UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA
v.
JANE KEMBER:
MORRIS BUDLONG
a/k/a MO BUDLONG: |
:
:
:
: |
Criminal No. 78-401(2)&(3) |
SENTENCING MEMORANDUM OF THE UNITED STATES OF AMERICA
The United States of America respectfully submits this Sentencing Memorandum
to aid the Court in imposing sentence in this case.
[...]
[The Scientology conspirators] challenged and attempted to undermine the
judicial
and governmental structure of the United States.
[...]
Thus, they perpetrated a fraud upon the American judicial system.
[...]
These crimes included: the infiltration and theft of documents from a number
of prominent private, national, and world organizations, law firms, newspapers,
and private citizens; the execution of smear campaigns and baseless law suits
for the sole purpose of destroying private individuals who had attempted to
exercise
their First Amendment rights to freedom of expression; the framing of private
citizens who had been critical of Scientology, including the forging of documents
which led to the indictment of at least one innocent person; and violation of
the civil rights of prominent private citizens and public officials.
[...]
[T]hese documents establish beyond question that the defendants, their
convicted
co-defendants, and their unindicted co-conspirators, as well as their
organization,
considered themselves above the law. They believed that they had carte blanche
to violate the rights of others, frame critics in order to destroy them,
burglarize
private and public offices and steal documents outlining the strategy of
individuals
and organizations that the Church had sued. These suits were filed by the Church
for the sole purpose of financially bankrupting its critics and in order to
create
an atmosphere of fear so that critics would shy away from exercising the First
Amendment rights secured them by the Constitution. The defendants and their
cohorts
launched vicious smear campaigns, spreading falsehoods against those they
perceived
to be enemies of Scientology in order to discredit them and, in some instances,
to cause them to lose their employment.
[...]
To these defendants and their associates, however, anyone who did not agree
with them was considered to be an enemy against whom the so-called "fair
game doctrine" could be invoked. Allard v. Church of Scientology of
California,
[58
Cal. App. 3d 439, 129 Cal. Rprtr. 797 (Ct. App, 1976), cert denied, 97 S.
Ct. 1101 (1977)]. That doctrine provides that anyone perceived to be an enemy
of Scientology or a "suppressive person," "[m]ay be deprived of
property or injured by any means by any Scientologist without any discipline of
the Scientologist. [He m]ay be tricked, sued or lied to or destroyed." Id.
This policy, together with the actions of these defendants who represent the very
top leadership of the Church of Scientology, bring into question their claim that
their Church prohibited the commission of illegal acts.
[...]
The defendants directed and encouraged a number of covert operations against
private individuals and public officials to destroy and discredit these persons
because they had either attempted to exercise their First Amendment rights by
criticizing Scientology or by attempting to carry out their duties as public
officials.
[...]
That these defendants were willing to frame their critics to the point of
giving false testimony under oath against them, and having them arrested and
indicted
speaks legion for their disdain for the rule of law. Indeed, they arrogantly
placed
themselves above the law meting out their personal brand of punishment to those
"guilty" of opposing their selfish aims. The crimes committed by these
defendants is of a breadth and scope previously unheard. No building, office,
desk, or files was safe from their snooping and prying. No individual or
organization
was free from their despicable scheming and warped minds.
[...]
These defendants rewarded criminal activities that ended in success and
sternly
rebuked those that failed. The standards of human conduct embodied in such
practices
represent no less than the absolute perversion of any known ethical value system.
In view of this, it defies the imagination that these defendants have the
unmitigated
audacity to seek to defend their actions in the name of "religion."
That these defendants now attempt to hide behind the sacred principles of freedom
of religion, freedom of speech and the right to privacy -- which principles they
repeatedly demonstrated a willingness to violate with impunity -- adds insult
to the injuries which they have inflicted on every element of society. These
defendants,
their co-conspirators, their organization, and any other individual or group that
might consider committing similar crimes, must be given a clear and convincing
message: criminal activities of the types engaged in here shall not be tolerated
by our society.
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