------------------------------------------------------------------- F.A.C.T.Net, Inc. (Fight Against Coercive Tactics Network, Incorporated) a non-profit computer bulletin board and electronic library 601 16th St. #C-217 Golden, Colorado 80401 USA BBS 303 530-1942 FAX 303 530-2950 Office 303 473-0111 This document is part of an electronic lending library and preservational electronic archive. F.A.C.T.Net does not sell documents, it only lends them according to the terms of your library cardholder agreement with F.A.C.T.Net, Inc. ------------------------------------------------------------------- Respondent's response to: Case No. 87 DR 2467-2 PETITIONER'S INTERROGATORIES TO RESPONDENT AND REQUEST FOR PRODUCTION OF DOCUMENTS IN RE THE MARRIAGE OF: {wife] (F/N/A [married name]), Petitioner, and [husband], Respondent. August 1, 1993 Respondent states as follows. Compliance with the interrogatories and request for documents would endanger the respondent and his business associates and other associates in ways that are neither necessary nor relevant to the case at hand. A protective order is therefore appropriate. Context: At a mediation session held pursuant to the parties' Separation Agreement, both Petitioner and Respondent agreed that their minor children are subject to emotional stresses which need to be addressed for the benefit of the children's well-being. At that mediation session, Respondent proposed and Petitioner refused to allow evaluation and possible intervention by qualified mental health professionals. Respondent then filed a motion for modification of custody which would grant him sole custody in the specific areas (only) of health care, education, and religious upbringing. No change was proposed to the children's residence or visitation. No monetary claims were made against Petitioner. A hearing date has been set for November, 1993. Because of the long delay during which the children's needs remain unaddressed, Respondent filed a second motion requesting that the court order an evaluation by qualified mental health professionals. It was so ordered, and the court appointed (xxx) and (yyyy) to conduct the evaluation. Respondent has met with both of them and awaits their meeting with Petitioner. Respondent anticipates delay and obstructionist action by Petitioner. The "Church of Scientology" has been mentioned in these proceedings, but only as possible explanation of Petitioner's position and actions. That organization itself has not, until now, been directly relevant to the proceedings of this case. ALLEGATION: If disclosure were made to Petitioner per the interrogatories and request for documents, the resulting information about Respondent and his associates would become available to the "Church of Scientology." ALLEGATION: Scientology has an extensively documented criminal history, including "dirty tricks" attacks against those it perceives as adversaries, in accordance with its "fair game" policy (still used in practice, despite cult allegations to the contrary) which states than an enemy "may be deprived of property or injured by any means by any Scientologist without any discipline of the Scientologist. May be tricked, sued, lied to or destroyed." Respondent has been formally declared an "enemy" of Scientology and thus is subject to the cult's "fair game" policy. As a representative example of the cult's conduct against perceived adversaries, we submit a declaration from Lawrence Wollersheim, who has a thirteen year history of litigation with Scientology, including a unanimous jury decision and $30 million award of damages in a widely publicized case, and another declaration by Steven Fishman who was himself involved in illegal activity on behalf of the cult.. Documentation of Scientology's criminal activity and its abuse of the justice process, particularly in relation to perceived adversaries, is vast and extensive. Further material supporting these allegations is available upon need or request by the court. Respondent further states: Scientologists may learn infamous Scientology practices such as "fair game," "knowledge reports," "ethics," "TR-L" (Training Routine - Lying -- a drill used to train Scientology operatives to lie in court or elsewhere despite any evidence) and other practices, either directly through formal training or indirectly through role models who demonstrate what a good Scientologist looks like and how he or she is to act. Without reliance on how Petitioner came to acquire such behavior, Respondent asserts that she has evidenced behavior toward him, consistent with Scientology's infamous policies, and he believes she would continue to do so, either on her own volition or under pressure from cult "hard sell" practices. In 1984, in Clearwater Florida, Petitioner and Respondent both attended a Scientology event at which a new membership organization was announced, called the International Association of Scientologists (IAS). Respondent was appalled at the coercion, psychological manipulation, deception, and lack of informed consent which were in evidence during that event. Later that night, in the privacy of their own room (Respondent and Petitioner were married at that time), Respondent communicated to Petitioner his discomfort with the event. The very next morning Respondent was summoned to the cult's "Ethics Officer" and questioned about the exact statements he had made privately to his wife the night before. Also in 1984, in Boulder Colorado, Petitioner arranged and cooperated with an assault by Scientology operatives against Respondent, in which Respondent was physically restrained, intimidated, threatened, and otherwise harassed. Petitioner later justified this event to herself in terms of Scientology "ethics," and showed no remorse except to state that she should not have done it in their home. There was and is no indication that Petitioner would not repeat such conduct. In 1986 in Boulder Colorado, Petitioner joined with a group of local Scientologists in a covert attempt, while Respondent was out of town, to seize control of Petitioner and Respondent's (then) jointly owned business for the purpose of putting it under control of the cult and making its revenues available to the cult. The rights of Respondent both as shareholder and as corporate President were disregarded in favor of cult "ethics." Respondent asks the court for a Protective Order to prevent disclosure to Petitioner (and therefore to the "Church of Scientology") information that could be used, per documented policies and practices of the cult, to harass or harm Respondent and/or his associates. I declare under penalty of perjury under the laws of the State of Colorado that the foregoing statements are true and correct to the best of my knowledge and understanding. Executed August _______, 1993 at [location]. ____________________________________________________________________ [husband], Respondent DECLARATION OF LAWRENCE WOLLERSHEIM OF AUGUST 6, 1993 I Lawrence Wollersheim declare: 1.) I am an expert on the nature, tactics, and policy of Scientology and Dianetics. I was a member of Scientology for 11 years and for the last 13 years I have been involved in extensive research, litigation, and litigation consulting against Scientology and Dianetics. 2.) I have read the Petitioners Interrogatories to Respondent ([husband]) and I am gravely concerned for the following reasons: A.) [husband] is considered by Scientology to be a strong and active critic and adversary. In Scientology's terminology he has been put on their enemies list and has been labeled a suppressive person. The significance of being put on the enemies list by being declared by Scientology to be a suppressive person is better understood from the "Fair Game Policy." "An enemy," [they] "may be deprived of property or injured by any means by any Scientologist without any discipline of the Scientologist. . .may be tricked, sued, lied to, or destroyed.'' B.) Scientology and Dianetics are currently considered by most experts to be one of the most dangerous and destructive of the global cults (in the category of the Jonestown or Waco group.) Government investigatory agencies treat the possibility of violence or harassment against perceived critics or perceived adversaries as very serious. C.) The interrogatories filed on [husband] are remarkably similar in style to the interrogatories filed directly or indirectly by the intelligence division of Scientology in many other cases involving ex-members who are now active critics of Scientology. It is my expert opinion that the information requested in these interrogatories was directly or indirectly created with the assistance of Scientology's intelligence division and goes far far beyond the very limited and specific information needed to address and resolve the issues of [husband's] suit against his former wife regarding limited custody and Guardian rights. D.) It is my opinion that the real reason for the request of so much unneeded and detailed financial information is to gather additional information for the intelligence divisions of Scientology for probable use in future harassment actions against [husband]. I believe this to be a credible probability because: i.) According to firm Scientology policy [husband]'s ex-wife currently a Scientology staff member must assist and work closely with Scientology's intelligence divisions by turning over all information on [husband] that could involved a threat to Scientology or Scientology's public relations image and consequently their income. Especially if that threat involves any individual that she is connected to that is currently criticizing Scientology publicly (as Bob is.) ii.) I personally have experienced two of Scientology's financial harassment and Black PR campaigns where either my creditors, employees, or investors were contacted and discouraged from continuing their relationships with me by giving them damaging and alarming false data about me and my businesses. In Aspen Colorado in a business of mine my creditors, employees, and investors were called by an individual working for Scientology and were told I was being invested by the Security and Exchange commission for fraud. On another occasion in an earlier business of mine in California, accounts receivable debtors were contacted by a Scientology agent and discouraged from paying their bills causing the eventual collapse of that business. In this same business employees also were contacted and encouraged to quit. En masse over a 2-4 week period many left. iii.) Additionally, it is also Scientology's firm policy to punish its critics through abuse of the legal system. One aspect of that is to overwhelm their adversaries in onerous legal expenses and other harassment as is expressed in the following quotes from the writings of L. Ron Hubbard: "The purpose of a lawsuit is to harass and discourage rather than to win....Don't ever defend. Always attack. Find or manufacture enough threat against them to cause them to sue for peace. Originate a black PR campaign to destroy the person's repute and to discredit them so thoroughly they will be ostracized..." "The law can be used very easily to harass, and enough harassment on somebody who is simply on the thin edge anyway, will knowing that he is not authorized, will generally be sufficient to cause his professional decease. If possible, of course, ruin him utterly." From "A Manual on the Dissemination of Material" (1955) by L. Ron Hubbard. "The goal of the department [of governmental affairs ] is to bring the government and hostile philosophies or societies into a state of complete compliance with the goals of Scientology. This is done by a high level ability to control and in its absence by a low level ability to overwhelm. Introvert such agencies. Control such agencies." -- LRH "The purpose of the legal officer is to help LRH handle every legal, government, suit, accounting and tax contact or action... and to bring the greatest possible confusion and loss to its enemies." -- LRH Documentary evidence in Church of Spiritual Technology (COST) vs. U.S., November 22, 1989. 3 .) Because of the before mentioned it is my opinion that it would seriously endanger the livelihood and business of [husband] to require the over broad and onerous interrogatories to be answered in their current form. Because of the proven dangerous history of the Scientology organization extreme discretion, precision, and security sensitivity is required by the court in determining what financial information is absolutely necessary to be disclosed by [husband] to resolve the issues at hand. I declare under penalty of perjury under the laws of the State of Colorado that the above is true and correct to the best of my recollection and understanding. Executed this ______ day of August, 1993, at [location] ____________________________________________________ Lawrence Wollersheim DECLARATION OF STEVEN FISHMAN I, Steven Fishman, declare as follows: 1. I have personal knowledge of the facts stated herein, unless stated on information and belief, and if called upon to testify to these facts I could and would competently do so. 2. I am a Defendant in the case of Church of Scientology v. Steven Fishman and Uwe WI Geertzl United States District Court, Central District of California, Case Number 91-6426- HLH(Tx). I am currently serving a five year sentence for mail fraud and I am on Parole under the supervision of the United States Probation Office, Southern District of Florida. 3. I am readily familiar with the practices of the Church of Scientology International regarding their taking of depositions, and of discovery. My deposition was taken by Timothy Bowles and James L. Jackson on March 24-26, 1993. Further, my psychologist, Uwe W. Geertz, provided the Church of Scientology with discovery including tape recordings of my psychological sessions with Dr. Geertz, who is my co-Defendant in the above-captioned case. 4. Subsequent to obtaining copies of these tape recorded sessions, I was visited and phoned by various agents of the Office of Special Affairs of the Church of Scientology International without their permission or consent. These tape reeordings included copies of hypnosis sessions performed by Dr. Geertz. These OSA Agents, inclu~ing Brad Van Dyck a~d Virginia Smedberg Redmon, used these taped sessions to induce hypnosis in an attempt to manipulate me and to influence the outcome of the civil case in their favor. They attempted to secure my unwilling participation to sign a confessional and a request for an amnesty, both of which would have been perjurious and prejudicial to my case. 5. It is standard and typical procedure for the Office of Special Affairs of the Church of Scientology to use information garnered from depositions and other forms of discovery to intimidate, harass, and occasionally to cause physical and emotional harm to their perceived enemies and to the families, psychologists, psychiatrists and attorneys of their perceived enemies, under the doctrine of Fair Game. 6. When I was attached to the Guardian's Office and later to the Office of Special Affairs, part of my hat or job assignments were to flood enemies of the Church with junk mail in an operation known as Bingoing. This involved sending a group of staff members to the public library, in order to raid the periodicals section and pick out technical journals and magazines, circling numbers on the business reply cards wildly and randomly, and filling in the name and address of the perceived enemy, so that he or she would be flooded with junk mail. Many such requests originated from information secured during discovery including depositions conducted in legal cases where litigation and disputes were ongoing between the Church and its enemies. I was oftentimes asked to phone the perceived enemies or "SPs" (Suppressive Persons) in the middle of the night, and either make a specific telephonic threat or simply hang up, at the direction of the Ethics Officer of the Org or the Director of Special Affairs (OSA liaison). Prior to my arrest in 1988, I had been put on a detail known as Ringbacks, where I was instructed (by my Ethics Officer Frank Thompson) to dial a series of five hundred or more beeper numbers in succession from one dialing prefix, and then leave the telephone number of our enemy so that he or she would be flooded with unwanted telephone calls by parties who genuinely believed that someone had phoned them on their beeper. Such harassment was typical of what the Church of Scientology International does with names and addresses obtained through legal discovery. 7. Furthermore, active staff members, including family members if any, were required by the Director of Special Affairs to write up Knowledge Reports concerning intimate details of the personal life of the Suppressive Person to be used in discovery and in the taking of depositions. Once further information was secured, whenever possible, the Director of Special kffairs, following the Hubbard Communications Office Policy Letters referring to Black PR would amass a file of damaging information on the Suppressive Person or enemy of the Church in order to further sue, attack, or whenever possible, to ruin him utterly. The Church of Scientology would encourage Scientologists to disconnect from former members who fell out of favor with the Church, and it is not uncommon for discovery to be used to alienate family members from one another and to split them up. In September of 1984, I was ordered to get a divorce, and I was actively assisted by Yvonne Shirley "Bonny" Mott, the Authorization and Verification Unit Officer of the Commodore's Messenger Organization, to bring the divorce to its End Phenomenon or conclusion, as part of her "stat" or statistic, in order to increase and encourage my production of my own "stats", which were criminal activities involving the filing of fraudulent class action lawsuits, for which I was eventually arrested and convicted. 8. It is my viewpoint that all depositions involving the Church of Scientology should be videotaped, or be taken before a Special Master as ordered by the Court, in order to prevent abuses of discovery. I declare under penalty of perjury under the laws of the State of Florida that the above is true and correct to the best of my recollection and understanding. Executed August 4, 1993 at Sunrise, Florida. (signature - Steven Fishman) From the words of L. Ron Hubbard the founder of Scientology in HCO policy letter of 18 October 1967. "In my opinion the church has one of the most effective intelligence operations in the U.S. rivaling even that of the F.B.I." From Ted Gunderson a former head of the F.B.I's Los Angeles office. [From the Time Magazine cover story on Scientology May, 1992.) Upon request, a detailed summary of government investigation and non-government documents are available which detail Scientology's history of harassment and intelligence operations Scientology's intelligence division. ================================================================= If this is a copyrighted work, you are acknowledging by receipt of this document from FACTNet that on the basis of reasonable investigation, you have not been to obtain a copy elsewhere at a fair price, and that you are and will abide by the following copyright warning. WARNING CONCERNING COPYRIGHT RESTRICTIONS: The copyright law of the United States (Title 17, United States Code) governs the making of photo copies or other reproductions of copyrighted material. Under certain conditions specified by law, libraries and archives are authorized to furnish a photocopy or other reproduction. One of these specified conditions is that the photocopy or reproduction is not to be "used for any purpose other than private study, scholarship, or research." If a user makes a request for, or later uses, a photocopy or reproduction for purposes in excess of "fair use," that user may be liable for copyright infringement. FACTNet reserves the right to refuse to accept an order for copying or other duplication, or delivery of copied or duplicated material if, in its judgment, fulfillment of the order would involve violation of copyright law. ------------------------------------------------------------------- ------------------------------------------------------------------- DOS FILENAME OF TEXT FILE: CUST1X1.TXT DOS FILENAME OF IMAGE FILES: none ADMINISTRATIVE CODE: SECURITY CODE: DISTRIBUTION CODE: NAME FOR BBS: Father's petition for protective order upon reciept of discovery request on the case described in CUST1*.* SORT TO: scn, files, legal CONTRIBUTOR: bp LOC. OF ORIG: bp NOTES: For additional verification see image files contained in the file with same name and .ZIP extension. UPDATED ON: UPDATED BY: =================================================================