STATE or NtVA~A ) ) u.s

County of Douglas) .

x. ;ROKUl) EJ:I!iCAIU) DEWOL!', fon:erly known .s L. Ron

HUbbar~, ~r., ~eing duly sworn, bereby depole .n~ state:

1. I have ~een in!on:e~ that Lyle Stuart inten~s to

publish a ~ook concerning the late L. Ron Hubbara an~ the

Church of Scientology. I have been further in!on:e~ that the

~ook is to ~. entitled h. Een H~=b!rd, an~ that Hr. Stuart

inten~s to publish the ~oek with myself an~ Bent Cory~on liste~

as co-authors.

2. I have not seen the manuscript for the ~ook, an~ have

not given Hr. stuart or anyone elle pen:ilsion to use my name

in connection with the book. In fact, as shown by the letter

attache~ hereto, I have specifically refule~ to len~ my name to

Hr. Stuart or to Cory~on for this book.

3. Since it now appears that, despite my refusal, Mr • •

Stuart and Corydon intend to proceed with publication of the

book, I wish to make the following facts perfectly clear:

a. To the exten~ that any portion of the ~ook is ~ase~ on

my previous manuscripts, entitle~ at various times 1/10th of

11 and The Telling of He, the ~ook i. complete an~ utter .

fantasy without the slightest figment of truth,

~. ~c the extent that any'pcrtion of the ~ook·is ~as.d on

my previous manuscripts, referred to i~ediately hereinabove,

the use of that material is in violation of copyrights.

hop aOif/~?

c. To the extant that any portion of tho-book is bale~ on

:y co~unications vith !ent Cory~on, vhether written or-cral,

tha book is inaccurate an~ fal.e.

•• Eecause L. ~on ~ubbar~'. litestyle, first as a vriter

an~ then later aB a Naval officer ~urini ~orl~ ~ar ~I, vas such

that he travelle~ a qreat ~eal, :y personal knowle~ie of Hr.

Hubbar~ prior to the .n~ of ~orl~ ~ar II vas ireatly limited.

In fact, the only perio~ in vhich I spent an appreciable amount

of time at all vith Hr. Hubbar~ vas between 1951 an~ 1959;

vhen I vas also'a me~~er of the Church of Scientology. ~ven

then, however, he continue~ to travel and Ve vere of~.n

separated. ~~at personal knowle~ge I ~o have concerning L.

~on Hubbar~ an~ the Church of Scientology ended in late 1959.

S. The statements I made in the manuscripts referred to

hereinabove, an~ in :y cor.~unications to !ent corydon an~

ethers, were sb,ply no more than wil~ flights of fantasy

based en :y o.~ unlimited i~aiination. To now represent those

state~ents as "truth," an~ 'to steal the har~ earne~ value ef

the nalne tiL. Ron Hubbard" by using :y fomer name as the

co-author ef a book I have neither written nor reviewe~, is an

unethical act ef the highest :agnitu~e.

Sworn and subscribe~ to betore me this 20th ~ay of Hay, 19B7 at Carson City, Neva~a.

Notar3 Public for the State of Nevada (./

A,~tP'~~/ ROHALO ~ DE'IIOLF

.--.- --'"-----,.- -"

PCOVEY, SACHS, HIANC~ , CAltNACCI A Professional Corporation One Cate~ay Center N~~ark, New ~ersey 07102 (2\)1) 622-4702

- - anI! -

1.UBtLL AND U7BtLL 220 fifth Avenue New York, Nev York 10001 (212) 683-5000

At~orneys for Plaintiff

trnl!t'O STATtS DISnUC'l' COl.l'Rl' DIS!~IC'l' or NtW JtRSty

__________________________ x

~CNALO t. DeWOLF,

Plaintiff,

-against-

1.YU: S :rW •. Rl', INC.,

De!en~ant.

: Civil Action No. 17-233S (HLS)

: ~rr!p~V!T or EO~ALO t. otwCLl

.' • __________________________ x

STATt or NtVJ..DA

cOtrnTY or C~ON

) 155.: )

~ONALO Z; DtWOLF, being ~uly sworn, ~eposes and says:

1. I am the plaintiff in this action. I make this

affjdavit in support of =y application for expedited ~iscovery

anI! a tn.porary restraining order anI! in opposition to

~efendant" motion to ~is=1a ••

2. It vas never my ~nderstand1ng vith Sent Corydon that

cory~on vould do the actual vrit1ng of the book and that my role

es co-author vas to supply information and insight. ~ather, ·it

vas my.~nderstand1ni that ~ waa to be Corydon', co-author in

I

every lense of the ~or~1 I ~oul~ ~rit. certain sections of the

book an~ I'woul~ :ake e~itorial changes .n~ a~~ zy cwn written

:'Uerial to the nctions of the book that Cory~on ~oul~ ~dta~

3. In fact, :y un~erstan~ing of bow it woul~ work is

supported by zy April 28, 1985 letter to Cory~on ~hich Corydon

attached to his af!i~avit as ~xhibit C. In this letter, I .sked

Corydon to lend :e his draft so that I woul~ :ake :y own'~ritten

contributions to it.

Bring an~/or send a print-out and/or disks. I'll do the

sa~e, but my book is in :y head and so is cur book. I ~ork very

fast and very har~. Very focused. So send :e all your stuff so

I can add :ine out of ~y head ••• [para) So, do~~load to :e all

your book stuff and I'll a~~ :y stuff cut of :y head and upload

to ·you fast and into the hands of your agent friend (Corydon

';xh. clI.·

4. In addition, it ~as always :y intention to make :y own

~ritten contributions and editorial changes to the first two

·sa:ple chapters. As I wrote. in :y April 28, 1985 letter, •

[yJou prob~bly have enough for the requested first two

chapters. I'll add to it and really blow the publisher's sockl

eff (Cory~on Ixh. C).

However, ~hen I finally received the chapters from Corydon

during the s~er cf 1985 I was physically incapable of :akin;

:y own written contributions and cf editing eory~on's drafta. ,

During the spring and sumcer ~f 1985, I had bee~ luffering from

gall bladder attacks. On ~uly 5, 1985, I underwent ;all -l/ References to the ~une 23, 1087 affidavit cf Bent G.

Corydon will be cited as "Corydon Para. . .-

I

bla~~er surgery. I am a diabetic an~ am therefore very alow to

heal and recover from surgery. In addition, I developed bloc4

clot., wal pla~ed in intensive care and hospitali:ed from ~uly 5

until ~uly 15, 1985.

5. I never agreed with Bent Corydon or with' Lyle Stuart,

Inc. that I would !:le Hentified as the co-.author of the

purported biography of my !a~er L. ~on Hubbard even if I·made

no written contributions to the !:look. Corydon and I understood

that I was going to do some of the writin; of the book and· would

add to and edit other portions of the book written by Corydon.

This understanding was shared with Lyle Stuart, Inc. . .

.5. Corydon is simply wrong when he states that ~e taped

our conversations on March 2B and 29, 1985 so that we CQuld

begin our collaboration on a book about my father (~ Corydon .

para 5-6).' We did not tape those conversations for a book.

'rhose conversatio::s \oIere taped so that Corydo%l' ·could pay them

for ·classes at his Mission in ltiverside, Cali!crnia.

7. Contrary to Corydon'" a i:cplication (~. para 5-8,

Exhs. A,!), the reference in my April 2, 1985 letter to

"sit[tingl downa and talk[ingJ some real hardcore,

straightforvard, nuts and bolts business" had nothing to do with

writing a book together about my father. Instead I was

referring to coming down to Corydon's ~iversid. Mission to teach

some classe.. In that same letter I atated that I would ba

tea.ching "major Special Training Courses" overuu and in the

United states to reinforce my willingness to participate in the

business of teaching classes at Corydon' a ~!.yerside Mission.

-3-

. : -~-' ==------- -------- . I

•• Corydon i. also inaccurate in d~scribing the

conversation ~here I informed him that I ~a. ~ithdrawing fr=:

the book projlct and that I ~idn't ~ant any ef the ~anulcript. %

had written to bl used and that.I didn't ~ant my na:e te be Used

er associated ~ith the book project in any ~ay (~ 14. para 11). Corydon ~id not :ention the pay:e~t ilsue in this

conversation, While ~orydon had :ade several previous pro:iles .

to cend :e =y share ef the money, he ~id not cpeak ef money in

thil conversation (and he never sent :e the money). Corydon did

say, however, that he ~al going to torce me to ~o it

(pres1.l.l!\ably, be ASsociated ~ith the book) ",hether I liked it er.

not.

t. Corydon is vrong about the nu~er of conversations ~e

had about my tather (~~. Para 12). We did not talk at

least once a ",eek during the period fro: mid-3une, lSB! to Hay,

IS26. At ~ost "'. talked twelve times during that period.

10. Corydon's :isstatements include his discu~sion ef my

so-called contributions to the book (~. para 16). Hanyef . the things Corydon claimed to be hearing from me tor the f~rst

ti:e tor this book vere publicly known fro: my ~uly, lSB3

penthouse interview ~hich ~as veIl-known to Corydon: •• i. the

falce charge about my father and drugsl the speculation about my

brother Quentin's deathl the stories I had ",eaved about =y

Ch~ldhoOdl and =y father's so-called harass:ent and manipUlation

cf .ethan. In addition, I told Corydon that my' father har!

vri~en the Church ef Scientology's "standard tech" cr

"Brainwashing Hanual" enly to dispute the claim that Corydon had

.. -----------_ .. --_.- .

. ,

told me vas being ma~e by others that my father ha~ not written

the tech.

11. I viii never be able to recover -- either

professionally or personally -- .fro: baving ~y na:e associated

with thil purporte~ biography of =y~ather which I ~id not

write. Lyle stuart, Inc. is continuing to i~entify me a. the

co-author because, a. L. ~on Hubbard'. son, zy name adds

instance credibility to the book'. charges an!!, in addition,

leads the reader to believs that be i. getting inside

infor=ation available only to intimate family me~ers. A ••

result of this false representation about =y contributions to

the book I will be held responsible by the book-buying public

for a scurrilous attack on my father whic~ I did not writ.,

which I do not endorse and which I publ1"cly disavov. I will be

. subjected to crit1c.1sl:! for so=ething I did not do and over which

I had no control whatsoever. Not only did I not write any part

of this book, I al:! not even being per=itted to read the

manuscript bearing my name prior to publicationl In the past, I

have said and written things about my father which I deeply

regret and which caused him and =e great pain. ~he penhopse

interview i. an example. But penthouse by its nature bas a

limited circulation and a dubious reputation. Lyle stuart,

Inc., in contrast, 'is a reputable publisher and i. obviously

marketing this book to a nationwide audience. My national

reputation then 1. forever dependent upon a book'which I did not

wri~ and which will prevent =e from ever making =y peace with

my deceased father, our family and bi. Church. If thi. book i.

released with my.name on it even though I made no written

I

contribution to the book, I will never be able to stop:y public

~ilplay of filial ~illoyalty and ~ut it all behind ze.

Sworn to before :e thil 1st .~ay of July, 1587

-s-----_. I