|AFFIDAVIT AND DEMAND FOR REFUND AND REPAYMENT
19 April 2003
Delivered by USPS mail To:
Sherman Lenske, Registered Agent, Church of Spiritual
Sherman Lenske, Registered Agent, Religious Technology Center
Jeanne M. Gavigan, Registered Agent, Church of Scientology
Jeanne Gavigan, Registered Agent, Church of Scientology, Western
Jeanne Gavigan, Registered Agent, Church of Scientology of Los
Timothy Bowles, Registered Agent, Church of Scientology of
Gregory A. Long, Registered Agent, World Institute of
Laurie Bartelson, Registered Agent, Scientology Missions
Jeffrey G Quiros, Registered Agent, Church of Scientology San
International Association of Scientologists
US IAS Members' Trust
Church of Scientology, Advanced Organization Los Angeles
Church of Scientology, American Saint Hill Organization
David Miscavige, Chairman of the Board of Directors, Religious
The above Registered Agents are hereby directed to
deliver a true copy of this affidavit and demand for Refund and
Repayment to David Miscavige and the actual person or persons
who has ultimate authority to issue Refunds and Repayment.
Copies are being sent to:
US Department of Justice
California Department of Justice
Federal Bureau of Investigation
Joint Committee on Taxation
Governor of California
Senator Barbara Boxer
Senator Diane Feinstein
Congresswoman Diane Watson
District Attorney, County of Los Angeles
Mayor of Los Angeles
American Civil Liberties Union
Los Angeles Times
Michael Leonard Tilse
P.O. Box 954
Newport, OR 97365
Dear Registered Agents, Churches and David Miscavige,
Michael Leonard Tilse hereby declares these true facts to all
My name is Michael Leonard Tilse.
I am over the age of 18.
The statements herein are of my own personal knowledge and
research reading and I can testify competently thereto.
I first encountered the Church of Scientology in mid-October,
1975 at the so-called Church of Scientology San Francisco
Organization, then on Mason Street.
On or about 13 January 2003 and thereafter I became aware of
having been defrauded by the so called Church of Scientology,
the Scientology Religion and various of its affiliates and
organizations of its overall ecclesiastical and corporate
structure, (the Church), in a number of ways as set forth in in
Since October 1975 The Church has defrauded me by
representing to me that it is the most ethical and law abiding
group on the planet so as to secure my continued membership,
contribution, support and monetary donations.
Whereas as revealed in sworn testimony I have now read from
various court cases the actual truth is that at all times since
at least October 1975 there have been members, staff members and
executives of the Church, who have been involved in crimes as a
matter of the normal operation of the Church. Examples are the
the Church's Guardian's Office department members who pleaded
guilty and agreed to all the crimes mentioned in the governments
stipulation of evidence in the case of US vs. Mary Sue Hubbard,
who then went to jail.
In 1976 when I was on staff at the Church, San Francisco, the
Guardian's Office staff at San Francisco Organization approached
me to borrow a miniature "Minolta 16" camera from me so they
could photograph documents when they did their breaking and
entering capers. At the time I did not realize that this was
actually criminal acts that were being planned. I have since
read testimony of 70's Church Guardian Office staff who relate
the criminal operations of this group.
I have read accounts of the Church Office of Special Affairs
using its operatives to impersonate Spanish policeman in an
operation conducted to intimidate ex-scientologists in Spain.
I have read testimony of former staff of the Church Author
Services, Inc., about David Miscavige as Chairman of the Board
of Author Services, Inc., as head of this for-profit
corporation, (in the 80's), taking millions of dollars out of
the nonprofit status Church of Scientology and Scientology
Missions for the use and inurement of L. Ron Hubbard. One of
these depositions was from Jesse Prince whom I had known while I
was in the Church Sea Organization during 1977-1978.
I was never told these facts. I would never have joined or
stayed in a group that I knew was engaged in such crimes.
When I was in the Church Sea Organization in 1978 I was
ordered to destroy documents which I now realize were material
evidence in Federal investigations as to the continued influence
and intimate control of the Church of Scientology by L. Ron
Hubbard when such control and influence was illegal due to the
nonprofit status of the Church. I was not told that destroying
these documents was a crime and that such control and influence
were subjects of investigation even though there is testimony
and recorded tapes from that time that show that executives
within the Church at the time knew and discussed these exact
I feel that my personal reputation and integrity has been
blackened by having been ordered to commit this crime and my
having done it because I was told at the time it was not
unethical or a crime. Had I known it was a crime I never would
have done it.
In 1975 and at all times thereafter the various "Churches of
Scientology" I have associated with have defrauded me by falsely
representing to me that the various files about me kept in the
organizations such as "P.C." folders, or "Confessional
Formulary" files, "ethics files", "student files" and staff
applications and other Church records regarding me are
confidential and are only used for internal Church purposes to
deliver the elements of the Scientology applied religious
I was specifically told this when, after doing the
"Communication Course", (Hubbard Apprentice Scientologist
Course), in October 1975 in the San Francisco Church of
Scientology on Mason Street, I was very upset after I had read
articles in the "British Statesman" at San Francisco public
library. These were articles about the Church which told of the
Church of Scientology in England using the contents of staff
applications and auditing sessions against ex-members.
When I brought these articles and the statements in them to
the attention of Bill Steiner the then ethics officer of the San
Francisco Church of Scientology as causing fears that I had had
while doing the "life History" section of the staff application
form, specifically that this information could be used against
me, He assured me that all of it was confidential and would
never be used against me as a matter of Church policy and that
the articles in the British Statesman were lies.
It was fundamental to my agreement to remain in the Church as
a member at that time and after and then to join Church staff in
February 1976 and after, that I was assured the information I
was giving the Church in the staff application, other
communications and in auditing sessions about my sex life,
childhood wrongdoing, family members, etc., would NEVER be used
It is part of the public policy of the Church that "auditing"
or "P.C." files are to be kept secret and confidential. These
folders are even marked "confessional formulary."
I now discover through reading sworn testimony that it is
common practice and is even written in Church Guardian's Office
and Church Office of Special Affairs confidential and secret
policy to search and extract or "cull" P.C. files and other
files of individuals who are ex-members, for crimes or sexual
events or any other embarrassing information and "buttons" that
can then used to harass, intimidate and destroy the lives of
those who have left the Church, testify in court to Church
crimes and activities or those who are critics or reformers who
speak out about Church abuses.
There is sworn testimony in court cases, such as the
so-called "Wollersheim" case in which former members of the
Church Guardian's Office or the Church Office of Special Affairs
have testified to the fact of the practice of using such
confidential information to harass and intimidate ex-members and
spread information to their families, friends and employers in
order to destroy their lives and reputations. I believe that the
actual written Church policies have also been entered into
evidence in court cases.
Had I been told by the Church that such materials and
information obtained from members had ever been used or would or
could be used against anyone who had left the Church I would not
have associated myself or remained associated with the Church
nor given them any money for counseling or training. I was
defrauded by the false assurance of the Church in its policy and
by its executives that the Church adhered to and delivered only
the pure and unaltered Scientology applied religious philosophy
as written by the man L. Ron Hubbard.
In my many years of taking Church courses I was required to
read the L. Ron Hubbard written policy known as "Keeping
Scientology Working" many times and I have been assured many
times by this policy and by written Public Relations articles in
magazines, bulletins, local announcements, and at group events
by executives such as David Miscavige that the Church adhered to
and delivered only the pure and unaltered works of L. Ron
Yet now I find that L. Ron Hubbard's technical bulletins,
books, tapes and policy are being reissued by the Church with
deletions, additions and wording changes as many as 16 years
after he has died, which changes cannot be traced back to any
original verifiable L. Ron Hubbard handwritten directives for
I have personally verified deletions, additions and changes
to several books which have been published by the Church
publishing organization Bridge Publications as being copyrighted
by the L. Ron Hubbard Library and which are sold in bookstores.
These include the "Introduction to Scientology Ethics" book and
the "New Slant on Life" book. These books are designed to
confuse readers by including the words "L. Ron Hubbard" in the
title and represent that they are "new" editions of similarly
titled books actually authored by L. Ron Hubbard. These altered
editions are then used by the Church to deliver training courses
and counseling and other activities which are represented as
being the pure Scientology applied religious philosophy as
authored by L. Ron Hubbard.
There are many reports of other books, tapes and other
writings by L. Ron Hubbard being issued after his death that
contain additions, alterations and deletions as compared to the
original published tapes, books and articles. These include
changes in the technical application of the Scientology applied
religious philosophy, something which L. Ron Hubbard
specifically warned against.
This is a fraud on me as I was led to believe only pure L.
Ron Hubbard writings and lectures would be delivered to me as a
student and as a person receiving counseling and such confidence
was the basis for my donations of funds for training, counseling
and membership. Gaining my confidence and selling me on the
basis of this promise of pure and unaltered technology and
philosophy and then delivering to me an altered version with
changes not traceable to actual works provably written by L. Ron
Hubbard is complete fraud.
I would not have continued to support the Church or donated
time, effort or money to it had I known it was delivering
something else than pure and unaltered L. Ron Hubbard technology
I was defrauded when I was convinced to donate money to the
Church International Association of Scientologists by being told
the falsehood that the International Association of
Scientologists and its money collecting organizations such as
the West US IAS Membership Tour, the US IAS Members Trust or
others, were solely established for and operated to "Unite,
Support, Advance and Protect Scientology applied religious
philosophy..." when the truth was quite different.
I was sold an IAS membership and pressured into further
donations to the IAS on the basis it was to protect the
scientology applied religious philosophy. Many "briefings" were
given me in the sales efforts of IAS registrars such as Howard
Becker, Bridgett Kelleher and Michael Roberts, in which stories
of "attacks on Scientology" in countries such as Germany, Spain,
Italy and France were used to convince me that I had to urgently
give them them money to "Protect Scientology".
Such registrars as Howard Becker and Michael Roberts even
came to my house uninvited and verbally "double-teamed" me,
playing on my "buttons" of my desire to help and support my
religious philosophy for hours until I was emotionally beaten
into giving them more money for the IAS. I was made to feel
guilty if I did not give them more money. I had to forcefully
ask them to leave more than once. One time I had to flee my own
house because they were putting so much manipulative emotional
pressure on me.
I now know that in fact IAS monies have been used to defend
church staff, executives and organizations from the consequences
of their own criminal acts as in the so-called "Crusade" against
the Larry Wollersheim Case, the David Mayo case and now
currently the Lisa McPherson case.
I have now read testimony and reports that the so-called
"attacks" in Spain, Germany and France were in fact caused by
the unethical and criminal acts and the financial crimes of
Church members, staff and executives and these so-called
"attacks" were actually legitimate judicial investigations,
inquiries, trials and lawsuits brought by Governments who had
actual evidence, not some fabricated conspiracy.
Furthermore, the IAS is represented as the official
membership organization of the Scientology Religion yet it was
not created by L. Ron Hubbard, it was not authorized by L. Ron
Hubbard, nor was the policy accepting it as the membership
organization of the Church of Scientology written by L. Ron
Hubbard. Even the whole issue type of this policy, known as a
"Scientology Policy Directive" was never authorized by L. Ron
Protecting staff, executives and organizations from the
consequence of their crimes is a false and fraudulent use of the
monies I donated for the protection of the Scientology applied
religious philosophy and had I known this money was going to be
used in that way, I would never have donated it.
I have been convinced under the false pretenses above to
donate of USD $31,867.00 to the IAS via various organizations
such as the West US IAS Membership Tour and the US IAS Members
Trust and by such registrars as Howard Becker and Michael
Roberts and also Ted Bronson of the IAS office aboard the Church
vessel known as the "Freewinds". I would imagine that would thus
be an International monetary crime since the ship was in the
Caribbean at the time of that registration effort and my
It is known to me that the Church organization known as CMO
International ordered the IAS to refund money involved in
another fraud and this demonstrates that the IAS and its
associated organizations are in fact an inseparable part of the
overall Church structure.
I hereby DEMAND full repayment of all monies and the value of
all stock as credited to my IAS account with no delay or
I was defrauded into contributing time, effort, support and
monies to the Church by a false and clever wording of documents
and promotion pieces designed to convince me that the
"Scientology Religion" composed of these Churches was the same
thing as the "Scientology applied religious philosophy" as
authored by the man L. Ron Hubbard.
My continued membership in the Church has always been based
on my desire to personally benefit and secure for others benefit
from the Scientology applied religious philosophy as authored by
the man L. Ron Hubbard. This personal desire has cleverly and
fraudulently been diverted into support for and agreements
signed with organizations of the Church "Scientology Religion"
through being presented with documents and advertising
containing clever and deceptive wording designed to convince me
that they are the same thing. They are not. In fact the lawyers
for the Church of Scientology have argued in court that the
"Scientology Religion" has no legal obligation to adhere to any
of the writings of L. Ron Hubbard.
My interest and participation in the Church has been in part
to attain the promised spiritual awareness and abilities of the
Scientology philosophy "upper levels" known as the ""OT levels".
These "OT Levels" are the basis for the promise of "Total
Freedom" and "Immortality as a Spiritual Being" made in the
writings of L. Ron Hubbard. The possibility of being denied
access to these "OT Levels" is a matter of huge duress to me. I
have been fraudulently induced into signing agreements, waivers
and other documents with the Church, (Such as the Advanced
Organization Los Angeles and the American Saint Hill
Organization, the RTC and possibly others), under the duress of
not being allowed access to these "OT Levels". It was made clear
to me by staff and executives and the documents themselves that
if I did not enter into these agreements and sign these
documents I would not be allowed access to these "OT Levels".
Yet per testimony of people who have studied these "OT Level"
documents, the "Scientology Religion" and its Churches are not
delivering pure unaltered L. Ron Hubbard writings for these
levels and thus they are factually NOT available within the
Church. Thus all agreements I have made with any of these
organizations and any documents I have signed of any kind with
them are invalid due to this fraud and duress upon me.
I was defrauded of legally required minimum wages in the
2-1/2 years of work I did for various Churches as a staff
When I was a staff member in the Church I was told I was
working for a charitable organization and later that I was in a
religious fellowship, (The Sea Org). However, I was not told at
any time during my tenure on staff that the Church actually was
involved in crimes, was involving me in crimes and that it had
its nonprofit status under review, such status had been revoked
or that funds being collected by the Church were inuring to
for-profit organizations, (Author Services, Inc.), and to
individuals. Thus the so-called Churches should have in fact
been paying me at least minimum wages for work.
Confidential parishioners donation records of mine have been
sent to the IRS without my knowledge or agreement.
In 2000, (as I remember it), I was notified of an IRS audit
of my taxes for 1998. In the course of collecting information
about this I found that my 1999 parishioner's statement from the
Church Advanced Organization Los Angeles was in error with
nonsensical computer generated characters that made the
statement values incorrect. I was disturbed about this because
the IRS was also requesting my 1999 returns and documents. I
spoke to Marc Jefferson, the Director of Income at the Advanced
Organization Los Angeles. When I told him he would have to give
me a corrected statement to send to the IRS, he told me that the
church had already provided the parishioners statement
information to the IRS independently as part of its tax
compliance program. It was clear he was not speaking of a 1099
form or a summary, but the actual detailed parishioner's
statement. I was outraged by this.
I was never told prior to this that the Church organizations
had a practice of sending by unrevealed separate channels the
information about my church donations to the IRS. I was never
asked to agree to this and never would have agreed to this.
This practice of the Church makes them an agent of the IRS
which is a violation of my privacy, a fraud upon me because I
never would have agreed to this practice and possibly a
violation of laws regarding government interference with
In order to fraudulently induce me to continue my membership,
support and money donations to the Church and the "Scientology
Religion", David Miscavige, Pat Broker, Ray Mithoff, Earle
Cooley, Annie Broker, Norman Starkey and possibly others
conspired to hide from me the actual events and circumstances of
L. Ron Hubbard's death. They did this by fabrication of a
so-called "Acceptable Truth" which then became the LIE that that
they individually and together told at the Hollywood Palladium
event in January 1986 to assembled members of the Church, which
audience included me personally.
The actual facts of L. Ron Hubbard's death include that he
had a stroke nearly 8 days before he died, that the attending
physician, Dr. Denk, had informed the coroner's investigator
that L. Ron Hubbard had exhibited dysphraisia after the stroke,
that he had Vistaril tranquilizer in his blood at his death and
that 11-1/2 hours passed before anyone called the funeral home
to report his death. And especially, suspiciously, that he
supposedly had signed a new will on the day before his death.
Per testimony, there also appears to have been no effort on
the part of these church corporation executives to inform
Hubbard's wife or children of his sickness and impending death,
nor to allow them to attend the body, be involved with the
investigation or attend the cremation of the body.
These facts which are alarming in the extreme to anyone who
has been involved with Scientology for any length of time were
carefully omitted from the fabricated story told at the
Hollywood Palladium event in January 1986.
The continued conspiracy included fraudulently concealing
from me and other Church members that there were many challenges
filed to the last will of L. Ron Hubbard and the probate of his
estate which the church then paid out millions of dollars to
settle and obtain "gag agreements" from those challengers. Had I
been informed of the actual facts of L. Ron Hubbard's death and
its suspicious circumstances I would have personally supported
independent investigation of it and challenge to the probate and
probably would have joined the challenges myself. I certainly
would not have accepted the story I had been told by these
In 1997, when I did start asking Church executive and estate
executor Norman Starkey questions about L. Ron Hubbard's death I
was refused answers to my specific questions and I was ordered
to undergo counseling at my expense which attempted to find out
the source of my questions. This was sold to me as part of my
"OT Preps" and it was clear I would not be allowed on the "OT
Levels" without this "handling". This is intimidation and duress
for trying to find out the truth.
Also under the duress of being denied my "OT Levels" if I did
not sign, I was given a document and fraudulently induced to
sign an agreement that I be subjected to the so-called
"Introspection Rundown" if the Church decided it was the
appropriate "Spiritual" procedure by its estimation and that
this could include my being held isolated from family, friends
or legal representation and that I could not rescind this legal
At the time I was being induced to sign this agreement, the
Church withheld from me that at the Church organization known as
Flag, Lisa McPherson had in 1995 been held against her will on
the so-called "Introspection Rundown" for 17 days and had died
while under the care of the Church staff and executives. Nor did
they disclose to me that Flag was the subject of two felony
indictments in this death. I would not have signed this
agreement or donated further monies to the Church had I known
the facts of this case.
I hereby declare that any agreement I may have signed or
otherwise entered into that grants any Church organization,
member, staff member or executive the right to subject me to any
procedure or counseling, including the "Introspection Rundown",
is invalid, false, illegal and fraudulent and has no force nor
may it be enforced upon me in any way.
I personally can testify that the Church Religious Technology
Center has received stolen property and that I was told how the
RTC then used it.
I personally can testify that the Church Advanced
Organization, WISE, Church of Scientology International and the
RTC knew that a crime had been committed against me by another
member of the Church and all these organizations refused to
follow the L. Ron Hubbard justice policies that I cited to
remedy the situation. This is evidence that the Church in
practice feels that it has no duty to follow the writings of L.
Ron Hubbard but is instead following some other divergent
I personally can testify that the Church Advanced
Organization, American Saint Hill Organization and the Flag
Service Organization have known of an actual crime against me by
a member in good standing with these organizations, yet have not
taken any effective steps that I know of to get this member to
remedy his crime, but instead have questioned me as to my ethics
and have threatened me with denial of access to the "OT Levels"
and expulsion from the Church.
I can testify that I was told in "briefings" during the
so-called "Wollersheim" trial that when the International
Association of Scientologists (IAS) was created in 1984,
millions of dollars were transferred from the Church of
Scientology of California into the IAS by the ruse of the Church
donating $2000.00 "Lifetime Memberships" for each staff member
in the Church at the time so as to deplete the assets of the CSC
and thus deny payment in the event of loss of lawsuits.
I can testify that this scheme of buying IAS memberships for
staff members occurred when I was myself on staff in the Sea Org
at Scientology Missions International, yet I was subsequently
reguired to purchase an annual membership in the IAS, and later
purchased a Lifetime membership even though it supposedly had
been previously bought by Church of Scientology of California.
I can testify that while on staff at Scientology Missions
International, I observed that the international statistics were
In my experience in the Church since 1975 I have been told
many times by the Church that critics of the Church tell only
lies and distortions and that reading the comments of or
communication with such critics or ex-scientologists can upset
me and that the fact of my doing so can be used to deny me
access to the "OT Levels" or even membership in the Church.
Because of this duress and fear of being denied attaining the
promised spiritual awareness and ability of the "OT Levels",
that I was also told was only available within the Church, I
kept myself from reading information that was critical of the
Church. Instead because I had questions born of my own personal
observations of the Church's refusal to follow the writings of
L. Ron Hubbard within the Church and because specifically I
questioned the story that had been told about L. Ron Hubbard's
death, in 1997 I wrote to Norman Starkey, who is executor of L.
Ron Hubbard's estate, asking him questions so I could determine
the true story of L. Ron Hubbard's death, including asking what
was on the death certificate and what the coroner had reported.
Between 1997 and 2003 the only answer I received from the
Church was that L. Ron Hubbard had died of natural causes. This
was not a responsive answer to my detailed and extensive
questions. The Church had received from me many communications
that it was important to my own peace of mind and continued
participation in the Church that I have these questions honestly
and responsively answered.
In January 2003, after almost six years of being denied
within the Church answers that would resolve my personal doubts,
I finally began to research using the Internet to find the
answers to my questions.
Only after I had become convinced that I would never be
answered and that I also would never be allowed access to the
"OT Levels" because I kept asking these questions, did I then
break from the prohibition of the Church against communication
with information from critics or ex-scientologists. I began to
read postings regarding facts of the death of L. Ron Hubbard and
other reports and only then did I realize that I had been lied
to by the Church.
I verified for myself that the postings were true and correct
by obtaining official documents from the County of San Luis
Obispo in California.
In further research on the Internet I came across various
postings of court testimony, depositions, historical records,
documents, official filings and personal writings having to do
with the Church and its history and activities.
There are a number of these sworn testimony postings which
confirme my own experiences within the Church and which are by
people I had met or known of. Many of these ex-members had been
in the Church as long or longer than myself.
Only after I read these various information sources did I
become aware of the way in which the Church has defrauded me in
many areas since 1975, as detailed in this document, by
withholding from me the actual truth about its secret policies
and activities and the actual truth about the various court
cases and "attacks". Had I not been prohibited from researching
this information by the intimidation of the Church, I would long
ago have sought out this information and severed my association
with the Church and demanded my money back. The duress of never
being allowed access to the "OT Levels" and the general
intimidation of the Church against members finding out critical
information about it is a fundamental part of the fraud it
perpetrated upon me.
The Church in fact has paid refunds and repayments and court
awards to many ex-Scientologists including Larry Wollersheim,
Greg and Deborah Barnes, Loretta Miscavige, Virginia McClaughry,
Tory Christman and others. Many of the points of fraud I have
brought up in this document have been issues in litigation which
the Church has lost.
I refuse to have my money held hostage in exchange for
waivers or gag agreements. I will not sign any waiver of rights
or "gag agreement" in order to get my own money which was, as
detailed in this documents, swindled from me by fraud.
I cannot sign any promise not to sue or testify against the
Church in the future because I cannot guess in what way the
Church may harass me, intimidate me, commit criminal acts
against me or otherwise create grounds for such prosecution or
lawsuit against itself. An example would be using any
information contained in counseling or auditing or P.C. files or
other files in any way. Such an act would be completely against
the law due to the promises which the Church made to me as to
confidentiality of these files and I would therefor have to seek
criminal prosecution and civil suit.
I will not sign any waivers because I cannot know at present
if or when some future criminal prosecution or civil action
against the Church may name me as a party along with the Church
due to my long association with it. Also, it is part of my
inalienable rights and my duty to speak out about criminal and
fraudulent acts and thus I cannot sign any gag agreement that
would prevent me from communication of what I know.
I will not sign any "gag agreement" because I am a writer and
the memories, experiences and documents I have accumulated in my
27 years of association with the Church are a vital part of what
I have to write about. Any such agreement would thus impair my
future prospects as a writer, a further fraud.