AFFIDAVIT OF LAUREL SULLIVAN 
 
 I I, LAUREL SULLIVAN, hereby state under the pains and 
penalties  of  perjury that I have personal knowledge of the  
 .  
 following: 

1.  I joined Scientology in 1966 at the age of 17. In 
1967, I went to work for L. Ron Hubbard (LRH) and Scientology 
and thereafter served in many staff positions in the top echelon 
 
of  the organization. I left Scientology in November 1981. 
 
 2. Although LRH allegedly resigned from all Executive 
Director positions from the world-wide Churches  of  Scientology 
in 1966, in fact, he remained in active control and as the 
ultimate authority in all of Scientology's affairs. From this 
time forward Ron Hubbard expanded his control, as  Scientology  expanded its activities. 
 
 3. In 1967, LRH was living aboard ship and was 
becoming known to Scientologists as the "Commodore" as well as 
the Founder  of  Scientology. 
 
 The ship was known as  ‘*Flag@@  and in that year LRH and a 
group of his closest supporters formed an elitist organization 
called the Sea Organization. People joining the Sea 
Organization pledged their support by signing a contract for 1  

 billion years. 
 
 I went aboard ship to serve LRH as a supporter in the 
Sea Organization in November 1967. 
 
 4. LFU3 set up for himself a  Personal  Office, Staff 
Aides and an organization of messengers to assist him in his 
personal interests and the international management  of 
 Scientology. These organizations augmented an already existing 
network of LRH Communicators, whose job it was to enforce LRH's 
orders and policy at every level of management. I also served 
as an LRH Communicator during my early membership in the Sea 
Organization. 

5.  In the late sixties, Continental Offices were set 
up to act  as  mail relays and Management Liaison Officers between 
"Flag" and Scientology Organizations throughout the world.  
 These became known as Flag Operations Liaison Offices. Attached 
hereto is a chart outlining the basis structure and control in 
effect until 1981. (Exhibit 11 
 
 6. Beginning in the spring  of  1972 until the fall of 
1973, I was involved in the international management and control  
of  personnel in Scientology. During this time, I actively 
recruited people for staff membership aboard  Flag as  the  Flag  Personnel Procurement Officer.  

 I am familiar with the recruitment and personnel 
management procedures in use at that time and assisted LRR to 
develop personnel policies which were followed thereafter. 
 
7.  In late 1973, I was assigned as LRR*s Personal 
Public Relations Officer and head of the LRH Personal Public 
Relations Bureau. From this position I was responsible to LRH 
for representations made to the public on his behalf. 
Representations made were as ordered or cleared by LRH. 
 
 a. LRE? instructed me personally in the art of "yellow 
journalism " and I learned by regularly submitting my writing to 
him that all representations made on his achievements were to be 
done using superlative and exaggerated terms. 
 
 If I toned down a claim I could not substantiate about 
his background, I was accused by him  of  downgrading his 
achievements by being inadequate in my research and not being in 
possession  of  the facts. This  was  considered a serious error 
 for  a PR person to make, and I was frequently reprimanded until I got the VVfeelV1 for how he said representations should be made. 
 
 When I reviewed LRH's personal history, I frequently 
ran  across  conflicting statements made by himself about his 
background. Many times I attempted to clarify the facts with  

. 

 him, but I found even these clarifications would turn out  to be  contrary.  At  the time, I dismissed these discrepencies on his 
part as failing  memory. 

At  times when information was presented about U&I's 
past and it was  not  flattering or raised a question about his 
own claims, LRH would complain loudly that intelligence 
operations and governmental deletion campaigns had been run 
against him altering his record. This was said specifically 
about his schooling, war record and his authorship of some 
manuscripts.  
9. He  also stated to me that his own archives had been 
stolen from him on two occasions.  He  claimed that journals of 
all his written works were stolen from his home in Phoenix in 
1953 and also that in Washington, D.C., letters, manuscripts and 
documents had been ransacked and stolen by his second wife, Sara 
Northrop Hubbard, so there was no possible way to substantiate 
his past. 
 
 10. From 1968 through 1981, there were at least 4 
major attempts to get a definitive biography of Hubbard 
completed. In  response  to a submission made in 1977 LRH's 
instructions were to write a fictionalized biography because his 
past records had been so altered by hostile hands that any --research of his past would be obstructed by such deletion  

-J : :. * -- - ,J ‘X 

. 
, 
 campaigns.  He  seemed to  be  of two minds on the dissemination  of 
 information from his past. On the one hand he wanted the 
recognition and public aknowledgement for his accomplishments, 
and on the other hand it was hard to get a real handle on his 
background.  He  has both ordered  me  to become fully 
knowledgeable on his background and ordered me to "quit probing 
around" in his past. 
 
 11. In 1979, numerous documents were recovered from 
storage and it was my hope that they would provide much of the 
missing picture. With LRH's permission, we began again to track 
his life in earnest and Gerry Armstrong was assigned as 
researcher and Omar Garrison was contracted  in  1980 as the 
author of a biography. 
 
 12. Once this project was begun, it was not difficult 
to document LRH*s past. It was, however, most difficult to 
substantiate LRH's claims. 
 
 13.  Claims  that I myself believed on entering 
Scientology in 1966, i.e.,  that Scfentology  was a science and 
that much of its foundation was the subject of laboratory 
studies, that LRH was a nuclear physicist, or a medical doctor 
or had even studied equivalent material in any degree at all 
were found to be absolutely false.  

 14. In tracking LRH's life it was my hope and 
intention to find the missing link of materials that would 
substantiate and support all claims made by LRR about his 
background and to support all his claims about the way in which 
he had conducted his research to form the scientific basis of 
Scientology. 
 
 15. In December 1979, LRR had asked  me in  written  memo 
 to procure for him the Nobel Prize for his discoveries relating 
to his Purification Program. He allocated me an unlimited 
budget of Scientology funds to do so. The Purification  Program 
 was an update of his  book  "All About Radiation."  As  it turned 
out, research files which should have substantiated all claims 
in the book "All About Radiation" were of no use at all. 
 
 They failed to contain any scientific literature or 
references. There were no test groups or any research protocol  
at  all. 
 
 16. To attempt further to substantiate LRH's claims I 
retained gene Denk, M.D. of Los Angeles to conduct tests on a 
group of 100 people and to write a medical paper on the 
results.  He  was paid $lO,OOO.OO of Scientology's funds. 
 
 This project lasted a few months and could not 
substantiate any of LRH's claims. There was no evidence that  

 this program did anything about radiation and no evidence  of  any 
physical improvement on the part of the test group beyond what 
could be expected from people put on vitamins, and daily running 
and saunas. 

17.  Claims about raised IQ; aptitude, leadership and 
personality traits as a result of Scientology auditing had a 
similarscenario. 
 
 These tests were developed by LRH, MSH, Raymond Kemp 
and Julia Salomen sometime in the sixties. 
 
 18. It is standard practice in Scientology to 
administer these tests before and after Scientology auditing. 
The tests used were the OCA (Oxford Capacity Analysis); APA 
(America Personality Analysis) and IQ test, an Aptitutde Test  
and  Leadership Survey. 
 
 By using the  same tests again  and again an improved  
score  can be obtained by virtue of the person's familiarity 
gained with the guestions. The scores appear better and better 
over time and the person himself can be fooled into believing he 
or she is actually making progress. 
 
 19. Those tests were  likewise  administered on the same 
test group studied by Dr. Denk in 1980, and it was my conclusion 

-79 

 that using these tests in this way was the same as using loaded 
dice. It was also my conclusion that whenever Scientology was 
faced with a serious intellectual challenge as was the case with 
the claims made by this program the solution taken by 
Scientology was to try to justify these claims by falling back 
on protection afforded it as a religion and by labelling those 
who questioned its scientific basis as *'hostile" or "enemies."  
 I concluded that it was in this way that Scientology created its 
own enemies. 
 
20.  One of my tasks as LRH's Personal Public Relations 
Officer was to see that LRR was remunerated by Scientology for 
service he performed on behalf of Scientology. The fact of any 
remuneration was to be kept confidential and concealed from 
staff in general and the public. A different story had been 
published for these people in articles such as What Your Fees 
Buy," (Exhibit 121). This article stated LRH received less pay 
from Scientology than the average  staff  member. This statement 
clearly was not true. Various stories about LRJi's income were 
released at different times and LRH always asserted to staff and 
public that he was poorly paid and hinted at irregularity by the 
Church  for  banking money that was otherwise due him. All of 
these stories were false. 
 
 21. In private he gave orders to collect whatever and 
whenever funds could be collected for himself. I worked closely  

 with LRH and was well briefed on his activities and 1 was put in  
 liaison with his Personal Accountant and instructed by Lm to  
 make sure the Accountant billed for all his services. 
 
 22. These  inStrUCtiOnS  to me were first set forth in 
Central Office of DIW Executive Directive (CODPIjDD) 2 authored 
 
by  LRH. 
 
 23. LPI?  was  already receiving payments from the 
Churches  of  Scientology into personal numbered Swiss bank 
accounts and I was to ensure that billings continued for the 
following: (N.B. "consulting" was a term used to justify LRH 
control. It was supposed to indicate that LRH was a private 
consultant to an independent Boards of Directors. In fact, he 
did no consulting. There was no request  for  assistance by any 
Board of Directors except as memorialized in minutes  by  these 
sham boards on LRH's order. LFU ran these corporations by 
himself and had access to all their resources. The term 
consultant was merely a smoke screen to create the impression  of  some regularity).  
 -taped and written messages to the Scientology Public 
-consulting regarding ship matters 
-consulting to Church of Scientology management 
-administrative research 
-technical research 
-auditor instruction 
 
 -9-I ( 
2 -5 “d 2  

 -case supervision 
-director's fees 
-musical scores, poems, and songs written 
-advanced Scientology upper level research whether 
released to Scientology or not. 
 
 24. LRH frequently and loudly complained that he was 
being forced to run Scientology through the incompetence of 
Scientology's executives. 
 
 Incredible and unreasonable demands were placed on 
these people in terms of work load. Frequent changes were made 
in systems and frequent shifts of personnel occurred. 

Never  once did he place the blame on himself for any . 
Scientologyfailure. It was always placed on others. He only 
claimed responsibility as the source of every success. 
 
 What most people did not see was that he was billing  
for  all his services. Staff in general just thought LRH worked 
hard and that he was forced to do this through their 
incompetence. 
 
 25. I was also to ensure that future income was 
generated for LRH and was'instructed to  create a  position within 
the Personal PRO Bureau called LRH Properties which  was  to see  

 to the compilation and editing of books, notes and tapes which 
would be sold under LRH's copyright to Scientologists and the 
Public at large. Royalties for sale of these publications and 
materials would then be collected by LRR as the author.  
 Scientology personnel were used to ghost write these 
compilations on his behalf. These staff were not separately 
paid for their work as a work for hire, neither was Scientology 
paid for the services. LRR assumed he was "owed" this service. 
 
 26. Some time in 1974, LRH gave instructions that no 
book was to be published under his name without being reviewed 
by myself. There were checklists  of  items by which the contents 
of an edited book could be reviewed and I reviewed these items. 
 
 I never saw any copy of document No. 71-2064, United 
States of American v. Article or Device....Wubbard 
Electrometer" or "Hubbard  E-Meter,”  etc. Founding Church of 
Scientology, et al, Appellants. (Exhibit 3) 
 
 There is no inclusion of the required legal notice 
regarding the E-Meter in the Dianetics and Scientology Technical 
Dictionary published  in  1975. 

 It would have been the responsibility of Mary Sue 
Hubbard and the Guardian's Office to ensure that the contents  of  this judgment was relayed so that those responsible for posting 

 -ll-  

 and publishing the required Warning notices were informed of  
 them.  
 27. The categories of income for LRH at this time 
were : 
 
 -LRH 10$'s (Repayment of services formerly delivered 
and back billed) 
-Royalties 
-Consulting  fees  from Operation  and  Transport 
Corporation, a front corporation for Scientology 
-payment of newly performed services for the Church of 
 
Scientology  of California 
-Veteran's checks. 
 
 In 1973, a sham corporation was set up from which L. 
Ron Hubbard could be paid on behalf of Scientology. This 
corporation was known  as  the Religious Research Foundation (RRF) 
with its accounts in Lichtenstein. 
 
 Between 1973 and 1981, RRF received at least $2000$300 
million dollars paid to it by non4J.S. Scientologists for 
Scientology services. 
 
 It  was  from this account (RRF) that LRH received 
regular installments. LRH ordered this account to be set up and 
controlled it from 1973 on. 
 
 -12-  

 RRF otherwise did no other business and delivered no 
goods or services. 
 
 28. Although the LFUi Accounts position operated from 
the Personal Office of LRH, LRH's accountant also  took  direction 
and supervision from  Mary Sue  Hubbard  (MSH)  who  was I&H’s  wife, 
Controller of Scientology and direct supervisor to the 
Guardian's Office World Wide. 
 
 LRH's Accountant sent billings out in many cases via 
the Guardian's Office lines and collected for LPH using 
Guardian's Office Personnel. Because of this she was also known 
as MSH's personal staff, and reported on her activities to MSH 
as well  as LRH. 

 29. During this time period Mary Sue Hubbard also 
billed out for her own consulting services and collected income 
from Scientology in  a  similar fashion to LRH. The fact of this 
income going to MSH  was  likewise kept confidential. 
 
 Additionally,  MSH  collected $17.20 allowance weekly  as 
 did the other crew, creating the impression aboard that she  was 
 there on the same terms  as  everyone else. 
 
 When crew were  sjck  they were not paid and when MSH  was 

 -130  

 sick, she went so far as to write notes to deduct the 
appropriate amount from her allowance of $17.20. 
 
 This was all smoke as MSH was making a substantial 
income.  
. 
 30. In addition, LRH, MSH and the Hubbard family were 
supported by Scientology Funds and were provided with a 
household staff. These services were far in excess of those 
provided the ordinary staff or senior executives. The medical 
and dental bills of the Hubbard family were also figured in to 
the crew budget. The Hubbard family personal expenses were 
therefore next to nothing. They had the best of both worlds. 
 
 31. The Hubbard Household Unit consisted of a 
Commodore's Steward and an Assistant Commodore's Steward,  MSH  steward,  a  steward for the children, cleaning and laundry 
stewards, a  cook and  assistant  cook,  and Transport personnel for 
the maintenance of personal vehicles and boats kept aboard 
ship. The Household Unit was maintained on a separate budget 
and operated  as a  separate organization and received 
preferential treatment and service above the rest of the 
Scientology crew. MSH  managed  the household unit for the 
family. 
 
 32. In addition to her other duties  MSH  held the title 

 
-14-b 

 of Deputy commodore with the rank of Captain. As such she 
frequently  took  into her own hands matters which concerned the 
welfare  of  ships crew, personnel recruitment requirements, crew 
training, and the welfare of children aboard. She was known for 
setting standards in this regard. 
 
 32. Part of the recruitment requirements MSH set for 
people coming to Flag were set forth in Guardian's Order 824 (GO 
Order 824) and these included a thorough glbackground*V check of 
the individual which was conducted by Bureau 1 Intelligence 
Bureau,  of  the Guardian's Office. 
 
 33. During the time I was aboard ship (except for some 
shore duty in Scotland and Los Angeles) from 1967 to 1975, the 
living conditions, welfare and pay of the crew were of last 
priority and the allocation of funds  for  improvement in these 
conditions were of last priority.. Pay  was  from $10.00 to $17.20 
per week. People who were being penalized often were made to 
forfeit their pay. 
 
 34. If LRH thought it was necessary to order into any 
subordinates area for any length of time, it was said that he 
was "wearing your hat*' or doing your job. Under these 
circumstances, it was then customary to send LRH a dollar or the 
equivalent currency to buy your "hat" back. Meanwhile, LRH was 
billing Scientology for his services and rather than taking the  

 attitude of an outside consultant providing cooperative 
assistance to these staff, he abused their morale for having to 
step in. On his orders, I ran numerous "PR" campaigns to 
intimidate staff in this regard. 
 
 35. In order to get extra food other than that served 
at meal times, crew had to buy it from the Canteen. 
 
 36. Fines were also levied as a penalty. Standard 
breakages of equipment, even a dish in the galley, were billed 
to staff or deducted from their allowances. 
 
 37. Every member of the crew was expected to write LRH 
a daily report and a file was maintained by the messengers for 
each crew member. This was a major information source for him. 
 
 30. The ship's capacity for berthing was maximum 290 
and in its final days there were approximately 400 people 
aboard. About 35 people did not have berthing spaces at all. 

39.  Travelling  in  the tropics with so many people 
crammed onto  a  ship to live and work created extremely bad 
hygiene conditions. The ratio of people to latrines  was  approximately 15 to 1. Showers available were more like 40 
people to 1 shower.  

 -160  

b 

 40. If a crew member wanted to send personal clothes  
 or uniforms to the laundry they were required to pay for the 
laundry service. 
 
 41. There were no laundry facilities aboard for 
personal use and so people used the sinks available in the 
common washrooms or cabins to launder their clothes. Crew were 
at times issued with a bucket to launder their clothes. 
 
 42. Crew were never issued more than two changes of 
uniforms. Almost all crew paid for additional uniform items 
personally including gear for standing ship watches such as 
coats, gloves, rain gear, extra clothes, boots and socks. 
 
 43. The mail out from everyone aboard was read and 
censored for any security violations. 
 
 44. Fares to visit  ones  family on leave were to be 
paid personally by the crew member and so the expense of 
returning home from places like Europe and the Caribbean often 
made the trip prohibitive. 
 
 During my 14 years in the Sea Organization, I was able 
to see my family for a total of nine weeks cumulative.  
 On each occasion, I was given security checks before  

 leaving and after my return. 
 
 45. There was no airconditioning and a constant 
dampnessprevailed, and so as a consequence, mildew was common. 
It was very difficult to avoid skin fungus such as athlete's 
foot. 
 
 46. Discipline was extremely harsh and degrading. It 
was meted out often by both LRH and MSH to officers, executives 
and crew. 
 
 47. In the inner world of the Sea Organization with 
its ships and land bases it was an atmosphere of militarism in 
the highest degree. It was a tiny navy mentally at war with the 
world. 
 
 48. Buzz words like "planetary control," "clearing the 
planet," "security" and "beach head," "five prong attack," 
%issions, " "need to know" and "out flanking the enemy)' were 
part of the every day vocabulary. 
 
 49. "Command Intention" meant an LRH order or plan. 
Anyone who questioned Voxcaaand intention" was dealt with very 
severely. Being ignorant of it was no excuse. 
 
50.  Even minor infractions were punished. Even  a 

 -18-  

 suspected bad intention on the part of a crew member had the 
severest penalties and conditions. The ethics system developed 
by LFW used a scale of conditions: 
 
 Power 
Affluence 
Normal 
Emergency 
Danger 
Non-Existence 
 
 The Lower Conditions: 
 
 Liability 
Doubt 
Enemy 
Treason 
 
 51.  All  conditions below normal were penalized by 
extra  work  hours and no breaks at all. Failing to perform the 
functions required of any post copped a condition of 
non-existence with possible suspended pay and 15 extra work 
hours. 

5 2 .  No report  or  failing to report all facts  copped  a 
condition of liability where one ceased to be considered as  a 

 -19-3: J  
 ',  
 I -_ v  

 member of the group, thus forfeiting all rights and pay. One 
wore a boiler suit and a dirty grey rag around the left arm, and 
copped a 24 hour amends project to be completed outside of the 
regular working hours. 15 minutes were taken for  meals,  and 
food was given only after the regular  crew were  fed. On 
completion of the requirements for liability one had to petition 
the rest of the crew for reacceptance back into the group and 
could rejoin only by majority acceptance. If you were lucky 
enough to get LRH's signature, it was considered the equivalent 
of the majority. 
 
 53.  A  false report or even an inaccurate report or  an  expression  of  the notion  of leaving  the Sea Organization  or  Scientology copped the condition of Doubt. Penalties for this 
condition were as above only one was required to wear a chain 
around one's wrist signifying the condition to the rest  of  the 
crew and a 48 hour amends project was assigned. The chain was 
later replaced by an orange arm band.  
 ~-"s-Disagreement with Vormnand Intention"  expressed by  failing to carry out orders or committing an act contrary to 
orders was considered an "enemy" act and carried the equivalent 
penalties. One could "free fall" down the conditions to the 
 
bottom. 

55.  The  most  severe condition assigned was Treason and 
 
-2o- 
 54.  

 at times individuals were required to wear a black mark on their 
left cheek. A breakage  of  security carried an automatic 
condition  of  Treason. 
 
 56. Everyone was somewhere on the condition scale at  
 .  
 all times. LRH was considered to be in Power and ethically 
beyond reproach at the top end. 

57.  Sometimes  a  whole organization or ships company 
would be assigned  a  lower condition and every individual would 
be forced to dramatize the lower ethics condition. In the  case  where public relations might be damaged by open display  of  these 
dramatizations their might be concessions made  as  to 
appearances. 
 
 58. From 1968 through 1981, various project forces 
were set up for people who were considered repeated goofers and 
these people would be segregated from the rest of the crew for 
months at  a  time to dramatize these so-called "lower conditions 
of existence"and assigned to the lowest tasks  aboard  ship as: 
galley cleaning, deck scrubbing, scraping barnacles out  of  the 
salt water tanks which had been emptied, trash duty, or any 
filthy  task.  These people were the first to be called for ships 
stores parties or for cleaning up after fuelling, and the like. 

59.  They had to address every other member of the crew  

 as "Sir. " 
 
 60. They operated like a chain gang and were often 
suffering  severe  exhaustion from sleep deprivation,  lack  of 
nutrition and exposure.  Heat  prostration was also common. 
 
 61. Although first aid and vitamins could be had on 
request there was no qualified doctor aboard and when serious 
illness developed people were offloaded. These people were 
often destitute after long receiving little or no pay for being 
ill. 
 
 62. There were also times when people went into 
emotional shock or had nervous collapses and these too were 
offloaded. 
 
 63. When such things occurred, the first consideration 
was not the person's welfare, but whether or not there might be 
public relations or legal repercussions. Such a perceived 
threat was called a "flap." The facts were withheld from the 
crew in general and a story put out in its place. Then action 
was taken to eliminate any possible threat  before  the welfare of 
the person was considered. 
 
 64. I witnessed such ethics conditions during the 
years Tonja Burden was aboard ship and on land and I personally  
 -22-  

 have experienced them as deplorable, consentration camp-like, 
degrading and sub-human in standards. 
 
 65. I saw such ethics conditions applied to children 
as young as 5 years old and I saw children working regular posts 
as young as 8 years old. 
 
 It was only in March 1969 that the age limit of 
children aboard was set at 12 years. 
 
 66. The Commodore's Messenger Organization was 
composed of teenagers. These teens were considered future 
resources as executives in Scientology. No consideration was 
given to educating these kids for preparation in the outside 
world, or to the idea that they might someday wish to become 
professional people in society. A show was made of educating, 
them in junior high level instruction. Some achieved typing 
skills, and the basic 3  R’s.  The only full time instruction 
these teens received was when LRH was in New York in 1973 and 
off the ship. No instruction in English Literature, Science, 
Mathematics, Languages or History as any kind of routine or 
accredited correspondence course was taught. Only one 
accredited school teacher was aboard and qualified to instruct 
them, Richard Cohen of New  York,  and he often had  a  "class"  of 
 over 100 students to cope with.  

 -230  

 67. From 1973 to 1981 when I was part  of  the LRI-I  
 Personal Office, I worked closely with the Messengers and  
 observed their daily routines, schedules, study habits, and 
performed functions. 

68.  MSH was feared by the messengers and while I was 
aboard, messengers, David Rosseau and Jill Goodman both had 
their faces severely slapped by  MSH  while running messages  for  LRH. 

69.  In 1969, LRH broke  a  finger punching a crew 
member, Belakacem Ferradj. In 1978, LRH punched Steve Irwin in 
the  face. 

70.  In 1973, and 1974, there existed orders to "beef 
 
up”  the CM0 with teens and it was part of this program that 
Tonja Burden  was  recruited. LRH also ordered the CM0 to do 
their own  promotion  brochures which were printed and sent out. 
 
 71. On  a  brief trip to Los Angeles in approximately 
February 1974, I  observed  Tonja Burden as a likely candidate to 
go aboard the ship and be a part of the CMO. 
 
 She  was  not at that time attracted to the idea and told 
me she needed to find out more about it.  

-240 

 I took her name and passed it on to Terry Gillham 
Gamboa back on the ship. 
 
 72. Less than a year later I observed Tonja to come 
aboard the ship. 
 
 When Tonja ascended to become an actual messenger for 
LRR I observed her performing her duties along with the others 
through 1975 and 1976. 
 
 73. In October 1975, I left the ship with LRH and 
others from Curacao, NV, and helped set up a temporary base in 
Daytona, Florida from which we could operate. 
 
 74. The final base was located in Clearwater, Florida 
and is today known as the "Flag Land Base." 
 
 75. LRH's code signature became *'the BOSS" and he 
orchestrated the entire movement  of  some 400 people from the 
ship to the land base including the purchase of buildings, local 
intelligence, local PR, front corporations, deception  of  the 
Xmmigration and Naturalizaion Service and transfer of funds as 
well as organizational operations. 
 
 76. As was the case aboard the ship "Shore Stories" 
and front corporations were created to hide the actual  

 Scientology activities. 
 
77.  "Shore Stories" were stories that were made up as 
explanations of what was going on. They were deceptive in 
nature.  A  thread  of  truth, sometimes ran through them which was 
twisted to give a different impression, but  more  often than not 
they were far fetched fabrications or out and out lies. 

70.  The front corporations of Southern Land 
Development Corp. and the United Churches  of  Florida were set  up  to be the owner and leasor respectively of the Scientology 
buildings in Clearwater. 

79.  These front corporations and stories about their 
activities were so flimsly that local people began to question 
them and so people speculating on who we might be were targeted 
as trouble sources or enemies for further convincing or 
handling. 

80. As  usual, LRH made up the shore stories, and I 
assisted him in distributing them to the  Flag  crew for their 
use. 
 
 81. During November and December 1979, LRE and I were 
already accumulating information on the  Mayor  of Clearwater, 
Gabe Cazares. He was targetted by LRH as an enemy. 
 
-26- 

 LRH gave orders to "beef up" the Guardian's Office" in 
Clearwater and when these people arrived he gave them two 
briefings in his office in Dunedin. 
 
 Tonja Burden was present at, at least one of these  
 meetings. I attended both along with my assistant, Liz 
Gablehouse. Mary Sue Hubbard attended one and sent her 
Cozununicator to the second to  take  notes. 
 
 The subjects discussed were various intelligence 
operations with fast actions required against Gabe Cazares, two 
local Clearwater Sun reporters, PR operations to make allies out  
of  local officials, stiff security for the Unit we were in, and 
the various shore stories to be used. 

82.  LRH was fully in charge of  all  local Clearwater 
operations until 1976 when the Scientology %oveP was blown. 
He then went into hiding in Washington, DC along with  Kima  and 
Michael Douglas, and Claire and David Rosseau, leaving 
instructions to continue to carry out operations against the 
Mayor  of  Clearwater and others, all with the intention of either 
eliminating  or  winning  over  his  perceived  enemies.  He  was 
briefed on local affairs thereafter. 
 
 I observed Tonja Burden on active duty as a messenger  
 .  
-270 

 during this 1975 and 1976 period.  

 L  
 83. Later, LRH's headquarters were transferred to the 
California desert, first in LaQuinta and then in Gilman Hot 
Springs. Security about LFM's whereabouts was very, very tight. 
 
 '84. In January 1980, after Tonja Burden had left 
Scientology and filed an affidavit in the LaVenda Van Schaick 
case and testified in New York before  a  Federal Grand Jury, she 
 was  perceived as an antagonistic enemy of Scientology. The . 
Commodore's Messenger Log Books which contained a running record  
of  every order and activity of  LFM’s every move  for the  past  10 
plus years were reviewed by the messengers to find out just what 
Tonja Burden knew about the organzation. 
 
 85. She  was  considered a very serious threat at that 
time because she had witnessed LRH's direct control of the Sea 
Organzatfon, the Guardian's Office and various intelligence 
operations and  she  could provide evidence which would link  him  to these activities. These and other threatening circumstances 
caused LRH to go into hiding in early March 1980. 
 
 86. When Tonja Burden filed her awn lawsuit,  MSH  continued to stay abreast of the circumstances regarding this 
 case.  She  spoke  about developments in it to me. This case 
impacted a legal project she and I were doing to redefine LRH's 
 
 -280  

 relationshp to the organization and insulate LFW from service of 
process or discovery. 
 
87.  The Messengers Logs were filled with equally 
damning evidence concerning the complete lack  of  corporate 
integrity of the organzation as well as evidences  of  LRH 
domination and control of the Guardian's Office activites. 
These along with other documents were buried below the floor 
boards of buildings 127 and 28 of the Ranchos on the Gilman Hot 
Springs property. Some documents  were  buried at different 
locations on the grounds. 
 
88.  In 1981 at the request of MSH and Anne Mulligan, 
MSH*s Legal Assistant, I wrote an LRH Executive Directive  for  Broad Public Issue on LRH's behalf designed to foil  a  discovery 
attempt contemplated by Michael Flynn. 
 
 LREl had long promoted that he personally received all 
mail sent to him  by  Scientologists or the public. This letter 
line  was  called the Standing Order #l line (SO#l). In truth, 
LRH did not really see this mail. It was just promoted that he 
did. By attempting to use this line as a vehicle  for  discovery 
on LRX and his whereabouts, he  was  about to catch LRH in  a very  big lie. 

89.  The repercussions  of discovery  on this line were 
 
 -290  

 considered to be disasterous.  
 90. From 1969 to 1981, I observed conditions under 
which children were kept in the Scientology nursery in Los 
Angeles. 
 
 91. I also saw and heard reports of such conditions 
while part of Scientology management. 
 
 92. The most frequent problem plaguing the nursery was 
keeping it staffed. It was basicly staffed by people who were 
considered undesireable or of lesser quality for administrative 
posts within the Scientology organization. Sometimes it was 
staffed by expectant mothers in their final months of pregnancy.  
 93. Babies were bussed in a van to the nursery each 
morning and collected or delivered to parents again at the end  
of  the day.  
 94. **Family time" was allocated as 1 hour per day and 
only granted when parents were not considered in lower ethics 
conditions. 
 
95.  I observed babies to be dirty and unkempt and the 
conditions under which they were kept were squalid. Nutrition 
was poor, and parents were often irrate  over  issues  of  basic 
 
-300 

 care and cleanliness of quarters. 
 
96.  There were a few infant deaths, and occasional 
accidents. Once a child was actually left behind at a beach 
inadvertently and then later  recovered. 

 Infants were fed a formula prescribed for them by LRH 
made  up of  barley water, milk and karo syrup. It seemd to me 
that this formula contained an inordinate amount  of  sugar  for  a 
young child. 
 
 Young infants virtually lived on this formula as *@the 
next best thing to mother's milk." 
 
 There was almost no children's furniture for babies or 
small children. Those cribs provided were old, rickety and 
dirty. 
 
 Nursery laundry was particularly dingy. 
 
 Children were not adequately bathed or cleaned up and 
runny noses were not kept in check adequately. 
 
 An odor  of  urine and sour milk prevailed. 
 
 91. Occasionally, when Health Inspectors visited the  

t 

 nursery, there would be a hurried effort to clean and paint the 
place and allocate the legal number of staff. 
 
 98.  As  a solution in 1977, LRH issued several orders 
on the care and housing of children for compliance by his LRH 
Communicator U.S., Toby Young. 
 
 99. I saw these orders and discussed them with Toby. 
 
 Although facilities for children were the 
responsibility of the Sea Org, LRH placed the blame for the  poor 
 condition of the nursery and children squarely on the parents. 
 
 100. Parents meetings were held in which they were 
briefed on the LRH orders. They were told that a building would 
be procured about an hour distance from Los Angeles and babies 
and children would be kept there. It would be  run  as an 
organization like a military academy and parents would not be 
allowed to visit their childen except one day per week. The 
children would otherwise be cared for 24 hours per day at the 
nursery school academy. 
 
 101. Enormous upset resulted and some parents 
announced they would leave the Sea Org rather than be separated 
from.their children in this way. The plan was never executed. 
 
 -320  
4 , l ’ -, 
; 
- -:, J a-4 

 102. From 1971 until the time I left in 3981, I 
observed the culling of private information from the auditing 
files and confessional files of staff. 
 
 If a person expressed a desire to leave all of their 
folders were culled from beginning to end. This  sometimes 
 accounted for extensive delays in a person's being permitted to 
leave because the policy was to get the person to sign a 
statement confessing to their so-called  ttcrimes.tt 

 103. The person would be determined from ever 
expressing hostility toward the organization because it was 
obvious that the organization would use the person's Vrimes** 
against them. 
 
 104. These ltcrimestt were not only actions punishable 
by law in the legal sense but they were also transgressions  or 
 immoral acts or thoughts that the person may have expressed 
which could prove embarrassing  if  made public 
 
 105. It was also standard procedure for a person to 
coerced into signing non-disclosure bonds and agreements so that 
the person would never divulge what really went on in the 
organization. 
 
 106. If a person expressed a desire to leave they  
 I 
 
 -33-  

 would be assigned to lower ethics condition, segregated from  
 .  
 other personnel and/or their spouse, held under guard and  
 ___A--. -- .-. 
v--- --.-.__ .--- _ _ _ __ .-_ 
security checked and given degrading work to do until they  
 . - .- - _ 
e.--- _______e______pc------. .-_realized they wanted to stay. If they persisted in expressing  
 _-. ..-. -.--- ___________-...- _ ..c__---- -..--- -. . -.----. ___ __-. 
their wish to leave, their folders would be culled as above and  
 . - .- ___, __ .- --- _.__ .- ----.--. -.,___, ______ .-. 
a bxi calculated  at  current prices for the full value  of 
 ._..- I.-. _-..- ___--- -.-. -- - _... ...--- -.-_ 
services received while they were staff. I saw bills amounting  
 _c-. 
to-as much  as $100,000. 
, _ ._--,-__ .--. 

 107. If the person still persisted in leaving, he or 
she would be declared suppressive and any friends they had in 
the organization would be required to disconnect from them. 
 
 108. Often times the person would  leave  destitute. 
 
 For this reason, people desiring to leave often escaped  
 I __- -__ -.- / 
-- --to  a  place where they felt safe and then tried to  leave 
 --offizally on friendly terms by sending announcements of their 
intentions through the  mail. 
 In 1978, I was assigned to the RPF. I requested to 
 
leave.  I was locked up and put in the RPF and unable to sleep 
with my husband for virtually 10 months and could only speak 
with him privately for 15 minutes per day. 
 
 The next time I decided to leave, in 1981, I escaped 
 
 -34-  

 but then returned to receive security checks and to sign the 
release documents.  

 Signed under the pains and penalties of perjury 
thisday of March, 1986 .  
 /9  
dik 
 LAUREL SULLIVAN 
 
 COMMONWEALTH OF MASSACHUSETTS 
Suffolk, ss. March 19, 1986  
 Then personally appeared before me the above named 
LAUREL SULLIVAN and acknowledged the foregoing instrument to be 
her free act and deed.  
 Before me,  
 Notary Public 
 
 My Commission Expires 3/31/89  

 -35-  

I 
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 DECLARATION OF LAUREL SULLIVAN 
 
 I, LAUREL SULLIVAN, declare and state: 
 
 1 . I was associated with CHURCH OF SCIENTOLOGY 
organizations from September 1966 until  November  1981. From 
November 1967 onward I worked personally for I,. RON HUBBARD.  
 2 . After L. ROK HUBBAPD allegedly resigned from 
conducting the management of any Scientology organization, 
I held the position of LP& Communicator beginning in the Fall 
of 1968. This position was one of an international network of 
LRH Communicators and as such I was L. RON HUBBARD's representatil 
to the CHURCH OF SCIENTOLOGY organizations wherever I was stationc 
From this position, I assisted L. RON HUBBARD to control the 
CHURCH OF SCIENTOLOGY organizations, including the CHURCH OF 
SCIENTOLOGY OF CALIFORNIA.  
 3 . The job of LRH Communicator was to make sure that 
L. ROK HUBBARD's orders and policies were complied with by 
everyone in Scientology from the top down. I logged, recorded,  

 .  
 transmitted and checked on L. RON HUBBARD's orders until they 
were completed. I received mail for him personally and I 
answered that mail for him personally. Later while I was his 
personal PRO (Public Relations Officer) on his staff, I had 
access to his personal notes covering the entire range of his 
direction and control  of  the CHURCHES OF SCIENTOLOGY. L.  RON 
 HUBBARD's control  of  the network of CHURCH OF SCIENTOLOGY 
organizations continued during the time I was affiliated with the  
 3 . ..- . 
i I- J J  

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 CHURCH  OF  SCIENTOLOGY organizations.  
 4. As part of my duties as LRH Communicator and later 
as his Personal PRC, I often cancelled other orders contrary to 
the orders of L. RON HUBBARD. Any order given that was inconsistent or contrary to L. RON HUBBARD's orders was ignored or cancellen  
 5. L. RON HUBBARD personally planned the creation of 
the World Institute of Scientology Enterprises as a branch of 
the CHURCH OF SCIENTOLOGY OF CALIFORNIA in the late 1970's.  
 I saw original notes to this effect and I investigated a report 
of his receiving 12 l/2% of the gross income of businesses 
affiliated with it. The World Institute of Scientology Enterprises  
 _  
 in substance was created to profit  from  Scientologists who were y  
 :  
 .  
 businesss owners. The materials given to members of the World ' 
Institute of Scientology Enterprises was for the most part 
available to them through branches of the CHURCH OF SCIENTOLOGY 
without the World Institute of Scientology Enterprises. Others 
were created as derivative works from Scientology materials.  
 6. The World Institute of Scientology Enterprises 
was never actually operated as a separate and distinct corporation 
for as long as I was associated with L. RON HUBBARD and the  
 .  
 CHURCHES OF SCIENTOLOGY, although it was presented as such.  
 7. The World Institute of Scientology Enterprises 
operated on CHURCH OF SCIENTOLOGY policies. It has no independent 
existence from the CHURCH OF SCIENTOLOGY OF CALIFORNIA in 1978 
and 1979. It followed Scientology policies o:ritten by L.  RON 
 HUBBARD which were also used by all Church of Scientology 
organizations. 
//I/  

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8.  The World Institute of Scientoloqy Enterprises office: 
in 1978 and 1979 were in the same offices as the CHURCH OF 
SCIENTOLOGY OF CALIFORNIA in Clearwater, Florida which was the 
main address. The World Institute of Scientoloqy Enterprises 
had no real separate physical existence from the CHURCH OF 
SCIENTOLOGY OF CALIFORNIA at that time and its management contact 
people were in the CHURCH OF SCIENTOLOGY OF CALIFORNIA on up to 
the Commodore's Messenger Organization personnel within the 
personal office of L. RON HUBBARD. Those people were Annie 
Taskett and Susan Mithoff..  
 9. The members of the World Institute of Scientoloqy 
Enterprises were Scientoloqists adhering to the policies of 
L. RON HUBBARD and the CHURCH OF SCIENTOLOGY in 1978 and 1979. 
10. The staff of the World Institute of Scientoloqy 
Enterprises was comprised of Scientoloqists adhering to the 
policies of L. RON HUBBARD and the CHURCH OF SCIENTOLOGY in 
1978 and 1979.  
 11. Fees were required to be paid from the members of 
the World Institute of Scientoloqy Enterprises to L. RON HUBBARD 
in 1978 and 1979. The fees were paid to L. RON HUBBARD on a 
percentage of the gross income of the businesses of the members. 
L. RON HUBBARD's personal accountant collected the fees personallfor him. L. RON HUBBARD's fees were known as royalties Or a 
consulting fee. In fact, L. RON HUBBARD did no work in exchange 
for the fees. In later years collections were done via the 
W.I.S.E. corporation.' 
12. The CHURCH OF SCIENTOLOGY OF CALIFORNIA Staff sold  

 Scientologists who were business owners on joining the World 
Institute of Scientology Enterprises in 1978 and 1979 and if they 
were unwilling to join, it was treated as an "ezhics" offense.  
 13. Individuals of the World Institute of Scientology 
Enterp~rises followed the Ethics system of the CHURCH OF SCIENTOLOG' 
OF CALIFORNIA in 1978 and 1979.  
 14. The effect of a "non enturbulation order" and/or 
a "condition of confusion" issued on LARRY WOLLERSHEIM meant that 
he could not be dealt with or communicated to by Scientologists 
except as prescribed by the CHURCH OF SCIENTOLCGY order. 
Infractions of the order would be dealt with according to 
Scientology policies also. Otherwise the Scientologists would 
be in violation of the Scientology policies and "Ethics".  
 15. Roger C. Barnes was known by me to be a member of 
the elite Sea Organization ("SEA ORG") of the CHURCH OF SCIENTOLOG 
OF CALIFORNIA in 1978 and 1979.  
 16. A copy of my trial testimony in the case of 
the Church of Scientology of California v. Gerald Armstrong, 
Case No. C 420 153 is appended to these papers.  
 I declare under penalty  of  perjury under the laws  
 .  
 of the State of California that the foregoing is true and 
correct.  
 Executed this 1st day of November 1964 at Los Angeles, 
California.  
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