IN THE CIRCUIT COURT FOR THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, FLORIDA
STATE OF FLORIDA,
Case No. CRC 98-20377CFANO-S
vs.
CHURCH OF SCIENTOLOGY FLAG
SERVICE ORGANIZATION
SPNNO.01980179

AFFIDAVIT OF REVEREND MICHAEL J. RINDER

Reverend Michael J. Rinder, being duly sworn, deposes and says:

1. I have personal knowledge of the facts set forth in this affidavit, and if called upon as a witness, I could and would competently testify thereto.

2. I am a director of the Church of Scientology International ("CSI"). CSI is the "mother church" of the Scientology religion. CSI provides guidance and assistance to Scientology churches around the world, and is directly concerned with their stability and vitality, their ability to continue to propagate the religion, and the spiritual well-being of the parishioners they serve.

3. In my capacity as a CSI director and in furtherance of the purposes and functions of CSI as set forth in the preceding paragraph of this Affidavit, I became concerned about the
impact that the charges brought in this case would have on the Scientology religion, on Scientology churches, including defendant Church of Scientology Flag Service Organization
("FSO"), and on individual Scientologists throughout the world. I have witnessed the results of media coverage which has persistently labeled these proceedings as the prosecution of the entire religion itself, and the disturbing reactions such characterizations have engendered.

4. In charging the Church, the impact was predictable and has now been demonstrated.  That impact has stigmatized all Scientology churches and all Scientologists because of the

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widespread perception generated that the entire Scientology religion has been charged. Literally no Scientologist anywhere in the world is free from or immune to the public impression that those who practice the Scientology religion are suspect by association.

5. The statistics vividly illustrate my point. Articles characterizing the scope of these charges and labeling the accused as "Scientology," "Scientologists," or the generic "Church of Scientology" have appeared in over 255 newspapers in the United States, Australia, Canada, Denmark, England, France, Germany, Japan, the Netherlands and Spain. Analysis of the international media coverage reveals that 31 percent reported that "Scientology" was charged with the crime, 66 percent reported that the generalized "Church of Scientology" was charged, and only 3 percent accurately reported that FSO was the target of the charges. To illustrate just how broadly this has been disseminated, a list of the newspapers and wire services where such articles have been published is annexed to this Affidavit as Exhibit A, and a representative sampling of such coverage is annexed as Exhibit B.

6. Together, the newspapers and magazines identified in Exhibit A to this Affidavit have circulation of more than 48,650,000. The wire services identified in Exhibit A to this Affidavit supply news coverage to well over 500,000 subscribing media outlets, and even accounting for overlapping subscribers to such wire services, their reports reach millions of additional readers around the world.

7. Similarly, radio and television broadcasts generally stigmatizing "Scientology" or the "Church of Scientology" with suggestions of culpability in Ms. McPherson ' s death and the resulting criminal charges have reached well over 50,000,000 viewers and listeners. A list of the radio and television stations which have broadcast such stories is annexed to this Affidavit as Exhibit C.

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8. Another tangible result of the entire church being charged is anti-Scientologists have used the case as a springboard for more attacks on Scientology churches and their parishioners worldwide. Anti-Scientology hate groups have organized picketing that has occurred around the world. These "protests" are not orderly demonstrations. Instead, they are raucous and provocative assemblages, marked by taunts, insults, and even threats of violence. Since few, if any, of the "protestors" are disaffected former Scientologists, there is no other purported "cause" for their rallies, apart from the case of State of Florida v. Church of Scientology. Moreover, the vast majority of such "protests" have taken place at premises other than FSO, although some of the most provocative have been in Clearwater.

9. The following is a representative example to illustrate my point. The Information in this case was filed on November 13,1998. Widespread media coverage followed. On December 4, 1998, a group of "protestors" -none of whom even lived in Clearwater- began their demonstration in Clearwater by convening a press conference which they commenced by announcing, "Welcome to occupied Clearwater." Then, having obtained a permit from the Chief M-Police of Clearwater in an extraordinarily abbreviated application/approval process -of approximately one business day's duration -these "protestors" occupied the entire public sidewalk in front of FSO. During the course of that "protest," they:

• blocked the path of parishioners arriving for, and leaving after, religious services with, among other things, a coffin with "Scientology Kills" painted on it;

• shouted anti-Scientology epithets through a bullhorn, disrupting religious services inside the building;

• chased the vans which FSO was forced to provide for the safe transportation of its parishioners;
  

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• vilified those same parishioners with personal barbs, taunted them and waved hateful, demeaning placards about their religion, with slogans such as the following:

• "Blood on $cientology Hands" with an autopsy photograph of Ms. McPherson's hand

• "Scientology, The Church With A Body Count"

• "Scientology: Doctors of Death!"

• "Lisa Macpherson [sic]: Killed by her Church?"

• "Thank God L. Ron Hubbard is Dead"

• "Honk if you Hate Scientology!"
  
  

• verbally taunted Church staff with personal insults regarding such things as their mother's supposed sexual indiscretions; and

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  made profane threats of physical violence against ecclesiastical leaders of the religion. (A representative sampling of photographs of the Clearwater demonstrations is annexed to this Affidavit as Exhibit D.)

10. In December of 1998, anti-Scientologists purchased advertising space on Pinellas County buses which they used for anonymous signs exhorting people, "Don't Walk, RUN ! Quit $cientology," and "Find Out Why So Many People Oppose Dianetics & Scientology." (Exhibit
E.) The bus ads were so offensive that one of the Pinellas Suncoast Transit Authority ("PSTA ") commissioners demanded they be taken down immediately. After they were removed, the anti- Scientologists appeared at several PSTA board meetings, threatening legal action against the
PSI A for refusing to carry their anti-religious message.
11. During the last six weeks of 1998, following the filing of the Information in this case, nearly two dozen such "protests" took place in the United States (including Washington, D.C.;

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Atlanta, Georgia; Buffalo, New York; Boston, Massachusetts; Chicago, Illinois; Tustin, California; Salt Lake City, Utah; Minneapolis, Minnesota; San Francisco, California; San Jose, California; and Phoenix, Arizona) and in cities around the world (including Toronto, Canada; London, England; Copenhagen, Denmark; Stockholm, Sweden; and Brisbane, Australia). They bore signs imputing responsibility for Ms. McPherson ' s death to the Scientology religion such as the following:

• "Scientology Indicted"
  "Scientology Kills"
  "Scientology killed Lisa McPherson"
  "Scientology HURTS PEOPLE"
  "Scientology Hurts People. Who will be next?"
  "Scientology is a Scam"
  "Scientology Charged [in] Lisa's Death"
  "Lisa McPherson is dead"
  Don't forget Lisa McPherson, killed by Scientologists"
  "Say No to Scientology -What on Earth do $cientologists Believe in Anyway?"

Annexed to this Affidavit as Exhibit F is a representative sampling of photographs of these protests.

12. In 1999, similar anti-Scientology demonstrations targeting the religion have been staged throughout the United States (including Atlanta, Georgia; San Jose, California; Phoenix, Arizona; Los Angeles, California; Los Gatos, California; Washington, D.C.; Dallas, Texas; and Salt Lake City, Utah) and elsewhere in the world (including Amsterdam, the Netherlands; Sussex, England; and Toronto, Canada). The slogans printed on protestors' signs in those

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demonstrations included:

• 
  "Scientology hurts people. Who will be next?"
  "Stop hurting people"
  "Scientology indicted in death of Lisa McPherson, December 5, 1995" "Scientology is a Scam"
  "Scientology is a cult"
  "Scientology didn't believe in God"
  "Scientology. Criminal cult of Greed, Fraud, Hate and Abuse"
  "Scientology proud to be evil"
  "L. Ron Hubbard is dead but his fraud continues!"
  "Scientology, threat to democracy!"
  "Scientology should not be tax exempt"
  "Lisa McPherson killed by her Church"
  "Is Scientology practicing medicine without a license?"
  "Scientology, Cult of Greed & Power"
  "Scientology boasts of brainwashing"

13. The widespread, international demonstrations described above, which exploit allegations relating to Ms. McPherson' s death to stigmatize an international religion and its adherents, establish that the charges in this case are being interpreted as directed against the entire Scientology religion rather than against the defendant. It is highly improbable there is a single Scientologist across the globe who has not been confronted with the allegation his or her religion killed one of its own members. Indeed, the false attributions of responsibility to the religion itself have become so widely publicized that even foreign governments have raised

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inquiries. In December of 1998, a member of the Danish parliament asked for an investigation into allegations regarding the Church' s treatment of Ms. McPherson. The questions raised by the Danish parliamentarian were directed toward the beliefs and practices of the Scientology religion, and not the conduct of any corporation or individuals.

14. So pervasive is the perception that the religion or the entire "Church of Scientology" has been charged in connection with Ms. McPherson' s death, that it even appears to have reached into the courthouse. Exhibit G to this Affidavit is a true and correct copy of a notice served upon defendant FSO by the Court in which the caption identifies the defendant as "Church of Scientology" without reference to "Flag Service Organization" or "FSO."
15. Although I recognize that the State neither writes the stories nor the headlines, the fact of charging FSO has been interpreted publicly as a sound denunciation of the Scientology religion and all its parishioners as criminally complicit. A March 28, 1999 article in the St. Petersburg Times encapsulates the essence of this perception. At the conclusion of a two-and- one-half page front-page article, the Times reporter wrote: "Cranes over downtown Clearwater stand in testament to the church' s continued growth as the church and its members change the

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face of that city. But standing in the way is Pinellas-Pasco State Attorney Bernie McCabe, the prosecutor and a fresh charge that strikes at the heart of Scientology's claim that it helps its adherents." (Emphasis added.)

FURTHER AFFIANT SAYETH NAUGHT.

[signed]
Reverend Michael J. Rinder

STATE OF FLORIDA )
) ss.:
County of Pinellas ) "
The foregoing instrument was acknowledged before me this 9th day of May, 1999, by Reverend Michael J. Rinder, who is personally known to me and who did take an oath.

[signed]
ASHER SAMUEL GHIORA
MY COMMISSION. CC69144S
EXPIRES October 26.2001