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 JONATHAN W. LUBELL 
MARY K. O'MELVENY 
COHN, GLICKSTEIN, LURIE, OSTRIN, 
LUBELL pL LUBELL 
1370 Avenue of the Americas 
New York, New York 10019 
(212) 757-4000 
JOHN G. PETERSON 
PETERSON &'BRYNAN 
8530 Wilshire Boulevard 
Beverly Hills, California 90211 
(213) 659-9965 
Attorneys for Plaintiff 
 
 UNITED STATES DISTRICT COURT 
CENTRAL DISTRICT OF CALIFORNIA 
 
 CHURCH OF SCIENTOLOGY OF ) CASE NO. 83-5052 R 
CALIFORNIA,  
 ; DECLARATION OF JOHN G. 
Plaintiff,  
 ;  
 PETERSON 
vs.  
 MICHAEL J, FLYNN,  
 Defendant 
 
I,  JOHN G. PETERSON, declare as follows under penalty of 
perjury:  
 The purpose of this Declaration is to detail for the  
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 22 Court the pattern of harassive, abusive, and criminal conduct  
 23 instigated and executed against the Churches of Scientology by  
 24 Boston lawyer MICHAEL J. FLYNN and a,number of co-conspirators,.  
 25 These persons have operated on their own and in unison as a 
 
3c;  front group called the Flynn Associates Management Corporation  

 Said conduct includes, inter alia (1) conspiracy in the 
form of a moneymaking scheme in which FLYNN, via FAMCO, promised 
investors up to a 400% "quick" return on their investment in 
exchange for buying shares to support massive litigation against 
the Church of Scientology; (2) collaboration with and funding of 
agents and operatives using brutal psychiatric "depersonalizing" 
techniques in an attempt to sway members of the Church of 
Scientology away from their religion and channel them into 
filing suits against the religion of Scientology; (3) abuse of 
the judicial process by inundating the courts with massive 
filings of frivolous, unfounded and duplicative lawsuits; 
(4) the planned usage of lies and inflammatory statements in : 
order to manipulate the media and government and thus influence 
pending litigation; (5) the use of libel, forgery and other 
criminal means in order to negatively influence pending 
litigation; and (6) the extensive use to which FLYNN has 
utilized Nevada residents in his overall scheme.  
 The information contained in this section is derived from 
sworn deposition testimony, documents authored by or for MICHAEL 
FLYNN, court proceedings and affidavits filed therein which the 
Court can take judicial notice of, newspaper reports and other 
sources, including the reports of private professional 
investigators. They all clearly evidence FLYNN's unfounded 
attacks on Scientology and CSC with the primary goal of 
extorting money from the Church in consideration of his 
terminating his unfounded litigation .and other governmental  
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 attacks and interference with the practice of the Scientology 
religion. 
 
 THE RELIGIOUS STATUS OF SCIENTOLOGY 
FLYNN has long attempted to undermine the religious 
status of Scientology. This is a matter which has been raised, 
and conclusively proven, by various Churches of Scientology in 
every court in which that issue has been litigated. The High 
Court of Australia, in October, 1983, after well over ten years 
of litigation involving the religious status of the Church of 
Scientology, concluded in the concurring opinion of Justice 
Murphy:  
 The applicant has easily discharged 
the onus of showing that it is 
religious. The conclusion that it is a 
religious institution entitled to the 
tax exemption is irresistible. 
(See High Court ruling, Opinion of Justice Murphy, attached in 
Exhibits to this sectionl). The Honorable Consuelo Marshall, 
Judge for the United States District Court for the Central 
District of California, ruled similarly in the case of Jane 
Peterson, et al. v. Church of Scientology of California, et al., 
Case No. , in 1983, stating:  
 1 . The religion of Scientology is 
a bona fide religion with all the  
 accoutrements of a religion. The Church  
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 of Scientology is a bona fide religious 
institution. . . . This case shall 
proceed on the basis that as a matter of 
fact and law Scientology is a religion 
and the Church of Scientology of 
California is a religious institution, 
entitled to the protections of the First 
Amendment to the Constitution of the  
 United States. 
Many other courts throughout the world have similarly found 
Scientology to be a valid religion. Where Scientology has been 
recognized as a religion in this country, it has been held to be 
entitled to all Constitutional and judicial safeguards that all 
other recognized and established religions receive. 
 
 THE CLASS ACTIONS 
Up until December 13, 1979, hlICHAEL FLYNN's law practice 
had centered on medical malpractice. This changed when FLYNN 
filed a so-called "class action" suit against CSC. This lawsuit 
strangely had only one plaintiff, an apostate former 
Scientologist and former Nevada resident by the name of Lavenda 
Van Schaick.  
 While the one person class action suit was pending, 
FLYNN initiated a series of virtually identical individual 
lawsuits. Using the Lavenda VanSchaick class action as a front, 
FLYNN solicited clients and attornevs to renresent some of them  
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 part of a well-developed scheme later formalized into a 
corporation called "FAMCO". These suits were brought by 
twenty-seven different persons (including Nevada residents Tonja 
Burden, Jane Peterson, Richard Peterson, Tom Jefferson and 
Debbie Keck) even though the claims involved virtually identical 
complaints, causes of action and even verbatim pleadings, which 
were substantially identical to the original, one person class 
action suit. FLYNN had not and has not yet filed any motions 
which would legally establish the existence of the "class" 
claimed or to establish the class of the suit he originally 
filed. The intention was only to make money by destroying the 
religion whatever way he could. 
 
 ABL!SE OF THE LEGAL SYSTEbi--FAMCO 
On August 28, 1980, Flynn Associates Management 
Corporation (FAMCO) incorporation papers were filed with the 
Commonwealth of Massachusetts.1 The incorporators,  as  listed on 
the Articles of Incorporation, were Kevin Flynn (brother of 
MICHAEL FLYNN), Cheryl Flynn (wife of Kevin), and MICHAEL J. 
FLYNN. ,  
 Despite the incorporation papers of FAMCO outlining a 
normal business management corporation which dealt with 
property, bonds and business transactions, an analysis of 
documents and sworn depositions from numerous persons reveals 
that the actual intent and practice of FLYNN's plan was to use 
FAMCO as a vehicle to destroy Scientology, as further outlined  
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 below, and to make millions of dollars through the abusive use 
of the judicial system.  
 As shown in his "Scientology--Review and Planning"', 
there were four basic goals to the FLYNN strategy:  
 1 . Closing Scientology organizations (Churches).  
 2. Adverse media.  
 3. Adverse public reaction. 
4. Federal and state attacks (on religion). 
Throughout 1980 and 1981, FAMCO was used as a front to 
sell shares in the hopes of rapidly raising $180,000.00 to 
finance litigation against the Church. A "get rich quick" 
scheme outlined in one FAMCO document 2 promised FAMCO 
"investors" between $2.00 and $4.00 for every $1.00 invested in 
FAMCO shares. Solicitation took various forms, including 
personal sales pressure by MICHAEL FLYNN.  
 Clearwater, Florida businessman Jim Grey has stated in a 
sworn affidavit3 that MICHAEL FLYNN visited him in his office 
and endeavored to enlist him to sell shares in litigation. FLYNN 
offered Grey the position of "Trustee of . . . FAMCO in the 
Clearwater area". Grey describes in his affidavit that he was 
told by FLYNN that his duties as trustee woulh be to "receive, 
raise and disburse monies which would be used to file suits 
against the Church of Scientology around the country and  
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 __-1 ' See attached Exhibits.  

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 therefore break the Church financially." Simply, the design was 
to destroy religion by illegally financing litigation.  
 FLYNN also engaged in the solicitation of co-counsel in 
various other jurisdictions, based on a fee-splitting system. 
As described in the document "Scientology - Review and Planning" 
and other FLYNN documents, FLYNN's plan had as its "primary 
purpose . . . to position ourselves such that to fight  US  would ' 
be cost ineffective." In the proposal called "Class Action Case 
Development Program"1 sent by FLYNN with a cover letter to 
numerous attorneys around the country in the hopes of getting 
them to join his anti-religious extortionist war, his proposal t 
forecast "one thousand lawsuits (against the Church of ' 
Scientology) . . . by the end of 1981." The idea being to ! 
create chaos and destroy.  
 A memorandum from a Los Angeles attorney, Chuck Diamond, 
posted on a bulletin board in the Los Angeles office of 
O'Melveney & Meyers2, illustrates FLYNN's plan very well. The 
memo asserts that Diamond's old schoolmate, FLYNN, "has made a 
substantial living suing the Church of Scientology." The memo 
indicates that there would be openings for "lawyers in the Los 
Angeles area who would be willing to undertake the joint 
prosecution of some of these claims (FLYNN's clients) on  a 
 contingent fee basis."  
 MICHAEL FLYNN apparently never informed Mr. Diamond that 
FLYNN had never won a cent from the Church in his several years  
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 of anti-religious litigation, and thus FLYNN's "prior successes'1 
alluded to in the memo are nonexistent. An attorney beguiled 
into "joining forces" with FLYNN because of these "prior 
successes" and the lure of a "substantial living" as mentioned 
in the Diamond  memo  would have linked up based on totally false 
information and promises. The term "church-busters" as used in 
the memorandum is appropriate to the context: FLYNN's campaign 
against the Church comes across as an attempt to harm and 
destroy a religion, for profit.  
 FLYNN made bold and sweeping promises to those who might 
work for or invest in his campaign. An April 22, 1981 letter1 
dangled "the opportunity to earn substantial monies" as a lure 
to potential co-counsel in FLYNN's cases against the Church. 
Since he had already saturated the Massachusetts courts with his 
"turn-key"'lawsuits, this offer was in the form of get rich 
quick promises to co-counsel in different states. Thus, FLYNN 
manipualted his way into various jurisdictions in order to 
forward his campaign to destroy a religion and make money while 
doing it.  
 FLYNN further bolstered his invitation by providing what 
he called "turn-key" or pre-packaged lawsuits. Part of the 
"Class Action Development Program" states, "We provide the 
clients, the damages, the pleadings, the memoranda, the, 
documents, the witnesses and virtually everything required for '  
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 an instantaneous trial with little or no necessity for  
:  discovery." 
 
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 ABUSE OF THE COURTS--FLYNN'S MULTI-LITIGATION 
FLYNN's animus and substantial pecuniary interest in 
attacking the Church directly in the civil actions which he 
commenced for himself and other clients or indirectly by seeking 
to divert the court's interest in the real issue of the case as 
is evident here is clear from the multitude of litigation in 
which FLYNN is involved. The following summary provides a 
partial list of state and federal cases which FLYNN has filed as 
counsel, as of counsel or as coordinating counsel pursuant to 
his illegal FAMCO program. The total recovery in damages sought 
by FLYNN, in his attack on Scientology, even in this partial 
list, is more than $1 Billion. 
 
 CURRENT SCHEDULE OF FLYNN RELATED CASES  
 Damages Prayed For 
 
 Armstrong v. CSC, LRH, CSI, RTC and  
 Does 1 through 100  
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 $ 60,000,000.00 
 
 Baptista v. C of S Msn of Cambridge 100,000.00 
Bear, Peggy v. C of S of NY, Msn of  
 East Manhattan, Celebrity 
Center, Inc., CSC 5,057,040.77 
Bear, Donald v. C of S of NY, Msn of  
 East Manhattan, Celebrity 
Center, Inc. 5,057,040.77 *  

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 Flynn v. CSC, C of S of Bsn, Kevin  
 Tighe, Robert Johnson, David 
Aden 
Garrity, Carol and Paul v. CSC,  
 MSH, LRH 
Vashel, Kim v. .C of S of Bsn, Inc., 
csc 
Hartwell, Ernest and May v. CSC 
and Does l-100 
Schemer, Homer v. LRH, ASI, David  

 Miscavage, Pat Broeker 
Hansen, Marjorie v. C of S of  
 Bosn, CSC 
Jefferson, Thomas v. CSC, LRH, MSH 
Lockwood, Dana v. CSC, LRH, MSH 
Peterson, Jane and Richard v. CSC,  
 LRH, MSH 
Samuels v. LRH 
Smith v. C of S of Bsn, CSC 
C of S of Bsn v. Michael Flynn, LUCY  
 Garritano, Steven Garritano, 
James Gervais, Peter Graves 
(counterclaim) 
 
Troy,  Janet v. C of S of Bsn, CSC 
La Venda Van Schaick v. CSC 
Christofferson, Julie v. C of S  

 Msn of Davis, CSC 
Corydon, Bent and Mary, Mark  
 Lutovsky, Phil Black, Mark 
Chacon, Church of Sciologos 
v. C of S Msn of Riverside, 
et al.  
 Clark, John v. LRH 35,000,000.00  
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 Amount to be 
determined by court 
 
 5,000,000.00  
 505,000.00  
 90,000.00  
 226,528,200.00  
 1,401,954.00  
 2,000,000.00  
 2,000,000.00  
 5,000,000.00  
 76,651,470.00  
 826.255.00  

 4,548,337.20  
 1,576,204.00  
 2,000,000.00  
 42,003,020.00  

 47,095,214.29  

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 Wakefield, Margery v. CSC In excess of  
 $10,000.00  
 Cazares, Gabriel and Margaret v.  
 CSC, Merrell Vannier, MSH, 
LRH and Joseph Lisa In excess of  
 $1,500,000.00  
 Wollersheim, Larry v. CSC, LRH,  
 Church of Scientology 
GRAND TOTAL  

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 100,000.00  
 $710,110,536.03  
 SCHEDULES OF FLYNN RELATED CASES DIShlISSED 
OR SETTLED 
Case Name Damages Prayed For 
Rosenkjar, Patrick v. CSC, LRH,  
 MSH $ 19,529.446.00 
Brown, Eileen v. Delphian Fdn, 
et al.  
 Re Estate of LRH (Probate) 
Barron, Mark v. C of S of Bsn   Keck, Deborah Ann v. CSC, AGLA,  
 C of S, LRH and MSH 519,276.OO 
Harper, Betsy v. LRH 
Bonstell, Joyce v. Pioneer Natl.  
 Title Insurance Co., 
et al.  
 Stifler, Dr. Lawrence v. C of S of  
 Boston, CSC 4,250,OOO.OO 
La Venda Van Schaick v. CSC 180,000.000.00 
Bear, Donald and Peggy v. C of S 
of NY, CSC Msn of East 
Manhattan, Celebrity Center 
Inc, CSC (two separate suits)  
 Cooper, Paulette v. C of S of  
 Bsn, LRH, MSH  
 2,800,OOO.OO 
Value of estate of LRH  
 41,962.50  

 1,248,OOO.OO 
 
 860,000.00  

 28,000,000.00  
 25,000,000.00  
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 Cooper, Paulette v. C of S 
of NY, Inc. et al. 
Cazares, Gabriel and Margaret v.  
 CSC, Merrell Vannier, 
Clyde H. Wilson,  Jr., 
 Wilson, Wilson & Namack 
Chartered, Tobias Tolzmann, 
MSH, Joe Lisa  
 GRAND TOTAL 
 
 Total of all cases current 
and dismissed or settled  
 1,500,000.00  
 $299,048,684.50  
 $1,009,159,220.53  
 FLYNN's pre-packaged damage claims, however, do not hold 
up once the FLYNN client is questioned at deposition. Richard 
Peterson, one of FLYNN's clients, had alleged fraudulent 
misrepresentations in his original complaint, that complaint 
having been prepared by hlICHAEL FLYNN. However, in depositionl, 
Peterson directly contradicted what had been charged in the 
complaint, stating that he felt the Scientologists he had dealt 
with had been very sincere. Peterson described the people on the 
staff at the Church of Scientology as "honest, ethical people. 
They think they are doing the right thing. Most of them are the 
most wonderful people I have met. They are very nice, polite. 
They don't commit crimes. They don't harm you. It is a very 
ethical group." In fact, all the other plaintiffs in that 
"turn-key" lawsuit--Jane Lee Peterson, Carol Garrity, Paul 
Garrity, Thomas Jefferson and Dana Lockwood--the identical 
charge, nonetheless admitted to believing that the  
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 the firm opinion that FLYNN deliberately weaves his complaints 
from whole cloth.  
 A part of MICHAEL FLYNN's plan was the solicitation of 
clients in the hopes of having 1,000 lawsuits in progress 
against the Ch'urch by the end of 1981, in order to destroy the 
Church financially. He used estranged former Scientologists, to 
convince further apostates of the religion of Scientology that 
they "had a valid legal claim" and thus file further lawsuits. 
 
 CREATING LAWSUITS BY DEPERSONALIZATION 
BY the mid-1980's, when the solicitation of new 
anti-religious clients ran dry, in order to feed his goal of 
1,000 lawsuits, FLYNN resorted to the use of force and coercion 
in the form of psychiatric depersonalizing, designed to make 
Church members betray their religion and then bring suit for 
"damages". Flynn accomplished this via use of professional 
depersonalizer Joey Flanagan, amongst others. The plan was to 
kidnap Scientologists, hold them against their will and coerce 
them to give up their religious beliefs. The person would then 
be pressured to bring suit against their Church with FLYNN as 
their attorney.  
 Flanagan was paid by FAMCO to perform depersonalizations, 
and has admitted in sworn deposition1 that he personally brought 
at least five persons to MICHAEL FLYNN after they had been 
depersonalized. There is evidence that some of these persons 
were influenced to bring suit against the Church of Scientology  
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 offer was a threat. Unless the Church made a proposal to him 
"within the next 14 days", it could expect an "additional 8-10 
cases . . . commenced in Washington, New York and Los Angeles." 
Fifteen days later, he wrote again to attorney Jay Rothl, this 
time saying that he planned "20 additional law suits" and that 
unless a settlement were made Quickly, "we will be left with the 
sole option of increasing the litigation as rapidly and in as 
great a number as possible." Amongst the cases FLYNN was 
offering to settle were those outside Massachusetts on which he 
was not even attorney of record, including the Ernie and Adelle 
Hartwell case in Las Vegas. -1  
 FLYNN's manipulations extended further than his / 
co-counsel. Having ostensibly obtained the trust of twenty 
additional clients and convinced them that it was in their best 
interests to file suit against the Church, he was nonetheless 
proposing to drop them cold in order to get money by settling 
cases already pending, in effect using the existence of these 
future claims to settle pending claims. 
 
 USE OF THE MEDIA AND GOVERNMENT AGENCIES 
The FLYNN plan included manipulation of the news media in 
order to attempt to create poisonous publicity problems so that 
the Church would be forced into a settlement. "Turn-key 
publicity" was another part of the packaged deal offered by 
FLYNN to prospective co-counsel. FLYNN was to provide a press  
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 after being put into a suggestible state following dates of 
torturous depersonalizing, not unlike the insidious, painful 
"brainwashing" techniques used on American servicemen by Chinese 
Communists during the Korean War.  
 In 1981, Scientologist Steve Miller was another target of 
the FLYNN depersonalizing scheme. I Miller was held against his 
will and harassed, badgered and threatened relentlessly for 
three days by three men in a vain attempt to get him to destroy 
the existence of his religious beliefs. During these three 
days, Miller was repeatedly encouraged to visit FLYNN to discuss 
the possibility of engaging in litigation against his Church. 
Kevin FLynn, who simultaneously acted as private investigator 
for his brother MICHAEL FLYNN, candidly admitted in deposition 
testimony that the unsuccessful depersonalizing of Miller cost 
Miller's parents $lO,OOO.OO, FAMGO's fee for its services, and 
that FAMCO paid the depersonalizers from its own bank account.:! 
 
 FLYNN'S SETTLEMENT STRATEGY 
While FLYNN promoted his avaricious plan to various i 
counsel in different states as a get rich quick scheme, a 
further look shows how he has manipulated.his co-counsel in 
order to achieve his own ends. In a June 2, 1981 letter to one 
of the Church's counsel, Jay D. Roth3, FLYNN proposed to settle 
"all existing cases" for $1.6 Million. Included in FLYNN's 
 
 ___-1 , See attached Exhibits. _  
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 package of poisonous material to lawyers who agreed to 
participate in "turn-key" lawsuits.  
 FLYNN's multi-pronged attack on the Church included 
newspapers, national magazines, wire services, local and , 
national television programs, and even provisions for book and 
film rights. FLYNN documents listed 15 separate detailed 
examples in a document entitled "Loss of Income and Business" 
under a section entitled "National Media attention attributable 
to our office." These include highly defamatory segments on "60 
Minutes" and ABC's "20/20", an article in Reader's Digest in 
which FLYNN's name appeared as an advertisement for future 
suits, wire stories on both Associated Press and United Press 
International and a sensationalized article in the National 
Enquirer.  
 In addition to the above actions, MICHAEL FLYNN and his 
co-conspirators executed their plan by attemptin,g to instigate 
prejudicial government attacks on the Church's religion through 
lies and false reports. In a blatant display of contempt for 
the U.S. Constitution and the First Amendment, MICHAEL and Kevin 
FLYNN plotted how the power of government could be used 
prejudicially against the Church. Kevin Flynn wrote in the 
March Conference notes1 that "issues (at the planned March 
conference) include . . . integration of government and private 
sources" for data collection and exchange. He proposed 
"Development of routine litigation support and consultation 
service between private and government attornies engaged in  
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 Scientology litigation." In the same seminar, he included a 
segment on "integration of organizational file data"--this data 
to come from not only the IRS, but from several other U.S. 
governmental departments as well.  
 In the "Class Action Case Development Program" document, 
he enumerates the prejudicial government agencies and numerous 
media FLYNN has been in contact with regarding the religion of 
Scientology, and he boasts that in a certain IRS case involving 
the Church of Scientology "most of the individuals testifying 
are our clients."  
 Attorney Stephen P. Delinsky, former head of the criminal 
division of the Massachusetts State Attorney General's office, 
was quoted in the May 31, 1983 Boston Globe as being sharply 
critical of FLYNN for "trying to use a possible prosecution of 
Scientologists to assist his own civil litigation." Delinsky 
states, "I felt that was not the proper use of the criminal 
justice system, and I felt uncomfortable." FLYNN has tried the 
same technique of lighting brush fires elsewhere.  
 In Arizona, it recently came to light that FLYNN had 
spread the false rumor that an investigation was underway in the 
state, and that indictments would be handed down on 
Scientologists by the Attorney General',s office there. This 
rumor stretched so far as to have the Nevada State Attorney 
General's office contact the Arizona office to determine the 
truth or falsity of the matter. It was found that FLYNN, through 
 
hin  manipulated client. Nevada resident Ronald DeWolfe, was the  I 
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 FLYNN appears to prefer the launching of a whisper 
campaign rather than an investigation of the Scientology 
religion by stating that indictments will be handed down soon 
and arrests will be made. This has occurred in Arizona, Boston, 
Florida, Los Angeles and even in the open court of Riverside, 
California. FLYNN seeks to misdirect the attention of the 
public and law enforcement away from him and onto the innocent. 
 
 FLYNN'S TACTICS EXPOSED BY DECLARATION 
OF PAULETTE COOPER 
FLYNN's plan also involved manipulating his clients into 
giving perjured testimony, or participating in other improper 
conduct. Typical of FLYNN's treatment of his clients while 
pursuing his outrageous and unfounded attacks on Scientology, is 
the way he worked with Paulette Cooper, an outspoken litigant 
against Scientology.  
 As Ms. Cooper's affidavit graphically details 
(Exhibit "2" herein), FLYNN made clear his strategy to "quickly 
and easily win" cases by "conducting an attack against 
Scientology Founder L. Ron Hubbard" by naming him as a defendant 
in her pending lawsuits. FLYNN specifically told Cooper that he 
believed that "Hubbard would never appear" in those suits 
because "by approximately 1979, Mr. Hubbard had severed his ties 
with the Church." (Cooper affidavit, Paragraph 4.)  
 FLYNN boasted that such a ploy would result in quick 
money judgments because the litigations could be "Quickly  
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 Mr. Hubbard." q&) Cooper explains how FLYNN filed sworn 
statements in her cases alleging Hubbard's control when Cooper 
lacked any evidence whatsoever of such a claim, "solely for 
strategic reasons in pursuit of a default judgment". (Id., 
Paragraph 3.)  
 Like his disregard of legal process and lack of respect 
for the courts as evidenced from his being held in contempt by a 
Florida and a California court, nothing stood in the way of 
FLYNN toward his goal of making money and more money by his 
attacks on Scientology. 
 
 FLYNN'S IMPROPER CLEARWATER ACTIVITY 
By 1982, FLYNN had not yet seen any fruits of his 
onslaught of litigation and so embarked on one of the most overt 
attempts to influence his civil litigation. This occurred in 
Clearwater, Florida. For approximately $150~,000.00, FLYNN 
" so 1 d " himself to the City of Clearwater as an "expert" on 
Scientology. He proceeded to hold five days of "public hearings" 
on Scientology, flying in a number of his clients and making 
wild unsubstantiated claims about the "criminal" dealings of the 
Church in Florida, with attendant media publicity, following his 
plan.  
 After this heresy trial in Clearwater, FLYNN drafted an 
anti-religious ordinance for the City which cut across the very 
foundation of First Amendment rights and freedoms. So blatant  
 . . . . e-L-2 --^A.2 ^..I +b.-+ +he  Nofinnel Pnlrneil o f 
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 Baptists and others sued the City of Clearwater. Federal 
District Judge Elizabeth Kovakevich threw this first ordinance 
out, saying "A cursory reading of Ordinance 3091-3 should 
indicate even to a layman that the ordinance impacts upon First 
Amendment freedoms . . . . Accordingly, the Court declares  
 Clearwater City Ordinance . . . unconstitutional . . . ."  
 After two years of operating on his plan, neither FLYNN's 
share-selling scheme nor his large number of lawsuits filed had 
brought him the money he had expected. Coincidently, it was at 
this time in June, 1982, that an attempt was made to steal 
$2,000,000.00 from the account of L. Ron Hubbard at the Bank of 
New England in Boston occurred, by the use of a forged check. 
 
 THE FORGED $2,000,000.00 CHECK AND  
 FLYNN'S INVOLVEMENT 
It was alleged by MICHAEL FLYNN during the course of 
proceedings in a probate action filed on behalf of Ron DeWolfe 
(estranged son of L. Ron Hubbard)  in  November of 1982 that the 
attempt to pass  a  forged check by one Aquil Abdulamiar at the 
Mideast Bank in New York City was evidence of the 
nmismanagementn of Hubbard's estate. It was further alleged by 
FLYNN during the probate proceedings that agents of the Church 
of Scientology were responsible for the check forgery. 
Knowing this accusation to be false, and because neither the 
Bank of New England nor the FBI could adequately explain the  
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 Dollar check forgery was evidence of Scientologists stealing 
from Mr. Hubbard's estate in his absence. Yet now FLYNN 
consistently contends in his various lawsuits that Mr. Hubbard 
is stealing from the Church.  
 At any rate, the investigation discovered that one Akil 
Al Tamimi, was a man who used the name Aquil Abdulamiar, and 
attempted to pass the L. Ron Hubbard check along with one other 
at the Mideast Bank. Akil was found in the United Arab Emirates 
as a result of a tip generated by reward advertisements placed 
in several leading newspapers. His photograph was positively 
identified by the manager at the Mideast Bank as that of Aquil 
Abdulamiar. Confronted with this, Akil admitted his role in the 
check passing in a detailed confession which was fully 
corroborated by private investigatorsl.  
 Akil also identified his brother, Ala Fadili Al Tamimi, a 
former resident of the Boston area, as another participant in 
the check scheme. Located in jail in Italy, Ala Tamimi also 
provided a detailed statement of the entire operation involving 
the forged Hubbard check2. Ala indicated that he personally had 
arranged to have copies made of original checks removed from the 
Bank of New England, had contacted the Mideast Bank to advise 
that the checks would be deposited, and had enlisted his brother 
to pose as Abdulamair and deposit the checks.  
 Most significantly, both Akil and Ala Tamimi identified 
MICHAEL FLYNN as a major participant in the conspiracy.  
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 According to Ala, it was FLYNN's contact at the Bank of New 
England who procured the original checks to be forged, and he 
identified FLYNN as a major co-conspirator.  
 FLYNN worked conspiratorily with Ala and met with Ala in 
Boston to hatch the plan and twice more in Fort Lauderdale, 
Florida, to arrange the transfer of funds from the Mideast Bank 
account to a bank in the Cayman Islands. At the original 
meeting in Boston attended by FLYNN, Ala Tamimi and three 
others, FLYNN offered to pay Tamimi 2056, or $400,000.00, from 
proceeds of the scheme if he cooperated. If he did not, FLYNN 
implied that harm would come to Ala's brother and sons, who 
lived in Boston.  
 The attempt to pass the forged checks was thwarted after 
Akil Tamimi attempted to deposit the check. The Mideast Bank 
contacted the Bank of New England to verify if the L. Ron 
Hubbard check was legitimate. Once it was verified that the 
check was a forgery, investigations were commenced.  
 Within one week of the attempt to pass the forged check, 
FLYNN, in speaking to a Bank of New England investigator, 
inexplicably claimed to know that the check was forged and 
provided false information to misdirect the investigator 
asserting that the Scientologists may have been behind it. FLYNN 
desperately accused the Church of Scientology of involvement in 
this crime to FBI agent Glenn Prinsze, who had been assigned to 
the investigation. FLYNN's involvement was publicly exposed by 
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 check cashing scheme, FLYNN knew the Church of Scientology had 
no connection with the check but promoted and alleged such a 
false statement nevertheless. 
 
 FLYNN'S MISUSE OF THE PROBATE COURT 
FLYNN's manipulation of his clients and the judicial 
process is even more evident when one views FLYNN's California 
probate case. In November, 1982, DeWolfe filed a probate action 
in Riverside, claiming that L. Ron Hubbard was missing, his 
affairs mismanaged and that he should be appointed to control 
his father's estate. The case, ostensibly undertaken to protect 
Hubbard's estate from the hands of Church officials, and filed 
with massive media publicity containing false and scurrilous 
allegations regarding the Founder of Scientology, was filed on 
the willful lie that Hubbard was either dead of mentally 
incompetent. The court denied FLYNN's Motion for Pro Hat Vice 
on the grounds of his extreme conflict of interest in 
representing DeWolfe in an attempt to take over the estate of 
Hubbard and control his assets while openly stating that such 
assets would be used to pay three civil claimants represented by 
FLYNN in pending actions filed against L. 'Ron Hubbard, one of 
which would be FLYNN himself. After Superior Court Judge J. 
David Hennigan threw the case out of court on a summary judgment 
motion made by L. Ron Hubbard's wife in June, 1983, finding 
Hubbard to be alive, entitled to his privacy, and that his 
26 II business affairs,were being handled competentlyl, MICHAEL FLYNN  

 admitted his purpose in the probate action was only to locate 
Hubbard in order to sue him. FLYNN was also found in contempt 
during the probate pr0ceedings.l  
 FLYNN's transparent plan was recognized by the Court when 
it disqualified Flynn from acting as counsel in the above case.2 
The Court found that FLYNN purported to be representing 
Mr. Hubbard's interest in the probate case in order to "protect 
his estate", yet at the same time was suing Mr. Hubbard in 
various courts across the land --an obvious conflict of interest. 
This did not stop hlICHAEL FLYNN from just months after the 
probate action was kicked out of court, abandoning his client. 
Ron DeWolfe and filing suit himself against Mr. Hubbard alone, 
for $141 Million, while DeWolfe had to pay court costs for 
FLYNN's malice.  
 The probate action was not the only action in which a 
civil court has denied MICHAEL FLYNN access to represent clients 
under a pro hat vice motion. As recently as hiarch 6, 1985, a 
Riverside, California court again denied FLYNN's application to 
so appear, finding that he not only appeared in other court 
cases in California without a California license, but engaged in 
substantial professional business or other business activities 
in California, encouraging other attorneys to become involved in 
lawsuits involving various Scientology institutions as 
co-counsel. The court obviously took into consideration FLYNN's 
many speeches at Citizen Freedom Foundation conferences and his  
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 solicitation and association with many California law.firms in 
order to engineer and prosecute  claims  against Scientology 
institutions and Scientology's founder, L. Ron Hubbard. These 
law firm associations include, but .are not limited to, the 
following Southern California firms: Contos & Bunch, Paul 
Morantz, Daniel Olsen, Cheong and Denove, and Green, O'Reilly, 
Agnew 81 Broillet.  
 The'probate dismissal also did not stop MICHAEL FLYNN 
from totally reversing his previous representations about L. Ron 
Hubbard. While during the probate action, FLYNN represented 
that the Church was in control of Mr. Hubbard's money and 
ripping off Mr. Hubbard's estate, he concocts a different story 
a year and a half later during a recent Los Angeles case in 
which FLYNN was representing a former Scientologist who had 
stolen materials from the Church. In this later action entitled 
Church of Scientology vs. Gerald Armstrong, FLYNN's reversal of 
theories now stated that it was L. Ron Hubbard controlling the 
Church and siphoning money from the Church. FLYNN's only 
consideration is to destroy. 
 
 CONCLUSION 
MICHAEL FLYNN's program of attack on Scientology is 
conducted primarily for his own selfish greed. He has admitted 
to Scientology being a religion, but only attacks it out of 
desperation in his program of extortion hoping to induce the 
Churches to pay large sums of money to him in order that he  
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5 
 For  \nearly  thirty-five years, the Church of Scientology  
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has seen that drugs are a destructive influence in life, and has  
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helped tens of thous'ands of individuals recover from their 
damaging effects. As the Church itself has expanded, its work 
has improved the lives of hundreds of thousands of people.  
 It is a testament to the integrity of the Scientology 
religion and its members, that they have chosen to spend many, 
many times the 1.6 million dollar "settlement" offered by FLYNN 
in 1980 in order to obtain ultimate vindication in the courts, 
rather than be a victim of extortion. Certainly a weaker group, 
facing similar attack, would have long since succumbed.  
 MICHAEL FLYNN's efforts to marshal1 forces to destroy the 
existence of a religion are unique not simply because he 
attacked the Church for money, but because his fundamental goal 
was to go beyond moneymaking and seek to drive a religious group 
out of existence. His manipulation and abuse of the judicial 
system, his co-counsel, and his clients are amply evident. 
Nearly  six  years of costly and abusive attacks based on FLYNN's 
scurrilous, venomous and underhanded efforts to poison public 
opinion and get media and governmental organizations working 
against the Church have not daunted the Church's determination 
to create a brighter future and to continue helping people 
around the world.  
 On Ma5c.h 20, 1985, Jeffrey A. Tidus,  
‘, 
 defendant's coubsel,  
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 of pla'iytiff 's intention to make,, this ex  
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-..W.+r.  ann7inatinn fn  nr~r111d~. sanctions and to file further  

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1B)RS. Mr. Martinez etatcd that he would appear In oppoeitton t o t h i s a p p l i c a t i o n and c o n t i n u e t o eesk diemi66al. 
I d e c l a r e undot p e n a l t y o f p e r j u r y t h a t the forepoiag C6 true and correct. 
Executedthis 20 thdayof March ) 19H3, It Los A n g e l e s , C a l i f o r n i a . 
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