Who Killed L. Ron Hubbard? - From the FACTnet Probate Brief

[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.

JANUARY 25,1987
[ ... ] 
  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
  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.
JANUARY 25,1987
 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
(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
(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.
 [ ... ] 
  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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