This is an Affidavit of my knowledge of certain facts which I learned while I was a member in good standing of the Church of Scientology concerning the position and policy of the Church and/or various Church staff members regarding United States District Court Judge Elizabeth Kovakevitch.
The first time I ever heard a staff member of the Church of Scientology speak about Judge Kovakevitch was in June 1986, in relation to Margery Wakefield. While working for the Guardian's Office during 1982, I had participated in a project to turn Margery Wakefieid's attorney Wait Logan against her by feeding him false information that Margery Wakefield was still a member of the Church of Scientology at that time, which was not true. I was somewhat familiar with the status of Margery Wakefield's case, as it was broadly discussed amongst members who were working for and helping the Guardian's Office such as myself.
In June 1986 I was told by Church executive Eilie Bolger that "Margery Wakefield would fry for breaking her gag order." I had never heard that term before, and Ellie Bolger explained that a gag order is a covenant not to talk against the Church to the media. At that time I was very enthusiastic about the prospects of seeing Margery Wakefield punished, and I asked Ellie Bolger how "we were going to get her." EIHe Bolger responded by saying, "We have a Judge who completely duplicates our viewpoint." I knew this phrase to be Scientology jargon indicating that the Judge was "on our side" or "sees our point of view."
Ellie Bolger then identified the Judge as Judge Elizabeth Kovakevitch from the Middle District of Florida, in Tampa. I had not heard of her up until that time. Ellie further explained that the Church had allied itself with the Judge through the "Say No To Drugs" campaign. She added that Judge Kovakevitch was on the mailing list to receive "lots of good roads, good weather, and good news PR", which meant to me that she was on a special type of mailing list circulated by the Dissemination Secretary of the Church which targeted public officials not for Church services particularly but rather to positively influence public opinion in the direction of the Church. I had prior knowledge that there was a specific public relations- type mailing list maintained by the Church.
E!lie Bolger was very confident at that time that Judge Kovakevitch would not consider ruling adversely to the Church of Scientology, and further indicated that Judge Kovakevitch "liked the Church because of our stand against drugs."
The next time I heard about Judge Kovakevitch from a Scientology staff member was in February 1987. Cathy Webb, an executive of the Church, told me in her office at 118 N. Fort Harrison Avenue, that "Kovakevitch would never rule against us again", and that "she was really O.K." I asked Cathy Webb why she was so sure, to which she responded, "We have Aunt Liz under surveillance. We followed her to Sarasota to find out what she's been doing and where she's been." I understood that "Aunt Liz" referred to the Judge. It was inappropriate for me to press Cathy for more details so I did not do so.
It is standard policy in Scientology that staff members are assigned to keep in close contact with Federal Judges and to keep their activities coordinated with the intelligence section of the Church, which is the Office of Special Affairs. Furthermore, it is also the policy to determine whether the decisions of Federal Judges remain in line with Scientology purposes, and to take whatever steps are necessary to influence the viewpoint or decision making process of all Judges who preside over Scientology litigation, irrespective of their jurisdiction.
I attended a seminar known as the Power Lines Conference sponsored by the Office of Special Affairs of the Church of Scientology which took place at the Fort Harrison Hotel of the Flag Land Base on or about February 9-11, 1987. I was the delegate to the Power Lines Conference from the Church of Scientology Mission of Fort Lauderdale. I was given an award for having arranged for Russell Means, the leader of the American Indian Movement, to meet with Church executives for the purpose of negotiations by Church officials for the lease of various Indian lands over which Mr. Means had considerable influence.
While at this conference, I met with Dennis Clarke, the President of the Citizens' Commission on Human Rights, an anti-psychiatry front group controlled by the Church. He told me "Now that we have Elizabeth Kovakevitch in our pocket, she will never rule against Scientology again!" He added that she had been to Flag (the Fort Harrison Hotel and/or the Sand Castle Hotel) in Clearwater, Florida at a public event.
In the context of that same conversation, and in front of Freddie Ulan, another executive of the Citizens' Commission on Human Rights, Dennis Clarke told me that the "Church had made a cash contribution to one of Elizabeth Kovakevitch's favorite pet projects." Dennis Clarke then said, "We need more Federal Judges like Kovakevitch in our corner."
It is standard practice for Church staff attached to the intelligence network of the Church, particularly the Office of Special Affairs, to do a thorough FBl-like investigation of all judges and attorneys involved in litigation involving the Church of Scientology, and whenever possible, to accumulate personal and confidential data about the targeted official which could later be made available to influence the official. It is not uncommon for Church officials to use secret information garnered from covert investigative practices as a means to even blackmail officials, in the process of threatening to expose information or hold the official up to ridicule. The practice is also used against psychiatrists, psychologists and [ missing word, ``other''? ] perceived "enemies" of the Church, including but not limited to expert witnesses testifying against the Church as well as the individual litigants themselves.
STATE OF FLORIDA
COUNTY OF BROWARD
Witnessed this 25th day of February, 1993, at HaHandale, Rodda.