of the post and hat which is the responsibility of Chuck and Tom. In effect the danger condition was not handled by the production staff and bypass was required to correct the situation. We were at the beginning of the quarter. My junior, James Burke, called me Saturday morning to tell me Denise and Jerry were there. Then he called me back and I decided it was too flappy so I went in to work. The reason for this drill was that some units were supposedly going to be shipped the following week. This is the data that was given to us and the crystal change, in addition to vibration was required. The servicing of this request was in direct response to a request from the CEO. This didn't happen for weeks later. This was the beginning of us working every weekend until the end of the quarter (October - December 31) except for one weekend. Just earlier that week, without any warning, Vince, Tom and I worked until five in the morning at the warehouse. Again we had gotten a report from VP Manufacturing that the Crystals were not sealed properly and that there was a high probability that there would be corrosion and moisture would get in and cause failures in the field. THIS is the reason for the hill 10. It is also not true that workers were on overtime from October to December. Jerry and I were in production at 6pm and noticed there was only one worker in house even though virtually ONE of the Q3 units were done. We were looking for a configuration sheet on Heidi's dsk for a shipment that needed to be made and notice time sheets from the previous period and were significantly surprised to note that virtually NOBODY was working any overtime of significance. The data that had previously been given by Bill and Chuck was that we "cannot ask for any more from these people or they will quit as they are way overworked": the data was alarmingly different. We subsequently drilled down to find he true data [attached]

Normally a quarter ran like this: we worked regular hours (and I worked about 45-50 hours a week). The data shows the norm to be more like 40 hours; additionally, it has been shown that a high abseeism (sic) is noted. Then in the last two to three weeks we worked Saturdays, sometimes Sunday and sometimes late. But absolutely nothing like we worked in September. Until August 1997, everyone was on salary, so the compensation was comp time with all employees who worked significant amounts of time over the 40 hours. It was found to be illegal not to pay the workers overtime, so given that I knew overtime was coming through and given that I knew we would work a lot of overtime in September, I pushed the overtime through in August for my employees. It was incredibly dev-t to dole out comp time for everyone at the beginning of the next quarter. Of course, neither I nor my Supervisors got overtime. We were supposed to have our pay adjusted for that. Therefore with the heavy overtime and given that my employees started to get paid overtime, I was suddenly making the same or less than they were in September. In prediction of the heavy amounts of hours that I knew I would be putting in in the coming months, I put in a CSW for my pay raise early and added in financial compensation. This was about $5,000/year more than I had discussed with Denise several months earlier. This was met with resistance from my boss and the then Dir of Personnel, Niall Dillon. I finally dropped the issue and took the raise that was suggested.

Since I saw that Manufacturing was beginning to get targeted I decided it was time to get some information out to key terminals in the company as to what we had been working against in the area of getting materials out in time. I came in very early one morning (October 17 - copy of report attached) and wrote up a report on this problem. I wrote it in the form of a Things that Shouldn't Be Report and sent a copy to Vince, Tom, Denise, Jerry, Barry Jawors (Purchasing in Treasury) and Bryan Zwan. While I was in my morning meeting with Tom, I received an "urgent" call from Denise telling me to go to my computer right away. She then gave me instructions on how to pull this report back from everyone but especially Bryan Zwan, that they were handling it and she would come right down to explain. When she arrived she pulled me off to the side and said that she didn't want this getting on Bryan's lines, that she was being paid for him not to have to handle things like this. She went on to tell me the material problem was actually Tom Williams' fault, that he wasn't wearing his hat and that she would be handling him and ESTOing him. She also said she didn't know if he was going to make it on the post.

At this point in time, I mistakenly trusted her judgement and pulled back my report. I let her case level and status cloud my judgement. This acted as a 3rd party on Tom. And it was basically a bypass of Tom to get me to withdraw the report and saying they were going to handle it. Denise had also made some comment weeks earlier about Tom's "businessman valence" which drove her crazy.

Tom and I had previously had a pretty good working relationship although he's not an easy person to work for, he's actually one of the more able non-Scientologists I've met and he actually knows Manufacturing very well, which is what he was hire for. After the comments that Denise had made to me, especially saying she didn't know if he was going to make it, I started thinking about the possibility that Tom was't going to be around for very long. I've since realized that this acted as a 3rd party. It was an off-line comment about my boss. I started looking at other out-points regarding Tom and I found a number of them. I did write one report regarding the outpoints that I was seeing with Tom and sent it to Denise. I feel that there were some real situations there but he does have quite a few plus points too. I'm currently workin to handle my out ruds with him. I admit that I find it difficult at times to work for a non Scientologist in a company mainly run by Scientologists. Also, I was pretty much a "lone OT" in the Manufacturing facility.

After this point in time, things started getting really hot. And the communications from Jerry and Denise to Tom and me, etc. were getting more and more intense, like we weren't doing our jobs. Also, Denise and Jerry started coming directly to me and bypassing Tom. Denise was very hard-nosed on her viewpoint that Manufacturing had "screwed up" and "what had we done all quarter?" Being a pretty responsible Scientologist, this pushed my buttons and I agreed, "yeah, what had we done?" and I was ready to kick ass for the good of the company. I was actually being put on the spot and being production-oriented, I didn't bring up some of the obvious counter-intention that Jerry and Denise both knew about which were a number of engineering problems that we were having to deal with, which meant we had to take units apart, put them back together again more than once, not to mention we couldn't record any of the production we actually were doing because it was "done the quarter before." As I mentioned ealrier, we were also battling overt product boards.

At some point in the middle of the quarter, Jerry's assistant, James Pritchett (a non-Scientologist), was sent down to take over the running of Manufacturing although this was later denied by Jerry who then said he was only being sent down to help out. Within several days after James Pritchett arrived, he saw what we were up against and went pretty much into agreement with Tom Williams' asssessment of the situation. He then lost favor with Denise and Jerry. James Pritchett had many years of engineering/manufacturing experience that made him qualified to make such an assessment. Over the time I've worked with him, I found him to be the most valuable engineering terminal that Manufacturing has had to work with. He's very well trained and very bright.

Denise and Jerry were spending more and more time at Manufacturing and some time around late November, Denise pulled me aside and said, "Tom's not going to make it, babe." I asked her if Tom doesn't make it, am I going to be in line for the position, at which time she responded, "Yes, either first or second position." This, I assumed to mean product officer/org officer system. I told her I liked the idea of a product officer/org officer system and that I made a better product officer than an org officer. I was very excited and by this time, Tom was seeming pretty disaffected and more and more out of the picture, having been bypassed for some time.

The pressure got increasingly severe from Denise and Jerry. They came down together most of the time. There was more and more BPC with the Manufacturing executives. In a meeting with Tom, Vince and myself, we were going over some of the events that had led to things getting to where they were and what we kept on going back to was the FALSE MANUFACTURING STAT from the previous quarter. Up to this point, I was under the impression that Bryan Zwan knew about it but according to Tom, he had overheard Denise and Jerry talking about how Bryan couldn't be told about it. I started thinking aboutthe HE&R that was being directed at us and it started looking to me like it was being created by the withhold. It was at this meeting that Tom said he wouldn't participate in boxing up half-done product again. I felt pretty much the same way aout it, seeing as how it minimally was creating a horrendous amount of dev-t for us and maximally that it could cause a major flap.

Soon after this meeting, Jerry came down by himself and had a meeting with the managers, including Tom and he was coming at us pretty hard and I had come to the conclusion that the heavy-handed approach was not only getting old but becoming quite destructive and I told him that. I told him if he and Denise want to help to pull this quarter off, you need to change your approach because it's getting too heavy. The other managers took my lead and agreed. I suggested that they could really help by coming out and giving a "pep rally" to the employees to encourage them in some way, a game that we could win at. Besides, it wasn't their fault that things had gotten to this point. Jerry immediately back (sic) down when I challenged him and began to see our viewpoint on it and tried to look at it more from a help flow instead of the other. In this conversation, we brought up to him the events that had led up to the situation we were in and I mentioned that Bryan should know what's going on here. I said "if I was running a company, I would certainly want to know if there was a major situation going on in the production area." Jerry told me that he was assured by Denise that this would not be a good thing to go over with Bryan and that he, Jerry, trusted Denise on this. This was a big out-point, but I didn't challenge him any further on it.

The "pep rally" was given but neither Jerry nor Denise showed up for it. Jerry had said at least one of them would come. James Pritchett ran it instead. It was soon after this that Denise and Jerry came down to me and told me of their plans to pull off this quarter by putting together an incentive porgram that was like a big Christmas party at work for the rest of the quarter. This was the beginning of December. This was right after the Thanksgiving holiday which we worked through. Just before Denise made this announcement to me, I had looked over the situation and saw how heavy things were getting and what created the situation and who was behind it. I realized Denise was the "who" creating the flaps in Manufacturing and I really blew down on that realization. I also realized that I had been 3rd partied on Tom and that he was really not the "who". I was going to write this KR at that time with the data that I had up to that point. When they came down with this new party idea, I backed down and decided that maybe their approach would change and everything would be okay.

By this time, I was becoming the central terminal that Jerry and Denise were working with in Manufacturing. They were bypassing Tom, they were bypassing James Pritchett and coming directly to me. I perceived that the BPC with the other managers was rising rapidly. Also, right about this time, in a conversation with James Pritchett, he suggested with all the work that I had to do, now having 40 juniors, I needed an assistant. Shortly after that, in talking to Denise and Jerry, the subject of the assistant came up again either by me or them (can't remember which) and Denise said, "well, let's get you an assistant." I came up with the name of a person I wanted to hire. I said to them, "please tell Tom about it," because he would "rip my face off" for getting an assistant on my own without him being involved. They said they would do it but several days later I asked Denise about it and she told me that I should get my confront up and go to Tom myself. I said okay though I really didn't think it was a good idea. The next time I talked to Denise, she said she would tell Tom about it. In the end, Tom was told about it by Jerry when my assistant showed up for work.

For the last four weeks of the quarter, most of my crew and myself were working hundred hour weeks (appx). We were getting a bonus incentive of $100/day if we made our targets. This went pretty well as handling for making people work 100 hour weeks during the holidays. Even though I was getting the $100 bonuses too, my juniors were getting overtime and even the assemblers (the lowest paid of my employees) were making more than I was and I was working harder hours and running the whole show. This seemed okay with me at the time as I felt that pulling the quarter off would get me some real returns. IE the promotion that Denise alluded to.

The quarter ended finally with me working until 3:00 AM on New Year's Eve and it was, I believe, earlier that afternoon around 4 or 5 o'clock that Denise called Tom and I aside and told us that Bryan had just made a huge sale. She gave us the plan of what was going to be shipped for the rest of the day and she then told us that we would be "filling that order" referring to Bryan's sale. What she meant by this was that we would be shipping out half-done units and raw materials to a freight forwarder with the illusion that these were fully completed units as we had done at the end of the third quarter. The difference here being that this was a larger scale operation. We actually only had completed somewhere in the neighborhood of 70 or so of the 308 units that were needed to fill the order. This is a rough guesstimate.

Later on I found out, according to Denise, that Tom and Vince weren't going to be "playing the game" which meant they weren't going to help out on the cycle. I originally wasn't going to do it myself but I was pretty keyed out at the production that we had gotten through and I was thinking about it in terms of purpose senior to policy. I had actually probed Denise on the subject several weeks before and she assured me that it was no big deal and there was nothing illegal about it. Also, I knew from other sources how important the first year's showing is with the stock market.

A hand-picked group of around 8 people including Denise and Jerry came in on New Year's Day and filled the 308 piece order. Before agreeing to do this, I stated to Denise EMPHATICALLY that I would do this IF I got Friday, January 2 and Monday, January 5 off and on that basis I worked the fourth holiday for that quarter. On New Year's Day, I was told that my crew wouldn't be called back until at least Tuesday, January 6 or probably Wednesday, January 7.

The next day, January 2, Tom left a message on my machine about needing to get a crew together to do warranty repair and me needing to come in Monday to help straiten (sic) the place out. This was contrary to what Denise and Jerry had promised us. Tom left another message on Saturday. Sunday, Jerry Gentile called and said Bill and Cathy (my two supervisors) had called him about when they went back. He told me that nobody was supposed to go back till Friday. He and Denise were in the office when he called. Denise was also on the phone. This is when she blurted out that I had told James Pritchett that I was getting an assistant and not to tell Tom. "That's your withhold from Tom, babe," she said. I just acked her but it did enturbulate me a little bit. I didn't really know what the point was or what was behind it.

I called Tom up and he told me I needed to get a crew together and that I needed to come in on Monday (the next day). I told him that I was promised that day off by Denise, that I wouldn't be coming in and I wouldn't be calling anyone because they were supposed to be off too. He told me that as far as he knew he was still my boss. He also told me he had talked to Doyle (customer service) and that warranty repair needed to get out. Basically that comm ended with no resolution. Now I was even more enturbulated. I had gotten agreement with my wife for me to come in on New Years based on that time off.

I called Jerry and Denise back and told them what had occurred and asked them if Tom knew ANYTHING about what was going on and they said they would call him because the time off had been awarded by Bryan Zwan. I also told Jerry that Tom had said something about needing someone in for warranty repair.

My wife and I went off to see my FSM and when we returned we had a message on our phone from Denise. She told me I had to go in, to knock off the "fucking" HE&R and that we needed to gear up for production and that I failed to tell her about warranty repair which of course I had not failed to tell Jerry. Jerry was right with her. This completely ignored the time I had off, the time supposedly awarded by Bryan, ran more can't-haves, and completely ignored Ethics protection for upstats. It really made me wonder what all my work had been for.

I called Doyle to find out what the real scoop was on warranty repair. I surmised from talking to Doyle that I really didn't need to be there until at least Tuesday. I called Noel, my warranty repair guy, to assemble a crew for Tuesday and I then called Denise to give her the info but just left a message on her phone as she didn't answer. I also said I would not be coming in on Monday, but Tuesday with my crew.

I didn't hear back from Denise but while I was still sleeping the next morning, I got a message from Jerry to call. I decided to write Denise an email because I didn't want to spend my day off trying to handle whatever she had going on. I was pretty upset as I had done my job and I had really confronted a lot to get the product. I felt quite invalidated for my effort.

I want to make clear here what Denise's message the night before created. My wife is 5 months pregnant and throughout the whole pregnancy up to that point I was working, weekends, nights, holidays. I told my wife that I was doing this for us and that there was something good coming for us in the future. I'm referencing what Denise told me about Tom not making it and me getting his job or the number 2 position. The only thing my wife got out of that message was: is this what it was all for? Here he were at the beginning of the next quarter. I had worked New Year's Eve till 3:00 AM and New Year's Day and we were still having our time cut into. With the wave of a hand I was given time off and with the wave of a hand it was taken away. But allegedly this was awarded by Bryan and I didn't see how Denise could take that away.

The next morning I went to the corporate office to see Denise which included seeing Jerry. The first thing that Denise said to me was that she had gotten my "theta email". I went over with her how inappropriate I felt her message was that she had left on my phone. She told me that I was going at her at a complete motivator flow. She was saying this in front of Jerry, by the way. She used a lot of Scientology words in front of him. She would clear some of them verbally. She then told me that they planned to "salvage" Tom and that even though he was probably in treason this wasn't the S.O. and they would probably have to apply danger and see if he would handle. Jerry said that he wasn't prepared to promote anyone in the area that they had spotted outpoints in my area and that most of the work that needed to be done during all of the times that they had spent in manufacturing was in my area anyway. (Denise had just told me a few days earlier what a good job I did running my area) Denise went over the money issues that I addressed in my email to her and said that she could easily find people to do my job for the money that I made. She also brought up the fact that I had gotten a lot of raises since starting work at Digital Lightwave, Inc. What's the point of my having gotten raises -- raises are based on promotions earned and annual merit raises. I was treated no differently than anyone else. The fact that I rose through the ranks so quickly only indicates that I deserved what I got. Denise also suggested that I write up my o/ws on Tom. These were the highlights of the comm. I walked away from the comm cycle feeling kind of foolish. All I could think was this wasn't what I worked so hard for. They also mentioned how much harder they had worked than anybody. They also mentioned that they had been "ambushed" by Tom, Vince and James Pritchett on Friday, January 2.

I went to work and spoke to Tom. He had a different view on the conversation from the previous Friday. He felt that he and the others had gotten their points across to Denise and Jerry. He also went over with me how upset he had been with Jerry and Denise in the previous weeks and to a large degree with me for following their orders and allowing him to be bypassed. He told me that Jerry and Denise had told him that they hadn't promised me any time off. They were both standing there when I went over that point with them very plainly. Besides why would my juniors who got overtime get time off and I on salary, whose compensation for extra hours IS time off, not get the same time.

I came in again Wednesday, January 7, 1998, and told Tom that I wanted Thursday and Friday off. He told me he'd rather give me Thursday and Monday off. I agreed with it begrudgingly because Denise and Jerry were there and I knew that my crew was coming back Friday and they would probably insist I be there, even though I had told them the day before I was planning on taking Thursday and Friday off. I had promised my wife for weeks before the end of the quarter that I would get that particular weekend those four days off as we had plans. After leaving that day, I decided that I would really upset my wife if I broke another promise to her so I decided I'd rather upset people at work than upset her. I tried to get a hold of Tom but he wasn't there so I left a message stating that I would be taking the two days off and I was turning off my pager and my answering machine because I didn't want to get disturbed as I had been the weekend before.

While I was out that weekend and fairly caved in I cognited on what I had realized before and suppressed. There was definitely a "who" screwing things up in Manufacturing and it really wasn't Tom after all. It was Denise. At this point major confusion blew off. Just as had happened the time earlier in the quarter that I had afterward suppressed.

When I came back to work today, Monday, January 12, 1998, I went over my not coming in on Friday with Tom and I apologized but it was just time to give my wife some time and get things squared away again. He told me that he'd played the message for Denise and she told him that I had been "well compensated" for my time and that she wanted to see me Wednesday morning when she came back. This sounds like another Denise bypass and what am I going to get on my lines besides invalidation? Tom still had a lot of BPC on me so I took it upon myself to show him the conditions in the Ethics book. I showed him how the junior danger formula included bypassing those normally in charge of a job and that Denise and Jerry were bypassing the area and the seniors. I told him also that in no way was this company running on Scientology administrative technology but since there were some Scientologists there, that they were doing what they knew how to do. I pointed out the points that weren't applied including telling the person that they're in danger. I also explained to him about the circumstances on my getting an assistant and he agreed it wasn't my job to tell him. I got the ARC back in with Tom.

The above is a general sequence of events that's occurred over the last months. Now I want to list some of the outpoints I've noted.

- Bypassing lines. She chronically bypasses terminals (like Tom, James Pritchett, Vince, me, etc.), but doesn't properly apply the condition if in fact that's the correct condition.
- False stats. We've had false stats for the last two quarters now. These are hidden from Bryan and are a huge potential flap. There are too many people who know about it and this makes Digital Lightwave, Inc. very vulnerable. What happens if someone goes to the newspapers, the investors, the SEC (Securities and Exchange Commission)? Not to mention putting Scientology and Scientologists at risk given the local scene. Look what happened with TradeNet. Also, where is the end to the false stat catch-up? Already we have to produce 800 units this quarter (this includes the units that were incomplete from the last quarter which we again, won't be able to count and will have to track separately) which is lining up again 10 hours days and weekends from the get-go. Not knowing lines in Manufacturing. On several occasions Denise has called me at the office or at home to ask me questions having nothing to do with my job as Manufacturing Manager. There are most usually DTS related questions.

- Out-PR. Denise uses a lot of foul language in front of non-Scientologists. On more than one occasion I've watched people's negative reactions to it. There is a local ethnic and foul language is not a part of it, especially coming from a woman. I also had one of my juniors, Maureen Holley, come up to me and ask me to do something about Denise because she's out of control. In this incident, Denise had signed her name across about seven steps of a routing form. These steps had not actually been done and she was ranting and raving at that point too.

- HE&R. We had admin we had to keep track of to give people cash bonuses for tax purposes. Denise was continually pulling the sheet off my clipboard in my office without my permission and leaving me with incomplete admin that I had to sort out with Maggie Taylor (on OTVVII) and Denise's assistant. One day I overheard Denise screaming at Maggie to handle the bonus admin when she herself was responsible for the out-admin (along with me for allowing it to happen). Maggie called me up a few minutes later totally flustered and asked me to help her out with the admin as it was really hard to get anything done with a crazy woman screaming in her ear. So I helped her.

- Invalidation. At the end of last quarter, I had felt like I had pushed, debug and driven more than I ever had this lifetime. I was really high on it and I really had done a good job. By the time Denise got through with me, I felt completely invalidated. The fact that I was upstat was completely irrelevant. I've gotten better application of ethics protection for upstats from Tom.

- Make-wrong. Denise made me wrong for saying it wasn't okay to leave an HE&Ry message on my phone where the messages were picked up by my wife. Also anyone who wasn't putting in sixteen hours a day during the last weeks of the quarter, which included most of the managers, were made wrong and said to be "non-players." MUs. If Tom is truly in treason, he will not be handled with a danger condition handling. To say that this is not the SO so we can't do treason is also an MU. Class V orgs, public and even non-Scientologists who used the admin tech apply conditions including the condition of treason. Now, according to Bryan's wishes as I know them, we are not using the Scientology administrative technology so if Denise is intending on using conditions as such, she either has to violate those wishes or use verbal data.

- Creating antagonism. By bypassing Tom and the others and going directly to me and making me the terminal without doing any ESTOing as promised, Denise created animosity towards me from the other managers and Tom. - Creating low morale. The Manufacturing Division had operated in high gear, high production high esteem BEFORE Denise got all over the line. Not there is low morale especially with the managers. According to Tom and James Pritchett, there are a number of people looking for jobs. Joe Fuchs, the Vice President of Quality Control, has also told me that he's heard there's key people on the streets looking for jobs. Joe is very much a company person. He came to me toward the end of last quarter. He said to me, "Chuck, do you know when this is going to end? I can't hold these people together much longer." By running can't haves on people on time, we are asking to have trade unions brought in, given that Manufacturing is traditionally a union operation. Also, I don't have to be an expert to know what a union can do to the stock.

- Collapsed Dynamics. Denise is operating with collapsed dynamics so has no problem expecting other people to do the same. Denise is married to Sam Licciardi and Jerry Gentile is also married. However, they are spending days, evenings, weekends together. I've already had my junior on OT VII ask me if Jerry and Denise had a 2D going. I told him no, they're both married, but they're leaving themselves wide open to speculation. On New Year's Eve, actually at 2:30 A.M., Sam Licciardi and his daughter came to Manufacturing looking for Denise who had already finished off production and was out having a drink with Jerry and several of my employees. Sam gave me a bewildered look.

- 3rd party and unmocking a working installation. Denis 3rd parties Tom to me, and vice versa. It looks to me like she 3rd partied Tom to Bryan because she said Bryan was pissed at Tom. Bryan has had no direct comm with Tom recently and previous to that, when we were in direct comm with Bryan, he held us and Manufacturing in high esteem. This division operated on a high affinity between the managers and personnel and we were able to pull off great feats without HE&R. As Tom said today, we had a working system (working installation). Now, our system has been undermined.

- Personnel problems. For months in the late summer and early fall, we had problems getting the personnel we needed. The personnel CSWs were being directly sent to Denise and as we found out later she wasn't even routing them to Niall (the Personnel director) It was Tom and I who came up with the solutions in the middle of the last quarter. Our solution was to hire temp-to-perm employees and we've totally handled the problem.

- Bad investigations. The above mentioned Adam investigation, the determination that Manufacturing was the "who" on product not going out and the investigation into manufacturing production hours from early last quarter. One of my supervisors had indicated that we were working every weekend and working a lot of hours, so Denise pulled the time sheets (again this was a bypass to get this information from this guy, as I wouldn't' have given her the same information) and came to the conclusion that we hadn't worked very much this quarter. The only problem, as in the previous mentioned investigations, she didn't bother to ask anyone any questions before drawing her conclusions and she included people not in my department in her list and didn't take into account not having materials so we had no units to build at certain points. This gave a completely false picture. I worked the people I needed and frankly what was she trying to prove with this investigation?

Manufacturing did just fine before Denise came into the area. I think she's already done some pretty severe damage to our area and to the company. I'm not looking forward to having to deal with this again. I'm not going to be one of her "players" this quarter because I am going to get on with my life. My experience in Digital Lightwave, Inc. up to this point has been a good one. I think the company generally exchanges very well to its employees. I think this has always been Bryan's intention. We'll again do very well in Manufacturing as we have in the past without this kind of interference. The situations I've outlined are very real and all someone who is interested in Digital Lightwave, Inc.'s future has to do is come down to the Manufacturing facility as everything I said can be substantiated.

It isn't my hat to speculate as to why she has created these effects. I hope she is big enough to see what she has done and get it corrected. It was very hard for me to spot what was going on as I had put her on a bit of a pedestal.

This is true,

Chuck Anderson