UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
NEW ERA PUBLICATIONS INTERNATIONAL, :
ApS, a corporation of Denmark,
HENRY HOLT and COMPANY, INC.,
A New York Corporation,
Civil Action No. 88 Civ. 3126 (PNL)
NOTICE TO TAKE DEPOSITION OF THE MILITARY RECORDS
PLEASE TAKE NOTICE that pursuant to Rules 30 and 45 of the Federal Rules of Civil Procedure (“FRCP”), the undersigned will take the deposition of the National Personnel Records Center (Military Records), 9700 Page Boulevard, St. Louis, Missouri 63132, Attention: Department of the Navy (referred to as the “Military Records Center”) through its Custodian of Records on July 6, 1988 at 12:00 noon at the offices of Schroeder Reporting, 818 Olive Street, St. Louis, Missouri 63101 before a notary public. The deposition will be continued from day to day until completed.
The Military Records Center shall make available for deposition at the above time and location the Custodian of Records of the Military Records Center concerning the documents set forth in plaintiff’s document request in the paragraph below.
PLEASE TAKE FURTHER NOTICE that pursuant to Rules 30 and 45 of the FRCP, the undersigned requests production at the deposition of the following documents: the Freedom of Information Act request of Russell Miller dated on or about December 5, 1985 and any response and/or documents sent to Mr. Miller and all correspondence and documents relating to the request.
[Handwritten: The pertinent file would be the records of Lafayette Ronald Hubbard, who served in the Navy during WWII.]
Dated: New York, New York
June 30, 1988
LUBELL AND LUBELL
220 Fifth Avenue
New York, New York 10001
Michael Lee Hertzberg
275 Madison Avenue
New York, New York 10016
Michael C. Elmer
FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER
1775 K Street, N.W.
Washington, D.C. 20006
Attorneys for Plaintiff
New Era Publications ApS
TO: Robert Callagy, Esq.
Satterlee, Stevens, Burke & Burke
230 Park Avenue
New York, New York 10169
Mallory Rintoul, Esq.
Henry Holt and Company, Inc.
115 W. 18th Street
New York, New York 10011
Attorneys for Defendant
Henry Holt and Company, Inc.
AFFIDAVIT OF PERSONAL SERVICE
STATE OF NEW YORK )
COUNTY OF NEW YORK )
CHARLES LAVIN, being duly sworn, deposes and says: Deponent is not a party to this action, is over 18 years of age and resides at New York, New York.
On the 30th day of June, 1988, deponent served the within Notice to Take Deposition of Military Records Center by its Custodian of Records on Robert Callagy, Esq., Satterlee, Stevens, Burke & Burke, the attorneys for defendant in this action by delivering a true copy to them personally at 230 Park Avenue, New York, New York 10169. Deponent knew the law firm so served to be the attorneys for the defendant.
Sworn to before me this
30th day of June, 1988.
NAN C. BASES
Notary Public, State of New York
Kaye, who would later become a psychologist, said she made a clinical diagnosis of Hubbard during the weeks they spent together in Palm Springs.
‘There was no doubt in my mind he was a manic depressive with paranoid tendencies. Many manics are delightful, productive people with tremendous energy and self-confidence. He was like that in his manic stage – enormously creative, carried away by feelings of omnipotence and talking all the time of grandiose schemes.
‘But when I arrived he was in a deep depression. He had been totally unable to work on his book, which had been originally scheduled for publication that month. That’s why he had called me – he was hoping I could help him get through his writers’ block. He was very sad and lethargic, lying around feeling sorry for himself and drinking a great deal. Sometimes he would go to the piano and fiddle around, improvising weird melodies of his own composition. He thought that Sara had hypnotised him in his sleep and commanded him not to write. He told me that the people in Elizabeth had tried to “slip him a Mickey” in his glass of milk and another time they attempted to insert a fatal hypo into his eye and heart to try and stop him from ever writing again. Those were the engrams he was running.
‘I tried to help him by using a technique I had learned at college, breaking down the problem into small parts and presenting it a step at a time. I got a block of butcher’s paper and said to him, “Look, you don’t have to write. Just sit down at this table and look at the paper and when you don’t want to look at it any more, get up and leave.” He sat there for ten minutes on the first day and this went on for several days until one day he picked up a pencil and began to write. Next day he was back at work, very excited and enthused about what he was doing. He was singing and horsing around, talking, laughing and discussing ideas in the kitchen until three o’clock in the morning.’
One of Hubbard’s favourite topics of conversation was psychiatrists. One night over dinner at Mel Avenue, he told Barbara about an occasion when he had demonstrated auditing techniques to a group of psychiatrists and one of them had said to him,
‘If you claim to cure people by doing that, if you’re not careful we’ll lock you up.’
He laughed excessively, took a bite out of a chicken leg and spluttered,
‘They called me a paranoid, can you imagine it?’
That night Barbara wrote in her diary:
‘My blood ran cold as he was saying that. It was all I could do to keep from weeping.’1
- Miller, R. (1987) Bare-faced Messiah: The True Story of L. Ron Hubbard (Web) ↩