Fair Game (Scientology)

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The term Fair Game is used to describe various aggressive policies and practices carried out by the Church of Scientology towards people and groups it perceives as its enemies.

Contents 1 Predecessors of "Fair Game" 2 Fair Game Law 3 Cancellation of the term "Fair Game" 4 Ongoing aggressive policy 5 Recent events 6 Court cases involving "Fair Game" 6.1 The case of L. Gene Allard, 1976 6.2 The case of Lawrence Wollersheim, 1980 6.3 The case of Jakob Anderson, 1981 6.4 The case of Gerald Armstrong, 1984 7 History of Fair Game in the UK 8 Ongoing use of "Fair Game" 8.1 Further policy modifications 9 See also 10 References 11 External links

[edit] Predecessors of "Fair Game"

In written policies dating from as early as the mid-1950s, Scientology founder L. Ron Hubbard told his followers to take a punitive line towards perceived opponents. In 1955, he wrote "the law can be used very easily to harass ... The purpose of the suit is to harass and discourage, rather than to win – if possible, of course, ruin [the target] utterly".^[1]

His confidential Manual of Justice of 1959 advocated using private investigators, as critics were invariably "found to be members of the Communist Party or criminals, usually both. The smell of police or private detectives caused them to fly, to close down, to confess."^[2] In a very similar vein, he advised that "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."^[3]

[edit] Fair Game Law

In 1965 Hubbard formulated the "Fair Game Law", which states how to deal with people who interfere with Scientology's activities. These problematic people, called suppressive persons, could be considered "fair game" for retaliation:

A Suppressive Person or Group becomes fair game. By FAIR GAME is meant, may not be further protected by the codes and disciplines or the rights of a Scientologist.^[4]

Later in December of that year, Hubbard reissued the Fair Game policy with additional clarifications to define the scope of Fair Game. He made it clear that the policy applied to non-Scientologists as well. He declared:

The homes, property, places and abodes of persons who have been active in attempting to: suppress Scientology or Scientologists are all beyond any protection of Scientology Ethics, unless absolved by later Ethics or an amnesty ... this Policy Letter extends to suppressive non-Scientology wives and husbands and parents, or other family members or hostile groups or even close friends.^[5]

Hubbard made it clear elsewhere in his writings that the policy would be applied to external organizations, including governments, that were guilty of having interfered with Scientology's activities. He told Scientologists:

If the Internal Revenue Service (in refusing the FCDC [Founding Church of Scientology, Washington DC] non-profit status) continues to act up or if the FDA does sue we can of course Comm Ev [Committee of Evidence] them and if found guilty, label and publish them as a Suppressive Group and fair game ... [N]one is fair game until he or she declares against us.^[6]

The policy was further extended in an October 1967 Policy Letter (HCOPL 18 Oct 67 Issue IV, Penalties for Lower Conditions), where Hubbard defined the "penalties" for an individual deemed to be in a "Condition of Enemy":

ENEMY — SP Order. Fair game. May be deprived of property or injured by any means by any Scientologist without any discipline of the Scientologist. May be tricked, sued or lied to or destroyed.^[7]

When a man named Peter Goodwin in Hampshire, England purchased a high-level Scientology course for £250 and resold it to friends for £50, Hubbard personally issued an Ethics order which "withdrew any future help from Goodwin and his associates, (presumably for eternity), and threatened the most dire retaliations."^[8]

[edit] Cancellation of the term "Fair Game"

In July 1968, Hubbard canceled HCOPL 18 Oct 67 Issue IV, Penalties for Lower Conditions, replacing it with HCOPL 21 July 68, Penalties for Lower Conditions.^[9] This redefined the condition of Enemy as follows:

"Suppressive Person order. May not be communicated with by anyone except an Ethics Officer, Master at Arms, a Hearing Officer or a Board or Committee. May be restrained or imprisoned. May not be protected by any rules or laws of the group he sought to injure as he sought to destroy or bar fair practices for others. May not be trained or processed or admitted to any org." ^[10]

In addition, in October that year, Hubbard issued HCOPL 21 Oct 68 Cancellation of Fair Game, which said:

"The practice of declaring people FAIR GAME will cease. FAIR GAME may not appear on any Ethics Order. It causes bad public relations. This P/L does not cancel any policy on the treatment or handling of an SP."

This letter states that it cancels only the use of the term "fair game" for its "bad PR" effect, and not the policy on the treatment of "suppressive persons" in question.

In 1976, Hubbard said in an affidavit that "Fair Game" was never intended to authorize harassment:

There was never any attempt or intent on my part by the writing of these policies (or any others for that fact), to authorise illegal or harassment type acts against anyone. As soon as it became apparent to me that the concept of 'Fair Game' as described above was being misinterpreted by the uninformed, to mean the granting of a license to Scientologists for acts in violation of the law and/or other standards of decency, these policies were cancelled.^[11]

[edit] Ongoing aggressive policy

An Ethics Order dating from March 6, 1968, issued by L. Ron Hubbard aboard his boat the Royal Scotsman, lists twelve scientologists who were accused of distributing altered versions of upper level technology. Hubbard writes "They are fair game. No amnesty may ever cover them. [...] Any Sea Org member contacting them is to use Auditing Process R2-45." ^{[12] [13]}

Critical authors such as Jon Atack and websites such as Operation Clambake, who make no reference to the existence of HCOPL 21 July 68 canceling the original penalties, use the wording of HCOPL 21 Oct 68 to assert that the practices outlined in HCOPL 18 Oct 67 Issue IV have been canceled in name only.^[14][15]

The Church has indeed retained an aggressive policy towards those it perceives as its enemies,^[16][17] and argued as late as 1985 that retributive action against "enemies of Scientology" should be considered a Constitutionally-protected "core practice" of Scientology.^[18] Apart from critics, several judges and juries have through their decisions or comments asserted that the tactics and penalties described in the October 1967 Policy Letter continued beyond both Hubbard's July 1968 Policy Letter canceling these penalties, and beyond his October 1968 order canceling the use of the term Fair Game.^[19][14][20]

For example, Lord Justice Stephenson, in the judgement in Church of Scientology of California v. Department of Health and Social Security [1979], declined to order discovery in favour of the Church of Scientology on the grounds that there was a real risk of harassment of the persons named in the documents:

I have carefully considered the documents to which we have been referred and some to which we have not. I am satisfied by my consideration of the documents that there is a real risk that all three categories of documents may be misused, ie not for legitimate purposes of the action but for harassment of individual patients, informants and renegades named in them, not only by proceedings for defamation against them but by threats and blackmail, and that they may be distributed to those in other parts of this worldwide organisation who may misuse them in the same way. I am thinking chiefly of the 'fair game law' against suppressive persons expounded in the HCO policy letter of 1 March 1965 and referred to in the particulars, and the policy letter of 21 October 1968 cancelling publication of the policy in the interests of public relations, but not the policy itself.^[21]

[edit] Recent events

In recent years, a number of ex-Scientologists who formerly held senior management positions in the Church have alleged that while working for the Church they saw "Fair Game" tactics continuing to be used. In 1994, Vicki Aznaran, who had been the Chairman of the Board of the Religious Technology Center (the Church's central management body), claimed in an affidavit that

Because of my position and the reports which regularly crossed my desk, I know that during my entire presidency of RTC "fair game" actions against enemies were daily routine. Apart from the legal tactics described below, the "fair game" activities included break-ins, libel, upsetting the companies of the enemy, espionage, harassment, misuse of confidential communications in the folders of community members and so forth.^[22]

[edit] Court cases involving "Fair Game"

[edit] The case of L. Gene Allard, 1976

In 1976, the Church was found legally liable for the malicious prosecution of a dissatisfied Scientologist named L. Gene Allard who left Scientology in 1969. The suit specifically charged the Church with "Fair Gaming" Allard according to Church policy.^{[citation needed]}

[edit] The case of Lawrence Wollersheim, 1980

In a long and contentious trial, Lawrence Wollersheim, a former Scientologist, alleged that he had been harassed and his business nearly destroyed as a result of "fair game" measures. During appeals, the Church again claimed "Fair Game" was a "core practice" of Scientology and was thus a constitutionally protected activity. That claim was denied by the appellate court on July 18, 1989. After over 20 years of legal wrangling, the Church of Scientology paid Wollersheim the amount of the judgement, plus interest: $8,674,643. ^[23]

[edit] The case of Jakob Anderson, 1981

In the March 11-16, 1981, Danish court case of Jakob Anderson vs The Church Of Scientology of Denmark, ex-Guardian's Office operative Vibeke Dammon testified that the Church did in fact practice Fair Game and had done so in Anderson's case, in an attempt to get Anderson committed to a psychiatric hospital.^{[citation needed]}

[edit] The case of Gerald Armstrong, 1984

In 1980, Scientologist and Sea Org officer Gerry Armstrong was assigned to organize some of Hubbard's personal papers as the basis for a biography of Hubbard. Omar Garrison, a non-Scientologist known to be sympathetic to Scientology, was hired to write the biography. Both Armstrong and Garrison quickly realized that the papers reflected unfavorably on Hubbard, and revealed that many of Hubbard's claimed accomplishments were exaggerations or outright fabrications. Garrison abandoned the project, and a disillusioned Armstrong and his wife left the Church, retaining copies of the embarrassing materials as insurance against the expected harassment to come.^[24] Armstrong was sued by the Church in 1982 for the theft of private documents. The "Fair Game" policy became an issue in court. Armstrong won the case, in part because the Judge ruled that Armstrong, as a Scientologist of long standing, knew that fair game was practiced, and had good reason to believe that possession of these papers would be necessary to defend himself against illegal persecution by the Church.^[25] In a scathing decision, Judge Paul Breckenridge wrote:

In addition to violating and abusing its own members civil-rights, the organization over the years with its "Fair Game" doctrine has harassed and abused those persons not in the Church whom it perceives as enemies. The organization clearly is schizophrenic and paranoid, and the bizarre combination seems to be a reflection of its founder LRH. The evidence portrays a man who has been virtually a pathological liar when it comes to his history, background, and achievements ... In determining whether the defendant unreasonably invaded Mrs. Hubbard's privacy, the court is satisfied the invasion was slight, and the reasons and justification for the defendant's conduct manifest. Defendant was told by Scientology to get an attorney. He was declared an enemy by the Church. He believed, reasonably, that he was subject to "fair game." The only way he could defend himself, his integrity, and his wife was to take that which was available to him and place it in a safe harbor, to wit, his lawyer's custody. (Judge Paul Breckenridge, Los Angeles Superior Court, June 20, 1984)

During the trial, the Church hired Frank K. Flynn, an adjunct professor of comparative religions, to write a report arguing that Fair Game was a "core practice" of Scientology and thus should be considered a constitutionally protected activity.^{[citation needed]}

[edit] History of Fair Game in the UK

In the UK, targets of Fair Game and related harassment over the years have included ex-members, authors, journalists, broadcasters, the mental health profession, cult-monitoring groups, government and law enforcement.

Maurice William Johnson was a scientologist who resigned in June 1966 and successfully sued for his money back. He told a court that after leaving he had received over 100 abusive letters, many of them using violent language. An article in "The Auditor", a Scientology publication, was produced to the court, stating outright that Johnson was "fair game" and describing him as "an enemy of mankind, the planets and all life."^[26][27]

Documents seized by the FBI in raids on the Church's US headquarters in July 1977 listed some operations against their British enemies. An agent had been sent to investigate Sir John Foster, author of the official UK Government inquiry into Scientology, in an attempt to link him to Paulette Cooper, author of The Scandal of Scientology and victim of Operation Freakout. The documents showed that Lord Balniel, who had requested the official inquiry, was also a target. Hubbard had written, "get a detective on that lord's past to unearth the tit-bits". A memo from Jane Kember, the Church's Saint Hill-based "Guardian" (or worldwide head of intelligence) reported that agents had got hold of a Metropolitan Police report on the Church. She asked for related documents so that a lawsuit against the police could be "mocked up".^[28]

According to a memo of 6 May 1971, Hubbard blamed the National Association for Mental Health (NAMH) and World Federation for Mental Health for attacks on Scientology and named Mary Appleby, secretary of the NAMH, as the ultimate source.^[28] Starting in 1969, the NAMH was the target of a mass infiltration campaign by Scientologists who tried to take over key offices and change the organisation's policy on psychiatry. The large numbers of new membership applications just before a deadline raised the suspicion of the existing members and led to a mass explusion. The Church of Scientology sued unsuccessfully in an attempt to get their members reinstated.^[29]

Kenneth Robinson, a Minister for Health, had attributed Scientology's success to its targeting "the weak, the unbalanced, the immature, the rootless and mentally and emotionally unstable" and said its practices were "a potential menace to the personality and well-being of those so deluded as to become its followers".^[30][31] Scientology publications titled "Freedom Scientology", "Freedom and Scientology" and "Freedom" conducted a libel campaign against him, beginning in 1968. According to these newsletters, he was responsible for creating "death camps" to which innocent people were being kidnapped to be killed or maimed at will. Robinson successfully sued for libel, prompting a total retraction and substantial damages.^[32]

Roy Wallis was the author of "The Road to Total Freedom: A Sociological Analysis of Scientology", first published in 1976. After the publication of the book, a Scientology agent visited Stirling University where Wallis was teaching and tried to get him to implicate himself in the drug scene. Subsequently, forged letters apparently from Wallis were sent to his colleagues implicating him in scandalous activities including a homosexual love affair.^[33][34]

Journalist Russell Miller wrote a biography of L. Ron Hubbard entitled "Bare-Faced Messiah", which was published in 1987. He was spied on while researching the book in the USA, and his friends and business associates received visits from scientologists and private detectives. Attempts were made to frame him for the murder of a London private detective, the murder of singer Dean Reed in East Berlin and a fire in an aircraft factory.^{[35][36][37][38]} Senior executives at publishers Michael Joseph, and at the Sunday Times, which serialised the book, received threatening phone calls and also a visit from private investigator Eugene Ingram, who worked for the Church.^[39] Another private investigator, Jarl Grieve Einar Cynewulf, told Sunday Times journalists that he had been offered "large sums of money" to find a link between Miller and the CIA.^[40] The Church unsuccessfully tried for an injunction against Miller and Penguin Books to stop the book being published; a move that the judge described as "both mischievous and misconceived".^[39][36]

In 1988, Scientology-connected group the Citizens Commission on Human Rights conducted a defamation campaign against Professor Sir Martin Roth, a Cambridge University professor of psychiatry. Material provided by the CCHR falsely alleged that experiments run by Professor Roth had damaged patients' brains with huge doses of LSD, led to more than 20 deaths in an Australian hospital, and maimed human subjects in Canada. The Newcastle Times, which had published an article based on the CCHR material, admitted the falsity of the allegations and paid substantial libel damages in 1990.^[41]

Jon Atack, an ex-scientologist who left in 1983, wrote the book "A Piece of Blue Sky: Scientology, Dianetics and L. Ron Hubbard Exposed" and the pamphlet "The Total Freedom Trap" as well as providing research for "Bare-Faced Messiah". He provided help to other members in leaving the organisation, as well as acting as an expert witness in various cases concerning Scientology. In response, Atack's home was repeatedly picketed by placard-carrying scientologists over the course of six days. Eugene Ingram, a private investigator employed by the Church, made visits to Atack, his elderly mother and other family and friends, spreading rumours that Atack would be going to prison. Scientologists also distributed leaflets entitled "The Truth about Jon Atack", implying that he was a drug dealer who only criticised Scientology for money.^[42][43][44]

Atack has complained of many additional forms of harassment. In 1991, he wrote, pairs of scientologists would arrive on his doorstep weekly to harangue him.^[45] In a court filing, Atack wrote that scientologists had used their own publications and leaflets, a public meeting and a letter to the Sunday Times to spread rumours that he had been convicted for drug dealing and for "lewdness" and that he was guilty of other criminal activities including rape, attempted murder and kidnap. He also named an individual scientologist who apparently had made a frivolous complaint of child molestation to social services.^[46]

Atack eventually went bankrupt due to the cost of defending himself against legal action from the Church.^[47] He is not the only one to have been driven bankrupt. According to Baroness Sharples speaking in the House of Lords, a number of ex-scientologists "have been both threatened and harassed and a considerable number of them have been made bankrupt by the church."^[48]

During 1995, Beverley Ryall, a solicitor based in Chichester, was visited at midnight by a policewoman and by the head of the Church of Scientology's Bournemouth mission after a false tip-off that she was holding stolen documents in her house. She also reported a late night visit from Eugene Ingram. At that time Ryall was helping ex-scientologists in litigation against the Church.^[49][42] She told a local paper, "They have been harassing my clients and it is quite wrong. [...] They are just trying to intimidate me with Gestapo tactics." In response, a Scientology spokeswoman said that these allegations "are made by people who are lamenting and crying because they have a guilty conscience."^[50]

An American who moved to Britain, Bonnie Woods had been a member of the Sea Organisation but left Scientology in 1982. Since 1992, she and her husband Richard have run a telephone helpline for families affected by Scientology. Having been declared a Suppressive Person, she had her house picketed and her family were put under surveillance. Private investigator Eugene Ingram persuaded a creditor of Richard Woods' failed building firm to accept free help from scientologists to pursue her money. As a result, the family were bankrupted.^[51][38]

Having been a target of investigation by Eugene Ingram, Bonnie told a local paper, "The biggest concern I have is for my children. Obviously I worry about their safety. I can never let them answer the phone or the door."^[52] Scientologists spread leaflets around her East Grinstead neighbourhood calling her a "hate campaigner". After six years of litigation, eventually reaching the High Court, the Church of Scientology admitted that the claims were lies and paid damages and costs.^[53][54] She told journalists that during the case she had been subjected to a "level of harassment that most people would find intolerable".^[55]

In 1995 a campaigning group was formed, calling itself Families Under Scientology Stress, to bring together ex-members and concerned families.^[56][57] Two members of FUSS, Richard and Judy Price of Tonbridge in Kent, were amongst those who received threats of legal action from the Church's solicitor, accusing them of planning "unlawful and tortuous acts" against the Church. The Prices told a local newspaper that they were suffering "harassment and intimidation" including unsolicited visitors to their house late at night.^[57][58] The Church of Scientology spread a rumour to the press that Richard Price was an alcoholic, which he denied.^[38]

When Twenty Twenty Television made a documentary for national television called "Inside the Cult", using undercover filming, the Church of Scientology took out an abusive private prosecution against the reporter, producer and production company, which was eventually thrown out.^[59] At around the same time, cars belonging to the team had their windows smashed in, and the reporter's mobile phone was cloned and used to run up huge bills. The staff said these events were part of a harassment campaign in response to their documentary, although no connection with Scientology was ever proved and the allegations were denied by the Church.^[60]

Cult-monitoring organisations have also been targeted. The Church of Scientology released a dossier about the UK's Cult Information Centre in 1997. This exposed personal financial details of its General Secretary, Ian Howarth and attempted to link him to a convicted criminal. Another dossier about FAIR (Family Action Information Resource) held lurid allegations about the sex life of an ex-official.^[38]

Paul Bracchi was a journalist at local paper the Evening Argus and later at the national Daily Mail. He revealed in 2007 that after writing a series of investigative articles on the Church for the Evening Argus, he was subjected to a "vicious smear campaign" that included defamatory leaflets, threatening letters and faxes and an attempt to find his ex-directory telephone number. One of his sources was a scientologist who was suspected of stealing documents. According to Bracchi, the man had been kidnapped and taken to Saint Hill Manor to be interrogated and subsequently received a written Suppressive Person declare, confirming that he was Fair Game. After that, he and his partner received anonymous death threats almost daily until they moved away.^[61]

In 1997, the makers of "Secret Lives: L. Ron Hubbard", a biographical television documentary, reported various forms of harassment. Private detective Eugene Ingram visited friends and associates of members of the team, spreading rumours that they were involved in crimes including money-laundering. A scientologist agent phoned friends of the director and producer, posing as a member of a survey organisation and thereby tricking the phone contacts into revealing their addresses. Those who did were visited by private detectives. It is not known how the agent obtained the numbers that the programme makers had dialled from their private phones.^[62] During the making of the programme, the crew said that they were trailed by private detectives in the United States and Canada as well as in England.^[63] A film crew calling itself "Freedom TV" made unannounced visits to the homes of the programme makers to film them.^[64]

When the BBC Panorama television programme visited the USA in 2007 to film a documentary about the Church, Scientology representatives followed them and repeatedly harangued them. Unknown men also trailed the team, one even appearing at the wedding of reporter John Sweeney.^[65][66][67] Sweeney later complained of being "chased round the streets of Los Angeles by sinister strangers [...] In LA, the moment our hire car left the airport we realised we were being followed by two cars. In our hotel a weird stranger spent every breakfast listening to us."^[68]

[edit] Ongoing use of "Fair Game"

Despite the ostensible cancellation of "Fair Game," it continued to cause serious damage to the Church's image and reputation for years afterwards. A series of court cases in England in the 1970s saw "Fair Game" being strongly criticised by senior judges, with (for instance) Lord Justice Goff citing it to highlight what he described as the Church's "deplorable means adopted to suppress inquiry or criticism."^[69] Similarly, in other cases, Lord Justice Megaw discussed "Fair Game" at length and concluded that the plaintiffs (the Church) "are or have been protecting their secrets by deplorable means" and "do not come with clean hands to this court in asking the court to protect those secrets" ^[70], and Lord Justice Stephenson noted "the policy letter of 1st October 1968 cancelling publication of the policy in the interests of public relations, but not the policy itself." ^[71]

It later emerged that "Fair Game" had actually continued in use until at least 1980, despite its cancellation, and there have been frequent allegations that it has remained in force since then. During the 1970s the Guardian's Office (GO) of the Church of Scientology, headed by Hubbard's wife Mary Sue, conducted a wide-ranging and systematic series of espionage and intimidation operations against perceived enemies of Scientology. (See Operation Freakout for a noteworthy example.)

The doctrine of "Fair Game" was a central element of the GO's operational policies. The original "cancelled" Fair Game policy is listed as a reference for GO staff in its confidential Intelligence Course, ^[72] which was later entered into evidence in a US Federal court case in 1979. ^[73] During the case Church lawyers admitted that the "Fair Game" policy had continued to be put into effect long after its supposed cancellation in 1968. Indeed, according to an American Lawyer investigation, "Fair Game" tactics had been used to force the withdrawal of the presiding judge in an attempt to "throw" the case. ^[74] As the US Government's attorneys put it,

"Defendants, through one of their attorneys, have stated that the fair game policy continued in effect well after the indictment in this case and the conviction of the first nine co-defendants. Defendants claim that the policy was abrogated by the Church's Board of Directors in late July or early August, 1980, only after the defendants' personal attack on Judge Richey."^[75]

The abrogation mentioned above was issued in a policy letter of 22 July 1980, "Ethics, Cancellation of Fair Game, more about", issued by the Boards of Directors of the Churches of Scientology. However, this cancellation was itself cancelled in a subsequent HCO Policy Letter of 8 September 1983, "Cancellation of Issues on Suppressive Acts and PTSes", which cancelled a number of HCOPLs on the ground that they "were not written by the Founder [Hubbard]". In two subsequent court cases the Church defended "Fair Game" as a "core practice of Scientology", and claimed that it was therefore protected as "religious expression". ^{[76] [77]}

Since then, a number of ex-Scientologists who formerly held senior management positions in the Church have alleged that while working for the Church they saw "Fair Game" tactics continuing to be used. In 1994, Vicky Aznaran, who had been the Chairman of the Board of the Religious Technology Center (the Church's central management body), claimed in an affidavit that

Because of my position and the reports which regularly crossed my desk, I know that during my entire presidency of RTC "fair game" actions against enemies were daily routine. Apart from the legal tactics described below, the "fair game" activities included break-ins, libel, upsetting the companies of the enemy, espionage, harassment, misuse of confidential communications in the folders of community members and so forth. ^[78]

[edit] Further policy modifications

The current policy on the handling of "suppressive persons" was promulgated in 1991. ^[79] It does not include the words "Fair Game", but sets out the type of acts considered to be "suppressive" and spells out how to deal with such situations. It concludes with this statement:

Nothing in this policy letter shall ever or under any circumstances justify any violation of the laws of the land or intentional legal wrongs. Any such offense shall subject the offender to penalties prescribed by law as well as to ethics and justice actions.

Critics have noted that this does not exclude the possibility of what might be termed "legal but unethical" actions such as the so-called "dead agenting" tactics of which the Church has often been accused. While the term "fair game" is not included in any publicly disclosed and current Church policy, critics of the Church have often charged that it continues to attack its perceived enemies relentlessly through any means possible. [1]

[edit] See also

• Game (Scientology)
• Dead Agenting
• Ethics (Scientology)
• Scientology Justice
• Keeping Scientology Working

[edit] References

[edit] External links

• Q. What does the term “fair game” refer to? -- from the Church of Scientology's FAQ pages.
• Eric J. Ascalon: "Dangerous Science: The Church of Scientology's Holy War against Critics", American Jurist, November 1995, Vol. 9 No. 2
• Robert Vaughn Young "Affidavit regarding Fair Game", declaration in the case Church of Scientology International v. Steven Fishman and Uwe Geertz, 1994.
• Stephen A. Kent, University of Alberta, Statement on Fair Game for the Dennis Erlich case, February 1999
• Clare Dyer, Scientologists pay for libel, The Guardian, 9 June 1999
• Fair Gamed Web Site, Some victims of Scientology's Fair Game Policy

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