Sara Northrup declaration

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wbarwell

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Feb 9, 2006, 9:14:49 AM2/9/06
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WARNER & JACKSON
639 South Spring Street
Los Angeles 14, California
Tucker 9171
Attorneys for Plaintiff


[Stamped: FILED Apr 23, 1951, Harold Cecily, County Clerk]


IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF
LOS ANGELES
SARA NORTHRUP HUBBARD, )
)
Plaintiff, )
)
vs.v )
)
L. RON HUBBARD, also known as )
LAFAYETTE RONALD HUBBARD; )
Los Angeles Department HUBBARD DIANETIC )
RESEARCH FOUNDATION, a partnership; )
THE HUBBARD DIANETIC RESEARCH FOUNDATION )
OF CALIFORNIA, INC., a California )
corporation; )
FRANK B.DESSLER; RICHARD B. DE MILLE; ) No. D
VINCE MC GONIGEL; ) COMPLAINT
WESTWOOD NURSES REGISTRY AGENCY; ) FOR DIVORCE
BEKINS VAN AND STORAGE CO.; )
BANK OF AMERICA NATIONAL TRUST & SAVINGS )
ASSOCIATION; )
SECURITY FIRST NATIONAL BANK OF LOS ANGELES;)
DOE ONE, DOE TWO, DOE THREE, DOE FOUR, )
DOE FIVE, DOE SIX, DOE SEVEN, DOE )
EIGHT, DOE NINE and DOE TEN, )
)
Defendants. )


[Stamped: D414408]

COMES NOW the plaintiff and for cause of action against defendants
alleges and says:


I

That in the early part of 1946, plaintiff, then age 21 and
unmarried, resided with her family in Pasadena, and a the University of
Southern California, that at said time, defendant L. Ron Hubbard,
hereinafter referred to as "Hubbard", was a married man, age 35, he
being then married to Margaret Grubb


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Hubbard of Bremerton, Washington, they having two children; that said
Hubbard represented to plaintiff that he was single and unmarried, and
plaintiff relying upon said representation, and having fallen in love,
entered into a marriage ceremony with said Hubbard on the 10th day of
August, 1946, at Chestertown, Maryland that said Hubbard thereafter
secured a divorce from said Margaret Grubb Hubbard on or about the 24th
day of December, 1947, at Port Orchard, Washington; that plaintiff and
said Hubbard ever since the said 10th day of August, 1946, have lived
together as husband and wife, and on the 8th day of March, 1950, had a
child born to them, Alexis Valorie [sic] Hubbard, at Point Pleasant, New
Jersey; that the parties have always considered themselves husband and
wife in their travels about the nation; that at all times herein
mentioned, said Hubbard has represented to plaintiff that they were
legally married, and plaintiff relied upon such representations; that by
reason thereof, plaintiff alleges herein. that plaintiff and said
Hubbard are husband and wife; that in the event it should be held that
the parties are not legally married, plaintiff will seek the damages
prayed for herein for fraud and deceit on the part of said Hubbard, in
entrapping plaintiff into the matrimonial predicament that she now finds
herself in.


II

That plaintiff was born in Pasadena, California on the 8th day of
April, 1925, and grew up and was educated in the State of California;
that plaintiff does now and always has considered California to be her
home state, and plaintiff and said Hubbard have maintained their
residence in California from time to time since said marriage in between
their travels about the United States and at all times have had their
furniture in the State of California, and have considered California to
be their permanent residence; that by reason thereof, plaintiff is now
and for more


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than one year immediately preceding the commencement of this action, has
been a resident of the State of California; that plaintiff has been a
resident of the County of Los Angeles for more than three months,
immediately preceding the commencement of this action.


III

Statistical facts required by section 426a of the Civil Code of
Procedure are:

Place of marriage; Chestertown, Maryland;

Date of marriage; On the 10th day of August 1946;

Date of separation; On or about the 24th day of February 1951;

Time elapsing between the date of marriage and the date of separation;
Approximately four years, six months and twelve days; and

there is one child of the marriage; Alexis Valorie Hubbard, age 13
months.
IV

That there is community property of the plaintiff and said Hubbard
consisting of a community interest in the Hubbard Dianetic Research
Foundation, with its headquarters in Elizabeth. New Jersey, and which
operates a school and clinic in Chicago, Illinois, New York City, Los
Angeles, Honolulu, Wichita, Kansas, and elsewhere; that said Hubbard and
said foundation did over one million dollars in business during the year
1950, and owns valuable community property and assets; that said
foundation operates in the State of California, under the name of "The
Hubbard Dianetic Research Foundation of California, Inc., a California
corporation", defendant herein; that said corporation. is the alter ego
of said Hubbard.


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That said separation took place by reason of the extreme cruelty
practiced upon the plaintiff by the said Hubbard, which has caused the
plaintiff great mental anguish and physical suffering during the past
five years of the married life of the parties, consisting in part as
follows;


That during the marriage up until the month of October, 1950, said
Hubbard, an "older man" completely dominated the youthful plaintiff,
both physically, mentally and emotionally and taking advantage of her
trusting love and desire for a successful marriage, repeatedly subjected
plaintiff to systematic torture, including loss of sleep, beatings, and
strangulations and scientific torture experiments, including the
following:
That in the latter part of September, 1950, said Hubbard told plaintiff
at the Chateau Marmont Apartments in Hollywood, that "I do not want to
be an American husband for I can buy my friends whenever I want them",
and he further said that he, Hubbard, did not want to be married, yet
divorce was impossible, for a divorce would hurt his reputation, and
that she, plaintiff, should kill herself if she really loved him.
That at said time and place, said Hubbard systematically prevented
plaintiff from sleeping continuously for a period of over four days, and
then in her agony, furnished her with a supply of sleeping pills, all
resulting in a nearness to the shadow of death. That the foregoing was a
frequent occurence [sic] during the married life of the parties.
That at said time and place, plaintiff became numb and lost
consciousness, and was thereafter taken by said Hubbard to the Hollywood
Leland Hospital, where she was kept under a vigilant guard from friend
and family under an assumed name, for five days.
That shortly following Christmas, 1953, said Hubbard

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-------------------------------------------------------------

violently strangled plaintiff and sadistically ruptured the eustachian
tube of her left ear, resulting in the impairment of her hearing. That
such strangulation of plaintiff was a frequent practice on the part of
said Hubbard.

That in January, 1951, at Palm Springs, while plaintiff was getting out
of an automobile operated by said Hubbard he intentionally started the
said car in gear, thus propelling plaintiff to the pavement resulting in
serious personal injury.
That plaintiff and her medical advisors, following the foregoing
incidents, concluded that said Hubbard was hopelessly insane, and crazy,
and that there was no present hope for said Hubbard, or any reason for
her to indure [sic] further; that competent medical advisors recommended
that said Hubbard be committed to a private sanitarium for psychiatric
observation and treatment of a mental ailment known as paranoid
schizophrenia; that plaintiff, on the 23rd day of February, 1951, caused
the national executive officer of the Hubbard Dianetic Research
Foundation at Elizabeth, New Jersey, to be advised of said preliminary
diagnosis and urgent need for treatment; that said national officer
immediately advised said Hubbard of said diagnosis.
That at 11;00 o'clock P.M., on said 23rd day of February, 1951, said
Hubbard, together with defendant Frank B. Dessler, head of the Los
Angeles Dianetic Foundation, abducted the infant child of the parties,
Alexis from her crib, and deposited said infant in West Los Angeles with
defendant Vince Mc Gonigle under the assumed name of Anne Marie Olson,
and concealed said infant from plaintiff until this day. That this was
admitted by said Dessler in the habeas corpus proceedings filed on the
10th day of April, 1951 entitled In re Alexis Valorie Hubbard, Los
Angeles Superior Court Number H.C. 35879.
That said Hubbard, Dessler and defendant Richard B. De Mille, having
secreted said infant child, feloniously dragged

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-------------------------------------------------------------

plaintiff out of her bed attired only in her night gown, it then being
1;00 o'clock A.M., of the morning of the 24th day of February, 1951, and
by the use of threats, strangulation, torture, and false promises to
return her child to her, carried and kidnapped plaintiff to Yuma,
Arizona, all as is detailed at length in the habeas corpus proceeding
above mentioned.

That plaintiff has ever since sought the whereabouts of her infant child,
and has consulted attorneys, police, sheriffs, Federal Bureau Of
Investigation agents, and courts, and has brought said habeas corpus
proceedings; that said Hubbard and his attorneys refuse any information
as to the whereabouts of her infant child, unless she goes back to live
with said Hubbard, an alternative that means certain continued torture
and possible death, a predicament no good woman, wife and mother should
have to face.
That through all her trials and tribulations, and up until the month of
February, 1951, plaintiff bore her suffering and sorrows in silence and
even now would not bare the truth to the world, except for the
compelling advice of her attorney, Caryl Warner, that she tell the truth
for the truth will make her free, and the truth alone, will bring back
her baby, if alive.
That by reason of the foregoing crazy misconduct of said Hubbard,
plaintiff is in hourly fear of both the life of herself and of her
infant daughter, who she has not seen for two months.
That all of said acts on the part of said Hubbard towards the
plaintiff have been without cause or justification, and without the
consent of the plaintiff, and have caused her great mental anguish and
horrible physical suffering.

VI

That the custody of said infant child Alexis should be awarded to
plaintiff, without reservation or condition; that the Court should order
and compel said Hubbard to submit to legitimate


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psychiatric examination in the interests of tile welfare and safety of
said minor child, who is secreted by Hubbard someplace in North America.


VII

That said Hubbard is an able-bodied man, and is well able to
support and provide for plaintiff and their child; that by reason
thereof, said Hubbard should be ordered to pay to plaintiff reasonable
support for plaintiff and said infant child during the pendency of this
action, and thereafter pay permanent alimony and child support; that in
addition thereto, said Hubbard should be ordered to pay a reasonable sum
as and for attorney's fees and costs of suit; that a lien should be
impressed upon the real property hereinafter described to secure payment
of the sums allowed herein.


VIII

That said Hubbard has harrassed [sic], injured and kidnapped
plaintiff as alleged herein, and has threatened to kill plaintiff; that
plaintiff is informed and believes, and upon such information and belief
alleges that said Hubbard, unless restrained from so doing, will carry
out his said threats, and will again injure and molest plaintiff; that
by reason thereof, the Court should restrain said Hubbard from molesting
or injuring plaintiff during the pendency of this hearing of this cause,
and upon the trial of this action, the Court should permanently enjoin
said Hubbard from committing any of said acts in regard to plaintiff.


IX

That said Hubbard departed from the State of California on the 24th
day of February, 1951, and ever since has remained outside of
California, for the purpose of evading the process of the Court, and for
the purpose of attempting to deprive plaintiff of her marital rights
herein; that said absence from the State on the part of said Hubbard was
and is for the purpose of resisting


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plaintiff's efforts to enforce her said rights against said defendant for
support and maintenance for herself and her child and to obtain an
equitable division of the community property of the parties; that said
Hubbard has repeatedly threatened that he would stay out of California
so as to make it impossible for her to get any money or support from him
and to prevent her from sharing in the community property of the
parties, and said Hubbard has stated that he would do everything in his
power to deprive plaintiff. of all of her said marital rights; that
plaintiff is informed and believes, and upon such information and
belief, alleges that pursuant to said threats, said Hubbard has
concealed various community assets, and has placed said assets in the
name of Hubbard Dianetics Research Foundation, and in the names of the
other defendants named herein, and in the names of other persons unknown
to the plaintiff that said Hubbard will continue to further hide and
conceal said community property assets from plaintiff unless prevented
from doing so by the appointment of a receiver herein; that by reason of
the said acts of said Hubbard, plaintiff has been compelled to exhaust
her own personal estates and to draw upon her family for support; that
by reason thereof, plaintiff is without adequate funds for her own
support or the support of her child, or to prosecute this action; that
all of the acts heretofore set forth on the part of said Hubbard were
perpetrated intentionally and willfully and for the express purpose of
defrauding plaintiff of her said marital rights, and to unjustly and
fraudulently deprive plaintiff of any and all of her rights whatsoever,
and to render her helpless and subject to his complete and arbitrary
will and domination.


X

That said receiver should be empowered to take over, operate, and
sell the defendant Hubbard Dianetic Research Foundation of California,
Inc., property at 2300 South Hoover Street, Los


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Angeles, California, and more particularly described as;

Lot 6 of Belgravia Tract, in the City of
Los Angeles, County of Los Angeles, State
of California, 8S per map in Book 23,
Page 54 of Miscellaneous Records of said
County, and a portion of Lot 3, Block 22,
of Hancock's Survey in said City and
County of Los Angeles, as per map recorded
in Book 2, page 108 of Miscellaneous
Records of said county;
that said receiver should be allowed to pay to plaintiff such sums
as the Court may allow for the support of plaintiff and the minor child,
and for her attorney's fees and costs incurred herein; that plaintiff
has no plain, speedy or adequate remedy at law other then the
appointment Of a receiver, for the reasons set forth herein.

XI

That the true names or capacities, whether individual corporate,
associate or otherwise, of defendants Doe One through Doe Tens
inclusive, are unknown to plaintiffs who there ore sues said defendants
by such fictitious names, and will as, leave to amend this complaint to
show their true names and capacities when same have been ascertained.


AND FOR A SECOND, SEPARATE AND FURTHER
CAUSE OF ACTION, plaintiff alleges and says;

I

Plaintiff refers to Paragraphs I, II, III, IV, V, VI, and VII of
her First Cause of Action and by reference makes them a part hereof.


II

That plaintiff believes herself to be the lawfully wedded wife of
said defendant L. Ron Hubbard, in that she entered


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into said marriage in good faith, all as is alleged herein; that in the
event the Court should find that she is not legally married to said
defendant, plaintiff in such an event alleges that said marriage should
be annuled [sic], and that she be awarded damages as hereinafter set
forth; that said defendant wilfully [sic] and intentionally caused
plaintiff to believe that she was his lawfully wedded wife, and if she
in fact is not, said Hubbard in such an event should be ordered to pay
the damages prayed for herein.


III

That plaintiff, believing that she was the lawfully wedded wife of
said Hubbard, over a period of five years, devoted her life to said
Hubbard, and served as wife, mother, housekeeper, author's assistant,
and pursuant thereto, washed dishes, cleared floors, scrubbed the floors
and walls, cooked and served meals for said Hubbard, bore him a child,
[loaned him over $20,000 - crossed out], and otherwise subjected herself
to the course of cruelty alleged herein; that by reason thereof, the
chances of plaintiff for happiness in life, and chances for a normal
marriage have been diminished, and plaintiff has been prevented from
following a profession of her choice, and has been so deprived of the
"golden years of a woman's life", and by reason thereof, she has been
damaged in the sum of $100,000.00 a year, making a total of $500,000.00
in all, if in fact it be found that she is not the lawfully wedded wife
of said Hubbard, and has been subjected to the shame of a bigamous
marriage.


IV

That in the event it be found that plaintiff is not the lawfully
wedded wife of said Hubbard, plaintiff should be accorded the right of a
putative wife, and by reason thereof, should be allowed the same
community property rights and interests in and to the property acquired
by the plaintiff and the said Hubbard, following said ceremonial
marriage on the 10th day of August,


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1946, all as is prayed for herein.


WHEREFORE, plaintiff prays judgment against defendant, L. Ron
Hubbard, as follows;

For a Judgment of divorce from said defendant, that the bonds of
matrimony heretofore and now existing between said parties be dissolved;
That the custody of the minor child of the marriage, Alexis Valorie
Hubbard, be awarded to plaintiff;
That defendant L. Ron Hubbard be ordered to pay to plaintiff reasonable
alimony and support, and further provide reasonable support and
maintenance for the minor child of the said marriage, Alexis Valorie
Hubbard;
That the community property of the parties hereto be equitably
apportioned, and the right, title and claim of interest of defendants
herein other than said defendant Hubbard, be determined and adjudicated.
That a lien be impressed upon the real property of said defendant
Hubbard, to secure the payment of the sums of the alimony and support
allowed herein;
That reasonable attorney's fees and costs of suit be awarded plaintiff
and her counsel, and that said defendant be ordered to pay the same.
That in the event it be held that plaintiff is not a resident of the
State of California, for the prescribed period, in such an event
plaintiff prays that a decree of separate maintenance be entered herein,
in lieu of a divorce;
That the Court appoint a receiver herein with customary powers to take
over, manage, operate, and sell the business and properties of the
community estate of the parties including the real property described in
the complaint, said property to be held by said receiver subject to the
order and direction of the Court, and that all defendants herein be
ordered

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-------------------------------------------------------------

and directed to pay to said receiver, any community funds and deliver any
community property they have in their possession, and that said receiver
to be appointed ex parte, and that upon notice, said appointment of said
receiver be confirmed and made permanent;

That said defendant Hubbard be restrained from injuring, molesting, or
harming plaintiff, and be restrained from interfering with the custody
of the minor child, and that upon the trial of the cause, said
restraining order be made permanent;
That said Hubbard be restrained from concealing, dissipating, transfering
[sic], or hiding any of the community property assets or property of the
parties hereto; and
That if said marriage be held bigamous, that it be annuled;
That plaintiff be awarded damages in the sum of $500,000, if said
marriage be found to be invalid;
That said Hubbard be ordered to submit to a psychatric [sic] examination
as a protection to said infant child; and
That plaintiff be awarded any such other and further relief as is meet
and proper.
WARNER & JACKSON

[signed: Caryl Warner]
By: ________________
Caryl Warner
Attorneys for Plaintiff

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STATE OF CALIFORNIA )
County of Los Angeles ) ss.

SARA NORTHRUP HUBBARD being by me first duly sworn, deposes and
says: that she is the plaintiff in the above entitled action; that she
has read the foregoing Complaint for Divorce and knows the contents
thereof, and that the same is true of her own knowledge, except as to
the matters which are therein stated upon her information or belief, and
as to those matters she believes it to be true.

[signed: Sara Northrup Hubbard]
_____________________
Sara Northrup Hubbard

Subscribed and sworn before me
this 23rd day of April, 1951.


[signed: B. R. Trout]
______________________________


Notary Public in and for said (SEAL)
County of Los Angeles, State of
California
--

To delight in war is a merit in the soldier, a dangerous
quality in the captain and a positive crime in a statesman.
- George Santayana

Cheerful Charlie

Lermanet.com

unread,
Feb 9, 2006, 3:18:09 PM2/9/06
to
On Thu, 09 Feb 2006 08:14:49 -0600, wbarwell <wbar...@mylinuxisp.com>
wrote:

>

nice, Id never seen this before thanks!

Arnaldo Lerma
Lermanet.com Exposing the CON

I'd prefer to die speaking my mind than live fearing to speake

If the Borg were to breed with the Ferengi you'd get Scientology!

29 November 1995 - Memorandum Opinion Judge Leonie Brinkema
"the Court is now convinced that the primary motivation of RTC in suing Lerma, DGS and The Post is to stifle criticism of Scientology in general and to harass its critics. "

The internet is the Liberty Tree

http://www.lermanet.com/faqs.html#psychiatry
http://www.lermanet.com/exit/hubbard-the-hypnotist.htm
http://www.lermanet.com/scientology/altreligionscientology-killfile-settings.htm
http://www.lermanet.com/scientologynews/crowley-hubbard-666.htm
http://www.lermanet.com/scientologynews/flint-suicides-in-scientology-040383.htm
both with IMAGES!!

"Scientologists believe that most human problems
can be traced to lingering spirits of an extraterrestrial
people massacred by their ruler, Xenu, over 75 million
years ago. These spirits attach themselves by "clusters"
to individuals in the contemporary world, causing
spiritual harm and negatively influencing the lives
of their hosts"
[Judge Leonie Brinkema 4 Oct 96 Memorandum Opinion]

What do we get from getting people out of scientology?
We create an individual who has become a Houdini of
all mind traps.. folks who won't be fooled again.
People who can DE-program, People who can spring mental
traps..

We create, by freeing someone of scientology, a being
who has the ability to break the strongest slave chains
of all.

Those forged of lies. (c) Arnaldo Lerma

ida...@aol.com

unread,
Feb 9, 2006, 11:16:09 PM2/9/06
to
thanks again--- I had not read this either. Nice that Hubbard's
meaness is recorded for all to read.

Ida Camburn

"If attacked on some vulnerable point by anyone or anything or any
organization, always find or manufacture enough threat against them to
cause
them to sue for peace."
- L. Ron Hubbard, Hubbard Communications Office Policy Letter,
15 August 1960, Dept. of Govt. Affairs

Susan

unread,
Feb 10, 2006, 12:07:03 AM2/10/06
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Hmmm, recognized as a paranoid schizophrenic then.

Susan

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