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
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