DECLARATION OF RONALD L. WADE¹

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 Declaration 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.

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 organization. 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.

7. Other parts of Mr. Gutfeld’s Declaration are equally misleading. Mr. Franks testified he did not receive 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 Scientology. This is not, however, surprising. Testimony in the 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 videotapes 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 using means to entrap Mr. Armstrong, that Mr. Armstrong did not any time seek to plant false or forged documents or do any of the things alleged by Mr. Cooley. In fact, 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 Section of the Los Angeles Police Department, the Criminal Investigation Division of the Internal Revenue Service, the Federal Bureau of Investigation and the United States Attorney’s Office in Boston, Massachusetts.

Signed under the pains and penalties of perjury under the laws of the State of Massachusetts this 18th day of April, 1985 in Portland, Oregon.

[signed]

RONALD L. WADE
SUBSCRIBED AND SWORN
to before me this 18th day of April, 1985.

Cynthia [ .] Chandler
Notary Pubic
for Oregon
My Commission Expires: 5/11/87

Notes