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DECLARATION OF MARGERY WAKEFIELD

by Margery Wakefield

SCIENTOLOGY -- L. RON HUBBARD'S INCORRIGIBLE BRAINCHILD

[Court/Case No.?]

I, Margery Wakefield, having personal knowledge of the following, hereby declare:

1. I was a member of the Church of Scientology of California from October of 1968 until February of 1980. I joined the Church in Los Angeles, California, where I was primarily based although I also took courses and/or worked at Church organizations in St. Louis, Washington, D.C., Atlanta, Georgia and Miami, Florida.

2. While in Scientology I progressed to the level of OT 3 (an advanced level) and was also audited on New Era Dianetics for OT's, which is now OT 5.

3. During the summer and fall of 1979, I worked as a volunteer for the Church's "intelligence" operation, then called the Guardian's Office (G.O.) and now called the Office of Special Affairs, or O.S.A. I performed volunteer work for the G.O. at the Cedars location in Los Angeles and at the old Bank of Clearwater location in Clearwater, Florida. It is concerning some aspects of this volunteer work for the G.O. that this declaration is written.

4. In the fall of 1979, I was approached by a young woman from the G.O. in Clearwater and given a special project involving Pinellas County Circuit Court Judge Harry Fogle. I was told that Judge Fogle was ruling on an important case involving Scientology, although I was not told any further details of the case, which would have been normal, as the G.O. operated on a need-to-know basis. My understanding was that this operation was being supervised by a G.O. agent named Milt Wolf.

5. My directions concerning Judge Fogle were as follows. I was sent with another Scientologist, pianist Mario Feninger, to attend Judge Fogle's Sunday school class at the Seminole United Methodist Church in Seminole, Florida. Mario gave a short talk on Scientology for Judge Fogle's comparative religion class. My directions were to befriend Judge Fogle after the class and get him to give me a tour of the church while engaging him in conversation. I was to try to get him alone in a room with me.

6. I was then instructed by G.O. personnel that I would be called into court where I would, under oath, make certain allegations concerning Judge Fogle: namely, that he had made sexual advances toward me, and also that he had made certain disparaging comments to me about Scientology. This was to be used to disqualify the judge from a case before him dealing with Scientology. I was coached by several different G.O. personnel who pretended to be the cross examining attorneys.

7. I was coached for my performance in court according to the Scientology policy called TR-L (for Training Routine Lie) which I was already familiar with as I had been introduced to it on one of my Scientology courses. TR-L teaches a Scientologist to lie with conviction under stressful circumstances.

8. I remember asking one of the G.O. staff members about the fact that they were teaching me to lie under oath, and I was quoted the Scientology policy called "the greatest good for the greatest number of dynamics," which simply means that whatever must be done to ensure the survival of the "third dynamic of Scientology" must be done regardless of the side effects. In other words, Scientology law is considered to be above and outside the jurisdiction of non-Scientology or "wog" law. Scientologists do not honor the Biblical oath, even though they may say that they do. This is TR-L in practice.

9. As instructed, I did meet with Judge Fogle in his Sunday school class. After the class, I did engage him in conversation, got him to give me a tour of the church, and was at one point alone in a room with him. As it happened, I never was called into the courtroom to testify against Judge Fogle, and I assumed that the situation had been taken care of in another way.

10. I was also engaged in another project at the Cedars building in Los Angeles and this project had to do with the Federal action involving the eleven Scientologists charged with burglarizing federal offices in Washington, D.C.

11. It was Standard Operating Procedure in Scientology to assign private investigators to collect information on each judge, and each lawyer and witness for the opposition in any important case. This information was then brought into the G.O. offices where a work station had been set up for each person being targeted for investigation.

12. All the information collected on one individual, for example a judge, was then laid out in chronological order in what was called a "time track." Bits and pieces of paper would be taped on a long sheet of paper. It was then the job of a writer to come in and write a narrative from this time track, and it was common knowledge that this narrative would be made available to the Scientology attorneys and it would be used for blackmail purposes when possible.

13. I was the writer assigned to complete a narrative on the U.S. Attorney's Office attorney named Raymond Banoun, which I did do. I was told to highlight with a yellow highlighter any mentions in the narrative of sexual misconduct, use of illegal substances or other crimes.

14. In another project in this same time frame, I was assigned the task of going through witness Michael Meisner's supposedly confidential preclear files and similarly tabbing any incidences of sexual irregularities, drug use, or criminal conduct to be used against him.

15. I consider myself to have been an average Scientologist in the performance of these and other duties for the G.O. In one other case, I was included in a meeting where two murders were planned by Scientology personnel, and I was at that time in agreement with everything I heard planned in the meeting.

16. It is my opinion that I was brainwashed and under hypnosis by Scientology for twelve years. If I had been ordered to commit suicide by the organization I would have, without question. I think I might have taken a life if ordered. This was the strength of the mind control that I was under in Scientology.

17. Therefore, to perjure myself under oath when so ordered by the organization was not, to me, an unreasonable task, especially if I were led to believe that the security and/or survival of the organization was at stake.

18. I believe that most any ordinary Scientologist who was trained in Training Routine Lie would, upon command, lie in court, and would lie also about having been so trained. To put it simply, nothing such a Scientologist says in court can be believed or regarded to be true, as the Scientologist believes him or herself to be above, or outside the jurisdiction of "wog law." Such a Scientologist will not honor the Biblical oath because it has no meaning to him/her.

19. I believe my opinion can be substantiated by corroboration by other ex-Scientologists, particularly those who have had experience in working for the G.O./O.S.A.

I declare under penalty of perjury, under the laws of the State of California, that the foregoing is true and correct. Executed the 23rd day of June, 1993, at Tampa, Florida.


Gerald Armstrong
715 Sir Francis Drake Boulevard
San Anselmo, CA 94960
(415) 456-8450
In Pro pria Persona

SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES

CHURCH OF SCIENTOLOGY INTERNATIONAL, a California not-for-profit religious corporation, 

Plaintiff,

vs.

GERALD ARMSTRONG; MICHAEL WALTON; THE GERALD ARMSTRONG CORPORATION a California for-profit  corporation; DOES 1 through 100, inclusive,

Defendants.

CASE NO. 157 680

DECLARATION OF MARGERY WAKEFIELD IN OPPOSITION TO MOTIONS FOR SUMMARY ADJUDICATION OF 20TH CAUSE OF ACTION; AND 13TH, 16TH, 17TH & 19TH CAUSES OF ACTION OF SECOND AMENDED COMPLAINT

DECLARATION OF MARGERY WAKEFIELD

I, Margery Wakefield, declare:

1. I am over the age of 18 years. I am a resident of the State of Florida. I have personal knowledge of the matters set forth herein, and if called upon as a witness I could testify competently thereto.

2. I was a member of Scientology from 1968 to 1980.

3. In 1982, I filed a lawsuit, Margery Wakefield v. Church of Scientology of California, United States District Court for the Middle District of Florida, Case No. 82-1313-Civ-T-10 for various wrongful acts committed against me.

4. In settlement of that case in 1986 I had to sign a document which prohibited me from thereafter discussing Scientology with anyone. I did not know that I was signing away such a right, nor that Scientology could later come after me with the aid of the courts to punish me for discussing my knowledge of the organization.

5. After leaving Scientology I became a Christian. I believe that I am saved by the Grace of God through my faith in His Son Jesus Christ. I also believe that I was called to speak out concerning the illegal practices of Scientology, its mind control techniques, and its anti-Christian nature and teachings. Appended hereto as Exhibit [A] is a true and correct copy of an essay I recently wrote entitled "What Christians Need To Know About Scientology." I have been motivated in speaking my thoughts based on my knowledge and experiences by the desire to reach the minds of people who are in Scientology and held by its anti-Christian mind control and pseudo-scientific dogma, and the minds of people who might be drawn into Scientology by its misrepresentations concerning its intentions, practices and religion. I believe that it is every Christian's motivation and desire to reach the unsaved with the message of the true gospel and a warning about false teachers like L. Ron Hubbard and false gospels like Scientology. I have felt that the right to speak and teach in this way is something that no court in this country should nor can take away.

6. I know that Scientology says it is a religion, that what it is engaged in is religious practice, and that all of its writings on Scientology are religious scripture. Even according to Scientology's use of the terms "religion" and "religious, " therefore, I believe that under the US Constitution I would be free to speak and could not contract away my right to speak about those religious scriptures, practices and experiences. But I also believe that what I experienced in Scientology were my own religious experiences, and what I experienced regarding Scientology after leaving are my own religious experiences, about which I cannot be silenced.

7. Indeed, Scientology's attacks on me and its efforts to silence me after the "settlement" motivated me further, even at great risk to myself and my freedoms, to do what I had been called to do. Appended hereto as Exhibit [B] is a true and correct copy of a document filed in my case in 1993 by Scientology entitled "Motion for order to show cause why plaintiff should not be held in criminal contempt." In this motion, which is still pending, Scientology seeks to have me jailed for up to twenty-two years for speaking about Scientology.

8. I want this court to know that I am at great risk in providing Gerald Armstrong with a declaration to support his opposition to Scientology's effort to silence him. I do not wish Scientology to further threaten or attack me. I believe, however, that everyone should be free to speak his thoughts, that the knowledge Armstrong has should not be silenced, and that the use of the courts by Scientology to silence its perceived critics, and thus be free to promote its anti-Christian religion should be opposed.

I declare under the penalty of perjury under the laws of the United States and California that the foregoing is true and correct.

Executed at Tampa, FL this 7th day of April, 1995.

[signed]

Margery Wakefield

Exhibit [A]
What Christians Need To Know About Scientology
http://www-2.cs.cmu.edu/~dst/Library/Shelf/wakefield/christians.html

Exhibit [B]
Motion For OSC Why Plaintiff Should Not Be Held in Criminal Contempt 02-12-1993

_______________

Exhibit A: What Christians Need to Know about Scientology

by Margery Wakefield (1991)

Abstract: When new people are inducted into Scientology, they are often told that there is no inherent conflict between Scientology and any religion, including Christianity. But it is common for Scientologists to be less than truthful at the outset. By calming the new person's misgivings, they know that by the time the person has become fully indoctrinated, these misgivings will no longer matter.

In fact, there is no compatibility between Scientology and Christianity. As a belief system based on satanic principles, Scientology is diametrically opposed to Christianity. The truth is that you cannot be both a Christian and a Scientologist.

Contents

  1. Introduction
  2. L. Ron Hubbard as Liar
  3. The Satanic Roots of Scientology
  4. Scientology and Christianity
  5. The Propaganda of Scientology
    Appendix
    1. Creation According to Scientology
    2. The Creed of Scientology
    3. Scientology Evaluated in the Light of Biblical Christianity
    4. A Summary of the Main Differences Between Scientology and Christianity
    5. Bibliography

For those of you whose Christian toes I may have stepped on, let me take the opportunity to disabuse you of some lovely myths. For instance, the historic Jesus was not nearly the sainted figure (he) has been made out to be. In addition to being a lover of young boys and men, he was given to uncontrollable bursts of temper and hatred.... You have only to look at the history his teachings inspired to see where it all inevitably leads. It is historic fact and yet man still clings to the ideal, so deep and insidious is the biologic implanting....

No doubt you are familiar with the Revelations section of the Bible where various events are predicted. Also mentioned is a brief period of time in which the arch-enemy of Christ, referred to as the anti-Christ, will reign and his opinions will have sway ... this anti-Christ represents the forces of Lucifer (literally, the "light-bearer" or "light-bringer"), Lucifer being a mythical representation of the forces of enlightenment.... My mission could be said to fulfill the Biblical promise represented by this brief anti-Christ period.

-- L. Ron Hubbard, Student Briefing, OT VIII Series I


1. Introduction

The controversial Church of Scientology had its beginnings in 1950 with the publication of the book Dianetics: The Modern Science of Mental Health by L. Ron Hubbard.

According to Dianetic theory, the mind is composed of mental image pictures of every event in a person's life. Memories, or pictures, of painful events from the past containing pain or unconsciousness are known in Dianetics as "engrams." By recalling and "erasing" these memories a person can be restored to perfect physical and mental health and analytical functioning. A person whose engrams have all been erased is called a "Clear."

It is the purpose of Scientology to "clear the planet." In other words, that every person in the world will eventually be cleared of his engrams through Dianetic "processing."

By 1954, Hubbard had "discovered" that in order to be truly "clear," a person also had to erase all the engrams from his hundreds of past lives. The new science of Scientology was founded and organized as a religion to incorporate this belief. Sooner or later, most people in Scientology will begin to "remember" (imagine) their past lives.

Scientologists do believe in reincarnation, which is an occult belief.

According to the theology of Scientology, a person is actually an invisible entity, similar to the soul in Christianity. This entity in Scientology is known as the "thetan."

As the thetan becomes relieved of his engrams, he will regain the many godlike powers that are inherently his -- powers such as telepathy, "exteriorization" (the ability to be separate from his body with full perception), telekinesis (the ability to move objects with thought), etc. The belief in Scientology is that we were once godlike, and that we have deteriorated over time. The promise of Scientology is that through Scientology counseling, called "auditing," the person can regain these godlike abilities.

A thetan who has been restored to a godlike state is known in Scientology as an "operating thetan," or "OT" (pronounced "oh-tee"). People in Scientology spend exorbitant fees, sometimes as much as $1000 per hour, to attain the exalted state of OT.

Death in Scientology is known as "dropping the body." According to Scientology theory, when a person dies, he (the thetan, or spirit) has been pre-programmed to "return" to an "implant station" out in space. In the implant station, the thetan will have all memories from the most recent lifetime electronically erased, and then the thetan will be sent back to earth to "pick up a new body," or start another life.

But Scientology promises that with auditing, the person can erase this "return command" so that he will never again have to return to an implant station after death. He will then be a "free being," able to drop his body and pick up a new body with full consciousness and self-determinism.

Scientologists therefore believe that they are very ancient beings, with memories that reach millions of years into the past, and that they are inherently immortal, once the impediments to immortality -- the engrams -- have been erased.

Scientologists believe that they can become gods.

2. L. Ron Hubbard as Liar

You belong to your father, the devil, and you want to carry out your father's desire. He was a murderer from the beginning, not holding to the truth, for there is no truth in him. When he lies, he speaks his native language, for he is a liar and the father of lies.
John 8:44

To his followers, L. Ron Hubbard was larger than life. The biographies of Hubbard given within the cult portray the metamorphosis of this legendary man in stages from youthful prodigy, to teenage adventurer, to brave war hero, to the long-suffering messiah who gave his life for all.

Unfortunately, almost every fact in the cult biographies of L. Ron Hubbard is a lie. While the legendary accomplishments of this cult guru could have come unedited from one of his swashbuckling novels, the true facts of his life reveal quite another picture.

As with the Wizard of Oz, once the curtain was drawn, the fearsome wizard was just an ordinary man. So it was with Hubbard.

"L. Ron Hubbard," the official biography begins, "was born in Tilden, Nebraska, on the 13th of March, 1911. His father was Commander Harry Ross Hubbard of the United States Navy. His mother was Dora May Hubbard...." [Corydon, p. 219]

So far, everything is true.

The biography continues:

Ron spent his early childhood years on his grandfather's large cattle ranch in Montana, said to cover a quarter of the state. It was on this ranch that he learned to read and write by the time he was three and a half years old. [Corydon, p. 219]

The truth is that Hubbard's grandfather was a small town veterinarian who did not own a cattle ranch in Montana. After Hubbard and his parents relocated to Helena, Montana, where his father was hired to manage a local theater, the grandparents soon followed, bought a house on Fifth Avenue, and the grandfather opened the Capital City Coal Company.

The story continues:

L. Ron Hubbard found the life of a young rancher very enjoyable. Long days were spent riding, breaking broncos, hunting coyote and taking his first steps as an explorer. For it was in Montana that he had his first encounter with the Blackfoot Indians. He became a blood brother of the Blackfoot.... [Corydon, p. 219]

Although these events may have existed in the imagination of a young boy in Montana, that is the only place where they did, in fact, exist.

Young Ron Hubbard lived with his parents in a small apartment on Rodney Street in Helena, and he attended the local kindergarten.

When he was six years old, his father enlisted in the Navy after the start of World War I. For the next few years, Ron and his mother followed Harry to a series of port cities where Harry was stationed.

By the time he was twelve years old, young Ron Hubbard had read a large number of the world's greatest classics -- and his interest in philosophy and religion was born. Ron Hubbard had the distinction of being the only boy in the country to secure an Eagle Scout badge at the age of twelve years.... [Corydon, p. 220]

Although Hubbard did receive an Eagle Scout badge, the Boy Scouts of America keeps only an alphabetical listing of Eagle Scouts, with no record of their ages.

The following years, from 1925 to 1929, saw the young Hubbard, between the ages of fourteen and eighteen, as a budding and enthusiastic world traveler and adventurer.... Having the financial support of his wealthy grandfather, L. Ron Hubbard spent these years journeying through Asia. [Corydon, p. 220]

He was up and down the China coast several times in his teens from Ching Wong Tow to Hong Kong and inland to Peking and Manchuria.

In China he met an old magician whose ancestors had served in the court of Kublai Khan. In the hills of Tibet he lived with bandits who accepted him because of his honest interest in them and their way of life.

In the remote reaches of western Manchuria he made friends with the ruling warlords by demonstrating his horsemanship. Deep in the jungles of Polynesia he discovered an ancient burial ground steeped in the tradition of heroic warriors and kings.... [miller, p. 26]

Heady adventures for a teenager!

The truth, however, is a bit more believable. At the age of thirteen, the Hubbards had moved to Bremerton, Washington, where young Ron was an eighth grader at Union High School. Hubbard enjoyed such activities as hiking and camping at the nearby Boy Scout campground.

Two years later, when Ron was a sophomore at Queen Anne High School, his father was unexpectedly posted to Guam, where Ron spent part of the summer, sailing with his mother on the steamship President Madison, with stops in Honolulu, Yokohama, Shanghai, Hong Kong and Manila.

In the spring of his junior year, Ron dropped out of school. Two years later, Ron was enrolled in the Woodward School for boys in Washington, D.C. as a substitute for taking the College Entrance Examination. In 1930, Ron was admitted to George Washington University School of Engineering with a major in civil engineering.

His grades for the first semester ranged from an A in Physical Education, a C in Mechanical Engineering, a D in chemistry, and F's in German and Calculus, earning him a D average. After a second and similar semester, he dropped out of school. Later he would say he had been a student in the first course in atomic physics in the country and that he had a Ph.D. -- which he renounced much later when it became known that the degree had been purchased from a California diploma mill.

Soon Hubbard married and began his career as a struggling science fiction writer. His stories began to appear regularly in Astounding Science Fiction magazine.

In 1941, as the United States was drawn into the Second World War, Hubbard was determined to get into the Navy. He composed his own letter of recommendation for the military:

I have known him for many years and have found him discreet, loyal, honest and without peer in the art of getting things done swiftly. "For courage and ability I cannot too strongly recommend him." [Miller, p. 93]

Hubbard's stories of his naval career serve as an example of his most outrageous fiction writing:

Commissioned by the U.S. Navy, Hubbard was ordered to the Philippines at the outbreak of the war and was flown home in the Secretary of the Navy's private plane as the first U.S. returned casualty of the Far East.

He served in the South Pacific, and in 1942 was relieved and rushed home to take part in the battle against German submarines as Commanding Officer of a corvette serving in the north Atlantic.

After serving in all five theaters of World War II and receiving twenty-one medals and palms, in 1944 he was severely wounded and was taken crippled and blinded to Oak Knoll Naval Hospital. [Miller, p. 95]

The truth about Hubbard's war career is quite different.

Hubbard's first job in the Navy was a desk job in public relations. He soon requested a transfer to Navy Intelligence. On his way to this posting, he so antagonized his superior officers that he was sent home, with an entry in his record stating that:

This officer is not satisfactory for independent duty assignment. He is garrulous and tries to give impressions of his importance. He also seems to think he has unusual ability in most lines. These characteristics indicate that he will require close supervision for satisfactory performance of any intelligence duty. [Miller, p. 98]

The report also added that Hubbard had become "the source of much trouble."

Hubbard was then given another desk job. Eventually, however, he worked his way out of this job, and into the Submarine Chaser Training Center in Miami, Florida. After a few misadventures on training ships under his command, the following notation was placed in his record:

Consider this officer lacking in the essential qualities of judgment, leadership and cooperation. He acts without forethought as to probable results. Not considered qualified for command or promotion at this time. Recommend duty on a large vessel where he can be properly supervised. [Miller, p. 107]

Subsequently, Hubbard was posted onto the U.S.S. Algol. As the Algol prepared to go into battle, in a strange incident which occurred just before the Algol sailed to the Pacific, Hubbard discovered a homemade gasoline bomb in a coke bottle amidst the cargo being loaded onto the ship. There was an investigation into this curious incident, but the results of the investigation were not recorded. However, that evening, Hubbard was relieved of duty.

Crippled and blinded at the end of the war, he resumed his studies of philosophy and by his discoveries recovered so fully that he was reclassified in 1949 for full combat duty. It is a matter of medical record that he has twice been pronounced dead and in 1950 he was given a perfect score on mental and physical fitness reports. [LRH, Facts About L. Ron Hubbard]

Hubbard reported in sick with a suspected ulcer, and was hospitalized at Oak Knoll Military Hospital in Oakland, California, where he remained until December 5th, 1945, when he was discharged from the Navy.

Contrary to his own report of receiving twenty-one war medals, he received four routine medals which were awarded to all servicemen serving in this war.

He was eventually awarded a small partial disability rating.

Two years later, in a pathetic letter to the Veteran's Administration, Hubbard wrote:

This is a request for treatment.

After trying and failing for two years to regain my equilibrium in civil life, I am utterly unable to approach anything like my own competence. My last physician informed me that it might be very helpful if I were to be examined and perhaps treated psychiatrically....

I cannot account for nor rise above long periods of moroseness and suicidal inclinations.... I cannot, myself, afford such treatment.

Would you please help me?

Sincerely, L. Ron Hubbard [LRH, 1947 Letter to the VA]

The Veteran's Administration apparently ignored this letter, to the great detriment of the thousands of souls caught up in Hubbard's later voyage into the world of the demonic in the dangerous cult of Scientology.

Had the Veteran's Administration heeded Hubbard's plea for help, the outcome for many might have been different.

The outcome of history is often ordained by the trivial and the mundane. So it was with Hubbard.

3. The Satanic Roots of Scientology

Have nothing to do with the fruitless deeds of darkness, but rather expose them.
Ephesians 5:11

It is a well documented fact that the religion of Hubbard was Satanism. Hubbard's mentor was, in fact, the infamous English black magician Aleister Crowley. Hubbard reportedly discovered Crowley's works as a teenager on a trip to the Library of Congress with his mother.

Thereafter, he was fascinated by Crowley's "Magick," and Crowley became Hubbard's mentor, a relationship that would last until Crowley's death in 1947. In one of his later lectures, Hubbard would refer to Crowley as "my good friend." [Miller, p. 135]

Crowley's most famous work was called The Book of the Law in which he expressed his philosophy of life: "Do what thou wilt shall be the whole of the Law." It is a philosophy Hubbard was to live by throughout his life.

Crowley wrote, in The Book of the Law:

We have nothing with the outcast and the unfit; let them die in their misery. Compassion is the vice of Kings; stamp down the wretched and the weak; this is the law of the strong; this is our law and the joy of the world.

I am of the snake that giveth Knowledge and Delight, and stir the hearts of men with drunkenness. To worship me take wine and strange drugs.... They shall not harm ye at all. It is a lie, this folly against self.... Be strong, Oh man! Lust, enjoy all things of sense and rapture ... the kings of the earth shall be kings forever; the slaves shall serve.

Them that seek to entrap thee, to overthrow thee, them attack without pity or quarter, and destroy them utterly.

I am unique and conqueror. I am not of the slaves that perish. Be they damned and dead! Amen. [Corydon, p. 49]

Many of Crowley's beliefs have been incorporated into Scientology, especially in the secret upper levels of Scientology, called the "OT levels."

Following in Crowley's footsteps, Hubbard adopted some of the practices of the black magician, including the use of drugs and the use of affirmations.

According to Hubbard's son, his father regularly used illegal drugs including amphetamines, barbiturates and hallucinogens including cocaine, peyote and mescaline. [Corydon, p. 53]

Among the many affirmations that Hubbard was known to have used was the following:

All men shall be my slaves! All women shall succumb to my charms! All mankind shall grovel at my feet and not know why! [Corydon, p. 53]

After being discharged from the Navy in December of 1945, Hubbard did not head for home, where his wife and two small children were living in Bremerton, Washington. He instead headed directly for a house in Pasadena, California, where an eclectic assortment of people lived including one Jack Parsons, the leader of a satanic organization called the Ordo Templis Orientis. That was the U.S. name for the organization headed in England by Crowley.

Parsons wrote to Crowley about Hubbard:

About three months ago I met Ron ... a writer and explorer of whom I had known for some time. He is a gentleman; he has red hair, green eyes, is honest and intelligent, and we have become great friends.

Although Ron has no formal training in magick, he has an extraordinary amount of experience and understanding in the field. From some of his experiences I deduce that he is in direct touch with some higher intelligence, possibly his guardian angel.

Ron appears to have some sort of highly developed astral vision. He described his angel as a beautiful winged woman with red hair, whom he calls the Empress, and who has guided him through his life, and saved him many times.

We are pooling our resources in a partnership which will act as a limited company to control our business ventures.

I need a magical partner. I have many experiments in mind.... [Corydon, p. 255]

Hubbard and Parsons struck up an occult partnership, the result of which was a series of rituals they carried out with the objective of producing a "moonchild," an incarnation of "Babylon" in an unborn child. A woman in the house was chosen to be the mother of this satanic child.

In order to obtain a woman prepared to bear this magical child, Parsons and Hubbard engaged in eleven days of rituals.

All this seemed to achieve its desired result and, on January 18th, Parsons found the girl who was prepared to become the mother of Babalon, and to go through the required incantation rituals. During these rituals, which took place on the first three days of March 1946, Parsons was High Priest and had sexual intercourse with the girl, while Hubbard who was present acted as skryer, seer, or clairvoyant and described what was supposed to be happening on the astral plane. [Corydon, p. 256]

Parsons wrote to Crowley:

I am under command of extreme secrecy. I have had the most devastating experience of my life between February second and March fourth. I believe it was the result of the ninth degree working with the girl.... I have been in direct touch with the One who is most Holy and Beautiful as mentioned in the Book of the Law. First instructions were received direct through Ron, the Seer. I have followed them to the letter. There was a desire for incarnation. I am to act as instructor guardian guide for nine months, then it will be loosed upon the world. That's all I can say for now.... [Corydon, p. 257]

Crowley remained unimpressed. He wrote to one of his associates:

Apparently Parsons and Hubbard or somebody is producing a moonchild. I get fairly frantic when I contemplate the idiocy of these louts. [Corydon, p. 257]

Later, Hubbard was to reveal some of his occult beliefs to his son in a conversation documented by L. Ron Hubbard, Jr.:

We were in Philadelphia. It was November 1952.

Every night in the hotel, in preparation for the next day's lecture, he'd pace the floor, exhilarated by this or that passage from Aleister Crowley's writings.

Just a month before, he had been in London, where he had finally been able to quench his thirst; to fill his cup with the true, raw, naked power of the magick. The lust of centuries at his very fingertips.

To stroke and taste the environs of the Great Beast, to fondle Crowley's books, papers, and memorabilia had filled him with pure ecstasy!

In London he had acquired, at last, the final keys; enabling him to take his place upon the "Throne of the Beast," to which he firmly believed himself to be the rightful heir.

"The books and contents to be kept forever secret," he says. "To reveal them will cause you instant insanity; rip your mind apart; destroy you," he says.

"Secrets, techniques and powers I alone have conquered and harnessed. I alone have refined, improved on, applied my engineering principles to. Science and logic. The keys! My keys to the doorway of the Magick, my magick! The power!"

"I've made the Magick really work," he says. "No more foolish rituals. I've stripped the Magick to basics -- access without liability."

"Sex by will," he says. "Love by will -- no caring and no sharing -- no feelings. None," he says. "Love reversed," he says. "Love isn't sex. Love is no good; puts you at effect. Sex is the route to power," he says. "Scarlet women! They are the secret to the doorway. Use and consume. Feast. Drink the power through them. Waste and discard them."

"Scarlet?" I ask.

"Yes Scarlet: the blood of their bodies, the blood of their souls," he says.

"Release your will from bondage. Bend their bodies; bend their minds; bend their wills; beat back the past. The present is all there is. No consequences and no guilt. Nothing is wrong in the present. The will is free -- totally free; no feelings; no effort; pure thought -- separated. The Will postulating the Will," he says.

"Will, Sex, Love, Blood, Door, Power, Will. Logical," he says.

"The doorway of Plenty. The Great Door of the Great Beast." [Corydon, p. 307]

It is possible that Hubbard not only believed in Satan -- he believed he was Satan!

According to Ron (Hubbard) Jr., his father considered himself to be the one "who came after"; that he was Crowley's successor; that he had taken on the mantle of the "Great Beast." He told him that Scientology actually began on December the 1st, 1947. This was the day Aleister Crowley died. [Corydon, p. 50]

This is the foundation of Scientology, the "Road to Total Freedom"!

4. Scientology and Christianity

Jesus answered, Watch out that no one deceives you. For many will come in my name, claiming, "I am the Christ," and will deceive many.
Matthew 24:4-5

Hubbard's teachings about Christ are somewhat contradictory. In an earlier writing he states that Christ never existed but was only an idea electronically implanted in our minds during the "between lives" period (he called this implant "R6").

Somebody on this planet, about 600 B.C. found some pieces of "R6."

I don't know how they found it; either by watching madmen or something. But since that time they have used it. And it became what is known as Christianity.

The man on the cross. There was no Christ!

The Roman Catholic Church, through watching the dramatizations of people picked up some little fragments of R6. [LRH, Routine R6EW]

Then in a later writing he portrays Christ differently:

For those of you whose Christian toes I may have stepped on, let me take the opportunity to disabuse you of some lovely myths. For instance, the historic Jesus was not nearly the sainted figure [he] has been made out to be. In addition to being a lover of young boys and men, he was given to uncontrollable bursts of temper and hatred.... You have only to look at the history his teachings inspired to see where it all inevitably leads. It is historic fact and yet man still clings to the ideal, so deep and insidious is the biologic implanting. [LRH, Student Briefing, OT VIII, Series 1]

Similarly, Hubbard's overall tone when writing about Christianity in general is usually derogatory:

The whole Christian movement is based on the victim.... They won by appealing to victims. We can win by converting victims. Christianity succeeded by making people into victims. We can succeed by making victims into people. [LRH, Technically Speaking]

And:

Very often you will find aberrative personalities addicted to religion, but the addiction will not be accompanied by any belief in the human spirit. Just how this paradox is accomplished -- a professed avowal of Christianity and a complete unwillingness to accept any effort to heal or help the human spirit -- is another one of the paradoxes which mark the aberrative personality. [LRH, from PABS, Book 1]

Hubbard, in fact, believed himself to be the reincarnation of Buddha, as expressed in his poem, The Hymn of Asia:

Everywhere you are
I can be addressed
But in your temples best
Address me and you address
Lord Buddha
And you then address
Meitreya.

Hubbard writes that Christianity is simply an extension of Buddhism:

And the parables of Gautama Buddha were re-expressed with some differences and additions to spread westward again as Christianity. [LRH, from PABS, Book 3]

And then Hubbard teaches that the goals set by Christ find their fulfillment in Scientology:

This science [Scientology] is formed in the tradition of ten thousand years of religious philosophy and considers itself a culmination of the searches which began with the Veda, the T'ao, Buddhism, Christianity and other religions.... Scientology can demonstrate that it can attain the goals set for man by Christ, which are: Wisdom, Good Health, and Immortality. [LRH, from PABS, Book 1]

In a curious piece of writing, Hubbard states that he has been to "heaven" three times in his past lives. Heaven, according to Hubbard, is an implant; and in one course he draws the pattern of the implant in something called a Line Plot:

Well, I have been to heaven.

Yes, I've been to heaven. And so have you. And you have the pattern of its implants in the ... Line Plots. It was complete with gates, angels and plaster saints and electronic implantation equipment. So there was a Heaven after all -- which is why you are on this planet and were condemned never to be free again until Scientology.

For a long while, some people have been cross with me for my lack of cooperation in believing in a Christian Heaven, God and Christ. I have never said I didn't believe in a Big Thetan but there was certainly something very corny about Heaven et al. Now I have to apologize. There was a Heaven. Not too unlike, in cruel betrayal, the heaven of the Assassins in the 12th Century who, like everyone else, dramatized the whole track implants....

The symbol of the crucified Christ is very apt indeed. It's the symbol of the thetan betrayed. [LRH, Routine 3 Heaven]

According to Hubbard's son, Hubbard considered himself to be Crowley's successor. When Crowley died in 1947, Hubbard believed that he had taken on the "mantle of the Great Beast," and that he was in fact the anti-Christ.

He makes this claim in a late writing:

No doubt you are familiar with the Revelations (sic) section of the Bible where various events are predicted. Also mentioned is a brief period of time in which an arch-enemy of Christ, referred to as the anti-Christ, will reign and his opinions will have sway ... this anti-Christ represents the forces of Lucifer (literally, the "light-bearer" or "light-bringer"), Lucifer being a mythical representation of the forces of enlightenment.... My mission could be said to fulfill the Biblical promise represented by this brief anti-Christ period. [LRH, Student Briefing, OT VIII, Series 1]

In this same essay, he also predicts that after his death, he will return as the anti-Christ of the Bible. He also states that the so-called "Second Coming" of Christianity will actually be an invasion of earth by a race called the Marcabians from outside the universe. But Hubbard, as the anti-Christ, will return to save us:

I will return not as a religious leader but a political one.... I will not be known to most of you, my activities misunderstood by many, yet along with your constant effort ... I will effectively postpone and then halt a series of events designed to make happy slaves of us all. [LRH, Student Briefing, OT VIII, Series 1]

When new people are inducted into Scientology they are often told that Scientology is non-denominational, and that there is no inherent conflict between Scientology and any religion, including Christianity. But it is common for Scientologists to be less than truthful to the public at the outset. By calming the new person's misgivings, they know that by the time the person has become fully indoctrinated into Scientology, these misgivings will no longer matter.

I hope that it is now clear that there is no compatibility between Scientology and Christianity; in fact, as a belief system based on satanic principles, Scientology is diametrically opposed to Christianity. The truth is that you cannot be both a Christian and a Scientologist.

The choice is up to you.

5. The Propaganda of Scientology

But there were also false prophets among the people, just as there will be false teachers among you. They will secretly introduce destructive heresies, even denying the sovereign Lord who bought them -- bringing swift destruction on themselves.
2 Peter 2:1-2

From one's first day in Scientology, one is constantly bombarded by propaganda. In the hundreds of tape recorded messages of Hubbard and the thousands of printed pages studied daily, one's world view is constantly being shaped according to the paranoid world view of the cult leader. This world view has nothing to do with Christianity.

In all of the propaganda of Scientology, three lessons predominate:

  1. That there is a problem.
  2. That there is a solution to the problem.
  3. That the solution can only be found in Scientology.

The first problem posed by Hubbard is the imminent danger of nuclear war. And only Scientology has the potential to thwart this danger:

We are the only people and the only organizations on Earth which have the technology and the ambition to attempt a clarification of situations which in other hands are considered entirely out of control, to wit, the atomic bomb and the decay and confusion of central governments. [LRH, Purpose]

And:

In the same period in history, two of the most sweeping forces Man has known have come to fruition: a knowledge of himself and others with Scientology, and a means of destroying himself and all others by atomic fission. Which force wins depends in a large measure on your use of Scientology. [LRH, Fundamentals of Thought]

And:

The mission of Scientology is not conquest -- it is civilization. It is a war upon stupidity, the stupidity of which leads us to the Last War of All. [LRH, Fundamentals of Thought]

And:

The primary race of Earth is not between one nation and another today. The only race that matters at this moment is the one being run between Scientology and the atomic bomb. The history of man, as has been said by well-known authorities, may well depend upon which one wins. [LRH, Fundamentals of Thought]

The second problem posed by Hubbard is that mankind is caught in a trap, and that he has been in this trap for millions of years during which he has been recycling back to earth through an endless series of lifetimes. It is only through Scientology auditing that he can escape this trap:

In fifty thousand years of history on this planet alone, Man never evolved a workable system. It is doubtful if, in foreseeable history, he will ever evolve another.

Man is caught in a huge and complex labyrinth. To get out of it requires that he follow the closely taped path of Scientology. [LRH, Safeguarding Technology]

And:

We're free men and women -- probably the last free men and women on Earth.... If we don't do a good job now we may never get another chance. [LRH, Your Post]

And:

Is there a way out?

Yes there is.

We have it in Scientology now. I have found it and charted it. I know exactly how to open the gate. [LRH, Escape]

And:

The whole agonized future of this planet, every Man, Woman and Child on it, and your own destiny for the next endless trillions of years depends on what you do here and now with and in Scientology. [LRH, Keeping Scientology Working]

The Scientologist is trained to believe that the only hope for the salvation of mankind is the "science" of Scientology. That there is no other hope.

In all the broad universe there is no other hope for man than ourselves. [LRH, Ron's Journal 1967]

And:

Let us face the reality of this thing. The world confronts several crises. Man's inhumanity to Man is gaining monuments daily. The time to bring a chaos under control is before it is well begun. We're slightly late as it is. Brutally, there is no other organization on Earth that can slow these down. Factually there is no other know-how on Earth that can plumb the problems of Man. So if we don't want all of us to be sitting amongst the charred embers, we had better get busy. [LRH, The Eighteenth A.C.C.]

And:

We are the first group on earth that knew what they were talking about. All right, sail in. The world's ours. Own it. [LRH, The World is Ours]

And:

Auditors have since the first session of Scientology been the only individuals on this planet in this universe capable of freeing Man. [LRH, Auditors]

Scientology is presented to believers in global terms as "The Road to Total Freedom" and as "The Only Hope for Mankind." The goal of every Scientologist is nothing less than to "Clear the planet," to ensure the salvation of every person on earth through the attainment of the Scientology state of "Clear."

We're playing for blood, the stake is Earth. [LRH, Policy Letter 7 Nov 1962]

And:

The purpose of the Field Staff Member [a Scientologist] is: To help LRH [Hubbard] contact, handle, salvage and bring understanding to individuals and thus the peoples of Earth. [LRH, Field Auditors]

And:

Now, without further discourse, let's get hot. This is Scientology -- the freedom for Man. Let it be known. [LRH, The Public Divisions]

And:

Scientology -- The Road Sign Out.

We are the Free People. We LIVE! We're FREE! [LRH, We Are the Free People]

And:

There is no greater game in the Universe than Scientology, for it is the only game in which everybody wins. [LRH, Contests and Prizes]

And:

The Valuable Final Products of a Scientologist are:
DISSEMINATED KNOWLEDGE
PURCHASED BOOKS
ENVIRONMENTAL CONTROL
A CLEARED PLANET [LRH, Org Board Division Six]

And:

The eons march on.... Perhaps, this time, due to our efforts, a humanitarian world can exist. We, the Prophets of the Morrow, know the way. [LRH, Scientology: The Philosophy of a New Age]

Scientology wants you -- your mind, your spirit, your soul.

"No one can serve two masters." Matthew 6:24

Jesus Christ or L. Ron Hubbard -- who will your master be?

Appendix A:
Creation According to Scientology

THE FACTORS, by L. Ron Hubbard

  1. Before the beginning was a Cause and the entire purpose of the Cause was the creation of effect.
  2. In the beginning and forever is the decision and the decision is TO BE.
  3. The first action of beingness is to assume a viewpoint.
  4. The second action of beingness is to extend from the viewpoint, points to view, which are dimension points.
  5. Thus there is space created, for the definition of space is: viewpoint of dimension. And the purpose of a dimension point is space and a point of view.
  6. The action of a dimension point is reaching and withdrawing.
  7. And from the viewpoint to the dimension points there are connection and interchange. Thus new dimension points are made. Thus there is communication.
  8. And thus there is light.
  9. And thus there is energy.
  10. And thus there is life....

    [There are thirty Factors in all.]

Humbly tendered as a gift to man by
L. Ron Hubbard
April 23, 1953

Appendix B:
The Creed of Scientology

We of the Church believe:

  • That all men of whatever race, color or creed were created with equal rights.
  • That all men have inalienable rights to their own religious practices and their performance.
  • That all men have inalienable rights to their own lives.
  • That all men have inalienable rights to their own sanity.
  • That all men have inalienable rights to their own defense.
  • That all men have inalienable rights to conceive, choose, assist and support their own organizations, churches and governments.
  • That all men have inalienable rights to think freely, to talk freely, to write freely their own opinions and to counter or utter or write upon the opinions of others.
  • That all men have inalienable rights to the creation of their own kind.
  • That the souls of men have the rights of men.
  • That the study of the mind and the healing of mentally caused ills should not be alienated from religion or condoned in nonreligious fields.
  • And that no agency less than God has the power to suspend or set aside these rights, overtly or covertly.

And we of the Church believe:

  • That man is basically good.
  • That he is seeking to survive.
  • That his survival depends upon himself and upon his fellows, and his attainment of brotherhood with the Universe.

    [Etc.]

Appendix C:
Scientology Evaluated in the Light of Biblical Christianity

(from Those Curious New Cults, by William J. Petersen)

How, then, can Scientology be evaluated by biblical Christianity?

First, its primary assumption that man is basically good is not biblical. Familiar scriptures such as "For all have sinned and come short of the glory of God," and "All our righteousnesses are as filthy rags," indicate quite clearly that the Bible and Hubbard are not in the same corner.

Second, Scientology's highest authority is not Jesus Christ or the Christian Bible but a science fiction writer named L. Ron Hubbard. In some ways, the Scientology organization is disturbingly similar to Orwell's 1984 with Ron Hubbard as "Big Brother."

Third, to Scientology God is irrelevant. Scientology alone is relevant. Whether God exists or not is not a matter of concern.

Fourth, Scientology has no salvation to offer the poor. Books are sold, counseling sessions are expensive. Nothing is said about the plight of the poor, the sick, the homeless and oppressed. According to Time magazine, one woman said, "It's the only church I've seen with a cashier's booth." Contrast that to biblical Christianity which offers salvation without money and without price.

Fifth, Scientology has a warped code of ethics. In the Scientology code are such statements as "Never fear to hurt another in a just cause," and "To punish to the fullest extent of my power anyone misusing or degrading Scientology to harmful ends." Such statements bear no resemblance to the words of Jesus: "Turn the other cheek," and "Love your enemies, bless them that curse you, do good to them that hate you and pray for them that spitefully use you and persecute you."

And sixth, Scientology deifies man. In fact, in their writings, man is often capitalized. Man's reason will produce perfect behavior and therefore solve all the problems of the human predicament.

Appendix D:
A Summary of the Main Differences Between Scientology and Christianity

(from The Challenge of the Cults, by Maurice Burrell)

  1. Authority
    Scientology: Although the Bible is used to bolster up the sect's ideas, the source of Scientology's philosophy and technology is Hubbard himself.
    Christianity: As the Word of God, the Bible is the yardstick against which all claims (including those of Hubbard) have to be measured.
  2. God
    Scientology: Although Hubbard and many of his followers are theists, belief in God is not essential to Scientology.
    Christianity: God is Trinity, Father, Son and Holy Spirit, three Persons within the unity of the Godhead.
  3. Christ
    Scientology: Christ has no essential or central place in the sect's teachings.
    Christianity: "God sent his Son to be the Savior of the world."
  4. Salvation
    Scientology: Man is basically good, but "engrams" (psychological hang-ups) prevent him from reaching his full potential. When released from these engrams through the sect's techniques, man begins to live on a higher level in terms of his own human achievement.
    Christianity: Man needs to be saved from sin and to be given new life. Both are available from God through faith in Christ.

Appendix E:
Bibliography

Atack, Jon. 1990. A Piece of Blue Sky. Secaucus, New Jersey: Carol Publishing Group.

Burrell, Maurice. 1982. The Challenge of the Cults. Grand Rapids, Michigan: Baker Book House.

Corydon, Bent. 1987. L. Ron Hubbard: Messiah or Madman. Secaucus, New Jersey: Lyle Stuart.

King, Francis. 1970. Ritual Magic in England. London: Neville Spearman, Ltd.

Miller, Russell. 1987. Bare Faced Messiah: The True Story of L. Ron Hubbard. London: Penguin Books, Ltd.

Petersen, William. 1982. Those Curious New Cults in the 80's. New Canaan, Connecticut: Keats.

_______________

Exhibit B:  Motion For OSC Why Plaintiff Should Not Be Held in Criminal Contempt 02-12-1993

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION

MARGERY WAKEFIELD,

Plaintiff,

vs.

THE CHURCH OF SCIENTOLOGY OF CALIFORNIA, etc.,

Defendant.

CASE NO. 82-1313-Civ-T-10

IN CAMERA

MOTION FOR ORDER TO SHOW CAUSE WHY  PLAINTIFF SHOULD NOT BE HELD IN CRIMINAL CONTEMPT

The Church of Scientology of California ("Church"), Defendant above and Movant herein, moves the Court for an Order requiring Plaintiff, Margery Wakefield, to Show Cause why she should not be held in criminal contempt for the violation of the terms of the preliminary and permanent injunction entered by this Court on May 16, 1989. The basis for this motion, as more particularly set forth herein and the attached exhibits and in the accompanying Memorandum of Law, is that Wakefield recently appeared on a television program which was broadcast on November 18, 1992, during which Wakefield made statements which she knew to violate this Court's permanent injunction. In support of this motion the Church alleges:

1. Margery Wakefield and the Church entered into a Settlement Agreement in the above-styled case which was approved by this Court and tiled under seal, with the Court on August 14, 1986.

2. Paragraph 5 of the Settlement Agreement provided that the parties promised and agreed for valuable consideration to comply with every term, condition and undertaking contained in the transcript of the in camera proceedings of July 11, 1986, a copy of which was attached to the Settlement Agreement as Exhibit 3. The parties further agreed that the Settlement Agreement would be enforceable by this Court.

3. The Church has fully complied with all the terms and conditions of the Settlement Agreement.

4. On July 2, 1987 the Church filed a Motion to Enforce Settlement Agreement and to Enjoin Plaintiff from violating the terms of the Settlement Agreement.

5. On May 16, 1989, the Court entered a Preliminary and Permanent injunction against Margery Wakefield which provided in relevant part as follows:

That Margery Wakefield is restrained and enjoined from disclosing to other persons, not members of her immediate family, matters relating to: a) the substance of her complaint against the Church; b) the substance of her claim against the Church; c) alleged wrongs committed by the church; d) the contents of the documents which were returned to the Church pursuant to the settlement agreement or similar fact  evidence.

6. On July 18, 1989 the church filed motions to hold Wakefield in civil and/or criminal contempt for repeated violations of this court's May 16 injunction, as a result of published interviews Wakefield granted to various newspapers and radio and television stations. This Court referred the matter to Magistrate Paul Game, Jr. for a hearing which was held in October and November, 1989.

7. In a Report and Recommendation dated June 25, 1990, Magistrate Game concluded that Wakefield had engaged in a total of forty-four separate willful violations of this Court's injunction which would warrant findings of civil contempt. Additionally, Magistrate Game deferred to this Court's discretion whether a referral should be made to the United States Attorney's office for prosecution of Wakefield on criminal, contempt charges. Magistrate Game's June 25, 1990 Report and Recommendation is pending before this Court.

8. On November 18, 1992 a television program entitled "Au Nom De La Loi" (In the Name of the Law") was broadcast in Belgium by television station RTBF (the "RTBF Program"). The RTBF Program contained several segments in which Margery Wakefield, who was identified each time by name, spoke on camera in English with a French "voice-over" about her experiences in the Church of Scientology and her views of Scientology. The televised segments involving Wakefield were apparently filmed in the Clearwater, Florida area. In the course of the RTBF program Wakefield made statements which are willful and knowing violations of this Court's May 16, 1989 injunction. Some of the aforementioned statements made by Wakefield on the RTBF Program are identical in substance to statements previously determined by Magistrate Game in his June 25, 1990 Report to have been willful contempts of this Court's injunction by Wakefield in 1989. The details of Wakefield's recent new violations are set out more fully in the Declaration of Michael Lee Hertzberg, Esq., attached hereto as Exhibit A and are evidenced by excerpts from a certified translation of the RTBF Program attached hereto as Exhibit B.

WHEREFORE, the Church respectfully moves as follows:

1. The Court appoint the United States Attorney or a private attorney to prosecute Wakefield's criminal contempt.

2. That the Court issue an Order requiring Plaintiff, Margery Wakefield, to appear before this Court and show cause why Wakefield should not be adjudged in criminal contempt of this Honorable Court and have sanctions imposed upon her as provided by law including but not limited to a fine of up to $500.00 or imprisonment not exceeding six (s) months for each act of contempt.

3. That Wakefield be required to pay costs and attorneys' fees incurred by the private prosecuting attorney.

Dated: February 12, 1993 [signed]
PAUL B. JOHNSON, ESQ.
JOHNSON & JOHNSON
Fla. Bar No. 039966
Box 3416
Tampa, Florida 33601
(813) 223-5321

MICHAEL SEE HERTZBERG
740 Broadway, 5th Floor
New York, New York 10003
(212) 982-9870
Attorneys for Defendant-Movant
THE CHURCH OF SCIENTOLOGY 0F CALIFORNIA

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy hereof has been furnished to MARGERY WAKEFIELD, P.O. Box 290402, Tampa, Florida 33687 by U.S. mail this 12th day of February, 1993.

[signed]
Paul Johnson
Attorney

MARGERY WAKEFIELD,

Plaintiff,

vs.

THE CHURCH OF SCIENTOLOGY OF CALIFORNIA, etc.,

Defendant.

CASE NO. 82-1313-Civ-T-10

IN CAMERA DECLARATION OF MICHAEL LEE HERTZBERG, ESQ.

MICHAEL LEE HERTZBERG hereby declares and states:

1. I am an attorney who has previously appeared before this Court on behalf of the defendant Church of Scientology of California ("the Church") in this matter. My co-counsel is Paul B. Johnson of the firm of Johnson and Johnson in Tampa. I submit this Declaration in support of the Church's Motion for Order to Show Cause Why Plaintiff Should Not Be Held In Criminal Contempt. I have personal knowledge of the facts set forth in this Declaration and could competently testify thereto if called as a witness.

2. On or about November 18, 1992 a television program entitled "Au Nom De La Loi" ("In the Name of the Law") was broadcast in Belgium by station RTBF (the "RTHF Program"). The narration and most of the interviews on the RTBF Program are conducted in French. Some of the interviews are in English with a voice over narration in French.

3. The RTBF Program includes several segments in which Margery Wakefield speaks on camera and is identified by name. Counsel representing the Church herein viewed a videotaped copy of the RTBF Program and concluded that remarks were made by Wakefield during the Program which violated an injunction entered by this court against Wakefield dated May 16, 1989.

4. Counsel hired a translator, Annette T. Gordon, to translate the RTBF Program from French to English and to prepare a transcript of her translation. Ms. Gordon, who has no relationship to the Church, has experience providing transcriptions from French to English for the United States Customs Service and has also translated from French to English in proceedings in the United States District Court for the Middle District of Florida. Attached as Exhibit B herein are eleven pages containing the portions of the transcript prepared by Ms. Gordon in which Margery Wakefield either speaks or is referred to, together with an affidavit from Ms. Gordon certifying the accuracy of her translation and reciting her professional qualifications. Should this Court desire, the church will file the forty-one page translation of the entire RTBF Program as well as a copy of the videotape of the program. The Church has not done so at this time to avoid burdening the court with excess material.

5. Significant portions of the RTBF Program were filmed in or about Clearwater, Florida, and Clearwater appears to be the venue for the segments involving Wakefield.

6. Wakefield is introduced on the RTBF Program as a former Scientologist qualified to describe what the Church of Scientology is like based upon her personal experience.

7. The narrator of the RTBF Program reports that Wakefield has disclosed that she was transformed by the Church into a "zombie" by techniques of "brainwashing":

VOICE: For 12 years MARGERY was a convinced Scientologist. And, now she's revealed to us how the sect transformed her into a zombie, an obedient and docile robot. The method is simple and frightening at the same time. A daily drill exacerbated by the techniques of brainwashing.

8. During the RTBF Program Wakefield claimed that the Church's training routines are designed as hypnotic processes:

MARGERY:

* * *

T-R-O-, the first drill that we did is part of the first Scientology course, which is called "Communication Course." They tell you that this drill serves in helping you better your visual contacts, but, really, is
designed to hypnotise. When I was in Scientology, this drill lasted 2 hours.

9. During the RTBF Program Wakefield stated that at the time she worked at the Church's Guardian Office she was aware of the planning of two murders:

MARGERY:

Michael Meisner was one of the two people that we had planned to murder in 1979. I think it was. And, the day that I was told that, we had the meeting in the Guardian Office, Michael Meisner was handcuffed to a bed. The Guardian Office had him somewhere in hiding. The plan was to take him, the next day, out to sea, out to the bay, tie weights on him and to.throw him overboard. In Scientology, it's called Deep Sixing." That was the plan.

I declare under penalty of perjury that the foregoing is true and correct and that this declaration was executed an February 11, 1993 at New York, New York.

[signed]
MICHAEL LEE HERTZBERG

AFFIDAVIT OF TRANSLATOR

STATE OF FLORIDA
COUNTY OF HILLSBOROUGH

I, the undersigned, ANNETTE T. GORDON, being first duly sworn, do certify that the attached transcript is a true and accurate translation from French into English of those portions of the xxxxxxxx ["attached" strikethrough] video tape entitled "In the Name of the Law" in which MARGERY WAKEFIELD appears.

I received my Bachelor of Arts Degree from the University of Arkansas in English and in French as an Honors graduate in 1971 and received my Masters Degree from the University of Arkansas in 1974.

While at the University of Arkansas, I taught French as a teaching assistant. I am fluent in the English and French languages and have traveled extensively in France.

I have provided transcriptions from French to English for the U.S. Customs Service and I have translated from French to English in proceedings in the United States District Court for the Middle District of Florida.

[signed]
ANNETTE T. GORDON

The foregoing instrument was acknowledged before me this 22nd day of January, 1993, by Annette T. Gordon, who has produced a Florida Drivers' License as identification and who did take an oath.

[signed] Valerie Aleksandar
Notary Signature


[notary seal]

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