Gerry Armstrong--Declaration of Ken Hoden 07-29-1985

§ What's New || Search || Legal Archive || Wog Media || Cult Media || CoW ^® || Writings || Fun || Disclaimer || Contact §

JOHN G. PETERSON, ESQ.
PETERSON & BRYNAN
8530 Wilshire Boulevard, Suite 407
Beverly Hills, California 90211
(213) 659-9965

DONALD C. RANDOLPH
CHARLOTTE I. ASHMUN
Members of
OVERLAND, BERKE, WESLEY, GITS,
RANDOLPH & LEVANAS
A Professional Corporation
2566 Overland Avenue, Seventh Floor
Los Angeles, California 90064
(213) 559-8150

Attorneys for Plaintiff and Cross-Defendant
Church of Scientology of California

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

CHURCH OF SCIENTOLOGY OF
CALIFORNIA, a California
Corporation,

Plaintiff,

GERALD ARMSTRONG, et al.,

Defendants.

AND RELATED CROSS-ACTION

)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)

CASE NO. C 420153

DECLARATION OF REVEREND
KEN HODEN IN RESPONSE
TO JULY 2, 1985
DISCOVERY ORDER

I, REVEREND KEN HODEN, declare as follows:

1. I am the President of the Church of Scientology of

Los Angeles. I have been a staff minister with the Church of

Scientology for the past 11 years and have received and

delivered thousands of hours of pastoral counselling

(auditing).

2. In its order of July 2, 1985, the Court refers to

"verbatim as well as sum and substance types recitals" from

-20-

the preclear folders. "Verbatim" and "sum and substance

type recitals" are not part of the auditing process and do not

appear in any of the internal Church scriptures specifying

what an auditor writes down in session. The Court specifies

material to be turned over including "name of interviewer."

An auditing session is not an "interview" and to refer to it

as such is a blatant degradation of this religious practice.

3. Materials and information stored or recorded within

the confessional folders (PC folders) are confidential and

privileged. Our religious doctrine prohibits any parishioner

or person receiving pastoral counselling (auditing) from

viewing the contents of their folders. Our religious

doctrines also prohibit any external dissemination of

preclear folders. Even our attorneys are forbidden to review

these folders. The only people who are allowed to view the

pastoral counselling folders are authorized Church ministers.

4. I myself have 24 confessional folders (PC Folders),

each one containing some 300 pages, and I have never seen

the contents of these folders, and I am the President of the

Church.

5. The Court refers to GO 121669 for justification in

saying that the clergymen-penitent does not apply for the

time period during which Armstrong was a member of the Church.

The Court refers to GO 121669 for justification for

abolishing the clergyman-penitent privilege. Yet nowhere does

the program call for a) external dissemination of the

preclear folder or b) use of information against anyone.

6. To cause preclear folders or preclear folder

-21-

information to be released from the care and control of

authorized Church ministers is to cause the destruction of

its parishioners' religious freedom and would be a severe

violation of Church ecclesiastical policies.

Executed this 29th day of July, 1985, in Los Angeles,

California.

I declare under penalty of perjury that the foregoing is

true and correct.

[signed]
REVEREND KEN HODEN

-22-

§ What's New || Search || Legal Archive || Wog Media || Cult Media || CoW ^® || Writings || Fun || Disclaimer || Contact §