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{{Short description|Actions of the Church of Scientology towards perceived enemies}} | |||
'''Fair Game''' is a status assigned to those whom the ] has officially declared to be '']s'' or ''SPs.'' "Suppressive Persons" are those whose actions are deemed to "suppress or damage Scientology or a Scientologist." Often, this means they have been overtly critical of the church. | |||
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The term '''fair game''' is used to describe policies and practices carried out by the ] towards people and groups it perceives as its enemies. Founder of ] ] established the policy in the 1950s in response to criticism both from within and outside his organization.<ref name="urban2006" /><ref name="urban2008">{{cite journal|last=Urban|first=Hugh B.|author-link=Hugh Urban|year=2008|title=Secrecy and New Religious Movements: Concealment, Surveillance, and Privacy in a New Age of Information|journal=Religion Compass|publisher=Wiley |volume=2|issue=1|pages=66–83|issn=1749-8171|doi=10.1111/j.1749-8171.2007.00052.x}}</ref> Individuals or groups who are "fair game" are judged to be a threat to the Church and, according to the policy, can be punished and harassed using any and all means possible.<ref name="urban2006" /><ref name="urban2008" />{{r|streeter|pp=217–219}} In 1968, Hubbard officially canceled use of the term "fair game" because of negative public relations it caused, although the Church's aggressive response to criticism continued.<ref name="urban2006" /> | |||
], founder of Scientology, formulated "The Fair Game Law" in a 1965 policy letter: "A Suppressive Person or Group becomes 'fair game.'" In a subsequent policy statement, Hubbard wrote that a person deemed "Fair Game" "may be deprived of property or injured by any means by any Scientologist without any discipline of the Scientologist. May be tricked, sued or lied to or destroyed." | |||
Applying the principles of "fair game", Hubbard and his followers targeted many individuals as well as government officials and agencies, including a ] of the ] (IRS) and other ] agencies during the 1970s.<ref name="urban2006" /><ref name="urban2008" /> They also conducted ], ] and ] against the Church's critics in the media.<ref name="urban2006" /> The policy remains in effect and has been defended by the Church of Scientology as a core religious practice.<ref name="wollersheim212calapp3d872" /><ref name="flinnp4032" /><ref name="wollersheimb023193" /> | |||
The ] consistently maintains that the Fair Game policy was rescinded in ]. However, critics offer considerable evidence it has effectively remained in force in subsequent decades, and has been applied to attack many non-Scientologists. "Fair Game" is often cited by journalists as one basis for Scientology's alleged pattern of harassing critics. | |||
Starting in the 1980s, for their major branch in Los Angeles, California, the Scientology organization largely switched from using church members in harassment campaigns to hiring private investigators, including former and current ]. The reason seemed to be that this gave the Church of Scientology a layer of protection in case embarrassing tactics were used and made public.<ref name="On the Offensive">{{Cite news |url=https://www.latimes.com/local/la-scientology062990x-story.html#page=1 |url-status=live |archive-url=https://web.archive.org/web/20150331141312/https://www.latimes.com/local/la-scientology062990x-story.html#page=1 |archive-date=March 31, 2015 |title=On the Offensive Against an Array of Suspected Foes |newspaper=] |first1=Joel |last1=Sappell |first2=Robert W. |last2=Welkes |page=A1 |date=June 29, 1990 |quote=Church spokesmen maintain that Hubbard rescinded the policy three years after it was written{{nbsp}} But various judges and juries have concluded that while the actual labelling of persons as 'fair game' was abandoned, the harassment continued unabated.}}</ref> | |||
==The "Fair Game Law," 1965== | |||
==Background== | |||
The ''Fair Game Law'' was introduced by L. Ron Hubbard in a 1965 '''Hubbard Communications Office Policy Letter''' (HCOPL) in March, 1965: | |||
]'s founder, ], said all opposition came from what he called "]s" (SPs) – which Scientologists claim are "anti-social people who want to destroy anything that benefits humanity."{{r|streeter|pp=217–219}} In written policies dating from the mid-1950s, Hubbard told his followers to take a hard line against perceived opponents. In 1955 he wrote, "The purpose of the suit is to harass and discourage rather than to win. The law can be used easily to harass, and enough harassment on somebody who is simply on the thin edge anyway, well knowing that he is not authorized, will generally be sufficient to cause his professional decease. If possible, of course, ruin him utterly".<ref>Hubbard, L. R. (1955). ''The Scientologist - A Manual on the Dissemination of Material'', reprinted in {{cite book|last=Hubbard|first=L. R.|title=The Technical Bulletins of Dianetics and Scientology|publisher=Scientology Publications|location=Copenhagen|year=1976|volume=II|isbn=0-685-04188-3}} Quoted in {{cite web|last1=Lane|first1=Jodi M.|first2=Stephen A. |last2=Kent|date=January 30, 2008|title=Malignant Narcissism, L. Ron Hubbard, and Scientology's Policies of Narcissistic Rage|page=24|url=http://www.arts.ualberta.ca/~skent/Linkedfiles/Lane-Kent_HubbardsNarcissism_EN_December08-2008.pdf|access-date=December 5, 2009}}, published in French as {{cite journal|last1=Lane|first1=Jodi M.|first2=Stephen A. |last2=Kent|year=2008|title=Politiques de rage et narcissisme malin|journal=Criminologie|volume=41|issue=2|pages=117–155|issn=1492-1367|publisher=Les Presses de l'Université de Montréal|doi=10.7202/019435ar|doi-access=free}}</ref> | |||
In his confidential ''Manual of Justice'' of 1959, Hubbard wrote "People attack Scientology. I never forget it, always even the score."<ref name="urban2006" /> He advocated using ]s to investigate critics, who had turned out to be "members of the ] Party or criminals, usually both. The smell of police or private detectives caused them to fly, to close down, to confess. Hire them and damn the cost when you need to."{{r|atack|page=144}} He said that in dealing with opponents, his followers should "always find or manufacture enough threat against them to cause them to sue for peace. Don't ever defend. Always attack."<ref name="stout">{{cite book|last=Kent|first=Stephen A.|title=Encyclopedia of religion, communication, and media|editor=Daniel A. Stout|publisher=CRC Press|year=2006|series=Routledge encyclopedias of religion and society|pages=390–392|chapter=Scientology|isbn=978-0-415-96946-8}}</ref> He urged the use of "]" to "destroy reputation or public belief in persons, companies or nations."<ref name="stout" /> | |||
:A ] or GROUP is one that actively seeks to suppress or damage Scientology or a Scientologist by Suppressive Acts... A Suppressive Person or Group becomes "fair game". By FAIR GAME is meant, may not be further protected by the codes and disciplines or the rights of a Scientologist. (source: HCOPL 7 Mar 65 Issue 1, ''Suppressive Acts - Suppression of Scientology and Scientologists - The Fair Game Law'') | |||
The Church of Scientology has retained an aggressive policy towards those it perceives as its enemies,<ref>{{cite book|last=Melton|first=J. Gordon|title=The Church of Scientology|publisher=] in cooperation with ]|year=2000|series=Studies in contemporary religions|page=|isbn=1-56085-139-2|url=https://archive.org/details/churchofscientol00meltrich/page/36}}</ref><ref name=Ultra>{{cite web |first=Douglas |last=Frantz |title=An Ultra-Aggressive Use of Investigators and the Courts |url=https://www.nytimes.com/1997/03/09/us/an-ultra-aggressive-use-of-investigators-and-the-courts.html |website=] |date=March 9, 1997 |url-access=subscription |archive-url=https://web.archive.org/web/20210308060210/https://www.nytimes.com/1997/03/09/us/an-ultra-aggressive-use-of-investigators-and-the-courts.html |archive-date=March 8, 2021 | access-date = April 1, 2008 }}</ref> and argued as late as 1985 that retributive action against "enemies of Scientology" should be considered a ]ally-protected "core practice" of Scientology.<ref>, Court of Appeal of the State of California, civ.no.B023193, July 18, 1989 ()</ref> | |||
Later that year, Hubbard would publish a new policy letter, HCOPL 23 December 1965: | |||
==Policy== | |||
: HCO POLICY LETTER OF 23 DECEMBER 1965 (Replaces HCO Policy | |||
In 1965, Hubbard formulated the "'''Fair Game Law'''", which states how to deal with people who interfere with Scientology's activities. These ] could be considered "fair game" for retaliation: | |||
:Letter of 7 March 1965, Issue I. ....) | |||
{{blockquote|text=By FAIR GAME is meant, may not be further protected by the codes and disciplines or the rights of a Scientologist.|author=L. Ron Hubbard |source=HCOPL 1 Mar 65 Suppressive Acts – Suppression of Scientology and Scientologists – The Fair Game Law<ref name="fgl"/>}} | |||
: ETHICS SUPPRESSIVE ACTS SUPPRESSION OF SCIENTOLOGY AND | |||
: SCIENTOLOGISTS THE FAIR GAME LAW | |||
: ... | |||
In other words, a person who attacked the Church would not be protected by the Church or granted the rights of Scientologists in good standing. | |||
: A SUPPRESSIVE PERSON or GROUP is one that actively seeks to | |||
: suppress or damage Scientology or a Scientologist by Suppressive | |||
: Acts. | |||
In December of that year, Hubbard reissued the policy with additional clarifications to define the scope of fair game. He made it clear that the policy applied to non-Scientologists as well, declaring: | |||
: SUPPRESSIVE ACTS are acts calculated to impede or destroy | |||
: Scientology or a Scientologist and which are listed at length in | |||
: this policy letter. | |||
: ... | |||
: A Suppressive Person or Group becomes "fair game". | |||
: | |||
: By FAIR GAME is meant, may not be further protected by the codes | |||
: and disciplines of Scientology or the rights of a Scientologist. | |||
: .... | |||
: The homes, property, places and abodes of persons who have been | |||
: active in attempting to suppress Scientology or Scientologists are | |||
: all beyond any protection of Scientology Ethics, unless absolved by | |||
: later Ethics or an amnesty. | |||
: .... | |||
{{blockquote|text=The homes, property, places and abodes of persons who have been active in attempting to: suppress Scientology or Scientologists are all beyond any protection of ], unless absolved by later Ethics or an amnesty{{nbsp}} his Policy Letter extends to suppressive non-Scientology wives and husbands and parents, or other family members or hostile groups or even close friends.|author=L. Ron Hubbard |source=HCOPL 23 Dec 65, Suppressive Acts – Suppression of Scientology and Scientologists – The Fair Game Law<ref name="fgl">{{cite web |url=http://www.planetkc.com/sloth/sci/sp_rules.html |title=HCOPL 23 Dec 1965, Suppressive Acts – Suppression of Scientology and Scientologists – The Fair Game Law |date=23 December 1965 |url-status=dead |archive-url=https://web.archive.org/web/20060614180458/http://www.planetkc.com/sloth/sci/sp_rules.html |archive-date=14 June 2006 }}</ref>}} | |||
This 23 December HCOPL was reprinted in OECs (Organizational Executive | |||
course), an official Scientology collections of HCOPLs, the "PTS-SP" | |||
course materials, GO agent training packs, and many other materials well | |||
into the 90s. For example it was found as an item to be studied in 1991 | |||
OSA "hat packs". | |||
In his ''Introduction to Scientology Ethics'', published in 1968, Hubbard wrote that no Scientologist could be punished "for any action taken against a suppressive person or Group during the period that person or group is 'fair game'."<ref name="urban2006" />{{r|lord}} | |||
HCO PL 18 Oct 67 Issue IV, ''Penalties for Lower Conditions'', extends the policy: | |||
He made it clear elsewhere in his writings that the policy would be applied to external organizations, including governments, that interfered with Scientology's activities. He told Scientologists: | |||
:ENEMY — SP Order. Fair game. May be deprived of property or injured by any means by any Scientologist without any discipline of the Scientologist. May be tricked, sued or lied to or destroyed." | |||
{{blockquote|text=If the ] (in refusing the ] non-profit status) continues to act up or if the ] does sue we can of course ] them and if found guilty, label and publish them as a Suppressive Group and fair game{{nbsp}} one is fair game until he or she declares against us. |author=L. Ron Hubbard |source=HCOPL 2 Apr 65, Administration outside Scientology }} | |||
==Cancellation and controversy== | |||
In a 1967 policy titled ''Penalties for Lower Conditions'', Hubbard wrote that opponents who are "fair game" may be "deprived of property or injured by any means by any Scientologist without any discipline of the Scientologist. May be tricked, sued or lied to or destroyed."<ref name="urban2006">{{cite journal|last=Urban|first=Hugh B.|author-link=Hugh Urban|date=June 2006|title=Fair Game: Secrecy, Security, and the Church of Scientology in Cold War America|journal=Journal of the American Academy of Religion|publisher=Oxford University Press|volume=74|issue=2|pages=356–389|issn=1477-4585|doi=10.1093/jaarel/lfj084|s2cid=143313978}}</ref><ref name="Allard1974">{{cite news|title=Sect ordered to pay $300,000 to victim|date=June 1, 1974|work=Los Angeles Times|pages=A20}}</ref><ref name="wallis" /><ref>HCOPL October 18, 67 Issue IV, ''Penalties for Lower Conditions''</ref><ref>{{cite book |last1=Sandberg |first1=Russell |url=https://books.google.com/books?id=VJe1CwAAQBAJ&q=scientology&pg=PT163 |title=Religion and Legal Pluralism Ashgate AHRC/ESRC Religion and Society Series |isbn=9781317068013 |access-date=June 23, 2016 |date=March 9, 2016 |publisher=Routledge }}</ref> | |||
Hubbard's "Fair Game" policy soon gained notoriety in the British press, and even received mention in Parliament. As a result, Hubbard issued a policy letter in 1968 entitled '"Cancellation of Fair Game": | |||
In a policy letter dated July 21, 1968, Hubbard explicitly cancelled these penalties. The new list of ''Penalties for Lower Conditions'' now said that someone in a condition of ''Enemy'' "(m)ay be restrained or imprisoned. May not be protected by any rules or laws of the group he sought to injure.{{nbsp}} May not be trained or processed or admitted to any .{{r|foster|p=128}} The same list says that in a condition of ''Treason'', a person, "May not be protected by the rights and fair practices he sought to destroy for others. May be retrained or debarred.{{nbsp}} Not covered by amnesties." Another policy letter from October that year announces: | |||
: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 SP. (HCO PL 21 Oct 68, ''Cancellation of Fair Game") | |||
{{blockquote|text=The practice of declaring people FAIR GAME will cease. FAIR GAME may not appear on any Ethics Order. It causes bad public relations. This does not cancel any policy on the treatment or handling of an SP.|author=L. Ron Hubbard|source=HCOPL 21 Oct 68, Cancellation of Fair Game<ref name="wallis" />{{r|foster|p=129}}{{r|atack|page=188}}}} | |||
Although this and subsequent policy letters publicly cancelled use of the phrase "Fair Game" and its practice outside of Scientology, confidential policy letters of the time show the previously expressed attitude remained in place. In fact, in the OEC volumes collecting official policy letters, HCOPL 21 October 1968 was attached as an addendum | |||
to HCOPL 23 December 1965, making plain that this HCOPL, "ETHICS SUPPRESSIVE ACTS SUPPRESSION OF SCIENTOLOGY AND SCIENTOLOGISTS THE FAIR GAME LAW" was the policy that was | |||
not to be cancelled as active policy on "treatment or handling of an SP". | |||
] have maintained that the fair game policy was rescinded in 1968 because people had misinterpreted it. Spokesmen said that Hubbard's intended meaning was merely that former members could not appeal to Scientology's legal system for support or protection against anyone who might try to trick, sue or destroy them.{{r|streeter|pp=217–219}}<ref name="On the Offensive"/><ref name="greenawalt" /> Sociologist ] commented that this interpretation seemed to be "contradicted by the words on the page, and by actions taken against those regarded as enemies of the movement."<ref name="wallis">{{cite book|last=Wallis|first=Roy|title=The Road to Total Freedom: A Sociological Analysis of Scientology|publisher=Heinemann Educational Books|location=London|year=1976|pages=144–145|isbn=0-435-82916-5|oclc=310565311|title-link=The Road to Total Freedom: A Sociological Analysis of Scientology}}</ref> | |||
Fair game concepts continued to be found in other HCOPLs. For example, in HCOPL 16 Feb 69 Issue II, ''Battle tactics'', Hubbard states: "One cuts off enemy communications, funds, connections. He deprives the enemy of political advantages, connections and power. He takes over enemy territory. He raids and harasses. All on a thought plane - press, public opinion, governments, etc. Seeing it as a battle, one can apply battle tactics to thought actions. ... Never treat a war like a skirmish. Treat all skirmishes like wars." | |||
The Church continued to pursue an aggressive response to external critics, especially the U.S. Government.<ref name="urban2006" /> The doctrine of "fair game" was a central element of the ]'s operational policies. The original 1965 "Fair Game Law" is listed as a reference for GO staff in its confidential ''Intelligence Course'',<ref>Guardian Order, ''Confidential – Intelligence Course'', September 9, 1974, p.18</ref> which was later entered into evidence in a U.S. federal court case in 1979.<ref>''United States vs. Mary Sue Hubbard et al.'', 493 F. Supp. 209, (D.D.C. 1979)</ref> During the case, Church lawyers admitted that "fair game" had been practiced long after its supposed cancellation in 1968. | |||
L. Ron Hubbard EXECUTIVE DIRECTIVE 2 December 1966, the "CONFIDENTIAL" "PROJECT SQUIRREL" states: | |||
: ... | |||
: (a) People who attack Scientology are criminals. | |||
: (b) That if one attacks Scientology he gets investigated for crimes. | |||
: (c) If one does not attack Scientology, despite not being | |||
:: with it, one is safe. | |||
: ... | |||
Hubbard said in a 1976 affidavit that he had never intended to authorize harassment: | |||
Other similar documents that paralleled and reinforced "fair game" policies included HCOPL 15 February 1966, Attacks on Scientology, the 18 February Attacks on Scientology continued, HCOPL 17 February 1966, Public Investigations, HCOPL 15 Aug, 1960, Department of Government affairs and others. | |||
{{blockquote|text=There was never any attempt or intent on my part by the writing of these policies (or any others for that fact), to authorise illegal or harassment type acts against anyone. | |||
: HCO POLICY LETTER OF 15 FEBRUARY 1966 | |||
: ... | |||
: ATTACKS ON SCIENTOLOGY (Additional Pol Ltr) | |||
: ... | |||
: This is correct procedure: | |||
: (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. | |||
As soon as it became apparent to me that the concept of 'fair game' as described above was being misinterpreted by the uninformed, to mean the granting of a license to Scientologists for acts in violation of the law and/or other standards of decency, these policies were cancelled. |author=L. Ron Hubbard |source=Affidavit of March 22, 1976<ref>{{cite book|last=Barrett|first=David V.|title=The New Believers: A Survey of Sects, Cults and Alternative Religions|publisher=Octopus Publishing Group|year=2003|page=464|isbn=1-84403-040-7|oclc=59368351}})</ref>}} | |||
In 1977, after Scientologists had been discovered infiltrating government offices and stealing documents (as part of ]), the FBI raided Scientology headquarters in Los Angeles and Washington DC. Scientology records seized in those raids revealed that Hubbard had set up a division in 1966 called the ] (GO) that gathered intelligence on and harassed percieved enemies of the organization. Among the items seized were 1974 GO agent "Hat Packs", the training materials for GO agents. Included there for study was the original 7 Mar 1965 HCOPL, "Fair Game." This HCOPL was marked "starrated," meaning that GO agents were expected to memorize and be drilled on that particular policy. | |||
As revised in 1991, Scientology's policy on the handling of "suppressive persons" states: | |||
Eleven Scientologists eventually plead guilty to the theft of government documents, including ], Hubbard's wife, who was head of the Guardian's Office. L. Ron Hubbard was named an un-indicted co-conspirator. Two GO officials, Jane Kember and Mo Budlong, admitted through their lawyer that "Fair Game" policy was practiced in the GO. | |||
{{blockquote|text=Nothing in this policy letter shall ever or under any circumstances justify any violation of the laws of the land or intentional legal wrongs. Any such offense shall subject the offender to penalties prescribed by law as well as to ethics and justice actions. |author=L. Ron Hubbard |source=HCOPL 23 Dec 65RB, rev. 9 Jan 91, Suppressive Acts Suppression of Scientology and Scientologists}} | |||
== Examples of Fair Game == | |||
==In practice== | |||
=== Paulette Cooper and "Operation Freakout"=== | |||
An "Ethics Order" dating from March 6, 1968, issued by L. Ron Hubbard aboard his boat the '']'', lists twelve Scientologists who were accused of distributing altered versions of upper level materials. Hubbard writes "They are fair game. No amnesty may ever cover them.{{nbsp}} Any Sea Org member contacting them is to use ]."<ref>{{cite web | author=L. Ron Hubbard | title=HCO Ethics Order – Subject: Racket Exposed | date= June 3, 1968 | version=No. 30 INT | publisher = Advanced Organisation Yacht Royal Scotman, via U.S. Dist. Court. S.D. of N.Y. | url=http://www.gerryarmstrong.org/50grand/cult/hco-ethics-order-30.html | access-date=June 7, 2006}}</ref><ref>{{cite journal |first=L. Ron |last=Hubbard |title=Racket Exposed |journal=The Auditor |issue=37 |year=1968 |url=http://www.gerryarmstrong.org/50grand/cult/auditor37.html}}</ref> The R2-45 Auditing Process consists of shooting a person with the intent to kill them.<ref name="Allard1978"/><ref name="ReligionInc">{{cite book | first=Stewart | last=Lamont | title=Religion Inc. | publisher=Harrap Ltd | location=London | year=1986 | chapter=1. L. Ron Hubbard: Guru, God or Demon? | chapter-url=https://www.cs.cmu.edu/~dst/Library/Shelf/lamont/guru.htm | isbn=0-245-54334-1 | page=192| title-link=Religion Inc. }}</ref> | |||
It later emerged that "fair game" had actually continued in use until at least 1980, despite its cancellation, and there have been frequent allegations that it has remained in force since then. During the 1970s the Guardian's Office (GO) of the Church of Scientology, headed by Hubbard's wife ], conducted a wide-ranging and systematic series of espionage and intimidation operations against perceived enemies of Scientology. (See ] for a noteworthy example.) | |||
] is a New York-based freelance journalist. Cooper wrote a critical article on Scientology in the British ''Queen'' Magazine (now ''Harpers Queen'') in 1969 . In 1971 she published a book, "The Scandal of Scientology". . | |||
According to an '']'' investigation, "fair game" tactics had been used to force the withdrawal of the presiding judge in an attempt to "throw" the case.<ref>"", ''American Lawyer'', December 1980</ref> As the US Government's attorneys put it: | |||
In 1973 Cooper was indicted by a US federal jury for bomb threats against Scientology offices and for perjury, and she underwent a year of psychiatric treatment as a condition of her negotiations with the US Attorney. | |||
{{blockquote |text=Defendants, through one of their attorneys, have stated that the fair game policy continued in effect well after the indictment in this case and the conviction of the first nine co-defendants. Defendants claim that the policy was abrogated by the Church's Board of Directors in late July or early August, 1980, only after the defendants' personal attack on ]. |source=1979 sentencing memorandum, Mary Sue Hubbard et al.<ref>{{cite web |url=https://www.mikerindersblog.org/wp-content/uploads/2023/03/USA-V-MSH-SENTENCING-MEMO.pdf |title=Sentencing Memorandum of the United States of America, Mary Sue Hubbard et al., Criminal Case No. 78-401 |date=3 December 1979}}</ref> }} | |||
In 1977 the FBI found Church of Scientology documents containing a precise plan to frame Cooper for bomb threats in order to get her "incarcerated in a mental institution or jail or at least to hit her so hard that she drops her attacks." . The plan was dubbed by its authors "Operation Freakout." Scientology operatives had sent the bomb threats, using Paulette Cooper's typewriter and paper with her fingerprints on it. On October 12th, 1977 Paulette Cooper was informed by the FBI that her innocence of the charges had been conclusively established. | |||
The abrogation mentioned above was issued in a policy letter of July 22, 1980, "Ethics, Cancellation of Fair Game, more about", issued by "The Board of Directors of the Churches of Scientology". However, this cancellation was itself cancelled in a subsequent HCO Policy Letter of September 8, 1983, "Cancellation of Issues on Suppressive Acts and PTSes", which cancelled a number of HCOPLs on the ground that they "were not written by the Founder ". In two subsequent court cases the Church defended "fair game" as a "core practice of Scientology", and claimed that it was therefore protected as "religious expression".<ref name="flinnp4032">Frank K. Flinn testimony in Church of Scientology of California, 1984, vol. 23, pp. 4032-4160</ref><ref name="wollersheimb023193">'''', Court of Appeal of the State of California, civ. no. B023193, July 18, 1989</ref> | |||
Cooper's history as the object of "fair gaming" is summarized in Paulette Cooper's Statement to City of Clearwater Commission Hearings in 1982 and in the harassment diary Cooper kept on the advice of her lawyers, which she posted on the internet in 1997. | |||
Since then, a number of ex-Scientologists who formerly held senior management positions in the Church have alleged that while working for the Church they saw "fair game" tactics continuing to be used. In 1994, ], who had been the chairman of the Board of the ] (the Church's central management body), claimed in an affidavit that: | |||
=== John Clark === | |||
{{blockquote |text=Because of my position and the reports which regularly crossed my desk, I know that during my entire presidency of RTC "fair game" actions against enemies were daily routine. Apart from the legal tactics described below, the "fair game" activities included break-ins, libel, upsetting the companies of the enemy, espionage, harassment, misuse of confidential communications in the folders of community members and so forth. |author=] |source=Affidavit<ref>{{cite book |chapter=Ethics Gone Astray | |||
], a professor of psychiatry at Harvard criticized Scientology 1976 during a testimony before the Vermont senate. | |||
|title=Scientology und (k)ein Ende |language=de|trans-title=Scientology With(out) an End |first=Tom |last=Voltz |date=September 22, 1995 |publisher=Walter |isbn=9783530899801 |url=http://www.lermanet.com/cisar/germany/books/swoe13.html }} </ref>}} | |||
Janie Peterson, a former Scientologist, testified in a ] hearing in 1982 that while working in the Guardians Office she had conducted smear campaigns against Church opponents, sometimes using information from confidential confessional files.<ref name="witnesses" /> A lawyer for the Church denounced the hearings as a "witch hunt".<ref name="witnesses">{{cite news|title=Witnesses Tell of Break-ins, Conspiracy|last=Girardi|first=Steven |date=May 9, 1982|work=Clearwater Sun}}</ref> The former Scientologist stated that the fair game policy still applied despite the cancellation of the name. | |||
Scientology started to harrass him in the next year. About this harassment, Justice Latey of the ] stated 1984 (Ref: Re B & G (Minors) FLR 134 and 493) | |||
:''"Beginning in 1977 the Church of Scientology has conducted a campaign of persecution against Dr. Clark. They wrote letters to the Dean at the Harvard Medical School and to the Director of the Massachusetts General Hospital. Then the Dean and the Director refused to gag him. Their agents tracked down and telephoned several of his patient, and interviewed his neighbors looking for evidence to impugn his private or personal actions. They submitted a critical report to a Committee of the Massachusetts State Senate. On three occasions during the last five years a Scientology "front" called the Citizens' Commission on Human Rights have brought complaints against him to the Massachusetts Medical Board of Registration alleging improper professional conduct. In l980 he was declared "Number One Enemy" and in 1981 they brought two law suits against him (summarily dismissed, but costly and worrying). They distributed leaflets in the Massachusetts General Hospital offering a $25,000 reward to employees for evidence which would lead to his conviction on any charge of criminal activity. They stole his employment record from another Boston hospital. They convened press conferences calculated to ruin his professional reputation. "'' | |||
===In the United Kingdom=== | |||
1985 Clark started a lawsuit against Scientology, alleging they tried to destroy his reputation and career. "My sin," Clark said in an interview, "was publicly saying this is a dangerous and harmful cult. They did a good job of showing I'm right." | |||
{{See also|Scientology in the United Kingdom}} | |||
In the UK, targets of fair game and related harassment over the years have included ex-members, authors, journalists, broadcasters, the mental health profession, cult-monitoring groups, government and law enforcement. | |||
Maurice William Johnson was a Scientologist who resigned in June 1966 and successfully sued for his money back. He told a court that after leaving he had received over 100 abusive letters, many of them using violent language. An article in ''The Auditor'', a Scientology publication, was produced to the court, stating outright that Johnson was "fair game" and describing him as "an enemy of mankind, the planets and all life".<ref>{{cite news|title=Scientology is slammed in court as "evil cult"|publisher=East Grinstead Observer|date= June 13, 1968}}</ref><ref>{{cite news|title=Scientology "brainwash': JP's comment as ex-student is cleared of theft|publisher=East Grinstead Courier|date=June 13, 1968}}</ref> | |||
In 1988, the church paid Clark an undisclosed sum to drop his lawsuit. In exchange for the money, Clark agreed never again to publicly criticize Scientology. | |||
], an ex-Scientologist who left in 1983, wrote the book '']'', and the pamphlet "The Total Freedom Trap" as well as providing research for '']''. He provided help to other members in leaving the organisation, as well as acting as an expert witness in various cases concerning Scientology. In response, Atack's home was repeatedly picketed by placard-carrying Scientologists over the course of six days. Eugene Ingram, a private investigator employed by the Church of Scientology, made visits to Atack, his elderly mother and other family and friends, spreading rumours that Atack would be going to prison. Scientologists also distributed leaflets entitled "The Truth about Jon Atack", implying that he was a drug dealer who only criticised Scientology for money.<ref name="palmer_intimidation">{{cite news|title=Cult Accused of Intimidation|work=]|publisher=Times Newspapers|date=April 3, 1994|last=Palmer|first=Richard}}</ref><ref>''Evening Argus''. "Victims Who Are Fair Game". April 12, 1994.</ref><ref>{{cite news|title=Scientologists picket house|publisher=East Grinstead Courier|date=March 18, 1994|last=Thompson|first=David}}</ref> | |||
=== Richard Behar and ''Time'' magazine=== | |||
Investigative journalist ] wrote an 11-page cover feature for ] magazine in 1991, titled "Scientology: The Thriving Cult of Greed and Power." Scientology initiated a libel lawsuit against ''Time'' and Behar. After years of legal wrangling, the suit was dismissed by the district court 1996, the dismissal was upheld by the court of appeals 2001 and the ] refused to reinstate the case . In a sidebar to the original article, Behar describes his experiences with Scientology's Fair Game tactics during the five months he was preparing the article: | |||
:''"For the TIME story, at least 10 attorneys and six private detectives were unleashed by Scientology and its followers in an effort to threaten, harass and discredit me... I later learned, copy of my personal credit report -- with detailed information about my bank accounts, home mortgage, credit-card payments, home address and Social Security number -- had been illegally retrieved from a national credit bureau called ]. The sham company that received it, "Educational Funding Services" of Los Angeles, gave as its address a mail drop a few blocks from Scientology's headquarters. The owner of the mail drop is a private eye named Fred Wolfson, who admits that an'' <nowiki>]<nowiki>]</nowiki>'' associate retained him to retrieve credit reports on several individuals. Wolfson says he was told that Scientology's attorneys "had judgments against these people and were trying to collect on them." He says now, "These are vicious people. These are vipers." Ingram, through a lawyer, denies any involvement in the scam. ... After that, however, an attorney ]ed me, while another falsely suggested that I might own shares in a company I was reporting about that had been taken over by Scientologists (he also threatened to contact the ]). A close friend in Los Angeles received a disturbing telephone call from a Scientology staff member seeking data about me -- an indication that the cult may have illegally obtained my personal phone records. Two detectives contacted me, posing as a friend and a relative of a so-called cult victim, to elicit negative statements from me about Scientology. Some of my conversations with them were taped, transcribed and presented by the church in ]s to TIME's lawyers as "proof" of my bias against Scientology."'' | |||
Atack eventually went bankrupt due to the cost of defending himself against legal action from the Church.<ref>''Writer is quizzed by creditors'' Nottingham Evening Post April 27, 1996</ref> According to ] speaking in the ], a number of ex-Scientologists "have been both threatened and harassed and a considerable number of them have been made bankrupt by the Church."<ref>{{cite news|title=Peer declares Scientology membership|publisher=Press Association|date=December 17, 1996|last=Evans|first=Andrew}}</ref> | |||
==The Fair Game policy in the courts== | |||
Journalist Paul Bracchi investigated Scientology in the mid-1990s while working at the '']'' in East Grinstead. He recounted the case of a Scientologist who had been accused of stealing documents from ], and was told in writing that he was a ] and fair game. The man's wife told Bracchi, "For months after, we had anonymous notes delivered in the post almost daily. They said, 'You bastard,' 'You're dead,' 'Nothing will save you.' It was terribly frightening."<ref>{{cite news|title=Scientology is not a church or charity. It is, in fact, a cult|last=Bracchi|first=Paul|date=May 24, 2007|work=Evening Argus|location=Brighton, UK}}</ref> | |||
===The case of L. Gene Allard, 1976=== | |||
Sandy Smith, the editor of the 2007 ] television programme '']'', alleged that his team had been subjected to fair game tactics from the Church while filming the documentary '']''.<ref>{{cite news|title=BBC reporter blows his top at Scientologist|last=Adams|first=Stephen|date=May 14, 2007|work=Daily Telegraph}}</ref> When the team were filming in the United States, Scientology representatives followed them and repeatedly harangued them. Unknown men also trailed the team, one even appearing at journalist ]'s wedding.<ref name="panorama">{{cite episode | title = Scientology and Me | episode-link= Scientology and Me | series = Panorama | series-link = Panorama (TV series) | airdate = May 14, 2007}}</ref><ref>{{cite news|title=Scientologists to BBC: what planet are you on?|work=The Sunday Times |date=March 13, 2007|last=Swinford|first=Steven|url=http://www.timesonline.co.uk/tol/comment/faith/article1782050.ece |archive-url=https://web.archive.org/web/20080829161040/http://www.timesonline.co.uk/tol/comment/faith/article1782050.ece |url-status=dead |archive-date=August 29, 2008 |access-date=May 3, 2008 | location=London}}</ref><ref>BBC 1 (TV) ''The Heaven and Earth Show with Gloria Hunniford'' May 13, 2007</ref> Sweeney later complained of being "chased round the streets of Los Angeles by sinister strangers{{nbsp}} In LA, the moment our hire car left the airport we realised we were being followed by two cars. In our hotel a weird stranger spent every breakfast listening to us."<ref>{{cite web | first = John | last = Sweeney | title=Row over Scientology video | url=http://news.bbc.co.uk/2/hi/americas/6650545.stm | work =] | publisher =British Broadcasting Corporation | date = May 14, 2007 | access-date = November 14, 2007 }}</ref> When the crew returned to London, Church of Scientology executive ] was sent from the United States to lobby the BBC, even camping out at their offices.<ref>{{cite news|url=http://www.tampabay.com/news/scientology/article1012520.ece|archive-url=https://web.archive.org/web/20090625114003/http://www.tampabay.com/news/scientology/article1012520.ece|url-status=dead|archive-date=June 25, 2009|title=Leaving the Church of Scientology: a huge step|last=Tobin|first=Thomas C.|author2=Joe Childs|date=June 23, 2009|work=]|access-date=June 23, 2009}}</ref> | |||
In 1976, Scientology was found legally liable for the malicious prosecution of a dissatified Scientologist named L. Gene Allard who left Scientology in 1969. The suit specifically charged the Church with "Fair Gaming" Allard according to Church policy. | |||
==Cases== | |||
===The case of Jakob Anderson, 1981=== | |||
A series of court cases in England in the 1970s saw "fair game" being strongly criticized by senior judges. The ] suggested in one case that Scientology organisations were willing to harass their critics.{{r|edge|p=420}} They also described ] brought against author ] as a deliberate form of harassment.{{r|edge|p=420}} In a case where the Church of Scientology of California sought to block publication of a book quoting Scientology materials, ] cited the fair game policy along with what he described as the Church's "deplorable means adopted to suppress inquiry or criticism." He concluded that publication of the materials was in the public interest.{{r|edge|p=417}} | |||
===Charles Berner, 1965=== | |||
In the March 11-16, 1981, Danish court case of Jakob Anderson vs The Church Of Scientology of Denmark, ex-Guardian's Office operative Vibeke Dammon testified that Scientology did in fact practice Fair Game and had done so in Anderson's case, in an attempt to get Anderson committed to a psychiatric hospital. | |||
] | |||
According to an FDA investigation, in 1965, ex-Scientologist Charles Berner received a "fair game order". Afterwards, Berner stated he received other life-threatening letters, "indicating he should apply technique ] to himself. This particular technique is a route whereby an individual places a 45 caliber pistol to his head and {{Sic|disassociates}} himself from his body."<ref>{{cite web|url=http://tonyortega.org/2015/03/17/more-proof-that-scientology-used-the-r2-45-method-to-intimidate-enemies/|title=More proof that Scientology used the 'R2-45' method to intimidate enemies « The Underground Bunker|website=]}}</ref> | |||
=== |
===L. Gene Allard, 1974=== | ||
In 1974, the Church lost a case against an ex-Scientologist named L. Gene Allard who in 1969, shortly after leaving the Church of Scientology, had been arrested on a charge of ] made by the Church of Scientology.<ref name="Allard1978" /> The charge was dismissed "in the interest of justice", and Allard sued the Church for ].<ref name="Allard1978" /> At the trial, Allard's lawyer introduced the October 1967 and October 1968 "fair game" policy statements into evidence.<ref name="Allard1978" /> Allard was awarded US$50,000 in compensatory damages and $250,000 in punitive damages.<ref name="Allard1974"/><ref name="Allard1978" /> Attorneys acting for the Church of Scientology had argued that the fair game policy had been canceled, was irrelevant to the suit and had not been applied to Allard.<ref name="Allard1978">{{cite news|title=Scientology Critics Assail Aggressiveness of Church|last=Rawitch|first=Robert|author2=Gillette, Robert|date=August 28, 1978|work=Los Angeles Times}} See .</ref> An appellate court, while reducing the amount of punitive charges from $250,000 to $50,000, upheld the verdict against the Church, arguing that the Church had been given ample opportunity "to produce evidence that the fair-game policy had been repealed" but had "failed to do so".<ref name="Allard1978" /> In July 1976, the ] refused to review the case.<ref name="Allard1978" /> | |||
===Paulette Cooper, 1976=== | |||
In 1980, Scientologist and ] officer ] was assigned to organize some of Hubbard's personal papers as the basis for a biography of Hubbard. Omar Garrison, a non-Scientologist known to be sympathetic to Scientology, was hired to write the biography. Both Armstrong and Garrison quickly realized that the papers reflected unfavorably on Hubbard, and revealed that many of Hubbard's claimed accomplishments were exaggerations or outright fabrications. Garrison abandoned the project, and a disillusioned Armstrong and his wife left Scientology, retaining copies of the embarrassing materials as insurance against the expected harassment to come from Scientology. | |||
]]] | |||
In ], the Church of Scientology attempted to cause journalist and writer ] to be imprisoned, killed, driven to suicide or committed to a mental institution, as revenge for her publication in 1971 of a highly critical book, '']''. The ] (FBI) discovered documentary evidence of the plot and the preceding campaign of harassment during an investigation into the Church of Scientology in 1977, eventually leading to the Church compensating Cooper in an out-of-court settlement. | |||
Armstrong was sued by the Church in 1982 for the theft of private documents. The Fair Game policy became an issue in court. Armstrong won the case, in part because the Judge ruled that Armstrong, as a Scientologist of long standing, knew that fair game was practiced, and had good reason to believe that possession of these papers would be necessary to defend himself against illegal persecution by the Church. In a scathing decision, Judge Paul Breckenridge wrote: | |||
===Department of Health and Social Security (UK), 1979=== | |||
:''"In addition to violating and abusing its own members civil-rights, the organization over the years with its "Fair Game" doctrine has harassed and abused those persons not in the Church whom it perceives as enemies. The organization clearly is schizophrenic and paranoid, and the bizarre combination seems to be a reflection of its founder LRH. The evidence portrays a man who has been virtually a pathological liar when it comes to his history, background, and achievements..."'' | |||
The Church of Scientology of California sued the ] (DHSS) in British courts for defamation. The DHSS had suggested that Scientologists were dangerous charlatans who would worsen rather than cure ].{{r|edge|pp=420–421}} The Church demanded as part of ] that the DHSS release letters and medical records from people who had complained about the Church. ] declined the request, citing the fair game policy, which he believed still applied despite its name being cancelled. He was concerned that the documents would be used "not for legitimate purposes of the action but for harassment of individual patients, informants and renegades named in them, not only by proceedings for defamation against them but by threats and blackmail."{{r|edge|pp=420–421}} | |||
===Lawrence Wollersheim, 1980=== | |||
:''"In determining whether the defendant unreasonably invaded Mrs. Hubbard's privacy, the court is satisfied the invasion was slight, and the reasons and justification for the defendants conduct manifest. Defendant was told by Scientology to get an attorney. He was declared an enemy by the Church. He believed, reasonably, that he was subject to "fair game." The only way he could defend himself, his integrity, and his wife was to take that which was available to him and place it in a safe harbor, to wit, his lawyer's custody."'' (Judge Paul Breckenridge, Los Angeles Superior Court, June 20, 1984) | |||
]]] | |||
{{See also|Wollersheim v. Church of Scientology}} | |||
], a former Scientologist, successfully argued that he had been harassed and his photography business nearly destroyed as a result of fair game measures. These included getting Scientologist employees to resign, and Scientologist customers to boycott or refuse to pay him.<ref name="greenawalt" /> The 1986 judgment by a Los Angeles jury was upheld by the ] in 1989.{{r|atack|page=356}} During appeals, the Church again claimed fair game was a "core practice" of Scientology and was thus constitutionally protected "religious expression".<ref name="wollersheim212calapp3d872">Wollersheim v. Church of Scientology, 212 Cal. App. 3d 872 (Cal. App. 2d Dist. 1989)</ref> The court decided that the Church's campaign "to ruin Wollersheim economically, and possibly psychologically" should be discouraged rather than protected.<ref name="greenawalt">{{cite book|last=Greenawalt|first=Ken|title=Religion and the Constitution|publisher=Princeton University Press|year=2006|volume=2|page=298|isbn=978-0-691-12582-4}}</ref> Twenty years after the start of the case, the Church paid Wollersheim a judgment, with interest, that amounted to $8,674,643.<ref>{{cite news|first=Richard |last=Leiby |url=https://www.washingtonpost.com/ac2/wp-dyn?pagename=article&contentId=A63143-2002May9 |title=Ex-Scientologist Collects $8.7 Million In 22-Year-Old Case |newspaper=] |page=A03 |date=May 10, 2002 |access-date=June 13, 2006 }}</ref> | |||
During the trial, Scientology hired Frank K. Flinn, a professor of comparative religions, to write a report arguing that Fair Game was a "core practice" of Scientology and thus should be considered Constitutionally protected activity. | |||
===Jakob Anderson, 1981=== | |||
===The case of Lawrence Wollersheim, 1985=== | |||
In the March 11–16, 1981, Danish court case of ''Jakob Anderson v. The Church of Scientology of Denmark'', ex-Guardian's Office operative Vibeke Damman testified that the Church did in fact practice fair game and had done so in Anderson's case, in an attempt to get Anderson committed to a psychiatric hospital.<ref>{{cite web|url=http://www.xenu.net/archive/go/legal/damman.htm|title=Transcript of testimony of Ms. Vibeke Damman, Oslo|website=xenu.net}}</ref> | |||
===Gerald Armstrong, 1984=== | |||
In a long and contentious trial, ], a former Scientologist, alleged that he had been harassed and his business nearly destroyed as a result of "fair game" measures. During appeals, Scientology again claimed Fair Game was a "core practice" of Scientology and was thus Constitutionally protected activity. That claim was denied by the appelate court on July 18, 1989. After twenty-five years of legal wrangling, the Church of Scientology paid Wollersheim the amount of the judgement, plus interest: $8,674,643. | |||
], Hubbard's archivist]] | |||
{{See also|Armstrong cases}} | |||
In 1980, Scientologist and ] officer ] was assigned to organize some of Hubbard's personal papers as the basis for a biography of Hubbard. Omar Garrison, a non-Scientologist known to be sympathetic to Scientology, was hired to write the biography. Both Armstrong and Garrison quickly realized that the papers reflected unfavorably on Hubbard, and revealed that many of Hubbard's claimed accomplishments were exaggerations or outright fabrications. Garrison abandoned the project, and a disillusioned Armstrong and his wife left the Church, retaining copies of the embarrassing materials as insurance against the expected harassment to come.<ref name="Millions">{{cite web| first = Robert | last = Lindsey | title = Scientology chief got millions, ex-aides say | url = http://select.nytimes.com/gst/abstract.html?res=F00A17F9385D0C728DDDAE0894DC484D81 | work=The New York Times| date = July 11, 1984}}</ref> | |||
==The fair game concept and Scientology doctrine== | |||
Armstrong was sued by the Church in 1982 for the theft of private documents. The "fair game" policy became an issue in court. Armstrong won the case, in part because the Judge ruled that Armstrong, as a Scientologist of long standing, knew that fair game was practiced, and had good reason to believe that possession of these papers would be necessary to defend himself against illegal persecution by the Church.<ref name="mind">{{cite web|first=Joel |last=Sappell |author2=Welkos, Robert W. |title=The Mind Behind the {{Sic|Reli|gon|nolink=y}} |url=https://www.latimes.com/la-scientology062490,0,7104164,full.story |work=Los Angeles Times |date=June 24, 1990 |access-date=April 11, 2008 |archive-url=https://web.archive.org/web/20080308182404/http://www.latimes.com/la-scientology062490%2C0%2C7104164%2Cfull.story |archive-date=March 8, 2008 |url-status=dead }}</ref> In a scathing decision, Judge Paul Breckenridge wrote: | |||
{{blockquote|text=In addition to violating and abusing its own members' civil-rights, the organization over the years with its "fair game" doctrine has harassed and abused those persons not in the Church whom it perceives as enemies.{{nbsp}} was declared an enemy by the Church. He believed, reasonably, that he was subject to "fair game".|author=Judge Paul Breckenridge, Los Angeles Superior Court, June 20, 1984 {{r|atack|page=331}} }} | |||
From the earliest days of Scientology, Hubbard implied that only those who had been processed according to his therapies were deserving of civil rights. In his view, those who were not "]" – still hindered by their "]" – were inherently untrustworthy. In '']'' (]), he states in the chapter ''Judicial Ethics'': | |||
===Latey judgment, 1984=== | |||
:''An ideal society would be a society of unaberrated persons, clears conducting their lives within an unaberrated culture: for either the persons or culture may be aberrated. ... Perhaps at some distant date, only the unaberrated person will be granted civil rights before the law.'' | |||
A child custody case in London's ] examined the culture of Scientology to investigate the risks to children being raised within it. Stating his conclusions in a public hearing, ] read some of Scientology's internal documents into the record.{{r|atack|pages=335–343}}<ref name="sinister">{{cite news|work=] |title=Judge brands Scientology 'sinister' as mother is given custody of children |date=July 24, 1984 |page=3}}</ref> Despite the alleged cancellation of "Fair game", he reported that, "Deprival of property, injury by any means, trickery, suing, lying or destruction have been pursued throughout and to this day with the fullest possible vigour."{{r|atack|page=2}} As an example, he cited the case of a doctor at ] who at one point was regarded as the Church's "Number One Enemy".{{r|atack|pages=335–343}} The Church had persecuted him by stealing his employment records from a hospital, launching frivolous lawsuits against him and tracking down his patients and neighbors. The ], which Latey described as "]", made multiple complaints of misconduct against the doctor.{{r|atack|pages=335–343}} | |||
===Pat Broeker, 1989=== | |||
Similarly, in '']'' (]), Hubbard states: | |||
In 2009, the '']'' reported that after ] left the Church of Scientology in 1989 and moved to Colorado, ] hired private detectives for $32,000 a month.<ref name="TwoDecades">{{cite news |url = http://www.tampabay.com/news/scientology/article1048116.ece |title = Has Scientology been watching Pat Broeker for two decades? |access-date = August 10, 2012 |date = November 2, 2009 |newspaper = ] |archive-url = https://web.archive.org/web/20120819031424/http://www.tampabay.com/news/scientology/article1048116.ece |archive-date = August 19, 2012 |url-status = dead }}</ref> They followed him for the next two decades to Wyoming and ten years in Czech Republic, where he went to medical school and worked as an English teacher.<ref>{{cite news |url = http://www.tampabay.com/news/scientology/article1254129.ece |title = Two detectives describe their two-decade pursuit of an exiled Scientology leader |access-date = October 10, 2012 |date = September 30, 2012 |newspaper = Tampa Bay Times |archive-url = https://web.archive.org/web/20121002204323/http://www.tampabay.com/news/scientology/article1254129.ece |archive-date = October 2, 2012 |url-status = dead }}</ref> In 2012, Paul Marrick and Greg Arnold, the two private detectives who followed Broeker for 25 years, sued the Church of Scientology for breach of contract when the organization stopped paying them for their investigations.<ref name="Lawsuit">{{cite news |url = http://www.dallasnews.com/news/state/headlines/20120923-texas-lawsuit-scientology-leader-paid-private-investigators-millions-to-monitor-former-rival.ece |title = Texas lawsuit: Scientology leader paid private investigators millions to monitor former rival |access-date = September 23, 2012 |date = September 23, 2012 |newspaper = ]}}</ref><ref>{{cite web |url = http://www.caller.com/news/2012/sep/21/latest-scientology-legal-battle-unfolds-in-bend/ |title =Latest Scientology legal battle unfolds in Coastal Bend as private investigators sue church |access-date = September 22, 2012 |date = September 21, 2012 |publisher = ]}}</ref><ref>{{cite web |url = http://kraftmstr.com/lawsuit/1stAmendedPetitionfiled9-20-2012.pdf |title = Paul Marrick and Greg Arnold vs Church of Scientology |access-date = August 10, 2012 |year = 2012 |publisher = Kraftmstr.com }}</ref> | |||
=== Pedro Lerma Gámez, 1990 === | |||
:''Such people should be taken from the society as rapidly as possible and uniformly institutionalized; for here is the level of the contagion of immorality, and the destruction of ethics; here is the fodder which secret police organizations use for their filthy operations. One of the most effective measures of security that a nation threatened by war could take would be rounding up and placing in a cantonment, away from society, any individual who might be connected with government, the military, or essential industry; since here are people who, regardless of any record of their family's loyalty, are potential traitors, the very mode of operation of their insanity being betrayal. In this level is the slime of society, the sex criminals, the political subversives, the people whose apparently rational activities are yet but the devious writhings of secret hate.'' | |||
The Dominican cartoonist Pedro Lerma Gámez,<ref name=ABC1>{{cite news |title=La Audiencia de Madrid considera a la Cienciología "una amenaza peligrosa"|publisher=ABC|agency=Servimedia|page=64|date=6 December 1990}}</ref> known as Petrus, was successfully treated for his drug addiction at a Narconon center in Paris. The Church of Scientology considered that Lerma was not following the instructions of the organization and sent missions to try to redirect him.<ref name=ABC2>{{cite news |title=La secta de la Cienciología utilizó a policías para encarcelar a un inocente|author=Alfredo Semprún|publisher=ABC|page=105|date=18 November 1990}}</ref> This included a smear campaign conducted against Lerma by "Judit" and "Greg" and a private detective and former National Police inspector, José Manuel Villarejo Pérez. During their fourth mission, Villarejo introduced a brother-in-law, (with the nickname ''el Pitrancas'' and codenamed ''Hero'') to Narconon; the information ''Hero'' gathered there made it possible to include the detox center's clients in the smear campaign.<ref name=ABC2/> | |||
Anyone who criticized Scientology was counted among the hateful, immoral, and "aberrated," in Hubbard's view. The logic of this was fairly simple: As Scientology was a purely charitable organization, dedicated to the improvement of mankind, clearly only the most depraved or corrupt individuals would have any interest in attacking it. There was no ''legitimate'' criticism of Scientology, so long as Hubbard's instructions were being followed to the letter. Thus anyone who attacked ''bona fide'' Hubbardian Scientology was by definition someone who had put themselves beyond the pale. | |||
In April 1984 a fifth mission, headed by Rodolfo Sabanero, was aimed at getting Lerma incarcerated. Villarejo brainwashed<ref name=ABC2/> Juan Carlos Borrallo Rebolledo, a drug addict with a criminal record for robberies who had been treated at Narconon. The plan consisted of Borrallo giving himself up to the authorities (for robbery) and then implicating Lerma in being accessory to a robbery at the Dianetics headquarters. On May 8, 1984, Borrallo appeared at a Madrid police station, admitting to two robberies that he had actually committed (to give credibility to the matter) and of a theft of several E-Meters at the Dianetics headquarters, saying that he was induced to steal them by Pedro Lerma. Another individual, named José Luis Díaz López, conveniently presented himself to police with the same deposition.<ref name=ABC1/> Villarejo – still having friendly contacts within the police – influenced the development of the police investigation, resulting in Lerma being arraigned and entered in prison with bail being set at 800,000 pesetas.<ref name=ABC2/> During proceedings, however, the presiding judge, José María Vázquez Honrubia, discovered the smear plot<ref name=ABC2/> and Lerma was acquitted by the Sixteenth Section of the Madrid Court in 1990.<ref name=ABC1/> | |||
Early on, Hubbard advocated a strong counter-attack as the response to any outside criticism of Scientology. In ''Manual of Dissemination of Materials'' (], collected from his writings in ''Ability'' magazine), he wrote: | |||
===Richard Behar, 1991=== | |||
:''The DEFENSE of anything is untenable. The only way to defend anything is to ATTACK, and if you forget that you will lose every battle that you engage in, whether it is in terms of personal conversation, public debate, or a court of law. NEVER BE INTERESTED IN CHARGES. Do yourself, much MORE CHARGINGS and you will WIN." | |||
]]] | |||
In 1991, investigative journalist ] wrote "]", a '']'' cover story on Scientology.<ref name=Behar>{{cite magazine|last1=Behar|first1=Richard|title=The Thriving Cult of Greed and Power|url=https://www.cs.cmu.edu/~dst/Fishman/time-behar.html|access-date=January 2, 2016|magazine=]|date=May 6, 1991}}</ref> The acclaimed article won several awards.<ref name="Judge dismisses">{{cite news|url=http://www.findarticles.com/p/articles/mi_m0EIN/is_1996_July_16/ai_18489022 |title=Judge dismisses Church of Scientology's $416 million lawsuit against Time Magazine |work=Time magazine press release |via=] |date=July 16, 1996 |access-date=June 1, 2006 |url-status=dead |archive-url=https://web.archive.org/web/20050324093216/http://www.findarticles.com/p/articles/mi_m0EIN/is_1996_July_16/ai_18489022 |archive-date=March 24, 2005 }}</ref> The Church of Scientology brought several lawsuits over the article, all of which were eventually dismissed.<ref name="Judge dismisses"/> While investigating the story, he experienced some of Scientology's "fair game" tactics: | |||
In the same work, he instructed his followers to use litigation as a tactical weapon against critics of Scientology: | |||
{{blockquote |text=I later learned, a copy of my personal credit report – with detailed information about my bank accounts, home mortgage, credit-card payments, home address and Social Security number – had been illegally retrieved from a national credit bureau called ]. The sham company that received it, "Educational Funding Services" of Los Angeles, gave as its address a mail drop a few blocks from Scientology's headquarters. The owner of the mail drop is a private eye named Fred Wolfson, who admits that an Ingram associate retained him to retrieve credit reports on several individuals. Wolfson says he was told that Scientology's attorneys "had judgments against these people and were trying to collect on them." He says now, "These are vicious people. These are vipers." Ingram, through a lawyer, denies any involvement in the scam.{{nbsp}} After that, however, an attorney ]ed me, while another falsely suggested that I might own shares in a company I was reporting about that had been taken over by Scientologists (he also threatened to contact the ]). A close friend in Los Angeles received a disturbing telephone call from a Scientology staff member seeking data about me – an indication that the cult may have illegally obtained my personal phone records. Two detectives contacted me, posing as a friend and a relative of a so-called cult victim, to elicit negative statements from me about Scientology. Some of my conversations with them were taped, transcribed and presented by the church in ]s to Time's lawyers as "proof" of my bias against Scientology. |author=Richard Behar<ref name=Behar /> }} | |||
:''The purpose of the suit is to harass and discourage rather than to win. The law can be used very easily to harass... If possible, of course, ruin him utterly.'' | |||
===Carmen Llywelyn, 2002=== | |||
In addition, he proposed to use a tactic he dubbed "noisy" or "overt" investigation – essentially a means of applying pressure – to dissuade critics of Scientology. In the 1959 ''Manual of Justice'', he stated: | |||
Actress and photographer ] was introduced to ] through her partner (and future husband) professional skateboarder and actor ]. In 2015, Llywelyn penned an article entitled "Why I Left Scientology". According to her account, when she revealed to her ] that she had read '']'', a book critical of the Church, she was labeled a ] and shunned (or "disconnected") by her Scientologist friends. Llywelyn's manager, a Scientologist, also "disconnected" and allegedly convinced ] to drop Llywelyn as a client.<ref name="gawker.com">{{cite news|last1=Llywelyn |first1=Carmen |title=Why I Left Scientology |url=http://gawker.com/why-i-left-scientology-1703997050 |access-date=January 2, 2016 |work=Gawker |date=June 23, 2015 |language=en-US |url-status=dead |archive-url=https://web.archive.org/web/20150623224621/http://gawker.com/why-i-left-scientology-1703997050 |archive-date=June 23, 2015 }}</ref> | |||
Llwelyn reports being subjected to a campaign of surveillance and harassment. Writes Llywelyn: "Scientology has a sophisticated intelligence agency known as the ], which is essentially a complex system dedicated to ruining the lives of those it sees as enemies in any way possible. Those who work for the OSA do not follow the law."<ref name="gawker.com"/> | |||
:''Investigation by outside sources: Overt investigation of someone or something by an outside detective agency should be done more often and hang the expense.'' | |||
===John Sweeney, 2007=== | |||
Thus, by the end of the ], the two key doctrinal elements that were to support the Fair Game policy were in place: the dismissal of any consideration for critics, and a willingness to take punitive action against them. | |||
]]] | |||
Journalist John Sweeney said of fair gaming: "While making our BBC Panorama film '']'' I have been shouted at, spied on, had my hotel invaded at midnight, denounced as a 'bigot' by star Scientologists and been chased round the streets of Los Angeles by sinister strangers." Sweeney also claimed that his family and neighbours had been harassed by unidentified strangers back in the UK, including an intruder at his wedding who fled when confronted.<ref name=videorow>{{cite news |first=John |last=Sweeney |title=Row over Scientology video |url=http://news.bbc.co.uk/2/hi/americas/6650545.stm |work=] |date=May 14, 2007 |access-date=January 21, 2008}}</ref> | |||
==References== | |||
===Mark and Monique Rathbun, 2009=== | |||
*L. Ron Hubbard, ''Dianetics: The Modern Science Of Mental Health'', 1950 | |||
]]] | |||
*L. Ron Hubbard, ''Science of Survival'', 1951 | |||
*L. Ron Hubbard, ''Manual of Dissemination of Materials'', 1955 | |||
], a former senior executive of the Church of Scientology, left the organization in 2004. A one-hour feature titled ''Scientologists at War'' was broadcast on June 17, 2013, on British ].<ref>{{cite web|url=http://www.channel4.com/programmes/scientologists-at-war|title=Channel 4: Scientologists at War|work=Channel 4|access-date=October 21, 2014}}</ref> The feature, a rare insider view of the Church of Scientology, investigated the pressure tactics used by the "Squirrel Busters" affiliated to the organization to discredit and silence members who leave the Church. It highlighted the story of Mark Rathbun, his role in Scientology, his fall out with Scientology leader David Miscavige, his attempts to further the cause of an independent Scientology movement, his confrontations with the "Squirrel Busters" and the repercussions on his family life. | |||
*L. Ron Hubbard, '''', 1959 | |||
* (Michel Snoeck) | |||
Videographer Bert Leahy reported being paid $2,000 a week by the "Squirrel Busters" to help document their activities.<ref name=ccct110806>{{cite news|last1=Collette|first1=Mark|title=Former Scientology film crew member describes surveillance activities in Ingleside on the Bay|url=http://www.caller.com/news/former-scientology-film-crew-member-describes-surveillance-activities-in-ingleside-on-the-bay-ep-359-316193271.html|access-date=January 2, 2016|work=]|date=August 6, 2011}}</ref> Leahy reported that his employer had "flat-out said our goal is to make Marty's life a living hell".<ref name=VV110807>{{cite news|last1=Ortega|first1=Tony|author1-link=Tony Ortega|title=Scientology Goons Exposed: "Make Marty's Life a Living Hell" (UPDATED)|url=http://blogs.villagevoice.com/runninscared/2011/08/scientology_goo_2.php|access-date=January 2, 2016|work=]|date=August 7, 2011|url-status=dead|archive-url=https://web.archive.org/web/20150526065015/http://blogs.villagevoice.com/runninscared/2011/08/scientology_goo_2.php|archive-date=May 26, 2015}}</ref> | |||
* (William C. Barwell) | |||
* Ex-Scientologist ], Affidafit regarding Fair Game | |||
In 2013, Mark Rathbun's wife, a non-Scientologist, filed suit against the Church of Scientology, alleging four years of harassment by the Church.<ref name=SAEN140123>{{cite news|last1=MacCormack|first1=John|title=Judge to Scientology: Leader must testify in Texas case|url=http://www.mysanantonio.com/news/local/article/Judge-to-Scientology-Leader-must-testify-in-5166735.php|access-date=January 2, 2016|work=San Antonio Express-News|publisher=]|date=January 23, 2014}}</ref> In October 2014, Rathbun filmed an encounter which he claimed showed three members of the Church's top management as they "ambushed" him at ].<ref name=ibt141021>{{cite news|last1=Mintz|first1=Zoe|title=Top Scientology Leaders Caught In Videotaped Verbal Assault At LAX|url=http://www.ibtimes.com/top-scientology-leaders-caught-videotaped-verbal-assault-lax-1708821|access-date=January 2, 2016|work=]|publisher=IBT Media Inc.|date=October 21, 2014}}</ref><ref name=TUB141019>{{cite web|last1=Ortega|first1=Tony|author1-link=Tony Ortega|title=Marty Rathbun on being ambushed at LAX by raving Scientologists: 'It was insane' « The Underground Bunker|url=http://tonyortega.org/2014/10/19/marty-rathbun-on-being-ambushed-at-lax-by-raving-scientologists-it-was-insane/|website=The Underground Bunker|access-date=January 2, 2016|date=October 19, 2014}}</ref> The Church defended this activity as being protected by ] (religious freedom) and free speech rights.<ref name=cns0516 /> {{As of|January 2016}}, the court has denied a Church motion to have the case dismissed under anti-] law,<ref name=Radar151106>{{cite news|title=Scientology Takes Legal Hit In Ongoing Harassment Suit|url=http://radaronline.com/celebrity-news/scientology-lawsuit-monique-rathbun-legal-win/|access-date=January 2, 2016|work=Radar Online|date=November 6, 2015}}</ref> but the ruling that Miscavige must testify in the case was overturned on appeal.<ref>{{cite news|last1=Childs|first1=Joe|title=Judge: Scientology leader not required to give deposition|url=https://www.tampabay.com/news/scientology/ruling-scientology-leader-not-required-to-give-deposition/2189099/|access-date=January 2, 2016|work=]|date=July 18, 2014}}</ref> After more than 32 months of litigation, Monique Rathbun dropped the lawsuit against the Church, after firing her attorneys in January 2016, due to financial constraints.<ref name=cns0516 /> She filed a motion to end the legal proceedings which the state Supreme court granted on May 6, and Monique Rathbun filed for dismissal on May 10.<ref name=cns0516>{{Cite web|url=http://www.courthousenews.com/2016/05/13/woman-drops-lawsuit-against-scientology.htm|title=CNS - Woman Drops Lawsuit Against Scientology|website=www.courthousenews.com|access-date=July 1, 2016|url-status=dead|archive-url=https://web.archive.org/web/20160619095343/http://www.courthousenews.com/2016/05/13/woman-drops-lawsuit-against-scientology.htm|archive-date=June 19, 2016}}</ref><ref>{{Cite web|url=http://www.houstonpress.com/news/another-scientology-lawsuit-meets-a-strange-abrupt-end-in-texas-8424797|title=Another Scientology Lawsuit Meets a Strange, Abrupt End in Texas|last=Wray|first=Dianna|date=May 25, 2016|access-date=July 1, 2016}}</ref> | |||
* Eric J. Ascalon: ''Dangerous Science: The Church of Scientology's Holy War against Critics'', American Jurist, November 1995, Vol. 9 No. 2 | |||
===Ronald Miscavige Sr., 2012=== | |||
David Miscavige's father, ], was a longtime Scientologist who left the Church of Scientology in 2012. In July 2013, Wisconsin police responding to a suspicious person call found Dwayne S. Powell outside Ronald's home. Powell was in possession of firearms and an illegal homemade ].<ref>{{cite web|url=https://www.latimes.com/local/california/la-me-scientology-private-eyes-20150409-story.html#page=1|title=Scientology head's father was spied on, police report says |date=April 8, 2015|work=Los Angeles Times |access-date=April 10, 2015}}</ref> Powell claimed to have received $10,000 a week, for over a year, to conduct full-time surveillance on the elder Miscavige for Scientology.<ref>{{cite web|url=http://tonyortega.org/2015/04/08/let-him-die-scientology-leader-david-miscavige-had-private-eyes-watching-his-father-say-police/#more-21658|title='Let him die': Scientology leader David Miscavige had private eyes watching his father, say police|access-date=April 10, 2015|website=]}}</ref><ref>{{cite web|url=http://www.today.com/id/26184891/vp/18424824#18424824|title=TODAY Video Player - popup|access-date=April 10, 2015|archive-date=May 12, 2015|archive-url=https://web.archive.org/web/20150512175746/http://www.today.com/id/26184891/vp/18424824#18424824|url-status=dead}}</ref> Powell told police that on one occasion, he witnessed what he believed to be Ron Sr. undergoing cardiac arrest. According to Powell, after immediately reporting the perceived emergency to his superiors, he received a call for further instructions from a man who identified himself as David Miscavige. According to the police report, Powell was instructed "to let him die and not intervene in any way."<ref name=TMZ150408>{{cite news|title=Scientology Leader David Miscavige -- P.I.s Say They Stalked His Dad ... David Said 'Let Him Die'|url=https://www.tmz.com/2015/04/08/david-miscavige-scientology-father-ronald-pi-private-investigators-silencer-guns-followed/#ixzz3WpWweTx2|access-date=January 2, 2016|work=TMZ|publisher=EHM Productions, Inc.|date=April 8, 2015}}</ref> | |||
===Mike Rinder and Tony Ortega, 2015=== | |||
]]] | |||
In March 2015, private investigator Eric Saldarriaga pleaded guilty to the federal charge of conspiracy to commit computer hacking after he illegally gained access to at least 60 email accounts.<ref name=NYT150306>{{cite news|last1=Goldstein|first1=Matthew|title=Investigator Admits Guilt in Hiring of a Hacker|url=https://www.nytimes.com/2015/03/07/business/dealbook/a-guilty-plea-in-a-hacker-for-hire-case.html|access-date=January 2, 2016|work=The New York Times|date=March 6, 2015}}</ref> Among those targeted were ], the former spokesman for the Church of Scientology, and journalist ].<ref name=NYT150625>{{cite news|last1=Goldstein|first1=Matthew|title=Prison Term Sought for Private Eye Who Hacked Email|url=https://www.nytimes.com/2015/06/26/business/dealbook/prison-term-sought-for-private-eye-who-hacked-email.html|access-date=January 2, 2016|work=The New York Times|date=June 25, 2015}}</ref> Both men had participated in the ] documentary film ].<ref name=Ars150626>{{cite news|last1=Gallagher|first1=Sean|title=Private investigator snooped on e-mail of Scientology critics |url=https://arstechnica.com/tech-policy/2015/06/private-investigator-snooped-on-e-mail-of-scientology-critics/|access-date=January 2, 2016|work=Ars Technica|publisher=Condé Nast|date=June 26, 2015}}</ref> | |||
==See also== | |||
* ] | |||
* ] | |||
* ] | |||
* ], used by the Church of Scientology to intimidate, harass, and attack their enemies | |||
* ] | |||
* ]—See the section "L. Ron Hubbard and lawsuits" for more on the "Fair Game Law" as envisioned by Hubbard | |||
* ] | |||
== References == | |||
{{Reflist|refs= | |||
<ref name="atack">{{Cite book |url=https://archive.org/details/pieceofblueskysc00atac/ |title=A Piece of Blue Sky: Scientology, Dianetics and L. Ron Hubbard Exposed |first=Jon |last=Atack |author-link=Jon Atack |date=1990 |publisher=] |isbn=081840499X |ol=9429654M}}</ref> | |||
<ref name="edge">{{Cite book |last=Edge | first= Peter W. |title=Legal Responses to Religious Difference |year=2002|publisher=Martinus Nijhoff | isbn=978-90-411-1678-9 }}</ref> | |||
<ref name="foster">{{cite web |url=https://ia803209.us.archive.org/1/items/FosterReportEnquiryIntoThePracticeAndEffectsOfScientology/Foster%20Report%20-%20Enquiry%20into%20the%20Practice%20and%20Effects%20of%20Scientology.pdf |first=John |last=Foster |author-link=John Foster (MP for Northwich) | title = Enquiry into the Practice and Effects of Scientology | publisher = ], London | date = December 1971 }} UK National Archive piece reference () See also ].</ref> | |||
<ref name="lord">{{Cite journal |journal=Marburg Journal of Religion |volume=21 |issue=1 |last=Lord |first=Phil |title=Scientology's Legal System |year=2019 |doi=10.2139/ssrn.3232113 |doi-access=free |ssrn=3232113 |url=https://escholarship.mcgill.ca/concern/articles/9z9034375 }}</ref> | |||
<ref name="streeter">{{Cite book|last=Streeter |first=Michael |title=Behind Closed Doors: The Power and Influence of Secret Societies |publisher=New Holland Publishers |year=2008 |isbn=978-1-84537-937-7 |url-access=registration |url=https://archive.org/details/behindcloseddoor0000stre}}</ref> | |||
}} | |||
==External links== | ==External links== | ||
* Fair game used in courts and real life | |||
* | |||
* Eric J. Ascalon: , ''American Jurist'', November 1995, Vol. 9 No. 2 | |||
* | |||
* ] "", declaration in the case ''Church of Scientology International v. Steven Fishman and Uwe Geertz'', 1994. | |||
* | |||
* ], ], , February 1999 | |||
* | |||
* | |||
{{Scientology}} | |||
] | ] | ||
] | ] |
Latest revision as of 00:38, 24 December 2024
Actions of the Church of Scientology towards perceived enemies
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The term fair game is used to describe policies and practices carried out by the Church of Scientology towards people and groups it perceives as its enemies. Founder of Scientology L. Ron Hubbard established the policy in the 1950s in response to criticism both from within and outside his organization. Individuals or groups who are "fair game" are judged to be a threat to the Church and, according to the policy, can be punished and harassed using any and all means possible. In 1968, Hubbard officially canceled use of the term "fair game" because of negative public relations it caused, although the Church's aggressive response to criticism continued.
Applying the principles of "fair game", Hubbard and his followers targeted many individuals as well as government officials and agencies, including a program of covert and illegal infiltration of the Internal Revenue Service (IRS) and other United States government agencies during the 1970s. They also conducted private investigations, character assassination and legal action against the Church's critics in the media. The policy remains in effect and has been defended by the Church of Scientology as a core religious practice.
Starting in the 1980s, for their major branch in Los Angeles, California, the Scientology organization largely switched from using church members in harassment campaigns to hiring private investigators, including former and current Los Angeles police officers. The reason seemed to be that this gave the Church of Scientology a layer of protection in case embarrassing tactics were used and made public.
Background
Scientology's founder, L. Ron Hubbard, said all opposition came from what he called "suppressive persons" (SPs) – which Scientologists claim are "anti-social people who want to destroy anything that benefits humanity." In written policies dating from the mid-1950s, Hubbard told his followers to take a hard line against perceived opponents. In 1955 he wrote, "The purpose of the suit is to harass and discourage rather than to win. The law can be used easily to harass, and enough harassment on somebody who is simply on the thin edge anyway, well knowing that he is not authorized, will generally be sufficient to cause his professional decease. If possible, of course, ruin him utterly".
In his confidential Manual of Justice of 1959, Hubbard wrote "People attack Scientology. I never forget it, always even the score." He advocated using private investigators to investigate critics, who had turned out to be "members of the Communist Party or criminals, usually both. The smell of police or private detectives caused them to fly, to close down, to confess. Hire them and damn the cost when you need to." He said that in dealing with opponents, his followers should "always find or manufacture enough threat against them to cause them to sue for peace. Don't ever defend. Always attack." He urged the use of "black propaganda" to "destroy reputation or public belief in persons, companies or nations."
The Church of Scientology has retained an aggressive policy towards those it perceives as its enemies, and argued as late as 1985 that retributive action against "enemies of Scientology" should be considered a Constitutionally-protected "core practice" of Scientology.
Policy
In 1965, Hubbard formulated the "Fair Game Law", which states how to deal with people who interfere with Scientology's activities. These suppressive persons could be considered "fair game" for retaliation:
By FAIR GAME is meant, may not be further protected by the codes and disciplines or the rights of a Scientologist.
— L. Ron Hubbard, HCOPL 1 Mar 65 Suppressive Acts – Suppression of Scientology and Scientologists – The Fair Game Law
In other words, a person who attacked the Church would not be protected by the Church or granted the rights of Scientologists in good standing.
In December of that year, Hubbard reissued the policy with additional clarifications to define the scope of fair game. He made it clear that the policy applied to non-Scientologists as well, declaring:
The homes, property, places and abodes of persons who have been active in attempting to: suppress Scientology or Scientologists are all beyond any protection of Scientology Ethics, unless absolved by later Ethics or an amnesty his Policy Letter extends to suppressive non-Scientology wives and husbands and parents, or other family members or hostile groups or even close friends.
— L. Ron Hubbard, HCOPL 23 Dec 65, Suppressive Acts – Suppression of Scientology and Scientologists – The Fair Game Law
In his Introduction to Scientology Ethics, published in 1968, Hubbard wrote that no Scientologist could be punished "for any action taken against a suppressive person or Group during the period that person or group is 'fair game'."
He made it clear elsewhere in his writings that the policy would be applied to external organizations, including governments, that interfered with Scientology's activities. He told Scientologists:
If the Internal Revenue Service (in refusing the FCDC non-profit status) continues to act up or if the FDA does sue we can of course Comm Ev them and if found guilty, label and publish them as a Suppressive Group and fair game one is fair game until he or she declares against us.
— L. Ron Hubbard, HCOPL 2 Apr 65, Administration outside Scientology
In a 1967 policy titled Penalties for Lower Conditions, Hubbard wrote that opponents who are "fair game" may be "deprived of property or injured by any means by any Scientologist without any discipline of the Scientologist. May be tricked, sued or lied to or destroyed."
In a policy letter dated July 21, 1968, Hubbard explicitly cancelled these penalties. The new list of Penalties for Lower Conditions now said that someone in a condition of Enemy "(m)ay be restrained or imprisoned. May not be protected by any rules or laws of the group he sought to injure. May not be trained or processed or admitted to any . The same list says that in a condition of Treason, a person, "May not be protected by the rights and fair practices he sought to destroy for others. May be retrained or debarred. Not covered by amnesties." Another policy letter from October that year announces:
The practice of declaring people FAIR GAME will cease. FAIR GAME may not appear on any Ethics Order. It causes bad public relations. This does not cancel any policy on the treatment or handling of an SP.
— L. Ron Hubbard, HCOPL 21 Oct 68, Cancellation of Fair Game
Scientology officials have maintained that the fair game policy was rescinded in 1968 because people had misinterpreted it. Spokesmen said that Hubbard's intended meaning was merely that former members could not appeal to Scientology's legal system for support or protection against anyone who might try to trick, sue or destroy them. Sociologist Roy Wallis commented that this interpretation seemed to be "contradicted by the words on the page, and by actions taken against those regarded as enemies of the movement."
The Church continued to pursue an aggressive response to external critics, especially the U.S. Government. The doctrine of "fair game" was a central element of the Guardian's Office's operational policies. The original 1965 "Fair Game Law" is listed as a reference for GO staff in its confidential Intelligence Course, which was later entered into evidence in a U.S. federal court case in 1979. During the case, Church lawyers admitted that "fair game" had been practiced long after its supposed cancellation in 1968.
Hubbard said in a 1976 affidavit that he had never intended to authorize harassment:
There was never any attempt or intent on my part by the writing of these policies (or any others for that fact), to authorise illegal or harassment type acts against anyone. As soon as it became apparent to me that the concept of 'fair game' as described above was being misinterpreted by the uninformed, to mean the granting of a license to Scientologists for acts in violation of the law and/or other standards of decency, these policies were cancelled.
— L. Ron Hubbard, Affidavit of March 22, 1976
As revised in 1991, Scientology's policy on the handling of "suppressive persons" states:
Nothing in this policy letter shall ever or under any circumstances justify any violation of the laws of the land or intentional legal wrongs. Any such offense shall subject the offender to penalties prescribed by law as well as to ethics and justice actions.
— L. Ron Hubbard, HCOPL 23 Dec 65RB, rev. 9 Jan 91, Suppressive Acts Suppression of Scientology and Scientologists
In practice
An "Ethics Order" dating from March 6, 1968, issued by L. Ron Hubbard aboard his boat the Royal Scotsman, lists twelve Scientologists who were accused of distributing altered versions of upper level materials. Hubbard writes "They are fair game. No amnesty may ever cover them. Any Sea Org member contacting them is to use Auditing Process R2-45." The R2-45 Auditing Process consists of shooting a person with the intent to kill them.
It later emerged that "fair game" had actually continued in use until at least 1980, despite its cancellation, and there have been frequent allegations that it has remained in force since then. During the 1970s the Guardian's Office (GO) of the Church of Scientology, headed by Hubbard's wife Mary Sue, conducted a wide-ranging and systematic series of espionage and intimidation operations against perceived enemies of Scientology. (See Operation Freakout for a noteworthy example.)
According to an American Lawyer investigation, "fair game" tactics had been used to force the withdrawal of the presiding judge in an attempt to "throw" the case. As the US Government's attorneys put it:
Defendants, through one of their attorneys, have stated that the fair game policy continued in effect well after the indictment in this case and the conviction of the first nine co-defendants. Defendants claim that the policy was abrogated by the Church's Board of Directors in late July or early August, 1980, only after the defendants' personal attack on Judge Richey.
— 1979 sentencing memorandum, Mary Sue Hubbard et al.
The abrogation mentioned above was issued in a policy letter of July 22, 1980, "Ethics, Cancellation of Fair Game, more about", issued by "The Board of Directors of the Churches of Scientology". However, this cancellation was itself cancelled in a subsequent HCO Policy Letter of September 8, 1983, "Cancellation of Issues on Suppressive Acts and PTSes", which cancelled a number of HCOPLs on the ground that they "were not written by the Founder ". In two subsequent court cases the Church defended "fair game" as a "core practice of Scientology", and claimed that it was therefore protected as "religious expression".
Since then, a number of ex-Scientologists who formerly held senior management positions in the Church have alleged that while working for the Church they saw "fair game" tactics continuing to be used. In 1994, Vicki Aznaran, who had been the chairman of the Board of the Religious Technology Center (the Church's central management body), claimed in an affidavit that:
Because of my position and the reports which regularly crossed my desk, I know that during my entire presidency of RTC "fair game" actions against enemies were daily routine. Apart from the legal tactics described below, the "fair game" activities included break-ins, libel, upsetting the companies of the enemy, espionage, harassment, misuse of confidential communications in the folders of community members and so forth.
— Vicki Aznaran, Affidavit
Janie Peterson, a former Scientologist, testified in a Clearwater City hearing in 1982 that while working in the Guardians Office she had conducted smear campaigns against Church opponents, sometimes using information from confidential confessional files. A lawyer for the Church denounced the hearings as a "witch hunt". The former Scientologist stated that the fair game policy still applied despite the cancellation of the name.
In the United Kingdom
See also: Scientology in the United KingdomIn the UK, targets of fair game and related harassment over the years have included ex-members, authors, journalists, broadcasters, the mental health profession, cult-monitoring groups, government and law enforcement.
Maurice William Johnson was a Scientologist who resigned in June 1966 and successfully sued for his money back. He told a court that after leaving he had received over 100 abusive letters, many of them using violent language. An article in The Auditor, a Scientology publication, was produced to the court, stating outright that Johnson was "fair game" and describing him as "an enemy of mankind, the planets and all life".
Jon Atack, an ex-Scientologist who left in 1983, wrote the book A Piece of Blue Sky: Scientology, Dianetics and L. Ron Hubbard Exposed, and the pamphlet "The Total Freedom Trap" as well as providing research for Bare-Faced Messiah. He provided help to other members in leaving the organisation, as well as acting as an expert witness in various cases concerning Scientology. In response, Atack's home was repeatedly picketed by placard-carrying Scientologists over the course of six days. Eugene Ingram, a private investigator employed by the Church of Scientology, made visits to Atack, his elderly mother and other family and friends, spreading rumours that Atack would be going to prison. Scientologists also distributed leaflets entitled "The Truth about Jon Atack", implying that he was a drug dealer who only criticised Scientology for money.
Atack eventually went bankrupt due to the cost of defending himself against legal action from the Church. According to Baroness Sharples speaking in the House of Lords, a number of ex-Scientologists "have been both threatened and harassed and a considerable number of them have been made bankrupt by the Church."
Journalist Paul Bracchi investigated Scientology in the mid-1990s while working at the Evening Argus in East Grinstead. He recounted the case of a Scientologist who had been accused of stealing documents from Saint Hill Manor, and was told in writing that he was a suppressive person and fair game. The man's wife told Bracchi, "For months after, we had anonymous notes delivered in the post almost daily. They said, 'You bastard,' 'You're dead,' 'Nothing will save you.' It was terribly frightening."
Sandy Smith, the editor of the 2007 BBC television programme Panorama, alleged that his team had been subjected to fair game tactics from the Church while filming the documentary Scientology and Me. When the team were filming in the United States, Scientology representatives followed them and repeatedly harangued them. Unknown men also trailed the team, one even appearing at journalist John Sweeney's wedding. Sweeney later complained of being "chased round the streets of Los Angeles by sinister strangers In LA, the moment our hire car left the airport we realised we were being followed by two cars. In our hotel a weird stranger spent every breakfast listening to us." When the crew returned to London, Church of Scientology executive Mike Rinder was sent from the United States to lobby the BBC, even camping out at their offices.
Cases
A series of court cases in England in the 1970s saw "fair game" being strongly criticized by senior judges. The Court of Appeal of England and Wales suggested in one case that Scientology organisations were willing to harass their critics. They also described multiple cases brought against author Russell Miller as a deliberate form of harassment. In a case where the Church of Scientology of California sought to block publication of a book quoting Scientology materials, Lord Justice Goff cited the fair game policy along with what he described as the Church's "deplorable means adopted to suppress inquiry or criticism." He concluded that publication of the materials was in the public interest.
Charles Berner, 1965
According to an FDA investigation, in 1965, ex-Scientologist Charles Berner received a "fair game order". Afterwards, Berner stated he received other life-threatening letters, "indicating he should apply technique R2-45 to himself. This particular technique is a route whereby an individual places a 45 caliber pistol to his head and disassociates [sic] himself from his body."
L. Gene Allard, 1974
In 1974, the Church lost a case against an ex-Scientologist named L. Gene Allard who in 1969, shortly after leaving the Church of Scientology, had been arrested on a charge of grand theft made by the Church of Scientology. The charge was dismissed "in the interest of justice", and Allard sued the Church for malicious prosecution. At the trial, Allard's lawyer introduced the October 1967 and October 1968 "fair game" policy statements into evidence. Allard was awarded US$50,000 in compensatory damages and $250,000 in punitive damages. Attorneys acting for the Church of Scientology had argued that the fair game policy had been canceled, was irrelevant to the suit and had not been applied to Allard. An appellate court, while reducing the amount of punitive charges from $250,000 to $50,000, upheld the verdict against the Church, arguing that the Church had been given ample opportunity "to produce evidence that the fair-game policy had been repealed" but had "failed to do so". In July 1976, the California Supreme Court refused to review the case.
Paulette Cooper, 1976
In Operation Freakout, the Church of Scientology attempted to cause journalist and writer Paulette Cooper to be imprisoned, killed, driven to suicide or committed to a mental institution, as revenge for her publication in 1971 of a highly critical book, The Scandal of Scientology. The Federal Bureau of Investigation (FBI) discovered documentary evidence of the plot and the preceding campaign of harassment during an investigation into the Church of Scientology in 1977, eventually leading to the Church compensating Cooper in an out-of-court settlement.
Department of Health and Social Security (UK), 1979
The Church of Scientology of California sued the Department of Health and Social Security (DHSS) in British courts for defamation. The DHSS had suggested that Scientologists were dangerous charlatans who would worsen rather than cure mental illness. The Church demanded as part of discovery that the DHSS release letters and medical records from people who had complained about the Church. Lord Justice Stephenson declined the request, citing the fair game policy, which he believed still applied despite its name being cancelled. He was concerned that the documents would be used "not for legitimate purposes of the action but for harassment of individual patients, informants and renegades named in them, not only by proceedings for defamation against them but by threats and blackmail."
Lawrence Wollersheim, 1980
See also: Wollersheim v. Church of ScientologyLawrence Wollersheim, a former Scientologist, successfully argued that he had been harassed and his photography business nearly destroyed as a result of fair game measures. These included getting Scientologist employees to resign, and Scientologist customers to boycott or refuse to pay him. The 1986 judgment by a Los Angeles jury was upheld by the California Court of Appeal in 1989. During appeals, the Church again claimed fair game was a "core practice" of Scientology and was thus constitutionally protected "religious expression". The court decided that the Church's campaign "to ruin Wollersheim economically, and possibly psychologically" should be discouraged rather than protected. Twenty years after the start of the case, the Church paid Wollersheim a judgment, with interest, that amounted to $8,674,643.
Jakob Anderson, 1981
In the March 11–16, 1981, Danish court case of Jakob Anderson v. The Church of Scientology of Denmark, ex-Guardian's Office operative Vibeke Damman testified that the Church did in fact practice fair game and had done so in Anderson's case, in an attempt to get Anderson committed to a psychiatric hospital.
Gerald Armstrong, 1984
See also: Armstrong casesIn 1980, Scientologist and Sea Org officer Gerry Armstrong was assigned to organize some of Hubbard's personal papers as the basis for a biography of Hubbard. Omar Garrison, a non-Scientologist known to be sympathetic to Scientology, was hired to write the biography. Both Armstrong and Garrison quickly realized that the papers reflected unfavorably on Hubbard, and revealed that many of Hubbard's claimed accomplishments were exaggerations or outright fabrications. Garrison abandoned the project, and a disillusioned Armstrong and his wife left the Church, retaining copies of the embarrassing materials as insurance against the expected harassment to come. Armstrong was sued by the Church in 1982 for the theft of private documents. The "fair game" policy became an issue in court. Armstrong won the case, in part because the Judge ruled that Armstrong, as a Scientologist of long standing, knew that fair game was practiced, and had good reason to believe that possession of these papers would be necessary to defend himself against illegal persecution by the Church. In a scathing decision, Judge Paul Breckenridge wrote:
In addition to violating and abusing its own members' civil-rights, the organization over the years with its "fair game" doctrine has harassed and abused those persons not in the Church whom it perceives as enemies. was declared an enemy by the Church. He believed, reasonably, that he was subject to "fair game".
— Judge Paul Breckenridge, Los Angeles Superior Court, June 20, 1984
Latey judgment, 1984
A child custody case in London's High Court examined the culture of Scientology to investigate the risks to children being raised within it. Stating his conclusions in a public hearing, Mr. Justice Latey read some of Scientology's internal documents into the record. Despite the alleged cancellation of "Fair game", he reported that, "Deprival of property, injury by any means, trickery, suing, lying or destruction have been pursued throughout and to this day with the fullest possible vigour." As an example, he cited the case of a doctor at Harvard Medical School who at one point was regarded as the Church's "Number One Enemy". The Church had persecuted him by stealing his employment records from a hospital, launching frivolous lawsuits against him and tracking down his patients and neighbors. The Citizens' Commission on Human Rights, which Latey described as "a Scientology 'front'", made multiple complaints of misconduct against the doctor.
Pat Broeker, 1989
In 2009, the Tampa Bay Times reported that after Pat Broeker left the Church of Scientology in 1989 and moved to Colorado, David Miscavige hired private detectives for $32,000 a month. They followed him for the next two decades to Wyoming and ten years in Czech Republic, where he went to medical school and worked as an English teacher. In 2012, Paul Marrick and Greg Arnold, the two private detectives who followed Broeker for 25 years, sued the Church of Scientology for breach of contract when the organization stopped paying them for their investigations.
Pedro Lerma Gámez, 1990
The Dominican cartoonist Pedro Lerma Gámez, known as Petrus, was successfully treated for his drug addiction at a Narconon center in Paris. The Church of Scientology considered that Lerma was not following the instructions of the organization and sent missions to try to redirect him. This included a smear campaign conducted against Lerma by "Judit" and "Greg" and a private detective and former National Police inspector, José Manuel Villarejo Pérez. During their fourth mission, Villarejo introduced a brother-in-law, (with the nickname el Pitrancas and codenamed Hero) to Narconon; the information Hero gathered there made it possible to include the detox center's clients in the smear campaign.
In April 1984 a fifth mission, headed by Rodolfo Sabanero, was aimed at getting Lerma incarcerated. Villarejo brainwashed Juan Carlos Borrallo Rebolledo, a drug addict with a criminal record for robberies who had been treated at Narconon. The plan consisted of Borrallo giving himself up to the authorities (for robbery) and then implicating Lerma in being accessory to a robbery at the Dianetics headquarters. On May 8, 1984, Borrallo appeared at a Madrid police station, admitting to two robberies that he had actually committed (to give credibility to the matter) and of a theft of several E-Meters at the Dianetics headquarters, saying that he was induced to steal them by Pedro Lerma. Another individual, named José Luis Díaz López, conveniently presented himself to police with the same deposition. Villarejo – still having friendly contacts within the police – influenced the development of the police investigation, resulting in Lerma being arraigned and entered in prison with bail being set at 800,000 pesetas. During proceedings, however, the presiding judge, José María Vázquez Honrubia, discovered the smear plot and Lerma was acquitted by the Sixteenth Section of the Madrid Court in 1990.
Richard Behar, 1991
In 1991, investigative journalist Richard Behar wrote "The Thriving Cult of Greed and Power", a Time cover story on Scientology. The acclaimed article won several awards. The Church of Scientology brought several lawsuits over the article, all of which were eventually dismissed. While investigating the story, he experienced some of Scientology's "fair game" tactics:
I later learned, a copy of my personal credit report – with detailed information about my bank accounts, home mortgage, credit-card payments, home address and Social Security number – had been illegally retrieved from a national credit bureau called Trans Union. The sham company that received it, "Educational Funding Services" of Los Angeles, gave as its address a mail drop a few blocks from Scientology's headquarters. The owner of the mail drop is a private eye named Fred Wolfson, who admits that an Ingram associate retained him to retrieve credit reports on several individuals. Wolfson says he was told that Scientology's attorneys "had judgments against these people and were trying to collect on them." He says now, "These are vicious people. These are vipers." Ingram, through a lawyer, denies any involvement in the scam. After that, however, an attorney subpoenaed me, while another falsely suggested that I might own shares in a company I was reporting about that had been taken over by Scientologists (he also threatened to contact the U.S. Securities and Exchange Commission). A close friend in Los Angeles received a disturbing telephone call from a Scientology staff member seeking data about me – an indication that the cult may have illegally obtained my personal phone records. Two detectives contacted me, posing as a friend and a relative of a so-called cult victim, to elicit negative statements from me about Scientology. Some of my conversations with them were taped, transcribed and presented by the church in affidavits to Time's lawyers as "proof" of my bias against Scientology.
— Richard Behar
Carmen Llywelyn, 2002
Actress and photographer Carmen Llywelyn was introduced to Scientology through her partner (and future husband) professional skateboarder and actor Jason Lee. In 2015, Llywelyn penned an article entitled "Why I Left Scientology". According to her account, when she revealed to her talent manager that she had read A Piece of Blue Sky, a book critical of the Church, she was labeled a suppressive person and shunned (or "disconnected") by her Scientologist friends. Llywelyn's manager, a Scientologist, also "disconnected" and allegedly convinced United Talent Agency to drop Llywelyn as a client.
Llwelyn reports being subjected to a campaign of surveillance and harassment. Writes Llywelyn: "Scientology has a sophisticated intelligence agency known as the Office of Special Affairs, which is essentially a complex system dedicated to ruining the lives of those it sees as enemies in any way possible. Those who work for the OSA do not follow the law."
John Sweeney, 2007
Journalist John Sweeney said of fair gaming: "While making our BBC Panorama film Scientology and Me I have been shouted at, spied on, had my hotel invaded at midnight, denounced as a 'bigot' by star Scientologists and been chased round the streets of Los Angeles by sinister strangers." Sweeney also claimed that his family and neighbours had been harassed by unidentified strangers back in the UK, including an intruder at his wedding who fled when confronted.
Mark and Monique Rathbun, 2009
Mark C. "Marty" Rathbun, a former senior executive of the Church of Scientology, left the organization in 2004. A one-hour feature titled Scientologists at War was broadcast on June 17, 2013, on British Channel Four. The feature, a rare insider view of the Church of Scientology, investigated the pressure tactics used by the "Squirrel Busters" affiliated to the organization to discredit and silence members who leave the Church. It highlighted the story of Mark Rathbun, his role in Scientology, his fall out with Scientology leader David Miscavige, his attempts to further the cause of an independent Scientology movement, his confrontations with the "Squirrel Busters" and the repercussions on his family life.
Videographer Bert Leahy reported being paid $2,000 a week by the "Squirrel Busters" to help document their activities. Leahy reported that his employer had "flat-out said our goal is to make Marty's life a living hell".
In 2013, Mark Rathbun's wife, a non-Scientologist, filed suit against the Church of Scientology, alleging four years of harassment by the Church. In October 2014, Rathbun filmed an encounter which he claimed showed three members of the Church's top management as they "ambushed" him at Los Angeles International Airport. The Church defended this activity as being protected by first amendment (religious freedom) and free speech rights. As of January 2016, the court has denied a Church motion to have the case dismissed under anti-SLAPP law, but the ruling that Miscavige must testify in the case was overturned on appeal. After more than 32 months of litigation, Monique Rathbun dropped the lawsuit against the Church, after firing her attorneys in January 2016, due to financial constraints. She filed a motion to end the legal proceedings which the state Supreme court granted on May 6, and Monique Rathbun filed for dismissal on May 10.
Ronald Miscavige Sr., 2012
David Miscavige's father, Ronald Miscavige Sr., was a longtime Scientologist who left the Church of Scientology in 2012. In July 2013, Wisconsin police responding to a suspicious person call found Dwayne S. Powell outside Ronald's home. Powell was in possession of firearms and an illegal homemade silencer. Powell claimed to have received $10,000 a week, for over a year, to conduct full-time surveillance on the elder Miscavige for Scientology. Powell told police that on one occasion, he witnessed what he believed to be Ron Sr. undergoing cardiac arrest. According to Powell, after immediately reporting the perceived emergency to his superiors, he received a call for further instructions from a man who identified himself as David Miscavige. According to the police report, Powell was instructed "to let him die and not intervene in any way."
Mike Rinder and Tony Ortega, 2015
In March 2015, private investigator Eric Saldarriaga pleaded guilty to the federal charge of conspiracy to commit computer hacking after he illegally gained access to at least 60 email accounts. Among those targeted were Mike Rinder, the former spokesman for the Church of Scientology, and journalist Tony Ortega. Both men had participated in the HBO documentary film Going Clear: Scientology and the Prison of Belief.
See also
- Dead agenting
- Mobbing
- Keeping Scientology Working
- Noisy investigation, used by the Church of Scientology to intimidate, harass, and attack their enemies
- Scientology beliefs and practices
- Scientology and law—See the section "L. Ron Hubbard and lawsuits" for more on the "Fair Game Law" as envisioned by Hubbard
- Vexatious litigation
References
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- ^ Urban, Hugh B. (2008). "Secrecy and New Religious Movements: Concealment, Surveillance, and Privacy in a New Age of Information". Religion Compass. 2 (1). Wiley: 66–83. doi:10.1111/j.1749-8171.2007.00052.x. ISSN 1749-8171.
- ^ Streeter, Michael (2008). Behind Closed Doors: The Power and Influence of Secret Societies. New Holland Publishers. ISBN 978-1-84537-937-7.
- ^ Wollersheim v. Church of Scientology, 212 Cal. App. 3d 872 (Cal. App. 2d Dist. 1989)
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- ^ Wollersheim v. Church of Scientology of California, Court of Appeal of the State of California, civ. no. B023193, July 18, 1989
- ^ Sappell, Joel; Welkes, Robert W. (June 29, 1990). "On the Offensive Against an Array of Suspected Foes". Los Angeles Times. p. A1. Archived from the original on March 31, 2015.
Church spokesmen maintain that Hubbard rescinded the policy three years after it was written But various judges and juries have concluded that while the actual labelling of persons as 'fair game' was abandoned, the harassment continued unabated.
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- "Scientology's War Against Judges", American Lawyer, December 1980
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- Leiby, Richard (May 10, 2002). "Ex-Scientologist Collects $8.7 Million In 22-Year-Old Case". The Washington Post. p. A03. Retrieved June 13, 2006.
- "Transcript of testimony of Ms. Vibeke Damman, Oslo". xenu.net.
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- "Judge brands Scientology 'sinister' as mother is given custody of children". The Times. July 24, 1984. p. 3.
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External links
- Scientology's written HCO Policy starting 18/Oct/67 Fair game used in courts and real life
- Eric J. Ascalon: "Dangerous Science: The Church of Scientology's Holy War Against Critics", American Jurist, November 1995, Vol. 9 No. 2
- Robert Vaughn Young "Affidavit regarding fair game", declaration in the case Church of Scientology International v. Steven Fishman and Uwe Geertz, 1994.
- Stephen A. Kent, University of Alberta, Statement on fair game for the Dennis Erlich case, February 1999
- Scientology's Enemies List: Are You On It?