Fourth declaration of Vicki Aznaran from 19 May 1994
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DECLARATION OF VICKI J. AZNARAN

I, VICKI J. AZNARAN, hereby declare as follows:

1. I am over 18 years of age and a resident of the State of Texas. I
have personal knowledge of the matters set forth herein and, if
called upon to do so, could and would competently testify thereto.

2. From 1972 until 1987, 1 was a member of various Church of
Scientology ("Church") entities. During that time I held a number of
senior positions in the corporate and ecclesiastic hierarchy of the
Church.

3. From 1981 onward I knew both Vaughn and Stacy Young, whom I met
and had contact with as a result of my work as a staff. r,ember in
the Church of Scientology. I am familiar with their positions in the
Church.

4. In my staff capacities in the early 1980s, and later in my
executive positions in the Religious Technology Center, I was
directly or closely involved in meetings with senior staff members of
various Church corporations. These senior staff made significant or
major decisions which affected the future of the Church. I know that
neither Vaughn nor Stacy Young were included in such senior
decision-making processes. They were never senior or key Church
executives.. They were not consulted regarding, nor were they privy
to, the meetings where major issues were discussed and decisions
made.

5. I am informed that the Youngs have made claims to specialized
knowledge about the corporate status and structure of the Church.
Such claims are false. Neither of the Youngs were in a position to
have detailed knowledge of the corporate and fiscal structures and
operations of any Church of Scientology. In fact, Vaughn Young worked
in the area of Public Relations for the entire time that I was
acquainted with him. Stacy was primarily a writer in the Church
public relations department.

6. Another false allegation is Vaughn Young's claim to be not only
knowledgeable about but personally affected by a dispute in 1986 and
1987 between David Miscavige and Pat Broeker concerning Scientology
scriptures. I was with Broeker during this period and was aware of
this situation. To my knowledge Vaughn Young was not in a position to
know what happened during this dispute.

7. That Vaughn and Stacy Young are experts is not true. They are
being called experts not due to expertise in Scientology but in order
to collect insurance money for their testimony. When Graham Berry
retained me for $2,500 to write declarations, he made it clear to me
he would get me classified as an "expert" so the insurance company
would pay.

8. What this creates, and what the Youngs are part of, is a stable of
people who, for pay, write declarations. The Fishman case is a good
example. Neither the Youngs nor I have ever met Steve Fishman.

9. Stacy Young apparently claims special expertise regarding
Scientology scriptures. This is just another part of the sham that
has been erected around this litigation. She doesn't hold herself out
as an "expert" in her life outside of this litigation. It is only
when testimony is needed for Mr. Berry th at the "expert" title is
used.

10. To give an example of how this "expert" plan works, Vaughn Young
claims, as an "expert," that Steven Fishman was known and discussed
by senior Church executives and staff. For years in the inid-1980s I
was one of the highest ranking executives in all of the Churches of
Scientology. Furthermore, I never heard David Miscavige or Marc
Yager, whom I had regular contact with, ever mention his name. Thus
it is inconceivable to me that Vaughn Young would have heard any
Church staff member or executive talk about Fishman. He was not in a
position to know and I was.

11. The Youngs rely on innuendo to make allegations under the guise
of "expert knowledge." Here are some specific exanples: a) that End
of Cycle within the Church means committing suicide. There is no such
policy and in fact this is totally contrary to Church policy and they
know this; b) that members of the Church are involved in murder of
adversaries. This never occurred at any tire and it is a lie that
anyone connected with he Church would recognize including the Youngs;
c) Vaughn Young implied that there might be something suspicious
about the death f L. Ron Hubbard. This is fictitious scandal. I was a
senior executive and can state that L. Ron Hubbard's death was not by
anything other than natural causes; d) inferring that the death of
Flo Barnett was covered up by Mr. Miscavige. There was never ny
question that the cause of her death was due to self-inflicted
gunshot wounds. Additionally, the facts are that there was never any
order by David Miscavige or anyone else to keep the matter quiet. If
such an order existed, I would have known about it: e) an additional
forum in which this false information is spread in FACTNET. This is a
computer base which seeks to create the impression that Scientology
is somehow responsible for the deaths of certain individuals. Anyone
who knows Scientology or has been involved with it knows this is not
realistic.

12. The above are examples of the falsehood and innuendo created by
the stable of false "expert" witnesses that has been created here.

I declare under the penalty of perjury under the laws of the United
States of America, and under the laws of each individual state
thereof, including the laws of the states of California and Texas,
that the foregoing is true and correct.

Executed this 19th day of May, 1994 in Dallas, Texas.

Vicki Aznaran