Scientology controversy

From Academic Kids

This article examines controversial issues involving Scientology and its affiliated organizations. For a fuller examination of Scientology, see the main article.

Scientologists draw a distinction between the Church of Scientology and the beliefs and rituals of Scientology, and point out that just as untoward behavior by the Vatican does not invalidate Catholic dogma, so allegations against managers of the Church should not taint the entire subject of Scientology. Indeed, there are those who practice a brand of Scientology entirely outside the Church of Scientology—they affiliate under the name Free Zone—although the Church considers this an illegal use of Scientology materials. In the case of Scientology, however, boundaries between the organization and the religion are often unclear. Some of the issues below relate to actions of Church leaders, some to L. Ron Hubbard's private behavior, and some to Hubbard's writings, which are the sacred texts of Scientology.

Related material is available in several other articles, including L. Ron Hubbard, Scientology beliefs and practices, Church of Scientology, and Scientology and the legal system.


Church of Scientology dealing with critics and perceived enemies

The Church of Scientology has a history of dealing forcefully with critics (which the organization calls "suppressive persons").

Alleged abuse of Copyright and Trademark laws

Unlike most other religious organizations, the Church of Scientology maintains strict control over the use of its symbols, names and religious texts. It claims copyright and trademark ownership over its "Scientology cross," and the church has taken legal action against individuals and organizations who have quoted short paragraphs of Scientology texts in print or on Web sites, in some cases asserting that their scriptures constitute "trade secrets." Individuals or groups who practice Scientology without formal affiliation with the Church of Scientology have been sued by the Church for violation of copyright and trademark law.

One example of alleged abuse of copyright law cited by critics of the Church is a 1995 lawsuit against the Washington Post, et al. The Religious Technology Center (RTC), the corporation that controls Hubbard's copyrighted materials, sued to prevent a Post reporter from describing the church teachings that were at the center of another lawsuit, claiming copyright infringement, trade secret misappropriation, and that the circulation of their "advanced technology" teachings would cause "devastating, cataclysmic spiritual harm" to those not properly prepared for them. In her judgement in favor of the Post, Judge Leonie Brinkema noted:

"When the RTC first approached the Court with its ex parte request for the seizure warrant and Temporary Restraining Order, the dispute was presented as a straight-forward one under copyright and trade secret law. However, the Court is now convinced that the primary motivation of RTC in suing Lerma, DGS and The Post is to stifle criticism of Scientology in general and to harass its critics. As the increasingly vitriolic rhetoric of its briefs and oral argument now demonstrates, the RTC appears far more concerned about criticism of Scientology than vindication of its secrets." -- U.S. District Judge Leonie Brinkema, Religious Technology Center v. Arnaldo Lerma, Washington Post, Mark Fisher, and Richard Leiby, 29 November 1995

"Attack the Attacker" and "Fair Game" policy

Scientology is reputed for its hostile actions towards anyone that criticizes it in a public forum; it has proclaimed that it is "not a turn-the-other-cheek religion." Journalists, politicians, aggreived former Scientologists and various anti-cult groups have made accusations of wrongdoing against Scientology since the 1970s, and almost without exception these critics have been targeted for retaliation by Scientology, in the form of lawsuits and counter-accusations of personal wrongdoing. Many of Scientology's critics have also reported they were subject to threats and harassment in their private life.

The organization's actions reflect a formal policy for dealing with criticism instituted by L. Ron Hubbard, called "attack the attacker." This policy was codified by Hubbard in the latter half of the 1960s, in response to government investigations into the organization. In 1966, Hubbard wrote a criticism of the organization's behavior and noted the "correct procedure" for attacking enemies of Scientology:

(1) Spot who is attacking us.
(2) Start investigating them promptly for FELONIES or worse using own professionals, not outside agencies.
(3) Double curve our reply by saying we welcome an investigation of them.
(4) Start feeding lurid, blood sex crime actual evidence on the attackers to the press.
Don't ever tamely submit to an investigation of us. Make it rough, rough on attackers all the way. You can get "reasonable about it" and lose Sure we break no laws. Sure we have nothing to hide. BUT attackers are simply an anti-Scientology propaganda agency so far as we are concerned They have proven they want no facts and will only lie no matter what they discover. So BANISH all ideas that any fair hearing is intended and start our attack with their first breath. Never wait Never talk about us - only them. Use their blood, sex, crime to get headlines. Don't use us. -- Attacks on Scientology, "Hubbard Communications Office Policy Letter," 25 February 1966 [1] (

The organization's tactics and methods for attacking its critics have remained largely unchanged since then. Hubbard detailed his rules for attacking critics in a number of policy letters, including one often quoted by critics as "the Fair Game policy," which allowed that "suppressive persons," (that is, those who had been declared enemies of the Church) "May be deprived of property or injured by any means... May be tricked, sued or lied to or destroyed." Scientologists sometimes claim that Hubbard canceled the Fair Game policy in 1968. What the "HCO Policy Letter of 21 October 1968" actually says, however, is "The practice of declaring people FAIR GAME will cease. FAIR GAME may not appear on any Ethics Order. It causes bad public relations. This P/L does not cancel any policy on the treatment or handling of an [suppressive person]."

Under pressure by seperate investigations into Scientology in England, New Zealand and Australia, and bad publicity in the press, Fair Game was publically cancelled in 1969. (HCOPL Mar 7, 1969)

However, in 1977, FBI raids on Scientology instigated because of Scientology GO (Guardian's Office) infiltration of various government agencies by Scientology, uncovered Guardians Office training materials, the GO "Hat Packs". The packs included numerous Hubbard HCOPLs and HCOBs that were considered policy for GO agents. These included the Mar 7 1965 HCOPL Fair Game policies alledgedly cancelled. This HCOPL was also "starrated", meaning GO agents were expected to pay particular attention to this HCOPL and to be drilled on it. Jane Kember and Mo Budlong, top GO officials did admit that in fact fair game was policy in the GO. (Us vs Kember, Budlong Sentencing Memorandum - Undated, 1981) Mary Sue Hubbard, Hubbard's wife ran the GO under Hubbard's supervision.

In separate cases in 1979 and 1984, attorneys for Scientology argued that the Fair Game policy was in fact a core belief of Scientology and as such deserved protection as religious expression.

A term defined by Hubbard and used frequently within Scientology is "dead agenting." Used as a verb, "dead agenting" is described by Hubbard as countering negative or false accusations against Scientology, by diverting the critical statements and making counter-accusations against the accuser (i.e. "attack the attacker"). Hubbard defined the PR (public relations) policy on "dead agenting" in a 1974 bulletin:

"The technique of proving utterances false is called "DEAD AGENTING". It's in the first book of Chinese espionage. When the enemy agent gives false data, those who believed him but now find it false kill him - or at least cease to believe him. So the PR slang for it is 'Dead Agenting.'" -- L. Ron Hubbard, Board Policy Letter, PR Series 24: Handling Hostile Contacts/Dead Agenting, May 30, 1974 [2] (

Critics of Scientology state that "dead agenting" is commonly used on the newsgroup alt.religion.scientology to discredit and slander them, and they define the term as "to spread malicious lies and rumors about Scientology critics or organization, in an attempt to so thoroughly discredit them that everyone concerned will be disgusted with them, and not listen to the information they have to give about the cult." [3] (

In the last decade, the Church has focused on critics who use the Internet as a forum. The Electronic Frontier Foundation maintains an archive ( of documents related to the church's efforts to interfere with online critics.

Allegations of criminal behavior

Much of the controversy surrounding Scientology is reflected in the long list of legal incidents associated with the organization, including the criminal conviction of core members of the Scientology organization.

In 1978, a number of Scientologists including L. Ron Hubbard's wife Mary Sue Hubbard (who was second in command in the organization at the time) were convicted of perpetrating the largest incident of domestic espionage in the history of the United States. Called "Operation Snow White" within the Church, this involved infiltrating, wiretapping, and stealing documents from the offices of Federal attorneys and the Internal Revenue Service. The judge who convicted Mrs. Hubbard and ten accomplices decried their attempt to plead freedom of religion in defense:

"It is interesting to note that the founder of their organization, unindicted co-conspirator L. Ron Hubbard, wrote in his dictionary entitled Modern Management Technology Defined ... that 'truth is what is true for you.' Thus, with the founder's blessings they could wantonly commit perjury as long as it was in the interest of Scientology.
The defendants rewarded criminal activities that ended in success and sternly rebuked those that failed. The standards of human conduct embodied in such practices represent no less than the absolute perversion of any known ethical value system.
In view of this, it defies the imagination that these defendants have the unmitigated audacity to seek to defend their actions in the name of 'religion.'
That these defendants now attempt to hide behind the sacred principles of freedom of religion, freedom of speech and the right to privacy -- which principles they repeatedly demonstrated a willingness to violate with impunity -- adds insult to the injuries which they have inflicted on every element of society." [4] (

Following this episode, offices of the church in Los Angeles, California and Washington, D.C. were searched by FBI agents and documents confiscated. Eleven church staff, including Mary Sue Hubbard and other highly placed officials, pleaded guilty or were convicted in federal court based on evidence seized in the raids, and received sentences from two to six years (some suspended).

There is disagreement over the extent to which the illegal activities had been sanctioned by the Church. The Church of Scientology claims that a "rogue" branch of the church was responsible, and that group was shut down when their abuses came to light, and responsible staff members were expelled or sanctioned. Some observers believe that the reorganization was simply an internal coup by one church faction to eliminate the power of a rival faction, which did nothing to change the Church's ethical standards. Former members allege that illegal operations were conducted after the arrests, even that they are ongoing today, a charge that is vigorously denied by the Church.

Other noteworthy incidents involving criminal accusations against the Church of Scientology include:

  • During the 1960s, Scientology was accused by the United States government of engaging in medical fraud by claiming that the E-meter would treat and cure physical ailments and diseases. A 1971 ruling of the United States District Court, District of Columbia (333 F. Supp. 357), specifically stated, "the E-meter has no proven usefulness in the diagnosis, treatment or prevention of any disease, nor is it medically or scientifically capable of improving any bodily function." As a result of this ruling, Scientology now publishes disclaimers in its books and publications declaring that the E-meter "does nothing," and that it is used specifically for spiritual purposes.
  • In 1978, L. Ron Hubbard was convicted in absentia by French authorities of engaging in fraud, and sentenced to four years in prison. Hubbard was not present at the trial in France, though the head of the French Church of Scientology was convicted at the same trial and given a suspended one-year prison sentence.
  • The FBI raid on the Church's headquarters revealed documentation that detailed Scientology actions against various critics of the organization. Among these documents was a plan to allegedly frame the mayor of the city of Clearwater, Florida; plans to discredit the skeptical organization CSICOP by spreading rumors that it was a front for the CIA; and a project called "Operation Freakout," aimed at ruining the life of author Paulette Cooper, author of an early book critical of the movement, The Scandal of Scientology.
  • In 1988 the government of Spain arrested Scientology president Heber Jentzsch and ten other members of the organization on various charges, including "illicit association," coercion, fraud, and labor law violations. Jentzsch left Spain and returned to the United States after Scientology paid a bail bond of approximately $1 million, and he has not returned the country since. Scientology fought the charges in court for fourteen years, until the case was finally dismissed in 2002.
  • The Church of Scientology is the only religious organization in Canada to be convicted on the charge of breaching the public trust: The Queen v. Church of Scientology of Toronto, et al. (1992)
  • In France, several officials of the Church of Scientology have been convicted of crimes such as embezzlement. The Church was listed as a "dangerous cult" in a parliamentary report.
  • The Church of Scientology long considered the Cult Awareness Network (CAN) as one of its most important enemies, and many Scientology publications during the 1980s and 1990s cast CAN (and its spokesperson at the time, Cynthia Kisser) in an unfriendly light, accusing the cult-watchdog organization of various criminal activities. After CAN was forced into bankruptcy and taken over by Scientologists in the late 1990s, Scientology proudly proclaimed this as one of its greatest victories. (Source: Scientology press release ( issued upon winning the CAN court battle and another view ( from the American Lawyer. June 1997.)

The Church of Scientology's replies to its critics

Scientology's response to accusations of criminal behavior has been twofold; the church is under attack by an organized conspiracy, and each of the church's critics is hiding a private criminal past. In the first instance, the Church of Scientology has repeatedly stated that it is engaged in an ongoing battle against a massive, worldwide conspiracy whose sole purpose is to "destroy the Scientology religion." Thus, aggressive measures and legal actions are the only way the church has been able to survive in a hostile environment; they sometimes liken themselves to the early Mormons who took up arms and organized militia to defend themselves from persecution.

The church asserts that the core of the organized anti-Scientology movement is the psychiatric profession, in league with deprogrammers and certain government bodies (including elements within the FBI and the government of Germany [5] ( These conspirators have allegedly attacked Scientology since the earliest days of the church, with the shared goal of creating a docile, mind controlled population. As an official Scientology website explains:

"To understand the forces ranged against L. Ron Hubbard, in this war he never started, it is necessary to gain a cursory glimpse of the old and venerable science of psychiatry-which was actually none of the aforementioned. As an institution, it dates back to shortly before the turn of the century; it is certainly not worthy of respect by reason of age or dignity; and it does not meet any known definition of a science, what with its hodgepodge of unproven theories that have never produced any result-except an ability to make the unmanageable and mutinous more docile and quiet, and turn the troubled into apathetic souls beyond the point of caring. That it promotes itself as a healing profession is a misrepresentation, to say the least. Its mission is to control."[6] (

On the other hand, L. Ron Hubbard proclaimed that the only reason anyone would attack Scientology is because that person or entity is a "criminal." Hubbard wrote on numerous occasions that all of Scientology's opponents are seeking to hide their own criminal histories, and the proper course of action to stop these attacks is to "expose" the hidden crimes of the attackers. The Church of Scientology does not deny that it vigorously seeks to "expose" its critics and enemies; it maintains that all of its critics have criminal histories, and they encourage hatred and "bigotry" against Scientology. Hubbard's belief that all critics of Scientology are criminals was summarized in a policy letter written in 1967:

Now get this as a technical fact, not a hopeful idea. Every time we have investigated the background of a critic of Scientology we have found crimes for which that person or group could be imprisoned under existing law. We do not find critics of Scientology who do not have criminal pasts. Over and over we prove this. -- Critics of Scientology, "Hubbard Communications Office Policy Letter," 5 November 1967 [7] (

Scientology claims that it continues to expand and prosper despite all efforts to prevent it from growing; critics claim that the Church's own statistics contradict its story of continuing growth [8] (

The Church of Scientology has published a number of responses to criticism, including *Those Who Oppose Scientology (, available online.

Analyses of Scientology's counter-accusations and actions against its critics are available on a number of websites, including the critical archive Operation Clambake.

Allegations of mistreatment of members

Lisa McPherson and the "Introspection Rundown"

For more details, see: Lisa McPherson, Introspection Rundown

Over the years, the Church of Scientology has been accused of culpability in the death of several of its members (

The most widely publicized such case involved the death of 36-year-old Lisa McPherson, while in the care of scientologists at the Scientology-owned Fort Harrison Hotel, in Clearwater, Florida. Having experienced symptoms usually associated with mental illness (such as removing all of her clothes at the scene of a minor traffic accident), the Church intervened to prevent McPherson from receiving psychiatric treatment, and to return her to the custody of the Church of Scientology. Records show that she was then placed in isolation as part of a Scientology program known as the Introspection Rundown. Days later, she was pronounced dead on arrival at a local hospital, exhibiting signs of severe dehydration.

Criminal charges were filed against the Church of Scientology by Florida authorities. The Church of Scientology denied any responsibility for McPhearson's death and they vigorously contested the charges; the prosecuting attorneys ultimately dropped the criminal case. After four years, a $100 million civil lawsuit filed by Lisa McPherson's family was settled in 2004. The terms of the settlement were sealed by the court.


The Church of Scientology is frequently accused by critics of employing brainwashing and intimidation tactics to influence "public" members to donate large amounts of money, and to force "staff" and "Sea Org" members to submit completely to the organization. Time magazine published a cover story in 1991, "The Thriving Cult of Greed and Power" (, that supported such charges. (The Church of Scientology launched an extensive campaign in response to the article, asserting that Time was going after Scientology at the behest of their advertiser Eli Lilly, the manufacturer of psychiatric drugs.)

One alleged example of the Church's brainwashing tactics is the Rehabilitation Project Force, to which church staff are assigned to work off alleged wrongdoings under conditions that many critics characterize as degrading. Some of these allegations are presented in Stephen Kent's Brainwashing in Scientology's Rehabilitation Project Force (RPF) ( Articles that rebut those charges include Juha Pentikäinen's The Church of Scientology's Rehabilitation Project Force ( and J. Gordon Melton's A Contemporary Ordered Religious Community: The Sea Organization (


The Church of Scientology has been criticized for their practice of "disconnection," in which Scientologists are directed to sever all contact with family members or friends who criticize the faith. Critics, including ex-members and relatives of existing members, attest that this practice has divided many families. [9] (

The disconnection policy is claimed by critics to be further evidence that the Church is a cult. By making its members entirely dependent upon a social network entirely within the organization, critics assert, Scientologists are not merely kept from exposure to critical perspectives on the church, they are also put in a situation that makes it extremely difficult for members to leave the church, since apostates will be shunned by their entire universe of family and friends.

The Church of Scientology acknowledges that its members are strongly discouraged from associating with "enemies of Scientology", and likens the disconnection policy to the practice of shunning in other religions, including the Jehovah's Witnesses and the Amish.

The legitimacy of Scientology as a religion

The nature of Scientology is hotly debated in many countries. The Church of Scientology pursues an extensive public relations campaign arguing that Scientology is a bona fide religion. The organization cites a number of studies and experts who support their position, many of which can be found at the Web site ( Critics contend that most cited studies were commissioned by Scientology to produce the desired results.

Many governments (including Belgium, Russia, Greece, France, and Spain) reject the Church of Scientology's claims to be a legitimate religious organization; it has been variously judged to be a commercial enterprise or a dangerous cult (see the list of alleged cults).

Scientology is, however, legally accepted as a religion in the United States and Australia, and enjoys the constitutional protections afforded to religious practice in each country. In October of 1993 the U.S Internal Revenue Service recognized ( the Church as an "organization operated exclusively for religious and charitable purposes." The Church offers the tax exemption as proof that it is a religion. (This subject is examined in the Wikipedia article on the Church of Scientology).

In 1982, the High Court of Australia ruled that the State Government of Victoria lacked the right to declare that the Church of Scientology was not a religion (Church of the New Faith v. Commissioner Of Pay-roll Tax (Vict.) 1983, 154 CLR 120 ( The Court found the issue of belief to be the central feature of religion, regardless of the presence of charlatanism: "Charlatanism is a necessary price of religious freedom, and if a self-proclaimed teacher persuades others to believe in a religion which he propounds, lack of sincerity or integrity on his part is not incompatible with the religious character of the beliefs, practices and observances accepted by his followers."'

The country to take the strongest stance against the organization is Germany. The Church of Scientology has waged a far-reaching public relations campaign to convince the world that Scientologists are persecuted regularly in Germany, in the same fashion that Jews were persecuted by the Nazis during the Holocaust. The Church of Scientology has taken out full-page ads in the New York Times accusing the German government of persecuting Scientologists in Europe; while they have made repeated requests to the United Nations to have resolutions passed condemning the discrimination against Scientologists in Germany. Germany, in turn, classifies the Church Scientology as a dangerous practice and a "sect," and it has placed the organization under surveillance for alleged criminal activities.

Critics also allege that L. Ron Hubbard's Dianetics research was largely inspired by the achievements of other mental researchers such as Freud and William Sargant; the Church of Scientology maintains that Hubbard's work was entirely original and derived from no preexisting practice.

L. Ron Hubbard and starting a religion for money

While the often-cited rumor that Hubbard made a bar bet with Robert Heinlein that he could start a cult is almost certainly false, others have claimed direct knowledge that during 1949 Hubbard did make statements to other people that starting a religion would be a good way to make money.

Writer and publisher Lloyd Arthur Eshbach, for example, reported Hubbard saying "I'd like to start a religion. That's where the money is." Writer Theodore Sturgeon reported that Hubbard made a similar statement at the Los Angeles Science Fantasy Society. Likewise did writer Sam Moskowitz reported in an affidavit ( that during an Eastern Science Fiction Association meeting, Hubbard had said "You don't get rich writing science fiction. If you want to get rich, you start a religion."

The Church of Scientology denies that Hubbard ever made any such statement, and has sued at least one publisher, the German magazine Stern, for publishing claims that he did (Stern won the lawsuit). Members hold that the truth or falsity of such claims is irrelevant in judging whether the church meets their spiritual needs.

The following letter, written by L. Ron Hubbard, was discovered by the FBI during its raid on Scientology headquarters. The letter shows Hubbard turned Scientology into a "religion" for financial reasons:





The arrangements that have been made seem a good temporary measure. On a longer look, however, something more equitable will have to be organized. I am not quite sure what we would call the place - probably not a clinic - but I am sure that it ought to be a company, independent of the HAS but fed by the HAS. We don't want a clinic. We want one in operation but not in name. Perhaps we could call it a Spiritual Guidance Center. Think up its name, will you. And we could put in nice desks and our boys in neat blue with diplomas on the walls and 1. knock psychotherapy into history and 2. make enough money to shine up my operating scope and 3. keep the HAS solvent. It is a problem of practical business. I await your reaction on the religion angle. In my opinion, we couldn't get worse public opinion than we have had or have less customers with what we've got to sell. A religious charter would be necessary in Pennsylvania or NJ to make it stick. But I sure could make it stick. We're treating the present time beingness, psychotherapy treats the past and the brain. And brother, that's religion, not mental science.

Best Regards,


An article of Prof. Benjamin Beit-Hallami documents the secular aspects of Scientology from Scientology's own writings. Marburg Journal of Religion - Scientology: Religion or Racket? (


The following is a selection of quotations from L. Ron Hubbard that are frequently cited by critics of Scientology as proof of the organization's alleged hypocrisy and true intent. While not denying Hubbard as the true author of these quotes, the Church of Scientology vehemently insists these quotes are being taken out of context, and that critics are misstating their actual intent. Critics, however, note that Scientology has been reluctant to explain these quotes in a manner so that they are not taken out of context.

"Somebody some day will say 'this is illegal'. By then be sure the orgs say what is legal or not." -- L. Ron Hubbard, Hubbard Communications Office Policy Letter, 4 January 1966
"Don't ever tamely submit to an investigation of us. Make it rough, rough on attackers all the way." -- L. Ron Hubbard, Hubbard Communications Office Policy Letter, 25 February 1966
"Having viewed slum clearance projects in most major cities of the world may I state that you have conceived and created in the Johannesburg townships what is probably the most impressive and adequate resettlement activity in existence." -- L. Ron Hubbard, Letter to South African Apartheid Government, 1960
"THE ONLY WAY YOU CAN CONTROL PEOPLE IS TO LIE TO THEM. You can write that down in your book in great big letters. The only way you can control anybody is to lie to them." -- L. Ron Hubbard, Technique 88
"They smell of all the baths they didn't take. The trouble with China is, there are too many chinks here." -- L. Ron Hubbard (Diary entry circa 1928)
"If anyone is getting industrious trying to enturbulate [sic] or stop Scientology or its activities, I can make Captain Bligh look like a Sunday-school teacher. There is probably no limit on what I would do to safeguard Man's only road to freedom against persons who ... seek to stop Scientology or hurt Scientologists." -- L. Ron Hubbard, 15 August 1967
"People attack Scientology; I never forget it, always even the score. People attack auditors, or staff, or organisations, or me. I never forget until the slate is clear." -- L. Ron Hubbard, The Manual of Justice
"So we listen. We add up associations of people with people. When a push against Scientology starts somewhere, we go over the people involved and weed them out. Push vanishes." -- L. Ron Hubbard, The Manual of Justice
"At this instance there are men hiding in terror on Earth because they found out what they were attacking. There are men dead because they attacked us - for instance Dr. Joe Winter. He simply realized what he did and died. There are men bankrupt because they attacked us - Purcell, Ridgway, Ceppos." -- L. Ron Hubbard
(Dr. Joe Winter was a board member of the Hubbard Dianetic Research Foundation, but he broke with Hubbard over the use of "past lives" to explain engrams. Don Purcell, Derricke Ridgway and Art Ceppos were former supporters of Hubbard who also broke with him. One explanation offered for the context of this quotation is that Hubbard meant that the expansion of Scientology would save lives; Scientologists believe they are responsible for disasters because they did not disseminate their technology well enough.)
"Bluntly, we are out to replace medicine in the next three years." -- Hubbard College Reports, 13 March 1952

External links

  • Scientology's "Fair Game" Policy ( (Google search regarding controversial Scientology policy)
  • "Operation Clambake" ( (a comprehensive archive of critical material on Scientology )
  • Those Who Oppose Scientology ( (Scientology's response to its critics)
  • Religious Freedom Watch ( Scientologist-run web site attacking critics of Scientology
  • The Fishman Affidavit ( The case file for Church of Scientology International v. Fishman and Geertz
  • ( What's Wrong with Scientology
  • Bigot Flier ( Libellous Flier Distributed by Scientology


  • Brinkema, Leonie M. Civil Action No. 95-1107-A: Memorandum Opinion, (Alexandria:US District Court for the Eastern District of Virginia—Alexandria Division, November 28 1995)
  • Hubbard, L. Ron. Attacks on Scientology, "Hubbard Communications Office Policy Letter," February 25, 1966
  • All England Law Reports (London: Butterworths,1979), vol. 3 p. 97
  • Transcript of judgement in B & G (Minors) (Custody) Delivered in the High Court(Family Division),

London, 23 July 1984.


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