IN THE HIGH COURT OF JUSTICE
CHURCH OF SCIENTOLOGY OF CALIFORNIA
- and -
(1) RUSSELL MILLER
(2) PENGUIN BOOKS LIMITED
OF KENNETH DAVID LONG
California 90027, United States, an executive employed in the
Legal Division of the Church of Scientology of California,
MAKE OATH and say as follows:
eleven years, and employed by the Church of Scientology of
California (hereinafter the "Church") for the past seven
years. The Church is a non-profit making religious
corporation registered in California since 1954. My duties for
the past five years have required that I work closely with and
assist Church counsel in all phases of litigation in the
upcoming book entitled "Bare-Faced Messiah," a purported
biography of Scientology founder, L. Ron Hubbard.
biography of Mr. Hubbard appear to be Jonathan Caven-Atack and
Gerald Armstrong. As demonstrated in my First and Second
Affidavits of October 5, 1987, Mr. Miller's and Mr.
Caven-Atack's claims that they obtained documents concerning
Mr. Hubbard and the Church from public sources, including the
Los Angeles Superior Court, are overwhelmingly false. In an
unsworn affidavit, Mr. Caven-Atack seeks to distract this
Court from his obvious contempt and violation of United States
court orders by a parade of irrelevant, disjointed and
conclusory diatribe, including accusations of criminal
activity. This is indeed an interesting turn.
the Church of Scientology as a parishioner, had a record of
drug use and drug pushing, including two convictions for
possession of drugs. In fact, Mr.Caven-Atack credited the
religious counseling procedures of Scientology with assisting
him in kicking his drug habit, during the time he was a member
of the religion. There is now produced and shown to me marked
"KDL 31" a petition written by Mr. Caven-Atack. In said
petition, he requested to be allowed to become an employee of
the Church of Scientology in Manchester, England, and details
his involvement with drugs. Due to the policy of the Church
whereby an individual with a criminal background is not
allowed to work as a member of Church staff, Mr. Caven-Atack
was denied employment by the Church, although he was not
denied membership in the Church nor its help in keeping him
in the Church. Thereafter, in late 1983, there was a theft of
sacred and confidential Church scriptures from a Church of
Scientology in Copenhagen, Denmark, by three British citizens
-- Ron Lawley, Robin Scott and Morag Bellmaine. Mr. Scott was
subsequentily arrested for the theft and convicted in Denmark.
There is now produced and shown to me marked "KDL 32" a copy
of the English High Court order enjoining the possession, use
and distribution of the stolen Church scriptures.
materials from Ron Lawley, made himself a copy of the
materials, and sent them to Larry West, a citizen of
California, U.S.A. There is now produced and shown to me
marked "KDL 33," excerpts from the transcript of the oral
testimony of Martin Ruston, taken in the United States, which
describe the part Mr. Caven-Atack played in the illicit
distribution of the scriptures stolen from the Church in
violation of the English court order.
would maliciously and deliberately engage in all manner of
irrelevant and highly prejudicial mud-throwing at the Church
of Scientology, given his own documented background as a drug
pusher, purveyor of the Church's stolen and confidential
religious scriptures and, as set forth in my First and Second
Affidavits, possessor of other documents belonging to the
religion's founder in violation of United States court orders.
Given the discreditable background and dubious motives of Mr.
Caven-Atack as regards a Church which opposes the use of
drugs, opposes crime, and which extended to Mr. Caven-Atack
its help regardless of his past transgressions, it is obvious
to me that the evidence he gives should be recognized for what
it is and disregarded.
provocateur of the U.S. Federal Government who planned to
plant forged documents in Church files which would then be
"found" by Federal officials in subsequent investigation as
evidence of criminal activity.
of these biographical documents were obtained by Mr.
Caven-Atack and Mr. Miller in violation of court sealing
orders. As such, the allegation of "unclean hands" in
contexts entirely unrelated to the facts at issue here has as
its only purpose to distract and inflame this Court into
denying the relief which the Church is seeking.
This document in pdf format.