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===Fair Game=== {{Main|Fair game (Scientology)}} Hubbard detailed his rules for attacking critics in a number of policy letters, including one often quoted by critics as "the [[Fair game (Scientology)|fair game]] policy". This allowed those who had been declared enemies of the Church, called "[[suppressive person]]s" (SPs), "May be deprived of property or injured by any means...May be tricked, sued or lied to or destroyed". (taken from HCOPL October 18, 1967 Issue IV, ''Penalties for Lower Conditions'') The aforementioned policy was canceled and replaced by HCOPL July 21, 1968, ''Penalties for Lower Conditions''. The wordings "May be deprived of property or injured by any means... May be tricked, sued or lied to or destroyed", are not found in this reference.<ref>''Enquiry into the Practice and Effects of Scientology'': Report by Sir John Foster, K.B.E., Q.C., M.P. β Published by Her Majesty's Stationery Office, London, December 1971, [https://www.cs.cmu.edu/~dst/Cowen/audit/foster07.html Chapter 7] {{Webarchive|url=https://web.archive.org/web/20190515133149/http://www.cs.cmu.edu/~dst/Cowen/audit/foster07.html |date=May 15, 2019 }} (also referred to as the [[Foster Report]])</ref> Scientology critics argue only the term but not the practice was removed. To support this contention, they refer to "HCO Policy Letter of October 21, 1968" which says, "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 a [[suppressive person|SP]]."<!--p. 188--><ref name="Double Crossed">{{cite web |first=Tony |last=Ortega |author-link=Tony Ortega |title=Double Crossed |date=December 23, 1999 |work=[[Phoenix New Times]] |url=https://www.phoenixnewtimes.com/news/double-crossed-6431852 <!--reprint version omits original photographs--> |url-status=deviated |archive-url=https://web.archive.org/web/20070312025501/http://www.phoenixnewtimes.com/1999-12-23/news/double-crossed/full |archive-date=March 12, 2007 |access-date=2006-06-05 }}</ref> According to a book by Omar Garrison, HCOPL March 7, 1969, was created under pressure from the government of New Zealand. Garrison quotes from the HCOPL, "We are going in the direction of mild ethics and involvement with the Society". Garrison then states, "It was partly on the basis of these policy reforms that the New Zealand Commission of Inquiry recommended that no legislative action be taken against Scientology".<ref name=":1">Garrison, Omar ''PLAYING DIRTY The Secret War Against Beliefs'' Ralton-Pilot, Los Angeles, 1980 pg 172-173 {{ISBN|0-931116-04-X}}</ref> The source of Omar Garrison for this is most likely the [[Dumbleton-Powles Report]], additional data and quotations are found in this report.<ref>''The Commission of Inquiry Into the Hubbard Scientology Organisation in New Zealand''; Chairman: [[Guy Powles|Sir Guy Richardson Powles]], K.B.E., C.M.G.; Member: E. V. Dumbleton, Esquire, June 1969, [https://www.cs.cmu.edu/~dst/Cowen/audit/nz02.html page 26] {{Webarchive|url=https://web.archive.org/web/20190515133254/http://www.cs.cmu.edu/~dst/Cowen/audit/nz02.html |date=May 15, 2019 }}</ref> In 1977, top officials of Scientology's "Guardian's Office", an internal security force run by Hubbard's wife, Mary Sue Hubbard, admitted that fair game was policy in the GO. (''U.S. v. Kember'', Budlong Sentencing Memorandum β Undated, 1981). In separate cases in 1979 and 1984, attorneys for Scientology argued the Fair Game policy was in fact a core belief of Scientology and as such deserved protection as religious expression.<ref>''Wollersheim v. Church of Scientology of California'', Court of Appeal of the State of California, civ.no.B023193, 18 July 1989, [http://www.lermanet2.com/reference/wollersheim.htm (courtesy link)] {{Webarchive|url=https://web.archive.org/web/20080511184516/http://www.lermanet2.com/reference/wollersheim.htm |date=May 11, 2008 }}</ref>
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