MR. FLYNN: Exhibit No. 30 will be a Hubbard Communications Office policy letter in June 1959. And I will refer the
Commission to the bottom of the page dealing with "duplicate contracts, releases and promissory notes."
And the relevant portion is as follows: "Any staff member signing up a preclear student or PE attendee will get one
original and one carbon copy of each contract, release, and promissory note necessary to.be signed.* And then,
skipping down to the last paragraph: "The carbon copy of the contract and release, along with the yellow invoice, is
routed to the Associate Secretary and from him to the department head concerned: 'the Director of Processing, the
Director of Training, or the PE Foundation Director. After being reviewed by the department head, these are then
routed for filing in the administrative division of each department. A carbon copy of the promissory note is routed to
the Director of Accounts. The policy -- this policy must be rigidly enforced as it saves much expense in
It's copyrighted by L. Ron Hubbard.
(A copy of a policy letter from Hubbard Communications Office, dated June 1959, was marked as Exhibit No. 30, as
of this date.)
MR. FLYNN: The next document -- the next document is a form affidavit.
(A copy of an affidavit was marked as Exhibit No. 31, as of this date.)
MR. SHOEMAKER:. Mr. Flynn, if I might ask: For instance, on that last document, it said it was copy-
righted by L. Ron Hubbard and it said Mary Sue Hubbard for L. Ron Hubbard.
Would you explain that as to what effect that has from a legal point of view?
MR. FLYNN: Everything -- or 99.9 percent of the publications of the Church of Scientology are copyrighted by L. Ron
Hubbard. At various points in time in connection with various areas of responsibility, such as Guardian's Office
activities, there was an immediate level of recognition in responsibility below L. Ron Hubbard, and that was,
primarily, Guardian's Office Legal Affairs and Guardian's Office B 1 Activities, which is intelligence gathering
activities, for which Mary Sue Hubbard was directly responsible.
So, in those types of publications, her name also appears.
And Exhibit 31 is a form affidavit for the Church of Scientology with regard to -- and I won't bother
reading through all this because we have a number of
forms for people who actually signed them. But basically,
itis a promise not to divulge any information about the
Church of Scientology without the prior consent of
Hubbard, its members, and the organization itself.
MR. BERFIELD: Counsel, where are these coming
from, so that we know they're not something that's just
being made up?
MR. FLYNN: All right.
'Well, the HCO policy letter comes right out of a
set of green volumes which, in order to -- in view of
the time constraints we're working under, I would have
to put into evidence all of the green volumes. if it
becomes necessary, we'll do that. There's some twelve
of them. And all of the ten red technical bulletins.
And if it becomes necessary, we'll do that. But the
amount of the paperwork the Commission could be confronted with in a very short time would be unwieldy.
MR. BERFIELD: No. I mean, if you would just
address that so that --
MRS. GARVEY: Just say where it's coming from.
MR. BERFIELD: -- just where it's
MR. FLYNN: That's where it's coming from.
And if.need be, at the conclusion of the hearings,
we can just simply put all of those books into evidence and correlate them to the particular xerox copies that I'm
And the form affidavit is also such a document.
The next exhibit, Affidavit of Janet Troy, is.-and there will be an affidavit signed by Janet Troy relative to this
document and relative to other matters that are involved with the Church of Scientology, which will be introduced at a
later time and we'll tie the two together.
Basically, if you go down to paragraph six, Janet has stated that she "hereby discharges fully and releases L. Ron
Hubbard, any Scientologist, and Scientology course, their assigns and successors from-all rights, claims, or any
actions myself or any successor or assigned to' myself may have now or hereafter the signing of this agreement
against L. Ron Hubbard, any persson, any -Scientology Church, their assigns or successors. This release is freely
and voluntarily executed by myself with my understanding of the terms used herein and the consequences resulting
"That I do hereby waive all rights to refund or repayment of any donations that I have made or will make in the future
to the Church of Scientology. I waive
this right of my own free will." (A copy of the Affidavit of Janet Troy was marked as Exhibit No. 31, as of this date.)
MR. SHOEMAKER: Mr. Flynn, is that legal?
MR. FLYNN: I believe the evidence will be that in for most people entering Scientology, they're made to sign these
documents at the outset and, for the most part, they have no idea what they're signing. At variouspoints during their
proceeding through Scientology, when difficulties arise -- if difficulties arise -- and as the last witness testified, he
left, and during the time he was in he was never in the RPF; so, no difficulties arose until-he had already left. And
afterward, hisbrother --- his brother's wife was visited by some unknownpeople.
But if- difficulties arise of a substantial nature during the period that they're in the Church, I believe the-evidence will
show that these people are made to believe that these documents are enforceable in a court of law. And I also
believe that the evidence will show that items such as I'm about to introduce indicate that promissory notes, legal
promissory notes, were signed.
In fact, when you asked me, "Is it legal," well, I would say that the thing is utterly unenforceable. But
the issue is whether or not the people are made to believe that it might be enforceable.
MR. LeCHEA: Didn't one.of the witnesses say that they were told that the money would be -- it would be a money
back guarantee, and some, at least, tried to get their money back and they were promised but never received it?
MR. FLYNN: That's true.
I think that the testimony there and the testimony in the future will be that they are told about a refund policy, but, in
fact, as you just saw in the Janet Troy Affidavit, it's often times -- most of the time they sign documents that they
don't even realize they're signing, saying they can't get a refund. And then, they are led to another policy which says
they can get a refund.
So, there's a conflict between the two policies. And most of the time, the people have no idea what their rights are.
MRS. GARVEY: Was Janet Troy a staff member?
MR. FLYNN: Janet Troy was a staff member; that's correct.
MRS. GARVEY: Is it different for a staff member than it is for a Scientologist that's coming for a course?
MR. FLYNN: It is. -
The people that sign -- there are different types
of waivers and different types of releases that are
signed for contract or staff members as opposed to a
public person who is just coming to get services.
For instance, the first affidavit that I introduced
in blank form was for someone who was a public person.
The one I just introduced is for a staff member.
MR. CALDERBANK: But these are made or represented
to the people as legal.documents, binding in the outside
MR. FLYNN: As I indicated before, for the most
part, when they're signing them, they don't even know
what they're signing. When difficulties arise, they are
presented with-the fact that they are enforceable documents and they can be used against them in a court of
And in fact, there will be affidavits in evidence
to that effect, which brings up one more point. In
view of the time and cost constraints of the four days
that we're laboring under and the seventeen or so witnesses we're going . to try to get through, I'm presenting
affidavits of people on some subjects to corroborate
other pieces of evidence. If the city at some point,
having-its appetite whetted, so to speak, about the potential scope of this subject saw fit to continue the hearings
and bring in more witnesses, I would suggest to the Commission that there are many, many more witnesses who
could come in and testify about specific points.
MR. CALDERBANK: Are these individual malcontents or are there many people like this who have been going
through the same or similar circumstances where they've been threatened, harrassed, apparently, threatened to be
sued by L. Ron Hubbard?
MR. FLYNN: What I have endeavored to do is rather than bring witnesses who have just been harrassed, I
endeavored to bring in witnesses who re present a crosssection of their experiences in Scientology so that the
Commission, I-believe, at the end of four days will have experiences with different people in different positions who
'experienced different things in the organization, rather than just a selection of victims who have been harrassed,
some of which you will hear about in detail.
MR. LeCHER: One thing about the contracts: You mentioned -- the young man, Mr. Kelley, mentioned about young
people younger than him? younger than eighteen, that were twelve and thirteen and handling vast sums of money.
Do they also sign these contracts?
MR. FLYNN: The next exhibit is an exhibit of Tonja Burden - it's a multi-page exhibit with some fifty or seventy
thousand dollars of promissory notes - who worked for the organization from the age of thirteen to the age of
seventeen. She never was given any education in this city; she was for two years and three months.
And as you will see from the exhibit, she signed releases, non-disclosure bonds, promissory notes
MR. LECHER: At what age did she sign these?
MR. FLYNN: At varying ages during -- with regard to the invoices and the promissory notes, at various times when
she was in the city. With regard to the releases, she signed releases when she was in the organization. And then,
afterwards, she was taken -- after she escaped from the City-of Clearwater, as the affidavit will show and if need be,
she can be called as a witness, but she does have a lawsuit against the Church, and I have made an effort to
discriminate between individuals who have a lawsuit and those who don't, but she could be called as a witness.
And as her -- some of her documents show, she was -- and her affidavit will show to the Commission, after she
literally escaped from the Fort Harrison RPF,
she went home to her -- the City of Las Vegas. And approximately two or three weeks later, two Guardian's office
operatives-arrived in the City of Las Vegas and took her to Los Angeles, locked her in a room, and put her on the
cans. And after that, she was made to sign many documents which are here, which I won't read at this particular
time but.I'll 'read in connection with her affidavit, whereby she was informed that she owed the organization some
sixty thousand dollars. And this is after she was out of the organization. And she was sent a freeloader's debt of
$63,000.00 which she was told she had to pay and
MR. LeCHER: What I'm getting at: Would she sign something that she believed to be legal? was she a minor; was
she under age?
MR. FLYNN:, That's correct.
MR. LeCHER: She was what, sixteen years old?
'MR. FLYNN: That's correct.
She was signing she signed many documents at various points in time from the age of thirteen to the age of
MR LeCHER: Can a thirteen to a seventeen year old sign something to pay eighty, ninety thousand dollars?
MR. FLYNN: Of course not.
MR. BERFIELD: Counsel, a question that I have
here: -This is an administrative or a legislative hearing,
and some of the rules of justice do not prevail here on
hearsay and what have you. But if you had to introduce
All of this into evidence, you said that it would be
What are you talking about in size?
MR. FLYNN: Well, for instance, if we -- when Mr.
Walters was on the witness stand - he is aware of most
policies within the Church - and to go into every policy,
his testimony could have taken a week in itself because
of the scope of his knowledge. And we could have put into
evidence, probably, fifteen or twenty different volumes
of some six hundred or seven hundred pages each, together
with, probably, a thousand documents of Guardian's Office
activities, which would begin to display the scope of
Since we don't have those -- that amount of time
and we're laboring under financial constraints - what
I've endeavored to do is to present some people at
different levels. And you will be hearing from some
Guardian's Office operatives who, actually, have committed
burglaries. You have just heard from an individual who
was simply a young boy who came into the organization and
worked at a very low level here at the Fort Harrison, and you heard it from his point of view. And you've heard Mr.
Walters' experiences from his point of view.
so, in order to give you a proper perspective -we could be here for two months. And in my own judgment, having
worked with the subject for three years, you would begin to realize the scope of the problem, in my own judgment.
In any event, the next witness is Rosie Pace.
MR. LeCHER: Miss Pace.
Will you bring in Miss Pace, please.
Commissioners, again I ask you to --and I remind myself, too - that we should be to the point and brief because we
do have thirteen or fourteen witnesses to go. And I think we have a day and-a-half to do it in.
MR. BERFIELD: Mayor, while she's coming in: Mr. Flynn, these volumes are available for our inspection, are -they
MR. FLYNN: Absolutely. And if the Commission desires, I will have them introduced into evidence at the close of the
proceedings for your perusal.
MR SHOEMAKER: Commissioner Berfield, also, some of the many of the documents which Mr. Flynn is referring to
were, in fact, submitted as appendices to
his initial report. The problem with that was that the
appendices were about this high
MR. BERFIELD: I realize that.
MR. SHOEMAKER: in addition to the report, so
we didn't distribute them. Certainly, they are available
in the public library and they're also available down
at the City Clerk's office for anyone who wants to see
MR. FLYNN: Correct.
On that point, I would like to simply suggest that
just to review Guardian's Office documents involving
operations in the City of Clearwater, there's a volume
about yea thick of probably a thousand pages. on
Guardian's Office operations nationwide, it's probably
five to ten thousand pages thick that are either currently
on record or could be produced. And that is not even
getting into issues of financial issues, training issues,
legal issues, such as the releases and the waivers I put
MR. CA.LDERBANK: If it pleased the Commission, at
the end of-the hearing process, then, I would like to have
as many of these documents entered in, in addition to the
documents that he is entering in throughout -- or during
the testimony to substantiate them. I'd like as much
information as possible from both sides..
MR. LeCHER: All right.
Let's get with Miss Pace. Miss Rosie Pace.
I have to ask you the five -- before I do that,
I must ask you to get sworn in, please.
Is the Clerk there, Mrs. Lamkin?
ROSIE PACE, a witness herein,
having first been duly sworn by a Clerk for the City of
Clearwater, was examined and testified as follows:
MR. LeCHER: Okay.
Miss Pace, we'--e goinq to ask you the f'ive basic
questions, then, we'll get on to have you discuss your
The first question: Are you appearing here today
and testifying-under oath voluntarily?
MS. PACE: Yes.
MR. LeCHER: Have you been paid by anyone for your
testimony, other than the expenses for coming to Clearwater?
MS, PACE: NO.
MR. LeCHER: Do you have a lawsuit against the
Church of Scientology?
MS. PACE: No.
MR. LeCHER: Does the Church of Scientology have a lawsuit against you?
MS. PACE: No.
MR. LeCHER: Has,anyone suggested to you that you should state anything but the truth, or has anyone suggested
that you change your testimony for any reason?
MS. PACE: No.
MR. LeCHER: Are you -- just to set the stage here, are you the sister of Lori?
MS. PACE: Yes, I am.
MR ". LeCHER: Who spoke yesterday.
Ms. PACE: Yes.
MR. LeCHER: Miss Pace, would you like to make a statement or would you like me to start asking you questions,
or would you like to do it in your own way?
MS. PACE: Well, I'd like to tell you how I got into Scientology.
MR. LeCHER: I'd like to hear that.
MS. PACE: Okay.
I've been in -- first of all, I'm very, very nervous.
MR. LeCHER: I know you are and you've been waiting a long time and so forth.
MS. PACE: I came into Scientology seventeen years
ago in 1965. 1 was thirteen. And I was having a lot of
trouble with school and I didn't want to go.
MR. LeCHER: To school?
MS. PACE: Yes.
So, my sister, Lori, had gotten involved in
Scientology and she felt that it could help me. And her
intention was that that would make me want to go to
But when I went into the organization, they told
me, well, I was right in not wanting to go to school
MR. LeCHER: At age thirteen?
MS. PACE: Yes.
And that the Board of Education was suppressive,
and that I would be harmed if I did go to school. And
at the time,--I.-loved it; I thought that was great. And
that they would write a letter to the Board of Education
that,I was getting spiritual counseling so that I
wouldn't be sent to a reform school or anything like
that, that it was okay that I didn't go to school because
of the spiritual counseling.
MR LeCHER: Did they write a letter to the Board
MS. PACE: Yes, they did.
MR. LeCHER: Did the Board of Education in that
particular community agree that spiritual counseling was
more valuable than school?
MS. PACE: At the time, it was for -- it was
supposed to be for a brief period of time that I would
be getting the counseling. Somehow, I managed not to
go to school. I just wanted not -- not to be sent to a
reform school. And I started getting Scientology training at the age of fourteen. And I was a highly classed
auditor at the age of sixteen. And that has been my
MR. LeCHER: Your life -- when did you leave the
MS. PACE: Just two months ago, officially.
MR. LeCHER: Can you tell me something with
respect -- were you in Clearwater?
MS. PACE: Yes, I was.
.MR. LeCHER:' How long were you in Clearwater?
MS. PACE: I was in Clearwater for seven months,
from May '79 till December '79.
MR. LeCHER: Can you tell me something about the
activities in Clearwater?
MS. PACE: Well
MR. LeCHER: From your first person point of view,
what you actually saw?
MS. PACE: All right.
I arrived in Clearwater, and the first night I was
taken to a room at the Gray Moss bec ause there was no
dorm for me. The next night I was brought to a dorm
which had no light, and I had my luggage and I couldn't
get in the room. There were about ten beds in the room.
MR. LeCHER: How old were you at the time?
MS. PACE: This is three years ago; I was twentyseven.
And there were suitcases all over the room, no
light. So, I just walked down the stairs and I said, "I'd
like to pay for my own room because I don't want to stay
in the dorm," and that's what I did.
And I was here for NED for OTs training.
MR. LeGHER: NED for OTs?
MS. PACE: NED for OTS.
MR. LeCHER: Oh, NED for OTs.
MS. PACE: Right, which was supposed to be beyond
your wildest dreams and it was just going to handle
everything that's wrong with you, and that I would be
treated like gold when I got to Flag Land Base. And I
later found out that that was an absolute lie.
I started my training. It was going along fine.
And Lori had come one month-later. And she was having a little bit of trouble and she blew, like she said. And my
other sister, Annie, was with me.
We got pulled into Ethics, immediately, and they told us it was a conspiracy. And I got very physically ill. I had a
high fever and swollen glands and I couldn't get out of bed. And I was ordered out of bed because there was going to
be a meeting with the senior CS of the Flag Land Base.
So, I got out of bed and he screamed and screamed and sc reamed and ordered me back on post the next morning.
Also, my sister, Annie, who's not, here, was sick, also. And he ordered her back on post the next morning and said
he would not tolerate any illness.
MR. LeCHER: Who was "he," and what was his title?
Ms. PACE: He was the senior case supervisor; his name was Jeff Walker.
And Lori came back the next day. By this time, I was afraid for Lori because, as far as I was concerned, this man,
this Jeff Walker, was insane. He was screaming and just totally psychotic.
Anyway, Lori came back. And I was having severe headaches. I've had them for a long time. And they had gotten
worse. And I decided to see an eye doctor because
I had some trouble with my eyes and I thought maybe that was the problem.
Anyway, it ended up, I had an eye operation. That's how I got out of-the Flag Land Base. Before then, I couldn't get
out; I thought I couldn't get out, mentally; I couldn't leave.
MR. LeCHER: What was wrong with you that they forced you out of bed? I mean, were you just emotionally drained
or did you have the flu or
MS. PACE: I had a high fever and swollen glands, sore throat, and I was just very weak. I was very upset that my
sister had blown because that's the worst thing you can do in Scientology. And I was afraid of what was going to
happen to her when she returned.
MR. LeCHER: Were you concerned then that you might infect other people?
MS. PACE: I'm sorry?
MR. LeCHER: Weren't you or they concerned that you might infect other people? Forgetting about your own health,
if you did have a temperature, you my have a tendency to infect the whole dorm or the whole organization.
MS. PACE: Well, obviously, he didn't care.
MR. LeCHER-. Is that Standard practice, that if you feel ill you cannot go to a doctor?
MS. PACE: Well, you're allowed to go to a doctor. I wasn't told to go to a doctor; I was told to return to post. So,
that's all I know.
You are allowed to see a doctor.
MR. LeCHER: Can you go alone to see a doctor or must you be escorted there by
MS. PACE: The MAA, the Master at Arms, of Flag Land Base said he'd have to come with me.
MR. LeCHER: You couldn't go on your own?
MS. PACE: Well, I convinced him that I was able to go on my own, that I really didn't want him to come with me.
MR. SHOEMAKER: Could you give that title, again, please?
MS. PACE: Master at Arms.
MR. SHOEMAKER: Master at Arms.
MS. PACE: That's the Ethics Officer.
MR. LeCHER: If you had a physical ailment that may be rather personal in nature, would that ailment be concealed
from the Master at Arms or from the organization, and would it be just between you and your doctor?
MR. PACE: No. The doctor is to write a report and give it to the Medical Officer.
MR. LeCHER: Were these doctors chosen at random
out of the phone book or were they Scientology doctors?
MS. PACE: They weren't Scientology doctors.
MR. LeCHER: Can you tell me about -- anything more about the living conditions in Clearwater?
MS. PACE: Well, I didn't live in a dorm. But after I had my eye operation, I couldn't stay in my regular room because
there was auditing going on in there, and I spent most of my days in the dorms just sleeping on a bunk. And there
were ants crawling all over you. There were
MR. LeCHER: Ants?
MS. PACE: -- ants-all over the bed. There were about eight to ten beds in each room, no air conditioner, luggage all
over the room; you could hardly walk. There were roaches all over the entire building.
MR. LeCHER: What about maid service or did you change your own linens and wash your own linens?
MS. PACE.: If you're -- if you're a staff member, you handle your own linens, do your own laundry. If you're a public
MR. LeCHER: You had maid service?
MS. PACE: Yes.
MR. LeCHER: Who -- where did you find these maids? Were they from within the community, trained domestics, or
were they also Scientologists that were doing
J- V 0
MS. PACE: They were staff members.
MR. LeCHER: Staff members.
MS. PACE: Of the Church of Scientology.
MR. LeCHER: How do you get to be a maid? I mean, do you apply for the job or are you given that job for performing
MS. PACE: Well, I think, when you first come in, you do this sort of work.
MR. LeCHER: You work your way up within the organization?
MS. PACE: Yes.
MR. LeCHER: Frcm a maid to a higher position?
MS. PACE: Yes. I didn't go through this process, but I -- you do physical work before you're promoted.
MR. LeCHER: You apparently were highly trained within the Church of Scientology. How did -- how much money
were you paid as a staff member?
MS. PACE: Well, it varied through the years. Sometimes, nothing; sometimes, twenty dollars a week, depending on
how much they made that week.
Mik. LeCHER: -If you were started at thirteen -- and you say you were in there for seventeen years?
MS. PACE: Yes.
MR. LeCHER: And obviously, your education must
have been limited; your skills, marketing skills, must have been limited. You were paid, at most,- twenty dollars a
How did you support yourself, buy personal objects, clothes, and things?
MS. PACE: Well, when I was a teenager, I lived wit my sisters and I babysat for them. And Lori was married I my
sister, Lori. That's how I lived then. And I worked on the outside to support myself later on.
MR. LeCHER: Did you work in Clearwater?
MS. PACE: No.
I had a business in California when I was at Clearwater. That's how I was able to get my own room.
MR. LeCHER: You and your sister seem like very industrious women in spite of all you've been through, the number
of years' hell that were spent in Scientology.
We talked about the -- did you have -- what about the Fair Game.? Has it been affecting you when you left -since
you left the Church, have they tried to contact you or talk you into coming back within the organization?
MS. PACE: No.
The only person who called me was my husband, who left me. When I told him what I had found out about
Scientology, that I had just been miserable -
MR. LeCHER: Is he a Scientologist?
MS. PACE: He's in the Sea Org., and he's filing for divorce. And he's the only person who has called me and tried to
harrass me, but hasn't.
MR. LeCHER: If you were not married to a high ranking member, do you think you would have been will erase the
question I'll yield now to Mr. Hatchett.
.MR. SHOEMAKER: Mrs. Garvey.
MR. LeCHER: Mrs. Garvey, sorry.
MRS. GARVEY: Did you ever find out in particular what your illness was?
MS. PACE: No.
MRS. GARVEY: When you were auditing, did you assume that the auditing information was confidential?
MS. PACE: Yes.
.MRS. GARVEY: When you were audited, did you assume the information was confidential?
MS. PACE: Yes.
MRS. GARVEY: When you were auditing, were you told it was based on scientific techniques?
MS. PACE: Yes.
MRS. GARVEY: What were you told about the Guardian