1. I am a sociologist by profession, specialising in the area of alternative religions. I am a Professor of Sociology at the University of Alberta in Edmonton, Alberta, Canada where I have worked for the past 10 years. I have been a Full Professor of Sociology since July 1997. Prior to that time I held various positions as Assistant and Associate Professor in the Department of Sociology. I maintain Adjunct Professor status in the Department of Comparative Literature, Religion, and Film/Media Studies, which means that I can co-supervise graduate students and have some of my sociology courses cross-listed for students in religious studies. I teach classes on the sociology of religion at both the undergraduate and graduate level. My particular area of expertise is in an area variously called "new religions," "alternative religions," or "sectarian groups." Scientology is among the groups that I have studied. In addition to these normal academic studies, I oversee a restricted-access collection of primary and secondary material on alternative religions owned by the University of Alberta Library, which includes Scientology material.

2. I began formal studies of Scientology (along with at least five other groups) in 1986, when I received a grant from the Social Sciences and Humanities Research Council of Canada to study "cults and new religions" in the country.

3. One of my articles on Scientology has appeared in a peer reviewed journal ("Scientology's Relationship with Eastern Religious Traditions," Journal of Contemporary Religion, 11 No.1 [1996] 21-36). I refer often to the organization in other articles that I have published on related "sociology of religion" topics. These additional articles include: 1) "Deviance Labelling and Normative Strategies in the Canadian 'New Religions/Countercult' Debate," Canadian Journal of Sociology 15 No. 4 (1990): 393-416; 2) "New Religious Movements" in The Sociology of Religion: A Canadian Focus, New York: Butterworths, 1993: 83-106; 3) "Social Control in Alternative Religions: A Familial Approach," Sociological Analysis 53 No.4 (1992), pp. 355-357 (in which I am second author with Robert Cartwright); 4) "Crimes," in Encyclopedia of Religion and Society, Edited by William H. Swatos, Jr. London: AltaMira Press, 1998, pp. 121-122; 5) "Deviance," in Encyclopedia of Religion and Society, Edited by William H. Swatos, Jr. London: AltaMira Press, 1998, p. 138; and 6) "When Scholars Sin: Alternative Religions and Their Academic Supporters," [co-author with Theresa Krebs] in Skeptic 6 No. 3 (1998), pp. 36, 39, 40, 41, 42, and 43. I continue to research and write about Scientology and other groups.

4. I have given invited talks on Scientology to audiences in Germany, and a Germany parliamentary committee invited me to present information to it about Scientology in September, 1997. In that presentation I spoke about my concerns around Scientology's operation of forced labour and re-indoctrination programs called the Rehabilitation Project Force or "RPF," and its ever harsher and more punitive Rehabilitation Project Force's Rehabilitation Project Force (RPF's RPF). These are programs that elite Sea Organization members enter after internal 'trials' or high-ranking leaders find them guilty of crimes against Scientology. The RPF program is of particular interest to the parties involved in this case because credible evidence exists from a number of sources that Scientologists have placed children (as young as twelve years old) on this harsh and abusive program.

5. By 1993, media reporters began calling me in order to receive my opinions on topics about which they were working. Since then, newspapers in Canada, the United States, Switzerland, and Germany have quoted me about the organization. Similarly, I have spoken on radio and television shows about Scientology in Canada, the United States, Germany, and Australia.

6. In light of my training and professional work, I consider myself qualified to speak about broad issues involving 'Scientology and children.'

7. Concerns about Scientology's impact upon children fall under several categories: a) auditing; b) children's contact with someone who is hostile to the Scientology organization; c) belief that auditing can eliminate various physical illnesses; d) time demands that interfere with parents' time in a manner that adversely affects their children; e) possible neglect of children; and f) security checking.

8. My sources of information about Scientology and children are:

a) American Saint Hill Organization. The Auditor Issue 269 (1997): 8pp;

b) Jon Atack, A Piece of Blue Sky: Scientology, Dianetics, and L. Ron Hubbard Exposed, New York: Lyle Stuart, 1990;

b) Church of Scientology International (compiler). The Scientology Handbook, Los Angeles: Bridge Publications, 1994;

c) CSI [Church of Scientology International], 1988. The Command Channels of Scientology, Booklet, [No Publisher or Place], 49pp.;

d) Hubbard, L. Ron. "Security Check Children" HCO WW Security Form 8. HCO Bulletin of 21 September 1961; Pp. 378-380 in L. Ron Hubbard, The Technical Bulletins of Dianetics and Scientology, Volume IV, 1960-1961, Los Angeles: Scientology Publications, 1976;

e) Hubbard, L. Ron, Revised at the Request of the Church of Scientology International, "PTS Personnel and Finance," Hubbard Communications Office Policy Letter of 12 May 1972R, Revised 27 October 1982; Pp.460-462 in L Ron Hubbard, The Management Series, Volume 1, Los Angeles: Bridge Publications, 1991;

f) Hubbard Research Foundation (compiler, from the research and lecture materials of L. Ron Hubbard), Child Dianetics, Los Angeles, Bridge Publications, 1951, reprinted 1982.

g) Kent, Stephen A. "Brainwashing in Scientology's Rehabilitation Project Force," Revised Version of a Presentation at the Society for the Scientific Study of Religion, San Diego, California (November 7, 1997), Available on the World Wide Web at <http://www.lermanet.com/cos/brainwashing.html> and <http://www.innenet.net/joecisar/rpf1000.htm>;

h) Kent, Stephen A. "Scientology--Is This a Religion?" The Revised and Corrected Version of a Shorter Presentation Given at the 27th Deutscher Evangelischer Kirchentag, June 20, 1997, Leipzig, Germany, and Available on the World Wide Web at <www.rickross.com/reference/Scien20.html> and <www.factnet.org/Scientology /is_this_religion.htm>; and

i) Miller, Russell. Bare-Faced Messiah: The True Story of L. Ron Hubbard, Michael Joseph, Penguin Books, Ltd., 1987.

9. In addition to these Scientology and critical sources, I also have read the affidavits/statements by Bryan Ronald Wilson and Christian Szurko, as well as a draft statement by the Respondent,[name deleted]. I will make a few comments about these statements toward the end of this document. Finally, I cite documents from Scientology's Office of Special Affairs.

10. Auditing--Scientology's own material states that auditing can be applied to children soon after they can talk. Child Dianetics, for example, states:

This passage indicates, therefore, that Scientologists are to believe that auditing of children is in the children's best interest.

11. According to Scientology's own material, one source of problems for children that will cause them to register negative experiences [which Scientology calls engrams] in a part of the mind that Scientologists call 'the reactive mind' is parents who have neuroses. As Hubbard said in Dianetics, "[a]berrated [i.e., irrational or manifesting engrams] parents are certain to infect their children with engrams" (Hubbard, Dianetics, p. 162). "The abberrated parents implant their mutual aberrations in the children..." (Hubbard, Dianetics, pp. 167-168). More dramatically, auditing supposedly can uncover the aberrations that mothers committed against their fetuses in prenatal periods. According to Dianetics:

12. Statements such as this one imply that many children were born despite mothers' failed attempts at self-induced abortions. Dianetics, of course, is the foundational book for both Dianetics and Scientology, and the existence of this passage, which Scientology's founder wrote, programs children to have this alleged memory.

13. Children's Contact with Someone Who is Hostile to the Scientology Organization--Scientology defines a "suppressive person" or "SP" as one "who seeks to suppress, or squash, any betterment activity or group" (Church of Scientology International [compiler], Scientology Handbook, p. 426). By this legal action, the Respondent, [name deleted], would be (according to Scientology) a suppressive person.

14. This designation has important implications for the manner in which Scientologists would view the children. Again according to Scientology's definitions, they would be "potential trouble sources" because of their continued relationship with their mother. As Scientology defines the term, a "Potential Trouble Source (abbreviated 'PTS')" is "[a] person who is in some way connected to and being adversely affected by a suppressive person. He is called a potential trouble source because he can be a lot of trouble to himself and others" (Church of Scientology International [compiler], Scientology Handbook, p. 426).

15. More specifically, a "PTS Type I" is "one who is associated with or connected to a suppressive person in his present time environment. By 'connected' is meant in the vicinity of, or in communication with in some way, whether a social, familial, or business relationship" (Church of Scientology International [compiler], Scientology Handbook, p. 428).

16. According to Scientology doctrine, Scientologists have their ability to progress in auditing damaged by being in contact with suppressive persons via potential trouble sources. Consequently, one accepted Scientology strategy is to attempt to get the Potential Trouble Source to cease contact (called 'disconnecting' in Scientology) from the suppressive person. As a Scientology publication states (after discussing how the organization had cancelled the disconnection practice in the past), "the tool of disconnection was restored to use, in the hands of those persons thoroughly and standardly trained in the technology of handling suppressives and potential trouble sources" (Church of Scientology International [compiler], Scientology Handbook, p. 440). Consequently, the Respondent, [name deleted], has every reason to fear that, in unsupervised visitations, her former husband would try to get the children to turn against their mother.

17. Belief That Auditing Can Eliminate Various Physical Illnesses--Scientology believes that around 70% of all illnesses are psycho-somatic, which makes them responsive to Dianetics auditing (see Hubbard, Dianetics, p. 108). Indeed, a Hubbard Communication Office Policy Letter (revised on October 27, 1982) even states that "[a] chronically ill person, whether the person is known to be connected to a suppressive or not, is always found to have been so connected and PTS" (Hubbard, "PTS Personnel and Finance," p. 460).

18. L. Ron Hubbard's book, Dianetics: The Modern Science of Mental Health (1950), speaks directly about the supposed causes of illness:

19. This belief that auditing can impact illness continues in the organization. In, for example, the Scientology "monthly journal," The Auditor (Issue 269, published in 1997), readers received the "Process for the Common Cold." The process involves repeatedly saying to someone with a cold, "'What haven't you lost lately?" or "Tell me something you haven't lost.'" The description of the process ends with the invitation, "[w]e want to hear about the miracles that occur when you use this process" (American Saint Hill Organization, The Auditor, p. 5).

20. Moreover, Scientology doctrine also states that a Scientologist touching an injury, infection, or illness can assist in healing or curing. As a Scientology publication indicates:

21. These unorthodox attitudes toward illness and healing raise legitimate concerns about whether Scientologists would respond quickly and appropriately if children were to become injured while in their care.

22. Time Demands That Interfere With Parents' Time in a Manner that Adversely Affects Their Children--In the paper that I delivered in Leipzig, Germany in 1997, I documented how the Scientology organization itself becomes, functionally, a new family for Sea Organization members, often at the expense of their spouses and children (Kent, "Scientology--Is This a Religion?," pp. 15-19). In essence, evidence exists that, at least in the past, Scientology's long and harsh work demands forced many of its most committed members to perform tasks that kept them away from their children. When an organization such as Scientology apparently places its most committed members under arduous work-hours, then concerns exist about similar kinds of time demands placed upon Scientology parents who are not Sea Org members but nevertheless are on staff at local Scientology offices.

23. Possible Neglect of Children--Also in my Leipzig presentation I documented instances of probable neglect of children by their Sea Organization parents (Kent, "Scientology--Is This a Religion," pp. 19-21). Living and play conditions for Sea Organization children seemed poor (at least in the past in some locations), and some children seemed to have been neglected while their parents fulfilled their Scientology responsibilities. Many more examples of probable instances of child abuse and neglect within Scientology are available on the World Wide Web at <www.taxexemptchildabuse.net> on a site entitled, "Scientology & Dianetics: Tax Exempt Child Abuse and Neglect?"

24. Security Checking--On September 21, 1961, L. Ron Hubbard produced a document entitled, "Security Check Children," and specified it for children whose ages range from six to twelve years old. It contained ninety-nine questions (by my count), and it leads into them with the statement, "[t]he first question is the most potent." That first question is, "[w]hat has somebody told you not to tell?" Other questions include, "[d]o you have a secret?," "[h]ave you ever done anything you were very much ashamed of?," and "[h]ave you ever cried when you shouldn't have?" Presumably Scientology adults put children through this security check while the children were on the reputedly spiritual counselling device, the E-Meter. I have never seen this children's security check cancelled, and its existence raises important questions about the extent to which the Scientology organization believes it has the right to intrude into the lives of its children.

25. In her draft statement, The Respondent, [name deleted], indicated that her former husband "used to sit [one of the children–name deleted] down and make him stare at him for as long as 1/2 hour without moving[.] (I now know this is called the first stage of the 'TR's)." This deduction is essentially correct. The Scientology Handbook describes the TR (training routine) "TR0 Confronting" in the following manner: "Training Stress: Student and coach sit facing each other, neither making any conversation or effort to be interesting. They sit and look at each other and say and do nothing for some hours. Student must not speak, fidget, giggle or be embarrassed or fall asleep" (Church of Scientology International [compiler], The Scientology Handbook, p. 168 [highlighting in original]).

26. The Respondent, [name deleted], also indicated that her former husband, who is the Applicant [name deleted], would not let her or anyone else "go near the children when they hurt themselves, as he claimed that speaking to them would create 'engrams.' This was one thing my heart would not let me give into, so it always ended up with him screaming at me, and physically trying to push me away from the children." This behaviour follows exactly what L. Ron Hubbard instructed in Dianetics regarding the prevention of engrams either occurring or becoming associated ("keyed in") to particular incidents:

27. Moreover, The Applicant's [name deleted] allegedly violent reaction (screaming, and trying to push his wife away from the children) is in accordance with Hubbard's instructions:

The Applicant's [name deleted] alleged behaviour and attitude toward injured children, and his alleged behaviour toward his wife (at the time) when she tried to comfort children who were hurt, was in keeping with Hubbard's directives.

28. Although the Applicant, [name deleted], has provided an undertaking to the Court that he would not indoctrinate the children into Scientology doctrines, Scientology's policies--which he must follow as a Scientologist--would make it necessary for him to attempt to do so were he to have the opportunity.

29. Finally, I must offer a few comments on parts of Dr. Bryan Wilson's affidavit, who is an expert on behalf of the Applicant, [name deleted]. Crucial facts are inaccurate, and these inaccuracies allow Dr. Wilson to draw erroneous conclusions.

30. First, Dr. Wilson states that he has "discovered no evidence of the operation of an 'intelligence agency' within the Church of Scientology" (para. 19). Actually, abundant information exists about this so-called internal 'intelligence agency,' formerly known as the Guardian's Office and now called the Office of Special Affairs (under which works the Department of Special Affairs). A 1988 publication by the Church of Scientology International describes the official structure and duties of the Office of Special Affairs as follows:

I note that this section also states that OSA claims to help orgs expand by keeping them "operating fully in accordance with the laws of the land...," but recently leaked documents indicate otherwise.

31. Insight into the actual operations of the Office of Special Affairs comes from confidential training documents that Office of Special Affairs personnel had to study in 1991, and which former Department of Special Affairs member, Frank Oliver (currently residing in Florida) has entered as evidence in an American court case between F.A.C.T.NET and Scientology's Bridge Publications International. The list of documents that members of The Office of Special Affairs Investigation Section had to study includes the following:

Of particular interest is the item, "OSA Inves 9 July 1991 - Frequent Flyer Club Hat," which instructed Office of Special Affairs Investigations staff how to call airlines and attempt to get the frequent flyer records of people (and hence the record of people's trips). Aside from being illegal, this activity is a classic example of Scientology's intelligence gathering activities.

32. While Bryan Wilson may not have had ready access to material filed in an American court case, abundant and easily accessible information exists on the Internet about Scientology's 'intelligence agency' and operations (for example, <http://www.entheta.net/entheta/go/>).

33. I note, too, that one of the documents that Office of Special Affairs Investigation staff studied was about suppressive persons and groups. Its inclusion as a document that Scientologists had to study indicates that both Mr. Christian Szurko (who is an expert on behalf of the Respondent, [name deleted], and I are correct in emphasizing (in contrast to Dr. Wilson) the importance of the "suppressive person" term in assessing how the Scientology organization views the Respondent [name deleted].

34. Dr. Wilson is incorrect when he states categorically, "Scientologists are voluntary participants in their religious faith. They are not incarcerated, and they are not subject to a regime of threats and blandishments" (para. 18). While I could debate the extent to which Scientologists are subjected to various types of threats as they progress in the organization, the organization's Rehabilitation Project Force (and its even more severe Rehabilitation Project Force's Rehabilitation Project Force) meets (in my opinion) the social scientific designation of "brainwashing." These two programs put supposedly deviant Scientology Sea Organization members (probably including some pre-teens around eleven or twelve years old) through "regimes of harsh physical punishment, forced self-confessions, social isolation, hard labour, and intense doctrinal study, all as part of leadership-designed efforts to regain members' ideological commitment" (Kent, "Brainwashing...," p. 1, see 68). Mr. Szurko (an expert on behalf of [Respondent’s name deleted]) is aware of the Rehabilitation Project Force, and refers to a short article of mine on the topic that his counterpart organization in Denmark published in a magazine (Szurko statement, para. 29).

35. Once again, Dr. Wilson (an expert witness for the applicant, [name deleted]) seems to be unaware of the Rehabilitation Project Force, even though he claims to have read "the commentaries and critical accounts of Scientology" (Wilson affidavit, para. 8). Among the best of the critical accounts is by Jon Atack, an Englishman whose book, A Piece of Blue Sky: Scientology, Dianetics, and L. Ron Hubbard Exposed was published in 1990 and has numerous sections on the Rehabilitation Project Force program (Atack, Piece of Blue Sky, pp. 206, 250, 252, 257, 266, 275-276, 322, 328, 341, 358, & 359).

36. While little point exists in analyzing Dr. Wilson's dismissal of Mr. Szurko's statements about L. Ron Hubbard's charlatanism (see Szurko statement, para. 11 & 12; Wilson affidavit, para. 16), suffice it to say that Dr. Wilson does not cite the definitive source on L. Ron Hubbard, which is another book written by an Englishman. When biographer Russell Miller published his unsurpassed Hubbard biography in 1987, he revealed his sentiments about Scientology's founder in the title of his book, Bare-Faced Messiah--a word-play on the phrase, 'bare-faced liar.'