------------------------------------------------------------------- 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. ------------------------------------------------------------------- Steve Fishman 1728O-OO4 C-N Unit FCI Tallahassee PMB 1000 Tallahassee, Florida 32301-3572 Sunday, July 12, 1992 Dear Larry, I received your letter of June 27th, and since then I have forwarded you some more motions I raised in answer to Scientology's demand to compel me to have my deposition taken over again. They have also called the prison and left messages for me to call the law offices of Bowles and Moxon in care of my Counselor. Right now I am working on filing a criminal complaint against Peter Comras, the Scientology Agent who gained access to the prison under false pretenses in order to turn over information to OSA. He lied, as you may recall, claiming to the prison officials that he was a representative of the Israeli government, which is a crime. He had also fooled Margery into believing that he was genuine, and consequently we gave him copies of a lot of the reports which was used as evidence in their civil suit against me. But I will not give up on him, because he is a real criminal. Unfortunately, in answer to your question, the prison rules are very strict and we are not allowed to use any type of computer discs or tapes. It is illegal to use them or to mail them out of the prison or receive them in the mail. So the best I can do is the letters I have been sending. Any form of computer media is considered contraband and there are severe penalties for that, so I hope you understand. But hopefully you can still arrange to copy what I have sent and circulate those to whomever needs interrogatories of that type. There is another inmate here named Jack Johnson who was defrauded out of his mineral rights to mine gold in Costa Rica by the Scientologists and a corporate shell they have called "GOLDCORE." He had mining rights to Portrero Beach, Costa Rica, and they were stolen from under him, and an individual involved in the scheme named Davey Brown was killed under mysterious circumstances. He dealt with Karl Erich Heilig (Trustee for the Church of Spiritual Technology and the Church of Scientology Spiritual Trusts) who used an alias named Harold Heye. Jack identified his picture from a brochure and told me that this was the individual he had been dealing with, and who impacted negatively upon his case for which he is serving the longest sentence for a white collar offense in U. S. history, 34 years. In any case, Jack is a good friend and has been helping me with the legal research. He recommended that since there are no attorneys willing to take my case, that we file a civil RICO lawsuit against them ourselves. I will keep you posted as far as how that goes. I am trying to get Jack a job in the Law Library, where he can continue the research. Other than that, the next hurdle is July 20th when the Judge will decide as to whether the Scientologists will have the right to take my deposition again or not. There will be a phone conference and the Judge will be hearing the motions at that time. If you have any suggestions, please let me know as soon as possible. I will continue to send you copies of all of the legal materials as they happen. With Best Wishes, te~ ---------------------------------------------------------------------- ------------------------------------------------------------------- ------------------------------------------------------------------- Affidavit of Steven Fishman I, STEVEN FISHMAN, am a former member of the Church of Scientology. I was on staff as the Fields Financial Planner of Fort Lauderdale, and later the Fields Financial Planner of Miami, between 1979-1988. I left the Church after a successful exit counseling attempt in August of 1990. I am currently serving a five year sentence for mail fraud in connection with my position at the Church of Scientology. I am currently incarcerated at the Federal Correctional Institution of Taiiahassee, Florida. I became acquainted with the civil lawsuit of Larry Wollersheim during the fall of 1985. Herein are the circumstances within which I became familiar with the case: During the summer and fall of 1985, I was being audited on my New Era Dianetics Grade V processing at the Mission of Fort Lauderdale and the Miami Organization of the Church of Sciento!ogy. Auditing is a form of spiritual counseling offered by the Church. My auditors were Nancy Witkowski in Fort Lauderdale and Leah Abady in Miami. In New Era Dianetics, the preclear, or person getting audited, is directed to view mental image pictures of pain and unconsciousness which the preclear or parishioner has been led to believe existed in his "past track" or successive episodes of past life experiences. The preclear is led to believe this through various mind control techniques, utilizing various forms of trance induction and hypnotic suggestion, namely the TRs or Training Routines, and in the latter case, through either "reverie", "anaten" or "boil-off", which are Scientology-defined phrases for specific conditions of hypnosis. This is done with the aid of an electropsychometer, or E-meter. During my specific experience with this New Era Dianetics (or NED) auditing, I was led to believe while under mind control that I had been the biological father of Jesus Christ, who was represented to me to be a very evil being, an enslaver of mankind who was given to violent rages and temper tantrums, and who was also a homosexual and molester of children. For five years (1985-1990) I believed that I had "pulled the evil Christ into my own universe" by having been sexually attracted to his mother (Mary) as a young man, and further that she became impregnated by virtue of the fact that each morning I would watch her bathe in a stream and having become aroused by watching her behind reeds (bushes), the semen (ejaculate) penetrated her via the movement of the current of the warm water in the stream. I was directed toward other (suggested) memories which were indicated by my auditors who measured the truth or falsity of these "events" on the E-meter, including the crucifixion of Christ, where I had believed myself to be present, having been directed to look at mental image pictures in a reduced state of hypnotic awareness of my having hammered his left foot to the cross, and other scenes. My viewpoint of Christ was that of Hubbard's himself, as evidenced on Saint Hill Special Briefing Course Tape # 112, wherein Hubbard stated that Christ died for his own sins. During this period of my auditing, my hatred for Christ reached a point where I felt an enormous level of guilt for having fathered such a "degraded being" as he was called by my auditors Witkowski and Abady. Further on in my auditing, after having sessions at the Flag Service Organization in Clearwater, Florida which validated or corroborated the results of the auditing in Miami and Fort Lauderdale, I was given further data my Ann Glushakow and Margaret Supak regarding who "Christ really was on the whole track", or what the previous life cycles or incarnations of Christ were. At that point, at the order of Inspector General for Tech Ray Mithoff, I was given some OT (Operating Thetan) data which was normally not extended to someone who had not attested to the State of Clear. Under the supervision of two Class XII auditors, Richard Reese and John Eastment, and where my folder was personally Case Supervised by Ray Mithoff, I was allowed to see some confidential materials which were photocopies of L. Ron Hubbard's handwriting and preserved in cellophane sheets. This data related to OT III, or the Wall of Fire, an advanced level in Scientology. I learned that there had been an Emperor Xenu who had brought us here to earth in an attempt to solve overpopulation on another planet called Marcab, or the Marcab Confederacy. I had asked Richard Reese where this planet was, and he showed me a Technical Bulletin (typed, not handwritten, but marked Confidential), that explained that Marcab was the planet between Mars and Jupiter in our own solar system, which had been destroyed in a war or holocaust which involved the use of the hydrogen bomb, and that this planet was now a fragment of rocks in space known as the "asteroid belt." Further, I was given data where at the time the Earth was known as "Teegeeack", and that we (all thetans or spiritual beings here or the aggregate population of the planet) were transported in clusters (packaged by the thousands together) and transported here in space ships that closely resembled DC-9 airplanes, and thereafter we were dropped in two volcanic areas, one of which was Las Palmas, and the other Hawaii. From there we dispersed, and through various means, including going up through the evolutionary or genetic track (of picking up bodies), we populated the planet. I was finally told that Xenu, who had been the most evil being of all, was toppled in a revolt in which L. Ron Hubbard participated as a "loyal officer" of the people. I was further told by Reese and via the handwritten document I was shown of Hubbard's that Xenu was trapped in an electronic mountaintop, where "he was to this very day." After a rigorous Security Check on the E-Meter by Hans Stahli, who was the Qualifications Secretary of the Religious Technology Center, I was routed back to Ray Mithoff, and was told by Mithoff that the Emperor Xenu had many subsequent evil life cycles, and one of these was that of Christ. I had raised the question of how this possibly could have been true when the data in Hubbard's own hand indicated that Xenu was trapped in or on an electronid mountaintop, where he remained "to this very day." Mithoff explained that the body remained there, but Xenu, the thetan, had dropped the body and has created havoc as a chaos merchant on the planet ever since. The explanation made perfect sense to me at the time, as I knew from previous training and processing in Scientology that the body is nothing more than a vehicle which the thetan or spirit operates, much like one can drive a car, and then abandon it. The above preface is relevant to this case, as I will now explain. Mithoff revealed to me that having failed to take responsibility for "fathering Xenu when he was Christ", I had pulled in much pain and suffering into the physical universe. Further, that Christ was back, but this time, presenting the most dangerous threat to the only hope mankind had, namely, the Church of Scientology. Mithoff explained to me that Xenu / Christ had returned as Larry Wollersheim, and I needed to handle him and thus rectify my overt act or high crime that I had caused by virtue of the fact that I had fathered Christ as an illegitimate son in that lifetime. My hatred for Xenu / Christ was now fixated and personalized against Larry Wollersheim. I felt compelled to destroy him, for I believed that he was the reason for all of humanity's ills and sorrow. I had been very active in the Guardian's Office of Scientology, working under Fred Hare, and in 1981, having destroyed the legal case of an ex-member suing the Church by the name of Lavenda (Van Schaick) Dukoff. After the Guardian's Office was renamed the Office of Special Affairs in 1983, I continued to work as a OSA Missionaire, under various Church officials, including Lyman Spurlock, who had participated in various covert operations, one of which was the recovery of some stolen documents (archival records of L. Ron Hubbard dating back to 1947-1948), which during said recovery, Lavenda's sister Lisa was raped. It was Lyman Spurlock who gave me specific data on Larry Wollersheim. I was told that he lived in Aspen, Colorado, and that this parents owned a steak grill or coffee shop in Milwaukee, Wisconsin. The Office of Special Affairs, under the direction at that time of Edward Parkin and Lynn Farny, had ordered the Permanent Off Loading of Larry Wollersheim. Permanently Off-Loading someone means killing or murdering them, although we referred to the practice as "an enforced abandonment of the mock-up" and other Scientological euphemisms. It was Lyman Spurlock who told me that the Office of Special Affairs had ordered the Permanently Off-Loading of Wollersheim, and under the mind control influence I was under at the time, I fully agreed with the order, and further, I wanted to be an active participant in it. Lyman told me that the Office of Special Affairs needed someone with "great confront", (someone who could confront things more than other people were capable of doing), who could "handle" Wollersheim. The Office of Special Affairs had difficulty in locating Wollersheim at his home in Aspen, but concluded that at certain times of the year, such as on the birthday of his father and/or mother, or at Christmas, it was likely that Larry Wollersheim would bevisiting his parents in Milwaukee. Further, Lyman Spurlock indicated that as soon as he knew from Office of Special Affairs operatives in the Milwaukee area who had the home and coffee shop of his parents under constant surveillance that Larry Wollersheim was visiting his father, Larry Sr., then that would be the best time for Larry Wollersheim to be Permanently Off-Loaded. Lyman wanted me to relocate to the Milwaukee area and apply as a waiter, cashier, or other food service worker in Larry Sr.'s coffee shop, and if that were not possible to frequent the location as a "regular" and gain a foothold into that scene as a plant. Lyman told me that the best way to handle Larry Wollersheim was to "Pixie-Dust him", or have him given doses of cyanide poisoning. Lyman also had a very strong hatred for Larry's mother, whose name was Elinor. I remember her name because it was the same name as one of my supervisors, Ellie Bolger, the Fields Financial Planner International. Lyman wanted Elinor to be Pixie-Dusted as well, which was supposed to serve as a means to localize the incident and deflect any responsibility away from the Office of Special Affairs. There was another family member named Cindy who he disliked, but I do not recall how she was related to Larry. It may have been his sister, although I cannot recall more about her. I expressed an eagerness and a willingness to do the Operation, although I never was told what the name of the Operation was. However, I was not called upon to fly to Milwaukee, and two years later, I had asked my Ethics Officer, Dori Hare (Fred Hare's wife, as Fred Hare later became the Mission Holder of Fort Lauderdale), why I was never asked to handle Wollersheim. Dori Hare told me that I could not go anywhere when I was having ethics troubles of my own, plus, she did not want my production (of securities class action lawsuit claims) to be interfered with. I was also a telex/data entry operator for the Flag Banking Office Network External, later incorporated as part of the INCOMM Computer Network of Scientology, and I was one out of three people authorized to send and receive on the INCOMM network in connection with a global tax evasion and money laundering scheme known as Operation Paper Chase, so it was not possible, according to Dori Hare, for me to be away from the Miami Org and/or Mission of Fort Lauderdale for any extended length of time. I also was having difficulties with the Church because of a PTS situation (Potential Trouble Source) occurring because my own parents had become antagonistic to Scientology as a result of conversations with a psychologist who was a friend of the family named Uwe Geertz, and who later served as an expert witness in my criminal case, along with Dr. Margaret Singer and Dr. Richard Ofshe, notable experts on thought reform and specifically on the Church of Sciehtology's use of mind control techniques. I was very offended that despite the fact that Lyman Spurlock had offered me the chance to kill Wollersheim, I was never invited to go to Milwaukee and do it. I argued that I was the most suitable for the job as I had been the father of Wollersheim when he was Christ. I further reminded Dori Hare that quantities of cyanide (provided to us by an employee of the American Cyanamid Corporation who was a Scientologist) was readily available at the warehouse in Miami under the custody of Warehouse Manager Charlie Fox, as well as the Flag Service Organization Warehouse, under the custody of Flag Warehouse Manager Bruce Ferguson. Nevertheless, Dori Hare told me that until my production was up and my own ethics were handled (with regard to my antagonistic parents), I was not going to be allowed to handle WollerSheim at all. I suggested to Dori that I would be willing to blow up an airplane that Wollersheim was on as a passenger, if she would provide me with that data when the Office of Special Affairs discovered when he was traveling on a plane in connection to his legal case against the Church. Dori Hare told me that too many innocent people would die along with Larry Wollersheim if I did that, and then I would be committing an overt act against these innocent people. She said that although Wollersheim deserved such a fate, that the airplane method was not the way to go about it. During the intervening year of 1986, on or around August 23, 1986, I went to Los Angeles to participate in the "Battle of Los Angeles", or the Anti-Wollersheim Crusade for Religious Freedom, as it was called. During that time, I worked under Deborah Truax, who was attached to Golden Era Productions, raising money for the Defense Fund by calling Scientologists all over the country. Although I raised $ 16,800 in contributions, my stat for that endeavor was "Emergency" because I failed to meet my quota of $ 25,000, which in retrospect was an impossible amount to raise during the time period allotted. Deborah Truax admonished me and said that had my "confront" been sufficient and my "postulates" positive enough, I could have raised that amount from just one person alone. To compensate for this failure, I was asked to help her in the covert operations which occurred in the evening. On one occasion I raided the trash can of Charles O'Reilly, who was Wollersheim's attorney at the time. I found nothing of value during that raid. During the night, I also was ordered by Deborah to call the home of O'Reilly as well as Psychiatrist Louis Jolyon (Jolly) West, who was assisting Wollersheim in his civil case against the Church. I was told to scream and threaten whoever answered the telephone. I was told by Bridge Publications Sales Manager Jon Stachelrodt that a campaign to harass Attorney O'Reilly, and another attorney named George Rosenberg, until their lives were made so miserable that they would "just give up in apathy." Later in 1988, Commander Kurt Weiland of the Office of Special Affairs had ordered "Wollersheim completely individuated from his attorney(s)", and this was communicated to me through the Director of Special Affairs of Miami, Humberto Fontana, who had been given this data at a confidential OSA briefing at Flag. Humberto Fontana had a group of us write letters to Charles O'Reilly at that time, telling him he was a fool for staying on the case because Larry Wollersheim was never going to settle no matter what, and he (O'Reilly) was never going to get paid. The letters were sent to O'Reilly somewhere in Santa Monica, California, and this was a different address from the location on Figueroa Street in Los Angeles where I had searched the garbage during the Crusade. These letters were sent to O'Reilly via remailing services which we used throughout the country. We did not identify ourselves as Scientologists, but rather as relatives of Wollersheim who were angry that "Larry didn't use his common sense and settle the thing." Some of the staff members who were mustered to write the letters were Linda Mac Phee, the Citizens Commission on Human Rights Representative; Fran Hardy, the Public Executive Secretary of Fort Lauderdale, and Toni Levy, the Personnel Procurement Officer of the Hubbard Communications Office in Miami. We sent the letters to O'Reilly via remailing services at the Mail Center of Chicago at 323 South Franklin Boulevard, as well as other locations we had access to in Gretna, Louisiana; St. Louis Missouri; and Fullerton, California. We were never told that the campaign was successful, as I only recently learned that O'Reilly was no longer representing Larry Wollersheim, although I do not know whether our "Individuation Campaign" was the precipitating factor in it. After we lost the "Battle of Los Angeles" and Wollersheim had received a $ 30,000,000 verdict from the jury, the effort to overturn the decision through covert operations was stepped up as the case was being prepared to go before the appeals court. One method that I am aware of was to move money out of the country using such corporate shells such as Theta Management, ASSISCO, the Author Family Trust, the Church of Spiritual Technology (which manages the gold-storage facilities and the RPF Estates Section used to accumulate' profits (gold bullion) from Operation Paper Chase; as well as other lesser known entities such as the Church of Scientology Religious Trust, which recently became the successor in interest to the Author Family Trust, as control is now completely under the control of Religious Technology Center Chairman David Miscavige. Please evidence a document (attached hereto) which describes the actual holdings of the Church of Scientology, as directly quoted from International Scientology News, Issue 24, which was printed by the Church of Scientology at the end of 1989: "In this decade (1979-1989) the VSD (Value of Services Delivered) has been running routinely at new highest ever levels and has expanded by over 800% with 1.1 billion dollars (emphasis added) of Value of Services Delivered." Nevertheless, the Church conducted a deliberate campaign to understate its assets to the Court in the Wollersheim case, in very much the same way as it understates income to the Internal Revenue Service on a routine basis. In March of 1988, as a matter of course in the performance of my post, I worked with Flag Banking Officer Leona Grimm in transferring funds to accounts maintained by the Church under the name of Theta Management at the Bank Leu in Lausanne, Switzerland; Bank Leumi in Tel-Aviv, Israel; the Ziraat Bank of Ankara, Turkey; the Indosuez Bank and the Banque du Commerce et Credite Internacionale both of Luxembourg, and the Foreign Commerce Bank of Vienna, Austria. I did the journals and reported the stats to the Flag Banking Officer International, David Gaiman, while the actual journals and transfers of funds were done electronically by wire at Flag. Leona Grimm signed off on all of my entries on the INCOMM computer. She had mentioned on two occasions that there was an urgency to get the records completed because of "mocked-up" (false) reports required to be sent in to the Appeals Court in the Wollersheim Case. Our entries on INCOMM were forwarded to Carol Martiano at the Office of Special Affairs in Los Angeles, and then she in turn forwarded the completed and authorized documents to Larry Heller, who was the Church attorney arguing the case in California on our behalf. The above Affidavit is true and correct to the best of my knowledge. Steven Fishman ---------------------------------------------------------------------- ------------------------------------------------------------------- ------------------------------------------------------------------- Operation Paper Chase Within the next several weeks I will be testifying before Interpol regarding a Scientology operation that has been going on since 1974. Operation Paper Chase was started by Mary Sue Hubbard while Controller of the Guardian's Office. The operation was headed by David Gaiman, and I became involved with it in 1981, when I was trained on the computer network used by INT management which is now known as the INCOMM network. Operation Paper Chase involved the placement of highly trained Scientologists in various international banking, credit and world funding organizations who were responsible for the granting of credit to foreign countries. Many of these countries were third world countries who had applied for loans through the International Bank for Reconstruction and Development, known as the World Bank. Besides the World Bank, we have employees positioned in the International Monetary Fund, the Export-Import Bank of the United States, the Advisory Commission on Intergovernmental Relations, and the National Endowment for Democracy. Additionally, in Europe, we covertly comprise staff on the Bilderberg Trust, the Council on Foreign Relations, and the Trilateral Commission-- the very agencies which Freedom Magazine constantly exposes as fraudulent. In Britain we have infiltrated the Royal Institute for International Affairs, the holding company of the Council on Foreign Relations. We have research personnel working for the Church of Scientology who have jobs in the Federal Reserve Bank as well. My job was to coordinate the data received in the forms of telexes and dispatches from key personnel in all of the above agencies who were our comm lines, and enter the data into the INCOMM network, so that it could be analyzed and acted upon. The only data we were interested in was data relating to the denial of credit to developing countries or nations where political upheaval was on the rise. When I was on staff, I worked for the Guardian's Office (1981-1983), and continued to do this same operation for OSA (Office of Special Affairs), until my arrest (from 1983-1988). This was part of my FP MM hat, but I served as a data entry clerk, and what I particularly looked for were indications that credit which was once promised, was now withdrawn or denied. I highlighted those entries on the INCOMM network and compared them to previous entries indicating that credit would be granted. This data was on line to the Commanding Officer of INCOMM, which since the G. O. was disbanded was David Gaiman. The balance of this network was run in Europe by Isidore Chait, and was persohally supervised by the Miscavige family (David, Michelle, and Ronnie~. Network. The largest and longest position that we ever were was a series of repetitive shorts (in and out) on several the Soviet bloc countries, and what is interesting about is was that we shorted the Russian Ruble in 1985, long before the collapse. Often, we would only be in a position for a day, as in the case of Fiji, about four years ago. It depended upon the information which we were constantly receiving and processing and analyzing from our operatives within the international credit granting agencies. I do not recall the names of any of our people connected with the Trilateral Commission, the Council on Foreign Relations, and the Bilderberg Trust. Those wires came in on a stat report from NEP in Copenhagen, and they were coded with numbers representing the origin of the data. Occassionally I received telexes from our office in Saint Hill, at East Grinstead Sussex, England. These were from the World Bank, and their offices were at New Zealand House, Haymarket, London. With the Washingt,on Scientology staff members I can be of significantly more help. These are the following contacts I remember: (1) Danny Bond, who was the Country Risk Analyst for the Export-Import Bank of the United States, located somewhere on Vermont Avenue, in Washington, D. C. We had someone in there before Danny named Tom Forbord, doing the same job. (2) Jack Frenkel, who worked in the Research Department of the International Monetary Fund as an Economic Director. His address was on 19th Street in Washington. (3) Joan Casey and Marcia Carroll, both Research Assistants for the Advisory Commission on Intergovernmental Relations, in Washington, D.C. (4) Joe Wood, who handled Risk Management and Financial Policy for the World Bank on H Street and 18th, in Washington, D. C. Joe is a Vice President of the Bank, which is officially called the International Bank for Reconstruction and Development. (5) Diane Bettge, and then later' Margaret Ferry, both worked for the Public Information Office of the National Endowment for Democracy, in Washington. I was never sure of what role they played in all of this, although we received telexes from that office all the time. I believe they assessed political stability of foreign governments for the CIA, but that is only what I was told by Ellie Bolger. I wish I could give you more data regarding the mechanism of the actual currency transactions, but as stated earlier, that was the hat and post of David Gaiman and I only entered the stats (inflows and outflows), and that is all that I can recall at this time. ---------------------------------------------------------------------- ------------------------------------------------------------------- ------------------------------------------------------------------- THE F.B.I. CASE 28. In Founding Church of Scientology of Washington, D.C.v. William H. Webster, Director of the Federal Bureau of Investiga- tion, 802 F. 2d 1448 (D.C. Cir. 1986)(hereinafter, "the F.B.I. casew~), the United States Court of Appeals for the D.C. Circuit affirmed the District Court' s July 1985 dismissal of the Founding ~ i,~.. ~ . ., ~, = ~!~ .l/. i? a Church' s complaint, on the grounds that L. Ron Hubbard, who had ~ li ~, ,~/ ~ ~ =,~, ~ ~ ~a 0" 8 failed to appear to be deposed, was ~e Founding Church's managing U~ ~ ~ agent. The D.C. Circuit's'opinion included ~e following: ~ ~ L. Ron H~bard resided from his official position ~ as Executive Director of Scientology Churches in 1966 * * *. The Gover~ent offered ~undant evidence in the District Court, however, ~at H~bard played a uni~ely prominent role wi~in Scientology and various affiliated j~C~ organizations from 1966 until ~e early 1980's. * * * ~ From evidence adduced below, H~bard appears to 7 have maintained control in a~inistrative matters ~rough high positions in such entities as ~e Sea Organization * * *. Indeed, uncontested declarations x before ~e District Court leave little dolt ~out either ~e ecclesiastical or a~inistrative dimensions ~ . - '~F ~ , of H~bard's authority during ~e period from 1966 ~ ~Jo~1982.-~ * * * [802 F. 2d at 1453.] ~ ~,~ ~undant evidence supports ~e proposition ~at ~ H~bard continued in his de facto position as head of ~ ~e Church. * * * [Ii. at 1454.] ~ * * * So far as we can discern, ~e record reveals no ,~ evidence that Hubbard intended to end his relationship /,;. wi~ Scientology, but only that he wanted, in his unfettered discretion, to determine whe~er and how to continue that relationship. Ultimate control, we have ,*, continued through 1984 not only as ~e potential leader ~ ~F o~ ~ ~~o~o~y o~=~o~ ~ ~ ~ ~~ ~' - leader. * * * [~. at 1456.] ~ W~ . - 33 - 29. Among the evidence relied on by the Court in the F.B.I. case (see 802 F. 2d at 1453) was an August 1984 declaration of Laurel Sullivan stating in part (AR Ex. 1-32; AR pages 1-292 to 1-301; Govt. App. 40-49): 10/ lO. At all times from 1967, to No~vemb~~e_r~2IL1981~ L. Ron Hubbard could and did assume direct and complete control over the major operations, management and administration of the church of Scientology and organizations related directly or indirectly to the Church * * *. At times this control was'directly exercised, and at times it was more relaxed and exercised through others but itexisted absolutely. Throughout this period of time, substantial sums of money, running in the millions of dollars, collected by instrumentalities of.the Church were directly controlled by L. Ron Hubbard, and funds were remitted directly for his personal use. 11. I am aware that, on numerous occasions, the Church of Scientology, and indeed L. Ron Hubbard himself, commonly stated in public that L. Ron Hubbard had resigned from conducting the management of all Scientology-related organizations and no longer influenced or controlled the management of these organizations. I participated in the preparation of such statements. These statements were wholly and completely untrue. * * * 16. In 1980 and 1981, I was assigned to lead the "Mission Corporate Category Sort-Out" project. The purpose of this project was to restructure all Church-related entities in a way that would make it clear that L. Ron Hubbard was not the alter ego of Scientology and in control of all Scientology organizations. The structure I was to establish was also intended to facilitate the fumeling of Scientology funds to L. Ron Hubbard to avoid impairing the tax-exempt status of the Church due to the distribution of Church funds for Mr. Hubbard's personal benefit. l_q/ Defendant points out that this proposed finding (like subsequent Findings 30-31 and 33-34) concerns only the fact that such testimony was given, not whether it was correct. - 34 - Another goal of this project was to insulate Mr. Hubbard ~ from legal process by creating the impression that ! Mr. Hubbard was no longer associated with the Church. !7. Numerous proposals for this restructuring were developed and discussed by high officials of the Church. Legal advice was also sought to ascertain whether the restructuring could be accomplished legally. The project dragged on for longer than necessary because of a disagreement I had with David Miscavige. I was unwilling to structure the Church in a fashion whereby L. Ron Hubbard could continue to assume control at any moment. I determined that for L. Ron Hubbard's own safety he should sever all controls. Miscavige insisted that L. Ron Hubbard be able to maintain control. /"!.-:i Therefore, Missio.n Corporate Category Sort-out was C-~'-~~ disbanded and Mary Sue Hubbard removed, and Terry Gamboa ~'/~ [see Finding 42, infra] and Norman Starkey hired new ~/~> lawyers on L. Ron Hubbard's instruction and they ., fashioned the structure in place ~o~day~ ú , , , , -~, ~ ,~ . ~/~ 19. I believe that L. Ron Hubbard is still in >~l j~;. control of the Church of Scientology based on reports ~u ~ that I have recently received from individuals still affiliated with the Church. * * * .... ~- - 35 - 30. Among the evidence relied on by the Court in the F.B.I. case (see 802 F. 2d at 1454) was an August 1984 declaration of Kima Douglas stating in part (AR Ex. 1-33; AR pages 1-303 to 1-308; Govt. App. 50-55): 5. I have been actively involved in a variety of matters relating to the various organizations which comprise the Church of Scientology. Regardless of its ~ ,/---"1 !~ .I.,,.-, legal or corporate structure, the Church is one entity, an umbrella which encompasses a number of organizations, among which is the Church of Scientology of California. , , , 6. As a result of my association with the Church ú of Scientology, I know that L. Ron Hubbard exercised almost complete control.over Church activities'during the period of my affiliation with the Church. In fact, the Church is considered and treated by its officials and members as one organization, notwithstanding the number of corporations and entities the Church has established to provide a contrary impression, and L. Ron Hubbard exercises complete control over the entire organization. * * * 31. Among the evidence relied on by the Court in the F.B.I. case (see 802 F. 2d at 1454) was a September 1984 declaratioa of Gerald Armstrong stating in part (AR Ex. 1-33; AR pages 1-310 to 1-315; Govt. App. 56-61): ~. 3. On or about September 28, 1980, a meeting was I~. held at the Cedars Complex at Los Angeles, California, '~ ~ r' ~/~,.~,~ ~ one of the corporate headquarters of the Church of Scientology of California (CSC). * * * Ms. Sullivan was then in charge of a special mission, called the "Mission Corporate Category Sort-Out" (MCCS). The purpose of MCCS was to restructure the Church of / Scientology and, by so doing, conceal L. Ron Hubbard's , ~ d/~,.~ control of the Church of Scientology and develop .~,~ /.I/~ _ strategies to effectuate actual control of SCientology ~i by Mr. Hubbard without his incurring legal ! responsibility for the activities of the Church of Scientology. Dick Sullivan, a junior executive of the MCCS mission, pursuant to orders, tape recorded the meeting. * * * 4. At the meeting, the following exchange took place relating to the corporate structure of the Church of Scientology and Mr. Hubbard's position within the structure. This exchange was tape recorded with the knowledge and assent of all present. L.S. [Laurel Sullivan] "There is no need for them to be the actual Board of Directors." C.P. [Charles Parselie] "* * * The only reason it's worked so long without that occurring is because everyone has effectively been bound by the authority of LRH and have ignored corporate lines." (Emphasis supplied) ú , ú , , 6. Mr. Hubbard received millions of dollars through a dummy corporation, Religious Research Foundation (R.R.F.), specifically set up to funnel money to him which should have been paid to CSC by foreign customers paying for "Flag" services. "Flag" is part of CSC. At a strategy meeting on September 29, 1980, held by several high ranking senior executives of the Church * * * It]he exchange was as follows: - 37 - CP: "* * * Fortunately for us, RRF wasn't incorporated until 1973 and we are now litigating 1972. So, I haven't really tried to sort this one out but it obviously is the classic case (loud laugh) of inurement, if not fraud" (Several laughs.) LS: "Well, put." Speaker Unidentified: "It's all privileged." DS: "The tape recorder is going here, Charles." , , ú ú , Re California Appeals Court ( 2rid appellate district, Division 3, case ~ Civ No.B 038975, Church of and Mary Sue .ubb,~ ú Scientolo~ ~ n~e is ~A~ MOORE. I was in the Sclento10gy c~lt fro/~ 19'~4. I was indoctrinated as a ceunsellor ( auditor ), Co~s~structor and Ethics Officer. I have Oeen actl~ely exposing cults since brewing away - I operate the CULT IN~TION ~R~CE in Calgary, assisting the punlie, business and goverment in the cult area. In Scientology I have witnessed not the pesitive, e~anelng er tae planned short and/or lemg tern growth efa person but the short a~ leag ~em delinerate planned destruction of individuals critical thl~iag, eojeotivlty, self esteem, f~ily life, relatiomships, financial and educational goals, ethical and moral sta~a~s. Ia s~ort their lives are totally sacrificed ~y Scientolo~ te bring money amd power to the Seientolo~ leadership. These vietin caret speak for themselves - they benore recruiters, promoters and defe~ers of Sciem~ology - They are pro~med ~ Srainwashed ) te act on written and verDal Scientolo~ orders sad te never question Scientole~, its leaders er any iastruetions. Scientology decexves and ~rainwashes tae public to trust t~em and be dependent en Scientelo~ policies, bulletins, newsletters, cassettes a~ videos for direction in their lives - They are promised a Detter life. T~e catch ~ere is - They are told to wait untill all the copses are ever before Judgi~ - To not tni~ snout it. What t~e victms are net told is t~at the courses never end, and this is hew the mind control ~ Brain washi~ ) works - t~ey are systematically made te surre~er their oOJectivlty, questioni~ and thi~ing" untill someday when they will see all that they hawe neen promised "The day ef copse newer comes SETTLEMENT AGREEMENT A. PRIOR SETTLEMENTS: Settlement agreements made prior to November 1, 1986 and prior to the collective settlement are stated below: Client Amount Fee and Expenses (1) Bears $115,000.00 To be determined w th local counsel (2) Garritys $175,000.00 To be determined with local counsel (3) Petersons $175,000.00 To be determined with local counsel (4) Jefferson $150,000.00 To be determined with local counsel i5) Lockwood $150,000.00 To be determined with local counsel (6) Hartwell $150,000.00 To be determined with local counsel $915,000.00 To be determined with local counsel B. INDEPENDENT SETTLEMENT: The Christofferson-Titchborne settlement was made separate from the collective settlement. It was agreed to between attorney Gary McMurray, his client, Julie Christofferson-Titchborne and the Church of Scientology. Client Amount Fee and Expenses Christofferson- $100,000.00 To be determined Titchborne by attorney McMurray and client. None of the attorneys representing other clients in the collective settle- ment represent or have represented Christofferson- Titchborne. C- COLLECTIVE SETTLEMENT: The following cases/clients are part of a collective settlement made on December 11, 1986. The undersigned acknowledge that the settlement set forth above in Paragraphs A and B were made as separate settlements, meaning that the cases/clients listed in Paragraphs A and B agreed to the amounts stated therein prior to the collective settlement as in Paragraph A, and independent from the collective settlement as in Paragraph B. The total amount of the collective settlement is $2,800,000.00. The total amount of the collective settlement and the prior independent settlements in Paragraphs A and B is $3,815,000.00. The collective settlement allocation is as follows: Client Amount Fee and Expenses ú ( 1 ) Nancy Dincalci $ 7,500.00 None ( 2 ) Kima Douglas $ 7,500.00 None (3) Robert Dardano $ 15,000.00 None (4) Warren Friske $ 15,000.00 None (5) William Franks $ 40,000.00 None (6) Laurel Sullivan $ 40,000.00 None (7) Edward Walters $100,000.00 To be determined between client and attorneys (8) Howard Schomer $200,000.00 To be determined between attorney Bunch and client (9) Martin Samuels $500,000.00 To be determined between attorney McMurray and client (10) Gerald Armstrong $800,000.00 To be determined v. Church of between attorney Scientology Bunch and client (11) Fees and expenses $500,000.00 To be determined to attorneys between attorneys Contos & Bunch, Contos & Bunch, ------------------------------------------------------------------- ------------------------------------------------------------------- Canadian prosecutor rejects ScientoJogy's offer to aid poor if criminal charges are dropped Ontario Attorney General Ian Scott has rejected an offer by the Church o[ Sdentology to donate up to $1 million to community agencies that work with the elderly and the poor if criminal charges against it are dropped. The offer may have been unprecedented in the histoe7 of Canadian criminal prosecutions. The church is cha~ged with several counts of theft of photocopies of confidential documents from Ontario Government offices by church members while some of them were working for government agencies. The documents all referred to the Church of Scientology. The charges resulted fxom the largest police raid in Canadian history. One hundred police officers seized approximately two million documents in a 20hour raid on the orgunization's Ontario headqutters in 1983. In addition to the church, 15 of its members were subsequendy charged with the theft of photocopied documents. Four have pleaded guilty and have received absolute or conditional discharges. The othen are awaidng trial. The chufch's offer did not insist that the charges against its members be dropped. A preliminary hearing into the charges against the church, begun in March, is to resume for two weeks in November and to condnue next February,. Despite the desire of mar, y community organizations for more money and voluntee= worken, several such organiza~ons that were contacted by The Globe and Mail newspaper of Om,~o were cool to the Scientologists' offer. A spokesman for 3essie's Centre for Teeangers, one group that was mentioned by the Church as a possible recipient of cash and volunteer workers, said, "Our clients are teenagers. We worried that they (the Scientologists) might try to p/oselytize," and decided to decline any offers from the Scientologists. The executive director of Foodshare, another group mentioned as a possible recipient, said, "If they hope to extricate themselves from a case by paying guilt money, we would not accept it." ------------------------------------------------------------------- ------------------------------------------------------------------- &m emmmm/'mm, aelMmulew lZ. LvW9 Scientology ordered to face theft;"'";"""' ;~ l fia~ I " By BILL DUNFHY , TernreSin (?Toronto Sun?) For the first time in Canada, a church has been ordered to stand trial on criminal charges Mr. JimIns WUUam Babe yesterday ordered is Church d ~elentology or Toronto to trial an seven theft counts and fmat eoents d bmch of tmsL Charges dismissed .=ded o, o.,,o'. '""-'-,, ...- Nine former Selentolo~r officials will also stand trial on similar crtmi- fro= .ll.ed activities of the church and eemin key offidais in the mid- to its 1970~.. They where laid after a massive Ontario Provincial Police raid on Setentology hudqurters in 19Sa. The marts' has been in and out of the coum ever since. At one point church officials wrote to Attorney General Ian ScotL offerLug .to donate millions 9f dollars to charity if he would drop the eharu~_ 'But yesterday, within minute of Babe ordering the church and former offlciala to stand Lrial, defence lawyer Clayton Ruby had filed applications to cluash the decision against Scienr~lollY on Igrmmds it was an Infringement of religious freedom. He also filed an application on behalf of the nine individual defendante asking the coum to stay pro- !ceedtngs~ them beeam of the ength o~ time bergen the laying of chaxles and the planned trial start. .. These applications ace due to be heard early in the new yesr. Earl Smith, _vast president of the T~-om efiurefi,. said Seientology had ~mt !~ milllira cu its dalenee and if allot gcee to trial mid have to pay eut another $1 millira. ú ,: Trjall dflte to be set Babe ordered the defendants to in "..t . t, t .J.,: :"' CIwsSdmld~.!mml. aemmek alyn leleb~mJm, aedamleeWhamv. ---------------------------------------------------------------------- -------------------------------------------------------------------