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22. The legal strategy of Scientology and the existence of
numerous potential legal problems, some of which are set forth
below, were known to me when I was a staff member in
Scientology.. Enemies of Scientology are deemed to be
"suppressive persons" ("SPs"). One becomes a "suppressive person"
by doing a suppressive act, such as suing Scientology as a
litigant or lawyer. In the jargon of Scientology, when one is
"declared" this means that one has been declared a "suppressive
person" and, therefore, may be harassed, hurt, damaged or
destroyed without regard to truth, honesty or legal rights. It is
considered acceptable within Scientology to lie, cheat, steal and
commit illegal acts in the name of dealing with a "suppressive
person."
23. This practice or policy is sometimes referred to as the
policy of "fair game." In the jargon of Scientology, a person who
is declared is understood to be a suppressive person ("SP") .
This means that the person is "fair game." The fair game policy
was issued in the 1960s. It was never canceled. A document was
issued for public relations reasons that purportedly canceled
"fair game"; however, that document stated that it did not change
the manner of handling persons declared "SP." In reality, the
purported cancellation of fair game is at most a matter of
semantics. Enemies of Scientology are treated as fair game.
24. Because of my position and the regular reports that came
across my desk I know that throughout my presidency of RTC, fair
game actions against enemies were commonplace. In addition to the
litigation tactics described below, fair game activities included
burglaries, assaults, disruptions of enemies' businesses, spying,
harassive investigations, abuse of confidential communications in
parishioner files and so on. I specifically recall seeing one
report regarding attacks against Bent Corydon after Scientology
became aware that he was writing a book against Hubbard.
FRIVOLOUS SCIENTOLOGY LITIGATION
25. Other Hubbard writings encourage Scientologists to pursue
litigation purely for harassment without regard to the merits of
a claim to cause enemies to fold. Hubbard's writings state: "The
purpose of the suit is to harass and discourage rather than to
win ... The law can be used very easily to harass and ... Will
generally be sufficient to cause (the enemy's) professional
decease. If possible, of course ruin him utterly." (Hubbard,
"Magazine articles on Level 0 Checksheet" American Saint Hill
Organization 1968.)
26. As President of RTC and a Sea Organization member, I attended
meetings concerning the numerous legal actions involving
Scientology organizations. During this time period, I had
personal access to all legal documents having to do with RTC. I
received a report every day on my computer that included a
synopsis of each on-going legal case involving Scientology. I
received, or so I was told, copies of every major motion filed in
cases involving Scientology was on the "approval lines" for legal
documents dealing with RTC.
During this time period, I had the option of attending legal
meetings, although some were mandatory. I attended many
litigation meetings and became generally aware of Scientology's
dirty tricks and legal maneuvers. On specifics, I frequently
deferred to in-house and outside counsel; however, at least in
theory, I was the head of RTC and had access to any business or
litigation "secrets" of Scientology.
27. It is the stated policy and practice of Scientology to use
the legal system to abuse and harass its enemies. This crude,
fundamental directive of Scientology is no secret. The policy is
to do anything and everything possible to harass the opposing
litigant without regard to whether any particular motion or
maneuver is appropriate or warranted by the facts of applicable
law. That policy was followed in every legal case I was involved
with or learned about while a member of the Sea Organization. The
management of Scientology consistently expressed and demonstrated
a complete disdain for the court system, viewing it as nothing
more than a method to harass enemies. Some examples of this are
set forth below.
SCIENTOLOGY DESTROYS EVIDENCE AND REWRITES HISTORY
28. During litigation between Gerald Armstrong and Scientology,
which was before Judge Breckenridge of Superior Court for Los
Angeles County, the court ordered the production of Armstrong's
preclear ("PC") folders - These are files maintained by
Scientology on those who submit to interrogation sessions in a
process called auditing.
During the course of that litigation I was ordered to go through
Armstrong's folders and destroy or conceal anything that might
support Armstrong's claim against Scientology. This practice is
known within Scientology as "culling PC folders" and is a common
litigation tactic employed by Scientology.