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Faneuil Hall Office
One Faneuil Hall Marketplace

Law Offices of
MICHAEL J. FLYNN
Twelve Union Wharf
Boston, Massachusetts 02109
Telephone
(617) 523-1644

 

 

 

January 24, 1984

Sherman Lenske, Esquire
Lenske, Lenske, Heller & Magasin
Woodland West Building, Suite 315
6400 Canoga Avenue
Woodland Hills, CA 91367

John Peterson, Esquire
4676 Admiralty Way
Marina del Rey, CA 90291

Eugene M. Ingram, Private Investigator
Ingram Investigations
1212 North Vermont Avenue
Los Angeles, CA 90029

Dear Sirs:

           You are hereby placed on notice that Eugene
Ingram, expressly acting as the agent of L. Ron Hubbard,
Sherman Lenske and John Peterson, has made the following
statements to at least 10 individuals.  Several of the
statements were made recently to reporters for the Boston
Globe
and the Boston Herald for the purpose of publication:

(1) Michael Flynn and Kevin Flynn were "involved
in" or "participated in" the forgery of a two
million dollar check belonging to L. Ron Hubbard;

(2) Michael Flynn and/or Kevin Flynn were involved
in the theft of checks belonging to L. Ron
Hubbard; and Kevin Flynn was seen in the check
processing department of the Bank of New England
where said checks were maintained;

(3) Eugene Ingram is part of an "official investi-
gation" by the "F.B.I." and the "Treasury Depart-
ment" and that he is "working with" those offical
agencies. Ingram made the foregoing statements

Sherman Lenske, Esquire
John Peterson, Esquire
Eugene M. Ingram, Private Investigator
January 24, 1984
Page 2

for the purpose of obtaining information from
numerous individuals;

(4) Michael Flynn is the "target" and/or "focus"
of an investigation by the F.B.I. and the
Treasury Department;

(5) Michael Flynn has been selling shares in Flynn
Associates Management Corporation for the pur-
pose of illegally acquiring funds to deprogram
people and to "attack" the Church of Scientology;

(6) Michael Flynn has been receiving money "skimmed
off" the profits of a restaurant corporation
which is financing litigation against the Church
of Scientology.

          Each and every one of the foregoing statements
constitutes libel and slander, are totally false, and have
been made by Ingram solely for the malicious purpose of
destroying the reputation of Michael Flynn.

          On Monday, January 23, 1984, Ingram, on behalf
of Hubbard, Lenske and Peterson placed a full-page ad in the
Boston Globe for the purpose of soliciting telephone calls,
generating publicity, and disseminating the libelous state-
ments made in the foregoing numbered paragraphs. Further,
the combination of placing the ad in the newspaper for the
purposes stated together with the libelous statements of
Ingram constitutes a conspiracy to "frame" and/or implicate
Michael Flynn and Kevin Flynn in the commission of a crime.

          Finally, Ingram, Lenske, Peterson and Hubbard are
fully cognizant of the fact that the forgery of L. Ron Hub-
bard's check which is the alleged purpose of Ingram's in-
vestigation, was done by high-ranking members of the Church
of Scientology in May-June 1982 immediately after Lenske
prepared a will and trust for Hubbard; and Lenske, David
Miscavige, Lyman Spurlock, and James Issacson assumed control
over all of the financial affairs of L. Ron Hubbard.

Sherman Lenske, Esquire
John Peterson, Esquire
Eugene M. Ingram, Private Investigator

          You are hereby notified to do the following:

(a) Retract forthwith any and all statements and/or
innuendo set forth in paragraphs (1) through
(6) hereof by writing to each and every person to
whom the statements have been made;

(b) desist from all further harassment of Michael J.
Flynn and Kevin Flynn;

(c) desist from soliciting information from indivi-
duals responding to the ad placed in the Boston
Globe
on the basis that Michael J. Flynn is the
"suspect" in the foregery of Hubbard's check
or the "target" of an "official" investigation.

          Your failure to comply with each of the items
requested will result in full invocation of all available
remedies under civil and criminal law.

Sincerely,
[signed]
Michael J. Flynn

MJF/let
Enclosure
cc: The Honorable Joseph L. Tauro
The Honorable David Nelson
The Honorable Thomas Morse
The Honorable W. Arthur Garrity
Boston Office - Federal Bureau of Investigation
New York Office - Federal Bureau of Investigation
Bank of New England
The Boston Globe
The Boston Herald
Suffolk County District Attorney
Harvey Silverglate, Esquire

 

 
 

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