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LOUISE G. HUBBARD Plaintiff No. 23323



The petition of Polly Morton respectfully shows to this Court:

That she is the plaintiff in the above-entitled section whose former name was Louise G. Hubbard. That she resides in the city of Beverton, Kitsap County, Washington.

That the plaintiff and he defendant intermarried at Elkton, Maryland, on April 13, 1933; that two children were born the issue of said marriage, to-wit: Lafayette Ronald Hubbard, Jr., born on May 7, 1934 and Katherine May Hubbard, born January 15, 1936.

That the plaintiff filed her complaint herein for a divorce from the defendant on April 14, 1947, upon the grounds of desertion and nonsupport. That the defendant entered his written appearance in said action and stipulated, among other things, that the custody of the minor children of the parties be awarded to the plaintiff and that the defendant pay o the plaintiff for care and support of said children the sum of $25.00 a month for each of them, payable on the first day of each month, starting as of June 1, 1947; and that the action proceed as on default.

That in its findings of fact the court found that the defendant willfully abandoned plaintiff and said children in the month of December, 1945, and since that date had continued said abandonment and failed to make suitable financial provisions for his family.

That on June 25th, 1947, an interlocutory decree of divorce was entered herein divorcing plaintiff from the defendant, the material parts of which read as follows:

“ORDERED, ADJUDGED AND DECREED, that the plaintiff be and hereby is granted the care, custody and control of Lafayette Ronald Hubbard, Jr., and Katherine May Hubbard with reasonable rights of visitation reserved to defendant at proper times and places, and in the event of plaintiff’s death during the minority of the children, their custody should be awarded to the defendant, and it is further “ORDERED ADJUDGED AND DECREED, that the plaintiff be and she hereby is awarded, for the care and support of said minor children, the sum of $25.00 per month for each child during minority, payable on the first day of each month, starting as of June 1, 1947.”

That in said decree the defendant was also ordered to pay plaintiff an attorneys fee of $100.00 and costs of suit amounting to $18.70.

That said interlocutionary degree of divorcee was made final by a decree entered on December 24, 1947, and remains in full force and effect and has never been modified.

That plaintiff supported herself and said children who were in her possession, since defendant deserted them in the month of December, 1945, until the final decree of divorce was entered herein on December 24, 1947. That since that date said children have been in the custody of the defendant at Bremerton, Washington, with Katherine May living with the plaintiff and Lafayette Ronald Hubbard, Jr., living with his paternal grandparents at Bremerton, Washington, under an arrangement with the plaintiff.

That since the entry of the final decree herein plaintiff is informed and believes that the defendant has promoted a cult called “Dianetics”; has authored a best selling book called “Dianetics, The Modern Science of Mental Health”, published May (1?) 1950; and has substantial interest in the Hubbard Dianetic Research Foundation, which has operated a school or clinic in Chicago, Illinois; New York City; Los angles; Honolulu; Wichita, Kansas; Seattle, Washington; and elsewhere; that said defendant and said foundation did over one million dollars in business during the year 1950, and owns valuable property and assets; that said defendant and said foundation operate in the State of California, under the name of “The Hubbard Dianetics research Foundation of California, Inc.” a California corporation, and in the state of Kansas under the name of the Hubbard Dianetic Foundaion, Inc., a corporation, 211 West Douglas avenue, Whichita 2, Kansas; and that said foundation and said corporations are the alter ego of the defendant.

That plaintiff made no attempt to collect any children’s support money from the defendant until he was financially able to pay it. That her first request to the defenant that he pay was made by plaintiff’s counsel to defendant by letter dated March 4, 1951, which brought no response.

That plaintiff then learned for the first time, and unpon information and belief alleges the fact to be, that the defendant bigamously married one Sara Northrup Hubbard on August 10, 1946, at Chestertown, Maryland, and that they lived together as husband and wife, and he supported her until on or about February 24, 1951, when they separated in the State of California.

That the plaintiff is informed and believes that said bigamous marriage was terminated by a decree of the District Court of the State of Kansas in and for Sedgewick County, Judge William C. Kandt, presiding, in cause NO. A – 36 594 entitled “Sara Northrup Hubbard, plaintiff, vs Lafayette Ronald Hubbard, defendant”; that the decree was granted to the defendant on June 12, 1951, as an “emergency” upon his claim that he had o go see his sick father in Bremerton, Washington. That said defendant has not visited his father and not been in the State of Washington at any time during 1951, as plaintiff is informed and believes.

That plaintiff has received no support from defendant for herself or her two children since he deserted them in the month of September, 1945. That since the entry of her decree of divorce herein the plaintiff has never received from defendant any check or checks and has never returned any to him uncashed.

That there is now due and owing to the plaintiff from the defendant the monthly sums of $50.00 due on the 1st day of every month starting as of June 1st, 1947, plus 6% interest on each monthly installment of $50.00 from the respective time they became due, plus, the sum of $118.70 costs and disbursements together with 6% interest thereon since June 23rd, 1947.

That plaintiff should be allowed her costs and reasonable attorneys fee in connection with these proceedings.

That plaintiff is informed and believes that the defendant resides at No.911 West Douglas Avenue. Wichita, Kansas, a state which has adopted the Uniform Reciprocal Enforcement of Support Act, and that the District Court of the State of Kansas in and for Sedgewick County obtain jursidiction of the defendant or his property.

THEREFORE YOUR PETITIONER PRAYS that the Court determine that defendant owes a duty of support and that a Court of the State of Kansas may obtain jurisdiction of the defendant or his property and that the court make its certificate to that effect and court certified copies of this petition, the certificate and an authenticated copy of the Uniform Reciprocal Enforcement Act to be transmitted to the Kansas Court for action above.

Ronald Danielson
Counsel for Plaintiff


Polly Morton, being first duly sworn, on oath deposes and says: That she is the petitioner in the foregoing petition, that she has read said petition, knows the contents thereof and believes the same to be true, except as to those matters therein states on information and as to those matters she believes them to be true.

Subscribed and Sworn to before me July 25th, 1951
R.E. Danielson NOTARY PUBLIC in and for
The state of Washington, residing at