I, MICHAEL J. FLYNN, swear under the pains and penalties of perjury under the laws of Massachusetts, California, Nevada, Florida and the United States, that the statements made in this affidavit are true.

1) On Monday, July 23, 1984, I received a telephone call from a reporter from the Boston Globe who advised me that affidavits were being filed on that date in the case of Miller v. Flanagan, Los Angeles Federal District Court, relating to claims by an individual named Ala Tamimi, that I had participated with him in the attempted forgery of a two-million dollar check drawn on an account of L. Ron Hubbard. Up to that date, I had never heard the name Ala Tamimi. To this date, I have never met with him, seen him, talked to him on the telephone, or had any involvement with him of any nature or description. He is a total stranger to me. The meetings, conversations, and involvements described by Tamimi in his affidavit with respect to me are completely false. As to Tamimi's participation in the check incident, I have no knowledge of what he did or did not do, but the first information that I have ever received relative to his participation in this incident was on July 23, 1984, when the reporter called me on the telephone and advised me of Tamimi's affidavit.

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2) I first learned of an attempt to pass a two-million dollar check drawn on the account of L. Ron Hubbard on June 14, 1982, while I was staying at the Holiday Inn Surfside in Clearwater Beach, Florida. I was in Florida at that time as special counsel to the City of Clearwater for the purpose of dealing with various matters in the aftermath of the hearings held before the Clearwater City Commission in May 1982, relative to L. Ron Hubbard and the Church of Scientology. While at the Holiday Inn Surfside, I received a telephone call or calls from Mr. Joseph Snyder of Security Management Services, Inc., Boston, Massachusetts, who had been retained by the Bank of New England for the purposes of finding L. Ron Hubbard and obtaining information from Hubbard as to the circumstances surrounding the two-million dollar check. Mr. Synder informed me that approximately one week prior to his phone call, someone had attempted to pass a two-million dollar check on an account of L. Ron Hubbard in the Middle East Bank in New York City.

3) I had met Mr. Snyder for the first time many months prior to his calling me in Florida, when I delivered a speech concerning L. Ron Hubbard and the Church of Scientology to a group called the American Society for Industrial Security. The speech was well received and related to the intelligence/espionage tactics of Scientology which kindled the interest of many of the investigators present including Mr. Snyder. The speech to the group of which Mr. Snyder was a part was the only involvement with him that I had ever had

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of any nature or description up until the time that I received the phone call from him in June 1982 concerning the check.

4) When Mr. Snyder called me on or about June 14, 1982, he said that he had attended the speech that I had given relative to Hubbard and the Church of Scientology and that he was working in the employ of the Bank of New England for purposes of finding Hubbard. He was reluctant to give me any details on the telephone but agreed to pick me up at Logan Airport in Boston when I arrived back from Clearwater, Florida. After returning from Florida, I met with Mr. Snyder and his colleague, Andrew Fink, on several occasions, provided them all of the information that I could relative to Hubbard and Scientology, and thereafter I had a telephone conversation with Mr. Kevin Sheehan, an executive at the Bank of New England relative to the check incident.

5) In November 1982, as a result of several factors set forth below, Ronald DeWolf, the oldest son of L. Ron Hubbard, decided to bring a "missing person" petition in Riverside Probate Court in order to obtain a judicial determination of his father's legal status. I represented Mr. DeWolf in this petition. During the pendency of the petition, I was contacted by numerous individuals both inside the Church of Scientology and outside relative to circumstantial evidence suggesting that some of L. Ron Hubbard's closest aides may have been involved with the

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check incident. This information included the fact that one Jan R. Goergen, president of Intercap, Ltd., L. Ron Hubbard's primary investment advisor, had received large sums of money from the same Hubbard account at the Bank of New England on which the 2 million dollar check was drawn, and that Goergen was involved in several gem transactions involving L. Ron Hubbard. Most significantly, the vice president of that company, David Delozier, had been indicted by an Arizona Grand Jury and Delozier was then being investigated for his contacts with organized crime.

6) During the pendency of the Probate petition relative to Hubbard's missing person's status, and in other litigation in the United States relative to Hubbard and the Church of Scientology, substantial evidence was produced that Hubbard's name had been forged on several legal documents, that David Miscavige had allegedly notarized Hubbard's signature during a period when both the Church of Scientology and Hubbard's attorneys had claimed that there were no means to communicate with Hubbard, that no one had communicated with him since February 1980 and that no one connected with the Church of Scientology had seen him since that period of time. However, David Miscavige was then the highest ranking official of the Church of Scientology. Additionally, Mary Sue Hubbard had filed affidavits in various cases stating that she had not seen her husband since late 1979. However, evidence was adduced that she and her husband had purportedly signed powers of attorney together in July 1980, in Los

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Angeles, approximately seven months after she had allegedly last seen Hubbard. The foregoing facts, together with the indictment of Intercap's principal, David Delozier, together with the attempted passing of the two million dollar check, which was attempted at the same time that large sums of money were paid to Intercap by Hubbard, together with the fact that Hubbard had been defaulted in the Cooper case and was about to be defaulted in other cases, and lastly based on the fact that Hubbard's own attorney, Alan Goldfarb, stated that Hubbard was a missing person, all warranted a finding that Hubbard was indeed missing. However, the day before the Riverside Probate Court was going to rule on Hubbard's missing person's status in connection with a motion for summary judgment filed by Mary Sue Hubbard, a declaration purportedly signed by L. Ron Hubbard was produced stating that his affairs were being handled by Author Services, Inc. Based on the declaration of L. Ron Hubbard, the Court adjudicated that L. Ron Hubbard was not a missing person.

7) During the pendency of the Probate proceeding relative to Hubbard's missing person's status, Hubbard's attorneys retained Eugene M. Ingram. Ingram had previously been dismissed from the Los Angeles Police Department for pandering, pimping, conspiring to run a house of prostitution and aiding narcotics dealers. Ingram was also indicted for conspiracy to obstruct justice and on the pimping, pandering and prostitution charges, but the indictment was later

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dismissed.

8) Between May 1983 and the present, Ingram, other private investigators including Andrew Palermo of Boston, Massachusetts, and various Scientology agents, have engaged in a consistent course of conduct to harass, intimidate and to "frame" me for the check incident. This conduct includes close constant surveillance by as many as four automobiles at a time following me in Boston, Los Angeles, and other locales, contacting my clients and informing them that I was a drug dealer, that I was connected to organized crime, and that together with my brother, Kevin Flynn, I had attempted to pass L. Ron Hubbard's two million dollar check, for which I was going to be indicted, that I was going to be disbarred, and similar statements.

9) In January 1984, Ingram placed full-page ads in the Washington Post, the New York Times and the Boston Globe offering a one hundred thousand dollar reward for information leading to the arrest and conviction of the person or persons responsible for the two million dollar check incident. Individuals responding to the advertisement including several newspaper reporters such as Beverly Ford of the Boston Herald and Glen Fowler of the New York Times were told that the primary suspects in the check incident were Michael Flynn and his brother, Kevin Flynn and that evidence existed to prove that Kevin Flynn had trespassed into various areas of the Bank in order to steal checks of

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L. Ron Hubbard. Ingram used the reward offer as a means to pay Ala Tamimi and his brother, Akil Tamimi a large sum of money (at least $25,000) for purposes of signing a false affidavit. Tamimi is currently wanted in four countries, and he has been indicted for fraud, and in two separate cases for perjury.

10) On Monday, July 23, 1984, Hubbard, and the Church of Scientology through its attorneys John Peterson and Donald Randolph, launched an international "black propaganda" campaign against me by filing the false declarations of Ala Tamimi and Akil Tamimi in the Los Angeles Federal District Court, issuing press releases throughout the United States which were sent to most of my clients and friends, and holding press conferences in Los Angeles, Boston, New York, and Clearwater, Florida. In the press releases, the press conferences, television and radio appearances, and in private interviews with individuals from the media, Ingram, Heber Jentzsch and John Peterson have falsely stated that I offered $400,000 to Ala Tamimi to forge one of L. Ron Hubbard's checks. This media blitz to destroy my reputation based on completely false testimony of an indicted perjurer, (Tamimi) procured by Eugene Ingram, a known sex offender, and paid off by the Church of Scientology whose top eleven leaders have all been convicted of a variety of crimes for which they were incarcerated in Federal prison, is despicable beyond description. The media blitz was timed to defuse the recent juducial findings made by Judge Paul Breckenridge of

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the Los Angeles Superior Court in the case of Church of Scientology v. Armstrong, C.A. No. C 420 153, wherein Judge Breckenridge ruled that Hubbard was a "pathological liar" and that the Organization was a "massive fraud" that engaged in a "form of blackmail and extortion against its members." Similarly, a high court judge in London in a 50-page opinion, ruled that Scientology was "immoral, corrupt and sinister" and that its methods were "grimly reminiscent of the ranting and bullying of Hitler and his henchmen." In an effort to counter the growing world-wide awareness of Scientology, its methods and practices, Hubbard, Peterson, Ingram, and agents of Hubbard have implemented the familiar policy of "attack the attacker" for purposes of destroying my reputation based on knowlingly false testimony.

11) As a result of the constant, close and harassive surveillance, and as a result of the frame-up now being engineered against me, which is being disseminated in the news media world-wide, my family and I have suffered extreme emotional anguish, great loss of reputation, and substantial interference with my law practice.

12) The pattern of conduct now engaged in by Hubbard and his agents is similar to past activities they have engaged in against their critics, including the frame-ups of Gene Allard, Paulette Cooper, and Gabriel Cazares, the mayor of Clearwater, as well as numerous harassive activities taken against judges, lawyers, the American

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Medical Association, reporters, and anyone who has attempted to speak out against Hubbard and his Organization. For some examples of this type of conduct, I have attached the "Sentencing Memorandum" of the United States Government hereto, as Exhibit A.

13) The Church of Scientology and Hubbard through its agent, Eugene Ingram, have also procured an affidavit from George Edgerly stating that I offered a bribe to Edgerly not to testify in his own defense in exchange for the payment of $500.00 per week to Edgerly's wife, that Edgerly accepted this proposal and that I paid him $1,000.00 several weeks later. The statements of Edgerly are completely false. Edgerly has been convicted of first degree murder and is presently serving a life prison sentence in Massachusetts. He has also been convicted of fraud, and he had previously been indicted for the murder of his wife. He is a well-known and infamous criminal in Massachusetts. The fact that Hubbard and Scientology would accept as true the statements of a convicted murderer is indicative of the desperate measures that they are now willing to employ in order to rebut the truthful findings of Judge Breckenridge in the Armstrong case and of Judge Latey in England.

14) The Edgerly and the Tamimi affidavits both procured from infamous criminals by Eugene Ingram in exchange for the payment of large sums of money is a transparent attempt to frame me as Hubbard and his Organization have previously

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done or attempted with Paulette Cooper, Gabriel Cazares, and Eugene Allard. See for example, documents attached hereto as Exhibit B, reflecting "operations" against the above named people by Scientology. Hubbard and his Organization have also attempted to victimized judges and lawyers who have fought to bring them to justice. See for example, the article attached hereto as Exhibit C, "Scientologists' War Against Judges."

In sum, the recent "attack" against me by Ingram and Hubbard based on the false declarations of convicted criminals, both of which are now serving time in prison, is transparent and outrageous. I have turned the entire matter over to the United States Attorney's Office in Boston, Massachusetts and have requested that criminal charges be brought against Ingram, and others responsible for manufacturing this outrageous attempt to frame me.

Finally, the Church of Scientology and the Hubbards have unsucessfully attempted to disqualify me from representing my clients in other Scientology related proceedings. I have attached hereto as Exhibit D, a copy of the Los Angeles Superior Court's ruling in the recent case of Church of Scientology v. Armstrong, No. C 420 153, in which disqualification was denied. I have also attached hereto as Exhibit E a copy of the Court's decision in that case.

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Signed under the pains and penalties of perjury this 10th day of August, 1984.