CRC 98-20377 CFANO-S



Filed MAR 29 2000


Proposed amicus curiae is a member of the Board of Directors of the Church of Scientology International, the Mother Church of the Scientology religion, and is joined by the ecclesiastical leaders of the churches of Scientology in the United States and in more than 100 other countries. Our religion, our churches, and our congregants have been directly and adversely affected by a great injustice brought about by the charges filed in this case. Our churches have been vandalized, our parishioners assaulted, our reputations defiled, and our, faith vilified because the State of Florida has chosen to target our religion in an unprecedented prosecution. Criminal acts are committed against us and our congregants every day by ignorant people who have been inflamed by lies and


reassured by a perceived alliance with authority that these charges have engendered.
That a nation founded on the very principle of freedom from government oppression of minority religions has chosen this church - in fact, this religion - to prosecute, is an outrage to its heritage. The prejudice has spread far beyond Pinellas County, the State of Florida or even the borders of the United States and fosters the violence and bigotry our churches and adherents are enduring around the world.
The profound and damaging impact addressed below is not a mere collection of allegations such as those proffered by the prosecutor against our religion. Rather, we submit numerous sworn affidavits that reflect the scope of the hatred unleashed by this prosecution in many locations in the United States, as well as in Australia, Italy, Germany, Austria, Denmark, Belgium, France, England, Canada, and in other nations around the world where our members seek peacefully to practice our faith.
A great deal of time and effort has been expended just to maintain relations with our local communities in the face of these charges. Creating and maintaining an environment where our churches can conduct their activities in peace and without constant rebuke and the threat of physical violence, has been an enormous task not just in the local area, but as a result of the State's charges, in virtually every land around the globe.
We file this amici curiae brief to inform the Court of the repercussions of this prosecution and the harm it has engendered around the world, and to petition the Court to restore justice and reason to these proceedings through dismissal of this action.



The executives of churches of Scientology other than the defendant, Flag Service Org, submit the instant memorandum for the Court's consideration, addressing the effects upon our congregations around the world.
The Scientology religion has been called the fastest-growing religion in the world. This is not surprising, because Scientologists take their religion seriously and they take very seriously their responsibility for what happens to our world. We are not engaged in the promulgation of our religion as executives and ministers of our churches for lack of other employment or because we were necessarily born into this faith. Each of us has a duty and a trust to help create a sane, happy and productive civilization through application of the principles of our religion. We are totally committed to our mission and assisting our parishioners to achieve the spiritual enlightenment and the freedom we know is available through Scientology.
However, this prosecution attempts to place us in fear of the consequences of the very practice of our religion. In the face of these charges, can we be sure that providing any of our religious services to the members of our faith will not result in prosecution because some zealot in a government agency disagrees with our beliefs? Can any of us be sure that if one of our parishioners in the future needs an Introspection Rundown, it will not result in our Church being charged? The answer is, of course, no. And that is an intolerable result.
The allegations of the prosecutors, now spread around the world, have made our religious endeavors increasingly difficult. Haters and bigots have rallied around the false allegations regarding Lisa McPherson in an unsettling and often dangerous way. Criminal charges against a church have seemingly


galvanized the latent hostility all young religious movements confront, and liberated the prejudices of people with nothing in common other than wishing to harm members of our religion. It has resulted in the promulgation of 55 Internet sites concerning Lisa McPherson, proclaiming "Scientology kills." It has resulted in death threats against the ecclesiastical leader of the religion and other church officials.
In nearly all instances, those attacking our churches and parishioners have no firsthand knowledge concerning our religion, its precepts, or its activities. They know nothing about Lisa McPherson other than what they have read in alarming media accounts mimicking irrational protestors or Internet hate pages. The vile allegations thus spread are given great credence by others inclined to distrust, intolerance or hate, as seen in our accompanying Affidavits. Day after day, media in our local cities and countries have attacked us and the entirety of our religion because of allegations against a church in Florida, regarding a parishioner we never knew or had even heard of prior to the filing of criminal charges. For example:
- At the Founding Church of Scientology in Washington, D.C., there have been many demonstrations by hate-mongers holding large signs with photographs of Lisa McPherson, stating, in part, "Scientology's Cure for Mental Illness - Murder." The pickets have attracted violent groups who have joined the fray including members of the "Utopian Anarchist Party." This fanatical organization has included a section on Scientology on its Internet web page, next to instructions on how to build bombs and suggestions on killing police and bombing schools. The Washington, D.C. demonstrators also include members of an anti-Semitic, neo-Nazi organization called Liberty Lobby, whose newsletter, The Spotlight, has published more than 50 stories regarding Lisa McPherson and Scientology. (Ex. A, Affidavit of Susan Lee Taylor.)


- Churches of Scientology in Australia have been besieged by violence and propaganda regarding allegations concerning Lisa McPherson. In Canberra, demonstrators carry the typical "Scientology Kills" signs and leaflet the area around the church with commentary on "how the Church of Scientology killed Lisa McPherson." (Ex. B, Affidavit of Sue McClintock.) Similar demonstrations occurred in Melbourne, Sydney and other Australian cities. (Id.) Following one of the demonstrations in Melbourne, passers-by yelled obscenities in the door and the 62 year old female Executive Director of the Church was physically assaulted by one of the hoodlums who came into the church. (Id.) Thereafter, the Melbourne church experienced repeated acts of vandalism, anti-Scientology graffiti, damage to book stocks, smashed windows, other property damage and physical assaults on church staff. (Id.) In Perth, in Western Australia, a man demonstrating regarding Ms. McPherson publicly posted on the Internet threats of violence against the Church, including an intention to shoot Scientologists. He also confessed to the local police that he had been engaging in acts of vandalism against the churches. (Id.)
- In Austin, Texas, the local church has been the target of picketers and graffiti regarding Lisa McPherson, including accusations that "Scientology Kills" and providing the address of an anti-Scientology web site regarding Lisa McPherson. The graffiti has been accompanied by vandalism at the church and eggs thrown at the church windows. (Ex. C, Affidavit of Daniel L. McMurrough.)
- In Edmonton, Alberta, Canada, numerous articles and public commentaries were made regarding Ms. McPherson, including leafleting at bus stops with false and disgusting allegations regarding her death. Protestors have disrupted meetings, blocked the church entrance, upset family relationships and disrupted public events. On Christmas Eve, 1999, a vandal scratched the words, "Lisa McPherson", on the front window of the church. (Ex. D, Affidavit of


Deborah Jurt.)
- In Copenhagen, Denmark, there have been several TV shows and articles in the local papers regarding the allegations that the church killed Ms. McPherson, as well as numerous anti-Scientology demonstrations at the local church. A member of parliament with jurisdiction over the local church's pending application for permission to perform marriages, attacked in Parliament the treatment by the Church of Scientology of sick members, based on these allegations. (Ex. E, Kama Jensen.)
- In Brussels, Belgium, the false statements regarding Ms. McPherson were expanded even beyond the allegations of the prosecutors in this case, through a television broadcast that called Ms. McPherson's death a homicide. (Ex. F, Affidavit of Marc Bromberg.) This sort of exaggeration of the allegations is both predictable and prevalent in foreign countries where the Pinellas County prosecutor's allegations - scurrilous and inflammatory enough in their own right - are intentionally or carelessly mistranslated.
- Boston, Massachusetts is the home of Robert Minton, the financier and investor in the civil case arising out of Ms. McPherson's death with which the prosecutor here is apparently coordinating his efforts. The Boston church has been the target of many demonstrations, derogatory media, and acts of violence. The night after an appearance by Minton on a local radio show in 1998 repeating the false allegations of this case, a five-pound rock was thrown through the local church's front window. The window was repaired and another rock thrown through the same window the next day. Thereafter, an Associated Press article datelined Clearwater in November of 1999, was republished in Boston, announcing the establishment of the "Lisa McPherson Trust," a for-profit corporation owned by Minton and repeating the most lurid of the allegations regarding Ms. McPherson. That week, a bullet was fired into the church.


Fortunately no one was injured. (Ex. G, Affidavit of Suellen Burkey.)
- In Orange County, California, an article ran in late 1997 in the local newspaper regarding Ms. McPherson and engendered the ensuing hate crimes against the local church. Picketers at that time and since have carried hate messages such as "Scientology Kills" and "On Trial for Murder in Florida." Immediately thereafter, the church received anonymous calls stating that the church would be set on fire. (Ex. H, Affidavit of Edwin Dearborn.)
- The Los Angeles area has been a particular target of these hate crimes, as it contains the largest population of Scientologists in the world. Frequent pickets have been staged there at events and church holiday gatherings, causing upset to Scientologists and their families and disruption of activities. The demonstrations arose out of the allegations in this case and were organized by anti-Scientology hate groups via the Internet. Those demonstrations, which include taunting of parishioners and at least one "hanging in effigy," then generate news articles in a vicious circle which expands the allegations even further. For example, one local LA "radical" paper published photographs of a demonstrator with a sign stating, "Scientology Hurt Lisa McPherson . . . Who Will Be Next?" and new demonstrations immediately followed. As is typical of nearly all of the churches outside Clearwater, the staff and its members in Los Angeles did not even know Ms. McPherson or know any of the details of this case. Nevertheless, they have been harassed and threatened by the protestors as if all Scientologists had some personal responsibility for an unproved "crime." (Ex. I, Affidavit of Jeanie Ibert.)
- Our churches in Northern California have also been the repeated targets of malicious demonstrations and media reports concerning the allegations of this case, which have caused numerous upsets among Scientologists, their friends and relatives. Picketers have positioned themselves outside one church where they have sought to dissuade members or interested persons from entering. (Ex.


J, Affidavit of Sandra Jesse-Figueroa)
- The church in San Jose, California has been located in the same building for 20 years, and has established very good relations with its neighbors over that period. However, after the publication of scurrilous allegations regarding this prosecution in 1997, haters sought to damage this relationship with the persistent display of "Scientology Kills" picket signs, and repeated harassment of church staff and the neighbors of the local church. Immediately following one of the demonstrations, a church staff member ate at the restaurant next door to the church and received in his change, a dollar bill with the phrase, "Scientology Kills" stamped on it. (Ex. K, Affidavit of Janice Silber.)
- The Church in Toronto, Canada has also been the target of a particularly large number of hate crimes and harassment since the McPherson allegations were made public and disseminated in the media. These acts of harassment included photographing children at Church charitable events which were later posted to the Internet, photographing and posting pictures of staff on the Internet, bursting into the church premises and loudly shouting to keep the staff "edgy," spray painting "Scientology kills" in the neighborhood, posting the same statement on neighborhood bulletin boards, and making threats of violence. (Ex. L, Affidavit of Janet Kenyon Laveau.) Some haters have posted statements on the Internet relating to the Toronto Church following these demonstrations, stating, "You pieces of shit have got to go. GET OUT OF TORONTO!" (Id.) Another stated, "I won't shed a tear if someone does a 'Columbine High' on these people. Why did it have to be KIDS and not some filth like Scientology. The world would be a nicer place." (Id.) Disgusting and inflammatory articles ran in the media following these events denigrating Scientology. (Id.) Many other incidents of a similar or identical nature occurred throughout the world, including in Nevada (Ex. M, Affidavit of Mary Gay); Munich,


Germany (Ex. N, Affidavit of Johann Altendorfer); Milano, Italy (Ex. O, Affidavit of Bruno Cestari); Brescia, Italy (Ex. P, Affidavit of Maria Luisa Franchi); Vienna, Austria (Ex. Q, Affidavits of Johannes Silli and Elfriede Fasching); Vancouver, British Columbia, Canada (Ex. R, Affidavit of Anne Byrne); New York City (Ex. S, Affidavit of John Carmichael); Philadelphia, Pennsylvania (Ex. T, Affidavit of Bonnie DiMartino); Salt Lake City, Utah (EX. U, Affidavit of Judy Steed); San Jose, California (Ex. V, Affidavit of Joy Botelho) and Sussex, England (Ex. W, Affidavit of Graeme Wilson).
There are many more affidavits which have been collected recently from other churches in the United States not mentioned above, including Ann Arbor, Michigan; Phoenix, Arizona; Honolulu, Hawaii; Boulder, Colorado; Buffalo, New York; Chicago, Illinois; Cincinnati, Ohio; Coral Gables, Florida; Dallas, Texas; Los Gatos, California; Nashville, Tennessee; Orlando, Florida; Santa Barbara, California; St. Louis, Missouri; Portland, Oregon; Denver, Colorado; Detroit, Michigan; New Haven, Connecticut; Palo Alto, California; San Diego, California; San Francisco, California; and Seattle, Washington (see collected Ex. X), as well as other countries, including Switzerland, Germany, Italy, Australia, Sweden and France. These additional affidavits recount similar horror stories of hatred and bigotry arising from the allegations of this case which are repeated throughout the world.
The snippets and summaries of information above cannot do justice to the extent of actual harm and disruption caused to Scientologists around the world by the broad and inflammatory dissemination of allegations of the prosecutors and their civil co-conspirators concerning Lisa McPherson. We do not address here the base lies that our religion would ever harm or condone harming a member. But they are base lies. Our religion has the sole purpose of helping our civilization, including every man, woman, and child on this planet, including


Scientologists and even those who attack us.


Perhaps most disturbing is the effort of the prosecutor to justify his action by attempting to portray our religion as something it is not. In fact, he argues Scientology is not a religion, and among other things, that we do not believe in God, we do not carry out the traditional role and duties of other mainline faiths, and we should not be afforded the same treatment as his religion. All of the Prosecutor's assertions are false. Apart from the myriad of precedents in courts and with governmental agencies around the world that highlight the absurdity of his assertions, we also attach for the Court's information and review, The Background, Ministry, Ceremonies and Sermons of the Scientology Religion.
Our belief in an ultimate creator and necessity for all to reach toward God are evident in the words of our Founder:

When a culture has fallen totally away from spiritual pursuits into materialism, one must begin by demonstrating they are each a soul, not a material animal.

From this realization of their own religious nature individuals can again come to an awareness of God and become more themselves.

See quote at forward and also see The Scientology Prayer For Total Freedom, pages 46 and 47.
o The prosecutor offers a distorted picture of Scientology while then
attempting to distinguish it from religions he considers "valid." What is clear is
the prosecutor lacks anything but a shallow knowledge of religions across this
planet and throughout history. See The Religious Background of Scientology, page 7.


o The prosecutor gives a distorted account of the history of the formation of
the Scientology religion itself. Born in the 20th century, Scientology has evolved
from its earliest days to what it is today. There is nothing unusual about that.
Mr. Hubbard's life's work was the search for the ultimate answers to life, with
many discoveries throughout the years. The prosecutor misinterprets this
evolution by pulling individual writings out of context, giving his interpretation
as to our beliefs and practices and even suggesting he is attempting to make us
comply with our own religious policies. Yet when understood in context, one
sees the evolution of the religion with each new discovery building upon the
previous, from the publication of Dianetics in 1950, to the end of Mr. Hubbard's
life in 1986. See Fundamentals of tire Scientology Religion, page 15.
o As for our sincerity in our beliefs, Scientologists consider their religion a
much greater part of their life than those who merely worship on Sunday. In
fact, we believe that the decline of civilization can be traced to the loss of spiritual
and religious values across the world. Unlike many other religions, we believe
all religions, even those with different beliefs than ours, are vital to planetary
salvation, since the decline of all civilization can be traced to times when God and
spirituality have been undermined. See Religious Influence in Society, page 29.
o While the full route one travels up the Bridge to Total Freedom is through
participation in training and one on one auditing, we also provide these
Scientology services in a group congregational setting. Sermons covering
fundamental Scientology beliefs as well as group auditing are both a part of our
Sunday services, held each week in churches and missions across the globe in 139
countries. See Scientology Congregational Services, page 35.
o As with all mainline religions, we have our own ceremonies and services.
These include Naming Ceremonies (for the newborn), pages 52-63, Weddings, pages
70-107, Funerals (which reflect our belief in life after life), pages 113-129 and

Ordinations for new ministers, page 134-137.
o As for our beliefs, although the materials of Dianetics and Scientology are
voluminous including 139 separate volumes, containing over 40 million words
and more than 2,000 tape-recorded lectures, one can find the fundamentals in our
congregational sermons, and that these relate to the ultimate answers to life. Yes,
we believe Scientology is a practical religion, providing practical answers, but
they are premised upon the underlying discoveries of the spiritual nature of man
and the source of life itself. Examples can be seen in Invitation to Freedom - Man
Can Save His Soul, page 152; The Supreme Being, page 154; Man's Search for His
Soul, page 156; Handling Life With Scientology, page 158; as well as any of the
many others encompassing Scientology and Spiritual Freedom, The Nature of Life,
Freedom and Happiness, Marriage and the Family, Ethics and Survival, and Making A
Better World.


The prosecutor alleges we seek to avoid responsibility by "merely attaching the word "religion"" to our activities and "by blending references to religion" into our activities to "change essentially commercial or secular undertakings into religious ones." His conceit is startling and incredibly offensive.
The effects of this prosecution are known to the prosecutors. They were, or should have been, aware of how these charges would be perceived and interpreted by the news media and those who, out of hate, target Scientology. This case improperly supports the pending civil case, which had been filed nearly two years before the criminal charges were brought, by distant relatives of


Lisa McPherson who never even really knew Lisa, disagreed with her choice of religion and had not communicated with her at all for many years before her death. The prosecutors brought their charges in the midst of a vicious media barrage based on the outrageous and unsupported allegations made in that case. Though the prosecutor's charges did not repeat all the lurid allegations made by anti-Scientologists and the inflamed media; the clear implication in bringing these charges was that they supported those allegations in bringing these charges, and the prosecutor knew full well what the result would be: charging "the Church" over the death of one of its members would be interpreted as Scientology (the religion) "kills," we "murdered Lisa." It was predictable based on the previous media coverage and statements made by hate groups that the prosecutor's charges would then seem to say "the State agrees."
The fact that the prosecutor has not seen fit to discontinue his criminal prosecution in the face of the amended death certificate only reinforces this view. An accidental death by pulmonary embolism would not even give rise to an investigation, let alone a criminal prosecution, had it been anybody other than a Scientologist in Clearwater. The magnitude of these assaults demonstrate several things to us, and we submit they should so demonstrate to anyone who steps back from these events and views them in context of our numerous and widespread good works, the unproven nature of the charges, the large number of happy and active Scientologists, and the discriminatory nature of the prosecution.
First, the harms which are addressed above result from the dissemination of the prosecutor's mere allegations far and wide, to cause disruption to our entire religion.
Second, even if the false allegations were true, the demonstrations and media are far out of proportion to the alleged wrong for the very reason the State


has charged an entire church. One need not look far to find actual crimes of religious persons of other faiths. Yet, the state has never prosecuted an entire church in its history nor has there been such a prosecution in the history of this country. The media have never, to our knowledge, remotely displayed the fervor of persecution it has embraced regarding this case.
Third, while our religion has experienced its growing pains vis a vis acceptance in a world of persons necessarily espousing other religious views, the type of criminal acts and harassment against our churches described above were virtually non-existent prior to the broad dissemination of the allegations in this case.
These acts against our churches are directed, throughout the world, at who we are, not what any of our members did. We strongly believe that by holding up the hope and reality of spiritual freedom and true solutions for the world's travails, we have incurred the wrath and become the enemy of those who intend the opposite. We are serious about our desire to help mankind rise above the insanity revealed only too clearly by how viciously we have been attacked.


When agents of a branch of government inflicts damage to a group because of disparity of religious beliefs, those agents have strayed far from the trust endowed by public office.
As a result of the actions of the prosecutors in this case, acts of prejudice have been committed not only against this State's own citizens, but also against all those associated with the target of their action. The destructive effects of this wild fire of anti-religious sentiment have reached around the world. For the


foregoing reasons, amici request the Court dismiss all charges against our religion.

Respectfully Submitted,

[signed by Mike Rinder]
Michael Rinder
Church of Scientology International,
Amicus in pro per,
And the executives of the
Churches of Scientology
throughout the world

Dated: March 29, 2000