IN THE CIRCUIT COURT FOR THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, FLORIDA
STATE OF FLORIDA

v.
Case No. CRC98-20377-CFANO-S
CHURCH OF SCIENTOLOGY
FLAG SERVICE ORGANIZATION
SPN NO. 01980179

AFFIDAVIT OF PAUL KELLERHALS

STATE OF FLORIDA
 
COUNTY OF PINELLAS

I, Paul Kellerhals, being duly sworn, hereby depose and say:

1.
I am over the age of 18. I make the following statements of my own
personal knowledge, and if called to testify as to these matters, I could and would do so
competently.

2.
I have been in Church Security since October 1981. I arrived in Clearwater
in late September 1993 to work for the Church of Scientology Flag Service Organization
(“FSO”) and was administratively senior to the Security Force from that time until May
1996 when I became the Security Chief.

3.
In my experience in Church Security I have had to deal with a great deal of
harassment, attacks and threats against Scientologists in Clearwater. The environment 
in Clearwater became extremely hostile and dangerous toward the end of 1996. Attacks
Church and individual Scientologists escalated to a level far higher than I had
experienced here or anywhere else.

4.
Examples of incidents that have occurred since that time are set forth in the
following paragraphs, based on contemporaneous records in my custody. I ensured that
when appropriate these threats and attacks were reported to police, that they were
documented in police reports and that we kept the official report numbers on file.
Examples of some of the hundreds of instances of harassment and crimes against our staff
and our property are as follows.

5.
On the 26th of December 1996. two cars drove past the Hacienda Gardens
(an apartment complex for Church staff in Clearwater) and fired several shots in the
direction of the buildings from an automatic firearm. One of the neighbors reported that
one or two bullets had hit his house. The police arrived on the scene and they pursued the
cars that came driving by again, but apparently did not catch the perpetrators. We heard
nothing more on the matter.

6.
On the 30th of December 1996, a Church staff member went into a
restaurant named Angie’s Restaurant on the corner of Missouri Avenue and Cleveland
Street near FSO. He was immediately approached by a 6 foot tall, 300 pound employee,
who angrily said, “You have two minutes to get out of this restaurant! I do not serve
Scientologists.” This was said in a way that conveyed violence would ensue if not
obeyed.

7.
In early 1997, faced with religious bigotry and hatred of an intensity I had
never before experienced, I invested a great deal of time and Church funds to develop
procedures for dealing with bomb threats and other physical attacks against FSO. This
required professional consultation and drilling of staff to deal with threats to the Church
and its members in the event that any such threat were to be carried out. Continuing to
the present. FSO has had to retain former law enforcement personnel who specialize in
protective services on a permanent basis to guarantee the safety of the Church. its
parishioners and staff.

8.
On the 17th of April. 1997. a bomb threat was received by a Church staff
member over the phone. The man said, “A bomb has been installed in one of your buses
across the street. in a brake line in the rear wheels. It will detonate at a certain speed and
a lot of people will get killed.” The police were called, a thorough search was conducted
and no bombs were found. The source of the threat was never found by the police. We
never heard anything further on the investigation.

9.
On the 18th of April 1997, a man wearing a ski mask jumped over the wall
into the courtyard of the Fort Harrison Hotel. He left the property after being seen by
parishioners and was followed by two Church security staff When the staff members
approached him, he pulled out a knife and lunged at them, attempting to stab them. The
police were called and he was very belligerent with the police about Scientologists and
Scientology and even admitted that he had made bomb threats to the Church in the past.

10.
On the 9th of May, 1997, a threatening phone call was received by the
Church’s phone switchboard operator. A female voice said, “you know you just killed
another person — how do you feel about that? We’re going to run you out of town, we’re
going to burn you out!” and then hung up. This was investigated by an arson detective
and traced back to a teenage girl from a nearby town who, with other teenage girls, had
been reading a recent St. Petersburg Times article regarding Lisa McPherson and decided
to make the threat. 

11.  On the 20th of June, 1997. a sports utility vehicle passed in front of the Fort  
Harrison Hotel and a passenger of the vehicle tossed several firecrackers into a crowd of
Church staff who were waiting for the Church’s bus to take them home. 

12.  On the 4th of July. 1997. a car drove past the front gate of the Hacienda  
Gardens, and the passenger threw a smoke bomb over the fence onto Church property. 

13.  On the 6th of July. 1997. a car carrying two males drove past the front of the  
Fort Harrison Hotel. The passenger in the vehicle threw a firecracker at the front of the
building. 

14.  On the 3rd of August, 1997, one of the Church staff members living at the  
Hacienda Gardens reported that he had heard a sound like “an exploding light-bulb.”
Investigation found that one of the apartments had been shot at with a BB gun. breaking
the window. 

15.  On or about the 18th of September 1997, a man was charged with assault for  
verbally threatening to shoot two Church staff. Then, on the 20th of September 1997, the
same man attacked two Scientologists on Fort Harrison Avenue. He lunged at one of the
Scientologists and slapped the other one several times and spit on him. The police
responded to a call and arrested the man for battery. Before the police arrived, the man
expressed confidence that the police would support him in his attack because the
“Clearwater police hate Scientologists.” 

16.  On the 14th of November, 1997, a telephone call came into the Church and  
a man with a deep, calm voice said, “There is a bomb in the Coachman [building], it will 

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go off at three p.m.” The police were called. the building was evacuated with more than a 
thousand staff and parishioners forced onto the Street, and a thorough bomb-search was 
done. No bombs were found, but the harassment was extreme, putting all of our 
parishioners in fear. The source of the bomb scare was never located by the police and 
we've never heard about further investigation.

17.  On the 23rd of December. 1997, a pick-up truck drove by the Hacienda  
Gardens and one of the passengers in the truck threw a smoke bomb over the fence and 
onto our property. The truck circled the property and then one of the occupants threw a 
homemade "acid" bomb over the fence into the property. The bomb consisted of a large 
plastic bottle full of sulfuric acid into which pieces of aluminum foil had been dropped, 
creating a chemical reaction and heat to result in an explosion. The bomb made a loud 
explosion, splattering acid over a large area. The police were called and both the 
Clearwater police and the Sheriff Forensic Unit responded.

18.  On the 28th of January, 1998, a car was driving around the Fort Harrison  
Hotel, with the driver yelling obscenities about the death of Lisa McPherson. The driver 
was a white male. He then called the Church and said he was Lisa's brother (Lisa’s 
brother had been dead for many years) and threatened to kill one of the Church’s staff. 
The police located the man but the State Attorney refused to file charges.

19.  On the 4th of April, 1998, a Church staff member was standing on the corner  
of Cleveland and Fort Harrison and was hit in the back by a dart shot from a dart gun 
from a passing car.

20.  On the 11th of June, 1998, an unidentified person threw a flare-type  
firework onto the balcony of an apartment at the Hacienda Gardens.

5

21.  On the 6th of July. 1998, a Church staff member was punched in the face by  
a drunk on a bicycle. The police arrested him for battery. During questioning he stated 
several times that he “hated Scientologists.”

22.  On the 7th of July. 1998. a pick-up truck drove over the newspaper boxes on  
the sidewalk in front of the Church’s Fort Harrison Hotel. It then backed up and drove 
into the hotel lobby smashing through the front doors. which were locked for the night. 
The police were called, they located the truck and the driver was arrested. The driver was 
later identified as a Clearwater native who has participated in demonstrations in front of 
the Church, protesting over the death of Lisa McPherson.

23.  On the 4th of December. 1998, a bomb threat was received by the police  
department on the 911 line. The caller said there was a series of seven devices that had 
been planted along the exteriors of some of the Church buildings along Cleveland Street. 
The Pinellas County Sheriffs Office conducted a bomb sweep of the entire area, and a 
full bomb search was done of our buildings, but nothing was found. The perpetrator was 
never located and nothing further was heard from the police on the investigation.

24.  On the 10th of December, 1998, one of the Church’s staff was approached  
by a man in a car who asked him if he was a Scientologist. When the staff member 
replied that he was, the man said, “You need to find yourself a new town, buddy! I'm 
giving you a fair warning! I’ll be back!” Also on the 10th of December 1998, a 
Scientology parishioner was hit by a half-full can of coke thrown from a truck. 

25.  On the 1 1th of December, 1998, the child of a Church staff member was  
punched in the face by a local man.

26.  On the 1 5th of February. 1999, a man came to the front doors of the Fort  

6

Harrison Hotel and told a staff member that if we didn’t call the police, he would hurt 
someone. He continued to attempt to start a fight until the police came and arrested him 
for drunk and disorderly conduct.

27.  On the 25th of February. 1999, an unidentified man made threatening phone  
calls to the Church on two occasions. He told the receptionist he was going to torture him 
and chop his legs off and stated that all Scientologists should die. In the second call, the 
man said angrily. “Go fuck yourselves, go kill yourselves!” and hung up. This was 
reported to the police but we never heard back on the investigation.

28.  On the 10th of April. 1999, a Church staff member was hit and run over by a  
car which then fled the scene. The staff member was hospitalized with multiple fractures 
to his right arm.

29.  In October 1999, a series of anonymous letters were sent to Church  
executives in Clearwater, threatening violent assaults on the Church. One letter 
mentioned building an “arsenal” and that C4 explosives with remote detonating devices 
had been placed in our new building under construction, to forward a “jihad” because of 
Lisa’s “cruel death”. It brought that buildings construction to a halt, required the 
evacuation of non-Scientologist contractors, and the need to bring in both local and 
Federal (FBI) law enforcement to inspect the entire site (including the use of bomb 
sniffing dogs) to locate any explosives that were said to have been planted. The police 
were provided the name of the suspected perpetrator. We never heard anything back on 
the investigation. (Ex. 1) 

30.  On November 1, 1999, the owner of the local anti-religious hate  
group, the Lisa McPherson Trust Inc., struck a Church staff member with a picket sign.

7

The assault resulted in the entry of a restraining order against the group to stay at 
least 10 feet away from all Church buildings, and the filing of criminal charges against 
the assailant.

31.  On November 22. 1999, a Church staff member walking on Fort Harrison  
Avenue to the church was approached by a pick-up truck. The passenger in the truck 
threw a cup of soda on the staff member and sped off

32.  On 16th of February. 2000. an anonymous message was sent to the  
“Scientology.org” internet site, stating. "We are going to start killing Scientologists, be 
extra alert to any psychos around, they might have been sent here for this purpose.”

33.  On three occasions since I have been Security Chief at the FSO. I have been  
threatened and another Church staff member has been threatened with felony arrest by 
Clearwater Police Officers, when there was no reasonable or arguable violation of law. 
The threats appear to arise out of pure bias. I have also been present during several police 
investigations of criminals who have made attacks on Church staff members and 
individual Scientologists and in each case the assailant spoke to the police as if they were 
allies in their assaults against Scientolo2ists. as if it were a well known fact that police 
would side with them against any Scientologist.

34.  This affidavit is only a summary of incidents of harassment and threats  
made to individual staff members. There are many, many other incidents of vandalism 
or damage to property, which literally number in the hundreds. , 

[signed]
Paul Kellerhals

8

STATE OF FLORIDA PINELLAS COUNTY

The foregoing instrument was acknowledged before me to be true and correct to the best 
of his ability this 21st day of March 2.000. by Paul Kellerhals. He is personally known to me 
and did take an oath. 

Notary Public in and for the State of Florida

ANNIE MORA
Notary Public - State of Florida My Commission Expires Oct 10. 
Commission # CC878437