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Deponent: Kenneth David Long
Deponent's: Third Affidavit
Sworn on 5th October 1987
In Support of Plaintiff

1987 C No. 6140

IN THE HIGH COURT OF JUSTICE

CHANCERY DIVISION

B E T W E E N :

CHURCH OF SCIENTOLOGY OF CALIFORNIA

{Plaintiff}

- and -

(1) RUSSELL MILLER

(2) PENGUIN BOOKS LIMITED

{Defendants}

AFFIDAVIT

OF KENNETH DAVID LONG

I, KENNETH DAVID LONG of 1301 North Catalina, Los Angeles,

California 90027, United States, an executive employed in the

Legal Division of the Church of Scientology of California,

MAKE OATH and say as follows:

1. I have been a member of the Church of Scientology for

eleven years, and employed by the Church of Scientology of

California (hereinafter the "Church") for the past seven

years. The Church is a non-profit making religious

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corporation registered in California since 1954. My duties for

the past five years have required that I work closely with and

assist Church counsel in all phases of litigation in the

United States.

2. I have read the final draft of Russell Miller's

upcoming book entitled "Bare-Faced Messiah," a purported

biography of Scientology founder, L. Ron Hubbard.

3. The main sources of information for Mr. Miller's

biography of Mr. Hubbard appear to be Jonathan Caven-Atack and

Gerald Armstrong. As demonstrated in my First and Second

Affidavits of October 5, 1987, Mr. Miller's and Mr.

Caven-Atack's claims that they obtained documents concerning

Mr. Hubbard and the Church from public sources, including the

Los Angeles Superior Court, are overwhelmingly false. In an

unsworn affidavit, Mr. Caven-Atack seeks to distract this

Court from his obvious contempt and violation of United States

court orders by a parade of irrelevant, disjointed and

conclusory diatribe, including accusations of criminal

activity. This is indeed an interesting turn.

4. Upon information Mr. Caven-Atack, prior to joining

the Church of Scientology as a parishioner, had a record of

drug use and drug pushing, including two convictions for

possession of drugs. In fact, Mr.Caven-Atack credited the

religious counseling procedures of Scientology with assisting

him in kicking his drug habit, during the time he was a member

of the religion. There is now produced and shown to me marked

-3-

"KDL 31" a petition written by Mr. Caven-Atack. In said

petition, he requested to be allowed to become an employee of

the Church of Scientology in Manchester, England, and details

his involvement with drugs. Due to the policy of the Church

whereby an individual with a criminal background is not

allowed to work as a member of Church staff, Mr. Caven-Atack

was denied employment by the Church, although he was not

denied membership in the Church nor its help in keeping him

off drugs.

5. In 1983 Mr. Caven-Atack resigned from his membership

in the Church. Thereafter, in late 1983, there was a theft of

sacred and confidential Church scriptures from a Church of

Scientology in Copenhagen, Denmark, by three British citizens

-- Ron Lawley, Robin Scott and Morag Bellmaine. Mr. Scott was

subsequentily arrested for the theft and convicted in Denmark.

There is now produced and shown to me marked "KDL 32" a copy

of the English High Court order enjoining the possession, use

and distribution of the stolen Church scriptures.

6. In 1984, Mr. Caven-Atack received a copy of the stolen

materials from Ron Lawley, made himself a copy of the

materials, and sent them to Larry West, a citizen of

California, U.S.A. There is now produced and shown to me

marked "KDL 33," excerpts from the transcript of the oral

testimony of Martin Ruston, taken in the United States, which

describe the part Mr. Caven-Atack played in the illicit

distribution of the scriptures stolen from the Church in

-4-

violation of the English court order.

7. It thus does not surprise me that Mr. Caven-Atack

would maliciously and deliberately engage in all manner of

irrelevant and highly prejudicial mud-throwing at the Church

of Scientology, given his own documented background as a drug

pusher, purveyor of the Church's stolen and confidential

religious scriptures and, as set forth in my First and Second

Affidavits, possessor of other documents belonging to the

religion's founder in violation of United States court orders.

Given the discreditable background and dubious motives of Mr.

Caven-Atack as regards a Church which opposes the use of

drugs, opposes crime, and which extended to Mr. Caven-Atack

its help regardless of his past transgressions, it is obvious

to me that the evidence he gives should be recognized for what

it is and disregarded.

8. Gerald Armstrong has been an admitted agent

provocateur of the U.S. Federal Government who planned to

plant forged documents in Church files which would then be

"found" by Federal officials in subsequent investigation as

evidence of criminal activity.

9. The evidence is irrefutable that the great majority

of these biographical documents were obtained by Mr.

Caven-Atack and Mr. Miller in violation of court sealing

orders. As such, the allegation of "unclean hands" in

contexts entirely unrelated to the facts at issue here has as

its only purpose to distract and inflame this Court into

-5-

denying the relief which the Church is seeking.

This document in pdf format.

See also Armstrong Declarations of 03-15-1990 and 12-25-1990

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