------------------------------------------------------------------- F.A.C.T.Net, Inc. (Fight Against Coercive Tactics Network, Incorporated) a non-profit computer bulletin board and electronic library 601 16th St. #C-217 Golden, Colorado 80401 USA BBS 303 530-1942 FAX 303 530-2950 Office 303 473-0111 This document is part of an electronic lending library and preservational electronic archive. F.A.C.T.Net does not sell documents, it only lends them according to the terms of your library cardholder agreement with F.A.C.T.Net, Inc. ===================================================================== DECLARATION OF LAWRENCE WOLLERSHEIM OF AUGUST 6, 1993 I Lawrence Wollersheim declare: 1.) I am an expert on the nature, tactics, and policy of Scientology and Dianetics. I was a member of Scientology for 11 years and for the last 13 years I have been involved in extensive research, litigation, and litigation consulting against Scientology and Dianetics. 2.) I have read the Petitioners Interrogatories to Respondent ([respondent]) and I am gravely concerned for the following reasons: A.) [respondent] is considered by Scientology to be a strong and active critic and adversary. In Scientology's terminology he has been put on their enemies list and has been labeled a suppressive person. The significance of being put on the enemies list by being declared by Scientology to be a suppressive person is better understood from the "Fair Game Policy." "An enemy," [they] "may be deprived of property or injured by any means by any Scientologist without any discipline of the Scientologist. . . may be tricked, sued, lied to, or destroyed." B.) Scientology and Dianetics are currently considered by most experts to be one of the most dangerous and destructive of the global cults (in the category of the Jonestown or Waco group.) Government investigatory agencies treat the possibility of violence or harassment against perceived critics or perceived adversaries as very serious. C.) The interrogatories filed on [respondent] are remarkably similar in style to the interrogatories filed directly or indirectly by the intelligence division of Scientology in many other cases involving ex-members who are now active critics of Scientology. It is my expert opinion that the information requested in these interrogatories was directly or indirectly created with the assistance of Scientology's intelligence division and goes far far beyond the very limited and specific information needed to address and resolve the issues of [respondent]'s suit against his former wife regarding limited custody and Guardian rights. D.) It is my opinion that the real reason for the request of so much unneeded and detailed financial information is to gather additional information for the intelligence divisions of Scientology for probable use in future harassment actions against [respondent]. I believe this to be a credible probability because: i.) According to firm Scientology policy [respondent]'s ex-wife currently a Scientology staff member must assist and work closely with Scientology's intelligence divisions by turning over all information on [respondent] that could involved a threat to Scientology or Scientology's public relations image and consequently their income. Especially if that threat involves any individual that she is connected to that is currently criticizing Scientology publicly (as [respondent] is.) ii.) I personally have experienced two of Scientology's financial harassment and Black PR campaigns where either my creditors, employees, or investors were contacted and discouraged from continuing their relationships with me by giving them damaging and alarming false data about me and my businesses. In Aspen Colorado in a business of mine my creditors, employees, and investors were called by an individual working for Scientology and were told I was being invested by the Security and Exchange commission for fraud. On another occasion in an earlier business of mine in California, accounts receivable debtors were contacted by a Scientology agent and discouraged from paying their bills causing the eventual collapse of that business. In this same business employees also were contacted and encouraged to quit. En masse over a 2-4 week period many left. iii.) Additionally, it is also Scientology's firm policy to punish its critics through abuse of the legal system. One aspect of that is to overwhelm their adversaries in onerous legal expenses and other harassment as is expressed in the following quotes from the writings of L. Ron Hubbard: "The purpose of a lawsuit is to harass and discourage rather than to win....Don't ever defend. Always attack. Find or manufacture enough threat against them to cause them to sue for peace. Originate a black PR campaign to destroy the person's repute and to discredit them so thoroughly they will be ostracized..." "The law can be used very easily to harass, and enough harassment on somebody who is simply on the thin edge anyway, will knowing that he is not authorized, will generally be sufficient to cause his professional decease. If possible, of course, ruin him utterly." From "A Manual on the Dissemination of Material" (1955) by L. Ron Hubbard. "The goal of the department [of governmental affairs ] is to bring the government and hostile philosophies or societies into a state of complete compliance with the goals of Scientology. This is done by a high level ability to control and in its absence by a low level ability to overwhelm. Introvert such agencies. Control such agencies." -- LRH "The purpose of the legal officer is to help LRH handle every legal, government, suit, accounting and tax contact or action... and to bring the greatest possible confusion and loss to its enemies." -- LRH Documentary evidence in Church of Spiritual Technology (COST) vs. U.S., November 22, 1989. 3 .) Because of the before mentioned it is my opinion that it would seriously endanger the livelihood and business of [respondent] to require the over broad and onerous interrogatories to be answered in their current form. Because of the proven dangerous history of the Scientology organization extreme discretion, precision, and security sensitivity is required by the court in determining what financial information is absolutely necessary to be disclosed by [respondent] to resolve the issues at hand. I declare under penalty of perjury under the laws of the State of Colorado that the above is true and correct to the best of my recollection and understanding. Executed this ______ day of August, 1993, at Pitkin County, Aspen, Colorado. ____________________________________________________ Lawrence Wollersheim From the words of L. Ron Hubbard the founder of Scientology in HCO policy letter of 18 October 1967. "In my opinion the church has one of the most effective intelligence operations in the U.S. rivaling even that of the F.B.I." From Ted Gunderson a former head of the F.B.I's Los Angeles office. [From the Time Magazine cover story on Scientology May, 1992.) Upon request, a detailed summary of government investigation and non-government documents are available which detail Scientology's history of harassment and intelligence operations Scientology's intelligence division. 4 ================================================================= If this is a copyrighted work, you are acknowledging by receipt of this document from FACTNet that on the basis of reasonable investigation, you have not been to obtain a copy elsewhere at a fair price, and that you are and will abide by the following copyright warning. WARNING CONCERNING COPYRIGHT RESTRICTIONS: The copyright law of the United States (Title 17, United States Code) governs the making of photo copies or other reproductions of copyrighted material. Under certain conditions specified by law, libraries and archives are authorized to furnish a photocopy or other reproduction. One of these specified conditions is that the photocopy or reproduction is not to be "used for any purpose other than private study, scholarship, or research." If a user makes a request for, or later uses, a photocopy or reproduction for purposes in excess of "fair use," that user may be liable for copyright infringement. FACTNet reserves the right to refuse to accept an order for copying or other duplication, or delivery of copied or duplicated material if, in its judgment, fulfillment of the order would involve violation of copyright law. ------------------------------------------------------------------- CARD CATALOG ENTRY DOS FILENAME OF TEXT FILE: E:\PCB\SCN\FILES\LEGAL\CUST1E1.TXT DOS FILENAME OF IMAGE FILES: ADMINISTRATIVE CODE: SECURITY CODE: DISTRIBUTION CODE: NAME FOR BBS: SORT TO: CONTRIBUTOR: LOC. OF ORIG: NOTES: For additional verification see image files contained in the file with same name and .ZIP extension. UPDATED ON: UPDATED BY: =================================================================