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adverse attorney, Michael Flynn, for supposedly forging a check
on L. R. Hubbard's account. Ingram paid money to Ala Tamimi, a
criminal in jail, for a statement saying he was hired to forge
the check by Michael Flynn. I was then informed by Mark Rathbun,
then Miscavige's legal executive in ASI, that Ingram bribed
Tamimi in order to get Michael Flynn charged criminally. After
this incident failed, I learned that Ingram was spending quite
some time living in Mexico in order to avoid the authorities
investigating the matter.
MISCAVIGE STRIKING SCIENTOLOGY STAFFERS
14. Contrary to the claims in his February 4, 1994, declaration
Miscavige has struck staff members when they do things he
dislikes.
In 1981, I witnessed him hitting John Axel, a Sea Org member in
the mouth in 1982. Miscavige had two other tall male staff
members to back him up when he hit John Axel. This despite the
fact that John Axel is a fairly small and very mild-mannered
individual. Miscavige also does such things as set up photos of
staff members who have fallen into disregard and use them as
targets for pistol shooting.
I witnessed him doing this with the Golden Era Musicians, Of
which Fernando Gamboa was one of his targets.
THE DEATH OF HUBBARD
15. When I arrived at Hubbard's ranch, in San Luis Obispo,
following his death, I was informed by Miscavige that Hubbard was
dead and that he did not want to see "any grief bullshit about
it."
Earl Cooley, Esq. and others convinced the San Luis Obispo
coroner not to do an autopsy on Hubbard's body which was cremated
approximately 24 hours after death. Miscavige then announced to
the Scientology world that Hubbard had "dropped the body" and
would continue his work elsewhere. Scientologists believe that
upon death the person drops the body, picks up another body and
continues to serve Scientology. This is how the billion year Sea
Organization employment contract is performed.
16. I was aware just before Hubbard's death, that certain IRS
indictments were about to be handed down against Hubbard.
Miscavige reportedly said that "the only way to stop it now is if
the old man [Hubbard] dies."
17. I was one of the small group summoned to the Hubbard ranch
after he died. Vaughn Young and David Miscavige were also
summoned to the ranch.
THE DEATH OF MIKE HINDER'S BABY
18. Mike Rinder, a member of the CMO International and his wife,
Kathy, had a newborn baby in Clearwater, Florida in the early
eighties. Mike Rinder was in Gilman Hot Springs, California at
the time. This baby died when only a few days old. The baby had
received Hubbard's baby care technology. After the baby died,
Rinder asked to receive some time off to go to be with his wife
and family.
When Miscavige was told of this, he responded that time off was
"bullshit" and Rinder did not need time off, he just needed to
work as his stats ("statistics") were down. Besides the baby
would get another body and there was nothing to be so upset
about.
END OF CYCLE PROCESSING
19. The term "End of Cycle" does exist in Scientology. it means
to terminatedly end something. There are many Scientology
processes and routines that incorporate this concept. The idea
that someone ends cycle when they die is a Scientology concept
and is expressed in Hubbard's writings. (See attached Exhibit D)
THE TIME MAGAZINE ARTICLE WAS NOT OF AND CONCERNING CSI
20. I have read the Time Magazine article entitled "Scientology
Thriving Cult of Greed and Power" published on May 6, 1991. In
particular, I have read two paragraphs of that article concerning
comments allegedly attributed to Steven Fishman and Dr. Uwe
Geertz.
There are references to "Scientology" and "the church" in these
two paragraphs. I have also been advised by Graham E. Berry,
Esq., that the Church of Scientology International alleges that
the words "Scientology" and "the Church" were "of and concerning"
Church of Scientology International ("CSI"). This allegation is
absurd and false. CSI is a management church only. It has no
members. In essence, it is a trademark/copyright licensing
vehicle and a financial conduit. Moreover, the corporations of
Scientology are a carefully contrived sham and shell structure
intended to confuse and divert litigants, the courts and the
I.R.S. Indeed, Mission Corporate category sort out ("MCCS"), of
which the MCCS tapes were a part, (see the Zolin case) was part
of the creation of this corporate shell game.
21. Accordingly, it is absurd to allege that the words
"Scientology" and "the church", as used in the relevant sections
of the Time Magazine article, refer to anything other than
Scientology or the Church generally and/or generically.
Certainly, they are not of and concerning CSI.
SUPPRESSIVE PERSONS AND FAIR GAME
22. The legal strategy of Scientology and the existence of