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Note: The Goodrich Suit Evaluation was written by L. Ron Hubbard. See Mike McClaughry's statement about it here: http://members.cox.net/batchild1/transcript/mike2.htm

On the hard copy we have, the initials "LRH" have been excised, and we have put them back in square brackets ([LRH]). Excising Hubbard's name, initials or references to him in cult documents was a common practice in Scientology, particularly after the 1977 FBI raid.

All other words, and all spelling, capitalization, abbreviations, punctuation and page order have been left as they are in the hard copy.

 
 

 

 
     
 

[CT 6335]

SECRET

6 June 73

The Goodrich Suit Evaluation

Policy: Evaluate situations before planning actions and
handling.

Investigate and thoroughly prepare all legal actions before
acting.

Thoroughly prepare legal actions; wins are proportional to
preparations.

SITUATION: Suit lodged against C. of S. for 500 million by
a Goodrich of San Francisco, including a Class Action.

DATA: A preliminary and a further surface study of the
case reveals long strings of omitted data and omitted prepara-
tions.

An evaluation was omitted, one that is correctly done.

The advices by Intelligence show gross omissions, even the
normal data surveys of individuals involved.

The plaintiff, his cohorts and attorneys are omitted totally
as targets in the legal planning.

A wrong target exists re books. This is also dropped out time.
Nothing that can be done to books now will help THIS suit.
1 to 4 of ltr 4 June 73 apply with realism to FUTURE suits but
would have little bearing on this suit.

The attorney planning, while excellent in itself, is not, how-
ever adjusted to THIS suit and applies to any such suit.
Omitted are compromising actions that would cause the suit to
be thrown out such as conspiracy, government instigation and
other factors. And these are omitted because routine intelli-
gence is omitted and because an evaluation has been omitted.

A gross planning error exists. It is assumed that the opposing
side is laying a groundwork to govt destruction of Scn, the
exact steps of how this COULD be done are laid out. There is
no factual evidence that this situation really exists, only
that the plaintiff may hope it could exist. The exact error
is, as a General, assuming (out of one's own specific knowledge)
that the enemy will make certain splendidly planned steps which
will lead him to inevitable victory whereas the enemy does not
have that knowledge, and may very well have entirely different
things in mind. Then to place all ones defense so as to repel
that hypothetical attack but not solidly meet the existing
attack can lead to a severe defeat. Dropped out time, wrong
sequence, wrong target.

Omitted is a bright idea that will undo all this and this again
is omitted because of very little (omitted) normal intelligence
like credit reports, familial relationships, past criminal
records, involvement with earlier fraudulent suits, possible
disbarments, sources of data, sources of finance.

[CT 6336]

-2-

G EVAL

Omitted by the plaintiff are actual plaintiffs if any.
False data is found in the early and scanty intelligence
reports; it is alleged govt agencies are in full cry
including foreign governments; yet as to agencies, "nobody
has answered yet" from these agencies.

"Somebody very big" is back of all this BUT their suit is
badly prepared by legal estimation and full of technical
faults. These are conflicting facts as a "very big" would
not be pushing a faulty filing or allowing one.

Omitted are any transcripts of SP org members or those in
other orgs who might have had to deal with Goodrich.

File A. is excellently summarised. By the evidence to hand
it is not being fully used, as it contains data in itself
which would successfully terminate this suit on its merits
and when well examined and USED removes danger from any
actual trial as the plaintiff severely injured his head
many times BEFORE processing and also fell from a motorcycle
and hurt his head in the earliest part of processing. But
more importantly he planned to destroy Scn on 25 August 69
for which record and a witness exist and yet refused refund
and continued on, thus proving his sole interest was to
destroy Scn.

Examining the complaint and the books quoted, the outpoints
are dropped out time and false reports, of which the dropped
time is also falsified.

The plaintiff signed two success stories available in record.

The wife Lois Goodrich shows extreme hostility and moves in
and out, back and forth, per Record A. She is a trifle
domineering, threatens with "Federal Marshals" and other
officials and is the source of this delusion that this is a
very wide case in which the govts are interested. These
show false as an outpoint type.

The plaintiff stayed around too long for the action to have
begun as a plot by outside interests. It is obviously a
plot by him. He is PTS type III and has both mother and
wife trouble.

As to receiving treatment, the record shows that he only
received a little Dianetics and a quick pass on the grades.
BUT SPENT MOST OF HIS TIME IN ORGS INVOLVED WITH TRYING TO
HANDLE HIS DOMESTIC LIFE AND DID NOT IN FACT RECEIVE FULL
HANDLING. He would not straighten himself out so he could
be audited. This is a point that can be made.

They refused refunds.

There must have been WAIVERS signed by both these people,
possibly several times, that they were not engaged in any-
thing but a religious activity. This is omitted from the
file and from planning. That they omit this though it must
be known to them is a falsification.

[CT 6337]

-3-

In actual fact all books used were 1950-51 and psycho-
somatic healing has not been part of any offering per-
mitted by the Church.

Omitted is any defense for [LRH], not an officer or director,
materials only for a term of good usage.

Falsified by the plaintiff is the corporate status, these
churches being different corporations. The plaintiff
having taken service from SIX organisations.

Omitted is the glaring fact that the plaintiff continuously
engaged in several other practices per File A and could not
be said to have suffered from one any more than the other.

The plaintiff falsified his first White Form, omitting the
fact which later emerged, that he had been pronounced
insane (probable) and incarcerated in an institution (certain)
at the age of 7, and (probable) has been in one at other times,
which fact is unknown. The plaintiff was hypnotised
apparently on several occasions long before coming to the
Church. The Church does not hypnotise so his complaint is
false.

Plaintiff said he was crippled by an "explosion in mid brain"
and alleges he could not work but when suspended at ASHO
worked for 7 months on a tanker.

These and other facts demonstrate that one is handling TWO
situations in this case. Thus the two separate evaluations
follow, based on above outpoints.

GO SITUATION EVAL G1

Policy: Fully evaluate all major situations.

SITUATION G1: The GO US is apprehensive about the Goodrich
suit and advocating measures which will not completely handle
with certainty, but which depend on technical legal expertise
- which they have and which they should employ and which they
are employing.

DATA: As above.

STATS: Very good legal stats.

OUTPOINT COUNT: The primary outpoint is omitted data.

This outpoint occurs over and over and over and appears in the
form of unutilised (omitted from use) data as well.

These outpoints in the majority occur in the area of Intelli-
gence.

WHY: Intelligence Bu head not providing sufficient information
even of a routine nature to permit legal to form solid reassur-
ing planning that will lead to an inevitable win.

[CT 6338]

-4-

SECONDARY WHY: GO US is miscalling "Evaluation" and is
doing brief off the cuff SITUATION-WHY-HANDLING write
ups which are not pure evaluation and do not use outpoint
counts or the Data Series in full.

IDEAL SCENE: US GO calm, confident and effective in all Bus.

HANDLING:

A. 1.

Continue the legal defence as it is proceeding
as it is technically sound in its legal
strategy and, considering that it is lacking
even elementary Intelligence data, is buying
enough delay to remedy lack of proper data
and evaluation.

____________________
LEGAL

 

B. 2.

Run out all ARC Breaks, then w/hs of
omission and commission on the head of
Intelligence. Handle any personal problems
that appear. Do this instantly.

 

 

C. 3.

Do the same for any other Intelligence
personnel.

____________________
STAFF AUDITOR

 

D. 4.

Promptly look over Intelligence and at
once remedy any reason for their organi-
zational troubles.

____________________
GO US

 

E. 5.

Get existing Int staff flat out at once
on the Goodrich case. Augment or handle
personnel/finance as needed so as not to
upset any other operation.

____________________
GO US

 

F. 6.

Produce any and all data needed for a
complete, sound, winning defence.

____________________
INT BU HEAD

 

G. 7.

Keep Legal continuously briefed.

____________________
INT BU HEAD

 

H. 8.

Method 4 and review all [LRH] data re
expertise in the Int Bu and as written for
them especially.

____________________
GO TRAINING
OFFICER.

 

I. 9.

Send an aide from Flag to instruct all US
GO personnel on the Data Series.

____________________

 

-----------------

[CT 6339]

-5-

GO SITUATION EVAL G2

Policy: Win a case on its merits.
Delay a case where the merits are indefinite or
until the merits can be firmly established.

SITUATION: A suit has been brought against the C. of S.
and several of its principals by a Robert Edmund Puthoff
Goodrich in the superior court of California, County of
San Francisco for personal "damages" and as a Class action,
alleging "fraud" in books and advertising and seeking to
blow up a common suit into an action far out of proportion
to its merits, but which constitutes a damaging thing only
if it is lost and makes a precedent.

DATA: See earlier summary.

STATS: Very good stats legally to date.

OUTPOINTS: The very numerous outpoints all add up to false
outpoints. Even where omitted data occurs it is omitted for
the purpose of falsification. This type of outpoint is
almost exclusive in the court except of course the wrong
target of suing C. of S.

WHY: Goodrich and his backers have entered upon a false
project from false backgrounds, are falsifying testimony and
records in the greedy hope of getting some cash.

SECONDARY WHY: Orgs being reasonable about PTS and refund
policy and the handling of psychotics.

IDEAL SCENE: Case fully evaluated and the evaluation being
pressed home effectively with an eventual win and useful
only to close up holes and as example in PR, restrain
further attacks.

HANDLING:

J. 1.

Legal to keep the opposition on the defensive
and to obtain needed time by means now in use
and as per current legal planning as contained
in 3 June 73 (d) Strategy, with this single
exception: Use Discovery along legal lines by
all means, but augment it with File A 2 June
73 Time Track and insist upon obtaining from
Int further data and utilise it. See G2-A.
Attached.

____________________
US LEGAL

 

K. 1A.

Strategy for defensive actions. See G2-AA.

____________________
LEGAL

 

L. 2.

If the case comes to a hearing or trial,
in addition to any other approach deemed
by Legal to be effective, use G2-B
attached.

____________________
US LEGAL

 

[CT 6340]

-6-

M. 3.

Lead as feasible the plaintiff or his
associates into making statement in sworn
deposition or under oath that can be shown
to be false. Develop such data from Int and
other records and lead them into asserting
a thing that can be proven false, then prove
it false and move for a charge of perjury.

____________________
US LEGAL

 

N. 4.

Work the case into a criminal type counter
charge by whatever means.

____________________
US LEGAL

 

O. 5.

Counter sue on the basis of G2-C or with
whatever other means turn up so as to make
an example.

____________________
US LEGAL

 

P. 6.

Work out a means of defense of [LRH ] in this
and utilise it, preferably to get an early
removal from being a defendant. See G2-6.

____________________
US LEGAL

 

Q. 7.

Rapidly institute Steps 1 to 3 of the letter
of M of 4 June 73 by B.

____________________
D/G US

 

R. 8.

Compose, with Legal assistance a disclaimer
that does not invalidate the work but
explains that the Church, while it is
perfectly at liberty to do so, does not
engage in psychosomatic handling or
accept persons for treatment of disease of
insanity and offers spiritual and religious
counseling and that the attainment of
betterment is at the responsibility of the
person himself; that the E-Meter does
nothing by itself but serves only as a guide
to ministers of the Church; that the author
was recounting only observations as a con-
sequence of his work and is not responsible
for any promises or misuse of these materials
etc; the import being that the person reads
these works as his own responsibility. The
purpose of this is to debar any slightest chance
of being charged, Church or author, with Fraud.
Design it handsomely like a book plate with
space for the persons name on it "This book
belongs to ____" at the bottom with
plenty of space for the name and the type
rather small.

____________________
D/G US

 

S. 9.

Get this pasted into all books inside the
front cover. All countries.

____________________
DG US
GO WW

[CT 6341]

-7-

T. 10.

Start the E-meter legal disclaimer with
"By itself, this meter does nothing. It
is solely for the guide of ministers of
the Church in Confessionals" then
continue with the court wording, the two
statements so placed that they appear to
have different origins but are read to-
gether even if not placed together.

____________________
DG US
GO WW

 

U. 11.

Complete and publish the religious bona
fides.

____________________
DG US (with
assistance).

 

V. 12.

Edit DMSMH, bringing it up to date,
adding a discussion of intervening years
and the role of the spirit. Reissue as a
"New Book", D + 24.

____________________
WRITER

W. 13.

Update the Garrison book and get it into
print.

____________________
GO WW

 

X. 14.

Work out a letter campaign to handle all
past neglected or hostile Scns.

____________________
GO WW

 

Y. 15.

Collect enormous numbers of existing
identity connected success stories and
select so as to cover actual stories and
as attainable in books and literature. Use
in court. Publish as "Success with Scn"
with statements by the editor. "We didn't
tell these people they could win" is the
motif.

____________________
DG US
Appointed
Team.

 

Z. 16.

Review these programs and add targets
that may be suggested or advised.

____________________

 

-----------------

[CT 6342]

-8-

TARGET 1 - G2-A

The keynote of these people is falsity. This will not apply
to just this suit. It will apply to their whole lives, past
and present.

BRIGHT IDEA ONE-A for this target: By obtaining a deposition
or interrogatory from LOIS GOODRICH or by other means utilise
her fixation on govt agencies and Lazaro's false claims of
Federal backing or his hopes from them, any connection between
Goodrich and the FDA ex-head, and any actual evidence to
either affirm or start rumors that this is a conspiracy,
prompted by others who are not shown as actual plaintiffs,
establish some illegal action by them, preferably theft of
records, breaking and entering, taps, espionage within the
orgs. Then use this with a blast of PR to "move for dismissal
at once". See Letter A,4 June 73, TLM.

A. (a)

Discover any connection between Goodrich and
his possible FDA namesake.

____________________

 

B. (b)

Attain much further data on the connections of
these people (i) credit rating (ii) past
involvements (iii) suing others (iv) govt
involvement (v) past criminal records (vi)
source of finance for the suit (vii) any
swindles as employee damages (viii) develop
a rounded picture of these people, their
finances and connections. Feed Legal the data
as fast as developed.

 

C. (c)

Explore how to effect Bright Idea One A above,
keeping in mind and USING at this stage the
false ideas being fed in by Lois G and
Lazarus and acting as if they were true and
you believed them (for now).

____________________
LEGAL BU

 

D. (d)

Do the submissions, interrogatory, deposition
steps necessary to develop and finally
explode the case.

____________________
LEGAL BU

BRIGHT IDEA G2-B: Goodrich has a mental hospital
record. Age of 7, also 1967, probably many more.
Use this to get him labeled as incompetent civilly
and not legally able to bring suit, or use it to
invalidate all testimony, and filings. See A, 2 June
73 Time Track.

 

E. (e)

Collect the records and evidence of the 7 year
old mental home, the 1967 NY hospital, the 18
Sept 69 visit to Samuel Scarlet, MD 490 Post
Street SFO, any other mental evidence, by legal
means. Get it to Legal.

____________________

[CT 6343]

-9-

Tgt 1 - G2AB continued.

AF. (f)

Obtain documents as listed below and give to
Legal.

____________________
DG US

 

AG. (g)

Compose the proper court submissions to move
for dismissal on the grounds that the plaintiff
is insane, that he falsified his application
for service well knowing the insane and electric
shocked case is not accepted for processing or
service in the Church and knew also that he would
be rejected if the fact became known. That his
conduct while in the Church was that of an insane
person (do not furnish his threat to wreck Scn
as this must be masked until possible trial).
And that the case should be dismissed because of
mental incompetence of the plaintiff who has no
grounds for suit. Infer this was reason for
discontinuance of service but only infer it.

____________________
LEGAL BU

(Documents needed, PL on the insane, sample of
waiver, WF. Not the waiver pc signed which is to
be reserved for any trial).

BRIGHT IDEA: G2-C: Build up a mounting record
of false utterances by the plaintiff, his wife,
any others so that the atmosphere of total
falsity can later be used in case of trial. Ask
questions in additional depositions and interro-
gatories that are leading so as to provoke false
answers which can later be shown to be false.

 

AH. (h)

Locate anything false or of pretense in the
Plaintiff's life or in that of his wife or
mother. Give to Legal.

____________________
INT BU.

 

AI. (i)

Work over all data to hand and see how it can
be used to provoke false answers in depositions,
etc. Use them.

____________________
LEGAL BU.

 

AJ. (j)

Carefully list any and all false answers or
statements made by the plaintiff or those
connected with him, with place and date,
particularly those given under oath but not
omitting those made to other persons for
eventual use, in case of trial.

____________________
LEGAL BU.

 

-----------------

[CT 6344]

-10-

G2-AA
TARGET 1A - DEFENSE ACTIONS.

It is too optimistic to suppose that the plaintiff will
not have smut and muck to throw at Scn, bringing up all
sorts of cases that have been on the outs, bringing up
chain lockers and handcuffs, bringing in psychiatrists
"expert testimony" and trying to make the press with shocking
revelations. He may even release things to the press before
they come to court in true Democratic fashion in the best
tradition of Fascist Germany.

Therefore, these actions should be anticipated.

They should be ruthlessly handled to GAIN ADVANTAGE IN PROVING
EVENTUAL PERJURY as well as any other legal motive.

But be assured, it is my experience, that these charges are
FALSE. Do NOT fall into the trap of believing orgs or
Scns do these things unprovoked when they are done at all.
Every investigation I have ever conducted (they are MANY) I
have found that these entheta utterances and charges against
orgs and people were FALSE, and even in the most grave ones,
there were fantastic provocations.

In this zone of DEFENSE is where Intelligence (Information)
and Legal must work fast and furious and hand in hand.

Aside from legal invalidative tech on such charges and setting
them aside on technical grounds, THE STANDARD AND ONLY WORKABLE
WAY OF HANDLING THIS MATERIAL IS BY WHAT IS CALLED "Dead
Agenting". This is defined as it is in the old Chinese book
of war: When an agent is found to be feeding the enemy false
information, the enemy kills him: hence, "dead agenting". In
our case it means this:

ASSUME AND PROVE THAT EVERY CHARGE BROUGHT IS FALSE AND GET
THE DOCUMENTS AND WITNESSES AND DEPOSITIONS AND PROVE IT SO.

This means that any charge or allegation made can only be
answered or handled after Intelligence has slashed out and
gotten the documents to the contrary or contrary facts are
demonstrated in or through witnesses.

AK 1.

Understand and use the above.

____________________
LEGAL BU.

 

AL. 2.

Understand and use the above.

____________________
INT BU.

 

AM. 3.

Ask for delays until the thing can be dead
agented.

____________________
LEGAL BU.

 

AN. 4.

Get the contrary evidence. DO NOT LET A
SINGLE ENTHETA CHARGE GO BY! DA IT!

____________________
INT BU.

 

-----------------

[CT 6345]

-11-

G2-6

TGT 6 Data: Suggested argument for an action that must
be done.

There is no valid reason for [LRH] to be continued as a
defendant in this suit. Petition to remove him must be
made.

The facts are plain. He has not been a director or officer
of any of these orgs since three years before Goodrich ever
came near one.

He had no knowledge of Goodrich, as a case.

The books in question were written by [LRH] 20 years and 19
years respectively before Goodrich came on the scene. They
were written for publication. The copyright date alleged by
Goodrich is false.

The books were written years before the Church was founded.

[LRH] has no control over the use of his books any more than
any author has.

He wrote none of the advertisements offered.

His sole role in this is that of a writer of books nearly
a quarter of a century ago. In all that time they, as books,
have never been challenged and have been read by many, many
people.

It is completely unconstitutional in the United States to
charge a writer for writing books and will not stand up in
any contest of law regardless of who sold or used the books.

The First Amendment guarantees freedom of speech and press.

Therefore his name should be struck from this suit as a
defendant.

If the plaintiff disagrees, then [LRH] will have to initiate
independent legal action against the plaintiff for libel and
slander on constitutional grounds as [LRH]cannot legally be
considered a party to this suit.

-----------------

[CT 6346]

-12-

TARGET 2 - G2-B

This person has no case if it ever comes to trial,
providing only that the hearings are extremely well pre-
pared and continued on an attack line.

NOTE THAT AT THE BEGINNING OF A CHAPTER OF DMSMH (page 169 ?)
it says people who have been damaged by psychiatry cannot be
helped or are difficult to help. THIS IS THE WIPE OUT OF
[LRH] FRAUDULENT CLAIMS as he works hard to bring in this very
book as his complaint.

Further he signed a waiver. Possibly several as he was in
six orgs. He was informed we did not treat the insane or
institutionalised yet hid this data. (See White Form). He
was there on false pretenses. He refused a refund.

Throughout his processing he had witholds and sweaty hands,
most likely, which gives a low tone arm. He is a "low TA"
case which means that he is easily directed or misdirected
and very easily overwhelmed and will react very badly to
badgering or anyone's refusal to accept what he says, which
is valuable in face to face interrogation as he will blow up
or collapse and will present a bad appearance. Carried in
the right fashion during cross examination his blow up could
be timed (by simple refusal to accept what he says and by
asking the same question doubting his answer) to coincide
with a point which would look like an admission of guilt
and would be interpreted by a judge or jury as such,
particularly if the interrogator remains very calm and pleasant:
he will give the appearance of mental instability and guilt
any time a cross examiner wishes.

 

AO. 1. He has a long history of head injuries. See 4
June 73 A or (a) "Headache List". See 2 June
73A Time Track, White Form, pre-Scn motorcycle
accident (1 Feb 69 WF). Although he complains
about this, it can be safely assumed, for legal
purposes, that this is a fake. The org decided
he was not for them, sent him to an MD apparently
as on 18 Sept 69 we see Dr. Clark and Dr.
Scarlet on the scene saying he had nothing
wrong with his head. (Actually this is probably
true, enough of a bet to permit a new medical
exam which would also appear negative as to
head. Actually he probably is diabetic which
gives headaches of mysterious origin and turn
on under stress, meaning these headaches took
years to build up under a bad diet or drugs or
alcohol abuse). For legal purposes, it can be
established, within the competence of an MD at
contemporary tech of medicine that there is
nothing wrong with his head. They won't think
of blood tests or secondary causes. HIS "HEAD
TROUBLES" existed BEFORE auditing, that can be
established; he was sent to a doctor to handle;
he was offered refunds and refused them and
forced himself back on the org; and is currently
faking that there is anything wrong with his head.
ALL THIS M U S T be EARLY ESTABLISHED IN ANY
TRIAL.

[CT 6347]

-13-

AT. 2.

He had constant troubles with his wife Lois and
is undoubtedly being forced into the suit as
her pawn. Women who interfere with husbands
auditing want husband bad off, old stable
datum. It can be established that his relation-
ships with wife were awful, that she constantly
interfered with his life (not his auditing as
this point must be repressed for later reasons).
Attribute his loss of income to his wife troubles
establishing that by keeping him under stress he
was unable to work. That cares for claims that
Scn prevented him from working. Actually he would
really never get his life in shape to get audited
and received very little actual auditing. Make
the WIFE the villain for his income losses.

 

AQ. 3.

He is guilty not only of earlier practices but
contacts with other practices during his time of
bothering orgs. See 2 June 73 Time Track and
records concerning these. It can easily be estab-
lished by cross examination that he was concurrently
engaged in other practices while he was badgering
orgs. Thus any condition he has can as easily be
attributed to engaging in other practices as to
Scn. Dale Carnegie, medicine, hypnotism with
dentistry, neurology exist; you can be certain
others also existed. Yet he seems to be fixated
on blaming Scn. THIS POINT MUST BE ESTABLISHED
FOR THE WHAMO.

 

AR. 4.

He wrote two or more success stories in which he
stated he did have gains. These can be dug up and
presented. This is done to establish further his
falsity. He will say they didn't last. Infer that
this was his own irregular life.

 

AS. 5.

Now comes the piece de resistance that wins the
fraud case. Locate the section in DMSMH the
disclaimer as to the mentally ill. Locate the
PLs that forbid treating the insane or the
physically ill, locate the WFs which omitted his
psychiatric history. Present these as exhibits.
Unearth the full record of his earlier falsities.
Establish that he was fully aware that he was the
victim of psychiatry. Establish that he had read
DMSMH. Introduce waivers he signed foregoing
physical treatment. Establish that he actually knew
the subject excluded him in the claims and that he
falsified his attestation. Apply this to any other
plaintiff. Establish by an exhibit of tons of
success stories that it does work. Note that the
Handbook claimed only for 88% of cases. That the
Church does not use Dianetic claims per waiver.
Establish that he refused refunds and that refunds
were given his wife. Make the easily made point
that he forced himself on six churches, was
advised there was need to straighten out his life
before he could be helped but did not admit to him
he was classified under the insanity policy. Have
the claims re fraud dismissed. And the suit.

 

[CT 6348]

AT. 6.

Now the piece de resistance the Class suit if
it still hangs on. It is "On behalf of others
similarly situated". This would include only
those persons with a history of insanity who
hid the fact and badgered the Church for
service. All these people are weeded out when
found, as per policy. And by waivers they sign
and policies they are shown. If there is such
a class any claim they have is as illegal as
Goodrich's. Augment this as necessary. Have
the class portion of the suit dismissed. And
the suit.

 

AU. 7.

Here is the final whamo. Should the priest peni-
tent priviledge be waived, the session of 25
August 69 shows that, or can be made to show that,
he PLANNED TO DESTROY THE ORG AND SCIENTOLOGY AND
ONLY REMAINED IN IT TO DO SO for three years.
The person who audited him can so testify. The
report can be entered as an exhibit. That he is
lying to the court and to others and that his
wife and co-plaintiffs are engaged in inciting
action against Scn and by the Class Action itself,
he is carrying out his plan. When this is done,
his falsity has been established in earlier
instances, his equivocations will be exposed, the
full record of falseness should be entered as an
exhibit, between now and the future time of this
hearing there might be further threats of violence
or action against the Church, these can be brought
up as incited by Goodrich and his accomplices.
That he is insanely bent on destruction and is a
menace to society. Any instances of his efforts
to destroy ships or people covertly that have been
found can be included. The whole case should be
dismissed and the suit. And damages awarded the
defendant as well as all costs.

 

AV. 8.

Should for any reason the trial fail to dismiss,
introduce First Amendment considerations as were
originally planned for the trial strategy.

 

AW. 9.

If the First Amendment plan fails, appeal to a
higher court, as there would have had to have
been gross technical misbehavior on the part of
any judge who failed to dismiss this at one stage
or another. BE SURE TO KEEP A RUNNING RECORD OF
SUCH TECHNICAL FLAWS ON THE PART OF THE COURT OR
PLAINTIFF IN CASE IT IS NECESSARY TO APPEAL.

 

AX. 10.

Retry the case in the higher state court fully.

 

AY. 11.

If the state court fails, on the basis of the fact
that the Plaintiff alleges complaints against five
different organisations one of which is in another
state, and as it raises Constitutional issues and was
mis-tried, take it to the lowest Federal Court
nearby.

 

[CT 6349]

-15-

AZ. 12.

If for any reason the matter fails in that court,
by continuing record of technical flaws, take it
to a high Federal Court. By this time you could
be trying the legality of Class Actions themselves
as, unlike others, we cannot settle out of court,
and few if any Class actions actually have come to
trial. Thus it will be possible to go higher.

(In the meantime, there is hope that Class Actions
may have become illegal and that this suit has
been brought as a Class Action in the first place
destroys it utterly. But don't count on it.)

 

BA.

Constant alertness must be kept at all stages of this
suit for perjury. This is the key to it. You will find
that (a) THEY DO NOT KNOW WHAT YOU KNOW OR HAVE RECORDS
OF. (b) Their strategy will not be perfect and the
general strategy of attack envisioned at first probably
won't materialise but other odd ball things will. (c)
Their first perjuries should be let pass as they will
be small. This will embolden them. (d) As soon as
you have several small ones and a reliable big one,
MOVE TO CHARGE FOR PERJURY and dispose of the case by
using the falsity of the plaintiffs against them in this
fashion.

 

BB.

The moment you have a dismissal, work then not just for
costs but for some uproar so that you have PR in the
win. Do something freakish as soon as the dismissal
is sound, such as some extravagant demands such as (a)
move for arrest of all persons connected with the
plaintiff (b) put in an outrageous cost figure (c) put
in a one billion dollar damages claim against all members
of the class who supported him, thus seeking to create a
precedent that makes a class suit filing dangerous (d)
include in the damage demands any govt dept or agency
you have any trace of in the case (e) give an amnesty
to any news agency that was carrying anti Scn press
on it in such a way as to give them a shock of relief,
but in return for the favourable win. This is PR
BU ____________________ The rest of this tgt is LEGAL.

 

BC.

Review the whole case to establish any line of attacks
or patterns revealed by this suit and act to cancel
them as effective lines. See burning the folders hard
news stories at SH in late 60s.

____________________
DG US

 

BD.

Develop and invent into hard news blockers or
cancellers or invalidators of such lines of attack.

____________________
DG US

 

BE.

CAUTION ON TRIAL. Do not let the plaintiff derange
your line of attack. Handle his efforts and always come
back to the next stage of yours.

 

BF. Do not expose any of this planning in any way or
data connected with the trial strategy until the
actual trial, if any.

 

END OF EVALUATION.

[CT 6350]

-16-

8 June 73

The Goodrich Suit Evaluation
(Addition 1).

Page 5.

PP.

Add 1B: as already mentioned in strategy, make the
suit as expense as possible for them. But to this
include, as inexpensive as possible for us so its
expense does not unduly absorb funds and thus
curtail other needful actions elsewhere. One of the
ways of making it expensive for them is used abroad
and may be worked out for the US: i.e. the financial
competence and financial responsibility of the
plaintiff is continuously challenged such as on the
grounds of being transient, or often shifting jobs
or heavily in debt, thus making recovery of damages
for the expense he is causing impossible; this leads
to examination of his finances for the suit for one
thing; but abroad bond after bond can be demanded,
demurrers can be filed to taking depositions required
of one on the grounds of expense and new challenges
of financial responsibility can be made every time with
new bonds. The plaintiff is the one causing the
trouble and he is NOT financially responsible at all.
The attorney's source of funds can thus be traced.
Changes of venue can be re-pleaded at every pretext and
also on these grounds of financial burden. In each
such filing one drives home the irresponsible falsity
and the insane character of the plaintiff, questioning
any legal rights at all and repeating this was the
reason the Church refused him service. Work out other
ways of causing them expense. And in one or more of
these discover an already existing improper use of
funds or malfeasance in the plaintiff's or Lazarus'
methods of obtaining funds such as false promises to
other claimants. Steer it into a financial crime case
as feasible.

____________________
LEGAL BU

 

PQ.

Add 1 C Intel (Information Bu) to obtain legally
information as to how funds are being contributed
and to find the evidence that the suit, in fact, is
just a means of shaking down other claimants, a sort
of side swindle by the plaintiff and attorney.

____________________
INT BU

 

PR.

Add 1 D There is some possibility that Lois
Goodrich and Lazarus would get rid of Goodrich.
The pair may have something going and plan some-
thing about Goodrich whereupon his demise is used
to prove he had been harmed. There is something
wrong in that set up. Find it. Legally.

____________________
INT BU

[CT 6351]

-17-


Page 6 & Page 9B.


Target 6 and its suggested Data. REVISION.

If in legal opinion this will open the door to putting
[LRH] too solidly into the case, use this only if the
plaintiff brings it up, or lead in to get a removal only
when the plaintiff says clearly that it is only about
books that [LRH]is named as one of the defendants. If
the plaintiff could be led to state that, then a possible
move for removal could be attempted.

-----------------

 
 

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