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I, WILLIAM FRANKS, hereby state under the pains

and penalties of perjury that I have personal knowledge of the


1. I joined the Church of Scientology in 1968 and

between 1970 and 1979 at various times, I have worked directly

and personally with L. Ron Hubbard. In December 1979, I

was appointed by Hubbard to be "Senior Management Executive

International." In this position, I was in charge of all of the

administrative bureaus of the Church of Scientology throughout

the world, and worked on a regular basis with all of the highest

ranking officials of the Church of Scientology, including Mary

Sue Hubbard, David Miscavige, John Nelson, Herbert Parkhouse,

and many others.

2. In December 1980, I was appointed by L. Ron

Hubbard to be "Executive Director International" of all Churches

of Scientology throughout the world. I saw an order written by

L. Ron Hubbard himself appointing me to this position. The last

Executive Director International was L. Ron Hubbard himself, who

allegedly resigned from that position in 1966. Therefore, by

virtue of this appointment, which was a lifetime appointment, I

was senior to every Scientology executive throughout the world.

Theoretically, since I held the post of Executive Director

International, no person, even L. Ron Hubbard, could countermand



my orders. However, as I learned shortly after my appointment,

this was not how Hubbard intended me to operate.

3. Within a period of weeks following my

appointment, I learned that I was required to sign and file a

written resignation as Executive Director International which

was undated and which could be used at any time to remove me by

Hubbard. This was in keeping with the policy of Hubbard that

every Church of Scientology corporation officer or director must

resign in advance of their appointment and sign undated letters

of resignation so that they could be removed by Hubbard at will.

4. Additionally, I learned that I was to receive

all of my orders and directives through David Miscavige, who

held the position of being the direct liaison to L. Ron Hubbard,

who at that time, was in hiding. As the administrative head of

the Church, I actually would receive my orders from Hubbard via

Miscavige and implement the orders.

5. Throughout the period of time that I served as

Executive Director International, I observed the highest leaders

of the Church use documents and activities relating to illegal,

criminal, and tortious conduct against many individuals who have

been designated enemies of the Church. These individuals

include Attorney Michael J. Flynn and many of his clients. At

this time, Michael Flynn was one of the three top enemies of




6. In 1980 and 1981, I have personal knowledge of

many orders issued by L. Ron Hubbard concerning attacks against

Michael Flynn. Hubbard considered Flynn to be a "whore" and

Hubbard ordered him to be totally ruined. We were ordered to do

a complete investigation of Flynn, find or "manufacture " crimes

he had committed, expose his "crimes" to his clients and to law

enforcement officials, ruin his law practice, have him disbarred

and file numerous law suits or bar complaints against him

without regard to whether the complaints were meritorious or

not. L. Ron Hubbard personally ordered all these activities and

I saw many of the orders.

7. In 1980, L. Ron Hubbard personally ordered

Michael Flynn's trash to be picked up and gone through on a

daily basis. This was part of a huge investigation of Flynn

which Hubbard had ordered. According to Hubbard, and

Scientology policy, any individual who attacked Scientology must

be a criminal. Therefore, Hubbard ordered us to do as thorough

an investigation of Flynn as possible, to uncover Flynn's

crimes. We were ordered to go all the way back to his days in

law school.

8. When Hubbard ordered someone's crimes to be

found, his agents would "manufacture" crimes, if actual crimes

could not be found or did not exist. In fact, Hubbard's policy

on this issue specifically stated as follows:



"In the face of danger from Govts or courts there

are only two errors one can make: (a) do nothing

and (b) defend. The right things to do with any

threat are to (1) Find out if we want to play the

offered game or not, (2) If not, to derail the

offered game with a feint or attack upon the most

vulnerable point which can be disclosed in the

enemy ranks, (3) Make enough threat or clamor to

cause the enemy to quail, (4) Don't try to get any

money out of it, (5) Make every attack by us also

sell Scientology and (6) Win. If attacked on some

vulnerable point by anyone or anything or any

organization, always find or manufacture enough

threat against them to cause them to sue for

peace. Peace is bought with an exchange of

advantage, so make the advantage and then settle.

Don't ever defend. Always attack. Don't ever do

nothing. Unexpected attacks in the rear of the

enemey's front ranks work best."

Consequently, Hubbard's agents routinely manufactured incidents

and created incidents so that we would have "proof" of the

crimes our enemy had committed. A copy of the policy is

attached hereto.



9. Once we had found Flynn's "crimes," we were

ordered to expose them. Consequently, the Guardian's Office

agents contacted Flynn's clients, Scientology and

non-Scientology, with the intent of separating Flynn from his

clients in order to destroy his law practice. Those were

Hubbard's orders.

10. It was the policy of Hubbard and the Church

of Scientology throughout this time, to use the law to " attack"

and "harass" its enemies by bringing frivolous lawsuits against

them. Hubbard himself ordered lawsuits to be brought against

Flynn and his clients. These lawsuits were brought without any

concern as to whether they were meritorious or not, the whole

purpose was to "bury" Flynn in these suits. The filing of these

suits was to be very highly publicized by our public relations

people so that Flynn's reputation in the community would be

further harmed.

11. Pursuant to Church policy, because Hubbard

had ordered certain policies and operations to be taken against

Flynn, he would be informed of all actions taken pursuant to his

operations. Therefore, he was regularly briefed about attempts

to find Flynn's crimes, to expose Flynn as a criminal, to have

Flynn disbarred, the lawsuits against him, and other

operations. Hubbard would have also been informed of the

numerous attempts made by the Guardian's office to plant spies

in Flynn's office. These actions would have been taken pursuant

to Hubbard's orders to investigate Flynn as fully as possible.



12. In 1981, we obtained from the trash, a copy

of a draft prospectus for a corporation named Flynn Associates

Management Corporation (FAMCO). This prospectus made it look

like Flynn was attempting to finance the Scientology litigation

by selling shares in the litigation. From the trash documents

and other investigations of Flynn's finances, we already thought

that he would not have enough money to finance the litigation.

In fact, Hubbard ordered us to find out who was paying Flynn.

This prospectus seemed to provide the answer, and it was sent to

Hubbard. In fact, we later received information that shares in

FAMCO were never sold or even offered.

13. After seeing the FAMCO prospectus, Hubbard

issued an order stating that this proved that Flynn was

sydicating litigation. We were ordered to have him disbarred on

the basis of the FAMCO documents. FAMCO was viewed as the best

method of ruining Flynn's reputation in the legal community

because he had engaged in unethical conduct. Hubbard further

ordered that Flynn's clients be contacted and informed about

FAMCO and that Flynn would be shortly disbarred and sent to

jail. An attorney in Boston, Harvey Silverglate, was specially

hired to make sure that Flynn was disbarred. He was instructed

to file bar complaints and make sure that Flynn was unable to

practice law. At that same time, we were filing bar complaints

and trying to ruin Flynn's reputation, we had received

information that FAMCO shares had never been sold and nothing

was ever done with this corporation. In other words, we knew



our allegations about Flynn and his involvement with FAMCO were

false. Nonetheless, pursuant to Hubbard's instructions to ruin

Flynn, we still made the allegations and attempted to have Flynn


14. After Hubbard ordered me to fire his wife,

Mary Sue Hubbard as controller, I no longer saw copies of

Hubbard's orders to the Guardian's Office. These went directly to

Norman Starkey and Terry Gamboa. Nonetheless, Starkey and

Gamboa frequently referred to orders they received from Hubbard

including his instructions on how to follow up on the

disbarrment proceedings. Again, pursuant to Scientology policy,

because Hubbard had ordered certain actions to be taken, he

would have been briefed and informed about all actions taken

pursuant to his instructions.

15. In November 1981, I came into increasing

conflict with David Miscavige, the man who relayed Hubbard's

orders to me and everyone else in Scientology. The reason for

this conflict was because I attempted to block many of the

criminal and illegal operations implemented by Miscavige and the

Guardian's Office on behalf of Hubbard. In December 1981, I was

removed from my position, and then held against my will and

locked up in Gilman Hotsprings, California for a period of




16. While I was Executive Director of the Church

of Scientology, we continually attempted to shield L. Ron

Hubbard from any legal liability as a result of Church of

Scientology activities. To do this, we continually lied in

sworn affidavits and depositions about our contacts with L. Ron

Hubbard, his control of the Church of Scientology, and our

knowledge of his whereabouts. These perjurious statements were

intentionally and willfully made, with the knowledge of Hubbard

himself. In fact, he ordered many of the statements to be made.

The principal responsibility of attempting to shield Hubbard

from legal liability was handled by Norman Starkey and Terry

Gamboa. I had numerous discussions with Starkey and Gamboa

about shielding Hubbard from legal liabilities, despite his

total management control over all phases of the Church of

Scientology operations.


Signed under the pains and penalties of perjury

this 3rd day of April, 1985 in Boston,


Signature of William Franks Affidavit of 09-24-1985






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