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This suit seeks damages for acts perpetrated against plaintiff, an attorney, by defendant and various of his individual and organizational agents and employees pursuant to a written conspiracy to "destroy" the plaintiff. It arises out of plaintiff's representation of clients aggrieved by defendant and the Church of Scientology.
1. Plaintiff is Michael J. Flynn, an attorney admitted to practice in Massachusetts with offices at 12 Union Warf, Boston, Massachusetts, and with a domicile in Boxford, Massachusetts.
2. Defendant is Lafayette Ronald Hubbard a/k/a L. Ron Hubbard (hereafter "defendant" or "Hubbard" with last known residence and domicile in Hemet, California. Defendant has stated that he desires his present whereabouts to be unknown. They are unknown to plaintiff, but he can be notified through
3. Jurisdiction of this court exists pursuant to
The claims as hereinafter set forth have arisen in Massachusetts.
4. At all times material hereto, Hubbard has done business on a daily basis in Massachusetts, Nevada, California and Florida through the "Guardian's Office", as described infra and also directly through various entities known as the Church of Scientology of California, Inc. ("CSC"), the Church of Scientology of Boston, Inc. ("CSB"), Flag Services Organization, Inc. ("FSO"), Religious Technology Center ("RTC"), Church of Scientology International ("CSI"), Author Services, Inc. ("ASI"), as well as various other organizations (collectively "Scientology organizations") and individuals. He has done such business as follows:
A. Principal, Agency Relationship of Hubbard with various organizations and individuals
5. Defendant is the founder, controller, principal and absolute authority over the Scientology organizations and individuals. The Scientology organizations, as well as various individuals, acting as agents of defendant within the scope of the authority granted to them by and upon his express orders, engaged in the conspiracy to perpetrate the torts alleged herein.
6. Hubbard ordered that the directors and officers of each of the Scientology organizations enumerated above sign written resignations in advance of their appointment as Directors and Officers and this was done. Hubbard held these "resignations" and over a period of years whenever any of said Directors or Officers contested his orders or authority, he removed them from their capacity in said corporations, and appointed new individuals who complied with his orders and policies.
7. Hubbard was a required signatory on every bank account over $5,000 of each said Scientology organization.
8. Hubbard established, supervised and controlled an organization called the "Guardian's Office" ("G.O.") which he placed in each of the Scientology corporations for purposes of enforcing his express daily orders. He routinely called these orders the "daily battle plan."
At all times material hereto, the G.O. employed individuals under Hubbard's direction to operate in California, Las Vegas, Nevada, Boston, Massachusetts, Clearwater, Florida, and diverse other places. Plaintiff has possession of the written policy of Hubbard establishing and directing the G.O., together with the "training materials" of the G.O., written by Hubbard, all of which were used to commit the torts alleged herein.
9. At all times material hereto, Hubbard has controlled said Scientology organizations and issued express daily orders to them through several individuals. These agents include his wife, Mary Sue Hubbard, Jane Kember (the head of the G.O.), Arthur Maren (an employee of the G.O.), David Miscavige (the current liaison of express orders between Hubbard and the G.O. and all Scientology organizations), Norman Starkey (an employee of the G.O.), Joseph Lisa (an employee of the G.O.), Jim Mulligan (an employee of the G.O.) and Lyman Spurlock (in charge of ASI and all financial affairs of Hubbard and the Scientology organizations). Plaintiff is in possession of a 286 page "Stipulation of Evidence" filed in United States v. Mary Sue Hubbard Crim. #78-401 (D.C.D.C. 1978), and executed by Mary Sue Hubbard and eight (8) of the highest officials of the G.O., all as agents of Hubbard, in which said individuals stipulate that Hubbard is the "overall supervisor" of the G.O. Said "Stipulation of Evidence" is a detailed stipulation of the "operation of the G.O. to "destroy" some of the "enemies" of Hubbard, one of which was the plaintiff.
10. At all times material hereto Hubbard used the Scientology organizations and the above-named individuals and others to implement and enforce both his policies and his daily orders.
11. Some of these policies were written and copyrighted by Hubbard and his agents and used by his agents of overall policy directives to carry out his orders. Some of the written policies that were specifically implemented against the plaintiff as hereinafter described are set forth below:
Details of these activities are set forth below.
14. In July, 1979, plaintiff in his capacity as an attorney, undertook the representation of one LaVenda Van Schaick for the purpose of obtaining a refund of monies paid by her to CSC in the amount of approximately $12,000. Plaintiff sent a letter to CSC for the purpose of obtaining said funds in order to avoid the necessity of instituting a lawsuit. CSC refused to pay a refund.
15. Within several days after sending the aforementioned letter, Hubbard, who was then residing in Hemet, California, ordered an immediate infiltration of plaintiff's law office by a G.O. agent named Chuck Malone who sought employment from plaintiff posing as a Private Investigator. Malone's purpose was to steal records and information from plaintiff's offices.
16. During the period between July to September, 1979, when the correspondence concerning the Van Schaick refund was being exchanged, the plaintiff began to receive phone calls from clients, relatives and friends stating that they had received strange telephone calls from various individuals discrediting plaintiff and requesting information about plaintiff. One of the plaintiff's clients, Phyliss T. Sequeira, told plaintiff that she had received a call requesting her to report plaintiff to the bar because he had not turned over all of the funds he had received in the trial of a case. In fact, the client was present at the trial, received a trial judgment upon a jury verdict and was paid in full. Plaintiff is informed that the foregoing activities were conducted by Joseph Lisa, Gary Lawrence, James Mulligan, Kevin Tighe, Kathy Brown, Warren Friske and others all acting as agents of the G.O. under the authority and direction of Hubbard.
After receiving a letter denying the request for a refund, plaintiff received a letter dated September 11, 1979 from CSB. The September 11th letter stated that the Church would be willing to pay approximately 50% of the funds pain by Van Schaick and at the same time suggested that Van Schaick should not sue the Church for the balance of the funds because she had an extensive drug history, had "three abortions", had "attempted suicide", had severe mental problems, and had signed an agreement never to sue the Church of Scientology or the Hubbards.
17. Shortly after the receipt of the foregoing letter, plaintiff received several anonymous telephone calls suggesting that the representation of Van Schaick was a "dangerous matter," that no one "messes with the Church," that if the undersigned had any doubts about this issue, to contact other people who had sought to "interfere" with Scientology. These calls were made by individuals acting on orders from Hubbard.
18. During this time plaintiff observed individuals following him, defamatory calls were made to various clients of plaintiff shortly after he had called said clients on the phone, and personnel at the small airport where plaintiff maintained his airplane observed unidentified individuals viewing the plane and seeking information about it. The individuals performing these acts were acting on orders from Hubbard.
19. On or about October 19, 1979, plaintiff was flying said airplane to South Bend, Indiana, when the engine began to malfunction at approximately 8,000 feet in altitude, lost power entirely for a period of time, and plaintiff was forced to land at an airport in proximity to where the malfunction occurred. The plaintiff subsequently discovered that large amounts of water were present in his fuel tank, although prior to take-off the undersigned had engaged in a pre-flight examination of said fuel tanks, and no water was present. The presence of the water caused the malfunction of the engine and the cessation of power. Plaintiff believes that water balloons were placed in the tanks of the airplane by Joseph Lisa and James Mulligan, agents of the G.O., on orders from Hubbard.
20. For the period October, 1979 and the ensuing several months, plaintiff's client, Van Schaick, has claimed numerous incidents of personal harassment, including the surveillance of her home and her child, being run off the road in her car, numerous telephone calls to her neighbors, suggesting that she was an unfit mother, calls to her employer resulting in a loss of her job as a waitress and attempts to separate her from her husband. In November, 1979, Hubbard sent Gary Klinger, a G.O. agent from Los Angeles, to convince Van Schaick that the "harassive things" being done to her were done by plaintiff.
21. In November, 1979, nine (9) of the highest officials in the G.O. were convicted of a variety of crimes, and approximately 30,000 documents seized by the F.B.I. from CSC were released to the general public. These documents, in part, demonstrate that Hubbard, the G.O. the Scientology organizations and the above-named individuals were responsible for the inexplicable and harassive incidents that had occurred in the prior several months.
22. On December 14, 1979, after approximately six (6) months of research and investigation at a cost in the excess of $20,000 to the plaintiff, plaintiff brought a lawsuit against CSC on behalf of La Venda Van Schaick.
23. On or about December 27, 1979, two weeks after the commencement of the Van Schaick action, Hubbard, through the G.O., sent an individual named Bill Broderick to pose as a prospective client in order to gain information about plaintiff's office and his files on Scientology.
At the same time, defendant intensified his harassment of individuals associated with plaintiff and attempted to disrupt non-Scientology cases the plaintiff was involved in and generally initiated a campaign of unrelenting personal and legal harassment, as is described in the remaining paragraphs herein.
24. On January 3, 1980, approximately three weeks after the commencement of the Van Schaick case, without filing a counterclaim in said action, and without filing a Motion to Dismiss within the time allowed by the rules, the G.O. under the direct orders of Hubbard, through attorney Steven Burris, filed Church of Scientology of Nevada, Inc. v. Thomas Hoffman and others, Civil # KV-80-10-HEL (Nevada Fed. District Court, January 3, 1980). Plaintiffs were the said Van Schaick, Kevin Flynn, brother and employee of plaintiff, Thomas G. Hoffman, Esquire, a colleague of plaintiff working with plaintiff in the same suite of offices and Edward Walters, a client of plaintiff. That suit alleged a conspiracy by said individuals to deprive Scientology of its First Amendment rights. The suit was dismissed by the Federal Court within 120 days.
25. At the same time as the filing of said action, Hubbard, through the G.O., filed in succession, four (4) separate Bar complaints against plaintiff alleging, inter alia, conspiracy to violate Scientology's First Amendment rights and the unlicensed practice of law by Kevin Flynn. The first three complaints were filed on January 15, 1980, February 7, 1980 and April 3, 1980, all of which were dismissed on April 10, 1980 by the Massachusetts Board of Bar Overseers. On November 19, 1980, the G.O. filed yet another complaint which was dismissed on May 4, 1980. The purpose of filing said Bar Complaints was to harass plaintiff, and remove him from his "position of power" as a lawyer. They were filed without probable cause.
26. On or about May, 1980, after the dismissal of Hoffman supra in Nevada Federal District Court, Hubbard through the G.O., and attorney Burris, acting as an agent of the G.O., then commenced an action against the said Van Schaick, Kevin Flynn, Edward Walters, and other clients of the plaintiff in the state court in Nevada, which was nearly identical to the federal action. As to Van Schaick and Kevin Flynn, this suit was also dismissed. Said suit was brought on the basis of a false affidavit procured by the G.O. on behalf of Hubbard.
27. Defendant through his agents in March 1980, filed Church of Scientology of Boston, Inc. v. Michael Flynn et. al., Civil #40906 in the Massachusetts Suffolk Superior Court. The defendants were the plaintiff herein and four of his clients. The complaint alleged that the clients had stolen materials from CSB and turned them over to plaintiff. Said suit has been used to mislead various courts into the belief that plaintiff stipulated to the placement of the filed in court.
28. In September, 1980, Hubbard, through the G.O., filed a suit against the plaintiff. Church of Scientology of Nevada, Inc v. Michael Flynn Civil #202573 (Nevada Circuit Court), alleging essentially that the plaintiff was engaged in a conspiracy against Scientology and abusing the judicial process. Scientology counsel attempted to procure a false affidavit from a G.O. agent support the case (sic). The Nevada state court granted plaintiff's Motion for Summary Judgment in that action. The suit was brought for purposes of harassment. It was the fourth (4th) suit brought against plaintiff or his office and the third (3rd) suite dismissed as of November 1980.
29. Between January and May, 1980, plaintiff was subjected to hundreds of instances of personal harassment, which plaintiff is informed, based upon affidavits of Warren Friske, Carol Garrity, Gerald Armstrong, and other informants, to have been conducted by the G.O. under the direct authority and control of Hubbard. These included, inter alia, contacting the plaintiff's insurance agent, Philip Chesley, and informing the agent that the plaintiff had murdered the husband of one of his clients; making a bomb threat to the plaintiff's building, resulting in its evacuation; throwing rocks at his building; sending a post card threatening to poison the plaintiff; harassive phone calls at all hours of the day and night at plaintiff's home; making obscene telephone calls to neighbors and suggesting in said calls that plaintiff was making them; having process servers arriving at plaintiff's home at all hours terrifying plaintiff's wife and children, and placing dirt in the fuel tank of plaintiff's car.
30. Between approximately August, 1979 and up to and including at least September, 1981, the G.O., pursuant to policies and orders of Hubbard, and acting as his agent, stole documents directly from the plaintiff's private office condominium compound. Some of the G.O. agents involved in the theft and use of said stolen materials were Kevin Tighe, Chuck Malone, Gary Lawrence, James Mulligan, Joseph Lisa, Sylvana Garritano, Warren Fiske, David Aden, Robert Johnson and others.
31. These documents number at least 20,000 and include but are not limited to the following:
32. Hubbard and the G.O., as his agents, used the stolen documents and information to separate plaintiff from his clients, disrupt plaintiff's law practice, destroy plaintiff's reputation and business, interfere with plaintiff's causes and generally perpetrate all the tortious schemes set forth herein. A few examples are as follows: