1. I, Frank K. Flinn,. reside at 7472 Cornell. St. Louis. Missouri 63130.

2. I am currently self-employed as a writer, editor, lecturer and consultant in the fields of theology and religion. I am also a Senior Religion Editor at the Edwin Mellen Press of Toronto and New York.

3. I hold a Bachelor of Arts degree in Philosophy (1962) from Quincy College, Quincy, Illinois; a Bachelor of Divinity degree (1966), magna cum laude, from Harvard Divinity School, Cambridge, Massachusetts; and a Ph.D. in Special Religious Studies (1981) from the University of St. Michael’s College, Toronto School of Theology, Toronto, Ontario, Canada. I have also done advanced study at Harvard University, the University of Pennsylvania, and the University of Heidelberg, Germany. At the University of Heidelberg, I was a Fulbright Fellow, 1966-67. At the University of Pennsylvania, I was a National Defense Foreign Language Fellow, Title VI, 1968-69.

4. Since 1962, I have devoted intense study to religious sectarian movements, ancient and modern. A portion of my doctoral studies was focussed specifically on the rise of new religious movements in the United States and abroad since World War II. That study included the investigation of new religions in terms of their belief systems, lifetstyles, use of religious language, leadership, motivation and sincerity, and the material conditions of their existence.

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5. Prior to my present position, I taught at Maryville College, St. Louis. Missouri, 1980-81; St. Louis University, St. Louis, Missouri, 1977-79, where I was Graduate Director of the Masters Program in Religion and Education; the University of Toronto, Ontario, 1976-77, where I was Tutor in Comparative Religion; St. John’s College. Santa Fe. New Mexico, 1970-75, where I was Tutor-in the Great Books Program; LaSalle College, Philadelphia, Pennsylvania, Summers 1969-73, where I was Lecturer in Biblical Studies and the Anthropology of Religion; Boston College,. Boston, Massachusetts, 1967- 68, where I was Lecturer in Biblical Studies; and Newton College of the Sacred Heart, Newton, Massachusetts, where I was Lecturer in Biblical Studies.

6. I am a member in good standing of the American Academy of Religion, the Religious Education Association, the College Theology Society, the Council on Religion and Law, and am an associate member of the Christian Legal Society. I am a practicing Roman Catholic at All Saints Parish, University City, Missouri.

7. Since 1968, I have lectured and written about various new religious movements which have arisen in the 19th and 20th centuries in the United States. In my lecture courses “Anthropology of Religion” (LaSalle College), “Comparative Religion” (University of Toronto) and “The American Religious Experience” (St. Louis University), I have dealt with such religious movements as the Great Awakening. Shakerism, Mormonism, Seventh Day Adventism. Jehovah’s Witnesses. New Harmony, Oneida, Brook Farm, Unification, Scientology, etc. I have published several articles and been general editor of books on the topic of new religions. It is my policy not to testify about

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a living religious group unless I have long-term, first-hand knowledge of that group. I have been invited to testify on various aspects of the new religions before the U.S. Congress, the Ohio legislature, the Illinois legislature, and the Kansas legislature. I have delivered lectures on the topic of the new religious movements at colleges and universities in the United States, Canada and Europe.

8. I have studied the Church of Scientology in depth since 1976. I have sufficiently sampled the vast literature of Scientology (its scriptures) to form the opinions expressed below. I have visited Scientology Churches in Toronto, Ontario, St. Louis, Missouri. Portland, Oregon, Clearwater, Florida, Los Angeles, and Paris, France, where I familiarized myself with the day-to-day operations of the Church. I have also conducted numerous interviews (spiritual biographies) of members of the Church of Scientology. I am also familiar with most of the literature written about Scientology, ranging from objective scholarship to journalistic accounts, both favorable and unfavorable.

9. The question has arisen in the minds of some as to whether Scientology is a religion. As a comparative scholar of religions, I maintain that for a movement to be a religion and for a group to constitute a church,it needs to manifest three characteristics, or marks, which are discernible in religions around the world. Below, I define these three characteristics.

(a) First, a religion must possess a system of beliefs or  doctrines which relate the believers to the ultimate meaning of  life (God, the Supreme Being, the Inner Light, the Infinite, etc.).

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(b) Secondly, the system of beliefs must issue into religious practices which can be divided into 1) norms for behavior (positive commands and negative prohibitions or taboos) and 2) rites and ceremonies (sacraments, initiations, ordinations, sermons, prayers, services for funerals and marriages, etc.).

(b) [sic] Thirdly, the system of beliefs and practices must unite a body of believers so as to constitute an identifiable community which is either hierarchical or congregational in polity and which possesses a spiritual way of life in harmony which the ultimate meaning of life as perceived by the believers.

Not all religions will emphasize each of these characteristics to the same degree, but all will possess them in a perceptible way.

10. On the basis of these three criteria and of my research into the Church of Scientology, I can state without hesitation that the Church of Scientology constitutes a bona fide religion. It possesses all the marks of religion known around the world: (1) a well-defined belief system, (2) which issues into religious practices (positive and negative norms for behavior and religious rites and ceremonies), and (3) which sustain the body of believers in an identifiable religious community. In terms of their belief system Scientologists believe that mankind is basically good, that the spirit can be saved, and that the healing of both physical and spiritual ills proceeds from the spirit, which they define as “thetan.” According to Scientology belief, ” thetan” is immortal and has assumed various bodies in “past lives.” This doctrine has many affinities with the Buddhist belief in samsara or the transmigration of the soul. Belief in the Supreme Being is expressed in terms of the “Eighth Dynamic” which is equivalent to God or Infinity. The Creed of Scientology can be compared to the classic Catholic creed of Nicaea, the Lutheran Augsburg Confession and the Presbyterian Westminster Confession.

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11. In terms of religious practices, Scientology has many ceremonial religious forms which can be found in traditional religious groups, such as initiation or baptism (which is called “naming” in Scientology), marriage, funerals, etc. However, the central religious practice of Scientology is auditing, which is comparable to the confession of sins and spiritual guidance among traditional religious groups. Scientologists make a distinction between reactive or passive mind and analytical or active mind. The reactive mind records what adherents call “engrams,” which are like spiritual traces of pain, injury, or impact. The reactive mind is believed to retain engrams that go back to the fetal state and reach further back to past lives. The notion of engram is functionally equivalent to the notion of sin in Judaism and Christianity and bears close resemblance to the Buddhist doctrine of “threads of entanglement” which hare [sic] held over from previous incarnations and which impede the attainment of enlightenment. Scientologists believe that unless one is freed from these engrams through the activation of analytical mind, one’s survival ability, happiness, intelligence and spiritual well-being will be severely impaired. It is on this basis that adherents are motivated to go through the many stages of auditing. A beginner in the auditing process is called a “preclear” and one who has successfully discovered and erased all traces of past engrams is called a ” clear.” This distinction between preclear and clear may be compared to the traditional Christian distinction between sin and grace, as well as the Buddhist distinction between entanglement and enlightenment. Adherents who are at higher auditing levels are considered as striving to become “operating thetans” so that they may be at cause over matter, energy, space

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and time. While not opposed to consulting physicians for physical ailments, Scientologists have a firm taboo against the use of psychotropic drugs for the mental and spiritual healing of the soul. The bulk of Scientology ministerial practice is devoted to auditing, to courses for the training of auditors, who are like spiritual counsellors, and to achieving the many levels of spiritual enlightenment through the auditing  process. These many levels of auditing and spiritual enlightenment are remarkably like the levels of religious and spiritual enlightenment is the noted Christian treatises, Journey of the Mind into God by St. Bonaventure. and the Spiritual Exercises by St. Ignatius of Loyola.

12. As with every know religion, Scientology has a communal life and ecclesiastical organization which serves to preserve and to propagate the belief system and to foster the religious practices. In ecclesiastical structure Scientology is hierarchical rather than congregational. Congregational religions exercize authority horizontally by locally electing ministers of churches, voting on reformulations of belief systems and religious practices, as well as church polity. Hang Protestant denominations in the United States are congregational in polity. Hierarchical religions, on the other hand, exercise authority by appointment from the top down, either from a central religious figure such as the Pope in Roman Catholicism, the Dalai Lama in Tibetan Buddhism, and the Archbishop of Cantebury in Anglicanism, or from a central executive body, such as a synod of bishops or council of elders. Some religious groups such as the Missouri Synod Lutheran Church have a combination of congregational and hierarchical polities. In hierarchical religious, the church leaders are invested with the power to

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interpret doctrine, modify, religious practices and formulate polity. My study of the Church of Scientology shoved me that it followed the traditional hierarchical type of church polity.

13. In the course of time certain religious and ecclesiastical practices of the Church of Scientology have come under criticism by outsiders and disaffected members. Those criticisms can be enumerated under four topics: (a) the “disconnection” of Church members from their natal families; (b) the information gathering practices of the Church; (c) the disciplinary practices associated with the Rehabilitation Project Force (RPF); and (d) the use and confidentiality of the Pre-Clear files (contained in what are known as PC folders) of upper level members of the Church.

Below I will discuss these issues one by one. But, first, some general remarks are in order. As noted above, religions are constituted not simply by beliefs, however unintelligible to the non-believer, but also by acts and practices (ethical norms and rites), both of which serve to shape a way of life for a community of believers. In general, a great amount of attention has been given to the varieties of belief among the religions of the world, while religious acts have been subordinated to illuminating those beliefs. Most definitions of religion focus on the belief system to the detriment of the religious practices and community. Hence, the attention given to religious acts has tended to be either minimal or slanted. When religious acts are noticed, that attention has frequently been prurient, that is, religious rites elicit interest only in so far as they are odd, bizarre or quaint. Both beliefs and religious acts, however, are like two gears which

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make the transmission (the way of life) of a community of believer go around. All three — beliefs, acts, and way of life — need to be looked at both separately and in conjunction.

(a) Hang critics of the new religious movements, in general, and of Scientology, in particular, have claimed that converts have been deliberately induced to alienate themselves from their families and to devote themselves heart, mind and soul to their new-found religion. ‘Ibis claim and the tension between an older generation and new converts are neither a simple nor a new phenomenon.

I will address the complexity of the issue first. Here we are dealing, first, with a matter of media bias. Scholars of new religious movements have noted that newspaper, television and radio coverage of religion-related events keep pertinent information about mainline religions in the background while underlining that about the new ones. If, for example, two men, one an Episcoplian and the other a Jehovah’s Witness are arrested for murder, the news headline about the Episcopalian will read “Man Kills Wife,” while the one about the Jehovah’s Witness will read “Jehovah’s Witness Slays Mate.”

Secondly, the media often lump all new religious movements together such that the practices of one are attributed to another which has completely different practices. Media coverage of innovative religious movements frequently fall into the age-old trap of the sweeping generalization: ” If you have seen one, you have seen them all.” Immediately after the Jonestown massacre — indeed a lamentable tragedy — the media started carrying articles about ” suicide pacts” and “suicide drills” in other “cults” and ceased so

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doing only when the evidence proved absent. So, too, alienation of new converts from parents and other relatives, while true about some new religious movements under some circumstances, quickly became attributed to all. My study of the new religious movements showed that ” disconnection” between members and their relatives occurred the least among Scientologists.

Thirdly, my interviews with new converts of several new religions showed that friction between the young adult member and his or her parents — an often enough occurrence throughout American culture — often preceded the membership. Thus conversion to a religion, whether old or new, becomes the occasion but not the primary cause of the surfacing of long-standing family conflicts.

My studies show that contact with parents and others by members of new religions was nearly normal, even when the parents disapproved of membership in the new religion, until “deprogramming” became common. Because the new religions could not predict whether or not their members would be abducted when meetings were sought on the part of relatives, they naturally became guarded. Even on this score, Scientology was an exception for few of them were in fact “deprogrammed” at the instigation of their parents or other relatives.

Keeping in mind the complex factors sketched above. I can note that friction, tension, alienation, lack of communication between members of new religious movements and their parents is no more nor less than the same rifts that take place in every family known to me. Nor, in fact, are these rifts anything new in the history of religion. In his quest for spiritual

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enlightenment Gautama Buddha, born a Hindu prince, not only abandoned his parents, much to their dismay, but also his wife and children. Moses, reacting to the bondage of Israelite slaves under Egyptian domination, slew one of their persecutors and fled the comforts of the Egyptian court to encounter God is the desert of Midian. In the Middle Ages, both Thomas Aquinas, offspring of Neapolitan nobility, and Francis of Assisi, son of a wealthy Umbrian merchant, abandoned as youths their lives of ease and privilege, joined the urban youth movement of [sic] known as the Mendicants (Latin for ” beggars”), and took vows of absolute poverty, chastity and obedience. Both Thomas and Francis were kidnapped and imprisoned by their parents and relatives who, to no avail, used methods remarkably like those used by modern  “deprogrammers” in order to get them to abandon their nays. St. Thomas received the title “Angelic Doctor” by the Catholic Church because he resisted the blandishments of a prostitute employed by his brothers to get him to break his vow of chastity. Orthodox churchmen labelled members of the new mendicant orders, known today as Dominicans, Franciscans and Augustinians, as “dementes” (Latin for “insane”) and “filii diaboli” (”sons of the devil”). St. Thomas even wrote the first anti-deprogramming treatise, entitled ” Contra pestiferam doctrinam retrahentium homines a religionis ingressu” (”Against the Pernicious Doctrine of Those Dragging Youth Away from Entering Religious Life”).

Martin Luther instigated a lifelong alienation with his father, who wanted him to become a lawyer with a lucrative income, by joining the Augustinian order. In turn, Luther created a rift within Christendom itself by attacking. the practice of indulgences and holding to the doctrine of

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Justification by faith alone. Similar rifts and alienations have occured in American religious history, especially in the events surrounding the Great Great Awakening, which American historians recognize as a primary source for the rise of the democratic sentiment in America and the the [sic] principle of freedom in religious conscience and practice. The Great Awakening was the beginning of revivalism in American, a religious tradition still espoused by many, most notably the Rev. Dr. Billy Graham. As noted by Jonathan Edwards in his “Faithful Narrative” (1737), the New England revival of religion began among the youth. This resurgence of piety among the young stirred such staid Harvard divines as Charles Chauncey to score the revivalists for “a certain wildness …discernible in their general look and air.” Today deprogrammers attempt to convince parents that their offspring, often well educated and legally of majority age display “glazed eyes” or have been ” zapped” into being ” zombies” by the single glance of a guru’s eyes. The religions havechanged but the charge remains the same.

In past and present religious history alienation from family and kin has been not only an unintended, and seemingly unavoidable. byproduct of the conflict between the old and the new but also a fundamental tenet of religious practice. Thus the monks and hermits of the third century onwards practiced ” withdrawal from the world” because the world and its ways were believed to be “corrupt” and “under the dominion of the Prince of Darkness.”

The eremites of Asia Minor not only withdrew from the world but also their fellow monks, living alone in prayerful solitude in caves still to be seen in present-day Turkey. Members of contemplative orders, both in the West and the Far East. enter monasteries where rules of silence and solitude are so great

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that phone communication and letters to and from relatives are prohibited or restricted to a few feast days. As a member of the Franciscan order from 1958-64, I was alloyed no phone communication with my relatives for the entire year of my novitiate. wan not alloyed to attend my grandfather’s funeral, and received only one letter a month, which vas subject to inspection by the master of novices.

The “disconnection” between parents and adult offspring in the new religions appears to be part and parcel of the immemorial conflict between the old and the new. Though the conflict may be immemorial, it is not immutable. My acquaintence with enduring members of the new religions, including Scientologists suggests that over time familial rifts and disagreements become healed, especially as the member assumes positions of responsibility, gets further higher education, or marries and has children.

(b) The information gathering efforts of the Church of Scientology have stirred not a little controversy. I have heard it described as an “intelligence service” on the order of the Central Intelligence Agency and other governmental agencies. Though I in no way condone the violation of the lawful administration of government and the civil rights of others in the gathering and use of information, this aspect of the Church of Scientology deserves to be put in perspective.

First, scholars in many fields have noted that we live in an “information culture” of centralized data banks, computerized credit records, and electronic networking, etc. Just as early Christianity participated in the general culture of the Greco-Roman mystery religions with whi ch it shared

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such initiation rituals as baptism, so the new religions of our time share in the informational “networking” culture of the late twentieth century. The speed with which information of all kinds travels among the new religions has continually amazed me, but the same amazement holds for the general business culture. Secondly, Scientology is not alone among religions in having “intelligence” gathering services. It is well known that the Swiss Guards, formerly the mercenary protectors of such European monarchs as Louis XIV and now the protectors of the Pope of Rome, have intelligence units which gather and share information with other national intelligence agencies for the protection of the Pope and the benefit of the Vatican State. Furthermore, most religions — among whom I can name Greek Orthodoxy, Lutheranism, Presbyterianism, Episcopalianism, and Mormonism — have ecclesiastical tribunals, courts and councils of elders for maintaining purity of doctrine and practices. These ecclesiastical offices have information gathering powers for trying cases of heresy and church crimes such as sacrilege, annuling marriages, dispensing communicants from ecclesiastical impediments, compiling confidential dossiers on candidates to high ecclesiastical office, supervising seminaries, divinity schools and other institutions under ecclesiastical supervision.

Thirdly, while there has no doubt been some intrusion into government administration on the part of the new religions, their information gathering powers are dwarfed by those of modern states. The legislative, executive and Judicial branches of government in the 1970’s weighed heavily upon the new

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religious movements. Witness the number of bills both in Congress and in State legislatures which espoused investigations into the “cults,” denial of charitable status, conservatorships foe deconverting adherents, and penalties for fraudulent belief. Local judiciaries have issued conservatorships on scanty evidence. Agencies of the executive such as the Immigration and Naturalization Service, the Internal Revenue Service, the Food and Drug Administration have been called upon to examine, scrutinize and issue reports about the internal practices of the new religions in a way that would arouse national furor if used against mainline religions. The response on the part of some new religions — among whom I would include the Church of Scientology — has been a sense of persecution and sometimes — an aggressive pursuit of such laws as the Freedom of Information Act. In such a charged atmosphere neither religion nor state can flourish in their proper spheres. As the relation between the new religions and the state gets clarified and rectified by the higher courts, my expectation is that these skirmishes will diminish on both sides and both will be wiser and less wary of one another. Only then will religion and state be less inclined to view one another as conspiratorial enemies, which, unfortunately is the present perception on both sides.

(c) Another area for which the Church of Scientology is faulted is the manner with which it seemingly controls the daily life of its members, in general, and the apparently harsh discipline imposed upon Sea Org members in the Rehabilitation Project Force (RPF), in particular. In Scientology the Sea Organization is composed of highly dedicated members who take vows of eternal service and live a life in community. The RPF discipline is used

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when Sea Org members find themselves “non productive” or, in Scientology terminology, “stat crashers.” In these situations, members are put on a definite schedule, spend several hours a day studying Scientology Technology, and have co-auditing sessions to achieve what believers call ” release” and “full cleanup.” Members do physical labor, but also get lots of healthy food and lots of rest.

Critics of the new religions charge that this kind of discipline constitutes ” mind” and “milieu control” of the sort used by the Chinese Communists to enforce political re-indoctrination after the Communist takeover in 1949. The aim and goal of the RPF however is entirely different than that of the Communists in China. The Communists wanted to guarantee political uniformity, whereas the Scientologist wants spiritual ” release” and ” enlightenment” as “an immortal thetan.” Secondly, Chinese peasants were forced into the re-indoctrination programs, whereas the Scientologists freely participates in the RPF program as a consequence of his or her vows of eternal service. Thus the proper comparison is not to political but to spiritual disciplines, which are present in every religion known to me and which I have undergone myself.

When a young adult enters a contemplative order such as the Trappists or Carmelites, that person takes vows of poverty, chastity and obedience to superiors. The novice, or new member, cuts all ties with family and worldly concerns. Men receive the tonsure (shaving of the head) and women have their locks shorn to signify the renunciation of worldly vanity. In ceremonies, involving women entrants into religious orders that I have witnessed, the nun

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enters the chapel wearing a bridal garment to symbolise that she is about to enter a spiritual marriage with Christ. The garments are then removed, her hair is shorn, and she is invested with the habit of the order, which is often made of plain wool.

Contemplatives, soaks, mendicants and other religious societies not only take the three vows mentioned above, but also commit themselves to other religious practices such as long hours of meditation each day, periods of manual labor, midnight choir (the singing of Psalms), fasting during Lent and Advent, study of the rule of the order and other spiritual writings, and silence. As member of the Franciscan Order (which I left voluntarily and was free to do so). I myself freely submitted to the religious practice of flagellation on Fridays, striking the legs and back with a small whip to mortify the desires of the flesh and to commemorate the flagellation of Jesus Christ before his crucifixion. In the tradition of St. Benedict’s dictum “ora et labora” (Latin for “pray and work”), I also spent several hours each day, with the exception of Sunday, doing physical labor, including woodworking, tending a garden, cleaning floors, washing laundry, peeling potatoes, etc. These tasks were assigned to me by my superiors, and because I took a vow of obedience, I did them. Furthermore, as a mendicant, I took a vow of absolute poverty such that I owned absolutely no material possessions, including the robe which I wore. When rules of the monastery are broken, monks and friars are regularly assigned menial tasks as penances. Compared with these Roman Catholic practices, the practices of the RPF are not only not bizarre but even mild.

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The RPF program can also be compared to spiritual retreats conducted by many religions in order to restructure believers’ lives, including their secular life, and to provide refreshment for the soul. The Jesuits, much like the Sea Org members, have a period of retreat and rededication which is called Tertianship after undergoing a period of temporary vows. During Tertianship the Jesuit practices the “Spiritual Exercises” of St. Ignatius of Loyola, founder of the Society of Jesus. After Tertianship a Jesuit takes a fourth vow of special obedience to the Pope, much as the Sea Org members take vows of ” eternal service.”

Just as the Sea Org members who go through the RPF discipline to obtain “release” and “full cleanup” for the sake of redemption or salvation, so religions around the world have practiced sometimes stringent disciplines in order to attain “samsara” (escape from the cycle of rebirth in Hinduism), “moksa” (Buddhism), “satori” (Zen), the “beatific vision” (Roman Catholicism, Greek Orthodoxy), or communication with heavenly beings such as angels or transcendent “Masters” such as the theosophic Master of St. Germain believed in by the I Am religious group. (Perhaps it is worth mentioning that the beliefs and practices of the I Amers were the subject of the famous Supreme Court case U.S. v. Ballard in 1944).

It is my opinion that the spiritual disciplines and practices, such as the Rehabilitation Project Force, of the Church of Scientology are not only not unusual or even strange but characteristic of religion itself when compared with religious practices known around the world. Contrary to the generally second-hand opinions of outsiders and to the claims of disaffected

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members, whose motives are suspect, I would say that submission to such practices is not due to browbeating on the part of church leaders but follows as a natural consequence from a free religious commitment to a spiritual discipline in the first place.

(d) Another religious practice of the Church of Scientology which has come under scrutiny is the issue of the confidentiality exercised with respect to the auditing records of members and especially of the “pre-clear files” of upper-level church members. I find the practice of the Church of Scientology in this regard fully in keeping with the practices of other religions.

In general, there are two fundamental reasons why churches, including the Church of Scientology, seek confidentiality with regard to unauthorized examination of spiritual records. The first is to preserve the sanctity of the spiritual privacy of the believer. The second is to safeguard the integrity of a religion’s innermost sacred doctrines.

In regard to the first reason, the spiritual privacy of the believer, Scientology is like every religion known to me. The Roman Catholic Church protects the priest-penitent relationship with the severest of sanctions, including dismissal from priestly office and expulsion from the Church itself. Upon ordination priests take an oath of the “confessional seal” before they are allowed to hear the confession of sins and administer official spiritual counselling. My pastor, a Monsignor in the Roman Catholic Church, has testified to me that he would undergo imprisonment and death before revealing the contents of any confession, whether this revelation was

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demanded by the President of the United States or by the Pope of Rome. Furthermore, each Roman Catholic archdiocese possesses a sealed religious archive to which only the Bishop or Vicar General may grant access. Such archives include files on the spiritual lives and morals of the clergy and the religious orders, dispensations from impediments to the reception of the sacraments like marriage or ordination, judgments from ecclesiastical trials, unproven denunciations, episcopal admonitions and reprimands to believers. The strict regulations regarding the use of these archives are contained in what is known as the “Corpus Juris Canonici” or Code of Canon Law. Among such regulations are included rules for documented authorization of the use of the files, oaths of absolute secrecy, control over the amount of information to which a user may have access, limitations on historians researching deceased persons, etc. Abuse of the archive and unauthorized divulging of information can bring severe penalties, including demotion from office, penances and even excommunication.

Most Protestant denominations have similar regulations and penalties in their respective church polities. Likewise Scientology has codes of conduct for auditors and other officials regarding authorized files. The Church does not allow any outsider access to a parishioner’s files as a matter of priest-penitent privilege, as is the case with other churches. Confidentiality of this type of material touches on the nerve center of religion itself. The historical record shows that no church lightly suffers the intrusion into such records by the government or any other outside agency. The history of the Reign of Terror in France reveals the great number of priests who went to the guillotine rather than break the

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confessional seal.

The second reason, the safeguarding of a religion’s innermost religious doctrine, is also a motive for preserving the confidentiality of ecclesiastical files and records. As an outside scholar, I naturally had no access to Scientology auditing files. My interviews with members, however, showed that during the auditing process, especially with regard to upper level embers, [sic] matters calling for religious interpretation or appointment to higher church office often came up. The same kinds of questions come up in Roman Catholicism, Episcopalianism and the Orthodox Church when fundamental beliefs come into question or someone is a candidate for a bishopric or higher office and the files collected on the candidate are protected in the exactly same way. [sic]

Historically speaking, many past religions were led toward policies of confidentiality because public dissemination of personal spiritual information and more complicated religious doctrines led to abuse, outside ridicule of beliefs, theological disputes which spilled over into the secular arena and hostile misinterpretation. A religion’s guarding of its personal ecclesiastical files and its innermost teachings is like a sacred patent, comparable to the secular practice of protecting industrial patents and processes on the part of business corporations. Failure to protect these sacred patents would violate each believer’s trust and lead to the disintegration of the religion itself.

14. Throughout religious history mangy acts and practices of religious groups have elicited strong reaction from the surrounding society. Thus the Romans saw the early Christian ceremonies as “superstition” and as occasions for plotting sedition. Luther scored the ceremonial pomp of the Roman Curia as “more corrupt than Babylon and Sodom.” Many outsiders and even Catholics contemned Jesuit moral theology as “casuistry” with such great vehemence that the term ” Jesuitical” became synonymous with the terms casusitic and devious. To the westerner the Jain practice of “ahimsa” — not harming any form of life, even to the extent of wearing masks like those used in surgery lest a gnat be inadvertently killed — can seem downright ludicrous. The Amish practice of not wearing buttons or using tractors and electricity because they are showy and hinder the “plain life” enjoined by the Bible strike most Americans as unprogressive, at worst, and quaint, at best.

Many find the practices of Jewish Orthodoxy unusual and incomprehensible. Orthodox Jews follow strictly the laws of Deuteronomy and Leviticus. They do not mix milk with meat, weave linen with wool, sow wheat with barley or eat any animal which mixes the categories of creation sketched in the first chapter of the Book of Genesis as a matter of religious principle. All such mixings are deemed “unclean” and contrary to God’s will in ” separating” or “dividing” the orders of creation. To the Orthodox Jew these practices entail great inconveniences, such as keeping two completely separate sets of eating and cooking utensils. These food laws are not kept under compulsion but out of a desire to keep holy the ways of the Lord.

To the outsider, to sceptics and to agnostics, the religious practices I have discussed above might appear as nonsensical, primitive, devious, manipulative, or oppressive. But, just as belief is in the mind of the

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believer, so religious practice issues from the body of the believer to give concrete evidence and assurance of release from sin, impurity or spiritual ignorance and to signify to all the hope of redemption, salvation or enlightenment.

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Given this 14th day of July, 1985, in St. Louis, Missouri.

[signed]
Frank K. Flinn, B.D., Ph.D.

State of Missouri County of St. Louis

) )ss )

Sworn and subscribed before me this 14th day of July, 1985
[signed] Martha (illegible)
Notary Public
My commission expires 2/27/87