1                       DECLARATION OF GARRY SCARFF
 2          I, GARRY SCARFF, declare as follows:
 3          1.  All the facts contained within this Declaration are
 4     within my personal knowledge and if called to testify thereto, I
 5     could and would be competently able to do so.
 6          2.  I personallyy acted as an agent for the "Church" of
 7     Scientology's Office of Special Affairs in covert and overt
 8     operations directed against the Cult Awareness Network for a number
 9     of years.
10          3.  As part of my operations against the Cult Awareness
11     Network, I was encouraged to file a baseless lawsuit against the
12     Cult Awareness Network. The lawsuit, which was never filed, was to
13     be filed in the Circuit Court for the State of Oregon for the
14     County of Multnomah.  It was drafted by my attorneys, the law
15     offices of Bowles & Moxon, which is also the in-house law firm for
16     the "Church" of Scientology International, and part of the Office of
17     Special Affairs for the "Church" of Scientology International.  A
18     true and correct copy of the lawsuit is attached hereto as Exhibit
19     'A' to this Declaration.
20         4.  I had numerous conversations with the representatives of
21     the Office of Special Affairs of the "Church" of Scientology
22     International and attorneys at Bowles & Moxon regarding the filing
23     of this lawsuit on my behalf against the Cult Awareness Network.
24     Everyone involved in this conversations was aware of the fact that
25     the lawsuit I was going to file against the Cult Awareness network
26     was baseless, and that it only being filed in an effort to get the
27     Cult Awareness Network to go bankrupt defending itself. As part of
28     the plan to bankrupt the Cult Awareness Network, it was decided

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 1    that an outside attorney that was not associated with Bowles &
 2    Moxon should be brought in for the prosecution of my lawsuit. One
 3    of the attorneys engaged was an Oregon attorney, Michael Gordon.
 4    I recently wrote to Mr. Gordon and demanded he turn over my file to
 5    me. A true and correct copy of the file I received from Mr. Gordon
 6    is attached hereto marked as Exhibit B.  A quick review of the
 7    documentation contained within Exhibit B, will reveal numerous
 8    communications between Mr. Gordon and agents of the "Church,"
 9    including Aaron Mason and David Butterworth, in which the "Church" of
10    Scientology had promised to raise the money for Gordon to prosecute
11    an action on my behalf against the Cult Awareness Network.
12         I declare under penalty of perjury, that the foregoing is true
13    and correct.
14        Executed this day of September, 1993 at Los Angeles,
15    California.
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18                                    RY QCARFF, r   ~ant
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