united states district court for the district...

UNITED STATES DISTRICT COURT FOR THE

DISTRICT OF MASSACHUSETTS

) MICHAEL J. FLYNN, )

) Plaintiff, ) No. 83-2652-Mc

) v. )

) DECLARATION OF LAFAYETTE RONALD HUBBARD, ) RONALD L. WADE a/k/a/ L. RON HUBBARD, )

) Defendant. )

)

I, RONALD L. WADE, hereby state under the pains and

penalties of perjury that I have personal knowledge of the

following:

1. I am one of the attorneys for plaintiff in the

action currently being tried before the Multnomah County

Circuit Court in Portland, Oregon entitled Julie Christofferson-

Titchbourne v. Church of Scientology, Mission of Davis, Church

of Scientology of California and L. Ron Hubbard, case number

A7704-05184.

2. On April 18, 1985, I received a copy of the Dec-

laration of Howard A. Gutfeld, dated April 14, 1985, wherein

Mr. Gutfeld described the testimony of Mr. William Franks,

who had been called as a witness by plaintiff in Christofferson

action.

,-4 •-• t;2 - DECLARATION OF RONALD L. WADE

I

3. Mr. Gutfeld's Declaration is misleading, contains

testimony taken out of context and does not accurately

portray the testimony of Mr. Franks.

4. At trial, Mr. Franks testified he was appointed to

his former positions as Executive Director, International

and Senior Management Executive International by L. Ron

Hubbard.

5. On cross examination, defendants asked Mr. Franks

if he had denied he was appointed by Mr. Hubbard to a group

of mission holders in December of 1981. Mr. Franks candidly

stated that he had and explained that the statement was

made pursuant to the policy of L. Ron Hubbard and the

Church of Scientology that no public or written admissions

be made that L. Ron Hubbard was or is in control of the

Church of Scientology.

6. Other evidence at trial has established that Mr.

Hubbard has caused the Church of Scientology to destroy

documents evidencing Mr. Hubbard's control of the organi-

zation. Actual documents with portions cut out concerning

Mr. Hubbard are in evidence in the Christofferson action.

Mr. Franks, as the Executive Director, International, was

under orders to protect Mr. Hubbard and conceal his control

of the organization and he did so by telling the mission

holders that he was not appointed by Mr. Hubbard.

- DECLARATION OF RONALD L. WADE

7. Other parts of Mr. Gutfeld's Declaration are

equally misleading. Mr. Franks testified he did not re-

ceive communications from L. Ron Hubbard after August of

1981, but did testify that a communication line existed

between the organization and Mr. Hubbard. My recollection

is that Mr. Franks testified that he saw documents and

listened to tapes prepared by and for Mr. Hubbard after the

above date.

8. With respect to paragraph 8 of Mr. Gutfeld's

Declaration, Mr. Franks was told that he would be replacing

Mr. Hubbard as Executive Director International. He soon

found out that Mr. Hubbard was continuing to control the

organization through his Commodore's Messenger Organization.

Mr. Franks testified, and documentary evidenced established,

that Mr. Franks was the highest "public" official of the

organization under only Mr. Hubbard and Mr. Hubbard's

agents.

9. The contention that L. Ron Hubbard's policy was to

obey the law has been completely shattered in testimony by

Mr. Franks and others in the Christofferson case. Mr.

Hubbard's confidential policies setting up intelligence

units and urging the commission of despicable acts are part

of the record in the case.

10. It is true that Mr. Franks stated that he told

many lies while he was a member of the Church of Scien-

tology. This is not, however, suprising. Testimony in the

.--r7,0430 - DECLARATION OF RONALD L. WADE

Christofferson trial has evidenced that the Church of

Scientology is based upon falsehoods that are perpetuated

until this very day. As stated by a current Scientologist

in an illegally obtained videotape used against one of

plaintiff's witnesses in trial, Scientologists "lie for the

cause" on a daily basis.

11. I would also like to respond to the Declaration

of Earle C. Cooley regarding the cross-examination of Gerald

Armstrong and the claims of Mr. Cooley that the illegally

acquired videotapes reveal a plan by Mr. Armstrong and

Michael Flynn to take over- the Church of Scientology. In

fact, the Court ruled initially =that the first two video-

tapes disclosed entrapment of Mr. Armstrong, were illegally

acquired, inadmissible into evidence and that they were

"devastating to the church."

12. After an order by the court, the church produced

two additional videotapes which, taken together with

the previous two, reveal that it was the church which

was usingw,klellt means to entrap Mr. Armstrong, that

Mr. Arristrputgl, not any anytime seek to plant false

or forged:- documents or do any of the things alleged by

Mr. Cooley....-- act, the videotapes, as stated by the

court, were a-devastating example of the church's illegal

means to cover up its own misconduct. We believe


that the verdict in the Christofferson trial will reflect

the credibility of Mr. Armstrong and other witnesses.

13. With regard to the allegedly "police-authorized

investigation," Mr. Cooley produced a document, attached

hereto as Exhibit "A," authorizing Eugene M. Ingram,

a private investigator in the employ of the church, to

tap the telephones of Michael Flynn, Gerald Armstrong

and others. Serious questions have been raised as to

how a Los Angeles Police officer can authorize a wire-

tap without approval of a state or federal magistrate

or judge, particularly where the wiretap without approval

has been allegedly obtained by a former Los Angeles

Police Officer from a present officer. Upon information

and belief, this entire illegal wiretap and videotaping

of Gerald Armstrong is under investigation by the

Internal Affairs Sectip=z;1117,7 s Angeles Police

Department, the Criminal In tion Division of the

Internal Revenue Servift, taa04114eral Bureau of Investi-

gation and the United S#Ates AttOrney's Office in Boston,

Massachusetts.

Signed under the painwiaisd Penalties of perjury

under the laws of the State of Massachusetts this 18th

702432 - DECLARATION OF RONALD L. WADE

day of April, 1985 in Portland, Oregon

1-3 RONALD L. WADE

SUBSCRIBED AND SWORN to belore me this 18th day of April, 1985.

Nat ry Pubic for Oregon NIV-Commillission Expires: 5/11/87


EUGENE M. INGRAM INGRAM INVESTIGATIONS California License Number flf19387 1212 North Vermont Avenue Los Angeles, California 90029

November 7, 1984

To: EUGENE M. INGRAM, PRIVATE INVESTIGATOR

From: PHILLIP RODRIGUEZ, POLICE OFFICER, NORTHEAST DIVISION, CITY OF LOS ANGELES

I hereby direct EUGENE M. INGRAM and his employees/agents or other persons acting under his direction, to intentionally and without the consent of all parties to a confidential communication, by means of any electronic amplifying or recording device, eavesdrop upon or record such confidential communication, whether such communication is carried on among such parties in the presence of one another or by means of a telegraph, telephone or other deuice, for the period November 7, 1984 thru November 14, 1984; provided however, that if recordings are accomplished on any day during the above period, EUGENE M. INGRAM is to report the results to me for further direction by me.

This authorization shall specifically pertain to the investigation of GERRY ARMSTONO, MICHAEL J. FLYNN, AND OTHERS NOT KNOWN AT THIS TIME, regarding possible criminal violations of, but not limited to, California Penal Code §664 (Attempts), §134 (Preparing False Documentary Evidence), §182 (Conspiracy) and/or any other violations of criminal laws.

This authorization is in compliance with California Penal Code §633.

Signed in Los Angeles, California, on November 7, 1984.

OFFICER PNIS1tPJUBA1GUEZ SERIAL NUMBER 16924 LOS ANGELES POLICE DEPARTMENT

EXHIBIT "A"

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