[CT 7966]

GENERAL REPORT ON SCIENTOLOGY — DECLARATION OF JONATHAN CAVEN-ATACK

I, Jonathan Caven-Atack, declare that I am over the age of 18 years. I am a citizen of and resident in the United
Kingdom. I have personal knowledge of the matters set forth herein, and if called upon as a witness I could
testify competently thereto. This declaration is supplemental to my declaration in support of Gerald Armstrong's
opposition to motions by the Church of Scientology International for summary adjudication.

Background and expertise

1. I was a member of the Church of Scientology from December 1974 to October 1983. During that time I
undertook the equivalent of 24 of the 27 available "levels" of Dianetic and Scientology "auditing" ("auditing" is
supposedly a form of counselling). I also completed eight courses related to "auditor" or counsellor training as
well as courses in recruitment and administration. As a part of my " indoctrination" (the word used by Hubbard
for training), I read more than 20 of Scientology founder L. Ron Hubbard's textbooks and listened to about 150
taped Hubbard lectures. I received "auditing" and " auditor" training at Scientology Missions or Churches in
Birmingham, Manchester and at the British headquarters at Saint Hill, near East Grinstead.

2. In January 1983, the Church of Scientology published a list of 611 people who had been "declared
Suppressive Persons" [JCA-1]. Shortly thereafter, I was informed that one of my employees had been similarly
"declared a Suppressive Person", and shown Scientology Policy Directive 28, "Suppressive Act - Dealing with a Declared Suppressive Person" [JCA-2]. This order forbids Scientologists any contact with any person " declared
Suppressive". This policy is known within Scientology as " disconnection". For six months, I wrote letters
questioning the "Suppressive Person declare" issued on my employee. During that time I made enquiries of the
Master at Arms, or Ethics Officer, at Saint Hill, of the Special Unit, of the International Justice Chief, of the
Executive Director International and ultimately of L. Ron Hubbard. The responses I received were evasive.

3. In September 1983, I decided to conduct my own investigation of the Church of Scientology. I was unwilling
to have my communication controlled and my freedom of association denied, and uneasy with the attitude of
Scientology's new management, who described themselves as " tough" and "ruthless" [JCA- 3], and unhappy at
the high price charged for Dianetic and Scientology services (" auditing", for example, had risen from #6 per hour
in 1978 to over #100 per hour) [JCA-4].

4. Since my resignation from the Church of Scientology, in October 1983, I have assembled a large
collection of Scientology and Hubbard related materials, and interviewed well over a hundred former
members, including a number of former Hubbard aides. I have also read thousands of pages of court
rulings, government enquiry reports, affidavits and sworn testimony relating to Hubbard and Scientology.
This research led to the publication, in 1990, of my book A Piece of Blue Sky, which is a history of
Hubbard and his organizations. This book has been cited as a principal source of reference in academic
papers by professor of sociology and history of religion Stephen Kent (" International Social Control by the
Church of Scientology", presented at the Society for the Scientific Study of Religion, November 1991)
[JCA-5] and by professor of neuropsychiatry Louis Jolyon West ("Psychiatry and Scientology", presented
as the "Distinguished Psychiatrist" lecture, American Psychiatric Association Annual Meeting, Washington
DC, 6 May 1992) [JCA-6].

5. I have been retained in connection with the preparation of many court actions in which consideration of
Scientology has arisen. In 1984, I assisted in assembling documents as evidence in a child custody case put
before Mr Justice Latey (" Re: Wards B & G"). In 1987, I provided documents and affidavits in the successful
defence of Russell Miller's biography of Hubbard, Bare-Faced Messiah, heard before Mr Justice Vinelott, in the
English High Court. I also prepared documents for the defence of Miller's book in the USA, Canada and
Australia. I have been consulted by litigants in the US, Canada, Brazil, Australia, Italy, Switzerland, Spain and

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[CT 7967]

the UK. In these cases, I have prepared documents, recommended relevant documents for discovery, and
contacted or recommended witnesses.

6. I was the principal researcher for Russell Miller's Bare-Faced Messiah, and was also consulted by Bent
Corydon for his L.Ron Hubbard: Messiah or Madman and by Stewart Lamont for his Religon Inc. I was the
principal researcher for the chapter on Scientology in Jean Ritchie's Secret World of Cults. I was also the
principal researcher for BBC Panorama and TVS programmes about Scientology (both broadcast in 1987). I
have been consulted by television and radio producers, and by journalists throughout the world.

L.Ron Hubbard's intent:

7. Scientology was devised by L.Ron Hubbard as a means of gaining authoritarian control over those deceived
into joining any of his many organizations. Hubbard cynically constructed a set of hypnotic techniques which
masquerade as therapy and create progressive psychological dependency upon the organizations of Scientology.
Hubbard also hid behind the pretence of religion.

8. I can give evidence regarding the techniques commonly employed by Scientology organizations to recruit
followers, to create and maintain their loyalty and to sell them courses, supposed counselling, Scientology films,
tapes, books and "Special Properties" (highly priced special editions of Hubbard works and Hubbard
memorabilia). Although I have no qualification in psychology or psychiatry, I have had contact with several
hundred former Scientologists in the last ten years, and feel able to estimate the effect of Scientology upon these
former members.

L.Ron Hubbard and the claims of Dianetics and Scientology

9. Despite possession of a massive archive of Hubbard's private papers, including numerous handwritten and
illustrated black magic rituals and accounts of Hubbard's extensive drug abuse [JCA-7], Scientology
management still deceive Scientologists by perpetuating Hubbard's fictitious claims about his life. Scientology
materials make many false claims, including the following: that Hubbard was a wounded and decorated war hero
[JCA-8], [JCA-9] he suffered from an ulcer [JCA-10], [JCA-11] and never saw combat [JCA-12] ; that Hubbard was a "nuclear physicist" [JCA-13] - he failed a short course in "atomic and molecular" physics which was part of the degree course he failed to complete [JCA-14]; that Hubbard had studied for five years as a teenager with holy men in India, China and Tibet [JCA-15], [JCA-16], [JCA-17] - he spent less than three weeks in China and did not visit India or Tibet [JCA-18], [JCA-19], [JCA-20]. These are a few of the many deceptions created by Hubbard and perpetuated by the cynical managers of Scientology. Gerald Armstrong and Vaughn and Stacey Young were formerly in charge of Scientology's immense "Hubbard Archive" and can testify to this deliberate deception.

10. After a chequered career as the author of adventure stories, Hubbard released his first supposed therapy text,
Dianetics: the Modern Science of Mental Health, in 1950 [JCA-21]. This book is still sold by the Church of
Scientology, which claims sales in the millions.

11. Dianetics was in fact a reworking of techniques abandoned by Freud, where traumatic memories are
supposedly re-experienced [JCA-22]. In the book Dianetics, Hubbard asserted that memories of physical pain or
unconsciousness ("engrams") are "the single and sole cause of aberration and psycho-somatic illness" (ibid,
p.68). Such buried traumata supposedly cause people to react to situations without conscious reflection and
constitute a "reactive mind".

12. Hubbard adopted Freud's notion that traumata form in "chains" and that it is necessary to find the earliest
traumatic memory on such a chain to relieve its symptoms. In Dianetics, Hubbard asserted that the earliest such
traumatic memories are birth and prenatal experiences.

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[CT 7968]

13. The book Dianetics describes a purported system of therapy which will supposedly release the individual
from compulsions, neuroses, repressions, psychoses, arthritis, bursitis, asthma, allergies, sinusitis, coronary
trouble, high blood pressure, the common cold, myopia, schizophrenia, manic depression, dipsomania (ibid,
pp.51-52, also p.92), visual and hearing deficiencies (ibid, pp.10-11), dermatitis, migraine, ulcers (ibid, p.92),
tuberculosis (ibid, p.93), morning sickness (ibid, p.156), conjunctivitis (ibid, p.126). Hubbard also wrote that his
techniques would bring about an individual with "complete recall of everything which has ever happened to him
or anything he has ever studied", who would be capable of performing a calculation which a "normal [person]
would do in half an hour, in ten or fifteen seconds" (ibid p.171). In later works, Hubbard also asserted that he
had found psychological cures for paralysis [JCA-23, p.9], blindness, cancer [JCA-24] and leukaemia [JCA-25], [JCA-26], and that his techniques had even be used to raise the dead [JCA-27, p.170].

14. In Dianetics: the Modern Science of Mental Health, Hubbard asserted that his techniques would work on
anyone not suffering from brain damage [JCA-21,p.17], and that the outcome of therapy would be a " Clear". A
Clear would be free from the disabilities, and possessed of the capabilities, listed in the foregoing paragraph. In
1971, in the Scientology publication "Advance!", the following claim was made: "A Clear has over 135 I.Q., a
vibrant personality, glowing health, good memory, amazing vitality, self- control, happiness and more. The most
valuable thing you can do for yourself, and for your family, friends and Mankind is attain the state of Clear. You
can achieve Clear - not in years but within months through the most advanced technology of the human spirit -
Scientology" [JCA-28]. A 1988 issue of "The Auditor", a Scientology magazine, asserts that "A Scientology
CLEAR has: Over 135 IQ, Creative imagination, Amazing vitality, Deep relaxation, Good memory, Strong will
power, Radiant health, Magnetic personality" [JCA-29]. Such claims are repeatedly made in literature produced
by the Church of Scientology. For instance, a 1991 issue of Scientology's "Celebrity" magazine states:
"Scientology auditing can help you - you can get - A higher IQ to handle your problems ... More energy to make
more money - Better health ... More years to live." [JCA-30]

15. In 1952, Hubbard incorporated notions of the spirit (or " thetan") and reincarnation into his system. He
asserted that we have all existed as spiritual beings for trillions of years (by the 1970s, he was talking of
quadrillions). In the 1950s, Hubbard coined the phrase "Operating Thetan", meaning a spirit capable of
"operating" separately from its human body (" exterior"). The goal of Scientologists is to be "exterior with full
perception". Hubbard defined "Operating Thetan" as the "ability to be at cause knowingly and at will over
thought, life, form, matter, energy, space and time, subjective and objective." [JCA-31]. Currently, eight
"Operating Thetan" levels are available to Scientologists, most of which consist of a form of exorcism, sold to
Scientologists for over 300 pounds per hour [JCA-32]. Scientologists come to believe that they are possessed by
thousands of spirits which can of course lead to mental illness.

16. Many of the fundamental ideas of Scientology can be found in the works of black magician Aleister Crowley.
Hubbard recommended Crowley books to his followers and called Crowley "my very good friend" [JCA-33]. As
with all other magical systems, Scientology seeks to stregthen the will of the individual so that the physical world
and other people can be controlled by intention alone. Scientologists believe that by undergoing Hubbard's
"processes" they will ultimately be able to order events through "postulates" or wishes. Hubbard promised
godlike powers to his followers.

The religious nature of Scientology

17. In a lecture given in 1952, Hubbard asserted: "In 1938 I codified certain axioms and phenomena into what I
called SCIENTOLOGY" [JCA-23, p. 8]. Factually, Hubbard had briefly lost control of Dianetics, so restyled his
ideas "Scientology" (He was probably unaware that the word was already in use, meaning "pseudoscientific
ideas"). In April 1953, Hubbard wrote to the head of the Hubbard Association of Scientologists, Helen O'Brien,
asking for her opinion on "the religion angle" [JCA-34]. In December 1953, Hubbard registered the Church of

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[CT 7969]

Scientology, and a parent body called the Church of American Science, in Camden, New Jersey [JCA-
35], [JCA-36], [JCA-37]. In February 1954,

Hubbard's associate, Burton Farber, incorporated the Church of Scientology of California [JCA-38]. Within a
few years all organizations affiliated to Hubbard had been restyled " Churches" of Scientology. These Churches
tithed 20 percent of their income to Hubbard's Church of American Science [JCA-35]. In March 1954, Hubbard
announced that graduate auditors "can be given any one of three or all of the following certificates: DOCTOR
OF SCIENTOLOGY, FREUDIAN PSYCHO-ANALYST, DOCTOR OF DIVINITY." [JCA-35].

18. Numerous claims have been made by Hubbard and his organizations for the religious nature of Scientology.
In 1954, Hubbard said: "a Scientologist has a better right to call himself a priest, a minister, a missionary, a
doctor of divinity, a faith healer or a preacher than any other man who bears the insignia of religion in the
Western world" [JCA-38]. In a Bulletin of 18 April 1967, Hubbard asserted that "Scientology is a religion by its
basic tenets, practice, historical background and by the definition of the word " religion" itself ... Scientology is ...
a Religious practice in that the Church of Scientology conducts basic services such as Sermons at Church
meetings, Christenings [sic - Scientology makes no claim to be a Christian Church], Weddings and Funerals."
[JCA-39]. In a Bulletin of 4 May 1972, Hubbard asserted "Dianetics is a science which applies to man, a living
organism; and Scientology is a religion." [JCA-40]. In the textbook What is Scientology?, first published in 1978,
Scientology is defined as "an applied religious philosophy" [JCA-17, p.3]. Most Scientology textbooks contain a
disclaimer such as the following "This book is part of the works of L. Ron Hubbard, who developed Scientology
applied religious philosophy and Dianetics spiritual healing technology." [JCA-41].

19. The Church of Scientology offers a "Minister's Course" to its members [JCA-42]. After two weeks of
training, Scientology ministers wear dog collars and the Scientology cross and conduct Sunday services,
weddings, naming ceremonies and funerals [JCA-43]. The Church of Scientology has in the past commissioned
religious experts such as E.G. Parrinder [JCA-44] and Frank Flinn [JCA-45] to prepare reports or give testimony
to the effect that Scientology is a bona fide religion. The booklet "The Corporations of Scientology" [JCA-46]
claims that "In the Scientology religion, the scriptures are all the spoken and written words of L. Ron Hubbard".
All Scientology organizations are licensed by the Religious Technology Center, a California based corporation,
and sign an agreement accepting that the Dianetics and Scientology teachings are " scripture" [JCA-47].
Hubbard's "scriptures" are incontrovertible: "It is hereafter firm Church policy that LRH [Hubbard] ISSUES
ARE TO BE LEFT INTACT AS ISSUED [emphasis in original]. No one except LRH can revise his issues."
[JCA-48]. Since Hubbard's death in 1986, his work has been written in stone.

20. The ambiguity of Scientology's religious claims is evident in a document which discusses the establishment
of a Scientology organization in Japan: "Even the point of whether we go religious or non- religious has to be
covered as it will determine whether the books mention the Church [of Scientology] or not and whether they have
Church symbols, etc." [JCA-49]

21. Scientology has been granted religious tax-exemption in Australia and the USA. However, in Regina v.
Segerdal, in July 1970, the then Master of the Rolls, Lord Denning ruled that Scientology is not a religion [JCA-
50].

22. Scientology is a proselytizing faith and all Scientologists are termed "Field Staff Members" and expected to
effect conversions. The methods of conversion are spelled out in the Hubbard memoranda reissued in the "Field
Staff Member Kit" [JCA- 51], in the "Registrar Drills" [JCA-52] and in "FSM Breakthrough - New FSM TRs -
Controlling a Conversation" [JCA-53]. I was extensively trained in recruiting at the Birmingham Mission of the
Church of Scientology, in 1975. The Field Staff Member is instructed to discover through questioning what is
"ruining" a person's life (termed "the ruin" by Hubbard) and to exploit any "fear of worsening". Having brought

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[CT 7970]

the individual face to face with their weakness, the Scientology Field Staff Member " brings to understanding"
- the understanding that Scientology can solve whatever problem is disclosed.

23. In a tape-recorded lecture Hubbard said the following: "all the social machinery people have actually breaks
down before direct intention. But the thing that causes difficulty in moving people along this line of methodology,
has a great deal to do with the invasion of privacy. I won't call it privacy because that dignifies it. You have to be
willing to invade privacy, very definitely ... If you have a hard time invading people's privacy, you'll have a hard
time 8-Cing [controlling - "8-C", literally "infinite control"] them into a chair in an HAS Co-audit unit [Hubbard
Apprentice Scientologist], first PE [Personal Efficiency Course], and so forth. Because you think they have rights. Nah [sic]! They don't have any rights! What do you mean? What do they have - what has rights? That
machinery? Those dramatizations? Those computing circuits? You mean those things have rights? Hah! Pish-
pash [sic] ... If you invade this guy's privacy that just walked in, believe me, he walks straight in." [JCA-54].

24. Hubbard asserted that every individual has a particular emotional level or " tone" [JCA-55], [JCA-56], and
during recruiting it is necessary to approximate the emotional condition of the would be recruit (Scientologists do
elaborate role-playing of emotional states, including the "Mood Training Routines"), so creating rapport. Using
emotional manipulation, the individual is reduced to a depressed condition where he or she will realize a
desperate "need of change" in his or her life [JCA-57].

25. Hubbard called non-Scientologists "wogs" [JCA-58] or "raw meat" [JCA-59] and said that non-members are
"dead" in the "head" [JCA-60] - in a hypnotic daze and therefore easily controllable. Non-Scientologists are held
to be in the grip of their "Reactive minds" and so incapable of logical decision. Consequently, Field Staff
Members are urged not to discuss the ideas of Scientology, but to play upon the emotional weaknesses of the
potential recruit [JCA-51], [JCA-61].

26. The most used method of recruitment in Scientology is the Oxford Capacity Analysis Personality Test or
"OCA" [JCA-62]. This derives from Scientology's "American Personality Analysis" of the early 1950s, which in
turn was constructed from existing tests devised by psychologists. The OCA has no connection with Oxford, let
alone Oxford University. The original test has long been outdated and was rewritten by individuals with no
background in psychology or personality testing. Further, it is made clear in internal literature that far from being
a "free" test, its function is solely to recruit people into Scientology [JCA-63] .

27. Hubbard openly employed "hard-selling" techniques [JCA-51], under "hard sell", [JCA-64]. Sales staff
undertake frequent (often daily) "hard-sell drilling". Scientology organizations use a printed manual called the
"Hard Sell Reference Pack". I frequently experienced the use of such techniques. For instance, on my first visit
to the British headquarters, at Saint Hill, in August 1975, I was taken to a staff recruiter at 11 p.m. and remained
with her until about 1 a.m. My refusal to join Scientology's paramilitary " Sea Organization", which entails a
"billion year" commitment (Scientologists believe in reincarnation), was met with progressively more stern
entreaties. I was shown a Hubbard memorandum, which I was assured was entirely secret, which asserted that
the third world war was imminent and that the Church of Scientology would be the only organization capable of
surviving this holocaust and governing the world beyond it. According to this memorandum, this was the real
purpose of the Sea Organization, despite Hubbard's published assertion that Scientology is " non-political". As a
last stab, the recruiter told me that anyone who refuses to join the Sea Organization is insane.

28. On one occasion, between June and August 1982, I spent thirteen hours being given a sales interview by
Scientologist Peter Buttery at my apartment in East Grinstead. In the same year, I was visited by the same
Scientology salesman who had brought Scientologist money-lender Lee Lawrence with him. They attempted to
persuade me to borrow #7,000. The assertion was made that after " upper level" Scientology counselling it would
be easy for me to recoup

5

[CT 7971]

the money and pay back the loan and the 30 percent per annum interest. Lawrence's loan applications had to be
approved by Scientology [JCA-65].

29. Scientology sales staff, or "registrars", rapidly form a picture of an individual's assets and borrowing
capacity. I have dealt with many individuals whose financial security was undermined by their involvement with
Scientology.

30. Scientologists are told that if they fail to undertake certain courses they will be "at risk" [JCA-66] . Ominous
warnings are often given to those who declare an intention to leave the Churches of Scientology [JCA-67].

31. Sophisticated sales techniques are aquired by Scientology registrars on the " Registrar Salesmanship Course"
[JCA-68], and through the application of material in the "Hard Sell Reference Pack" [JCA-64].Scientology
registrars spend long hours "drilling" these techniques and learning how to overcome resistance [JCA-52]. Such
drilling continues throughout the registrar's career, especially after a failure to sell.

32. Hubbard made many extravagant and unfounded claims for Scientology and these are often used by
registrars. For instance, in Flag Mission Order 375 Hubbard said: " Advanced Courses [in Scientology] are the
most valuable service on the planet. Life insurance, houses, cars, stocks, bonds, college savings, all are transitory
and impermanent ... There is nothing to compare with Advanced Courses. They are infinitely valuable and
transcend time itself." [JCA-69]. In a magazine article, Hubbard said: "For thousands of years men have sought
the state of complete spiritual freedom from the endless cycle of birth and death and have sought personal
immortality containing full awareness, memory and ability as a spirit independent of the flesh ... In Scientology
this state has been attained. It has been achieved not on a temporary basis, subject to relapse, but on a stable
plane of full awareness and ability, unqualified by accident or deterioration." [JCA-70].

33. The Scientology attitude towards new recruits is unequivocal. In a 1959 Bulletin, which is still circulated,
Hubbard said "NEVER let anyone simply walk out. Convince him he's loony if he doesn't gain on it [an auditing
procedure] because that's the truth" [JCA-71]. In a Policy Letter which is still a part of most Scientology courses,
Hubbard said: "When somebody enrols, consider he or she has joined up for the duration of the universe - never
permit an 'open-minded' approach ... If they enrolled, they're aboard, and if they're aboard, they're here on the
same terms as the rest of us - win or die in the attempt. Never let them be half-minded about being Scientologists
... When Mrs. Pattycake comes to us to be taught, turn that wandering doubt in her eye into a fixed, dedicated
glare ... The proper instruction attitude is '... We'd rather have you dead than incapable.'" [JCA-72]. In " Critics of
Scientology", Hubbard asserted "it is totally hopeless and fatal not to be a Scientologist." [JCA- 73].

34. In a lecture, still sold as part of a Scientology course, Hubbard said "But what kind of a government and
what kind of a weapon is really serious? Not a weapon that destroys mud. A weapon that destroys minds, that's
serious. Out of the body of knowledge which lies before you [i.e., Scientology] a sufficient technology is [sic -
exists?] to take over, seize and handle any government on the face of the Earth ... You can control men like you
would control robots with those techniques ... Contained in the knowable, workable portions before your eyes
there are methods of controlling human beings and thetans [spirits] which have never before been dreamed of in
this universe. Control mechanisms of such awesome and solid proportions that if the remedies were not so much
easier to apply, one would be appalled at the dangerousness to beingness [sic] that exists in Scientology ... This
universe has long been looking for new ways to make slaves. Well, we've got some new ways to make slaves
here." [JCA-74] . In private papers revealed to a California court in 1984, Hubbard said "Men are my slaves"
[JCA-75].

The hypnotic nature of Scientology

35. An analysis of Hubbard's early publications on Dianetics makes it clear that he had practised hypnosis since
his teens. He claimed vast experience as a hypnotist. Dianetics was a fusion of Freudian technique and "light

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[CT 7972]

trance" hypnosis. Hubbard also made it clear that aspects of his original Dianetic technique are hypnotic.
Although these practices were briefly suspended in the 1950s, they have been back in full use for more than a
decade in all of Scientology's many organizations. For example, in a 1950 lecture, Hubbard withdrew the system
of counting people into a state of "reverie" prior to a Dianetic session, " Sometimes people go into a hypnotic
trance by accident with this count system" [JCA-76]. In his 1951 book Science of Survival Hubbard said "When
an auditor finds his pre-clear unusually suggestive [sic], he should be very careful what he says to the pre-clear.
He may notice that a pre-clear after he closes his eyes will begin to flutter his eyelids. This is a symptom of the
very lightest level of hypnotic trance." [JCA-77] However, in the current " Book One" Dianetic procedure, the
auditor is to "Count slowly and soothingly from 1 to 7" until " the preclear's eyes close and you notice his eyelids
flicker" [JCA-78].

36. Hubbard said that Dianetics can be used to "play on another individual like a good organist plays on a
Wurlitzer ... Knowing by observation, the push buttons of another person - or, as in Political Dianetics, a society
- the organist can play whatever piece he likes at will." [JCA-79]

37. Recipients of Dianetic "processing" will tend to invent " memories" (for example, believing that they are
reliving birth and conception or "past lives" in extra-terrestrial societies), so causing False Memory Syndrome.
The techniques of Scientology exploit this collapse of distinction between memory and imagination to induce
euphoria and dependency. In "Training Routine Zero", a fundamental practice of Scientology, individuals are
expected to spend "some hours" sitting immobile and staring at another similarly immobile Scientologist [JCA-
80]. This leads to a hypnotic state in which the Scientologist hallucinates and experiences spatial distortion. In
the Scientology "process" "Opening Procedure by Duplication", the Scientology "auditor" commands the
recipient to walk between two tables, picking up the book on one and the bottle on the other and guessing their
weight and temperature. This procedure is received in two hour sessions, and as many as 18 sessions can be
administered over a few days. The procedure leads to spatial dissociation, which the Scientologist is told
indicates that he has left his human body although all of his perceptions are still channelled through it [JCA-81].

The Sea Organization

38. The Sea Organization, or Sea Org, was created by Hubbard in August 1967. According to promotional
literature, "The Sea Org is the only guarantee of the survival of Scientology technology on this planet. Without
the survival of Scientology technology, there is no hope for the survival of Man." [JCA-82].

39. Speaking of Sea Org members, Hubbard said "the whole value of a being is to his group and not to himself at
all..." [JCA-83].

40. Hubbard asserted that the Sea Org is "fabian", and redefined that word to mean "using stratagem and delay
to wear out an opponent" [JCA-84]. Hubbard wanted the Sea Org to be seen as "a determined but elusive and
sometimes frightening group". He also asserted that the Sea Org has " tough discipline", and that "Only those
members who are not used heavily aboard [ship] or on mission seem to go slack." [JCA-85].

41. The Sea Org is a paramilitary organization, in which members wear pseudo- naval uniform and hold pseudo-
naval ranks [JCA-86]. Members also wear the equivalent of campaign ribbons [JCA-87].Scientology teaches
reincarnation, and Sea Org members sign a contract for a billion years [JCA-88]. Elsewhere this is styled "a
pledge of eternal service". This text adds: "New Sea Org members undergo rigorous basic training ... Sea Org
members, having devoted their lives to their religion, work long hours for little pay and live a communal
existence" [JCA-89]. The recruit gives away certain rights by signing the Sea Org contract: "I ... fully and
without reservation, subscribe to the discipline, mores and conditions of this group and pledge to abide by them"
[JCA-88]. The Sea Org member is also expected to abide by the "Code of a Sea Org Member": "1. I promise to
uphold, forward and carry out Command Intention ... 5. I promise to uphold the fact that duty is the Sea Org

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[CT 7972]

Member's true motivation, which is the highest motivation there is ... 11. I promise to accept and fulfill to the
utmost of my ability the responsibilities entrusted to me whatever they may be and wherever they may carry me
in the line of duty ... 17. I promise through my actions to increase the power of the Sea Org and decrease the
power of any enemy." [JCA-90].

"Ethics"

42. In the mid-1960s, Hubbard began to experiment on his followers with "ethics penalties" - the use of
humiliating and degrading practices to enforce unthinking compliance with his orders. In the "Policy Letter",
"Awards and Penalties", Hubbard outlined "penalties" that staff members must suffer, prefacing his comments
with this statement "Does not apply to Sea Org which has its own, much worse." Under "Non-existence",
Hubbard wrote: "Must wear old clothes. May not bathe. Women must not wear make-up or have hair-do's. Men
may not shave. No lunch hour is given and such persons are expected not to leave the premises." [JCA-91]. In
the "Penalties for Lower Conditions", Hubbard ordered that staff in a certain "ethics condition" should be
subjected to "day and night confinement to org premises." [JCA-92]. This was reiterated in a subsequent "Policy
Letter" [JCA-93] . Speaking of his "ethics penalties", Hubbard asserted "one ex-Naval person, reading them
realized suddenly, 'you could kill a man with the penalties of non-existence, by work and no sleep.'" [JCA-94].

43. In 1968, Hubbard introduced the practice of "overboarding". A photograph of this practice was published in
Scientology's magazine "The Auditor", issue 41, with the caption: "Students are thrown overboard for gross out
tech and bequeathed to the deep!" [JCA-95]. Overboarding was used as a punishment for failure to comply
exactly with Hubbard's orders. At about the same time, the tank punishment - where individuals were put into
the bilge tanks and kept awake for 84 hours - and the chainlocker punishment - where individuals were put in the
dark, cramped, waterlogged, rat-infested and filthy chainlocker. Witnesses have said that even children were put
in the chainlocker at Hubbard's order.

The Rehabilitation Project Force

44. In 1973, Hubbard introduced the "Rehabilitation Project Force" ("RPF") [JCA-96]. Disobedient Sea Org
members have been assigned to the RPF from that time. The RPF replaced the "Rehabilitation Unit" [JCA-96]of
which Hubbard said "The unit is worked hard during the day on a rigorous schedule...". This unit had replaced
the "Mud Box Brigade" - "persons appointed to clean mud boxes, fuel lines, water lines, bilges, etc." [JCA-97].
Few of the internal memoranda which apply to the RPF are publicly available. All are relevant to litigation, as
they show the true character of Scientology and the inhuman pressures brought to bear upon Sea Org members.
The designations for RPF material are "Executive Directive 965 Flag 'RPF Reinstated'" and all additions and
"Flag Order 3434" and all additions (there are at least 56 memoranda in this series, numbered FO 3434-1 to FO
3434-56).

45. The RPF is virtually a labour and thought reform camp. Members are forbidden communication with any but
their "bosun" (the head of the RPF); they have to comply immediately with any order; they sleep even shorter
hours than other staff; they eat even poorer food than other staff (often rice, beans and porridge for weeks. For
some time in Florida, "RPFers" were fed left-over food) [JCA-98]; they sleep in "pig's berthing", i.e. without
beds [JCA-99], [JCA-100]; they do hard labour and menial tasks, including toilet and sewer cleaning; they are
rarely permitted time off; they receive one quarter of the already derisory pay of other staff [JCA-101]; and they
have to write down
detailed "confessions", which may be published by the organization [JCA-102], [JCA-103]. Finally, an RPF
sentence is open-ended and may last for as much as four years. Failure to comply leads to posting to the "RPFers
RPF", which according to witnesses has consisted of false imprisonment. False imprisonment or "isolation" is a
part of the "technology" of Scientology [JCA-104], [JCA-105]. There are hundreds of former members who
suffered the RPF.

8

[CT 7974]

Isolation watches

46. While aboard ship during the early 1970s, Hubbard introduced " isolation watches" where an individual is
forcibly confined after a "psychotic break" (a mental breakdown, usually caused by Scientology's hypnotic
procedures). Such people can be held for weeks under 24-hour guard [JCA-104], [JCA-105]. The procedure is
referred to as "babywatching" or "babysitting" in Scientology. In 1994, The Independent newspaper in Britain
published an account of "babywatching" [JCA-106]. HCO Ethics Order 2543 of 28 September 1993, concerning
Heidi Degro, makes it clear that the practice is still in use [JCA-105]. Indeed, the practice forms a part of
Scientology's incontrovertible "scripture" [JCA-104].

The Erosion of Critical Thinking

47. I have spent over ten years interviewing and counselling former Scientologists, and have come to the firm
conclusion that Dianetics and Scientology tend to erode independent decision making and critical thinking.
Hubbard claimed that his techniques were the only valid approach to mental and spiritual well- being. He derided
all psychotherapeutic practices [JCA-107]. Hubbard asserted with regard to psychology and psychiatry that "the
instigators, patrons and supporters of these two subjects classify fully and demonstrably as criminals." [JCA-
108]. Although Scientology claims to be "open to people of all religions" [JCA-109], Hubbard asserted that
heaven has been deserted for at least 43 trillion years [JCA-110], and that Christ is simply a fabrication [JCA-
111].

48. The techniques of Dianetics and Scientology induce uncritical euphoria and heighten suggestibility.
Scientologists are forbidden criticism of Hubbard, his organizations, his techniques, and of other Scientologists
except in written reports to those organizations [JCA-112], [JCA-113]. Such " ethics reports" are encouraged. To
even attempt to discuss the processing techniques is termed "verbal tech[nology]" and forbidden [JCA-114].
Offenders are subjected to a "Committee of Evidence", a Scientology tribunal, for the commission of a
"Suppressive Act" or "High Crime". Such "High Crimes" are considered the equivalent of murder [JCA-115].

49. During the first stages of involvement, a new recruit is often flattered as an exceptional individual [JCA-52]
and encouraged by false claims of physical cure (e.g., [JCA-21], [JCA-23] to [JCA-30] and psychic abilities (e.g., [JCA-69], [JCA-70] made in Hubbard's works and by euphoric Scientologists.

50. Scientologists are bombarded with promotional literature, magazines such as Impact, Source, Advance!, The
Auditor, Communication, Certainty, Freedom, Freewinds, Good News, Inroads, Celebrity, International
Scientology News and Keeping Scientology Working News. These all point to the supposedly positive and
beneficial effects of Dianetics and Scientology, but avoid any mention of court decisions, medical reports,
government enquiries or media pieces critical of these practices.

51. In its publications, Scientology incites hatred for anyone critical of its ideas and techniques. For example, in
"Ron's Journal 34", which has frequently been reprinted, Hubbard said: "Time and again since 1950, the vested
interests which pretend to run the world (for their own appetites and profit) have mounted full- scale attacks.
With a running dog press and slavish government agencies the forces of evil have launched their lies and sought,
by whatever means, to check and destroy Scientology. What is being decided in this arena is whether mankind
has a chance to go free or be smashed and tortured as an abject subject of the power elite ... a review of these
battles over the past
thirty-two years moves one to contemptuous laughter. The enemy, perched in their trees or swinging by their
tails, have been about as effective as one of their psychologist's monkeys peeling a policeman's club thinking it is
a banana and then throwing it only to hit the chief ape in the face ...The AMA, pouring lies into the press
through gnashing teeth persevered for years - and then went bankrupt. The psychiatrist, riding high in 1959,
hoping to place one of his ilk in a blackmail position behind every head of state, hoping to consign any citizen at

9

[CT 7975]

his whim to a psychiatric Siberia, trying to preserve his right to kill and maim as a profession above the law, is
today a butt of comic strips. And what of the FDA that, for fifteen years snarled and snapped at the E-Meter?
One hardly hears of them today. And what of the mighty Interpol, that tool of the CIA? It was found to be a nest
of war criminals hiding out from the law itself ... You do not hear much about this from the running dog press
because, of course, they were the tool of the enemy in the first place. They lose because they traffic in lies ...
They are mad monkeys ... just remember a maxim: if the papers say it, it isn't true." [JCA-116].

52. Scientologists are discouraged from reading anything hostile to Scientology (" entheta") [JCA-117], and
ordered not to communicate in any way with anyone critical of its teachings [JCA-2]. This is quite obviously a
form of mental imprisonment or psychological slavery.

53. Scientology advertising is based upon the principles of motivational research, and seeks to recruit people by
bypassing their reasoning. This policy was clearly stated by Hubbard [JCA-54]. In 1988, the Church of
Scientology hired leading Public Relations firm Hill and Knowlton to make its advertising more effective [JCA-
118].

Processing

54. Hubbard termed the hypnotic counselling procedures of Dianetics and Scientology " auditing" or
"processing". Scientologists undertake some 27 " levels" consisting of hundreds of different processing
procedures. Scientology practitioners are rarely, if ever, trained in psychology or psychotherapy.

55. Most processing is done with the subject, or "preclear", connected to a psychogalvanometer, described by
Hubbard as a "'lie detector' as used by police and in psychology laboratories" [JCA-119]. The subject is
connected to the galvanometer by two hand held soup cans, which function as electrodes. The galvanometer
measures variations in a small electric current passed through the subject. Where an individual is unwilling to be
interrogated on the E-meter, the following practice forms a part of the " scriptures" of Scientology: "When the
subject placed on a meter will not talk but can be made to hold the cans (or can be held while the cans are
strapped to the soles or placed under the armpit, I am sorry if that sounds brutal, it isn't [sic]), it is still possible to
obtain full information from the subject." [JCA-120].

56. During the course of auditing the individual is frequently asked to disclose guilty secrets or "withholds". The
auditor writes these confessions down. According to the Bulletin " Miscellaneous Reports": "When an Auditor
finds an Ethics Situation [in session reports] he should mark it and circle it in red after the session. The pc
[preclear - subject] is not necessarily turned in ... but the Auditor should make mention of it ... If it is a serious
situation that affects others, then it is the Auditor's responsibility to report it." [JCA-121]. A copy of the report is
sent to a Scientology Ethics department.

57. Scientologists are periodically subjected to confessional interrogations, where printed lists, sometimes
numbering hundreds of questions, are asked [JCA-122]. Scientologists pay #200 per hour for these
"confessionals" [JCA-32]. Confessional lists are checked with the subject connected to the "E-meter" [JCA-103]. Such interrogations are now generally styled "confessionals", " integrity processing" and " eligibility confessionals" but were originally styled "security checks" or " sec checks": "In the early '60s LRH [Hubbard] developed the technology known as Sec Checking. As issued it was
used for two purposes: as a general tool to clean up a pc's overts and withholds and as a security tool to detect
out-ethics persons and security risks." [JCA-123]. In " The Only Valid Security Check", details are requested
concerning potential past misdeeds, including: shoplifting, theft, forgery, blackmail, smuggling, drunkenness,
burglary, embezzlement, cannibalism, drug addiction, sexual practices and counterfeiting. There are also 21
questions relating to Hubbard, his wife and Scientology [JCA-122]. A Scientology " Bulletin" says "The specific
details of each misdeed must be gotten." [JCA-124].

10

[CT 7976]

58. In the " Hubbard Communications Manual of Justice", Hubbard said " Intelligence is mostly the collection of
data on people ... It is basically a listening and filing action. It is done all the time about everything and
everybody." [JCA-125] . Hubbard also said "The main danger of Integrity Processing is not probing a person's
past but failing to do so thoroughly. When you leave an Integrity Processing question 'live' and go on to the next
one, you set up a nasty situation" [JCA-126]; "Take up each reading question [i.e., each question which causes a
reaction on the 'E-meter'], getting the what, when, where, all of every overt [transgression] ... Get specifics ... For
security investigation purposes, get all the exact names, dates, addresses, phone numbers, and any other
information that might be helpful..." [JCA-103].

59. Scientologists can also be subjected to "HCO Confessionals", where they are told that the information they
give will not remain confidential: "The second use of Integrity Processing is as an ethics or security measure ...
[it] can be done as a straight security action." [JCA-123]. The same sets of questions are used in both forms of
confessional: "The term 'I am not auditing you' only occurs when a Confessional is done for justice reasons.
Otherwise the procedure is the same (By 'justice reasons' is meant when a person is refusing to come clean
[sic]...) ... A Confessional done for justice reasons is not auditing and the data uncovered is not withheld from the
proper authorities." [JCA-103].

60. In Church of Scientology of California v. Armstrong, Mary Sue Hubbard, former " Controller" of Scientology,
admitted that she had issued Guardian's Order 161269 which orders that "processing files" - the written records
of confessionals - are to be reviewed so that discreditable material in them can be used against former members
[JCA-127]. This despite many representations that such confessional files are confidential. In July 1977, the FBI
seized many examples of such "folder culls". Former senior Scientology executives testified in the Armstrong
case that folder culling was a common practice in Scientology (Laurel Sullivan, Nancy Dincalci, Kima Douglas
- all of whom had worked with Hubbard, and Edward Walters, a former Guardian's Office intelligence operative)
[JCA-128], [JCA-129], [JCA-130], [JCA-131]).

61. Any critisicm of Hubbard or Scientology is attributed to the critic's guilt and fear of being found out.
Hubbard asserted: "Now, get this as a technical fact, not just a hopeful idea. Every time we have investigated the
background of a critic of Scientology, we have found crimes for which that person or group could be imprisoned
under existing law. We do not find critics of Scientology who do not have criminal pasts. Over and over we
prove this." [JCA-73] .

62. Should a Scientology student question any of the tenets of Scientology, he is required to look up definitions of
words in the text: "The student says he does not understand something. The Supervisor has him look earlier in
the text for a misunderstood word." [JCA-132]; "Whenever a person has a confused idea of something or
believes there is some conflict of ideas IT IS ALWAYS TRUE THAT A MISUNDERSTOOD WORD EXISTS
AT THE BOTTOM OF THAT CONFUSION." (Emphasis in original, [JCA-133]). No-one who disagrees with
Hubbard can continue in Scientology. All practices have to be adhered to absolutely. To do otherwise is regarded
as a violation of "standard technology". In this way, even factual errors in Hubbard's work remain unchanged.
For example, the phrase "The 14th century psychiatrist" used in the "Policy Letter" "Sanity" [JCA-134]. A
"course supervisor" at the Birmingham Scientology organization spent almost 30 minutes trying to persuade me
that this was not a typographical error for "19th".

63. Hubbard's "Policy Letter" "Suppressive Acts...", [JCA-115], lists over 100 actions considered "High Crimes"
or "Suppressive Acts" by Scientology. The list begins with "murder", making it clear how severely Scientology
views the other listed actions. These include: "Public statements against Scientology"; "Testifying hostilely before
state or public inquiries"; "Continued membership in a divergent group"; "Continued adherence to a person or
group pronounced a suppressive person or group"; "Delivering up the person of a Scientologist without
justifiable defense or lawful protest to the demands of civil or criminal law"; "Permitting students to talk to each
other ... during course hours"; "to publicly depart Scientology". For committing any of these "high crimes", a

11

[CT 7972]

Scientologist can be expelled and "declared Suppressive" and his Scientologist friends and family forbidden
further communication with him [JCA-2].

64. In training, Scientologists are subjected to an elaborate system of " checkouts" to ensure that they have exactly
"duplicated" Hubbard's teachings. These include "high crime checkouts" [JCA-135]. The purpose of such
"checkouts" is to bring about absolute agreement with Hubbard. Should a student fail to agree with Hubbard, he
will be sent first to the "Cramming" section of the organization and then, if that fails, to the "Ethics" section. No
student is permitted to continue with a course beyond a disagreement, and students who disagree are separated
from other students. Continued disagreement leads to expulsion from Scientology.

65. HCO Policy Letter "Policies on Physical Healing..." explains categories of people forbidden involvement
with Scientology: "a. Persons intimately connected with persons ... of known antagonism to ... Scientology";
"Persons who 'want to be processed to see if Scientology works' ... News reporters fall into this category.";
"Persons who 'have an open mind'" [JCA-136].

66. Scientologists are forbidden medical assistance without consent from Scientology [JCA-137]. All
psychotherapies and meditational practices are forbidden [JCA-138].

67. Any Scientology "Clear" can be questioned to determine which of Hubbard's claimed criteria they have
obtained - for example, freedom from the common cold, a near perfect memory and the ability to do a calculation
in ten or fifteen seconds that would take a "normal" person 30 minutes. The claims for "Operating Thetan levels",
which come after "Clear", are stranger yet. Scientology " Operating Thetans" should be asked about their ability
to leave their bodies and remotely perceive events. Demonstration should be sought. Having failed to meet
Hubbard's criteria, the individual will still show absolute loyalty to Hubbard.

Retribution against litigants, critics, competitors and former members

68. The Hubbard "Policy Letter" "Suppressive Acts, Suppression of Scientology and Scientologists" [JCA-115],
shows how easy it is to commit "High Crimes" or " Suppressive Acts". These include "Public disavowal of
Scientology", "Public statements against Scientology", "Bringing civil suit against any Scientology organization",
"Demanding the return of any or all fees", "Continued adherence to a person or group pronounced a suppressive
person or group", "publicly departing Scientology" and "Violation or neglect of any of the ten points of Keeping
Scientology Working" (in particular "Knowing it [Scientology "technology"] is correct", "Applying the
technology", "Hammering out of existence incorrect technology"). Strictly speaking, anyone who does not know
that Scientology's "technology" is correct is deemed a " Suppressive Person".

69. It is made clear in Scientology's published policy that a person expelled from Scientology is "Fair Game"
[JCA-139]. A "Suppressive Person declare" is Scientology's equivalent of the Shia Muslim "fatwa".

70. In " Justice, Suppressive Acts, Suppression of Scientology and Scientologists, the Fair Game Law", Hubbard
asserted "By FAIR GAME is meant, without rights for self, possessions or position, and no Scientologist may be
brought before a Committee of Evidence or punished for any action taken against a Suppressive Person or Group
during the period that person or group is 'fair game'." [JCA-140] In this Policy Letter, we learn that "Suppressive
Acts include ... 1st degree murder, arson, disintegration of persons or belongings not guilty of suppressive acts".
Scientologists are thereby given leave to destroy the person and property of a "Suppressive Person".

71. Elsewhere, Hubbard carefully explained the provisions of Fair Game: A Suppressive Person "May be
deprived of property or injured by any means by any Scientologist without any discipline of the Scientologist.
May be tricked, sued or lied to or destroyed." [JCA-141].

12

[CT 7978]

72. In 1968, Hubbard ordered that the words "Fair Game" "may not appear on any Ethics Order. It causes bad
public relations." However, the practice of Fair Game was not cancelled "This ... does not cancel any policy on
the treatment or handling of an SP [Suppressive Person]." [JCA-142].

73. A training checksheet used as evidence in the conviction of eleven Scientology officials in the US (including
Hubbard's wife and immediate deputy), shows that the 1 March 1965 " Policy Letter" [JCA- 140] still formed part
of a secret course for Scientology harassment operatives (members of "Branch One" of the "Guardian's Office"
of Scientology) [JCA-143, p. 18, second item].

74. When the nominal head of Scientology's "Guardian's Office", Jane Kember, and the head of Scientology
Intelligence, Morris Budlong, were sentenced to imprisonment in the United States, in 1980, the sentencing
memorandum included this statement: "Defendants, through one of their attorneys, have stated that the fair game
policy continued in effect well after the indictment in this case and the conviction of the first nine co-defendants.
Defendants claim that the policy was abrogated by the Church's Board of Directors in late July or early August,
1980." [JCA- 144, footnote p.16].

75. The " Policy Letter" which allegedly cancelled "fair game" in 1980 [JCA-139], was itself cancelled by a
Policy Letter of 8 September 1983 [JCA-145]. As such, Fair Game is an incontrovertible "scripture" of the
Churches of Scientology [JCA-46], [JCA-47], [JCA-48], even though the words "fair game" are no longer used to describe the practice [JCA-142].

76. Mr. Justice Latey ruled in the High Court in London, in July 1984, that "Deprival of property, injury by any
means, trickery, suing, lying or destruction have been pursued throughout and to this day with the fullest possible
vigour ... The 'Church' resorts to lies and deceit whenever it thinks it will profit it to do so." [JCA-146].

77. In Wollersheim v. Church of Scientology of California (the "mother church" of the Churches of Scientology
at the time the suit was filed), the California Appeal Court ruled, in a decision upheld by the US Supreme Court:
"Wollersheim was compelled to abandon his wife and his family through the policy of disconnect. When his
mental illness reached such a level he actively planned his suicide, he was forbidden to seek professional help.
Finally, when Wollersheim was able to leave the Church, it subjected him to financial ruin through its policy of
'fair game'." [JCA-147 pp.A-7, 15 & 16]. At appeal, Scientology asserted that " fair game" was a "core practice
of Scientology", and therefore protected as "religious expression". This position was also made on behalf of
Scientology in the case against Gerald Armstrong, in 1984, by religious expert Dr. Frank Flinn [JCA-45].

78. In the same case (Church of Scientology of California v. Armstrong) [JCA-7], Judge Paul Breckenridge
criticised the continued use of Fair Game, showing that the policy had remained in force beyond the supposed
cancellation in 1980. Judge Breckenridge said: "In addition to violating and abusing its own members' civil
rights, the [Scientology] organization over the years with its 'Fair Game' doctrine has harassed and abused those
persons not in the Church whom it perceives as its enemies." Judge Breckenridge added, "After the within suit
was filed ... Defendant Armstrong was the subject of harassment, including being followed and surveilled by
individuals who admitted employment by Plaintiff; being assaulted by one of these individuals; being struck
bodily by a car driven by one of these individuals; having two attempts made by said individuals apparently to
involve Defendant Armstrong in a freeway automobile accident; having said individuals come onto Defendant
Armstrong's property, spy in his windows, create disturbances, and upset his neighbors".

79. Fair Game has long been a policy of Scientology. In 1955 Hubbard wrote, speaking of practitioners of
Scientology not licensed by him: "The law can be used very easily to harass ... if possible, of course, ruin him
utterly" [JCA-27, p.157]. Hubbard also wrote, "If attacked on some vulnerable point by anyone or anything or
any organization, always find or manufacture enough threat against them to cause them to sue for peace." [JCA-
148].

13

[CT 7979]

80. In 1965, Hubbard wrote in Scientology's "Auditor" magazine: "Principals of the Victorian government such
as the 'Prime Minister', Anderson the 'Q.C.' and hostile members of the 'Victorian Parliament' are continued as
suppressive persons and they and their families and connections may not be processed or trained and are fair
game." [JCA- 149].

81. Current Scientology "scriptures" attribute only negative qualities to " Suppressive Persons" [JCA- 150].
Between 1983 and 1992, the number of people ajudged "Suppressive Persons" by Scientology increased from
600 [JCA-1] to 2, 400 [JCA-151]. According to Scientology leader David Miscavige, the next section of
Hubbard's supposed psychotherapy - Operating Thetan Course Section 9 - will not be released until "ethics is
fully gotten in on the SPs [Suppressive Persons]" [JCA-152]. This means that all critics of Scientology must be
silenced. In light of the "scripture" of "Fair Game", the interpretation of this order to all Scientologists can only be
alarming.

82. The lengths to which Scientologists will go to harass opponents are shown by a Hubbard lecture, still
distributed within Scientology, where Hubbard boasted of the creation of his intelligence agency the "Guardian's
Office", and its infiltration of newspapers, international banks and even the British government: "With all of this
action being taken against us in the last 17 years ... it was vitally necessary that I isolate who it was on this planet
who was attacking us ... The Organization, under the direction of Mary Sue [Hubbard], ... employed several
professional intelligence agents who had long and successful professional backgrounds and they looked into this
matter for us and the results of their activities - although still in progress - have told us all we needed to know
with regard to any enemy we had on this planet. Our enemies on this planet are less than 12 men. They are
members of the Bank of England, and other higher financial circles. They own and control newspaper chains and
they are oddly enough directors in all the Mental Health groups in the world ... Wilson ... the current premier of
England [sic] is totally involved with these fellows ... They have collected rather interesting files on us ... and
their orders concerning what to do about this as part of their files all makes very interesting reading. We of
course have full copies of their files. It was, of course, their bad luck to tangle with someone who had been
trained in the field of intelligence by the allied governments, which is myself and they had insufficient security
and insufficient loyalty amongst their own people to keep out the intelligence agents which we sent against
them." [JCA-153].

83. Ten years after Hubbard initiated the practice of infiltration and theft, Churches of Scientology in the US
were raided. This led to the conviction and imprisonment of eleven Scientology officials [JCA-154] . Almost forty
others were cited as "unindicted co-conspirators", including Hubbard [JCA-155]. Similar events led to
convictions in Canada in 1992.

84. The sentencing memorandum in USA v. Mary Sue Hubbard et al makes clear the scale of the offences
committed by Hubbard's agents: "The United States initiated the investigation which resulted in the instant
indictment in view of the brazen, systematic and persistent burglaries of United States Government offices in
Washington, D.C., and Los Angeles, California, over an extended period of at least some two years.
Additionally, the United States was confronted with the pervasive conduct of the defendants in this case in
thwarting a federal Grand Jury investigation by harboring a fugitive, in effect forcefully kidnapping a witness
who had decided to surrender to the federal authorities, submitting false evidence to the Grand Jury, destroying
other evidence which might have been of valuable aid to its investigation, preparing a cover-up story, and
encouraging and drilling a crucial witness to give false testimony under oath to that Grand Jury ... a review of the
documents seized in the ... searches ... show the incredible and sweeping nature of the criminal conduct of the defendants and of the organization which they led. These crimes include infiltration and theft of documents from
a number of prominent private national and world organizations, law firms and newspapers; the execution of
smear campaigns and baseless law suits to destroy private individuals who had attempted to exercise their First
Amendment rights to freedom of expression; the framing of private citizens who had been critical of Scientology,
including the forging of documents which led to the indictment of at least one innocent person; violation of the

14

[CT 7980]

civil rights of prominent private figures and public officials. These are but a few of the criminal acts not covered
in the 'uncontested' stipulation of evidence ... defendant Heldt's assertion that 'the policy of the Church prohibits
any illegality on the part of its members or staff...' is totally unfounded and incorrect. The evidence in this case ...
establish[es] beyond peradventure that the Church and its leadership had, over the years, approved, condoned
and engaged in gross and widespread illegality. One, indeed, wonders how it can even be suggested that the
defendants and their organization did not make illegal activities part and parcel of their daily work." [JCA-154].

Scientology's attitude towards the Courts

85. The scriptures of Scientology show little respect for the judicial system. In 1965, Hubbard wrote "Don't react
to Scientology Ethics as though it were 'wog' law. In society's 'courts' one is given the works and truth has little
bearing on the findings. A mean judge or clever attorney and small legal errors decide a lot of their cases. Wog
courts are like throwing dice. There is huge cost and publicity and punishment galore even for the innocent."
[JCA-156]. In another 1965 "Policy Letter", Hubbard said "Want to know why wog courts make people nervy?
Who can predict a wog court decision? Who can even predict the sentence man to man for the same crime?"
[JCA-157].

86. The second edition of What is Scientology? contains a section comparing "Scientology justice" to "wog law",
which says that the "justice system is bogged down in a morass of Latinized grammatical complexities and has
become, sadly, a matter of which attorney can present the better argument. Right and wrong, guilt and innocence
are relegated to bit players in the show. A lawyer defending a criminal on trial for armed robbery, for instance, is
not interested in establishing guilt or innocence; he is looking for a loophole or technicality on which the case can
be dismissed and his client set free whether guilty or not. Few have the wealth necessary or even try to pursue
justice through the courts and even if one prevails, attorney costs often make it a Pyrrhic victory. The due process
of the court system is in a virtual gridlock of motions, countermotions, depositions, injunctions, appeals, claims
and counterclaims." [JCA-158].

87. In a statement recusing himself from a Scientology case, California judge James Ideman said "The past eight
years have consisted mainly of a prolonged, and ultimately unsucessful, attempt to persuade or compel the
plaintiff to comply with lawful discovery. These efforts have been fiercely resisted by plaintiffs. They have
utilized every device that we on the District Court have ever heard of to avoid such compliance, and some that
are new to us. This noncompliance has consisted of evasions, misrepresentations, broken promises and lies, but
ultimately with refusal. As part of this scheme to not comply, the plaintiffs have undertaken a massive campaign
of filing every conceivable motion (and some inconceivable) to disguise the true issue in these pretrial
proceedings. Apparently viewing litigation as war, plaintiffs by this tactic have had the effect of massively
increasing the costs to the other parties, and, for a while, to the Court ... The scope of the plaintiffs' efforts have
to be seen to be believed ... 1,737 filings [were made by Scientology] ... Yet it is almost all puffery -- motions
without merit or substance." [JCA-159].

88. In the " scriptures" of Scientology, Hubbard wrote: "the law can be used very easily to harass." The
December 1980 issue of "The American Lawyer" makes it clear that this policy has extended to judges in trials
involving Scientology [JCA-160].

89. As part of their membership contract, Scientologists are compelled to sign the " Pledge to Mankind", first
issued in 1984, which reads in part "In the United States ... we are the targets of unprincipled attacks in the court
system by those who would line their pockets from our hard won coffers. Bigots in all branches of government ...
are bent on our destruction through taxation and repressive legislation. We have been subjected to illegal heresy
trials in two countries before prejudiced and malinformed judges who are not qualified or inclined to perceive the
truth." [JCA- 161].

15

[CT 7981]

90. A 1985 issue of the Scientology magazine "Impact" carries the following account: "Rev. Ken Hoden ...
President of the Church of Scientology of California recently won a motion in Los Angeles that allowed the
Church to rebring an important Federal Lawsuit. After one of the Church attorneys was arrested on the charge of
contempt of court and another escorted out of the Courtrooms by order of a suppressive Judge ... Rev. Hoden got
up. He argued before the judge for a full twenty minutes. He had effectively picked up the ball and gave a most
moving, pro-Church and anti-suppression speech, right to the face of the suppression: the judge in the case."
[JCA-162].

Counselling

91. Since 1983, I have counselled tens of former Scientologists and been appalled by a succession of
accounts of financial and psychological devastation. I have met individuals who borrowed money under
false pretences, bankrupted businesses to pay immense amounts for Scientology "auditing", and
abandoned spouses and even small children to pursue Scientology. I have also counselled individuals who
had left Scientology as much as 20 years before and who had been plagued by guilt and a sense of
inadequacy induced by Scientology and its techniques of psychological domination. Scientology is
especially dangerous to those with incipient mental illness. I have counselled two individuals who were
first committed to mental hospitals after encountering Scientology and been consulted by the staff of a
psychiatric hospital in a third case. A California Appeal Court judgment, upheld by the US Supreme
Court, shows that Scientology brought about manic depression and suicidal tendencies in former member
Lawrence Wollersheim [JCA-147 p.A-2].

92. The promises of Dianetics and Scientology are so attractive, the counselling procedures so invasive
and the selling techniques so forceful that former members can take years to see them as simply techniques
of psychological domination. U.S. academics Conway and Siegelman, who studied 400 former cult
members from 48 groups, concluded that Scientology has "the most debilitating set of rituals of any cult in
America ... although claiming the most severe long-term effects, former Scientologists surveyed reported
the lowest total of hours per week spent in ritual and indoctrination." Conway and Siegelman
approximated the time for unaided recovery at 12.5 years [JCA-163]. My own experiences as a counsellor
bear this out.

    I declare under the penalty of perjury under thelaws of the United States of America and the United
Kingdom that the foregoing is true and correct to the best of my knowledge and belief.

Executed in Radcliffe-on-Trent this 9th day of April, 1995,

[signed] J. Caven-Atack
Jonathan Caven-Atack

[JCA-1]. Sea Organization Executive Directive 2192 International, "List of Declared Suppressive Persons", 27 January 1983.

[JCA-2]. Scientology Policy Directive 28, "Suppressive Act - Dealing with a Suppressive Person", 13 August 1982.

[JCA-3]. Sea Organization Executive Directive 2104, "The Flow Up the Bridge...", 7 November 1982, p.7.

[JCA-4]. AOSHUK price list, 1983.

[JCA-5]. Professor Stephen A. Kent, "International Social Control by the Church of Scientology.", 23 March 1992.

[JCA-6]. Professor Louis Jolyon West, M.D., "Psychiatry and Scientology", 6 May 1992.

[JCA-7]. Memorandum of Intended Decision in Church of Scientology of California v. Gerald Armstrong, Superior Court for the State of California, C420153, 20 June 1984.

[JCA-8]. Church of Scientology International, What is Scientology?, second edition, 1992.

[JCA-9]. Church of Scientology, "A Report to Members of Parliament on Scientology, December 1968.

[JCA-10]. US Navy medical records for L. Ron Hubbard.

[JCA-11]. Look magazine, 5 December 1950.

[JCA-12]. Letter from the Department of the Navy to Mark Jones, 1 October 1985.

[JCA-13]. Hubbard, "Man who invented Scientology", Bulletin of 26 May 1959, reprinted in The Technical Bulletins of Dianetics and Scientology, volume 4, pp.470-471, 1979 printing.

[JCA-14]. Letter from the registrar, George Washington University to the US Navy, 27 May 1941, including Hubbard's college grades.

[JCA-15]. Hubbard, Mission into Time, 1973.

[JCA-16]. Hubbard, "A Short Biography of L. Ron Hubbard", "The Auditor" issue 63.

[JCA-17]. Church of Scientology of California, What is Scientology?, 1978 edition.

[JCA-18]. Hubbard, journal of his 1927 trip to Guam (exhibit 62 in CSC v Armstrong, 1984).

[JCA-19]. Hubbard, journal of his 1928 trip to Guam (exhibit 65 in CSC v Armstong).

[JCA-20]. Hubbard, "The Camp-Fire", "Adventure" magazine, 1 October1935.

[JCA-21]. Hubbard, Dianetics: The-Modern Science of Mental Health, New Era, Denmark, 1982 printing.

[JCA-22]. Freud, Two Short Accounts of Psycho-Analysis, trans and ed James Strachey, Pelican Books, England, 1984.

[JCA-23]. Hubbard, Address by L, Ron Hubbard, Arcadia Theater, Wichita, Kansas", 6 February 1952,

[JCA-24]. Hubbard, Scientology: A History of Man, 1968 printing.

[JCA-25]. Hubbard, "The Old Man's Case-Book", from "The Journal of Scientology", issue 15-G, May 1953, reprinted in The Technical Bulletins of Dianetics and Scientology, volume 1, p.337, 1979 printing.

[JCA-26]. "The Auditor", issue 198, worldwide, 1975.

[JCA-27]. Hubbard, "The Scientologist - A Manual on the Dissemination of Material", reprinted in The Technical Bulletins of Dianetics and Scientology volume 2, pp.151-171, 1979 printing.

[JCA-28]. "Advance!", issue 10, p.2.

[JCA-29]. "The Auditor", Africa and Europe, issue 231, p.3.

[JCA-30]. "Celebrity", minor issue 247,p.14.

[JCA-31]. Hubbard, Scientology 0-8, pp.134-135 (removed from subsequent editions), 1971 printing.

[JCA-32]. Advanced Organisation Saint Hill United Kingdom, "Donations Information", March 1992.

[JCA-33]. Hubbard, "Philadelphia Doctorate Course", lecture 18, 1982 transcript, p.17.

[JCA-34]. Hubbard letter to Helen O'Brien, 10 April 1953 (exhibit 500-4V in CSC v Armstrong 1984, cited in vol.12, p.1976 and vol.26, p.4619).

[JCA-35]. Hubbard, Associate Letter of 10 March 1954, reprinted in The Technical Bulletins of Dianetics and Scientology, volume 2, pp.32-34, 1979 printing.

[JCA-36]. Hubbard, Modern Management Technology Defined, 1976 edition, definition of "Church of American Science".

[JCA-37], Roy Wallis, PhD, The Road to Total Freedom - a sociological analysis of Scientology, Heinmann, England, 1976, p.128.

[JCA-38]. Hubbard, "Why Doctor of Divinity?" in "Professional Auditor's Bulletin", issue 32, reprinted in The Technical Bulletins of Dianetics and Scientology, volume 2, pp.72-75, 1979 edition.

[JCA-39]. Hubbard, "Religious Philosophy and Religious Practice", Bulletin of 18 April 1967, reprinted in The Technical Volumes of Dianetics and Scientology, volume 6, p.195, 1979 edition.

[JCA-40]. Hubbard, "Six Basic Processes", Bulletin of 4 May 1972, reprinted in The Technical Volumes of Dianetics and Scientology, volume 8, pp.107- 111, 1979 edition.

[JCA-41]. Hubbard, All About Radiation, Bridge, LA, 1989 edition.

[JCA-42]. Church of Scientology International. What is Scientology?, p.688, second edition, 1992.

[JCA-43]. Hubbard, The Background and Ceremonies of the Church of Scientology of California, World Wide, Church of Scientology of California, East Grinstead, 1973, pp.26-55.

[JCA-44]. Affirmation of E.G.Parrinder, 25 November 1971.

[JCA-45]. Frank K. Flinn testimony in Church of Scientology of California, 1984, vol.23, pp.4032-4160.

[JCA-46]. "The Corporations of Scientology", p.24, 1989.

[JCA-47]. Trademark License Agreement - SMI/Mission, licence to use Religious Technology Center trademarks and service marks.

[JCA-48]. Scientology Policy Directive 19, "The Integrity of Source", 7 July 1982.

[JCA-49]. Japan Eval, Vinay Agarwala, 29 January 1981, Sea Org Aides Order 549-1.

[JCA-50]. Regina v Registrar General, ex parte Segerdal, Queens Bench, London, November 1969 and Court of Appeal, July 1970.

[JCA-51]. Church of Scientology International, "Field Staff Member Kit ",1993.

[JCA-52]. Hubbard, "Registrar Drills", Policy Letter of 27 May 1980, revised 2 October 1981.

[JCA-53]. HCOB FSM Breakthrough - New FSM TRs - Controlling a Conversation, 27 January 1984, Field Staff Member Specialist, Bridge, LA, 1991.

[JCA-54]. Hubbard, "Second Lecture on Clearing Methodology", 13 May 1959.

[JCA-55]. Hubbard, Volunteer Minister's Handbook, pp.61-66, 1977 printing.

[JCA-56]. Hubbard, "The Tone Scale", Scientology 0-8, p.101, 1971 printing.

[JCA-57]. Hubbard, "Lower Awareness Levels", Scientology 0-8, p.133, 1971 printing.

[JCA-58]. Hubbard, Dianetics and Scientology Technical Dictionary, p.471, 1975 edition.

[JCA-59]. Hubbard, Dianetics and Scientology Technical Dictionary, p.335, 1975 edition.

[JCA-60]. Hubbard, Dianetics and Scientology Technical Dictionary, p.104, 1975 edition.

[JCA-61]. Hubbard, "Books are Dissemination", Bulletin of 28 April 1960, reprinted in The Technical Bulletins of Dianetics and Scientology, volume 4, pp.78-81, 1979 printing.

[JCA-62]. The Standard Oxford Capacity Analysis.

[JCA-63]. The Hat of the Personality Test Evaluator.

[JCA-64], Hubbard, "The Hard Sell Reference Pack", pp.i-vi, 1987.

[JCA-65]. Lee Lawrence, "To the Scientologist Loan Applicant", undated.

[JCA-66]. Hubbard, "The No-Interference Area Clarified and Re-enforced", undated.

[JCA-67]. Sea Organisation Executive Directive 2104 International, "The Flow Up the Bridge...", 7 November 1982, pp.17-18.

[JCA-68]. Hubbard, "Registrar Salesmanship Course Checksheet", Policy Letter of 2 December 1972, revised 20 May 1980.

[JCA-69]. Hubbard, promotional leaflet, 1992, from Flag Mission Order 375, 1970.

[JCA-70]. Hubbard, "OT and Beyond", " The Auditor" issue 19, 1966.

[JCA-71]. Hubbard, "The Organization of a PE Foundation", Bulletin of 29 September 1959, reprinted in The Technical Bulletins of Dianetics and Scientology, volume 3, pp.527-528, 1979 printing.

[JCA-72]. Hubbard, "Keeping Scientology Working", Policy Letter of 7 February 1965, reissued in 1980, The Organization Executive Course, volume 0, pp.7-13, 1991 edition.

[JCA-73]. Hubbard, "Critics of Scientology", Bulletin of 5 November 1967, reprinted in The Organization Executive Course, volume 1, pp.782-784, 1991 edition.

[JCA-74]. Hubbard, "Philadelphia Doctorate Course", lecture 20, 1982 printing.

[JCA-75]. Court transcript in Church of Scientology of California v Armstrong, volume 13, p.2056-2057.

[JCA-76]. Hubbard, Introducing Dianetics, 1950, reprinted in The Research and Discovery Series, vol.3, p.15, Bridge, LA, 1st edition, 1982.

[JCA-77]. Hubbard, Science of Survival, Hubbard College of Scientology, East Grinstead, 1968, pp.227-228.

[JCA-78]. Hubbard Dianetics Auditor Course, Bridge, LA, 1988, p.54.

[JCA-79]. Hubbard, Educational Dianetics, 1950, reprinted in Research and Discovery Series, volume 3, p.241, Bridge, LA, 1st edition, 1982.

[JCA-80]. HCOB Training Drills Remodernized, 5 July 1978.

[JCA-81]. HCOB Op Pro by Dup, 4 February 1959.

[JCA-82]. Promotional leaflet, "It's up to you", 1988.

[JCA-83]. Promotional leaflet, "What is the Sea Organization and what does it do?", dated "2/12/1979".

[JCA-84]. Hubbard, "Towards a Worthwhile Purpose", 1976.

[JCA-85]. Hubbard, "Functions of the Sea Org", 26 April 1968.

[JCA-86]. "New Sea Org Uniforms Enhance Ethics Presence", "High Winds", issue 7, 1987.

[JCA-87]. W.B.Robertson, "Service Insignia", Flag Order 2327R, 16 January 1974.

[JCA-88]. Church of Scientology International, Sea Organization "Contract of Employment", 1987.

[JCA-89]. Church of Scientology International, What is Scientology?, 1992 edition, p.360.

[JCA-90]. Hubbard, "The Code of a Sea Org Member", 1978.

[JCA-91]. Hubbard, "Awards and Penalties", Policy Letter of 26 September 1967.

[JCA-92]. Hubbard, "Penalties for Lower Conditions", Policy Letter of 18 October 1967, issue iv, published in Scientology Basic Staff Hat Book, number 1, p.26, Church of Scientology of California, East Grinstead, 1968.

[JCA-93]. Hubbard, "Penalties for Lower Conditions", Policy Letter of 21 July 1968.

[JCA-94]. Hubbard, "Titles of Address", Flag Order 87, 2 September 1967.

[JCA-95]. Hubbard, "The Auditor", issue 41.

[JCA-96]. Hubbard, Modern Management Technology Defined, Church of Scientology of California, 1976, defninitions of "Rehabilitation Project Force"and "rehabilitation unit".

[JCA-97]. as exhibit 96, definition of "Mud Box Brigade".

[JCA-98]. City of Clearwater Commission Hearings, Re: Church of Scientology, 7 May 1982, testimony of David Ray, vol.3, pp.165-170.

[JCA-99]. Team Share System, Sea Org Executive Directive 3490 Int, 24 July 1986.

[JCA-100]. Clearwater Hearings, 7 May 1982, testimony of Casey Kelly, vol.3, pp.51-53.

[JCA-101]. RPF Policy Checksheet, Flag Order 3434R-25RA, 25 July 1974.

[JCA-102]. RPF Graduation Requirements Checklist, Flag Order 3434RC-56, 17 March 1980.

[JCA-103]. Confessional Procedure, HCOB 30 November 1978, Technical Bulletins of Dianetics and Scientology, vol XII, Church of Scientology of California, Los Angeles, 1980 edition.

[JCA-104]. HCOB Introspection Rundown - additional actions, 20 February 1974, Technical Bulletins of Dianetics and Scientology, vol. VIII, pp.260-261, Church of Scientology of California, Los Angeles, 1976.

[JCA-105]. Sea Org HCO Ethics Order, AOSHUK 2543, Confidential Board of Investigation - Findings and Recommendations - Isolation Watch Heidi Degro, September 1993.

[JCA-106]. The Independent, England, 31 January 1994, The Prisoners of Saint Hill.

[JCA-107]. Hubbard, "Dianetics and Scientology compared to 19th Century practices", Bulletin of 29 November 1981.

[JCA-108]. Hubbard, "Criminals and Psychiatry", Bulletin of 29 July 1980.

[JCA-109]. Hubbard, "Scientology is a religion", Policy Letter of 6 March 1969, reprinted in The Organization Executive Course, volume 5, pp.289-290, 1974 printing.

[JCA-110]. Hubbard, "Routine 3 - Heaven", Bulletin of 11 May 1963.

[JCA-111]. Hubbard, "Confidential Resistive Cases - Former Therapy", Class VIII Bulletin of 23 September 1968,

[JCA-112]. Hubbard, "Ethics Chits", Policy Letter of 1 July 1965, reprinted in The Organization Executive Course, vol.1, pp.703-704, 1991 edition.

[JCA-113]. Hubbard, "Jokers and Degraders", Bulletin and Policy Letter of 5 February 1977, reprinted in The Organization Executive Course, volume 1, pp.822-823, 1991 edition.

[JCA-114]. Hubbard, "A New Type of Crime", Policy Letter of 17 January 1979, reprinted in The Organization Executive Course, volume 1, pp.908- 909, 1991 edition.

[JCA-115]. Hubbard, "Suppressive Acts, Suppression of Scientology and Scientologists", Policy Letter of 23 December 1965, re-revised 8 January 1991. reprinted in The Organization Executive Course, volume 1, pp.873-889, 1991 edition.

[JCA-116]. Hubbard, "The Future of Scientology", "Ron's Journal 34", 13 March 1982.

[JCA-117]. Hubbard, "Critics of Scientology", 5 November 1967, reissued as a Bulletin 27 August 1987, reprinted in "Impact" magazine, issue 15, pp.36-37.

[JCA-118]Heber Jentzsch letter of 7 April 1988.

[JCA-119]. Hubbard, Electropsychometric Auditing - Operator's Manual, 1952.

[JCA-120]. HCOB Interrogation (How to read an E-meter on a silent subject), 30 March 1960, Technical Bulletins of Dianetics and Scientology, vol.IV, pp.59-60, CSC, LA, 1976.

[JCA-121]. Board Technical Bulletin Miscellaneous Reports, 7 November 1972R, Auditor Admin Series 20R, Technical Bulletins of Dianetics and Scientology, vol.IX, p.53, CSC, LA, 1976.

[JCA-122]. HCOPL The Only Valid Security Check, 22 May 1961, Technical Bulletins of Dianetics and Scientology, vol.IV, pp.275-281, CSC, LA, 1976.

[JCA-123]. Board Technical Bulletin Integrity Processing Series 1 Definitions, 4 December 1972R, Technical Bulletins of Dianetics and Scientology, vol.IX, pp.261-263, CSC, LA, 1976.

[JCA-124]. Board Technical Bulletin Integrity Processing Series 16RA, Integrity Processing Info, 6 June 1968RA, Technical Bulletins of Dianetics and Scientology, vol.IX, pp.287-288.

[JCA-125]. Hubbard, HCO Manual of Justice, HCO, London, 1959.

[JCA-126]. HCOB Integrity Processing Series 10R, Integrity Processing Questions Must Be F/Ned, 13 December 1972R, Technical Bulletins of Dianetics and Scientology, vol.IX, p.278.

[JCA-127]. Mary Sue Hubbard, Guardian Order 121669, Programme: Intelligence: Internal Security, 16 December 1969.

[JCA-128]. Laurel Sullivan testimony, Church of Scientology of California v Armstrong, Los Angeles, case no. C 420 153, vol.19A, pp.3001-3004, 24 May 1984.

[JCA-129]. Nancy Dincalci testimony, CSC v Armstrong, 29 May 1984, vol.20, pp.3531-3533, 3553, 3568, 3569.

[JCA-130]. Kima Douglas testimony, CSC v Armstrong, 5 June 1984, vol.25, pp.4437-4439, 4460.

[JCA-131]. testimony of Edward Walters, CSC v Armstrong, 29 May 1984, vol.20, p. 3585. (see also testimony of Ernest and Adelle Hartwell in the Clearwater Hearings, May 1982).

[JCA-132]. HCOB Word Clearing, 24 June 1971, Technical Bulletins of Dianetics and Scientology, vol.IX, p.392, CSC, LA, 1976.

[JCA-133]. HCOB Confused Ideas, 31 August 1971, Technical Bulletins of Dianetics and Scientology, vol.VII, p.373, CSC, LA, 1976.

[JCA-134]. HCOPL Sanity, 19 May 1970, The Management Series, vol.1, Bridge, LA, 1982.

[JCA-135]. Board Technical Bulletin High Crime Checkouts and Technical OKs, 8 March 1975, Technical Bulletins of Dianetics and Scientology, vol.IX, pp.99-101, CSC, LA, 1976.

[JCA-136]. HCOPL Policies on Physical Healing, Insanity and Sources of Trouble, 27 October 1964R, Organization Executive Course, vol.1, 2nd edition, 1991.

[JCA-137]. HCOPL Students Guide to Acceptable Behaviour, 15 December 1965.

[JCA-138]. HCOB Expanded Green Form 40RD, 30 June 1971RD, Technical Bulletins of Dianetics and Scientology, vol.XII, pp.60-69, CSC, LA, 1980.

[JCA-139]. Boards of Directors of the Churches of Scientology, "Ethics, Cancellation of Fair Game, more about", Policy Letter of 22 July 1980.

[JCA-140]. Hubbard, "Ethics, Suppressive Acts, Suppression of Scientology and Scientologists, the Fair Game Law", Policy Letter of 1 March 1965, reprinted in the Scientology Basic Staff Hat Book, number 1, pp.40-44, 1968 edition.

[JCA-141]. Hubbard, "Penalties for Lower Conditions", Policy Letter of 18 October 1967, reprinted in the Scientology Basic Staff Hat Book, number 1, p.26, Church of Scientology of California, East Grinstead, 1968.

[JCA-142]. Hubbard, "Cancellation of Fair Game", Policy Letter of 21 October 1968.

[JCA-143]. Leif Windle, Morris Budlong & Jane Kember, "Confidential Intelligence Course", Guardian Order of 9 September 1974.

[JCA-144]. Sentencing memorandum of the United States of America, in USA v. Kember and Budlong, US District Court for the District of Columbia, criminal no. 78 401 (2) & (3).

[JCA-145]. Church of Scientology International, "Cancellation of Issues on Suppressive Acts and PTSes", Policy Letter of 8 September 1983.

[JCA-146]. Mr. Justice Latey in "B & G wards", Royal Courts of Justice, 23 July 1984.

[JCA-147]. Wollersheim v. Church of Scientology of California, Court of Appeal of the State of California, civ.no.B023193, 18 July 1989 (upheld by the U,S. Supreme Court, 7 March 1994).

[JCA-148]. Hubbard, "Dept of Government Affairs", Policy Letter of 15 August 1960,

[JCA-149]. The Auditor, issue 31.

[JCA-150], Hubbard, Overcoming Ups and Downs in Life, "The Antisocial Personality", 1988 edition.

[JCA-151]. Sue Porter, "Suppressive Persons and Suppressive Groups List", Sea Organization Flag Executive Directive, 25 July 1992.

[JCA-152]. Miscavige, reported in International Scientology News, issue 31.

[JCA-153]. Hubbard, "Ron's Journal, 1967", transcript of lecture, recorded 20 September 1967 (issued as a cassette tape recording in 1983).

[JCA-154]. Sentencing Memorandum in USA v MSH et al, US District Court for the District of Columbia, criminal case no. 78-401, pp.1-4 & 14.

[JCA-155]. ibid, p.69 (see also Stipulation of Evidence in this case, where the following co-conspirators or participants are named: Joseph Alesi (pp.98, 175); Don Alverzo (22, 89, 101f); Peeter Alvet (183, 244); Brian Andrus (231, 233, 241, 243, 251, 265); Michael Baum (146); Jim Douglas (249f); Nancy Douglas ("Pitts") (46, 70); Jim Fiducia (239); Janet Finn (183); Martin Greenberg (107, 133); Richard Kimmel (98); Paul Klopper (peripheral involvement) (157, 265); Gary Lawrence (247); Joe Lisa (35, 200); John Luke (247); Lynn McNeill (45); Arthur "Artie" Maren (51, 170); John Matoon (248); Carla Moxon (22); Rick Moxon (presumably Kendrick Moxon, attorney) (197, 213f); Jimmy Mulligan (108, 180); george Pilat (247); Lexie Ramirez (143); Bruce Raymond (aka Randy Windment) (131f, 212, 251); Chuck Reese (244, 250); Tom Reitze (Snow White I/C) (142); Mary Rezzonico (107, 170); Michael Taylor (62); Peggy Tyson (71); Bruce Ullman (22, 176); Hugh Wilhere (150); Lt warren Young (San Diego police) (205).

[JCA-156] HCOPL The Ethics of Scientology Its Use and Purpose Being a Scientologist, 27 March 1965.

[JCA-157]. HCOPL Handling the Public Individual, 16 April 1965, issue III, Organization Execuitve Course, vol.1, 2nd edition, Bridge, LA, 1991.

[JCA-158]. What is Scientology?, 2nd edition, p.245, Bridge, LA, 1992.

[JCA-159]. Declaration of Hon. James M. Ideman, United States District Court, Central District of California, in Religious Technology Center v Scott et al (no. CV 85-711 JMI [Bx]) and Religious Technology Center v Wollersheim et al (no. CV 85-7197 JMI [Bx]), filed 21 June 1993.

[JCA-160]. James B.Stewart, jr, Scientology's War Against Judges, American Lawyer, December 1980.

[JCA-161]. The Pledge to Mankind.

[JCA-162]. Impact, issue 3, 1985, pp.19 & 32.

[JCA-163]. Conway and Siegelman, Information Disease - Have Cults Created a New Mental Illness?, Science Digest, January 1982.