Response of Michael Flynn to Declaration of Heber Jentzsch (April 4, 1984)

This is a response to the “Declaration” of Heber Jentzsch who holds himself out as being a “Reverend” for the Church of Scientology. It is interesting to note that a “Reverend” is generally considered to be one who is a member of the clergy and is considered to be worthy of honor, respect, and admiration. Such honor and respect has in our society, traditionally been given to men who either individually or as part of a religious group, have demonstrated a high degree of love, kindliness, charitableness and good will toward all men. While Reverend Jentzsch purports to represent “goodness” about which he speaks in his “Declaration,” he proceeds to unleash a false, vitriolic diatribe against myself, psychiatrists, my colleagues, the government, my clients, (many of whom are former Scientologists who attained clear, OT-VIII, NOTS, auditors, and mission holders), as well as any other person or group who seeks to expose the lies, fraudulent conduct, and criminal activity of the RTC, the Church of Scientology, its agents and representatives, all of whom have inflicted wide-spread harm on many individuals and organizations.

At the beginning of his declaration, Reverend Jentzsch states that Scientology is a “symbol of good.” However, any person of reasonable intellect, upon examination of the record, must conclude that the thousands of “Guardian’s Office Operations” against its perceived “enemies” pursuant to the “Fair Game Doctrine” does not constitute “good.” The malevolence inherent in the very concept of the “Fair Game Doctrine” and “Suppressive Person Declares” is such that any man of good will should conclude that the very writing and implementation of such concepts which call for the “destruction” of anyone who opposes Scientology constitute acts of substantial depravity. Such concepts can only have as their purpose to destroy freedom of thought of which the Reverend Jentzsch purports to speak in support of.

The venom which pours forth from the brain and heart of the Reverend Jentzsch in his Declaration is such that most people knowledgeable of the “tech” would conclude that Reverend Jentzsch probably took special delight in doing the Guardian’s Office Hat Packs which train GO staff how to “destroy” people. Reverend Jentzsch appears to be consumed by an unfortunate quantity of anger, hatred, and delusion. Perhaps someone should recommend to the Reverend Jentzsch that he read verse 37, ch. 3 and verse 62, ch. 2 of the Bhagavad-gita, wherein it is stated:

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“It is desire, it is anger, born of Arajo-guna, all consuming and most evil. Know this to be the enemy here on Earth.”

“From anger arises delusion: from delusion unsteadiness of memory: from unsteadiness of memory destruction of intellect: through the destruction of intellect, he perishes.”

If the Reverend Jentzsch sincerely believes that Scientology has its origins in Eastern religion, it would behoove him to read the aforecited chapters of the Bhagavad-gita.

On P. 2 of his declaration, the Reverend Jentzsch states that I have entered into a conspiracy with a corporation called “FAMCO,” through which I am selling shares of stock and through which I am in “collaboration with forces trying to destroy freedom of religion in churches in American life.” The Reverend Jentzsch then goes on to state that I am brutally kidnapping and deprogramming people, depriving them of their legal rights, abusing the judicial process, manipulating the media, committing libel, forgery, and a host of other pernicious activities, all of which are designed to destroy the Reverend Jentzsch’s wonderful Church.

The first question any intelligent person should ask is does Jentzsch really believe such absurdity or is he merely acting as a dupe for someone else. If the Reverend

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believes that Michael Flynn is trying to destroy freedom of religion and churches in America, then one need inquire no further and simply dismiss Jentzsch as a nut. However, if Reverend Jentzsch is working for L. Ron Hubbard, RTC, Mary Sue Hubbard, or others, then the inquiry should relate to whom he is working for, what vested interests they have, and does the person he is working for really believe that Michael Flynn is trying to destroy freedom of religion and churches in America. If the persons who Jentzsch works for sincerely believe such nonsense, then they should be dismissed as suffering from delusions, anger and hatred for putting someone like the Reverend Jentzsch out on the street disseminating false information to those who are similarly deluded and who are paying the price for such delusion in the form of labor expended without payment, careers lost, millions of dollars paid, and in some cases even death. The sad, simple truth is that there are many who do and undoubtedly will believe Reverend Jentzsch and will thereby perpetuate their own self-deceit which inevitably, can only have extremely destructive consequences to them, to their loved ones, and to their families. Reverend Jentzsch’s efforts to perpetuate the lies, misrepresentations and chicanery for which the Church of Scientology has become famous, and which Michael Flynn has opposed and sought to

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expose, brings to mind the verse in Rudyard Kipling’s poem “If,” wherein Kipling states, “If you can bear to hear the truth you’ve spoken twisted by knaves to set a trap for fools.”

An analysis of what Michael Flynn has done in the four years in which he has engaged in litigation against the Church of Scientology and on behalf of former Scientologists reveals the following:

1. Mr. Flynn sued the Church of Scientology on behalf of La Venda Van Schaick because this so-called Church, pursuant to “Guardian Program Order 121669” as implemented by the “Assistant Guardian’s Full Hat,” sought to blackmail La Venda by using her auditing information illegally culled from her PC files, and then when the Church undertook a “black PR” campaign against La Venda and Attorney Flynn pursuant to a whole host of Guardian’s Office operations, Mr. Flynn sought to expose the Organization in the media. Is this the manipulation of which Reverend Jentzsch speaks? By this time, is there any question in anyone’s mind, after Mary Sue Hubbard and ten of her other cronies have all gone to prison, that the Guardian’s Office did in fact, conduct such operations, did in fact, conspire and plan to infiltrate and steal from nearly every major state and

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federal agency in the United States, frame Paulette Cooper, frame Mayor Cazares, harass former members and their families, blackmail people, and engage in a plethora of other illegal, destructive, anti-social, and deluded activities.

2. Michael Flynn brought an action on behalf of Tonja Burden, after she had given five years of her teen-age life to L. Ron Hubbard and the Church, working 18 hours a day, 6-7 days a week, not receiving a high school education, putting on Hubbard’s pants and zipping up his fly, catching his cigarette ashes while following him around, then fleeing from the Organization in a state of total fear, picked up, brought to Los Angeles, “sec checked” on the E-meter (the religious artefact) and then made to sign $61,000 in promissory notes, releases and disclosure bonds, all to protect Reverend Jentzsch’s wonderful Church. If such activity did not take place, one would question the necessity for making a young teen-age girl participate in such activities, sign promissory notes, sign confessions from culled auditing information, and give general releases to the Church so she can merely walk out the door after expending 5 years of her teen-age life providing free

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labor to the Reverend Jentzsch and his ilk. Does the Reverend Jentzsch believe that Mr. Flynn sought to destroy religion or religious belief by assisting Tonja Burden, or that he manipulated the media by bringing a lawsuit on her behalf, or that he abused the judicial process by seeking relief on Tonja’s behalf. Indeed, Mr. Flynn has expended hundreds of thousands of dollars of his own money representing Ms. Van Schaick, Ms. Burden and others without receiving a cent from them primarily because he believes that the heavy handed tactics utilized by the Guardian’s Office and the Church of Scientology against its own members is reprehensible, should be exposed, and that such people, even if they have no money, should be afforded judicial relief.

3. Mr. Flynn defended four Scientologists who took their auditing files with them when they left the Church of Scientology in criminal actions brought by the Church (which were dismissed), and subsequently defended them in civil actions brought by the Church. Mr. Flynn has also defended numerous other people in legal actions brought by the Church including the 13 legal actions brought against him, of which 11 to date have been

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dismissed. Does anyone believe that these 13 legal actions brought against Mr. Flynn and the literally hundreds of frivolous legal actions brought against other former Scientologists and people who have spoken out against the Church of Scientology constitute anything but a campaign of the Reverend Jentzsch’s Church to use the law to harass people? And yet, it is Jentzsch who asserts that it is Mr. Flynn who is abusing the judicial process. This is “Black PR” in its ultimate form. Any knowledgeable observer need only turn to the 1960 copyrighted edition of Level O Checksheet by L. Ron Hubbard on P. 55, wherein it is stated:

“The purpose of the suit is to harass and discourage rather than to win. The law can be used very easily to harass, and enough harassment on somebody who is simply on the thin edge anyway, well knowing that he is not authorized, will generally be sufficient to cause his professional decease. If possible, of course, ruin him utterly.”

L. Ron Hubbard wrote the foregoing instruction to his underlings long before Michael Flynn ever heard of the Church of Scientology. Yet now Reverend Jentzsch claims that it is Michael Flynn who is doing what the Church has done for the past 30 years.

4. Mr. Flynn has defended Gerald Armstrong against an onslaught of harassment and litigation brought by the

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Church of Scientology for one purpose: to prevent Armstrong from disseminating the truth about L. Ron Hubbard. Any intelligent observer should ask what is the Armstrong case about? The answer is simple. Gerry Armstrong was personally appointed by L. Ron Hubbard to collect documents for a biography of Hubbard to be written by Omar Garrison. During the document collection process, Armstrong and Garrison realized that most of Hubbard’s biographical data had been fraudulently misrepresented for many years and that thousands of people who paid millions of dollars believed those fraudulent representations. Rather than perpetuate such fraud by writing a biography that was false, Armstrong left the Church, was thereafter issued an SP declare, made subject to the Fair Game Doctrine, and sought legal refuge by contacting Michael Flynn. Would any rational person do anything different? And yet the Church has expended millions of dollars and hired an army of attorneys to prevent the documents collected by Gerald Armstrong from ever seeing the light of day. In fact, the documents were intended to be shredded pursuant to a massive destruction of documents campaign undertaken by the Church in order to perpetuate the fraud that L. Ron Hubbard was not connected to the

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Church of Scientology. Has any member of the Church ever asked why L. Ron Hubbard does not want to be connected with the Church of Scientology? The answer is simple. Hubbard has been taking hundreds of millions of dollars from the Church of Scientology through a corporation called the Religious Research Foundation, which has bank accounts in Liechtenstein. These funds have been taken over many years, and the association between Hubbard and the Church if proved by a governmental agency, could result in criminal prosecution. Does Reverend Jentzsch sincerely believe that it is Michael Flynn who is engaged in a “money-making scheme” or will he open his eyes long enough to see that he is the one who is acting as a dupe for a monstrous scheme of such pernicious character that it has had to create a “Fair Game Doctrine” to “destroy” anyone who opposes it.

In creating his declaration, the Reverend Jentzsch has dutifully followed HCO Policy Letter of 11 May 1971 entitled “Black PR” by taking a few germs of truthful information and creating a “parade of lies or half-truths or exaggerations.” Although the undersigned, Michael Flynn, seriously questions

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the practicality of bothering to refute the absurd allegations in Reverend Jentzsch’s declaration, since there are many who will believe them, and suffer the consequences thereof, I have concluded that there are many people of good intentions who have been affiliated with the Church of Scientology who are honestly trying to ascertain the “TRUTH.” Therefore, for all such individuals of good will and honest intentions, who sincerely seek to find out “who is Michael Flynn” and what if any truth there is in Jentzsch’s charges, I hereby state under the pains and penalties of perjury that the following is true:

1. There is a corporation called Flynn Associates Management Corporation which was initially incorporated by Kevin Flynn as a financial consulting corporation working with a separate electronics firm incorporated by another brother of Michael Flynn, George Flynn, who is an electrical engineer. No shares in FAMCO have ever been sold to anyone, or promised to be sold to anyone, nor has FAMCO ever raised any money to finance litigation against the Church of Scientology or anyone else.

2. Michael Flynn is not collaborating with forces who are trying to destroy freedom of religion and Churches in

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America.

3. Michael Flynn is not collaborating with anyone using brutal “deprogramming” techniques. Michael Flynn has never deprogrammed anyone. Those who have come to his office seeking information, assistance, and legal advice have been freely given such information and advice without charge for the sole purpose of helping them.

4. Michael Flynn has never personally or maliciously harassed any individual members of the Church of Scientology. In fact, Mr. Flynn believes that almost all members of the Church of Scientology, including Reverend Jentzsch at one time or another may be potential clients and he believes that such individuals are the the true victims of a monstrous scheme to deprive them of their money, their careers, their labor, and unfortunately, in some instances it has deprived them of their lives. Michael Flynn has never abused the judicial process by inundating any courts with massive docket filings which were frivolous, unfounded or duplicative.

5. Michael Flynn has merely exercised his First Amendment rights to speak out and oppose an organization whose 11

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top leaders have gone to prison and he has never sought to manipulate the media or use libel, forgery or other improper means in any of the litigation.

6. Michael Flynn has made no fraudulent representations of any nature or description but has merely sought to expose the representations made by the Church of Scientology.

7. Dr. John Clark has never been part of any operations of FAMCO of any nature or description, nor has Kevin Flynn through FAMCO or otherwise, attempted to involuntarily kidnap or brutalize anyone.

8. The “class action case development program” related to the fact that shortly after the inception of the La Venda Van Schaick suit, literally thousands of former Scientologists over a period of many months contacted the office of Michael Flynn seeking legal redress against the Church of Scientology. The attorneys involved in the litigation realized that most of these individuals had highly personalized lawsuits that were more subject to individual suits than a class action suit. For that reason, during 1981, more than a year after the beginning of the Van Schaick suit, the various

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attorneys began to develop a program to enlist the aid of other attorneys throughout the United States to seek legal counsel for the many victims of the Church. This effort has continued to the present day. Any one who knows anything about litigation with the Church of Scientology realizes how difficult it is to convince lawyers to litigate against the Church of Scientology when they know that they are going to have to take the case on a contingent fee basis, suffer through years of obstreperous and vituperative litigation, expend thousands of hours of work and potentially hundreds of thousands of dollars in the preparation of the case, and then experience vicious harassment at the hands of the Guardian’s Office. It is obvious under such circumstances, that a concerted effort had to be made to encourage attorneys to represent thousands of victims of the Church of Scientology.

9. The charge that Michael Flynn solicited an individual named “Jim Gray” to enlist him to sell shares in FAMCO is totally false. Gray was never offered any position, no shares were ever offered to him, and why he would make such allegations in a so-called “sworn affidavit” warrants further investigation.

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10. The charge that Mr. Flynn has solicited clients in connection with the Church of Scientology is absurd. Indeed, the reverse is true. As most knowledgeable observers are aware, there are thousands of Scientologists throughout the United States seeking to obtain legal counsel to obtain redress against the Church. The problem is that it is very difficult to get lawyers to take on such cases. Michael Flynn has been refusing clients not soliciting them. Although the Michael Flynn law firm has endeavored to help these people, and has never solicited any of them, in fact, it is incapable of representing the thousands of people who need representation.

11. Regarding settlement, in January 1981, the Church of Scientology through its lawyers, contacted Michael Flynn’s office and proposed settlement of all existing lawsuits against the Church. Pursuant to his ethical obligation under standard legal procedures, Mr. Flynn communicated the proposed settlement offer to all of his clients. The clients indicated that they wished to pursue the settlement discussions and to seek settlement if the Church was willing to pay reasonable

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damages. After a period of approximately 7 months of settlement negotiations, and after the Church had agreed to pay 1.6 million dollars to all of Mr. Flynn’s clients with pending or proposed cases, the Church demanded that all files relating to these individuals be turned over to it. This demand was refused and settlement negotiations terminated. The Church then brought one of its thirteen lawsuits against Michael Flynn and his colleagues claiming as does the Reverend Jentzsch that the settlement negotiations, which were initiated by the Church, constituted extortion! The suit was thrown out by the Los Angeles Federal District Court. It is a total falsehood to state that Mr. Flynn was going to leave any of his clients in the “cold” as suggested by the Reverend Jentzsch.

12. Jentzsch claims that Mr. Flynn is an advocate of “violent depersonalizings and brain-washing techniques” used by Dr. John Clark and the American Family Foundation. First of all, Michael Flynn has never advocated nor would he ever participate in any such activity. Secondly, to his knowledge, neither Dr. John Clark nor the American Family Foundation has ever participated in any such activities. Thirdly, Michael Flynn is not

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part of the American Family Foundation. The idea that Dr. John Clark is financing any part of the litigation relating to the Church of Scientology is a total falsehood. Does the Reverend Jentzsch sincerely believe that psychiatry and psychiatrists are as “evil” as he states in his declaration? Does he really believe that men and women who have studied medicine, chemistry, biology, and related disciplines through four years of college, three years of medical school, two years of residency and then generally two more years of residency for a total of eleven years after high school as a group are “evil”? Jentzsch states that “psychiatry seeks to destroy worship, to create evil, to create hate and to destroy religious freedom.” Any person of rational intellect must question how someone in the position of Jentzsch can honestly, under oath, make such an absurd, deluded, hatred-filled statement. Does the Reverend Jentzsch purport to claim that every one of the thousands of members of the medical profession practising psychiatry across the United States are trying to “destroy worship,” “create evil,” “create hate,” and “destroy religious freedom”? If the advancement of the human race through scientific analysis, coupled-with a deep abiding love for humanity

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and the care of the mentally and emotionally troubled in our society constitutes “pro-psychiatry loyalties” (P. 19 of the Jentzsch Declaration), then Michael Flynn admits to such.

13. Jentzsch claims that Michael Flynn “kidnapped, held against his … will, subjected to frightening threats and intimidation, and coerced into changing his beliefs,” one Steve Miller. In fact, the Church, through Steve Miller, brought a lawsuit against Michael Flynn and many other individuals who had never even met Steve Miller, knew nothing about him, solely for the purpose of harassment. This is one of the thirteen lawsuits brought harassively by the Church of Scientology against Michael Flynn, which has also been thrown out by the Los Angeles Federal District Court. For Mr. Jentzsch to compare Michael Flynn to “Nazi torturers,” participating in “beatings and rapes” and other such “atrocities,” represents delusion on the border of madness. Any person who has read the Jentzsch declaration and believes that Mr. Flynn would participate in such activities without contacting Mr. Flynn or his colleagues directly and seeking the truth, deserve Jentzsch, the Church of Scientology, and their ilk. Such delusion as set forth in the Bhagavad-gita, aforequoted, brings

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about the destruction of the intellect from which a person may ultimately “perish.” The mad ramblings of the Reverend Jentzsch bring to mind the insane and catastrophically destructive beliefs and activities of groups such as the Reverend Jim Jones, which feed on their own self-destructive tendencies. In his declaration, Jentzsch has Michael Flynn involved in “brutal depersonalizing schemes” against Steve Miller, Thomas Ward, Arthur Rozelle, Monty Pelto, Lark Brightman, and “a pregnant woman.” The facts are that prior to the suit brought by Steve Miller against Michael Flynn and others, Mr. Flynn had never even heard of Steve Miller!

Similarly, until Mr. Flynn read the Reverend Jentzsch’s declaration, he had never heard of and knows absolutely nothing about Thomas Ward, Arthur Rozelle, Monty Pelto, Lark Brightman or “a pregnant woman” who have allegedly suffered “atrocities” at the hands of “depersonalizing thugs.” The very suggestion that Michael Flynn had engaged in such activity for the purpose of having “Joey Flanagan,” Dr. John Clark, or Kevin Flynn bring him clients constitutes a falsehood beyond rational belief. Any one of the thousands of Scientologists who have contacted Mr. Flynn in the last four years is

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aware that he has continually turned down hundreds of clients because he is simply unable to help them. The suggestion that he is out beating them up and kidnapping them for purposes of solicitation should given anyone of a reasonable intellect a good perspective of the Reverend Jentzsch’s mental aptitudes.

14. The Reverend Jentzsch also has Michael Flynn and Kevin Flynn attempting to deprogram some people called the Garrisons. However, Mr. Jentzsch failed to state in his declaration that Warren Friske, the former head of the B-2 Bureau in Boston has stated under oath and in an affidavit that the Garrisons brought suit against Kevin Flynn and Paulette Cooper for an alleged deprogramming knowing that Kevin Flynn and Paulette Cooper had nothing to do with it, and that the suit was brought solely for the purpose of harassment. Recently, Bill Franks, former Executive Director International, confirmed that these suits such as the Miller suit and the Garrison suit, which are two of the thirteen suits brought against the Flynn office, were brought solely for purposes of harassment and that in fact, the Church knew in advance that Michael Flynn did not know about, nor did he participate in any way in any “meetings”

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with the Garrisons or Steven Miller. Significantly, while the Reverend Jentzsch accuses Mr. Flynn of the beatings and punchings set forth in his declaration, Mr. Flynn recommends that any present or former Scientologist interested in ascertaining the truth about such activities, contact John Nelson, Bill Franks, David Mayo and others similarly situated who have been subjected to punching, spitting, and other irrational or abusive behavior of David Miscavige and the RTC. Indeed, the deluded ramblings of the Reverend Jentzsch presumably acting as the mouthpiece for the RTC is analogous to the apocalyptic predictions of St. John in Ch. 13 of the Book of Revelations wherein it is stated that a false prophet bearing the number of the “Beast 666” shall lead astray the inhabitants of the earth requiring everyone to worship “the image of the beast who should both speak and cause that whoever should not worship the image of the beasts shall be killed.” The “Fair Game Doctrine” which calls for “enemies” of Scientology (which is the only salvation for mankind per the words of L. Ron Hubbard) to be “lied to, sued, cheated or destroyed,” bears remarkable similarity to the predictions of St. John. The efforts of the Church of Scientology and the Reverend Jentzsch to destroy Mr. Flynn pursuant to such deluded doctrines solely because

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he speaks out and seeks to assist people who have been victimized by the Church and the RTC, suggest that the Reverend Jentzsch would do well to read both the new and the old Testament. The destruction of human beings in the name of religion which the Reverend Jentzsch and his followers claim to be a part of, is something that man has suffered from for hundreds of years. The Reverend Jentzsch’s fervent, maniacal beliefs have led him into a similar trap.

15. Reverend Jentzsch states on P. 24 of his declaration that seven suits have been filed by the Church and that five are still pending. The truth is set forth below with names of the cases and the docket numbers:

I. Church of Scientology of Boston, Inc. v. Michael Flynn, Civil No. 40906, (Suffolk Superior Court, Massachusetts, 1980). Brought against Michael Flynn in February 1980 because 4 members of the Church left, took auditing files with them and gave Mr. Flynn possession of them as their lawyer.

II. Church of Scientology of Nevada, Inc. v. Thomas Hoffman, Kevin Flynn, et al., Civil No. LV-80-10-HEC, (D.Nevada, 1980). Suit dismissed in April 1980, four months after it was brought.

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III. Church of Scientology of Nevada, Inc. v. Kevin Flynn and La Venda Van Schaick, Civil No. 196880, Nevada Circuit Court. Case dismissed against Kevin Flynn and Van Schaick.

IV. Church of Scientology of Nevada, Inc. v. Michael Flynn, Civil No. 202573, Nevada Circuit Court. Case dismissed.

V. Steven Miller v. Michael Flynn, et al., Civil No. 81-4275 (C.D.Calif., 1981). Case dismissed against Michael Flynn and others.

VI. Cazares v. Church of Scientology, Civil No. 81-3472-CA-01, Volusia County Circuit Court. Contempt action against Michael Flynn dismissed.

VII. Garrison v. Kevin Flynn, et al., Civil No. 81-2608-T (D.Mass., 1981), Case pending.

VIII. Church of Scientology of California, Inc. v. Michael Flynn, Thomas Hoffman and Thomas Greene, Civil No. CV-83-896-CBM (C.D.Calif., 1983). Case dismissed.

IX. Church of Scientology v. Michael Flynn, Thomas Hoffman, Thomas Greene and Kevin Flynn, CV-81-3259-CMB; CV-81-3260-CMB (C.D.Calif., 1983). Case dismissed.

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X. Flag Service Org, Inc. v. Michael Flynn and the City of Clearwater, Civil No. 82-440-Civ-T-WC (Tampa Fla., 1982). Motion to Dismiss pending.

XI. Church of Scientology of California, Inc. v. Michael Flynn, 83-2386-S (S.Mass., 1983). Case dismissed.

XII. Church of Scientology of California, Inc. v. Michael Flynn, CV-83-5202-R (C.D.Calif., 1983). Case dismissed.

XIII. Church of Scientology v. Gerald Armstrong, Civil No. C 420 153, Los Angeles Superior Court. Contempt action against Michael Flynn dismissed.

16. The Reverend Jentzsch refers to an incident in 1976 wherein Mr. Flynn allegedly “wrote a bad check for $6500.00.” However, Reverend Jentzsch failed to state in his Declaration that the $6500.00 check was written in connection with a divorce proceeding for one of his clients, in which the husband of Mr. Flynn’s client gave Mr. Flynn a check which was deposited into Mr. Flynn’s account and upon which Mr. Flynn was instructed by his clients to issue a $6500.00 check as part of the divorce settlement. The husband however, failed to place sufficient funds in the bank to satisfy the check given to Mr. Flynn, which resulted in the $6500.00

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check issued by Mr. Flynn being returned for insufficient funds. Responsibility for the entire episode was the fault of the husband, in the divorce proceeding. Isolating and falsely stating the circumstances surrounding tne $6500.00 check is typical of the thinking and false premises inherent in the Jentzsch Declaration.

As for the quotations from the Attorneys Geller and Katz, who represent the Church of Scientology, both of whom have been involved in actions against Michael Flynn and his office for which they have received thousands of dollars in legal fees to bring such harassive suits, financed by the “donations” of Church members, the motives of such attorneys is self-evident. The allegations that Mr. Flynn has been disruptive in depositions and engaged in “evasive and dilatory tactics” is ridiculous. It is Mr. Flynn who is seeking to obtain trials of all of these cases and it is the Church of Scientology which has paid millions of dollars in attorneys’ fees to prevent the cases from being heard. Any knowledgeable observer is aware that Church “donations” have been flowing out of the Church in a rapidly increasing rate to fill the coffers of the many Church

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lawyers who are representing the Church as a result of the surge of legal proceedings against it.

13. The Probate case relating to Ronald DeWolf and the “missing person status” of L. Ron Hubbard was brought for the simple reason that L. Ron Hubbard’s own attorney, Alan Goldfarb, stated that L. Ron Hubbard was missing, and that he could not appear in one of the many suits that had been brought against him because no one knew where he was and no one from the Church of Scientology had communicated with him since February 1980. It was the conduct of Hubbard’s own lawyers and the group that now run the RTC and the failure of Hubbard to appear and defend himself in Court or even to appear and defend or assist his wife for that matter, which resulted in the probate case being brought. It was only after Hubbard filed a legal declaration, the day before a trustee was to be appointed in the probate case, that the Court held that L. Ron Hubbard was not a missing person. The finding of contempt against Mr. Flynn was one of the numerous legal proceedings brought against him. However, the Reverend Jentzsch failed to state that Mr. Flynn did not even appear and defend the contempt proceeding

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because of the onslaught of other harassment brought against him by the Church, but that the judge stated that no bad faith or misconduct was involved, but merely a technical violation of one of the court orders regarding disclosure of information about Hubbard.

19. The allegations that the Church of Scientology is beginning to win on the legal front are ridiculous. Every suit brought on behalf of former Scientologists or victims of the Church of Scientology in which Michael Flynn has participated is proceeding toward trial. Extensive legal obstacles interposed by the Church have been overcome, and judgment day is at hand. At the same time, the Church of Scientology is on the verge of losing its tax-exempt status, the Canadian government is investigating numerous fraudulent and criminal activities of the Church which may result in the indictment of high-level Church officials including L. Ron Hubbard, the Church of Scientology is disintegrating across the world, L. Ron Hubbard is in hiding, and the Reverend Jentzsch, on behalf of the RTC is now engaging in deluded and vitriolic diatribes that have no basis in reality.

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20. The idea that Kevin Flynn, Thomas Hoffman or Michael Flynn or anyone associated with them had anything to do with the forgery of one of L. Ron Hubbard’s checks is simply too fanciful to warrant extensive discussion. Suffice it to say that it was Michael Flynn who brought to the attention of the public and the courts the fact that one of L. Ron Hubbard’s checks, in the possession of individuals controlling the RTC was forged and an attempt to pass it was made right at the time in May-June 1982, when Hubbard wrote a will and in the will turned over control of Scientology to the RTC. It was at the same time that the RTC began to assert total dictatorial control throughout the Church of Scientology. Any intelligent observer can put two and two together to conclude that Mr. Flynn would not participate in the forgery of a two-million dollar check and then do everything in his power to investigate it.

21. The Reverend Jentzsch states that the Church does not violate the priest/penitent privilege. Anyone who is knowledgeable about Guardian’s Office B-l files collected from culled PC files knows that Reverend Jentzsch speaks falsely.

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In sum, there are certain inescapable conclusions, which even the Reverend Jentzsch would be unable to deny. These are that Michael Flynn has for four years assisted hundreds of former members of the Church of Scientology without receiving a penny from them. Michael Flynn has expended hundreds of thousands of dollars from his own money to help these people. These same people expended years of their lives and millions of dollars in a fanatical effort by the Church of Scientology to take labor and money from its victims with little or no return. How many former staff members of the Church of Scientology after years of labor at $17.50 a week are now confronted with lost educations, lost career opportunities, no pension or profit sharing plan, no health insurance benefits, disrupted or disconnected family situations, or failed or destroyed marriages. It is the Church of Scientology which has continued to drain the life blood out of its victims like a parasite sucking on a sore wound. Mr. Flynn has sought to heal these wounds. It is earnestly recommended that any present or former Scientologist who objectively investigates the “data” relating to the activities, conduct, believes and character of Michael Flynn, as opposed to the activities, beliefs, conduct and character of the RTC and its mouthpiece, the Reverend

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Jentzsch, will come to the inescapable conclusion that it is the RTC who deals in lies and it is Mr. Flynn who seeks justice. Indeed, any person of good intention who is or has been associated with the Church of Scientology and who has been subject to PTS declarations, SP declares, or any other of the insane activities that is characteristic of the RTC should seek justice and in doing so should heed the words in the Book of Isaias, Ch. 40 Verse 29-31, wherein it is stated that the seekers of truth and justice shall be given strength and increase in force and that “they shall run and not be weary, they shall walk and not be faint, and that they shall renew their strength and take up wings as eagles.” How many of you of you have been subjected to a “suppressive person declare” after giving years of your life and labor and thousands of dollars to the Church of Scientology? Where could the justification for such malicious conduct come from? One need look no further than the writings of L. Ron Hubbard on the subject of “the criminal mind.” Mr. Hubbard states that a criminal is one who hides and who cannot confront truth or reality. If such is true, and it is true that Mary Sue Hubbard and other Church leaders have gone to prison for “crimes,” and it is true that the

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Guardian’s Office as the controlling agency of the Church has engaged in hundreds of criminal acts over many years and it is true that L. Ron Hubbard was the “Founder” and creative force behind the Church, then one should ask, Where is L. Ron Hubbard? Is he in hiding and if so, Why? In order to answer this question, I recommend that you read L. Ron Hubbard’s, “The Criminal Mind.” After reading it, ask yourself, Who is hiding? Michael Flynn or L. Ron Hubbard, Pat Broeker, David Miscavige.

Signed under the pains and penalties of perjury this 4th day of April, 1984.

[Signed] Michael Flynn

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Notes