Captain David Miscavige
Supreme Commander
Pacific Area Command ("PAC")
of the Church of Scientologyv
and Chairman of the Board of
Religious Technology Center
1710 Ivar Avenue
Suite 1100
Los Angeles, California 90028
Via Facsimile
(213) 960-3508/09
Church of Scientology International
Office of Special Affairs
1331 Hollywood Boulevard
Suite 1200
Hollywood, California 90028-6329
Dear Captain Miscaviage:
We represent Michael Phillip Pattinson, who was recruited into the
Scientology Organization nearly twenty-five years ago. Since then, he has
expended much time, trust, labor and money, in excess of $500,000 in cash
alone, on Scientology training and auditing. At the time, Mr. Pattinson
joined the Scientology Organization it was represented to him that Scientology
was a peaceful, law abiding, bona fide and legitimate religion, acting in
compliance with all applicable laws, rules and regulations. Mr. Pattison has
recently discovered that these representations were false, and that the
Church's and corporations of Scientology perpetrated further fraud upon him by
way of material non-disclosures and upon which he reasonably relied. As
recently as May 2, 1998, the Church wrote to Mr. Pattinson in his O.T.
Ambassador capacity and continued the perpetration of this fraud.
Contrary to the pertinent representations, and consistent with the material
non-disclosures, Mr. Pattinson has learned that the Scientology organization
engaged in fraudulent conduct in order to procure its tax exempt status in the
United States, and that it continues to breach and violate applicable tax
laws, regulations, and rules, and the express terms of the IRS Exemption
Letter, and Secret Closing Agreement, entered into in 1993.
In addition, and again in pertinent part only, Mr. Pattinson has discovered
that the church in which he attained the highest possible levels of training,
has used his membership, monies and trust, to embroil agencies of the United
States Government, in violations of, most simply put, the separation of Church
and State provisions contained in the United States Constitution.
Again, and in pertinent part only, the Scientology organization has also
engaged in unlawful activity (contrary to the Tax Code and other laws) to
"persuade" the President of the United States, his National Security Advisor,
the Secretary of State, the United States Department of the Treasury, the
United States Department of Commerce, the Commissioner of the I.R.S. and the
United States Trade Representative to interfere in the internal affairs of
foreign governments, including but not limited to the governments of Germany
and Sweden. For example, the Scientology organization has convinced the
United States Government, through the United States Trade Representative, and
the State Department, to place the Nation of Sweden on a 301 Special Watch
List, preparatory to the imposition of trade sanctions being imposed by the
United States Government upon the Government of Sweden, because of that
government's refusal to remove the Church of Scientology's so-called sacred
scriptures from being available from certain public information repositories
in that country.
Unless a written stipulation is received in my office by 3:45 p.m. today,
agreeing that the Church of Scientology will immediately cease all activities
such as are described above, legal proceedings will be immediately filed
seeking, among other things, declaratory and injunctive relief against both
the Church of Scientology and various officials of the United States
Government in order to ensure the cessation of the unconstitutional and
unlawful use of the monies, labor, time, membership, and trust Mr. Pattinson
has reposed in the Church.
This letter is written without waiver of any of our client's claims, rights
and remedies, all of which are expressly preserved.
Very truly yours,
BERRY, LEWIS, SCALI & STOJKOVIC
Graham E. Berry
GEB:sam