Affidavit of Lawrence Wollersheim

late 1995



Alexandria Division

Civil Action No. 95-1107-A



et al.




1. I am 46 years old and live at 880 Moorehead Circle, Apt. 3K, Boulder, Colorado 80303. I make this declaration in response to the Declaration of Kim Baker, dated November 4, 1995 ("the Second Baker Declaration"). Except as expressly noted to the contrary, the following statements are made upon my own personal knowledge. I am competent to and could testify under oath to the facts set forth herein if called upon to do so in a court of law.

2. On or about October 30, 1995, I had a telephone conversation with Kim Baker of Cape Town, South Africa. In that respect, the Second Baker Declaration is accurate and truthful.

3. The Second Baker Declaration, however, is erroneous and misleading in its account of that conversation in paragraphs 4, 5 and 6. Here is what happened in that conversation:

(a) I told her that I had just received her first declaration, dated October 25, 1995, and that I was surprised and shocked by it. I then asked her how she had come to sign that declaration.

(b) Kim said she had agreed to meet with Scientology's people. When I asked the reason why she had agreed to meet with them, she said she was not given any specific reason by them which she could remember.

(c) She said she spent over 13 hours (from 2:00 p.m. until 3:30 a.m.) in a hotel room with a Scientology International intelligence division agent (Office of Special Affairs or "OSA") and some other individuals from Scientology. She told me that there were false statements in the declaration she signed and that she expressly told the Scientology people there were false statements in the declaration they prepared for her to sign. She said they said, "Sign it anyway. Those are just your considerations. Look at all the people who will be severely harmed by this copyright challenge to the Church of Scientology if you don't sign it." She said it was close to 3:30 a.m. when she told them it contained lies. They kept insisting she sign it as it was, and she finally did so.

(d) She said she did not write the declaration. It was prepared for her. She specifically said she would not have written herself what they had her sign.

(e) She was not given a copy of what she signed when she left. I was the one who had one faxed to her so she could review what she had signed for the first time since her 13 plus hours in that hotel room.

(f) I proposed to her that since she said there were lies in the document that she go out by herself and pray with no outside influence (including myself), but her soul and God, to see if she could find the courage to correct the false statements.

(g) She told me she let the Scientology people on to her computer to make copies of her e-mail. I asked her how she could give to Scientology confidential and FACTNet Board Member only e-mail that was sent to her in trust. She said that she had resigned from FACTNet at that point.

(h) Kim stated the International intelligence division person (OSA) was still there in Cape Town. She gave me the distinct impression that they were keeping her under surveillance to see if she would recant her declaration or be ready to apply any additional pressure to ensure that she didn't.

(i) Numerous times during our conversation at various intervals, I asked Kim if she was an "operative" or undercover agent or spy for Scientology. She denied it. I asked her once if she had been paid any money to make this declaration. She denied it.

(j) During the conversation, I told her that her declaration had severely hurt Bob Penny, who had trusted Kim and recommended her to become a FACTNet board member. I did remind her that Bob has the most serious kind of MS, and I said I was shocked she could do this to a friend who was disabled and dying.

(k) She said she felt suicidal after signing the October 25th declaration, and she seemed so despondent when I talked to her on the phone, I became more worried about her than pursuing the issues of the conversation.

(l) I never stated that I would only believe she was not a Scientology covert operative if she would sign a declaration correcting the falsehoods of her first declaration which she openly acknowledged to me. I told her to go and pray and do what her soul and God told her to do. I never in any stretch of the imagination ever told or implied she should lie for us.

(m) To the best of my recollection, I did not tell her it was illegal to have someone sign a declaration and not give them a copy. I did say that it was improper not to give her a copy of what she signed. I believe that in the U.S., it is the normal legal procedure to provide a copy of a declaration or contract to the signer.

(n) I did not tell her I would expose her to the whole world if she did not retract her declaration. Neither FACTNet nor I have not put out any information concerning Kim Baker on the Internet or anywhere else due to an agreement with Kim that we would do nothing until I heard from her again. I told her to take as much time as she needed so she felt no pressure from us at all. I specifically told her that she should make this decision with no influence or pressure from anyone.

4. I have not spoken to Kim or sent her any mail since this conversation. I have left her in peace and with my prayers to find the courage to stand up and correct her declaration.

5. Based upon my own involvement with Scientology and my working with the victims of Scientology for over 15 years, I have personal knowledge regarding the coercion, manipulation and intimidation Scientology regularly employs to silence witnesses or "roll over" ex-members. I, therefore, believe that similar tactics were used by the OSA representatives to induce Kim to sign the two declarations in question. My belief or opinion in this regard is reinforced by many other postings to alt.religion.scientology on the Internet. These postings included her autobiographical "My story," a copy of which is attached as Exhibit B to the second Declaration of Amaldo P. Lerma, dated November 3, 1995. Another relevant posting is her October 16, 1995, posting "REPORT: HUBBARD AND HITLER - A preliminary investigation into the sociopolitical ideo!ogy. of L. Ron Hubbard and Adolph Hitler," a copy of which is attached as Exhibit A.

6, Given the limited time I have had to read and analyze the Second Baker Declaration, my failure to comment on other points made in the Second Baker Declaration should not be interpreted as agreement with them.

7. I declare under penalty of perjury that the foregoing is true and correct. Executed on November __. 1995,

Lawrence Wollersheim

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