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County of Hillsborough

)  ss.



Before me, the undersigned authority, personally appeared

LaVenda (Van Schaick) Dukoff who, upon being duly sworn,

deposes and says:

1. I reside in Tampa, Florida. I am executing this

affidavit voluntarily and of my own free will. The statements

herein are made of my own personal knowledge and, if called

as a witness, I can and will testify competently thereto.

2. In or about June, 1979, attorney Michael J. Flynn of

Boston, Massachusetts was retained as my attorney. He was

retained to secure for me a refund of monies I had paid to the

Church of Scientology. This resulted in the filing, on or

about December 13, 1979, of a suit on my behalf seeking

$200,000,000.00 in damages; LaVenda Van Schaick v. Church

of Scientolgy of California, et al., U.S.D.C. Mass. Civil

Action No. 79-2491-G. This suit was subsequently settled, on

the verge of trial, on or about June 10, 1985.

3. On July 4, 5, 6, and 7, 1982, my deposition was taken

in the Van Schaick case in Boston, in the law offices of

Silverglate, Gertner, Baker & Fine. (See cover pages to

deposition transcripts, attached hereto as Exhibit "A".)

4. On one of these four days, although I cannot now

recall specifically which date, I was given access by Mr.

Flynn to a number of documents being kept on the third floor


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of his law offices at 12 Union Wharf in Boston. These

documents were maintained in boxes, some of which had no tops

at all and others of which had tops sitting underneath the

box. The boxes were scattered around the third floor, and

were openly available to anyone with access to the office area.

5. On this occasion, Mr. Flynn pointed these documents

out to me. He stated that I would find them very interesting

due to my own case against the Church of Scientology and L.

Ron Hubbard, the Founder of the religion of Scientology. He

stated that the documents included information concerning

Mr. Hubbard's record as a Naval officer during World War II, Mr.

Hubbard's personal relationships with his wives and other

persons, personal writings by Mr. Hubbard, and information

concerning the death of Mr. Hubbard's son, Quentin Hubbard.

Also present with Mr. Flynn and myself in the office during

this conversation was Boston attorney David Banash.

6. Following Mr. Flynn's introduction of these documents,

and with his full knowledge and permission, I spent

approximately one and one half hours reviewing and making

xeroxed copies from these documents. I then took the copies

I made home with me, again with the full knowledge and

permission of Michael Flynn.

7. In or about February, 1984, I discussed one of the

documents I had obtained from Mr. Flynn's office with Warren

Friske, another former member of the Church of Scientology,

and learned that he, too, had seen this document.

8. On September 20, 1984, pursuant to an order in the

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Van Schaick case, I underwent a psychiatric examination in

Boston, Massachusetts. (See cover page to examination

transcript, attached hereto as Exhibit "B".) I had arrived in

Boston early the previous day, September 19th, and had gone to

Michael Flynn's office at 12 Union Wharf.

9. Upon entering Mr. Flynn's personal office on the

third floor, I noted the same documents I had seen in July,

1982 were still present. They were contained in approximately

twenty boxes, located in Michael Flynn's personal office and

in the office on the same floor which had previously been

occupied by his brother, Kevin Flynn. As before, the boxes

were without tops or had tops sitting underneath them, leaving

them in plain view. The boxes were labelled "Armstrong Case",

which I understood to refer to a case in Los Angeles involving

Gerald Armstrong.

10. On this occasion, Mr. Flynn stated to me that he had

obtained additional documents since my previous visit. He

told me that I should look at these newly obtained materials

since I had not seen them before. He also indicated three

particular boxes of these documents to me, and stated that

they contained financial records which he was still going

through. Mr. Flynn told me that he was working with the

Internal Revenue Service on those particular documents and

that he would rather that I did not look at them. He stated

that they were complicated and that I would not understand

them. He told me, though, that if I did look at them, to keep

them in the same order due to his ongoing work with them.

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11. I then spent approximately four and one half hours

reviewing and making xeroxed copies of these new documents. I

copied approximately 3,500 pages worth of documents. Mr.

Banash was again present for much of the time while I was

making these copies which I did, as was the case before, with

the full knowledge and permission of Michael Flynn. In fact, when

I completed my xeroxing, I placed these copies in three

suitcases that I had brought with me for my stay in Boston. At

the end of the day, around 5:00 p.m., Michael Flynn and David

Banash both assisted me in carrying my suitcases out to Mr.

Flynn's car. Both Mr. Flynn and Mr. Banash commented as to

how heavy my suitcases were, and I told them that they

included the copies of the documents which I had made that

day. Michael Flynn then drove me to my hotel and assisted me

                                                       into MY HOTEL [initials LVD]
in carrying my suitcases up to my room. When I returned to my

home following the psychiatric examination, I took these

copies with me.

12. Although the great majority of the documents which I

copied in Mr. Flynn's office were themselves xeroxed copies,

at least one particular and personal document pertaining to Mr.

Hubbard was an original document. It was handwritten on

parchment paper which, due to its age, was beginning to

crumble at the edges and was extremely difficult to copy.

13. I did not make any copies of the materials

contained in the three boxes specifically indicated to me by

Mr. Flynn, but I did review their contents. As he had stated,

they contained financial documents referring to transfers of

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funds between Church of Scientology organizations, bank

accounts in foreign countries, Hubbard Communications Office

book accounts, and six or seven cassette tape recordings. Also

contained in one of these boxes were several documents which

might have been transcriptions, and which I recall contained

the acronym "MCCS".

14. Within just a few days of my return home, David

Banash called me and asked me to return the copies that I had

made. He told me that the documents were sealed, and that I

should not have them. I decided not to return the documents,

and did not return them, because I knew something was wrong.

I had been given completely free access to these documents by

Michael Flynn, and it did not make sense to me that I would

have to return them. I felt that Mr. Banash was either

confused or was trying to hide the fact that either he or I

had these documents, and I was unsure what the best course

was for me to take. I felt that I would be safer to keep the

documents, and try to find out the facts, than to return them

at that time.

15. Within several weeks of my return home, in either

late September or early October, 1984, I mailed copies of one

of the documents I had obtained from Mr. Flynn's office to

Eddie Walters in Las Vegas, Nevada and to Scott Mayer in Los

Angeles, California. I also discussed this document with Janie

Peterson, who had not seen it. In addition, I also sent

copies of several others of these documents which I had

obtained from Michael Flynn's office to Eddie Walters.

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16. Several months later, in approximately December,

1984, Michael Flynn called me and also asked me to return the

copies I had made. Since I had made duplicate copies of the

documents when I had originally copied them in Mr. Flynn's

offices, I simply pulled out about 45-50 pages of such

duplicate copies and mailed these back to Mr. Flynn. I

continued to retain copies of these documents in my possession.

I did not return all of the copies that I had because I still

felt that something was wrong, and I had begun to believe that

he was only trying to hide the fact that he had these

materials and had given them to me. I did not want to be

involved in such a scheme, and I decided to keep the documents

until I could decide what to do with them.

17. In June, 1985, I went to Boston for the scheduled

trial of the Van Schaick case. While in Boston, I told

Michael Flynn that I still had copies of the documents that I

had made in his office, but he did not ask for their return.

My case was then settled, without going to trial, and I

returned home following a severe disagreement with Mr. Flynn

regarding his handling of this settlement.

18. Several months later, in August, 1985, Michael Flynn

called me and requested that I return to him all of the copies

that I had made of the documents. He told me that he had made

a mistake; that he should not have allowed me to have access

to the documents as they were under seal and he or I could go

to jail. I did not return any of my copies to Mr. Flynn as his

call confirmed for me that it was illegal for either of us to

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have these documents, and that he only wanted to cover up his

actions. I no longer trusted Michael Flynn and was frightened

that he might try to place all the blame on me if anything

went wrong. Mr. Flynn's call convinced me that I was going to

have to find my own solution to this problem in which he had

gotten me involved.

19. On or about June 2, 1986, I called Michael Flynn's

law offices. He was not present, so I spoke with Gerry

Armstrong. I told Mr. Armstrong that I had documents which I

had obtained from Mr. Flynn's offices, and I described some of

these documents to him. I told him of my intention, at that

time, to take these documents to representatives of the press.

Mr. Armstrong obviously recognized these documents as he

became very upset. He told me that exposure of the

dissemination of these documents would destroy his court case

against the Church of Scientology. Approximately twenty

minutes later Mr. Flynn called me. I then told Mr. Flynn that

he had better treat his other clients more fairly and

ethically than he had treated me, and told him that I was

taking these documents to representatives of the press. He

accused me of extortion, although I had not requested money or

anything else from him. He threatened to have me arrested by

the Florida State Attorney's Office. His threat was the final

proof to me that I had been right in believing that he would

attempt to shift the blame for his illegal actions to me.

20. I believe that the documents which I obtained from

Mr. Flynn 's office are personal documents which properly

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belong to the Church of Scientology. Based on the facts

recited above, I also believe that Michael J. Flynn has

involved me in a knowing and willful violation of the law

which could result in civil or criminal liability for me.

Although he was my attorney for much of the time period

related above, he deserted me and left me to determine for

myself what my potential civil and criminal liabilities might

be for the possession of these documents, and of having to

extricate myself from this position.

Sig Van Shaick, notary 06-09-1986




This document in .pdf format

See also:
Michael Flynn Declaration07-31- 1986
Armstrong Declaration 08-02-1986
Breckenridge Minute Order of 08-18-1986




Armstrong Note:

The signature of the person who notarized Ms. Dukoff's affidavit appears to be "B A Asay" of Largo, Florida.

Largo is in Pinellas Country, across Tampa Bay from Hillsborough County, where Ms. Dukoff lived, and where the affidavit was apparently signed.

A Brian Asay attended a number of the sessions of the omnibus hearing in McPherson v. Scientology in May 2002, but I have not made a conclusive connection between the notary and the person who attended the hearing.

Note that this affidavit begins with text that is almost identical to the text in her affidavit that the cult's CLameleon Op has on its site.

They are two different affidavits, however, executed the same day. It is a usual pattern for Scientology to obtain multiple declarations or affidavits executed the same day from people the cult has turned; e.g., Vicki and Rick Aznaran, Paulette Cooper, and here LaVenda Van Schaick.

The CLameleon Op's comment about me on its LaVenda affidavit page is riddled with typical Miscavige cult lies. Miscavige, of course, is behind the Van Schaick betrayal and lies, and also behind the CLameleon Op site. The Op's claim that the site is not approved or sanctioned by any Scientology cult organization is a necessary lie because it's the cult's own covert intelligence op.

-- GA




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