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"legal daily report", of which I received a copy. This report
contained summaries of everything that occurred on any of
Scientology's lawsuits. Miscavige would issue orders and call
meetings concerning these matters on a regular basis. Litigation
is very costly and can result in severely adverse PR. Therefore,
Miscavige was never willing for the decisions concerning it to be
turned over to anyone else.
THE DEATH OF FLO BARNETT
11. Flo Barnett's suicide was a scandal within the inner circles
of Scientology. This was not due to the fact that she supposedly
committed suicide, but due to the f act that she had become a
member of a declared. enemy group, David Mayo's Advanced Ability
Center. She was receiving auditing and assistance from this group
and at the time of her death, possessed a pack of the NED for OTS
(secret upper level auditing procedures) which were believed to
have come from David Mayo's group. Flo Barnett's membership in
this group made her a suppressive person as she was actively
"squirreling" and a member of a suppressive group. The fact that
David Miscavige was linked to her by familial ties was extremely
repugnant to him and to his wife, Michelle Miscavige. David
Miscavige's comment upon her death was that "the bitch got what
she deserved." His wife Shelly, did not appear to feel any
different about it than David. I asked Shelly if she was doing
alright since receiving this bad news. She said that personally
she was doing just fine and that this was an excellent
opportunity to find out where the NED for OTs materials had come
from and to use it as leverage against Mayo. She also stated that
it was not surprising that this happened to her mother since she
had been "squirelling". The circumstances of the deaths of both
Flo Barnett and Yvonne Jentzsch are very relevant to the issues
in this case, as I understand them to be.
THE PURPORTED PURGE OF THE SCIENTOLOGY CRIMINALS
12. Hendrick Moxon, currently an attorney for Scientology in this
very case, and a member of the Sea Organization, was a prominent
participant in the criminal activities of the Guardian's Office.
Prior to becoming an attorney at Scientology's expense, he was a
Guardian's Office staff member in Washington, D.C. Moxon was
involved in the Scientology conspiracy to infiltrate the U.S.
government. This conspiracy was uncovered by the F.B.I. in 1977.
Scientology then stipulated to their crimes which included
Moxon's involvement in those crimes. Nine senior Scientologists,
including Hubbards, wife, went to jail as a result of these
criminal activities conducted by, and on behalf of, the Church of
Scientology. I became familiar with certain documents, which are
attached hereto, while being in charge of the 1981/82 040 mission
to take over the USGO. Moxon was involved in the criminal
activity, attempted cover-ups and obstruction of justice. The US
government subsequently prosecuted 11 top officials of
Scientology and named Moxon as an unindicted co-conspirator. (See
Exhibit C, pages 212-214). This is but one small example to
illustrate that Miscavige has not and will never offload the
criminal element from Scientology's ranks. Miscavige is well
aware of Moxon's status and maintains him as a high level legal
staff in the Sea Organization.
As a practicing Scientologist and in-house Scientology lawyer,
Kendrick Moxon's first duty is to protect Miscavige and
Scientology. This duty is paramount to any duty he might
otherwise owe the Court or the law.
13. Scientology was created by L. Ron Hubbard in the 1950's. The
policies and beliefs of Scientology were established by L. Ron
Hubbard. L. Ron Hubbard created the Guardian's office based on
his beliefs and ideals. The Guardian's Office was headed by his
wife, Mary Sue Hubbard. During the late 1960's and the 1970's,
many, many crimes were committed internationally by the
Guardian's Office. Hubbard was well aware of the Guardian's
Office activities and this is apparent from the reams of paper
containing his various orders to the Guardian's Office.
The policies and beliefs and ideals that established Scientology
and the Guardian's Office are still in place today, just as they
were in the 1950's, 1960's, 1970's and 1980's. These have not
changed as it is against the very heart of Scientology to change
or alter any of Hubbard's teachings and belief. The activities of
the Guardian's Office have not disappeared any more than
Scientology's "enemies" have. These activities are carried on by
the staff of the Office of Special Affairs ("OSA") and their
hired private investigators who ostensibly work for Scientology
lawyers, and are thus protected by the attorney work product
privilege.
Scientology learned the hard way to keep its criminal activities
at arm's length. An example of this is private investigator,
Eugene Ingram, who was hired by Miscavige, to get the evidence on