DECLARATION OF JOSEPH M. FLANAGAN1
I, Joseph M. Flanagan, being sworn, hereby state and declare:
1. I have known Paulette Cooper since June of 1979. She has told me, and others, on several occasions that she considers me one of her closest friends. She has frequently confided in me, especially on matters concerning Scientology.
2. In late January, 1985 Paulette called me to tell me that there was a realistic possibility that she could settle her numerous lawsuits with the Church of Scientology by herself. From that point on she kept me informed of her settlement negotiations.
3. In early February, Paulette indicated that negotiations had reached a critical stage and asked me to come to New York in order to discuss the negotiations with her. She was negotiating with the Scientologists by herself, and refused to allow her lawyers to get involved.
4. When we met on February 8, 1985 in her apartment, she told me that she realized just how much the Scientologists hated her attorney, Michael J. Flynn. She was convinced that they hated him more than her and that their hatred was so fanatical that they were willing to deal with even her. Paulette desperately wanted to settle and realized that Flynn was the Scientologists’ “button;” they would do anything to attack him. In order to further settlement talks, she told me that she had hinted to the Scientologists that she had information regarding a “conspiracy” which the Scientologists were convinced existed. She told me that she knew of no such “conspiracy,” but had made these comments in order to keep them interested in settling her case. She made it clear to me that she was telling them what she thought they wanted to hear.
5. Paulette now told me that the Scientologists would only settle if she gave them a deposition detailing information she had about Michael Flynn’s “conspiracy” against Scientology.
When I asked her “what information,” she replied something to the effect, “I don’t know. I’ll make it up as I go along.” Scientology indicated to her that they would pay her extra for testimony against Michael Flynn. Paulette told me that “the trick is to get as much money as possible” while the group is in a paying mood.
6. Originally, Paulette told me that she was going to negotiate for as much money as possible in the settlement and in extra payments. Having the money safely in hand, in the Scientology deposition she would tell the truth about what she knew of the “conspiracy:” namely, that there is no “conspiracy.” She was nervous, however, that her prior oblique references to the “conspiracy” were proving too vague to the Scientology negotiator. She felt that to close the deal and get more money, she needed to come up with more credible information about this imaginary “conspiracy.”
7. On Saturday, February 9, 1985, Paulette began to create events and scenarios which she would tell the Scientologists were part of the “conspiracy.” She bounced them off me to see if they were plausible. For example, she said that she could tell them Michael Flynn showed us sealed documents relating to Gerald Armstrong’s case after the court ordered all such documents to be sealed and returned to the court. I agreed that this is the kind of thing they might nibble on. Paulette and I knew that this never happened. I have never seen the Armstrong documents. This story was made up solely for the possible consumption of the Scientologists.
8. Paulette created similar stories such as Michael Flynn had knowingly filed frivolous lawsuits and had suborned perjury. These were stories; Paulette knew that none to these incidents had ever happened. She was going to imply that they had in order to enhance her negotiating status and obtain more money.
9. I left New York on Saturday afternoon. Paulette kept me informed throughout the week. The structure of the final deal was that Paulette would be paid a “settlement” of $400,000. Unknownst to her attorneys, she would be required to give a sworn deposition about the Flynn “conspiracy” for which she was to receive at least $50,000. (She also told me that she could receive as much as $10,000 for additional affidavits incriminating Flynn.) The settlement could not be consummated unless she agreed to the deposition. I was horrified to learn that Paulette no longer intended to tell the truth about the “conspiracy”–that it did not exist–but would instead tell under oath the stories that she had fabricated when I was with her on the weekend of February 8. I asked her in a heated conversation if she did not consider this a betrayal of her attorney, Michael Flynn, and others. She rationalized by stating that if a court found out that she had been paid $50,000 for a deposition, it would not believe her anyway.
10. I know through Paulette that the initial phase of the settlement was completed and that she received the $400,000. She told me that her deposition was scheduled to Saturday, February 23, 1985. I do not know how much she was paid for it or if it went forward.
11. Shortly before Paulette received her settlement, she called me somewhat excitedly and told me that she could get me out of the Garrison suit (a lawsuit brought against Paulette, myself, and others in which two individual Scientologists claimed we had involuntarily deprogrammed them.) I am a defendant in that case and I do not have a counterclaim in that case or any other lawsuit against any Church of Scientology. Yet Paulette informed me that the Scientologists would pay me $10,000 and dismiss the suit if I apologized in writing to the Garrisons and gave a deposition confirming that Michael Flynn had violated the court order and showed us sealed documents. I was shocked. I told Paulette that I could not give such a deposition because we never saw any documents. I told her that it was wrong to take money for false testimony and that she was getting in over her head.
12. Later that I called Michael Flynn and told him what Paulette was doing. Paulette learned of the phone conversation and called me on Monday, February 25. She was livid and told me that I may have cost her $400,000. She also called me early the next morning. She told me that I had possibly “ruined everything,” reiterated that I may have cost her $400,000, and ordered me not to tell Michael Flynn anything more about our conversations. I have not spoken with her since then.
Signed and sworn this 9th day of March, 1985 in Boston, Massachusetts under the pains and penalties of perjury under the laws of the State of California.
JOSEPH M. FLANAGAN