STATE

or

NtVA~A

) u.s

County of Douglas)

x.

;ROKUl) EJ:I!iCAIU)

HUbbar~, ~r., ~eing

1.

I have

publish a

~ook

duly sworn, bereby depole

~een in!on:e~

is to

inten~s

~.

L. Ron

.n~

that Lyle Stuart

I have been further

entitled h. Een

to publish the

~oek

H~=b!rd,

with myself

an~

state:
to

inten~s

concerning the late L. Ron Hubbara

Church of Scientology.
~ook

.s

DEWOL!', fon:erly known

an~

the
that the

in!on:e~

that Hr. Stuart

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.
attache~

hereto, I have specifically

Hr. Stuart or to
3.

In fact, as shown by the letter

Cory~on

refule~

to

len~

my name to

for this book.

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

my previous manuscripts,

entitle~

11 and The Telling of He, the

~ook

~ook

at various times
i. complete

an~

is

~ase~

1/10th

on

of

utter .

fantasy without the slightest figment of truth,

~.

~c

the extent that any'pcrtion of the

my previous manuscripts, referred to

~ookis ~as.d

i~ediately

on

hereinabove,

the use of that material is in violation of copyrights.

hop

aOif/~?

c.
:y

To the extant that any portion of tho-book is

co~unications

tha book is inaccurate

an~

Cory~on,

vith !ent

Eecause L.

an~

travelle~

~on ~ubbar~'.

a qreat

Hubbar~

prior to the

In fact, the only

.n~

of time at all vith Hr.

~eal,

of

perio~

litestyle, first as a vriter

~urini ~orl~ ~ar ~I,

then, however, he

continue~

~on Hubbar~ an~

S.

:y personal

~orl~ ~ar

Hubbar~

me~~er

~~at

vhether written or-cral,

vas such
of Hr.

knowle~ie

II vas ireatly limited.

in vhich I spent an appreciable amount

vhen I vas also'a

separated.

on

fal.e.

then later aB a Naval officer

that he

bale~

personal

vas between 1951

an~

1959;
~ven

of the Church of Scientology.

to travel and Ve vere

knowle~ge

~o

of~.n

have concerning L.

the Church of Scientology ended in late 1959.

The statements I made in the manuscripts referred to

hereinabove,

an~

in :y

cor.~unications

ethers, were sb,ply no more than

based en :y
state~ents

o.~

unlimited

as "truth,"

an~

wil~

to !ent corydon

an~

flights of fantasy

i~aiination.

'to steal the

To now represent those

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
unethical act ef the highest

reviewe~,

is an

:agnitu~e.

A,~tP'~~/
ROHALO

DE'IIOLF

Sworn and subscribe~ to betore me

this
20th ~ay of Hay, 19B7 at
Carson City, Neva~a.
Notar3 Public for the State of
Nevada
(./

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

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,
-against1.YU: S:rW.Rl',

Civil Action No. 17-233S (HLS)

~rr!p~V!T

or

EO~ALO

t. otwCLl

INC.,

.'

De!en~ant.

__________________________x
STATt or

cOtrnTY

NtVJ..DA

or

C~ON

~ONALO

1.

)
155.:

Z; DtWOLF, being

~uly

sworn,

~eposes

I am the plaintiff in this action.

and says:

I make this

affjdavit in support of =y application for expedited

~iscovery

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

~efendant"

2.
cory~on

motion to

~is=1a

It vas never my

~nderstand1ng

vith Sent Corydon that

vould do the actual vrit1ng of the book and that my role

es co-author vas to supply information and insight.

vas

my.~nderstand1ni

that

~ather,

it

waa to be Corydon', co-author in

I

every lense of the

an~ I'woul~

book

~or~1

:ake

~oul~ ~rit.

e~itorial

certain sections of the

changes

.n~ a~~

:'Uerial to the nctions of the book that

3.

In fact, :y

un~erstan~ing

af!i~avit

attached to his

Cory~on ~oul~ ~dta~

of bow it

supported by zy April 28, 1985 letter to

as ~xhibit C.

Corydon to lend :e his draft so that I

zy cwn written

woul~

work is

Cory~on ~hich

Corydon

In this letter, I .sked

woul~

:ake :y

own'~ritten

contributions to it.
Bring
sa~e,

an~/or

Very focused.

har~.

can add :ine out of

your book stuff and I'll

to you

fast

and

~y
a~~

~ork

very

So send :e all your stuff so

head [para) So,

do~~load

to :e all

:y stuff cut of :y head and upload

into the hands of your agent friend (Corydon

clI.

';xh.

4.
~ritten

In addition, it

[yJou

always :y intention to make :y own

~as

contributions and editorial changes to the first two

As I wrote. in :y April 28, 1985 letter,

sa:ple chapters.
prob~bly

chapters.
eff

I'll do the

but my book is in :y head and so is cur book.

fast and very

I

send a print-out and/or disks.

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

(Cory~on

However,
during the

have enough for the requested first two

Ixh. C).
~hen

s~er

I finally received the chapters from Corydon

cf 1985 I was physically incapable of :akin;

:y own written contributions and cf editing

eory~on's

During the spring and sumcer

gall bladder attacks.

On

~f

~uly

1985, I had

bee~

drafta.

luffering from

5, 1985, I underwent ;all

l / References to the ~une 23, 1087 affidavit cf Bent G.

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

bla~~er

surgery.

I am a diabetic

heal and recover from surgery.

clot., wal

pla~ed

until

15, 1985.

~uly

5.

an~

am therefore very alow to

In addition, I developed bloc4

in intensive care and hospitali:ed from

~uly

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 Imade
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
our conversations on March

2B

~e

taped

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.
referring to coming down to Corydon's
some classe..

Instead I was

~iversid.

Mission to teach

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
-3-

~!.yerside

Mission.

d~scribing

Corydon i. also inaccurate in

conversation

~here

I informed him that I

the book projlct and that I

~idn't ~ant

the

~a. ~ithdrawing

any ef the

fr=:

~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 (~
para 11).

Corydon

conversation, While

~id

not :ention the

~orydon

pay:e~t

14.

ilsue in this

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).

say, however, that he

~al

(pres1.l.l!\ably, be ASsociated

going to torce me to
~ith

~o

Corydon did

it

the book) ",hether I liked it er.

not.
Corydon is vrong about the

t.

had about my tather

(~~.

nu~er

Para 12).

of conversations

~e

We did not talk at

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

IS26.

10.

~ost

"'. talked twelve times during that period.

Corydon's :isstatements include his

so-called contributions to the book

the things Corydon claimed to

.
be

(~.

para 16).

~hich ~as

~uly,

ef my

Hanyef

hearing from me tor the

ti:e tor this book vere publicly known fro: my

penthouse interview

discu~sion

f~rst

lSB3

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

cf .ethan.
vri~en

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

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

the Church ef Scientology's "standard tech" cr

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

..

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

.
.

told me vas being

ma~e

ha~

by others that my father

not written

the tech.
11.

I viii never be able to recover -- either

professionally or personally -- .fro: baving

with thil
write.

purporte~

biography of

=y~ather

Lyle stuart, Inc. is continuing to

co-author because, a. L.

~on

~y

na:e associated

which I

~id

i~entify

not

me a. the

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.

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.
interview i. an example.

~he

penhopse

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
wri~

1.

forever dependent upon a book'which I did not

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

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-

- -_.

--