[As part of its legal strategy, FACTNET has contested the validity of the copyright transfers that took place after Hubbard's death. These excerpts are taken from a petition calling for the removal of Norm Starkey as Executor of the Estate due to alleged self-dealing and fraudulent activities before, during and after the creation of Hubbard's final will.]
Click here to read the entire filing in the original format.
DISAPPEARANCE OF L. RON HUBBARD
PURPORTED PRE-TESTAMENTARY ASSIGNMENTS AND OTHER FRAUDULENT AND PURPORTED DEALINGS WITH THE DISPUTED WORKS
THE SUSPICIOUS CIRCUMSTANCES OF L. RON HUBBARD'S DEATH ,AND PURPORTED EXECUTION OF ALLEGED LAST WILL AND TESTAMENT PURPORTEDLY DATED JANUARY 25,1987
THE IMPROPER, UNETHICAL, FRAUDULENT AND CRIMINAL, ADMINISTRATION OF THE ESTATE OF L. RON HUBBARD
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DISAPPEARANCE OF L. RON HUBBARD
12. In or about 1980, Mr. Hubbard went into seclusion and secretly resided in various locations including a ranch near Creston, California where he died on January 24, 1986.
13. Mr. Hubbard's said seclusion was caused, in large part, by the pendency of numerous civil actions, and the threat of criminal and IRS actions, in which he was named, or to be named, as either a defendant, or as one of the defendants. David Miscavige became head of a scientology operation (Project All Clear) organized by the Hubbard Successors, which was intended to remove Mr. Hubbard as a defendant in any legal proceedings so that he could emerge from seclusion. See Berry Decl. Exh. D, p. 4, fn. 5. Notwithstanding, the former President of RTC, Vicky Aznaran, has provided testimony under oath that David Miscavige told her that he never saw L. Ron Hubbard personally during this entire period. Furthermore, Robert Vaughn Young will testify that he went to the ranch where L. Ron Hubbard died, with David Miscavige; Robert Vaughn Young was told that David Miscavige had never visited the ranch before that night.
While in isolated seclusion, Mr. Hubbard was constantly attended by Patrick and Anne Broeker. His principal, and sole, means of communication with the outside world, and the Scientology Organization, was allegedly through David Miscavige. At the time, David Miscavige was a senior executive in ASI. Following the fraudulent transfer of the Disputed Works, David Miscavige became the head of RTC, the head of the Scientology Organization itself and is one of Hubbard's Successors. At all relevant times herein, Norman F. Starkey was a subordinate officer to David Miscavige within Scientology's chain of command, and as such, Norman F. Starkey was David Miscavige's "junior," received orders from David Miscavige, reported to him and was subject to horrendous disciplinary consequences should he not strictly comply with David Miscavige's wishes and whims. For example, in 1986, David Miscavige was apparently chairman of the Board of ASI and Norman Starkey was Executive Director of ASI.
14. In 1979, 1982 and 1983, Mr. Hubbard executed various testamentary instruments and trust agreements making certain provisions for his family, among others. Subsequently, David Miscavige severed all communication between Mr. Hubbard, his wife and family and orchestrated the execution of a new will and trust, purportedly signed one day before death, and its subsequent improper administration, which resulted in a fraud on Mr. Hubbard's wife, family, this Court and other Courts. Mr. Miscavige furthered these wrongful actions by arranging for the appointment of his subordinate officer, Norman F. Starkey, as Executor for the Estate despite the conflict of interest and breaches of fiduciary duty arising from his positions as, among other things, a Trustee of RTC which was a beneficiary of the estate and to which were fraudulently conveyed certain assets of the Estate including the Disputed Works.
15. Beginning in 1982, David Miscavige claims to have personally witnessed and notarized assignments of the Disputed Works to the Hubbard Successors which include himself. However, as referenced in paragraph 18 herein, former RTC President Vicki Aznaran has testified that David Miscavige had said to her that he never personally saw L. Ron Hubbard during these years. In any event, these various assignments, on their face, and in light of various surrounding circumstances, raise various serious issues of validity and capacity (for both Mr. Hubbard as to cognitive capacity and David Miscavige because of his inherent multiple non- waivable conflicts of interest) including improper notarization, fraud, duress, undue influence, inurement, conspiracy to defraud creditors, etc. Berry Decl. Exh. C, pp. 21-28.
16. Attached to the supporting Declaration of Graham E. Berry, as Exhibits J to N, are copies of:
(a) Assignment Agreement (L. Ron Hubbard/RTC).
Exhibit J.
(b)Churchof Spiritual Technology letter dated May 21, 1987 and attaching certain agreements. Exhibit K.
(c) Copyright license agreement between Church of Scientology of California and L. Ron Hubbard, effective as of April 1, 1982. Exhibit .
(d) Assignment Agreement between L. Ron Hubbard and Religious Technology Center purportedly made May 16, 1982. Exhibit M.
(e) Assignment Agreement between L. Ron Hubbard and Religious Technology Center relating to trade marks. Exhibit N. 17. These exhibits, among other things, raise the following observations, issues and questions. Exhibit J states that it was entered into on May 16, 198_. However, just below L. Ron Hubbard's signature on page 6, the document states that it was notarized on May 10, 1982. The notary public is David Miscavige. At the time, David Miscavige was a Trustee of RTC which is the beneficiary of the alleged assignment agreement. At the time, Norman F. Starkey, the Executor of the L. Ron Hubbard Estate was also a trustee of beneficiary RTC. In addition, David Miscavige was Chairman of the Board of ASI and Norman Starkey was his subordinate as Executive Director of ASI. The function of ASI, among other things, was to administer Mr. Hubbard's copyrights. Berry Decl. Exh. O. The document also contains an addendum which states that it is effective January 19, 1982 and modifies the document which purports to be notarized on May 16, 1982. This Agreement raises a number of issues including: the purpose of the addendum beingattached since it has no effect on the Agreement and is not incorporated by reference; why the original Agreement of January 1, 1982 was modified only 18 days later; and why the "2s" on pages 6 and 7 of the Agreement appear to have been originally "7's" that were fraudulently altered. Bearing in mind that L. Ron Hubbard died in 1986, this appears especially noteworthy.
18. The same document (Exhibit J) is attached to a letter from one of Hubbard's Successors (CST) to the IRS dated May 21, 1987. Berry Dec. Exh. K. This letter raises even more serious questions regarding the suspicious circumstances of L. Ron Hubbard's death, the execution of the various purported assignments and agreements, and the testamentary disposition of the copyrights and other items of intellectual property. In the letter, one of Hubbard's Successors states to the IRS that they made a mistake when they submitted the assignment agreement "Mr. Hubbard proposed to enter into with RTC on May 10, 1982 . . . in fact, Mr. Hubbard and RTC did not execute the proposed agreement." In summary, it now appears that this agreement, notarized by David Miscavige, concerning assets that belonged within the L. Ron Hubbard Estate, was never executed while L. Ron Hubbard was alive and that therefore Hubbard's Successors, including David Miscavige and Norman Starkey (the Executor herein) and Sherman D. Lenske, Esq. have engaged in numerous acts of perjury and fraud relating thereto.
19. Berry Declaration Exh. L is a copyright license purportedly executed by L. Ron Hubbard on May 10, 1982 but, unlike the other documents, was not notarized. Under the circumstances, this also raises questions for judicial inquiry.
20. Berry Declaration Exh. M purports to be a "assignment agreement (LRH/RTC ((Marks) dated on its face 18 May, 1982. Again, the handwritten "2" of 1982 on page 10 appears to be a modified or fraudulently altered "7".
21. Berry Declaration Exhs. J, L., M and N raise particular concern when, in connection to the proposedPetition for Quiet Title, Petitioners will include testimony, given under penalty of perjury, that David Miscavige possessed blank sheets of paper bearing the signature of L. Ron Hubbard. Furthermore, a prior president of RTC, Vickie Aznaran, who later escaped from the Rehabilitation Project Force at Hemet and sued Scientology, has testified under penalty of perjury that David Miscavige told her that he did not see L. Ron Hubbard from 1980 through to the date of his death. This raises serious questions of extrinsic fraud and serious questions as to the validity of various documents, including those relating to the Disputed Works, and now being relied upon RTC, BPI, David Miscavige and Norman Starkey who each had integral roles in the apparent fraudulent conduct relating to, among other things, the fraudulent handling of the Disputed Works in connection with the Estate herein. In addition, Vicki Aznaran also testified under penalty of perjury that she knew that David Miscavige had entered a false notarized document into the probate estate of L. Ron Hubbard.
22. Berry Declaration Exh. N is pertinent to the questions raised in the preceding paragraphs. Pages 1, 2 and 3 of Exhibit N are identical to pages 1, 2, and 3 of Exhibit J. However, page 4 of Exhibit N is drastically different than page 4 of Exhibit J. Moreover, page 5 of Exhibit N, although different in content, ends in exactly the same place as page 5 of Exhibit J. Page 6 of Exhibit N is identical to page 6 of Exhibit J, but with the exception of the fact that it isn't signed by L. Ron Hubbard and it doesn't have the date of the notary public filled in. Obviously, these are matters for serious consideration, not only by the Court but also by a questioned document examiner, especially because of the improbability of a page of a document being revised, retyped and still having the exact words in the exact sequence at the exact place on the final page of the document.
23. For many years prior to his death, Mr. Hubbard ingested various drugs, many of them allegedly hypnotic and psychiatric drugs, and other medications which were administered by certain assistants of Mr. Hubbard, such as a certain Andre Tabayoyon and Kim Douglas, whose testimony will be submitted with the Petitions sought to be filed herein. One of Mr. Hubbard's own sons has also testified to these facts in prior proceedings.
24. During the two years before his death, a Dr. Gene Denk was in constant attendance upon Mr. Hubbard on a full time basis. Dr. Gene Denk is understood to be a duly licensed California physician.
25. Approximately two weeks before Mr. Hubbard died, Dr. Denk left Mr. Hubbard's side in Creston, California and went on a gambling trip to Reno/Lake Tahoe, Nevada accompanied by his wife, Terri Gamboa, Rick Aznaran, and David Miscavige. In essence, it appears that L. Ron Hubbard's medical support was intentionally withdrawn from him. Prior to this gambling expedition, David Miscavige was reported in prior testimony as stating, in effect, "the IRS indictments are about to come down. The only thing that will save us now is if the Old Man dies." During their absence in Reno, Nevada, Mr. Hubbard suffered a crippling stroke. Upon information and belief, Mr. Hubbard received no medical attention from any physician licensed to practice in California, until Dr. Denk returned from Reno, Nevada. Dr. Denk had prescribed and administered a number of drugs to Mr. Hubbard, including the psychiatric drug Hydroxyzine (Vistaril) which is usually administered in combination with other hypnotic, psychotic and sedating narcotics and restricted drugs. Indeed, the Coroner's report indicates that there were "ten recent needle marks" in "the right gluteal area" of the dead body.
According to Dr. Denk's statement to the Coroner, Mr. Hubbard also had a "long history of chronic pancreatitis" (which is primarily cause by alcoholism) and a recent history of "dysphrasia." According to the Coroner, Dr. Denk also told the Coroner "of decedent's clinical history which supported a possible neurological problem;" thereby raising issues of cognitive capacity which Mr. Hubbard's personal representatives such as Norman F. Starkey, Sherman D. Lenske, Esq., and Earle Cooley, Esq. should have brought to the attention of this Court. Berry Declaration, Exhibit A, "Investigation," "Report on "Toxicology Report" Post Mortem Examination,
26. Mr. Hubbard's 1979, 1982 and 1983 testamentary instruments made no disposition of any copyrights which cannot, as a matter of law, be transferred by will. In addition, Mary Sue Hubbard had/has a fifty percent community property interest in each of these copyrights.
27. Immediately prior to Mr. Hubbard's death, Dr. Denk, Pat Broeker, Anne Broeker, Steven Pfauth, Ray Mithoff, and possibly others, were in attendance with Mr. Hubbard. All of them are within the group defined herein as Hubbard's Successors as defined in paragraph 3 herein.
28. Upon information and belief, neither Mr. Hubbard's wife, Mary Sue Hubbard, nor any of his children were present at the time of his death, were not advised of his ailing health and imminent demise, and the Hubbard Successors purposefully deprived the Hubbard family of the opportunity to be with him at his death bed. One day before he died, with his cognitive capacity in serious question, Mr. Hubbard purportedly signed a new will and trust agreement providing, among other things, for purported transfers of the Disputed Works to the Hubbard Successors, and which made certain lesser testamentary provisions for Mr. Hubbard's wife and certain of his children. Significantly the inherently suspect alleged last minute will, for the very first time, purported to unlawfully transfer the Disputed Works to the Hubbard Successors notwithstanding the community property interest of his wife who had been married to him when each of the Disputed Works were allegedly written by Mr. Hubbard alone. David Miscavige and Dr. Denk misrepresented the significance of the differences between the purported January 23, 1986 Will and the earlier testamentary instruments. Berry Decl. Exhibit A, Investigation Report, page 4, 2nd full para. Clearly, those misrepresentations of David Miscavige and Dr. Denk misled the coroner into concluding that there was no reason or motive to suspect foul play and therefore no need to investigate further. Upon information and belief, David Miscavige, Norman Starkey, and others participating provided no opportunity for any of the Hubbard Family members to be involved in these events.
29. The Coroner was unable, and not permitted, to conduct an autopsy of Mr. Hubbard's body. Mr. Hubbard's death was not reported to the authorities for many, many hours until attorney Earle Cooley, Esq. had traveled from Boston, Massachusetts to the ranch at Creston, California, had assessed the situation and then notified a funeral home which became suspicious as a result of the delay in reporting the death, and alerted the Coroner. Berry
The provisions of the 1986 will are generally described on pages 6-8 of the draft Memorandum of Points and Authorities attached to the supporting Berry Declaration as Exhibit C.
30. Following the brief investigation on January 25, 1996, the body of L. Ron Hubbard was released to the custody of David Miscavige "Representative of the Author Services in Los Angeles." Berry Decl. Exh. A. "Investigation," page 4. The body was immediately cremated, within 24 hours of death, and the ashes scattered at sea. See generally, Berry Decl. Exh. S. Extracts from "A Piece of Blue Sky."
31. The following issues of fact, for judicial inquiry, are raised primarily by documents on this Court's file:
(a) Attachment 8 to the Notice of Death of L. Ron Hubbard filed February 5, 1986, contrary to its contents, was not served on all of Mr. Hubbard's heirs.
(b) Norman Starkey's February 5, 1986 declaration evidences the inherent multiple conflicts of interest of David Miscavige, senior executive in ASI and subsequently senior executive in RTC, Norman Starkey's superior in the Scientology Organization and ASI, a trustee of RTC, in the various roles he assumed in relationto the pre-testamentary purported assignment of the Disputed Works and the purported testamentary transfer of the Disputed Works to the Hubbard Successors of which he was one. In addition, David Miscavige had previously removed Mary Sue Hubbard as Controller of Scientology and had in effect placed her under house arrest and constant surveillance through three household staff members who report to David Miscavige. This situation continues today. Indeed, less than one week, ago fearful that Petitioners would manage to contract Mary sue Hubbard, David Miscavige and/or others of Hubbard's Successors had her telephone number changed. Surveillance was increased and Suzette Hubbard was moved from her home to Scientology's Celebrity Center where Hubbard's successor would be able to more effectively prevent Petitioners from contacting her, arranging her "joinder" or serving her.
(c) As Executor and Personal Representative of the L. Ron Hubbard Estate, Norman Starkey himself had multiple material and undisclosed conflicts of interest arising from his position as a trustee of RTC (a principal, and later the sole, beneficiary of the Estate), a subordinate Scientology officer to David Miscavige, by virtue of his position below David Miscavige at Authors Services and his inferior rank with the Scientology Sea Organization, and his former corporate and ecclesiastical position(s) in relation to Mary Sue Hubbard and other Hubbard family members and heirs.
(d) Mr. Hubbard's estate planning attorney, Sherman D. Lenske, Esq.'s February 4, 1986 declaration, is in material contradiction of more recent declarations he has filed in connection with litigation involving the Petitioners andothers. in addition, Sherman D. Lenske, Esq. had undisclosed multiple and non-disclosed conflicts of interest in that he is also the registered agent for service of process on RTC, one of the principal, and later the sole, beneficiaries of the Estate of L. Ron Hubbard. Sherman D. Lenske, Esq. was/is also an attorney for RTC and received/receives benefits from RTC in the form of fees, etc. Sherman D. Lenske, Esq. is an attorney at law practicing within the jurisdiction of the California Courts.
(e) Although Mr. Hubbard alleged in his January 23, 1986 will that Alexis Hollister was not his heir, in his December 15, 1979 will he recognized her as an expressly disinherited "heir." According to the Probate files herein, no notices or documents herein were ever served on Ms. Alexis Hollister. In addition to Alexis Hollister, L. Ron Hubbard also disinherited his eldest son. According to the investigative writings of Mr. Jon Atak, both of these disinherited children "were later paid settlements ....Secret provisions were made for" other family members. Berry Dec. Exh. S, p. 356. None of these settlements or other provisions were entered into with involvement, knowledge or approval of this Court and no receipts have been filed in relation thereto.
(f) The February 4, 1986 declarations of Mary Sue Hubbard, Arthur Ronald Conway Hubbard, Diana Meredith DeWolf Hubbard Ryan and Mary Suzette Rochelle Hubbard raise serious and fundamental issues concerning their receipt of any legal counsel, let alone independent legal counsel, regarding their statutory rights in the Disputed Works, and their receipt of any bequests provided for them under the terms of the January 23, 1986 Trust Agreement and the previous wills and trust agreements. Upon information and belief, at least one of these family members was not permitted to read the declaration, the will, the Trust Agreement, or any other papers relating to the death and probate, was ordered to sign them, by a representative of David Miscavige,( who also held full power and authority over Norman F. Starkey), and has received no disposition of any property under the will and Trust and has made no knowing waiver of any rights relating thereto. The only benefit that child has received has been $190,000 which was paid from Mary Sue Hubbard's own funds. Upon information and belief, Mary Sue Hubbard resides in virtual house confinement accompanied, at all times, by at least three employees of Hubbard's Successors personally approved by David Miscavige and Executor Norman F. Starkey, receiving orders from them and reporting to them.
(g) Although Mr. Hubbard's last will acknowledges express provision for his wife and certain of his children under the terms of the Trust, Norman F. Starkey, the estate's executor, later claimed, in the Report of Executor and Waiver of Accounting filed December 15, 1988, that the final Trust provided for the distribution of the entire Trust estate to RTC, other Scientology entities and the Hubbard Successors who/which include the various witnesses and notaries to the relevant assignment and testamentary instruments. No evidence is on the Court file as to any waiver or consent by the Trust beneficiaries to such a transfer in its entirety. Furthermore, there is no document on the Court file evidencing that Mary Sue Hubbard and each of the Hubbard heirs (whether disinherited or not) had been apprised of their statutory rights in connection with either their community property rights, inheritance rights or any other rights in connection with the copyrights, Disputed Works and other intellectual property assets of Mr. Hubbard. In addition, there is no evidence that any of them knowingly waived those rights after receiving truly independent legal counsel. L. Ron Hubbard and Mary Sue Hubbard were married for 34 years and all of the Disputed Works were written during the marriage and subject to Mary Sue Hubbard's community property interests. Notwithstanding, paragraph 11 of the Report to Executor waiver of Accounting filed December 15, 1988 that "the whole of the estate is decedent's separate property." Nothing further has been filed in relation thereto.
(h) In 1987, the executor, Norman F. Starkey, valued the copyrights at $25 million. Upon information and belief, those copyrights and other intellectual property assets, which include the Disputed Works, are producing income to the Hubbard Successors of annual amounts many times that figure. Accordingly, the potential fraud upon the Estate, Mr. Hubbard's family, the IRS, the Federal and State government, and the Petitioners herein, involves many, many hundreds of millions of dollars. Indeed, in 1993, RTC filed a IRS 501(c)(3) application reporting approximate annual royalty income from the Disputed Works in the amount of $42 million. Thus, the potential amount of this massive fraud, over the relevant eleven year period, is at least $462 million.
(i) On February 4, 1986 Daniel J. Przybriski filed a declaration herein as to the disposition of Mr. Hubbard's purported life's work to the Church of Spiritual Technology, on eve of his death, seven days after suffering a crippling stroke while on the hallucinogenic drug Vistaril and without receiving immediate California licensed medical attention, while continuing to receive hallucinogenic and psychiatric drugs, and having "a possible neurological problem" as reported by Dr. Denk to the Coroner.
(j) On May 9, 1986, executor Norman Starkey executed a petition for extension of time to file an inventory of the purported copyrights (including the Disputed Works) within the estate. Norman Starkey claimed that the extension of time was required "to analyze the legal basis of the copyrights, which are the Disputed Works in connection with which Petitioners are being sued by RTC and BPI (two of Hubbards' successors).
(k) The probate court files include the filings of dozens of creditors' claims, alleging serious tortious misconduct, and totalling, in the aggregate, many hundreds of millions of dollars. According to Norman F. Starkey's Report filed herein on December 15, 1988, these various claims were later withdrawn on various dates in December 1986 without any indication of how those claims had been settled. Indeed, not all of the claimants, potential claimants and relevant litigants, (such as Gerry Armstrong and Lavenda Van Schaick) are even included in Norman F. Starkey's relevant report. In fact, and on information and belief, the Hubbard Successors entered into three group settlements in Boston, Florida and California and paid a sum of between $5 and $25 million in connection with the settlement of these various claims. This Court's authority was not sought in this regard. Indeed, no papers, reports or authority were filed or sought in this regard. In addition, the various settlement agreements contained provisions which, as far as the attorneys were concerned, represented egregious breaches of fiduciary duties and ethical conduct.
32. On April 10, 1987, Norman F. Starkey filed an Inventory and Appraisement specifying a total L. Ron Hubbard estate value of $26,305,706 of which the posthumous copyright and other intellectual property claims were valued at $25 million.
33. On December 5, 1986 Warren McShane, one of Hubbard's Successors, and a subordinate Scientology officer to Norman F. Starkey, executed a declaration for filing in this matter relating to the posthumous copyrighting of certain of the Disputed Works.
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38. In addition to the matters set forth in the above discussion of the Church of Scientology's criminal history, the need for special protective orders herein is supported by, inter alia, the destruction of Exhibits and Depositions herein pursuant to Order dated May 1, 1996, after questions began being asked regarding the involvement of David Miscavige in these matters. Petitioners, among others, had raised such questions in connection with the litigation the Hubbard successors had filed against them regarding the Disputed Works. Earlier, during the pendency of Wollersheim I and Wollersheim II litigation, the Executor herein, Norman F. Starkey, also arranged for evidence in the San Luis Obisbo County Coroners' files to be destroyed. Berry Decl. Exh. A, October 4, 1989 letter from Ogle & Merzon to Sheriff Williams.
39. David Miscavige and the other Hubbard Successors, as a result of informal notice of these proceedings, have engaged in activities clearly intended to intimidate and harass testamentary witness Pat Broeker. Berry Declaration, Exhs. Q and R. The same investigators, such as Eugene Ingram, were also deployed by David Miscavige to intimidate certain federal government officials. Berry Declaration Exh. X.
40. Limited discovery in relation to the proposed Petition for Appointment of Neutral Executor, CTA and the Petition for Quiet Title, will include depositions of Mary Sue Hubbard and each of the surviving Hubbard children and relatives. In addition, there must be depositions of all, or some of, David Miscavige, Norman F. Starkey, Dr. Gene Denk, Sherman D. Lenske, Esq., Lyman B. Spurlock, Ray Mithoff, Pat Broeker, Anne Broeker, Steven Pfauth, Daniel J. Przybriski, Vicky Aznaran, Joseph A. Yanny, Esq., Earle Cooley, Esq., R. Vaughn Young, Andre Tabayoyan, Diana Voegeding, Gerry Armstrong, Kim Douglas, Terri Gamboa, Rick Aznaran, the San Luis Obispo Coroner at the time of death and all involved official personnel and such others who may be deemed appropriate, and the immediate production of all the originals of all relevant documents. Accordingly, Petitioner's request an order that the Hubbard Successors, including but not limited to Norman F. Starkey, not have any communication of any nature with Mary Sue Hubbard or any of the surviving children or family of L. Ron Hubbard, pending the taking of discovery herein and the disposition of Petitioner's Petition for Appointment of Neutral Executor CTA and Petition for Quiet Title. In this regard, the Court is referred to Exhibits Q and R to the supporting Declaration of Graham E. Berry, which indicates the surveillance, intimidation and harassment of crucial witness Pat Broeker by Scientology private investigator Eugene Ingram -- acting on behalf and in the interests of David Miscavige. Upon information and belief, another crucial witness, Anne Broeker, has been held in solitary confinement in Scientology's Rehabilitation Project Force at the Scientology base at Hemet, which is also under the command of David Miscavige and Norman Starkey. In addition, David Miscavige and Norman F. Starkey are believed responsible for initiating the security measures responsible for initiating the security measures, referred to paragraph 28(b) herein, regarding Mary Sue Hubbard and Suzette Hubbard. This is an obvious attempt to thwart and obstruct justice and these proceedings.
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