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=== Fair game === {{Main|Fair game (Scientology)}} [[Fair game (Scientology)|Fair game]] is a retaliatory policy against perceived enemies which L. Ron Hubbard established in the 1950s, formalized in 1965, and described further in 1967. Since it caused bad public relations, in 1968 Hubbard prohibited ''use of the term'' "fair game" β but not its actions. The practice continues.{{r|urban2011|pages=108β109}} {{blockquote|text=[A bulletin] went out naming [someone] as having been relegated to the condition of "Enemy," to be considered "fair game," defined by Hubbard as somebody who "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."{{r|malko|page=160}}|author=[[George Malko]]}} Fair game is one of the penalties that can be leveled on a person for having committed a [[#High crimes|high crime]] against Scientology, or as a penalty after a [[#Comm ev|committee of evidence]].{{r|hubbard-admindict|page=258}} In two separate court cases ([[Church of Scientology of California v. Armstrong|Armstrong]] and [[Wollersheim v. Church of Scientology|Wollersheim]]) the Church of Scientology argued that fair game policies are a "core practice of Scientology" and are therefore protected as "religious expression".{{r|urban2011|pages=108β109}} Hubbard instructed his followers that "fair game" is appropriate treatment for journalists, judges, hostile lawyers, government agencies, psychiatrists and others.{{r|reitman|pages=113β114}}
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