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Evidence in Exhibits; this outline of evidence documented and indexed
separately with executive summaries for Calif., Canada and DOJ:

SUSPECTS
Not complete list. Other names on full list (Exhibits at XXXXX). Alleged
participation necessary to perpetration of suspected crimes and/or
cover-up of same:

Norton S. Karno, attorney
Sherman D. Lenske, attorney
Stephen Lenske, attorney
Lawrence E. Heller, attorney
Norman F. Starkey
Gerald "Gerry" Armstrong
Lyman D. Spurlock
Meade Emory, attorney, former IRS employee
Leon Misterek, attorney
David "DM" Miscavige
Laurel Sullivan
David Mayo
Michael Flynn, attorney
Patrick "Pat" Broeker
Anne "Annie" Broeker
Richard L. Brunelle, U.S. Treasury Department employee
Howard Doulder, U.S. Treasury Department employee
Dr. Eugene "Gene" Denk, physician
Barbara DeCelle

Full suspects list names other persons who claimed to be with Hubbard at
periods when he is believed to have been already deceased or kidnapped,
possible accomplises, additional TreasDept employees/former employees.

MOTIVE
Several hundreds of millions of dollars in properties and judgements
(Exhibits at XXXXX). Attorney suspects allegedly profited from padded
fees and/or judgements and kickbacks between them whichever "side" won
in allegedly fraudulent collusive suits (Exhibits at XXXXX). Some
suspects still profiting in self-created and self-serving positions
(Exhibits at XXXXX). Suspected additional embezzlements pending results
of XXXXXXXXXXXXXX invest. Armstrong believed to have received over
$2,000,000 for participation, Flynn more (Exhibits at XXXXX). Starkey
allowed to resign from Sea Organization and allegedly took payoffs in
supplement to approx. $50,000 a year (Exhibits at XXXXX). Spurlock
allegedly passed out large sums of unrecorded cash (Exhibits at XXXXX).
Emory unexplained windfalls (Exhibits at XXXXX). Suspected payoffs and
bribes and/or blackmailed participation/silence of others on list
(Exhibits at XXXXX). Control of and access to many millions of dollars
motive for suspect principals. See also RICO section (Exhibits at
XXXXX). Other possible motives may be in TreasDept personnel - outside
scope of this report. May develop in XXX invest.

OPPORTUNITY AND MEANS
Suspects Lenskes and Karno in custody and control of business and
financial affairs of Hubbards and of organizations at relevant times.
(Exhibits at XXXXX). Access to Hubbard's personal and business files,
literary properties, accounts and records personally and accounts and
records of organizations (Exhibits at XXXXX). Karno's firm had inside
financial and tax records of Hubbards, HASI, Inc. (owned copyrights and
trademarks), Church of Scientology of California (CSC) and Guardians
Office (Exhibits at XXXXX). Attorneys had all opportunity and means to
conduct every alleged crime and to support accomplises (Exhibits at
XXXXX). Attorneys had opportunity and means to secure self-protection
under privelege, also created self-protecting "release" forms including
Armstrong waivers (Exhibits at XXXXX) and had opportunity and means for
collusive initiative of allegedly fraudulent suits in collusion with
Flynn etc. setting precedent and blocking future civil discovery
pertinent to alleged crimes (Exhibits at XXXXX). Armstrong had custody
and control and insider knowledge important to alleged crimes. Armstrong
participated in numerous allegedly fraudulent suits with Flynn (Exhibits
at XXXXX). Opportunity and means of other suspects in context and
exhibits.

ALLEGED CRIMES

I. L. RON HUBBARD ALLEGEDLY KIDNAPPED AND/OR MURDERED ON OR BEFORE 1
MARCH 1980 BY PARTY OR PARTIES UNKNOWN. SUSPECTS ALLEGED TO HAVE
PARTICIPATED IN SAME AND/OR CONSPIRED IN COVER-UP OF SAME.

Outline of evidence of unreported missing person:

* Small number of suspects allege to have been in personal company of
Hubbard at relevant times. Reports of Hubbard being in company of
persons doing films was alleged fraud created during 1977-1979 by Karno
and other suspects. (Exhibits at XXXXX. See also "Friends of Karno" at
XXXXX.) Only a few persons had actual access to "Hubbard" (Exhibits at
XXXXX). No film footage of Hubbard. (See also Denk at XXXXX.)
Constitutes evidence that Hubbard was unreported missing person.

* HASI, Inc. owned Hubbard copyrights and trademarks. Revoked by Arizona
Corporations Commission 10 May 1977 for failure to file annual report.
Hubbard was HASI Trustee (Exhibits at XXXXXX) but did not respond to
avert revocation or to get corporation reinstated and did nothing to
secure succession of ownership of intellectual property. HASI, Inc.,
stated by Hubbard to be crucial to continuation of his organizations.
Membership in HASI required to keep organizations "auditors"
certificates in force (Exhibits at XXXXXX). After HASI revoke (which was
kept secret from public) suspects allegedly fraudulently sold HASI
memberships for over 7 years until creation of IAS 7 Oct 1984 (Exhibits
at XXXXX). Lenskes and/or Karno were in custody and control of Hubbards'
and organization's business affairs at relevant times. (Exhibits at
XXXXXX.) Constitutes further evidence that Hubbard was unreported
missing person not in custody and control of his interests and Trustee
obligations.

* Hubbard never made public recorded lecture after 7 Apr 1972. Made over
3,000 prior to that. Two scripted recorded lectures after that both
highly suspect. "Today and Tomorrow - the Proof" allegedly fraudulent.
(Exhibits and audio analysis charts at XXXXXX.) Miscavige party to
distribution of tape based on typed and unsigned orders placed on his
desk that he "knew" were from "Hubbard" because he "just knew."
(Exhibits at XXXXX.) Constitutes further evidence that Hubbard was
unreported missing person which was being covered up.

* 1974 non-Hubbard Board Policy Letters (BPLs) and Board Technical
Bulletins (BTBs) started supplanting Hubbard issuances. Recorded
approval only by anonymous and allegedly fraudulent "Boards of Directors
of the Churches of Scientology" which no record can be found of, not
legal body (Exhibits at XXXXX). Constitutes further evidence that
Hubbard was unreported missing person which was being covered up.

* Mid-late '70s non-Hubbard books and publications begin being published
e.g. "Volunteer Minister's Handbook," "Hymn of Asia," "Mission into
Time," "Dianetics Today," "What is Scientology?" Also "assisted by"
batches of allegedly fraudulent policies edited from Hubbard's "OODs"
items, dispatches and other items under custody and control of suspects.
Issued as Hubbard policies "assisted by" persons on projects under
custody and control of suspects to compile old writings into something
to appear as "new" from Hubbard. (Exhibits at XXXXXX.) Constitutes
further evidence that Hubbard was unreported missing person which was
being covered up and a premeditated effort to create illusion of Hubbard
being alive.

* Prior to "official seclusion" in Feb 1980: "Hubbard" described as
eccentric recluse travelling in van with blackened windows, disguises,
obsessed with cleanliness of surroundings and domicile, also described
as "Howard Hughes"-like person with long hair, dirty nails. Rumored
repeatedly to be in one form or another of hiding and/or in seclusion
convalescing from various alleged physical ailments (cancer operation,
strokes, etc.) and/or on the run from alleged crim or civil actions.
(Exhibits at XXXXX.) No such legal threats found in court papers.
(Exhibits at XXXXX.) Stories are allegedly lies and cover-ups: Person
travelling in blacked out van and wearing disguises alleged to be hired
person impersonating Hubbard. "Howard Hughes" stories proven in evidence
as false. (Exhibits at XXXXX: Kaye, Barbara; Sanderson-Douglas, Kima;
Rosenblum, Anne.) Alleged obsession with environmental cleanliness
determined by expert consultant to most likely be suspects' excuse for
wiping out evidentiary traces where "Hubbard" was alleged to have been.
(Exhibits at XXXXX.) See also e.g. David Mayo's description of Patrick
Broeker program to eradicate fingerprints and biological evidence after
"official seclusion" of "Hubbard" in late Feb 1980, while Broeker was
elsewhere reported to be with "Hubbard" at that particular time in said
"seclusion" (Exhibits at XXXXX.). Constitutes further evidence that
Hubbard was unreported missing person which was being covered up.

* Approx. Sep 1978 through early '80s David Mayo allegedly conspired
with Karno and Lenskes to write and issue and allow copyrights in
Hubbard's name for fraudulent bulletins purportedly by "Hubbard". Mayo
wrote and issued e.g. NOTs series (not in order or at actual time
written) with Hubbard's name on them. Mayo later allegedly circulated
fraudulent stories about personal interaction with "Hubbard" to
contribute to fraud that Hubbard had been alive and well, e.g. Xmas tale
(Exhibits at XXXXX.). Mayo alleged collusion with Starkey and list of
fraudulent issues tabbed and indexed. (Exhibits at XXXXX.) Constitutes
further evidence that Hubbard was unreported missing person which was
being covered up.

* Approx. mid-1979 Lyman Sprulock became "Investments Officer
International" resulting in allegedly witnessed association with Karno
and Lenskes and is alleged to have been a conduit for laundering funds
for the attorneys for numerous of the cover-up activities. (Exhibits at
XXXXX.) Witness testimony of his handing out large sum of cash without
records. (Exhibit at XXXXX.)

* 15 Dec 1979 Karno and Lenske allegedly conspired to create fraudulent
will for Hubbard naming Karno as Executor putting Karno's interests
senior to Hubbard interests, yet "Hubbard" purportedly signed this
instrument. (Exhibits at XXXXX.) Constitutes further evidence of forgery
to effect a cover-up of Hubbard's death or kidnapping and that Hubbard
was not a party and not able to represent his own interests.

* On or about 1 Jan 1980 suspect Armstrong allegedly conspired with
Karno and Lenske to plant boxes of "Hubbard documents" provided by Karno
at Gilman Hot Springs location purportedly the domicile of "Hubbard" and
to contrive false threat of raid to serve dual purpose of eliminating
all evidence of "Hubbard" while resulting in "discovery" of planted
boxes. Armstrong stories about box "discovery" contradictory and not
credible. (Exhibits at XXXXX.) E.g. Armstrong alleges that "Hubbard"
approved Armstrong's 8 Jan 1980 "petition"/"dispatch" (his story changes
from "petition" to "dispatch" in different versions, Exhibits at XXXXX)
to have Armstrong be in custody and control of a "biography project" on
Hubbard on strength of contents of "found boxes" without Hubbard seeing
boxes or contents or being apprised of contents. "Hubbard" purportedly
was at Gilman/Hemet (stories by different suspects contradict on
location, but in proximity, Exhibits at XXXXX) where Armstrong was at
relevant times. Hubbard did not go into "seclusion" from said location
until two months later in late Feb 80. "Hubbard" would have had ample
time to inspect contents of purportedly found boxes (timetable Exhibits
at XXXXX). Armstrong alleges in claims that "Hubbard" approved Armstrong
going onto alleged "biography project":
"He answered that with a couple of paragraphs. I did not have any
idea of the extent of the materials I had stumbled onto. Neither,
it turned out, did he". (Exhibit at XXXXX.)
Armstrong gives no explanation of why "Hubbard" would authorize a
biography of his life based on single dispatch/petition from Armstrong
advising "Hubbard" of the discovery of boxes allegedly found in same
domicile where "Hubbard" had purportedly been living with contents
uninventoried and undescribed.
Further, for two months afterwards Armstrong and "Hubbard" were
purportedly in same geographical location yet Hubbard did not in that
time inspect contents of alleged biography material according to
Armstrong's version of alleged events. Armstrong also admitted in re
"Hubbard's" purported approval of Armstrong's alleged petition/dispatch:
"Now I know what you're saying, 'How do you know he did, Ger?' And
I would have to say I don't; all his correspondence during this period
was typed, and often typed for him, and communications of the nature of
his to me were signed with a typed 'R.' But Barbara DeCelle, LRH
Personel Secretary at the time, later told me, because I asked, that
Hubbard had indeed seen my petition, and answered it". (Exhibit at
XXXXX.)
Armstrong later "revealed" some of "found" material in allegedly
collusive civil case with co-conspirator Michael Flynn which both
Armstrong and Flynn profited from via judgements and alleged payoff from
firm of Lenskes & Heller with suspected and alleged kickbacks to Lenskes
and Heller (Exhibit at XXXXX). The noncredibility of Armstrong's
cover-up story constitutes more evidence that Hubbard was unreported
missing person by this time and had no custody or control over his
personal property or over alleged "biography." Armstrong's allegations
also provided foundation for later related alleged criminal acts
including collection and confiscation by Armstrong in collusion with
Karno and Lenskes of all Hubbard literary property from international
locations, increasing "Hubbard archives" under Armstrong to hundreds of
thousands of intellectual property documents to secure custody and
control of said properties for Karno and the Lenskes.

* Karno and Lenskes and Armstrong conspired with attorney Flynn to file
frivolous civil suits, some naming "Hubbard" as party, to accomplish
several allegedly criminal purposes: 1. a "reason" for "Hubbard" to
"disappear;" 2. control on media stories about "Hubbard to effect
cover-up;" 3. options for receivership of Hubbard estate and/or
"motivation" for structuring it in ways beneficial to criminal intent;
4. personal profit from fees and judgements to come from "the Church"
and/or Hubbard accounts under their custody and control, with kickbacks
to Lenskes and Armstrong from Flynn and other possible suspects
(Exhibits at XXXXX).
Allegedly raudulent stories were circulated by suspects that suits
were reason for Hubbard to be in hiding but see court papers from suits
(Exhibits at XXXXX.). Nothing in suits to send Hubbard into hiding. Also
no criminal complaints against him. Story later changed that he wasn't
hiding, he was "in seclusion" to write. The alleged collusive "civil
suits" fraud run by Flynn with the Karno/Lenske/Heller group as
fraudulent "opposing" parties (through the churches) had alleged
criminal intent to embezzle Hubbard and church accounts to profit of all
suspect attorneys while also providing "plausible" cover for missing
Hubbard. Lenskes allegedly used Armstrong suit and DeWolf suit to get
press coverage on "proof" aided and abetted by Treas Dept personnel
(Doulder, Brunelle) that "Hubbard" was alive and in custody and control
of his business affairs which were in fact in the custody and control of
the Lenskes who were fraudulently pretending to be "Hubbard" through
production of forged documents. (Exhibits at XXXXX. See also XXXXXX for
trace routes Lenske-Emory-Brunelle-Doulder and to possible other
TreasDept personnel; also TreasDept personnel to Armstrong, Exhibits at
XXXXX.)

* Beginning as early as 1979 and continuing nearly through Hubbard's
announced "death" in 1986 communications from "Hubbard" were called "R"
advices and never signed but only identified with a typed "R" or "*" or
"# # #". (Exhibits at XXXXX.) Forgeries of his signature are alleged
to have been done by suspects but only when necessary. (Exhibits at
XXXXX.) Typed "dispatches" or "advices" with nothing but typed symbols
to "certify" that they had come from "Hubbard". Attorneys were allegedly
creating or having created for hire and delivering "advices" sending
them "down lines" through allegedly fraudulent and anonymous "Watchdog
Committee" which the attorneys are alleged to have created as a blind
for control as "R". Constitutes further evidence that Hubbard was
unreported missing person which was being covered up.

* On 23 Feb 1980 Karno, the Lenskes, Laurel Sullivan and Gerald
Armstrong conspired to create "Mission Corporate Category Sort-Out"
(MCCS) as alleged fraud to introduce to organizations the idea of
restructuring those organizations. The restructuring allegedly had
already been planned in secret before (Exhibits at XXXXX). E.g. evidence
of fraudulent nature of MCCS and its timetable is single page document:
"ALERT ADMIN EMERGENCY SMI...8 JANUARY 1980 RE: STARTER PACK FOR SMI
MISSIONS". SMI (Scientology Missions International) was not incorporated
until 22 Dec 1981 in corporate restructuring by Lenskes and Heller.
SMI's trademark "first use" dated 1982 with USPTO (Exhibits at XXXXX).
MCCS allegedly was fraud set up to give appearance of Sea Organization
involvement and to deceive organizational staff and executives into
believing that it was a "Hubbard" mission when it was actually under
custody and control of suspects via allegedly fraudulent and anonymous
"Watch Dog Committee". Alleged criminal purpose was to restructure
organizations to further their own profit and criminal intent.
MCCS also allegedly served fraudulent purpose of providing "Zolin
tapes" as fraudulent evidence that corporate restructuring was to cover
alleged "inurement" to "Hubbard". "Evidence" was allegedly manufactured
in recorded meetings by Laurel Sullivan specifically for the purpose of
being passed to Armstrong and then into the public record, of which
premeditated fraud on the courts Armstrong was allegedly knowing party
to. See Armstrong noncredible and contradictory stories about chain of
custody of tapes implicating DeCelle who was also on MCCS. (Exhibits at
XXXXX.)
Restructuring of organizations could not proceed without prior
revoke of HASI, Inc. (see above) and allegedly planned removal of
Guardians Office later executed (Exhibits at XXXXX). Hubbard had created
structure in policy and instructed that said policy could not be changed
lacking his approval. Restructuring done by suspects for alleged
criminal purposes conflicted Hubbard policy. Suspects allegedly created
fraudulent "Scientology Policy Directives" to carry out criminal intent
in absence of Hubbard. Constitutes further evidence that Hubbard was
unreported missing person which was being covered up.

* Sherman Lenske allegedly set up a "safe-house" for operations of part
of alleged criminal activity under the name of corporation Informed
Visuals, Inc. at 8335 Moorcroft Avenue Canoga Park, CA 91304. Location
close to Lenske offices. Set-up occured only a few months after Hubbard
"went into seclusion" and around same time firm of Lenske, Lenske,
Heller & Magasin formed to be "hired" at appropriate time by another
allegedly fraudulent "mission" of Norman F. Starkey and Terri Gamboa,
Armstrong's former wife. Property records in file include current and
former owner names and evidence of unusual grant of property. (Exhibits
at XXXXX. See also possible connection to Fed Reserve West at XXXXX.)

* In re MCCS and Lenske/Heller/Magasin hiring missions: according to
Armstrong Miscavige was "CMO Int Mission Ops" for both missions which
Armstrong says were on "Hubbard orders". (Exhibits at XXXXX.) CMO Int
was at relevant times under custody and control of allegedly
Karno/Lenske controlled anonymous "WatchDog Committee." Miscavige in
sworn deposition (Exhibits at XXXXX) testifies that at no time
subsequent to his becoming CMO Int Mission Ops at Gilman Hot Springs on
or around 1 Apr 1979 did he receive "any communications from Mr.
Hubbard...in writing, either by typed communication or telex regarding
the management of the Church of Scientology of California" (CSC). CSC
was mother church and housed Guardians Office. Constitutes more evidence
of fraudulent nature of MCCS with one of its allegedly criminal purposes
being to assist in covering up the death or disappearance of Hubbard.
Constitutes further evidence that Hubbard was unreported missing person
which was being covered up.

* Armstrong in 1981-82 in alleged collusion with Lenske converted
approx. 30,000 documents of Hubbard writings valued at approx. $5
million from "Hubbard archives" (see also ALLEGED CRIMES SECTION II).
Hubbard did not file criminal charges. Constitutes further evidence that
Hubbard was unreported missing person no longer in custody and control
of his property and interests which was being covered up by suspects.

* Hubbard was ordered by U.S. District Judge Manuel Real to appear for
deposition on 20 Mar 1985 in Los Angeles in civil suit allegedly being
conducted secretly by the Lenskes/Karno purportedly "against" attorney
Flynn with whom they were in alleged collusion. Hubbard failed to appear
resulting in case against Flynn being dismissed. Flynn had profited from
suits he had been party to in alleged collusion with Lenskes/Karno and
being a party to alleged fraud knew Hubbard couldn't appear and so
prevailed. Constitutes further evidence that Hubbard was unreported
missing person no longer in custody and control of his property and


 

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