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The Church of Scientology ® of Boston

448 Beacon Street, Boston, Massachusetts 02115 Phone: 266-9500



Rev.Heber Jentzsch
(213) 666-5570

John Peterson, Attorney
(213) 659-9965

Donald Randolph
(213) 474-6020


July 24, 1984




          LOS ANGELES - Federal investigators are in possession of

documentation detailing a criminal conspiracy to loot the

personal estate of New York Times list best selling author

L. Ron Hubbard with a counterfeit $2 million dollar check that

was used in the sensationalized Riverside, Calif., probate case

in an aborted attempt to seize control of the legendary writer's

estate, according to papers filed in a Los Angeles federal

court by noted civil rights attorney Donald C. Randolph.


L. Ron Hubbard, Founder

President: Rev. Maureen Nagles * Vice President: David Aden * Secretary-Treasurer: Rev Phyllis Nuccio

Copyright (c) 1984 by the Church of Scientology of Boston, Inc., a non-profit organization. All rights reserved. Scientology is an applied religious philosophy. SCIENTOLOGY TM and DIANETICS TM are trademarks of the Religious Technology Center. The Dianetics Center is a part of the Church of Scientology of Boston.


July 24, 1984
Page 2

          According to documented eyewitness accounts, Boston

personal injury attorney Michael Flynn, long time critic of the

church, secretly hired a forger to pass a counterfeit $2

million check against Hubbard's account. Flynn then used his

own felony to initiate the sensationalized 1982 probate case

brought by Hubbard's estranged son Ronald E. DeWolf to argue

that the best selling author's estate was in jeopardy and should

be seized.

          The attempt failed, however, when the court threw Flynn's

case out and ordered DeWolf, a 50 year old Nevada apartment

house manager, to pay all costs. Flynn was found in contempt

of court during the proceeding for violating court instructions.


          To finance his attack, Flynn created Flynn Associates

Management Corporation (FAMCO) and tried to sell shares on the

promise that profit would be made by capturing Hubbard's estate

through a series of frivolous suits, by generating so much

"adverse publicity" against Scientology and Hubbard that the

church would be forced to settle for millions of dollars. The

forgery and probate scheme was but one part of Flynn's

conspiracy now in the hands of several federal agencies.

          According to the declaration filed in federal court,


July 24, 1984
Page 3

"portions of evidence, some recently uncovered" reveal the

"evil motivation" of FAMCO and its agents and the "common

criminals engaged in a vicious attack upon Freedom of Religion"

with "every conceivable type of misrepresentation and accusation."

          The plot was revealed by Randolph in papers filed in a suit

brought by Steve Miller against Flynn's brother Kevin and FAMCO

in Central District Court for violating the civil rights of

Scientologist Steve Miller of Los Angeles. Michael Flynn is

an officer and director of FAMCO.

          After gaining access to the Bank of New England where

Hubbard had an account, Flynn illegally obtained sample checks

and then hired Ala Tamimi, a known forger residing in Boston,

to counterfeit and forge a $2 million dollar check on Hubbard's

account at the Bank of New England in Boston.

          In a signed, fingerprinted and notarized declaration given

in Italy and witnessed by his attorney, now in the possession

of federal prosecutors,Ala Tamimi related how Flynn had

promised him $400,000 to pass the check and transfer the $2

million from the account of the legendary writer to an overseas

account that Flynn would later designate. Tamimi then used his

brother Akil to try and cash the forged check in New York.

          According to his own sworn statement, also in federal


July 24, 1984
Page 4

hands, Akil was very nervous during his visit to the bank,

failed to produce proper identification papers, and left the $2

million check at the bank saying he would return with proper

identification the following day.


          Flynn's plot was thwarted when Akil panicked and failed to

return. Meanwhile, Hubbard's business managers learned about

the check and quickly alerted the bank to stop payment. Ala

Tamimi fled the country while his brother Akil disappeared into

Maine with the help of one of Flynn's men, according to the filed


          Flynn later used his aborted plan to file the California

probate petition with DeWolf in 1982. Flynn tried to put the

blame for his felony on Scientologists and claimed that the

crime proved that Hubbard's estate should be seized by the court

in order to allegedly protect it from Scientologists.

          Church of Scientology attorney John Peterson stated that a

portion of the results of the international inquiry were made

available to Randolph and his client when Kevin Flynn had

attacked the church in the case.

          According to Peterson, the affidavits "are but one small


July 24, 1984
Page 5

part of the evidence collected. We have eyewitnesses,

documents and photographs that leave not one shred of doubt."

          The declaration was filed in response to an attempt by Flynn's

brother Kevin to halt a court-approved inquiry into the

financial transactions of FAMCO and Blossoms, a Washington, D.C.

restaurant owned by Kevin Flynn. Randolph stated in his

declaration that Kevin Flynn's motives in "seeking to prevent

discovery of his fraudulent and criminal activities" were

"transparent and understandable. He does not wish to have this

information discovered as it may well subject him to severe


          According to the filed declaration, Kevin Flynn had

illegally obtained a loan from the Small Business Administration

"with fraudulent misrepresentations and misleading information

designed to prevent the government agencies involved from obtaining

the truth" about the restaurant and his activities with Michael


$100,000 REWARD

          The investigation of the criminal conspiracy to loot

Hubbard's estate was initiated earlier this year with a series

of full page ads in a number of national newspapers including

The New York Times, The Boston Globe and The Wall Street Journal

offering a $100,000 reward for information about the


July 24, 1984
Page 6

forged check. Private investigators operating in four countries

finally uncovered Flynn's conspiracy.

          Flynn, an unknown personal injury attorney until he tapped

Hubbard's popularity, had earlier demanded that the church pay

him $1.6 million to stop suing the organization. When the

church refused to pay, Flynn, schemed, devised and carried out

the forgery plot and the probate petition to plunder Hubbard's


          Ala Tamimi's participation in the conspiracy was enlisted

by Boston lawyer Wayne Hollingsworth, who works with Flynn.

According to Tamimi's sworn declaration, Hollingsworth informed

him in April 1982 that Tamimi's other brother Amer had incurred

a $40,000 gambling debt to underworld figures in Boston several

weeks before, and had not paid anything.


          "The boys in town are very mad and they can break legs,"

Hollingsworth told Tamimi, according to the declaration.

          In return for his help, Tamimi was told, his brother's

debt would be cancelled, plus Tamimi stood to gain 20 percent

of a "deal" which Hollingsworth said would be worth $2 million


July 24, 1984
Page 7

or more.

          At a subsequent meeting, Hollingsworth introduced Tamimi

to Flynn, and Flynn, according to Tamimi's declaration,

described what would be needed for the $2 million check forgery

conspiracy to be successful.

          Two other men were present at the meeting, according to

the declaration, and Flynn took the opportunity to threaten


          According to Tamimi's declaration, Flynn warned that

Tamimi's family would be in grave danger if Tamimi did not

follow through with his end of the bargain.

          "Flynn's language was blunt," Peterson said, "According to

Tamimi's sworn declaration, Flynn told him, 'Do not f--k us because

you have a brother and son in Boston'."

          In describing the course of the intensive six month

inquiry, Peterson said church investigators traced the path of

the conspiracy through more than a dozen cities, from Boston

and New York to Clearwater, Florida, the Cayman Islands and

finally to Italy and Dubai and Sharjah in the United Arab

Emirates. "The documentation is explicit and complete," he

added. "We have corroborative witnesses and documents

including photographs that completely verify the criminal


July 24, 1984
Page 8


          The same Bank of New England is currently the center of

another $2 million forgery case where a contact inside the bank

made confidential information available to a disbarred Boston

area attorney who fraudulently purchased gems with the stolen

cash from a Chicago dealer.


          A breakthrough came when church investigators located Ala

Tamimi and his brother Akil overseas.

          After a number of visits with Ala Tamimi and his attorney,

the investigators obtained Tamimi's agreement to document his

involvement in the conspiracy. Because of his fears for the

safety and well-being of his family, and for his own life,

Peterson stated, "Tamimi protected himself." Peterson would not


          Peterson said the information obtained on the probate-

forgery conspiracy, FAMCO and Blossoms are "but a small

percentage of what we have unearthed."

          Church of Scientology attorney John Peterson stated that a

portion of the results of the international inquiry were made


July 24, 1984
Page 9

available to Randolph and his client when Kevin Flynn had

attacked the church in the case.

          "The entire check forgery, probate fraud and the broader

FAMCO scheme of which it is clearly a part, proves that Flynn

and his cronies, entirely motivated by greed, will stop at

nothing to create chaos for profit," Peterson said. "He is

a despicable criminal - the totally unprincipled lawyer

accusing others of his own crimes. He breaks the law and then

amorally tries to use it as false evidence in court to generate

sensationalized press to extort money. He is a disgrace to the

legal profession and should be disbarred."


          When asked if he expected Flynn to respond with a libel

suit, Peterson said, "Flynn would have to answer these charges

under oath. Give him this message: Go ahead, make my day."

          Peterson stated that the church is continuing its

investigation into "other crimes" uncovered during the two year





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