------------------------------------------------------------------- F.A.C.T.Net, Inc. (Fight Against Coercive Tactics Network, Incorporated) a non-profit computer bulletin board and electronic library 601 16th St. #C-217 Golden, Colorado 80401 USA BBS 303 530-1942 FAX 303 530-2950 Office 303 473-0111 This document is part of an electronic lending library and preservational electronic archive. F.A.C.T.Net does not sell documents, it only lends them according to the terms of your library cardholder agreement with F.A.C.T.Net, Inc. ===================================================================== AFFIDAVIT OF EDWARD WALTERS I, Edward Walters, hereby depose and state under pains and penalties of perjury: 1. I have personal knowledge of the facts sworn to herein and if called as a witness to testify thereto could do so of my own personal knowledge. 2. I was a member of the Church of Scientology for approximately nine (9) years from 1970 through March of 19 79. 3. My position in the Church~f Scientology was that of Case Supervisor, a Class VIII Auditor and I was generally considered one of the highest "tech" people, knowledgeable about Scientology policy in the U.S., I was also directly responsible for the handling of preclear folders. 4. While a member of the Church of Scientology, I had frequent contact with Susan Reed, the Assistant Guardian, Matty Reese, the Assistant Guardian Public Relations Officer, and Chuck Reese, Assistant Guardian of Intelligence. Susan Reed often told me to be aware of "evil" and "suppressive" groups and organizations which were out to stop Scientology. She said "evil groups \ were as I remember, the United States Government, the American Medical Association, the Better Business Bureau, doctors, lawyers, and police agencies of any kind. She stated that the Guardian's Office was responsible for stopping these attacks against Scientology by any means available including electronic surveillance, infiltration, burglary and theft. The above named Guardian's Office personnel would tell me of the "wins" that they would have in their covert operations to stop or destroy those groups 'or individuals whom they considered to be suppr~ssive. At this time Susan Reed introduced me to a fellow in her office and who told me his name was Randy.. Randy said he was an intelligence agent working directly under Mary Sue and L. Ron Hubbard, and that he worked on the most sensitive and most secret of all Scientology's covert operations. He also stated that there was a need to do away with "suppressives" and groups attacking Scientology in whatever way necessary, including burglary, larceny, and "framing". He informed me how the Guardian's Office technology worked. For instance, he said that the Guardian's Office would plant dope on some "SP", then call the police and have the fellow arrested. The Guardian's Office would circulate word of the fellow's arrest and whatever the fellow said about Scientology would not be believed. It was in this -2- way that they framed some of the SP's. He then told me that if Susan Reed wanted me to contact him that I should call the Los Angeles Guardian's Office and ask for either "Randy", "Bruce", "Raymond" or "Bruce Raymond". He then told me I was not to reveal what he had told me or who he was to anyone and that grave consequences could result to me if I divulged any of this. 5. On several occasions I overheard phone conversations between the above named individuals and people in the United States Guardian's Office in Los Angeles with respect to illegal acts and covert operations requested to be done by the United States Guardian's Office in Los Angeles. 6. I know from my own personal experience that the Guardian's Office of each local'Org is controlled by and reports to the United States Guardian's Office in Los Angeles. The United States Guardian's Office in Los Angeles is operated by the Church of Scientology of California and is controlled by Mary Sue Hubbard and L. Ron Hubbard. I also know that there is a direct telex connection between the United States Guardian's Office and the Clearwater headquarters of the Church of Scientology and that this telex connection is used by the United States Guardian's Office to consult with Mary Sue and -3- L. Ron Hubbard, of Clearwater, Florida. The United States Guardian's Office in Los Angeles consults on a periodic basis with officials in Clearwater, Florida but would always consult with them in matters of special importance to the Church of Scientology. 7. I know from my experience and observation that the Guardian's Office has systematically, through the years, used "pre-c!ear" data as a tool against a pre-clear who would threaten to go to authorities or see a lawyer to sue or get his money back. I observed Matty and Chuck Reese of the Las Vegas Guardian's Office do this for many years and at tires, the had told me how "we stopped" or "we showed that lawyer what a client he really has and he backed off right away", etc. 8. While Case Supervisor in 1978 at the Celebrity Center Mission in Las Vegas, Bruce Hamilton of the Las Vegas Guardian's Office came to see me and asked me to go through my PC files and to provide him with any information which had been disclosed in auditing sessions which I thought would be helpful to control the person and would be "helpful to his cause". When I disagreed with these "gestapo type tatics" he told me that these orders came "directly from Los Angeles" or "this comes directly from Clearwater", and that if I didn't comply, it would be "treason". -4- 9. On a number of occasions I had been requested by individuals in Clearwater, Florida to forward preclear folders to them or people who were undertaking auditing. In accordance with these requests I have sent a number of pre-clear folders to the Clearwater headquarters and have received written receipts for them. I have a number of these receipts in my custody at this time. 10. I was a member of the Las Vegas Org throughout the period that La Venda Van Schaick was a member of the Church of Scientology in Las Vegas. I have personal knowledge of the solicitation techniques used on new members ("raw meat"). I have personal knowledge of the "Church" policy throughout the period 1971-1979 both in Las Vegas and throughout the U.S. with regard to the Church's "religious front" and with regard to the making of representations to raw meat to induce them to pay money or to join the organization. In Las Vegas and throughout the U.S. it was "Church policy" between 19711979 to state to everyone that the Church of Scientology was a law-abiding organization that operated only on scientific principles based on scientific validation of thousands of case studies over a period of 30 years by L. Ron Hubbard, a nuclear physicist, a combat veteran, -5- who healed war wounds with Dianetics. The scientific basis of Scientology, per policy, was held out to be more scientific than physics, etc. The representations made to people such as La Venda Van Schaick were made orally, in writing in small advertising flyers such as "What is Scientology" and through the sale of books and publications such as "Dianetics, The Modern Science of Mental Health". I was trained and others in the Org, called "body-routers" and "registrars" were trained to tell people that Scientology was a "science" not a , "religion" and that "Religion" was only used to deal with the Government, taxes etc. 11. It was common knowledge in the "Church" and it was "Church Policy" to use the "religious front" to deal with the Government, but to solicit new recruits and train members based on "scientific technology" devoid of religious significance or context. Representations made to induce people like La Venda Van Schaick to pay money and become members were uniformly made, per policy, in the context of "scientifically guaranteeing" them higher I.Q., cure of psychosomatic disease, increased educational and career opportunities, working with Hubbard, earning a salary, receiving courses and training, room and board, health care, etc. It was -6- "Church policy" not to inject "religion" into the foregoing representations. It was common knowledge to everyone in Scientology that I dealt with between 1971-1979 in Las Vegas including Barbara Glass and Robert Harvey, that (1) religion was used as a "front"; (2) that courses and books were sold to "make money" based on specific promises or guarantees which had no religious context; and (3) that elaborate plans were used to create the impression with the Government that Scientology was a religion pursuant to a policy called "The Minister's Mock-Up", based on the "religious image check sheet". This policy required someone in the Church to wear a "minister's costume" whenever the Church dealt with the Government. Between 1971-1979, I know of three instances where this was done: once when someone from the D.A. 's office came to the Org, once when a newspaper reporter came to the Org, and once when a magazine was preparing an article. 12. It is written "Church policy" to use the religious front for the Courts, the Government, lawyers, accountants, etc. In fact, the very effort presently made by Scientology lawyers in the Courts throughout the U.S. is based on Hubbard "tech" to present Scientology as a "religion". This is 180ø opposite to what in reality happens in the Org when Scientology is being "sold". If -7- we tried to sell Scientology as a "religion" on the street or to members for more courses, we would have been laughed out of town, and wouldn't have received a nickel. There is no religious context to the sale of Scientolo~ courses and books. After the F.D.A decision in the early 1970's, we were told to start putting "stickers" in the books which had something to do with a "religious disclaimer". However, it was Church policy to tell everyone that the "stickers" were just for the Government and didn't change anything. Scientology "tech" was an exact science, to be sold as such and not as a "religion". 13. The Church of Scientology of California totally controls every Scientology corporation in the U.S. primarily through the Guardian's Office. All directors of the corporations must resign in advance, and all policies issued by California must be rigorously adhered to, including but not limited to the policy of using religion as a front, but soliciting people and money based on the scientific basis and principles of / the organization. 14. The Church of Scientology has a very specific and deceptive policy of obtaining signatures on various forms, waivers, releases, etc. Often these forms are -8- signed just before or after auditing sessions, and the individual is told that it is just for the Government, or the individual does not even know what he is signing, or numerous documents are placed in front of an individual and signed without being read. This was a common practice. Signed under the pains and penalties of perjury this ~ ~ ~'~ ~ ~ ~ ' day of ~ , 1982. Edward Walters as cures from obesity, colds, headache, cancer, etc. Throughout 1979, when I discovered Hubbard was a fraud, I realized how much I had been defrauded. 16. I was required to sign many forms at the time I joined the "Church" and in later years. Most of the time I did not know what I was signing and the common "line" was that the forms were used to protect the "Church" from the Government. I was told that and I told other people the same thing. From the time I joined Scientology until the time I left, everyone I knew and dealt with was continually told and believed that the "Government" was our "enemy" to which we should always apply the Fair Game Law. To this day, I do not know what forms I signed, what their contents were, etc., but I do know that the Church applied the Fair Game Law to all of its "enemies" which includes using information and documents procured from Church members by any means possible, fraudulent or otherwise. 17. Upon information and belief I have been brutally and viciously harassed for almost 3 years pursuant to the Fair Game Doctrine by the Church of Scientology. Church agents contacted my place of employment as a result of which I lost my job. Church agents have called my friends and neighbors accusing me of child -10- beating, promiscuity, drug usage. I have been followed, threatened, harassed, sued twice (both dismissed), had my auditing information disclosed to the media. My lawyers have had documents stolen from them about my case. My child has been followed, kept under surveillance, called by telephone, contacted in person. Church agents have tried to influence my ex-husband to take my child away. "Operations"were implemented to "separate" me from my lawyer, my husband and my child. As a result of all of the above, I live in perpetual fear and I am presently in a condition of almost complete mental and emotional collapse. I donot presently feel that I can survive beyond September 1982 knowing that the Church will "attack" me ever more aggressively as the law suit continues. Church "policy" is very specific about "attacking" "enemies" and "traitors" of which I am one, and elaborate "operations" have to be implemented against me pursuant to "policy". These policies have never changed. 18. As the HCO Area Secretary in Las Vegas, I had personal knowledge that the Church of Scientology of California controlled and dominated every phase of the Church operation in Nevada including finances, solicitation policies, publications, prices, governing policies, criminal activities, etc. Control by Church of Scientology -11- of California was exercised by Flag agents, the Guardian's Office, and the Hubbard Communications Office. All members of all Boards of Directors were required to resign in advance of their appointment and the resignations were held by the Church of Scientology of California. 19. I did not discover the fact that Hubbard's academic credentials, naval background, professional qualifications asa nuclear physicist, research history, and case studies were all false, until 1979-1981. I did not discover the fact that there was, therefore, no scientific validation of Hubbard's claims and representations, and no scientific basis for making such representations until 1979-1981. I did not receive the benefits promised to me such as wages, health care, room and board or courses as represented between 1971 and 1979, but it was continually represented to me that those benefits were forthcoming right up to 1979, and in the last several years, 1976-1979, my mind was firmly indoctrinated with the fact that Scientology would provide all of the promised items. It was not until 1979-1981 that I learned that the financial control mechanisms established by Hubbard were such that the representations made to me between 1971-1979 were fraudulent when made, because Hubbard took all of the money and left each Org with only enough to continue in the manner it did for 7 years. -12- 20. The books that I was sold did not comply with the Judgment of the Court in the Article or Device case and I specifically never saw any publication which contained the "Warning" required by that case in 11 point leaded type on the title page on the cover page. I do recall the organization placing some "stickers" in some of the books about the religious nature of Scientology. However, these stickers were never placed in the books sold to me. The practice of putting the stickers in some of the books was not done until 1977-78, and I was told that it had something to do with the government and taxes. I have since learned from my attorney in the last several years about the required Federal Judgment. If I had known that a Federal Court in 1971 had said that Scientology representations in its publications were false, misleading, etc. and that Hubbard's credentials were all falsified, I would not have relied on the representations made to me. 21. If I had known that the Church of Scientology throughout the period 1968-79 was actively engaged in elaborate programs to break into, burglarize, and steal from state and federal agencies, defame and smear people with elaborate espionage programs to destroy anyone who stood in Hubbard's path, I would not have worked for the organization or given them money. -13- Signed under the pains and penalties of perjury this ' ~ day of ~_~ , . ' Y'~-~'- ' /c, .,.... <~ ~ ., ~ " La Venda V~n Sch~ick ' ' '~ ~ ~ Daniel Leipold Hagenbaugh & Murphy 2 701 South Parker Street, Suite 1200 Orange, California 92668 3 (714) 835-5406 4 Mark Goldowitz 1611 Telegraph Ave., Suite 1200 5 Oakland, California 94612 (510) 835-0850 Special Counsel for Defendant Lawrence Wollersheim 7 Lawrence Wollersheim 8 P.O. Box 10910 Aspen, Colorado 81612 9 (303) 650-3336 ~0 In Pro Per ~ SUPERIOR COURT OF THE STATE OF CALIFORNIA ]9. COUNTY OF LOS ANGELES ~3 CHURCH OF SCIENTOLOGY OF ) No. BC 074815 CALIFORNIA, ) ) DECLARATION OF VICKI ]4 Plaintiff, ) AZNARAN ]5 ) VS. ) ~6 ) LARRY WOLLERSHEIM, ) Date: June 24, 1993 ) Time: 9:00 a.m. ~7 Defendant. ) Dept: 14 ) ]8 ) 19 20 I, Vicki Aznaran, declare: The attached Declaration of Vicki Aznaran, which I signed on July 18, 1990, is a true copy of a declaration submitted in the USA v. Fishman case. I have personal knowledge of the 93 facts set forth therein, and they are true and correct. I declare under penalty of~e~jury that the foregoing is true and 24 correct. Executed this ~ ~day of44~, 1993 at Dallas, 25 Texas. , 9~6 ~;fck~i'A~na~ .... 27 1 NURIK & KYLE, P ú A ú 2 Attorneys for Defendant 2937 S.W. 27th Avenue 3 Suite 203 Miami, Florida 33133 ~ (305) 441-2400 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 7 CASE NO. CR-88-0616-DLJ 8 UNITED STATES OF AMERICA, 9 Plaintiff, 10 v. 1! STEVEN FISHMAN, 12 Defendant. 13 / l~ DECLARATION OF VICKI AZNARAN ~5 I, VICKI AZNARAN declare as follows under penalty of ~6 perjury: ~7 I joined the Church of Scientology in 1972. In 1978, ~8 after approximately four years as staff members, my husband ~9 and I joined the Sea Organization. From 1978 to early 1987, 20 my husband and I worked most of our waking hours, with very 2! few days off, at our various assignments within Scientology. 22 I eventually became President of Religious Technology Center 23 and,supposedly, the top "ecclesiastical" authority within 24 Scientology. Richard was a high-level security officer. 25 During this period my husband and I became intimately 26 familiar with the structure and activities of various 27 1 I Scientology organizations. Among other things, I was 2 briefed on and was sometimes a participant in meetings 3 involving litigation tactics and various means used to 4 attack and fight "enemies" of Scientology. In numerous 5 instances I was in the chain of command for approval for ~ such activities. From 1984 to 1987, I held the office of 7 Inspector General 0;~ e~ ~-h ~ highest worldwide officeS in the 8 organization and so was privy to the most arcane practices 9 of the group. 10 The legal strategy of Scientology and the existence of ]] numerous potential legal problems, some of which are set ~2 forth below, were known to me when I was a staff member in X3 Scientology. Enemies of Scientology are deemed to be 14 "suppressive persons" ("SPs"). One becomes a "suppressive ~5 person" by doing a suppressive act, such as suing ~6 Scientology as a litigant or la~er. In the jargon of 17 Scientology, when one is "declared" this means that one has 18 been declared a "suppressire person" and, therefore, may be 19 harassed, hurt, damaged or destroyed without regard to 20 truth, honesty or legal rights. It is considered acceptable ~1 within Scientology to lie, cheat, steal and comit illegal 22 acts in the name of dealing with a "suppressive person." This practice or policy is sometimes referred to as the 2~ policy of "fair game." In the jargon of Scientolo~, a ~5 person who is "declared" is understood :to be a suppressive ~6 person. This means that the person is "fair game." The fair 27 2 game policy was issued in the 1960s. It was never cancelled. A document was issued for public relations reasons that purportedly cancelled "fair game"; however, that document stated that it did not change the manner of handling persons declared "SP." In reality, the purported cancellation of fair game is at most a matter of semantics. Enemies of Scientology are treated as "fair game." David Miscavige was the Chairman of the Board of Author Services Inc., ("ASI") in 1984 and 1985. ASI was incorporated to be the funnel through which profits from Scientology were channelled to L. Ron Hubbard and, therefore, it was very important within SCientology. Miscavige represented Hubbard in all aspects of controlling Scientology. He attended regular meetings with myself and other top officials of Scientology organizations to review the status of all Scientology's activities, including its litigation and dirty tricks campaigns against Scientology's enemies. Because of my position and the regular reports that came across my desk I know that throughout my presidency of RTC that fair game actions against enemies were commonplace. In addition to the litigation tactics described below, fair game activities included burglaries, assaults, disruption of enemies' businesses, spying, harassive investigations, abuse of confidential communications in parishioner files and so on. I specifically recall seeing one report regarding 3 ! attacks against Bent Corydon after Scientology became aware 2 that he was writing a book against Hubbard. 3 Other Hubbard writings encourage Scientologists to pursue litigation purely for harassment without regard to 5 the merits of a claim to cause enemies to fold. Hubbard's 6 writings state: ? "The purpose of the suit is to harass and discourage rather than to win...The 8 law can be used very easily to harass, and...will generally be sufficient to 9 cause [the enemy's] professional decease. If possible, of course ruin him 10 utterly." Hubbard, "Magazine articles on Level O Checksheet" American Saint Hill ll Organization 1968. 12 As President of RTC and a Sea Organization member, I ]3 attended meetings concerning the numerous legal actions l~ involving Scientology organizations. During this time 15 period, I had personal access to all legal documents having 16 to do with RTC. I received a report every day on my computer ~7 that included a synopsis of each ongoing legal case IS involving Scientology. I received, or so I was told, copies ~9 of every major motion filed in cases involving Scientology. 20 I was on the "approval lines" for legal documents dealing 2! with RTC. During this time period, I had the option of 22 attending legal meetings, although some were mandatory. I 23 attended many litigation meetings and became generally aware 24 of Scientology's dirty tricks and legal maneuvers. On 25 specifics, I frequently deferred to in-house and outside 26 counsel; however, at least in theory, I was the head of RTC 27 4 and had access to any business or litigation "secrets" of Scientology. It is the stated policy and practice of Scientology to use the legal system to abuse and harass its enemies. This crude, fundamental directive of Scientology is no secret. The policy is to do anything and everything possible to harass the opposing litigant without regard to whether any particular motion or maneuver is appropriate or warranted by the facts or applicable law. That policy was followed in every legal case I was involved with or learned about while a member of the Sea Organization. The management of Scientology consistently expressed and demonstrated a complete disdain for the court system, viewing it as nothing more than a method to harass enemies. Some examples of this are set forth below. During litigation between Gerald Armstrong and Scientology, which was before Judge Breckenridge of Superior Court for Los Angeles County, the court ordered the production of Armstrong's pre-clear ("PC") folders. These are files maintained by Scientology on those who submit to interrogation sessions in a process called auditing. During the course of that litigation I was ordered to go through Armstrong's folders and destroy or conceal anything that might support Armstrong's claims against Scientology. This practice is known within Scientology as "culling PC folders" and is a common litigation tactic employed by Scientology. 5 1 During other litigation in Los Angeles known to me as 2 the Wollersheim case, I was told that the judge had ordered 3 the production of Wollersheim's folders. As ordered, I 4 "culled" these files. In other words, I removed contents 5 that might have been damaging to Scientology or might have ~ supported Wollersheim's claims against Scientology. For 7 example, I removed evidence of events involving his family, 8 the anguish this caused him, evidence of disconnection from 9 family and evidence of fair game. 10 I was involved in numerous meetings concerning what is ll known to me as the Christofferson case in Portland, Oregon. ~2 This case was tried twice. In the first case, a Scientology 13 witness by the name of Martin Samuels was coached and I~ drilled for hours on how to lie convincingly or avoid 15 telling the truth. Before or during the second trial he I~ admitted to this course of conduct. In this litigation, a ~7 Scientologist by the name of Joan Shriver produced 18 responsive documents that may have been incriminating. This ~9 was a serious breach of policy for which she was punished. 20 These documents were ordered produced on such short notice 2! that apparently files were not thoroughly "culled." In 22 another case, an attorney was severely criticized and almost 23 fired for failing to properly coach and feed the desired 24 answers to Heber Jentzsch. Mr. Jentzsch was, for public 25 relations reasons, the purported head of the Church of 2~ Scientology International. During his deposition, Mr. 27 6 28 Jentzsch was unable to answer fundamental questions concerning the management of Church of Scientology International. In later 1979 and early 1980, there was a massive document destruction program undertaken to destroy any 6~evidence showing that L. Ron Hubbard ("LRH") controlled Scientology. I participated in this activity in Clearwater, Florida and am informed that there was also intensive document destruction at facilities in Gilman Hot Springs, California. From at least that point onward there was a continuous effort to hide or destroy any evidence of Hubbard's control. For example, during an IRS investigation in 1984 and 1985, while in bed with pneumonia, I was ordered out of bed by Norman Starkey, who told me that they had received a tip from a Los Angeles police officer advising them of a pending IRS raid in Los Angeles. Mr. Starkey ordered me to go to a computer facility and insure that all information on the computers in Los Angeles that might show Hubbard's involvement and control of Scientology's money was destroyed except for one copy of each document. These copies were to be saved on computer disks which were to be hidden in secure storage places. At the time I was also instructed to destroy anything that would show the control of Mr. Starkey or Mr. Miscavige over Scientology. In or about 1981, while working in a Scientology organization known as the Guardian's Office, I had access to 7 ! and observed various written and oral communication pertaining to illegitimate activities participated in by the 3 Guardian's Office. The Guardian's Office attempted to 4 infiltrate both governmental and private agencies including 5 the IRS, the Department of Justice, and the American Medical 6 Association and the National Institute of Mental Health. The 7 purpose of this was to steal documents pursuant to Hubbard's 8 "Snow White" program. The goal of this program was to 9 eliminate any negative reports about Hubbard and Scientology 10 that may have been held by these various agencies. While involved in Scientology I became aware of various 12 operations directed against an author who had written a 13 negative book about Scientology. The author, Paulette 14 Cooper, was subjected to various forms of harassment. One 15 operation included an attempt to frame her. A false bomb 16 threat was written. Scientology agents lifted a fingerprint 17 from Cooper's apartment. These fingerprints were then 18 transferred to the bomb threat letter. Ms. Cooper was 19 subjected to an investigation and was not cleared until an 20 FBI raid resulted in the seizure of Scientology documents 21 that exposed the operation as a frame-up. There was at 52 least one other operation directed against Ms. Cooper. The 23 substance of it was to plant a boyfriend to reinforce and 24 play upon her suicidal tendencies in the hopes that she 25 would commit suicide. In 1976 and 1977, the then-Mayor of Clearwater, 8 Florida, Gabe Cazares, was involved with litigation against Scientology. Arrangements were made to have an attorney by the name of Merril Vanniere, a Scientologist, represent Mr. Cazares and sabotage his case. This plot was also exposed by documents obtained in an FBI raid of a Scientology facility. Also, in response to Mr. Cazares' litigation against Scientology, an attempt was made to implicate Mr. Cazares in a staged hit-and-run accident. During an IRS criminal investigation in the 1984 to 1985 time period, the IRS ordered production of various communications between Hubbard and Author Services, Inc. (ASI). The ASI staff worked literally day and night for several days reviewing documents so that unfavorable documents could be destroyed or otherwise concealed from the IRS. Lyman Spurlock and Marion M. Dendue, Scientologists involved in this operation, informed me of this operation. Also during this IRS investigation, my husband, Rick Aznaran, was ordered to remove and conceal any incriminating documents from certain locations. He was also directed to make the computer network "raid proof." This involved creating a system where incriminating documents could be deleted from computer storage rapidly and before the IRS could obtain control over the computers. I have examined certain documents regarding Steven Fishman's experience with Scientology, have had conversations with Mr. Fishman's counsel, and have reviewed 9 ! the 1151-page autobiographical account of Mr. Fishman's Scientology experience entitled "The Lonesome Squirrel." 3 Based upon my 15 years of experience in Scientology and my ~ review of the Fishman materials, I offer the following 5 conclusions: 1. I believe Mr. Fishman's assertions that he was a 7 member since 1979 and that he was as actively involved as he 8 states. This belief is based on my experience that only a 9 committed member of long standing would know the details of 10 the inner workings of the group; Mr. Fishman has such l] knowledge. Awareness of certain confidential projects could 12 be achieved only by a member who was trusted by the 13 hierarchy; Mr. Fishman had such awareness. Involvement in a l~ group that thrives on secrecy and excludes most members from 15 participation in high-level projects means that any member ~6 who exceeds a certain level of involvement enjoys the trust X7 of the leadership; such trust would be earned only by 18 extended membership. Mr. Fishman enjoyed that trust. His 19 accounts of meetings with high-level officials and his 20 knowledge of the operations and functions of the hierarchy 21 are so detailed and accurate that they couldn't have been 22 gained except through direct personal experience. 2. Refutation by Scientology officials of Mr. 2~ Fishman's membership prior to February 8, 1986, and their 25 disclaimer of his involvement and their lack of any records 26 pertaining to such membership is perfectly consistent with 27 10 I their standard procedure in protecting themselves. As noted 2 above, I was personally involved in the destruction of 3 records when it suited their purpose. Scientology propounds the belief that any action whatsoever taken to protect the 5 organization is justified, as the group takes precedence over the individual. Any member performing criminal acts for 7 the benefit of the group was kept at arm's length; if 8 apprehended, the member was disavowed by Scientology. This procedure was used even on the wife of the founder of 10 Scientology. Given the serious potential threat that Mr. ]1 Fishman's defense posed to the group, I find Mr. Fishman's 12 account of certain members of Scientology's involvement in 13 the plan to fabricate the threats against Mr. Fishman and his counsel and to thereby undermine Mr. Fishman's 15 credibility and render him useless as a witness against Scientology to be consistent with their rodus oDerandi. 17 I declare under penalty of perjury under the laws of the State of Texas that the foregoing is true and correct. Executed this / day of , 1990, in Dallas, VI~Ki ~ZN~LRAN ' 22 23 2~ 2S 27 11 SUPPLEMENTAD DECLARATION OF VICKI AZNARAN I, Vicki Aznaran, declare: 1. I joined the Church of Scientology of California ("Scientology") in 1972, and was a member until I left in April 1987. From 1984 until 1987, I was Inspector General of the Religious Technology Center, an affiliated Scientology organization. At that time, this was one of the highest worldwide offices in Scientology. One of my offices was located at 4751 Fountain Avenue, Los Angeles. 2. By virtue of my high position, I was "in the loop" to receive communications about some of Scientology's most secret operations. The facts set forth in this declaration are based on my own personal knowledge, which came from many sources, including numerous discussions and meetings with top Scientology "intelligence officials" and other Scientologists and reading ]ocuments which passed across my desk or came to my computer. 3. During the 1984-87 period, Scien~ology operated a ~umber of "dirty tricks" operations out of the Office of Special Affairs (OSA), including one called MFTC (for "Mission Find The Crimes") and the "WOLLY" unit (which targeted Lawrence Wollersheim, his attorneys, and his case). The orders for these operations would go directly from OSA to private investigators, although Scientologydeceitfully tries to cloak such operations under "attorney-client privilege". 4. MFTC and the WOLLY unit ~ach had about 8-10 staff, and engaged in whatever dirty tricks were necessary to attack people and entities which were considered to be "enemies" of Scientology. The dirty tricks they used included destruction of evidence, theft of documents, illegal surveillance or bugging, blackmail, bribery, physical assault and other intimidation, securing perjured testimony. MFTC's mission was to find or manufacture crimes for "enemies" of Scientology. 5. Before and during the trial in Wollersheim v Church Of Scientoloqy of California, MFTC and WOLLY ran a number of operations directed against Wollersheim, his counsel, and the Court. One of these operations was an attempt to put pressure on Bill Swearinger, the son of the trial judge in the Wollersheim case, based on his alleged homosexuality. The idea was to dig up, or manufacture (perhaps by setting the son up in a compromising sexual position with a minor boy), dirt on the son which could be used to pressure the Judge to rule favorably for Scientology, or else to get the Judge disqualified. 6. Attached as Exhibit A is a true copy of an internal Scientology memorandum, dated 6/21/86, which discusses this "Swearinger Investigation". I received a hard copy of this document at about that time, and I believe I also received a copy of this document on my computer. The Linda referred to on the first page is Linda Hamil, who at the time ran the MFTC. The Marty referred to on the first page is Marry Rathbun, a top Scientology "intelligence" official, who ran this operation. 7. Scientology's "ambush interview", discussed in Exhibit A, makes the Mike Wallace/60 Minutes interview called by the same name look tame. The "ambush interview" generally involves doing 26~hatever it takes -- threats, physical force, bribery, or whatever -- to get an unprepared and unsuspecting target to say what is wanted. 2_ 8. I understand that Lynn Farny has submitted a 2 declaration stating that Scientology complied with Judge 3 Swearinger's order in the Wollersheim case to produce 4 Wollersheim's pre-clear files. This is false. As I stated in 5 my Fishman declaration, I personally culled and destroyed 6 (shredded) from these files evidence which would help Wollersheim 7 and hurt Scientology in the case. I was personally ordered to do so by David Miscavige, the head of Scientology, and Marty 8 Rathbun. The culling and destruction took place at the Fountain 30 Avenue building in Los Angeles. I was assisted in the document destruction by then Scientologist Jessie Prince. Lynn Farny was a low level Scientology official, and was not at the meetings ~where this was discussed. However, Lynn Farny is not telling the truth, because as a Scientology staff member he knows it is Scientology policy never to turn over information in litigation without first culling out (deleting and destroying) material that will harm Scientology. It is also, however, Scientology policy to lie to cover up such misdeeds. 9. Attached as Exhibit "B" to this declaration is a true copy of a document called "TRL", which is a Scientologytraining 2~ ~dri11 to teach Scientologists to lie convincingly. ~ 10. I understand Scientology is trying to vacate |Wollersheim's judgment on grounds that Judge Swearinger was biased against Scientology and his bias infected the jury. This is a typical Scientology tactic which it frequently uses in trials as insurance when Scientology loses an important case. 26 Scientologywill do things to set up a mistrial, such as calling 27 jurors in the middle of the night and hanging up, threatening TOTAL P.ol WOLLY INVEST I/C < ..... 21-Jun-1986 10:37 To: WOLLY INVEST I/C From: MFTC I/C Re: Swearinger Invest for your info and whatever else you can do with this... 20-Jun-1986 20:56 I)ear Linda, What does JP want to do with Bill Swearinqer? What did Bowles say to him? Why would we want Bill S to have Royce confess? Confess ~o ~hat? When will the rest of the 13 original targets be done? ~IL Marry 20-Jun-1986 20:40 I)ear Si r, ~o~pl lance Report. ' W~at was ordered: I sent over a 18 step invest to revive the Swearinger Invest. In response yo~ merc'd' "'Ilk, I'll expect the results of all of this by Friday.' (In this same comm you asked for the Mayer invest which is forwarded in a separate Merc.) What ~as do~e: T~e results of the Swearin~er Invest are in the report below. ~e original targets are at the very end of this co~. This is DK. fill Li nda S~earinge~ Invest results: S~mmary: Five of the thirteen investigative steps were completed and resulted in a) two Swearinger neighbo~-s recalling a White Cherokee by Bill's house a few times in the last 6 months {that's what Royce drives} and b~ Bill Swearinger oalling up Tim Bowles wanting to end =y=le o~ it all once arid for all. Step by step results follow. 1. Learn was not yet interviewed as she has not yet been located. However we did find out that she has left the employment of Varsity Communications and ~e found her last name, tra~ed her through her parents and now have her unlisted phone number i~ Hollyw. ood. She has not been in yet but should be able to be reached either tonight or Saturday. The good ne~s is that she no longe~ works for the company so ~il.l ~ot be unde~ the thumb of Palmieri. ~/~. Perry and E~binder have not been at the offioe or at ho~e over the last ~ days so have not yet been confronted. ~. Ambush intervie~ of Steve Perry (aka Bubba}. He ~ould confirm t-elationship of Bill S. and Walker. ~. Photos were taken to Royoe's neighbors and none recalled having ~ee~ Bill, Non o~ Bill's distinotive ca~ in the vicinity. 5. Bill's neighbors ~ere shown Noyoe, Bubba and E~binder and did not ~e~ognize the~. They were also sho~n the photo of Royce's white Cherokee and t~o of his nearest neighbors independently recognized havir~ see~ suoh a ~ar parked adjacent to the stairs leading up to Bill's ho~se a few times over the last six months. One of theseneighbors, M~. Franklee (a film edito~ said that Bill frequently had parties ~here young boys were observed at Bill' s house but had no =Ltst inct memories o~' any faces. 6. We have not been able to confir~ where Casey was 9 - 10-11 May due~o terminals not being a~essible. '7. The line to the secretary to get further data from the oourt ~=pc~-te~ ran i~to a logisiti~s snag and will need to be done Monday. B. Tho~h Royce has refused to speak at all with F~'an~ovioh, a line to go i~ onto ~e-establish the oomm ~as ~orked out which ~an be done early ne~t week (~rancovioh will take ove~ a ~heck owed to ~oyoe which ~iil be ~oming in Monday or Tues,. ~. The ~oung mexican we'd seen ~ith SwearingOt last month has not been identified. The neighbor checked with (Pranklee) recalled having seen him about a month ago walking away from the house, upset, originating to this neighbor "I can't go on like this any more, I'm real,ly upset.' ~nd this neighbor hasn't seen him since. Checks were made at a local ~xican restaurant the two had stopped at when under surveillance, no data, and a number in Guatemala possibly associated with this kid was c~ecked but the only person at the number ~ith contacts in LA ~as out of to~n for a week. So the kid could not be located to interview. -18. Ti~e spots Hhere Bill was seen to stop on surveillance were checked for familiarity with Royce or his vehicle or friends and the~e was no recognition. The vicinity of an address where Royce had been seen dropping off two young men was checked and one neighbor, a foreigr, man (Mr. Behar) recognized having seen a car similar to Bill S~ear~nger's in the neighborhood. 11. Stuart and Steve's office was visited, they were not there but the current office manager related a sto~y consistent with Royce Walker's des~ril3tion of S~earinger and Walker only casually knowing each other. 1~. Royce & friend's photo was shown to the receptionist and security ~an at 69~ Hollywood (~here Swearin~er's office is located, but ~ot d~a~in~ attention to Swea~i~ger). No recognition. His old ~T-f.tc~e ~ross the street was also ~hecked, no reads. -11. It was found that Caryl Warner does still practice law and works ~ut of 69~ Hollywood - Suite 500 - a full schedule every day. However a check made on Thursday revealed that he was out until Monday so no pretext interview has yet been done. A definite impingemerit was made from the actions taken B~11S~earinger phoned Tim Bowles at ~:15 today and said the following: that A1Bei of Ingram investigations was asking his neighbors ~ his clients questions about the veracity of Royce Walker, was i~y upset~ and said he wants it to stop immediately. He wants to er.d cycle on this escapade on his knowledge of the Judge's prejudice "once and for all". He said he is not willing to submit to a deposition (because the federal judge ruled that such a depo i~ irrelevant). However, he said he is Nilling to meet ~ith us to tell us wh~t he knows. He insists there is no prejudice from his father. He termed our efforts 'shooting in a barrel with nonexistant fish", somwething like that. He said that if we can't come to an immediate resolution on i~hi~ is he going to take "self-help". He specificaly mentioned ~uyi~g a gun or drafting and fil ing a motion for protective order in the federal case. He said he couldn't wait until Monday, he i~e~jded to resolve it no~. It is of interest that A1Bei did not intervieH any of the lqei~hbors, that ~as done by Ma~k Marinc. A1 St. went to the 6922 Hollywood building (S~eartnger's office~ and A1 Bei Jr. went to Royce's office at 7715 Sunset. We don't kno~ ~ho any of Bill's cl~ents are (though one of the women t~tervie~ed by Marino could t~ve been a client}. Nexi a) Have the confrontation with Swearinger and get him to tell the truth about ~his matter. If he insists he is being truthful, have him drag in Royce to ~onfess, and Francovich can be there too. t'Th~ fol.lowing steps to be do~ but called off if step (a) resolves it a~ co~inuing would ~ pointless.] b) X~erview Leann (per last call her ~o~ate said she's expected to be there Saturday) ~ho is ~ longer part of the Varsity office. She'll be ~ked ~ut whether the boys ~nt to Palm Springs as well. c) Ingram to call Casey to ask him Just one more questin - the Palm Springs question he neglected to ask him during the intervi~. ~) P~.l ~ ~u~t reporter string via the secretary resour~. e) A~ i~terviews of Embinder and Bubba. f) Fra~ovich to recontact Roy~ ~ith check o~ed to him and get him in. f) Pull down Caryl Warner string through pretext interview. il_ Ambush interview on Leann, the secretary (she ~as the one other .l~erson mentioned in the depo of Walker as someone he talked to about Son. She will be gotten outside of the office as in the office someone .~i_U ~ontact Palmieri and she'll clam up.) .~. lqn~bu~-h ~nterview of Steve Perry (aka Bubba). He could confirm ~i~g of Bill S. and Walker. iS. ~q~ ~erv~e~ of Embinder as possible. ú 4. Phc~to of Bill and Ron taken to Royce's neighbors to see whether .~~ seen them around. 5. Photos of Royce, Bubba, Embinder and Casey shown to Bill Swearinger' s neighbors. 6. Find out where Casey Klinger was the weekend 9 - 10 - 11 May, i.e. whether he was in Palm Springs or not. (pretext has been worked out to get this.) If in Palm Springs, get identity of the two fags they were with. 7. Use secretary resource who has a good line already to the court reporters to find out anything further on the cash payment cycle, i.e. was the Judge irritated, who else may have been there, etc. ~). Francovich to re-establish comm line with Royce over some business dealing, and see what further can be obtained from this line, get him to cop out to what occurred (witness present). 9. Use our Spanish speaking PI (Joe) to suitably interview the young mexican (P. Garcia may be name) guy who was seen with Bill Swearinger at least three mornings, who may live with Swearinger, and get the data on Bill's relationship with Royce 18. Use the data we have on Bill's contacts (places he was observed ~oi.nO ~n~en under surveillance and known comm lines he has) to interview ~-he~e contacts with pictures of Royce and Bill re: their relationship. 11. Stuart and Steve (Bill's former employers and Royce's friend) ~=en w/photos to establish how many times and for what reason Royce visited Bill. 12. Suitably inquire (with photos) at Bill's current law office about Walker, does he show up there frequently etc. 13. Pull down strings on any possible relationship between Swearinger and Caryl Warner (work in same suite though different offices) - through pretext interview. ,Pzl.'l the above to be done by Friday, the analyzed and retargetted. EXHIBITB I]~FLLIGE::C-": SPECLa. LIST, T.'tAINIkr',, ROUTi::E - TR L Furpoet,: To trcin th,j ~tudcnt to give a fa.lse stat~.ent with Good TR-1. To train the studunt to outflow false d-~ta effectively. Position: Same ~ TR-1 C~-mand$: Part 1 "Te~ me a lie". C~mand ~ivcm ~ c6ach. Pa~ ~ ~ter~e ~)~e 2 WC by co~ch. , Trainir.,-~ Stress: In Part 1 coach gives c.o~,~and, student origir. ates a falsebc Coach fl~:s for out TR 1 or TP. O. In Part 2 coach asks. question= of the student on bJs bachground or a subject. Student' give~ =ntrue date of 'a plau~ sort %hzt the student backs up ~rith further exp.)or~tor-i data upon the. co~ch . further questi6ns. The coach f!ur~.s for out TR 0 an4 T~ 1,..an'~ for student ú -f~.blin~ on question ~:nswers.- The student should be coached on a ~radient until he/she can lie f~Lly. ' Short example: . Coach: %~n~re-do you c~e from? Student: I ccme frcm the H~usewives ~ittee Coach: But you said earlier tlmt ~u were sidle. Student: Well, act~y I was Pa-ied but ~ ~v. orccd~ ~ have 2 ',rids S~ t sub~bs ~here X ~ a housewife, in fa~'I'~. ~. m~b~ of the P.T.A COach: }~t to~ is it that you live Student: West ~hton . Coach: But there is no public school in West Br~ht.~ a P.T.A. m~b~. ~nch: Oh, and who is the C~an thee? etc. UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA RELIGIOUS TECHNOLOGY CENTER, a ) California corporation, et al., ) ) VERSUS ) CV 85-711 JMI (Bx) ) ROBIN SCOTT, an individual, ) CV 85-7197 JMI (Bx) et al. ) RELIGIOUS TECHNOLOGY CENTER, a ) California corporation, et al., ) ) VERSUS - ) ) LARRY WOLLERSHEIM, an ) individual, et al. , ) AND RELATED COUNTERCLAIMS ) ORAL DEPOSITION OF VICKI J. AZNARAN August 2, 1989 Pages. 130~252 ANSWERS AND ORAL DEPOSITION OF VICKI J. AZNARAN, a witness produced at the instance of the Defendants, taken in the above styled and numbered cause on the 2nd day of August, 1989, at 10:55 o'clock_ a.m., before KIM S. JOHNSEN, a Certified Shorthand Reporter in and for the State of Texas, at the offices of Clark, West, Keller, 'Butler &.Ellis,.4800 Renaissance Tower, 1201 Elm Street,' in the City Of Dallas, County of Dallas, State of Texas, in accordance with the Notice and Subpoena issued and the provisions set for_th: ~ (Defendants' Exhibit V. Aznaran Number ~ 1 16 was marked for identification.) ~' ~Looking) ~ 2 A. ' ~ ~ 3 Q. Ms- Aznaran, do you know what Exhibit 16 is? 4 A. Yes. It's an LRH executive directive. 5 Q. ~ave you ever seen it before? 6 A ú Yes - 7 Q. Did you see it when you were with the Church of 8 ScientologY? _. 9 A. Yes. 10 Q. May I see it for a moment? 11 A. (~anding) ú 12 MR. FAGELBAUM: Mark as Exhibit 17 a one-page 13 document bearing the notation TR-1. (Defendants' Exhibit V. Aznaran Number 14 17 was marked for identification.) 15 A. Okay ú 16 Q. Do you know what this document is? 17 A. Yes ú 18 Q. What is it? 19 A. It ' s known as TR lie. 20 Q. TR lie? 21 A. Yes ú 22 Q. L-i-e? 23 A. yes. 24 Q. Have you seen this document before? 25 A. Yes. i =-'.~- 1 Q. Where have you seen it? -.~ ~.~' " 2 A. I first saw it in a mission in Dallas, later saw it Z':.- ~ ... ~ ~_~ 3 in the Guardian's Office in Los Angeles. 4 Q. When you say "mission in Dallas," is that a ~ 5 Scientology mission in Dallas? 6 A. Yes. ,: 1 i 7 Q. And what is a TR lie? i 8 A. It's a training regimen where someone is trained to -~ ~l 10 MR. MOXON: I object to the question. She 11 answered before I could object on the basis of lack of 12 foundation. Move to strike. 13 0. Do you know what the purpose of this document was 14 !for? 15 MR. MOXON: Objection; lack of foundation. 16 A. I know what it was explained to me that it was for. ~,~ 17 O. Who explained it to you? 18 A. A member of the Guardian's Office named Danny 19 Ch adwe 11. 20 Q. When did this occur? 21 A. 1974 or 5, I'd say. 22 Q. And how was it explained to you at that time? 23 MR. HELLER: Objection; hearsay. 24 MR. MOXON: Same objection. 25 A. That the purpose of it was to teach you to be able "'-~ 1 to lie when you needed to when you were asked questions that ~, ' .-' ~ 2 you didn't want to answer about persons, such as reporters o~ ~. ! '~ 3 whatever. .__ -~ :mmssT 4 MR. MOXON: Move to strike. 5 Q. Who was exposed to this procedure in the Church of 6 Scientology? 7 MR. HELLER: Objection; calls for speculation. 8 MR. MOXON: I'll join in the objection. Also .... "" 9 lack of foundation. Tfl 10 A. I mean, I couldn't say over all the years who all 11 was exposed to this. 12 Q. Who was given this kind of training as a generic 13 class, not an individual? 14 MR. MOXON: Objection; lack of foundation. 15 MR. HELLER: And speculative. 16 A. People in B1 in the GO. 17 -- MR. MOXON: Move to strike. 18 A. And public relations staff and guardian area. 19 Scient ologist s, GAS is what they went by, GAS. 20 MR. MOXON:-. Move to strike. 21 Q. What are guardian area Scientologists? 22 A. These are Scientologists that did work in the field 23 for the Guardian's Office. 24 Q. And what is B1 of the GO? 25 A. Bureau 1 are the Intelligence Bureau. œ- 1 MR. HELLER: Sorry. :, . ú 2 A. In order to show compliance that it was occurring, .~_ ~- 3 and then I was involved in the approval of the new name for 4 it. 5 MR. HELLER: Objection; move to strike because 6 the answer is hearsay answer. 7 MR. MOXON: Join in the objection. ~ ~.~ = 8 Q. Now, was the process of TR-1 made available to ~ 9 personnel in OSA? 8~ 10 MR. KELLER: Objection; no foundation. .-~]~ ~ 11 MR. MOXON: Join in the objection. -~- 12 A. I think we could say the tech was certainly applied. 13 The -- this document did not exist laying around there. 14 MR. MOXON: Okay. And move to strike the first 15 part of that answer based on my objection and because it's 16 not responsive. 17 Q. Are you aware of the tech being applied of TR-1 to 18 personnel in the OSA? 19 A~ I'm aware of them applying it to others. 20 MR. HELLER: Objection; no foundation. Again, 21 move to strike. 22 MR. MOXON: Join. 23 Q. Bow were you aware of that? 24 A. Well, let's start -- we can start with depositions. 25 There are certain people offered up to be -- when a j 1 deposition is noticed for a corporation, there are certain ~. ~ 2 people offered up to go and have that deposition taken. ~ -~.-~- 3 Before they do that, they are coached on what they should 4 know and should and should not say. ~-! 5 Q. Did you personally observe that happening? ~: 6 A. Yes, I have. \'~ 7 Q. Rave you observed that happening in this case? ~ 8 MR. MOXON: Today. ~.a~,~ ~ 9 A. I don't know if it was in this case or not. 3E 10 Q. Do you know of personnel affiliated with RTC being ~ 11 afforded this opportunity? 12 MR. MOXON: Objection; vague and ambiguous, 13 lack of foundation. 14 MR. HELLER: And unintelligible. 15 A. Yes. 16 MR. MOXON: Also leading. ! 17 Q. who? 18 MR. MOXON: Move to strike. O~ject to the 19 pending question. 20 A. Jessie Prince. 21 MR.. MOXON: Move to strike. 22 Q. Do you know if Jessie Prince testified in the 23 hearing in this case? 24 A. As a matter of fact, he did. 25 Q. Was he given TR-1 training prior to his testimony? ~: 1 MR. MOXON: Objection; lack of foundation. ~: :' 2 MR. HELLER: I'll join in that objection. o~7~~ ~- , 3 A. He was drilled as to what to say and what not to ~'=. 4 say. .:! ~, ~ ú 5 MR MOXON: I want to caution the witness ~'~ 6 again. She 's obviously making some broad generalities that 7.~ : 7 are not responsive necessarily to the questions, but if she' s ?.~ 8 talking about attorneys speaking with some -- if she's o~M[' -~. 9 referring to attorneys speaking to a client before they go 9.~ 10 into a deposition, I'm not sure if that's what she's talking œ~ 11 about or if she's, you know, making up something new at this a88[- 12 point. But to the extent she's referring to some 13 attorney-client com~nication when she's making an inference 14 or opinion about it, I instruct her that it's a privileged 15 matter. 16 MS. MCRAE: I'll caution the witness. I 17 represent the witness, Mr. Moxon. 18 MR. HELLER: Well, it's not for you to caution 19 the witness. It's Mr. Moxon's privilege. It's his ciient 20 which is being breached. Assuming you are the most reputable 21 attorney in the world, it still is his job to caution the 22 witness and make sure there are no disclosures of that as 23 well as your job and as well, as I might say, Mr. Fagelbaum's 24 job. 25 I assume Mr. Fagelbaum is not going to get into it to : 1 make the determination in good faith, but in fact that's a '2_ 2 job of an officer of the court, most particularly Mr. Moxon' ~ ~ i~ -'~- 3 job .~_-_ ú 4 Q. Was Mr. Prince advised -- excuse me -- was Mr. 5 Prince drilled by somebody other than an attorney in this 6 case? 7 A. Yes, he was. t ~ 8 Q. Who was he drilled by? 9 A. Mysel f. li ' 10 Q. Was there anyone else present at that time? t 11 A. I believe Jeff Shriver was. 12 Q. Anyone else? 13 A. I don't think so. =. 14 Q. Did you follow the procedures set forth in TR-I? ~ 15 A. Not rotely, no. ~ 16 Q. To what extent were they followed? 17 A. Well, I worked out for him not to tell the truth 18 about what happened when he was signing certain documents 19 over in England. 20 Q. What specifically did you tell Mr. Prince not to 21 tell the truth about? 22 A. It was more a situation of Jessie and I working out 23 together what he was going to say. 24 Q. Okay. 25 A. And what he was not going to say. 1 Q. All right. Can you describe what that conversation 2 was? --~ 3 MR. SELLER: I'm sorry. Please repeat that. .__ e~ '. ~'~ 4 Q. Can you describe that conversation? ~ '- ~. !,i]~~~ 5 MR. KELLER: Object to the extent it calls for ~-, ~ 6 ~earsay. ., ..~ 7 MR. MOXON: Join in the objection. ,~.~. ~~ ~ ~ 8 A. There was a document signed by Jessie, handwritten ~- ~me$, 'f ~-~' 9 ]ocument agreeing to something. It was signed by him and __ ;~œ~-~-~ 10 another party in this -- on the other side in this lawsuit. ~', _'œ/~.+ 11 ~And we were concerned that this document would be if Jessie ~' 12 told exactly how this occurred that he signed that, that it '~3~ 13 would be seen as, I guess you'd say, a release so to speak or 14 something along that line. Jessie agreed that he would say 15 ~e did not have the authority to sign anything like that 16 ~hereas when he was sent to England he did have the '~ 17 authority, and he also, of course, had it as a senior :~ 18 executive in RTC. 19 Q. What was the purpose of sending Mr. Prince to 20 Europe? 21 A. England. 22 Q. Yes. 23 MR. MOXON: Object; lack of foundation. 24 A. To get the people, one or more of the other people 25 who were -- who were involved in the theft of the materials, 253 1 IN THE UNITED STATES DISTRICT COURT ~ FOR THE CENTRAL DISTRICT OF CALIFORNIA 2 RELIGIOUS TECHNOLOGY CENTER, A ) ~. California Corporation, et al.,)CV 85-711 JMI (Bx) 3 Plaintiffs, ) )CV 85-7197JMI (Bx) 4 vs. ) ) 5 ROBIN SCOTT, An Individual, ) et al. ) 6 Defendants. ) ) 7 RELIGIOUS TECHNOLOGY CENTER, A ) California Corporation, et al.,) 8 Plaintiffs, ) ) 9 vs. ) ) 10 LARRY WOLLERSHEIM, An ) Individual, et al., ) 11 Defendants. ) ) 12 AND RELATED COUNTER-CLAIMS ) ) 13 *********************************************** _ ORAL DEPOSITION OF VICKI J. AZNARAN = 14 AUGUST 3, 1989 15 16 ANSWERS AND DEPOSITION OF VICKI J. AZNARAN, 17 produced as a witness on behalf of the Defendants 18 and Counter-Claimants, taken in the above-styled 19 and -numbered cause on the 3rd day of August, 20 A. D.., 1989, before Lori A. Belvin, a Certified 21 Shorthand Reporter in and for the State of Texas, 22 in the conference room of CLARK, WEST, KELLER, 23 BUTLER & ELLIS, 4800 Renaissance Tower, City of 24 Dallas, County of Dallas, State of Texas, in 25 accordance with Federal Rules of Civil Procedure. COURT REPORTERS ASSOCIATED ~'I~~tF~ Dallas, Texas 75219 (214) 748.-3382 '2771 1 weapon? 2 MR. MOXON: I object. 3 MR. HELLER: Lack of foundation. I'm 4 not sure I see the relevance, and well given of 5 what I know of my clients' involvement in regards 6 to the counterclaim. 7 THE WITNESS: Yes. 8 Q. What was that policy? 9 MR. MOXON: Move to strike. Same 10 objection. 11 MR. HELLER: An objection on relevancy. 12 THE WITNESS: There was an order from 13 Hubbard -- actually more than one. One concerning 14 Michael Flynn and another one concerning 15 litigation in general, which state that lawsuits 16 can be used and should be used to deplete anyone 17 who sues you money and harass them and get them to 18 back off. 19 MR. HELLER: I move to strike. It's 20 hearsay. 21 MR. MOXON: I join. 22 Q. Did you have any discussions with Church 23 of Scientology management with respect to that 24 policy? 25 MR. MOXON: Same objection. Lack of COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748-3382 '278 1 foundation. 2 THE WITNESS: Yes. 3 Q. Who did you have such discussions with? 4 A. Pat Broeker, Ann Broeker, David 5 Miscavige, Lyman Spurlock, Marty Rathbun, 6 Marc Yager -- 7 MR. HELLER: I'm going to move to 8 strike. I move to strike based on relevance. 9 MR. FAGELBAUM: I don't believe the 10 witness has finished her answer yet. 11 MR. HELLER: Oh, I'm sorry. 12 THE WITNESS: Jesse Prince, Mark Ingber, 13 Wendell Reynolds, Steve Marlowe, Gary Reisdorf, 14 Bill Franks. That's all I can think of right 15 now. 16 Q. Did you ever have such discussions with 17 Norman Starkey? 18 MR. HELLER: Objection. Leading. 19 MR. MOXON: Objection. I join. 20 THE WITNESS: Not that I recall. 21 Q. Now, the people that you did identify 22 that you had such discussions with, did they all 23 approve of utilizing that church policy of using 24 litigation as a weapon? 25 MR. MOXON: Objection. Leading COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748-3382 ~80 1 and his group to spend money on litigation rather 2 than on their group or expanding their group. 3 MR. MOXON: I move to strike as the 4 reasons I've stated. It's also nonresponsive. As 5 we know, Mr. Fagelbaum, the litigation's being 6 paid for by Frank Gerbode, who's not yet a party 7 to this action. 8 MR. FAGELBAUM: I'm not going to respond 9 to your comments. If you want to make an 10 objection, make an objection. 11 MR. MOXON: I made an objection. I move 12 to strike the answer. 13 Q. While you were president of the RTC, 14 were you aware of any Church of Scientology policy 15 regarding compliance with discovery requests that 16 were issued in lawsuits? 17 MR. HELLER: I'm going to have to object 18 on relevance as well as lack of'foundation. 19 MR. MOXON: And ambiguity. I join in 2O it. 21 MR. HELLER: That's true. It's an 22 unintelligible question. 23 MR. MOXON: Also calls for a potentially 24 attorney/client communication, depending on the 25 witness' understanding of that ambiguous COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748-3382 '281 1 question. 2 Q. I'm only asking for information that was 3 provided to you by someone other than a lawyer? 4 MR. MOXON: That doesn't cure the 5 problem, Mr. Fagelbaum, as you know. 6 Communications can be -- can and were provided to 7 her indirectly from attorneys. 8 MR. FAGELBAUM: As you know, Mr. Moxon, 9 you can't immunize facts by feeding them through a 10 lawyer. 11 Q. You can answer. _ 12 MR. MOXON: So that means you're going 13 to ignore the privilege? 14 THE WITNESS: Yes, there was. 15 MR. MOXON: I move to strike. 16 Q. What was that policy? 17 MR. MOXON: Same objection. 18 THE WITNESS: Discovery requests as well 19 as orders to produce documents or something by a 20 judge were complied with only if what was being 21 produced would not be damaging. If it was -] 22 something damaging, then it was to be fought by 23 the attorneys or destroyed or whatever, so that it 24 wouldn't have to be produced. 25 MR. MOXON: I move to strike it. COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748~3382 '285 1 A. Marty Rathbun, Jesse Prince, David 2 Miscavige, Paul Kellerhaus, Pat Broeker, Lyman 3 Spurlock. That's all I can think of right now. 4 Q. Did you ever have such discussions with 5 Norman Starkey? 6 MR. HELLER: Leading. 7 MR. MOXON: Objection. Leading. 8 THE WITNESS: Not that I recall. 9 MR. HELLER: Let's take a very short 10 break. 11 MR. FAGELBAUM: Okay. 12 (Time Noted: 10:38 a.m.) 13 (Short recess.) 14 (Time Noted: 11:02 a.m.) 15 Q. Mrs. Aznaran, who is Paul Kellerhaus? 16 A. He is a security guard or he was a 17 security guard at Gilman Hot Springs. 18 Q. To your knowledge, has the policy that 19 you testified to concerning the Church of 20 Scientology's response to discovery requests been 21 applied in this lawsuit against David Mayo? 22 MR. MOXON: Objection. Leading 23 question. Lack of foundation. 24 MR. HELLER: I'll join in both 25 objections. COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748-3382 '286 1 THE WITNESS: Yes. 2 MR. MOXON: I move to strike. 3 Q. In what manner? 4 A. Larry Wollersheim is a part of this 5 counterclaim, is he not? Wasn't he served part of 6 this suit; is that correct? 7 Q. Larry Wollersheim is a defendant in this 8 lawsuit, and he's consulted. 9 A. In the counterclaim? 10 Q. Not in the counterclaim. One of the 11 lawsuits filed by the Church of Scientology. 12 A. Okay. So he's a part of this? 13 Q. Yes. 14 A. Okay. I and Jesse Prince removed 15 documents from his files that would be auditing 16 files, and personnel and ethics files that had to 17 do with his RPF assignment; letters from his 18 family; letters to his family; conditions 19 assignments; and HCO bulletins concerning upper 20 level materials. 21 MR. MOXON: I move to strike. 22 MR. HELLER: Are you finished? 23 THE WITNESS: Yes. 24 MR. HELLER: Move to strike as 25 completely nonresponsive. The scope of the COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748-3382 f '287 1t response has nothing to do with this lawsuit. 2~ Q. What was done with those documents that 3 were removed? 4 A. They were destroyed. 5 Q. By whom? 6 MR. HELLER: By whom? I didn't hear 7 that last question. 8 Q. By whom? 9 A. By me and Jesse and some probably by 10 Alison Andrus. 11 Q. Is that Jesse Prince? 12 A. Yes. 13 Q. And Alison Anders? 14 A. Andrus, A-n-d-r-u-s. 15 Q. What's Alison Andrus' post? 16 A. At that time she was my communicator or 17 secretary. 18 Q. By whose authority did you remove these 19 documents and destroy them? 20 .. A. By whose authority? 21 Q. Were you ordered to do that? 22 A. I was asked to do it, yes. 23 Q. By whom? 24 A. Marty Rathbun. 25 Q. Were you told at the time why that was COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748-3382 1 being done. 2] A. I believe it was because those files had 3 been ordered to be produced in the Wollersheim 4 case. 5 MR. MOXON: Objection. Speculation. 6 MR. HELLER: And it's hearsay, and, 7 again, the whole thing should be struck because 8 the predicate of the question was: Was it done in 9 this case. But clearly if the fact it ever 10 occurred, it has nothing to do with this case. 11 MR. MOXON: I join in the motion to 12 strike. 13 Q. The files you were referring to, the 14 Wollersheim files, were those his PC files? 15 Ai They were his auditing files, his 16 personnel files, and his ethics files. David 17 Mayo's PC files were also destroyed. 18 MR. MOXON: I move to strike. 19 MR. HELLER: It's nonresponsive. 20 Q. Did David Mayo have any auditing files? 21 A. He had a great number of them. 22 Q. Did David Mayo have any PC files? 23 A. That's -- I use the same, PC, auditing 24 files, same, same deal. 25 Q. Did David Mayo have any ethics files? COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748-3382 '289 1 A. Yes. 2 Q. During the pendency of this litigation, 3 were any of those files destroyed? 4 A. The auditing files were. 5 Q. Why were they destroyed? 6 A. So they wouldn't be available for any 7 production requests and have to be brought into 8 the courtroom. 9 Q. How do you know these documents were 10 destroyed? 11 MR. HELLER: I move to strike the prior 12 answer. It has no foundation and consequently 13 speculative. 14 MR. MOXON: I join the motion. 15 THE WITNESS: David Miscavige requested 16 that Jesse Prince and I have all the auditing ~ 17 files, PC files, if you will, destroyed of anyone ~' 18 we were in litigation with or were enemies that we ~_- 19 might end up in litigation with. -- 20 MR MOXON: I move to strike Hearsay ..~ 21 THE WITNESS: I then put together a ~_; 22 project to do that. Paul Kellerhaus saw to the ~- 23 execution of that project, and I think he .t-~ 24 destroyed two or three truckloads of files. -'~' 25 ~' MR MOXON: I move to strike !;-~ ' ' COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748-3382 [ '290 1 Speculation. Hearsay. 2 MR. HELLER: I join. 3 Q. Where did this document destruction take 4 place? 5 A. Documents were removed from Gilman Hot 6 Springs and taken to a place that's specifically 7 for the destruction of documents, you know, that 8 pulps them, and I don't know the name or location 9 of that place. I never went there. 10 Q. How did David Miscavige communicate his 11 request to you? ~ 12 A. In person verbally. 13 Q. Did he tell you at the time why he 14 wanted that done? 15 MR. MOXON: I object. It calls for 16 hearsay. 17 MR. HELLER: Same objection. 18 THE WITNESS: Yes, he did. 19 Q. What did he say? 20 MR. MOXON: Objection. Calls for 21 hearsay. 22 MR. HELLER: I join. 23 THE WITNESS: He said that we didn't -- 24 we had problems with these things having to be 25 produced in court. We didn't want them in the COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748~3382 '291 courtroom and to just get rid of them all now 2 before the problem ever came up again. 3 MR. MOXON: I move to strike. 4 Q. Are you familiar with L. Ron Hubbard's 5 handwriting? 6 A. Yes. 7 Q. Can you recognize it? 8 A. I believe so. 9 Q. Are you familiar with David Mayo's 10 handwriting? 11 MR. HELLER: I'm going to object to the 12 last answer for lack of foundation and this 13 question, as well. 14 THE WITNESS: Yes. 15 Q. Can you recognize it? 16 A. I believe I could. 17 Q. Have you seen examples of L. Ron 18 Hubbard's handwriting while you were with the 19 Church of Scientology? 20 A. Yes, I have. 21 Q. Have you seen examples of David Mayo's 22 handwriting while you were with the Church of 23 Scientology? 24 A. Yes. 25 Q. Are you familiar with an upper level COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748-3382 DECLARATION OF MARGERY WAKEFIELD I, Margery Wakefield, having personal knowledge of the following, hereby declare: 1. I was a member of the Church of Scientology of CalifOrnia from October of 1968 until February of 1980. I joined the Church in Los Angeles, California, where I was primarily based although I also took courses and/or worked at Church organizations in St. Louis, Washington, D.C., Atlanta, Georgia and Miami, Florida. 2. While in Scientology I progressed to the level of OT 3 (an advanced level) and was also audited on New Era Dianetics for OT's, which is now OT 5. 3. During the summer and fall of 1979, I worked as a volunteer for the Church's "intelligence" operation, then called the Guardian's Office (G.O.) and now called the Office of Special Affairs, or O.S.A. I performed volunteer work for the G.O. at the Cedars location in Los Angeles and at the old Bank of Clearwater location in Clearwater, Florida. It is concerning some aspects of this volunteer work for the G.O. that this declaration is written. 4. In the fall of 1979, I was approached by a young woman from the G.O. in Clearwater and given a special project involving Pinellas County Circuit Court Judge Harry Fogle. I was told that Judge Fogle was ruling on an important case involving Scientology, although I was not told any -2- further details of the case, which would have been normal, as the G.O. operated on a need-to-know basis. My understanding was that this operation was being supervised by a G.O. agent named Milt Wolf. 5. My directions concerning Judge Fogle were as follows. I was sent with another Scientologist, pianist Mario Feninger, to attend Judge Fogle's Sunday school class at the Seminole United Methodist Church in Seminole, Florida. Mario gave a short talk on Scientology for Judge Fogle's comparative religion class. My directions were to befriend Judge Fogle after the class and get him to give me a tour of the church while engaging him in conversation. I was to try to get him alone in a room with me. 6. I was then instructed by G.O. personnel that I would be called into court where I would, under oath, make certain allegations concerning Judge Fogle: namely, that he had made sexual advances toward me, and also that he had made certain disparaging comments to me about Scientology. This was to be used to disqualify the judge from a case before him dealing with Scientology. I was coached by several different G.O. personnel who pretended to be the cross examining attorneys. 7. I was coached for my performance in court according to the Scientology policy called TR-L (for Training Routine Lie) which I was already familiar with as I had been introduced to it on one of my Scientology courses. TR-L teaches a -2- -3- Scientologist to lie with conviction under stressful circumstances. 8. I remember asking one of the G.O. staff members about the fact that they were teaching me to lie under oath, and I was quoted the Scientology policy called "the greatest good for the greatest number of dynamics," which simply means that whatever must be done to ensure the survival of the "third dynamic of Scientology" must be done regardless of the side effects. In other words, Scientology law is considered to be above and outside the jurisdiction of non-Scientology or "wog" law. Scientologists do not honor the Biblical oath, even though they may say that they do. This is TR-L in practice. 9. As instructed, I did meet with Judge Fogle in his Sunday school class. After the class, I did engage him in conversation, got him to give me a tour of the church, and was at one point alone in a room with him. As it happened, I never was called into the courtroom to testify against Judge Fogle, and I assumed that the situation had been taken care of in another way. 10. I was also engaged in another project at the Cedars building in Los Angeles and this project had to do with the Federal action involving the eleven Scientologists charged with burglarizing federal offices in Washington, D.C. -3- -4- 11. It was Standard Operating Procedure in Scientology to assign private investigators to collect information on each judge, and each lawyer and witness for the opposition in any important case. This information was then brought into the G.O. offices where a work station had been set up for each person being targeted for investigation. 12. All the information collected on one individual, for example a judge, was then laid out in chronological order in what was called a "time track." Bits and pieces of paper would be taped on a long sheet of paper. It was then the job of a writer to come in and write a narrative from this time track, and it was common knowledge that this narrative would be made available to the Scientology attorneys and it would be used for blackmail purposes when possible. 13. I was the writer assigned to complete a narrative on the U.S. Attorney's Office attorney named Raymond Banoun, which I did do. I was told to highlight with a yellow highlighter any mentions in the narrative of sexual misconduct, use of illegal substances or other crimes. 14. In another project in this same time frame, I was assigned the task of going through witness Michael Meisner's supposedly confidential preclear files and similarly tabbing any incidences of sexual irregularities, drug use, or criminal conduct to be used against him. -4- 15. I consider myself to have been an average Scientologist in the performance of these and other duties for the G.O. In one other case, I was included in a meeting where two murders were planned by Scientology personnel, and I was at that time in agreement with everything I heard planned in the meeting. 16. It is my opinion that I was brainwashed and under hypnosis by Scientology for twelve years. If I had been ordered to commit suicide by the organization I would have, without question. I think I might have taken a life if ordered. This was the strength of the mind control that I was under in Scientology. 17. Therefore, to perjure myself under oath when so ordered by the organization was not, to me, an unreasonable task, especially if I were led to believe that the security and/or survival of the organization was at stake. 18. I believe that most any ordinary Scientologist who was trained in Training Routine Lie would, upon command, lie in court, and would lie also about having been so trained. To put it simply, nothing such a Scientologist says in court can be believed or regarded to be true, as the Scientologist believes him or herself to be above, or outside the jurisdiction of "wog law." Such a Scientologist will not honor the Biblical oath because it has no meaning to him/her. -5- -6- 19. I believe my opinion can be substantiated by corroboration by other ex-Scientologists, particularly those who have had experience in working for the G.O./O.S.A. I declare under penalty of perjury, under the laws of the State of California, that the foregoing is true and correct. Executed the 23rd day of June, 1993, at Tampa, Florida. -6- 11/Feb/90 Dear Margery, You sent me a survey. I am sorry you have been through what you have. I went through a lot as did many of us but not to the extent that you have. I spent over $100,000 in Scientology and sometimes worked 3 jobs to pay for- it. I stupidly refinanced my house which I am still paying for. But I came to tenms with Scientology did not force me to do any of this. I will ingly gave the,'n the money because I believed them. They may have lied and they may believe sincerely that they ape right. I am the one who is nespc, nsible for making the mistake. But you know as wel 1 as I do some of it worked and very wel 1. 'that is what I refer to as the universal truth. Then there is Hubbard's think that he threw in and I bought it. Oh yeah I got thrown in ethic:ss and did 72 hr. sessio~s with a tooth brush cleaning the carpet at the old AO in Scotland and that was just after writing my success story for clear. When I get with some "old" Scientologissts we tel 1 war stories and laugh our heads off that we bought it hook ,1 ine and sinker. We got to give the old man or-edit, he was a gpeat communicatop. Anyway I was in for 17 yrs. and some 1 ittl e voice in my head kept me from joining staff. I sigr~ed the sea org contract and was real l y dedicated but I had an inside knowinghess that kept me surviving. I understand it all now and know what I was doing in Scientology so that is the price I paid for the job I did. I graduated from the BC so I was a Class VI. When I final l y got out of Scientology was when I finisshed New OT VII on the Key to Life course in LA. So I attested to the EP there and knew that nobody would ever- believe me but I put it on peEopd. Then I went to Flag and gave them the EP, had a floating TA and got back from the CS that I needed to buy '2 more intensaives of audited NOTs. I real ized then that I was out the top and knew more than they did and still do today. After being threatened with the ethics offic:er and signing release papers, etc., etc. I got the heck OLtt of there for good. I misssed the fun of it all and the auditing but I didn't need the BS f~-om them anymor-e. Laten I went to S'~anta Barbaria and was vepified by David Mayo that I indeed had the EP and was done. So now what about you? What level did you ~each? With the counse~ ins I have done since I have been out o~ Sciento]ogy I wou~d say thene is some un~lat things. F~ank]y I don't give two hoots o~ a ho]le~ i~ someone wants to say that is eva]uative. Sciento]ogy does not have the whole o~ co~pect sto~y on OT III or- how to run the NOTs data cor"r'ecztly. They cJon't even have the correct story. I can and have blown somebodie's entire N0"['s case in about 5 mins. AncJ believe me the~E' a whole lot of people out there who never' even walked in a Scientology doop who ~::now about the same thing. I was amazed. No wonde~~ we ne've~ al l owect to ~ead any othe~ stuff we would have found out the whole wor'ld knows and wouldn't have paid the pr-ice. ]: don't charge and sso if this is all the case for- you giVE' me a cal 1 and I can do it ove~ the phone or' if you ar-e even in this apea stop by and I'll take car. E, of it for' you. Norwalk, California March 1, 1990 To whom it may concern: In support of Lawrence D. Wollersheim's charges against the so-called 'Church' of Scientology, I herewith offer the following testimony. From April 1975 to April 1976 I was in charge of public relations for the cult of Scientology ~n Denver, Colorado. I appeared numerous times on television and radio to promote scientolo~y. I hosted an hour long scientology radio program on three different radio stations: KAAT, KTLA, and KWGN. For thousands of people in Colorado, I was scientology. I was keenly aware that in the accepted sense of the word, ~e were not even remotely a religion. There was however a sham widely in practice throughout the scientology network consisting of mock 'Sunday Services' wherein a 'minister' wearing the black garb and clerical collar of a catholic priest would ~et up and mouth a lot of pseudo-religious so~nding bromides, none of which I observed were ever practice~ in the cult itself. An odd looking cross, the brain cbild ~f l,. Ron Hubbard, was hauled out,dusted off and put on display, all for the purpose of reinforcing the religious image of the cult. This was a front. Veteren Scientolo~ists did not usually attend these mummeries except as shills to create the illusion of parisheathers at w~rshjp, a~d lll~,I~ ~;~ly 'if a I;~r.s;e nnmber of n~,~c public persons were expected. I recall once, while I was still in Los AnReles the head of our cult branch, Yvonne Gilham Jentzsch laughingly discussing putting up stained glass windows to further dupe the *Wogs. I joined scientoloRy June 5, 1970 to improve my abilities and my life. But the longer I stayed ]n the organization the worse I got. I had been brainwashed however to believe that only scientology held the key to my survival. In March of 1971 I attempted suicide for the first time. I ha~t been in the cult nine months. Increasingly I became antisocial and anti-American. I was inculcated with contempt for my government, other religions, and all persons not scientoloRists. Only after thirteen years did the veil at last drop from my eyes and I was able, with the help of friends, to see what scientolo~,y really was. On October 1, 1983 I left the cult: but it was ~oo late. by then I was a shattered suicidal wreck. In December of 1983 I wrote a formal letter of resignation disconnecting from the 'Church' of Scientology. *Contemptuous term for non-scientologists Norwalk, California March 1, 1990 To whom it may concern: In support of Lawrence D. Wollersheim's charges aRainst the so-called 'Church' of Scientology, I herewith offer the following testimony. From April 1975 to April 1976 I was in charge of public relations for the cult of Scientology in Denver, Colorado. I appeared numerous times on television and radio to promote scientology. I hosted an hour long scientology radio program on three different radio stations: KAAT, KTLA, and KWGN. For thousands of people in Colorado, I was scientology. I was keenly aware that in the accepted sense of the word, ~e were not even remotely a religion. There was however a sham widely in practice throughout the scientology network consisting of mock 'Sunday Services' wherein a 'minister' wearing the black garb and clerical collar of a catholic priest would get up and mouth a lot of pseudo-religious sounding bromides, none of which I observed were ever practiced in the cult itself. An odd looking cross, the brain child of L. Ron Hubbard, was hauled out,dusted off and put on display, all for the purpose of reinforcing the religious imaRe of the cult. This was a front. Veteren Scientologists did not usually attend these mummeries except as shills to create the illusion of parishoners at worship, and then only if a large number of new public persons were expected. I recall once, while I was still in Los Angeles the head of our cult branch, Yvonne Gilham Jentzsch laughingly discussing putting up stained glass windows to further dupe the *Wogs. I joined scientology June 5, 1970 to improve my abilities and my life. But the longer I stayed in the organization the worse I got. I had been brainwashed however to believe that only scientology held the key to my survival. In March of 1971 I attempted suicide for the first time. I had been in the cult nine months. Increasingly I became antisocial and anti-American. I was inculcated with contempt for my Rovernment, other religions, and all persons not scientologists. Only after thirteen years did the veil at last drop from my eyes and I was able, with the help of friends, to see what scientolo~y really was. On October 1, 1983 I left tbe cult; but it was coo late. By then I was a shattered suicidal wreck. In December of 1983 I wrote a formal letter of resignation disconnecting from the 'Church' of Scientology. *Contemptuous term for non-scientologists At that time I was employed in my family's business in Long Beach, California. My father (a non-scientologist) was president, my brother (a Scientologist) was second in command. As soon as I wrote my letter of resignation, the cult began to put pressure on my brother to disassociate from me and fire me from my job. My father at first refused, but my brother eventually gave him an ultimatum and he was obliged to fire his own son, which he did in March of 1986 As a result of these events I had a nervous breakdown. I became so emotionally undone that I couldn't hold even the most menial job. After three months I became penniless and homeless. I attempted suicide on June 30, 1986, and ended up in the county mental hospital, on Johnson Street in San Luis Obispo, California. 'Church' of Scientology policy had been carried out on me. My life was now 'ruined utterly' This cult has destroyed my ability to function in the every day world. I am suicidal often and must take pills to prevent deep depressions, a problem I never had before scientology. For the past three and a half years I have lived in a garage existing on food stamps. As regards the technology itself, I continued to believe it worked for about a year after I left the cult. I thus continued to receive scientology auditing in the field. On July 18, 1984 while being audited on NOTS I almost died. Only quick thinking saved my life. While a staff member at Celebrity Centre in Los Angeles 1971-73 where Mr. Wollersheim was also employed, a high ranking scientolo~ist namad Bill Howie cam._e ~1ose to dyin~ while on OT III. Around the same time I saw another staff member, Karen Fuller sitting quietly studying with some other students. Suddenly without a word she fell over in a death-like faint. She was also on OT III at the time. In 1974 I took over public relations at the scientology mission at Vancouver, Canada. I was told by several staff members that one Douglas Dewhurst a 'parishoner' had commited suicide in his car behind the mission on 6th Street. I affirm the allegations made by Lawrence D. Wollersheim as being consistent with my own experiences in the cult known as the 'Church' of Scientology. respectfully, Reuben Hart aka Robert M. Hart UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS LA VENDA VAN ) SCHAICK, et al ) ) Plaintiffs ) ) CIVIL ACTION v. ) NO. 79-2491-G ) CHURCH OF SCIENTOLOGY OF ) CALIFORNIA, et al, ) ) Defendants ) AFFIDAVIT OF JANIE PETERSON I, Janie Peterson, being first duly sworn, depose and say: 1. I joined the Church of Scientology in March 1975 and was a member until July 1980, during which time I spent 2 1/2 years as a staff member. 2. When I was introduced to "auditing" I was told that all the information revealed in auditing sessions was strictly confidential between the auditor and the "pre clear" and that this was treated the same as a parishioner giving a confession to a minister or priest. 3. After joining staff to work in the division that delivered the auditing, I became aware of the practice of many other people having access to and going through the auditing folders. These - 1 - include but are not limited to: all technical division staff, students, ethics personnel, Guardian Office personnel; if on staff - the person's seniors, other auditors, case supervisors, "word-clearing" personnel and others. 4. While acting as "Technical Secretary" I witnessed an out-ofstate person named Morris Deutsch (I am not sure of spelling) from New Mexico's auditing folders, being sent to Las Vegas, Nevada to be gone through by the Guardian Office, as he was a "suppressive" person and an "enemy" of Scientology and the Las Vegas Guardian Office, was, at that time responsible for New Mexico also. 5. During my time in Scientology, I witnessed out-of-state "missionaires" for the Church of Scientology of California come into the Las Vegas organization and go through auditing folders of people who they were trying to recruit for the "Sea Org" and/or people they were suspicious of for any reason. This would include people who had parents, spouses, friends, etc. that did not want them in Scientology. They had complete access to all auditing files and it was firmly established that we were to cooperate with them either in person, on the telephone, telex or any other means of request for information from a person's auditing folder. This occurred on many occasions while I was in charge of the auditing and the auditing folders. 6. Guardian's Office staff and intelligence personnel from the - 2 - Guardian Office had a series of files kept on Scientologists and reports, by other Scientologists, or auditing information from auditing folders, basically anything suspicious about a person who had voiced any disagreement with Scientology or L. Ron Hubbard or executives was kept in these files. I personally saw these files and knew that auditing information was being filed in these files and this was no~ known to the people receiving auditing. 7. The Church of Scientology of California completely runs Scientology at all levels. The United States Guardian Office runs every Guardian Office in the country, including Clearwater, Florida. The executive management structure is in Clearwater, Florida. Another management structure is in Los Angeles, California (FOLO) and that this is also part of the Church of Scientology of California. These run the organization throughout the U.S. 8. The above-described actions regarding the use of auditing information, access to auditing folders, Guardian Office staff using auditing information is standard procedure and is followed throughout the U.S. at the direction of the Church of Scientology of California. 9. While working on staff in the Guardian Office, I witnessed staff going through the auditing folders of staff members and public people. This was a regular practice. I was aware that - 3 - certain information people would reveal in auditing would be sent to the Church of Scientology of California, the United States Guardian Office and Clearwater, Florida, if requested or needed. 10. While working in the Guardian Office, I personally saw a man I believed to be sent to Las Vegas by L. Ron Hubbard actually xerox copying Mr. Ernie Hartwell's auditing reports from his auditing folder. 11. I also saw auditing information from the auditing folder of Tonja Burden that was sent to Carol Garrity, a Guardian Office staff member, from the United States Guardian Office in California and Florida and Carol had an order from her senior in the "USGO" to get said auditing information published in the news media. Miss Burden was at that time engaged in litigation against Scientology and L. Ron Hubbard and she was considered a top enemy of Scientology. 12. This practice of using auditing information for other purposes than were stated at the time the person received his/her auditing was standard and done routinely during all my years in Scientology. 13. I am aware of Lavenda Van Schaick's auditing folders being gathered in Las Vegas and gone through by Guardian Office staff members at the time Mrs. Van Schaick retained the services of - 4 - Attorney Michael Flynn in Boston. This was done to gain information about Mrs Van Schaick. 14. Outer "missions" under the control of "Class 4" organizations routinely sent auditing information from persons' auditing folders who were under "ethics" actions or were in some kind of trouble regarding Scientology in the areas where the missions were. If needed, this auditing information would be sent to the Church of Scientology of California and the United States Guardian Office, which is part of the Church of Scientology of California. 15. A Guardian Program entitled "Shake and Bake" was written by the tip management of the United States and England Guardian Office to "handle" Lavenda Van Schaick so that she would not continue with litigation against Scientology and L. Ron Hubbard. I saw this program and part of it was an "information-gathering" section on Mrs Van Schaick, including going through her auditing information. 16. Due to all of the above actions, ~hen I thought about leaving Scientology and pursuing my legal remedies, I was in fear that these actions would be done to me and that my personal life and the information I gave during my auditing would be used to blackmail me and be taken to the news media for publication. - 5 - 17. During auditing a person reveals his most personal thoughts, feelings, actions and those of his families, friends and anyone influencing his life. 18. I am also aware of a Guardian's Office operation to get Michael Flynn disbarred and thereby eliminate him as a representative of individuals who have been victimized by the Church of Scientology. I observed "operations" being planned and executed to infiltrate Mr. Flynn's law office with a "plant" named William Broderick. This operation was called "Operation Oscar". The purpose of that operation and others that were being planned was to get someone inside Mr. Flynn's office for the purpose of gathering information. Signed under the pains and penalties of perjury this 25th day of May, 1982. Janie Peterson SUBSCRIBED and SWORN to before me this 25th day of May, 1982. (PHYLLIS NORQUAY) NOTARY PUBLIC Glossary: FOLO - Flag Organization Liaison Office USGO - United States Guardian's Office - 6 - UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS LA VENDA VAN SCHAICK, ) ) Plaintiff ) ) ) CIVIL ACTION vs. ) NO. 79-2491-G ) ) ) CHURCH OF SCIENTOLOGY OF ) CALIFORNIA,~ et al, ) ) Defendants ) AFFIDAVIT OF GERRY ARMSTONG I, Gerry Armstrong, hereby swear under the pains and penalties of perjury as follows: 1) I have personal knowledge of the following facts: 2) I was a member of the Sea Organization of Scientology from February 1971 to December 1981, during which time I held many positions and was in many locations where I directly observed L. Ron Hubbard and other Scientology executives. At no time did I ever get the impression that Mr. Hubbard or any other senior executive considered that Scientology is a religion. My own understanding, held throughout all the time I spent in Scientology, and the policy expressed to me by other Sea Org members was that Scientology operated totally as a business, and its efforts to be recognized as a "religion" were only to evade taxation and government regulations. 3) In January 1980, I was assigned to a project to collect materials about L. Ron Rubbard for the purpose of providing documentation for a biography to be written by Omar V. Garrison. During the following two years I read several thousand pages of documentation, much of it written by Mr. Hubbard himself. Never before had anyone within Scientlogy ever had all this information assembled in one place or had the opportunity to view and assimilate the whole truth about L. Ron Hubbard. From these documents and other sources I learned that Mr. Hubbard had continually misrepesented himself and had lied about his past, his accomplishments and credentials. I learned also from the documents I collected that Mr. Hubbard had lied about how and why Scientology had been established as a "religion". In a despatch he wrote in early 1980 to the people in charge of the projects he had ordered to remedy his legal problems with the IRS and various damage claim cases, he stated that the creation of Scientology as a "religion" was not his idea but had come about when the membership of Scientology in the early 1950's, unbeknownst to him, had voted to form a "church". I personally saw and read that despatch. Mr. Hubbard's statement is a lie. In a letter to the head of Scientology in the US in early 1953, Mr. Hubbard stated: "We don't want a clinic. We want one in operation but not in name. Perhaps we could call it a Spiritual Guidance Center. Think up its name, will you. And we could put in nice desks and our boys in neat blue with diplomas on the walls and 1. knock psychotherapy into history and 2. make enough money to shine up my operating scope and 3. keep the HAS solvent. It is a problem in practical business. "I await your reaction on the religion angle. In my opinion, we couldn't get worse public opinion than we have had or have less customers with what we've got to sell. A religious charter would be necessary in Pennsylvania or NJ to make it stick. But I sure could make it stick. We're treating the present time beingness, psychotherapy treats the past and the brain. And brother, that's religion, not mental science." I found a great deal of similar evidence in the materials I assembled before I left Scientology. Mr. Hubbard's life has been a continuing pattern, since the early 1940's, of fraudulent business practices, tax evasion, flight from creditors and those seeking recompense, and then going into hiding, outside the reach of wronged individuals and legal jurisdictions. In short, it is the life of a con man. 4) In early 1980 I was also assigned to a mission, the purpose of which was to work out legal strategies, and get them implemented, which would allow Mr. Rubbard to still control all of Scientology via his Commodore's Messenger Organization while being shielded from any lawsuits or legal invlvements and responsibilities. One of the main problems which had to be resolved by this mission, and one of the arguments .used in various court cases as proof that Scientology was not a religion, was the fact that Scientlogy was set up so that funds inured to the benefit of L. Ron Hubbard. For years Mr. Hubbard had had his legal representatives claim that he was not paid by Scientology, other than a $35,000.00 annual consultant's fee, and royalties from sales of his books. Another claim was that he did not control Scientology monies. The fact is he had absolute control of all Scientology accounts. As late as 1980 I saw a despatch from him in which he ordered that unlimited Scientology funds were approved for a project to get him a Nobel Prize. Another fact is tht he received millions of Scientology dollars directly from a foreign corporation called Religious Research Foundation. Payments for auditing or courses at Flag by non-US Scientologists went into RRF accounts which Mr. Hubbard controlled absolutely and used totally for his own purposes. 5) I learned through my study of the documentation I assembled, and from more than ten years of observation of Mr. Hubbard and the Scientology movement, that Mr. Hubbard has cruelly deceived his followers to the point where they will themselves lie and attempt to deceive others about the truth cncerning him and Scientology. Scientology spokesmen and witnesses have stated that Mr. Hubbard doesn't control the organizations. The fact is he has absolute control, including financial control, and Scientologists know it. Between 1978 and 1980 I participated, along with at least 250 other Scientologists, in several massive operations to destroy or hide the evidences of Mr. Hubbard's control. Scientology spokesmen and witnesses have claimed that throughout 1980 and 1981 Mr. Hubbard could not be reached through the organization, or that organization executives did not know where he was. The fact is, the most senior executives were in continual communication with him throughout this period. Scientology spokesmen and witnesses have gone to great lengths to "prove" that Scientology is a valid religion, while knowing that it was simply a behavior therapy masquerading as a "church", and making a mockery of actual honest religious practices. In 1980, Wa.tchdog Committee, the senior CMO body, responsible only to Mr. Hubbard and senior to every Scientology organization, ordered that every Sea Org member had to complete the Minister's Course in two weeks or they would be assigned to the RPF. The reason given was to make every Sea Org member a "minister of the church of Scientology" and so avoid the US Selective Service draft then pending. What most Scientologists, and especially Sea Org members, don't know is that Mr. ~ubbard had duped 'them. My knowledge based on documentation and observation, is that the major reason for Mr ~ubbard's calling Scientology a "religion" in ú , addition to tax evasion, is to hide behind Constitutional guarantees for religions and so carry out his scheme of mind control to keep his followers duped. He has systematically and knowingly lied to and defrauded his followers, kept them from finding out the truth or becoming free with cruel and bizarre treatment, as for example with the RPF, and kept them economically and mentally suppressed,.while he made millions of dollars from their labor. 6) I am personally aware that Mr. Hubbard's policy of Fair Game is still a practice of Scientology. Since I left the organization with my wife in December 1981, I have been declared an enemy, and I believe my life and my wife's life, are in danger. Signed under the pains and penalties of perjury this 22'nd day of July, 1982. Y ARMSTRONG _ UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS LA VENDA VAN ) SCHAICK, et al ) ) ) CIVIL ACTION v. ) NO. 79-2491-G ) CHURCH OF SCIENTOLOGY OF ) CALIFORNIA, et al, ) ) Defendants ) AFFIDAVIT OF RONALD DeWOLF a/k/a L.RON HUBBARD, JR. I, Ronald DeWolf, formerly L. Ron Hubbard, Jr., ]~'efeby de~6s~ and state as follows unaer :he pa-n~ ~nu penalties of perjury: 1) I have personal knowledge of the facts set forth in this affidavit. 2) I am the oldest son of L. Ro~ H'dbbard, having been born on May 7, 1934 in Encinatas, California. 3) Between 1949 and 1959 my father and I worked together on a regular basis in organizing, developing and promoting many organizations and corporations. which collectively became known as the Church of Scientology. 4) My father promoted the Church of Scientology with the sale of his books and publications based on his Various theories relating to the "science of mind" as the most "exact science" ever developed. He represented in writing in most of the Church publications that he possessed degrees from George Washington University, Princeton University, that he was a nuclear physicist, that he served four years in combat, was seriously wounded and healed his war wounds with his theories on the "science of the mind", which is the foundation of Scientology. Throughout the development years of Scientology and to the present date, the Church of Scientology has made the foregoing representations and most individuals who have joined the organization that I personally know, relied specifically on my father's represented qualifications and credentials. The stated representations are all false. He never obtained degrees from those universities, or ever served in combat. He was relieved of duty three times as being unfit, and ended up in a psychiatric hospital at the end of the war. He is a fraud and has always been a fraud. 5) My father's fraudulent conduct is exemplified -2- in the structure of his corporations including the Church of Scientology of California. In connection with each and every corporation which we created under general heading of 'the ChurcH0f scientology, my' f~ther always required all of' the Directors and Officers of all corporations to give him undated signed resignations in advance which he held. In that manner, he always has retained complete control over every corporation including its bank accounts. In the early years, my father regularly emptied out these corporation bank accounts whenever the A.M.A., or a local district attorney, etc. posed a threat to one of his organizations. A copy of express instructions on this point in my father's handwriting is enclosed. 6) My father represented orally and in writ/a~g that his theories relating to the "science of the mind" were based on 30 years of case studies conducted on a scientific basis by him as a nuclear physicist and scientist. Most people that I knew who paid money to my father's corporation to learn about this science also relied on the above stated representations in addition to my father's credentials. Similarly, the above stated representations are false. My father wrote his books off the top of his head based on his -3- imagination. There were no case studies. He is not a nuclear physicist and flunked nearly all of his science related courses in high school and college. 7) My father obtained the rights to the E-meter in 1952 from Volney Mathison in the same manner that he does everything - through fraud and coercion. My father learned about the E-meter from Mathison who developed it and my father fraudulently extracted those rights from Mathison so that my father could use it in Scientology auditing. 8) My father has always used the confidential information extracted from people during auditing sessions to intimidate, threaten and coerce them to do what he wanted, which often meant getting them to give him money. My father routinely used false threats and auditing information particularly about crimes people had committed to extort money from them. 9) My father has always held out Scientology and auditing to be based purely on science and not-on religious "belief or faith. We regularly promised and distributed publications with "scientific guarantees". This was and has always been common practice. My father and I created a "re- ligious front" only for tax purposes and legal protection 'from frahd Claims'. we almost always to-ldnearly everyone that Scientology was really science, not a religion, but that the~religious- ~ont was or~a~ed-t~D.--deal--wi~h t4~e government. 10) My father's basic policies relating to "suppressive persons", "Fair Game", "attack the attacker", etc. have .always been and will always be an'integral part of Scientology. The organizational structure of Scientology and the theories of Scientology cannot operate and Scientology would not be scientology without such policies. The entire basis of my father's "science" is the suppressive person, '(~':~i')'doct~inG. ..... sci~toiog~"'i~"~not'sclentology'~i'th'out' this theory, just as nazism would not be nazism without the theories of Aryan supremacy and anti-semitism. My father and I discussed the basic theories of dealing with suppressive persons, such as what eventually became designated as the "Fair Game Doctrine", on many occasions. These policies have never changed. Signed under the pains and penalties of perjury // - RONALD DeWOLF ** AFFIDAVIT ** PAUL SIMMEL 167 Pekara Drive Deerfield, Illinois 60015 August 16, 1989 Very roughly, to date i've spent over fifteen years in Scientology: I am officially still a member. By 1981/82 I had reached one of the "highest" levels in Scientology processing known at that time: Full OT 7 (old OT levels). For those not familiar with "OT levels", they are secret bodies of knowledge which are supposed to answer the mysteries of life, combined with processing techniques, which, when completed, produce super beings. These "OT levels" can only be given after one has first completed many, sometimes hundreds of hours of earlier, "preparatory" processing. The whole idea in Scientology is to scrape, steal, beg and borrow one's way up the road to "OT" which promises eternal, superior spiritual pow'ers far advanced than anything known to man. The cost, in terms of money for those levels and those needed previously, for me, was roughly 20,000 or more dollars. In exchange for my money and time, instead of spiritual states of awareness beyond my wildest dreams, abilities far and above those of mere human beings, power to will and create that which I wanted or needed in life far easier than ever before, I got brainwashed. It had started from the very beginning, as far as I am concerned. I had in many ways lost my own will. I was literally a captured individual whose autonomy had been supplanted with subservience, afraid to communicate any real feelings, felt constantly that my setbacks in life were because of my having committed crimes in this and past lives, that the fault for not getting what was originally promised lay in me, not the Church or its system which purported "mental health." At 20 or 21 years of age, in hopes of alleviating the very real pain I was experiencing from splitting with a girl friend, I tried Scientology's first course: the Communications Course. It was very difficult, for I had been in chronic grief, day and night for months. After the course, my grief was not substantially lessened. I was told I needed processing at the cost (then) of $500 per twelve and a half hour block, and because I had no money for this I wanted to leave. I was told that if I left, my home and surroundings would destroy me. I was told that unless I had this processing and continued with Scientology I would soon deteriorate. Apparently these words had their effect, for a year or so later, I again found myself involved with Scientology. This time I was told Scientology t~aining represented a career for me. This was very appealing because I had been for the most part uneducated, and this proposition was seen as an opportunity to better myself. I was also told the courses were in some states acknowledged as college credit soon to be accepted nationwide. This was where L. Ron Hubbard's many impressive "credentials" were introduced: the many years he spent traveling in Asia; his war record; a nuclear physicist, etc. As an "auditor", I was told I could earn up to $50 an hour provided I had the proper Scientology training. Thousands of dollars and a year or two later, the career never materialized, though I had attempted to counsel in the field (outside Scientology organizations) with some, but little success. States were not recognizing Scientology training as legitimate in the education fields. Most press was negative, calling their practices cult-like. It soon became apparent that one really needed the organizational ties to make any progress, and that meant working for them. I tried this for six or so months, earned perhaps $10 per week for roughly seventy hours of work, and when I left the organization as a staff member I was required to pay for the training courses they required of me. There were many grueling hours during the period I had been a staff member, (two times in all) as well as a "paying public". Six days and evenings a week, sometimes thirty hours at a stretch, drills, reading, word-clearing (a form of control), more drilling. Much of the time I had little or no sleep. At one point I had gotten a $15,000 loan for the upper OT levels (advanced levels where the power was), moved into my parents' basement with my wife to sav~ on bills, and did nothing but Scientology related activities for a few years. Plans were to rise to the level of "OT" and of power. We thought life would come together once the new abilities were exercized. We were to sacrifice "now" to ultimately "win" later. But after the levels were done, we were still in the basement. None of the coveted power was there. New levels had come out, "breakthroughs,, as they were called, which had to be done in addition to what had already been done. These now became the levels which produced the powerful phenomena I was counting on. So, I was told that if I didn't do these newer, "higher" levels, I would be at risk as a spiritual entity. I hadn't yet paid off the first loan for the first set of levels, and these new ones were much more expensive. But I never got them. Instead I spent over two years attempting to handle a very ugly dispute with my business partner (a Scientologist), within the Church's own justice system. Here, roughly 1981 through 1983 is where I had suffered greatly. I lost a business, lifetime friends, nearly my marriage. My "good name" as a Scientologist, as a person, my sanity as dictated by the Church ~v~as under heavy attack by "fellow" Scientologists. All of the transgressions committed against me and my wife by these people, were ultimately validated by the Church, primarily because the individual I had grievances with was a "paying customer", and I had stopped paying for future levels. I was under threat of expulsion if I took the matter into secular court to gain ba'ck my business or collect damages for slander and libel from my busines partner. I was told that if I spent some more money with the Church, I might get more favorable action. And since I did not, I was socially ostracized, labelled a "down-star" (one who does not pay lots of money to the Church) and virtually abandoned. I had put my life; marriage; family; friendships; business; income, into Scientology, all based on the promise that at the top-portions of processing and training~I would be better able and very powerfully equipped to handle life. Instead I had lost many years of that life to a system which truly can and does brainwash. For some the brainwashing ma~ never be undone. For others more lucky, like me, apparently because of becoming distanced from the daily grind, the effects begin to wear off enough so that the damage can be spotted, and if enough of you is left a healing process can take place. 5 Scientology is harmful, for the Church seeks not to help but to entrap. The Church does not coach one into a power position, but convinces one that alone, he can't be powerful and able, that in fact he is less than alive ~ithout a steady flow' of funds for I,. Ron Hubbards's teachings. Scientology inhibits growth, rather than gives it. From the very beginning the emphasis remains focused upon the negative, the evil, the inabilities of mankind (of which I am a part) in his present state. One is systematically broken-down, reduced in stature and size through the training and processing. Then, after one feels truly worthless, he is given the OT levels to "bring him up" from the muck he has been in. But of course'by now reality is so thoroughly transient anything can be believed. It is a real nightmare because it is very difficult to explain, and by the time one can articulate some of the effects much time has passed which gives the Church a feather in its cap, representatives inevitably saying, "Well, why didn't you say something at the time?" How has the Churct-j harmed me? Other than the above, false promises which lead one to genuinely commit self and resources toward fulfillment of genuine needs, spiritually and emotionally, take away from an otherwise potentially productive life and leave one with a failure in the end. Fraud and deceit, when used as forces to gain an intimate knowledge into one's most personal life, to pry into the mind to alter it, to impress a foreign substance against it leaves one with a need of repair which itself takes more time from otherwise productive activity. It's a person's life that gets slowed down, hurt, unnecessarily derailed, left in need of a healing process not unlike a physical injury which keeps one from living a full, happy life. I don't claim to have all the answers, or even know the extent of damage that can be done by such religious cults. I am not an expert. I can only speak from my personal experiences and relate some of the rationale which has helped me. I suppose I am the only one who can say whether or not I was harmed, bilked, or made unhappy. I don't know how many times I told myself, "Religion is not supposed to do this to me. Religion is supposed to help me, to validate me, to help me feel my worth to support me in my travels through this life. Not make me feel degraded and humiliated, weak and selfless, ever dependent and subordinate." ** AFFIDAVIT ** SUSAN SIMMEL 167 Pekara Drive Deerfield, Illinois 60015 Au9ust, 1989 I became involved in Scientology in 1978. I was attracted to the camaraderie, and impressed with the apparent importance and size of the movement. Like the promotion had stated, I too envisioned a better world without crime, insanity, or war. I was hopeful in improving the state of mankind. I was equally excited by the prospect of becoming a kind of spiritual super-human with abilities that mere mortals have only dreamed about. I was promised that Scientology and its technology had all the answers, and was the only way to achieve total freedom; LRH had mapped the only route. This was all possible because of the genius of LRH; the tech was his great sacrifice and gift to man. I was urged to join staff, and did so, because staff members were doing a great service and would also get their services for free. I lasted only 3 months because I could not afford the job. I was quick to discover that staff members were not getting their "free" services. Leaving staff was frowned upon by the group. By this time I had dropped all my former (ordinary) friends, proceeded to alienate my family, looked at all non-Scientologists as I was told to--like stupid, unaware, dramatizing degenerates--and looked at tile world through the veil of Scientology. My new husband and myself moved to L.A. so that he could become a professional auditor which was a much-needed and greatly appreciated job that was looked upon very highly by LRH. An auditor, it was said, would make a lot of money. I thought I had married a guy that was going to be incredibly respected in society, and very well paid in his profession. I worked, and he studied. I was offered a job 2 by the Guardian's Office as a receptionist-plant in an office in San Francisco where I would keep my ears open and relay information back to the Church. As a newlywed, I turned the job down. We lived for the next seven years in my in-law's basement. We did so because the rapidly rising costs of Scientotogy services made it impossible to move out. There was a lot of pressure to not spend ANY money on anything except Scientology. My husband's prestigious position as an auditor proved implausible. Any prospects he had were swiftly swayed to receive services elsewhere, like at an Org, and the Church's policy of "field auditing" was changing, making it difficult to work as an auditor. We eventually gave up on the idea of earnin'g a living this way. Our daughter was born, and I was pressured to obey LRH's preference of no breastfeeding of babies. I went so far as to write him personally and querry his position, but he reiterated his preference. Our daughter's front baby teeth were destroyed by LRH's baby formula which required barley water, milk, and corn syrup. There was a fast and furious rumor line in the Chicago area around that period of time. There were cliques, intense competition between people and their positions in Scientology, and competition between the Mission and the Church. Everyone knew everyone else's business. Amid this atmosphere, I made a grave mistake. In my desire to "keep Scientology working", I wrote-up a local opinion leader due to my doubts about his credibility. Trouble began, people quit talking to me, my husband was forced to leave his business, and the group tried to convince him that I was suppressire. I was publicly humiliated by being forced to answer to their contrived inquisition. My reputation was 3 slow to recover, and was really never the same. I had never known upset greater that at that time. I had never been treated so coldly or judged so harshly. I had entrusted my life, my entire identity to this religious c3roup, yet I was accumulating more grief, loneliness and despair than compassion and/or spiritual awareness. The Church had repeatedly promised to straighten out this mess. I would tell of my plight over and over again to any staff that came into Chicago from any part of the country. This was always humiliating and uncomfortable. Always they would promise to help but under the condition that I buy services. I was talked into flying to the Washington 0rg out of desperation; they would help me if I bought $21,000 of services. I considered a second mortgage. There was heavy pressure to do this, and I received phone calls from'L.A. and Florida well into many nights. When I finally said No, there was great, harsh criticism and make-wrong. I was again ostracized from the group. A very highly positioned staff member threatened me with expulsion because I was upsetting the Scientology field. He swore at me, screamed at me, called me names, and I was not allowed to leave the ORG until I passed an "end rudes check" proving that I had or had not lied. All of this degradation and humiliation was because I had reported on a well-paying member. This treatment was confusing as I was only obeying LRH and his rules. I spent many sleepless nights, and experienced great upset. Meanwhile, the prices of SCN had skyrocketed putting the cost of our services well in excess of $100,000 each; an unattainable goal. We knew ~e could never afford this as those prices increased each month. We complained that the prices were too high, and thus called into the 0rg for a "roll-back" which ~as designed to trace down rumors. Not 4 being able to afford our freedom basically meant that we were unable, no good, and would never amount to anything. This was a devastating realization. I began to think the SCN was not for the good of mankind as the average person's income ~~as even less than mine. People could not have spiritual freedom if they did not have a bottomless checkbook. This all made no sense. Negative stories were surfacing about Scientology. The Church had reorganized, people were thrown out, and the prices were ridiculous. I felt that there was nowhere to turn. I could never be "free", but was told that if I didn't proceed up the Bridge I was doomed, and life would be horrible. I was an emotional wreck, my husband was an unemployed, emotional wreck, there was ~o future, and life was no fun at all. The thought of leaving the Church and becoming an ordinary person was sickening and unthinkable. I felt like a misfit though; I didn't fit into Scientology's mold, and didn't fit into society anymore either. I wanted to leave it all behind me but was constantly reminded that the only way to make it in life was through Scientology. It was a never ending delemma, a brainwashing. As I distanced myself, I became more able to question the things that didn't make sense. Where was the comfort I had sought through my religion? How could a religion cause me so much grief and desperation? Yet, I could not lift that Scientology veil and see the world clearly. I could not because I had been told repeatedly by LRH that there was an advanced level beyond my ability to recognize, 0T 3, and I thought that this might be the reason for my disaffection. I felt that once I knew this level I ~›ould be able to leave the Church, that is, if I lived through it, because I was not properly prepared. When I read the secret story of OT 3 and did not die, as I had been told, I was on the long road to recovery. I have since read 5 the story of the advanced level OT 8, and did not subsequently spontaneously combust either. I have spent countless t~ours analyzing the effects of Scientology and the stories of LRH. My experience with the Church shows the malevolent side of the group. My benevolence was exploited. I am concerned with the repercussions of exposing myself, because I know the Church is a powerful and wealthy organization, but the truth must be made known. ** AFFIDAVIT ** CHRIS TYLER 6011 Shadow Lane ~68 Citrus Heights, California 95621 August 7, 1989 I spent 2~ years in the Sea Organization where I lived and worked on the Scientology premises in Los Angeles, California from 1978 to 1981. I worked about 14 hours a day, 6 - 7 days a week in exchange for a room I shared with several other men, three meals a day and from 12 to 24 dollars a week. I married in 1981 to a Scientologist, Lorelei Goltz, and left the Sea Org. We moved to Sacramento, my home town, right away. I was soon given a bill from the Sea Org for over 5,000 dollars for training received while on staff. I was told to pay it or I would be sued in court for the money. In 1982 we had a baby boy and at the same time went through a bitter divorce. She resisted letting me see Eric very often on the basis of the following-- Lorelei was still an avid follower of Scientology all this time and I had fallen away. I was not in good standing. The church pressured Lorelei to "disconnect" from people not in good standing with Scientology - including me. I put the pressure on with a court hearing to establish regular visitation. The situation was resolved. In 1984, while this was going on in court, Sea members visitincj the organization in Sacramento urged me to drop the court case. I refused. In 1984 I was formally expelled from Scientology and declared a Suppressire Person. One of my "crimes" listed on the declaration was the fact that I went to the state courts to seek an order allowing me specified visitation with my then 3-year-old son. I regret having ever been involved with Scientology. I believed at the time they wanted to help people. Now I believe that L. Ron Hubbard formed the Church of Scientology only for his own wealth and power. I believe Scientology to be nothing less than a dangerous cult. I have personally known dozens of persons who are former Scientologists whose lives were harmed by Scientology. I would not recommend Scientology to anyone. ** AFFIDAVIT ** HANK LEVIN 3841 Somerset Avenue Castro Valley, California 94546 September 4, 1989 In the late seventies I paid the Church of Scientology approsimately $4000 in advance for "NOTS", to be delivered at the Advanced 0rganization in Clearwater, Florida. At this time my wife and myself had at least $17,000 on account as advanced payments with the Church. When I arrived at Clearwater, the registrar asked if I'd be able to afford additional funds in the unlikely event that they might be necessary for "special repair actions" I confided that I did have some personal reserves invested in precious metals. Even though I was scheduled to begin "auditing" within the hour, I was suddenly told that the "Case Supervisor" had decided not to permit me to begin unless I paid in advance for additional "auditing" to the amount Of my personal reserve savings mentioned above. I petitioned all the way up to the "Commanding Officer" of the Advanced Organization, pointing out that I had been promised I could begin with the $4000 payment and had already paid for plane fare out from my home in Los Angeles, and to cash in my assets would require personally returning to L.A. and wasting double the plane fare. They were adamant in their insistence. I returned to L.A. and sold the gold at a substantial loss and sent them the money. But I insisted this time that I wanted a written promise that the Church's "Senior Policy" would be followed ("Always deliver what you promiseM") and that I would not be again refused service without warning. The promise never came, although I was told it had been sent. I began to tell them I was having a change of heart and was considerinq asking for a refund. (To actually ask for a refund would get me excommunicated.) The promise then came in the form of a telex, which I found (based on the Western Union coded data) had a falsified date. I then discovered that the staff was telling people that I had been sent back to Los Angeles because I had failed to get "Ethics 2 Clearance". This was a lie, because I still have the routing form which has my ethics clearance signed off. I then told them I wanted my money back--more to get their attention than to sever my ties with the organization which I still regarded as too valuable to do without. "Chaplain Worldwide" Robert Harvey phoned me to persuade me to withdraw my request for refund. He actually confided to me that the order preventing me from starting my service had indeed not come from the Case Supervisor, but from the registrars to get my additional funds they knew about. I then realized, in view of the fact that this order had been upheld all the way to the top, that I was dealing with a criminal organization. I then formally in writing demanded a refund of all my advanced payments totalling approsimately $17,000. I was given endless runarounds and innumerable people to talk to. I finally began a dialogue with Heber Jentzch, the nominal head of Scientology in the U.S. After much frustration I got him to admit that the actual Church "policy" (as opposed to the publicly stated policy) was to refund money only in the face of a serious legal threat. I accordingly documented to Heber that I was in communication with the staff of the TV program "60 Minutes", at which point the money was returned to me in full. I consider myself lucky. I know people who are still owed comparable sums for undelivered services. These situations must be publicized so people can evaluate whom they are trusting their money with and whom they are trusting to help them. *** AFFIDAVIT *** Tim Swa~son 10321 Meridian Ave~l~e N. #107 Seattle, Washington 98133 October 6, 1989 I was a member of Scientology from November 1985 to January 1987. What kept up my ixlterest during that time was their constant encouragement, assuri~lg me t~at Scientology would wort~ for me; and also, I believe now, because I was revealing so many secrets about myself to them in auditing sessions (this being a mandatory part of the auditing process) I felt a sense of relief, but 8t the same time, grew more and more dense on the subject of Scientology, unable to think critically about it. This is discussed in the book, L. Ron Hubbard: Messiah or Madman? In December 1986 I was accosted by recruiters from the Sea Organization in Los Angeles while I was at tile Seattle Scientology Mission. After being badgered by them for about 4 hours, I finally agreed to join them. I bad outstanding loans, which they offered to pay if I would report within 3 days. I said this meant quitting my job without sufficient notice. They kept drumming me with "The greatest good for the greatest number" By this time, I was already u~lder their control, I now believe. When I got there, I was screened by Security. I had stated in a questionnaire that my brother had worked for the IRS. This is regarded as a suppressire organization by Scientology. I was declared a security risk. For the 2 weeks I was there, I was not paid, other than meals and bedding in a hospital room which I shared with five others. The living quarters were dingy. I left and returned to Seattle. (I should mention that I had told the recruiters I was interested in becoming a computer programmer. I think they wanted me to believe this, although they had other plans for me since it would have been much trouble to train me.) I asked for a refund of my money still on account and unused. I also asked for a refund on books I had purchased after high-pressure sales talks. They said it was not policy to refund merchandise. After I went to a lawyer, they did. They put a stop payment on a check which already had been posted to my account. This was because ~.hey had forgotten to put a waiver on back of the check, stating that cashing of the check settled my claims against them. The check was for over 2000 dollars. Other things I should mention are their practices for collecting money. When I secured a loan, the Scientology registrar went with me to the Credit U~ion so he could have the money in by 2:00 pm. When collecting a personal check from me, they always seemed to come in pairs. When I said was concerned about the costs of their services, they had me bullbaited because I had a sensitive spot about money. I was talked to by the "Ethics Officer" because I was concerned about unfavourable articles I had read about I,. Ran Hubbard upon his death. In summary, Scientology is very clever and slicJ~. They can take many innocent people in. The need for spiritual or psychological comfort overrides their good judgemeat. No one should presume to belittle anyone who falls under their spell. What we need to do is help those who waist to leave, and console those who have been victimized. We need to assure it does not happen to anyone else. ** AFFIDAVIT ** ARLENE S. HELLER 1290 E. Oakland Park Boulevard Ft. Lauderdale, Florida 33334 Our family has been seriously affected by our daughter, Debbie's affiliation with the Church of Scientology in Atlanta, Georgia. She has been a member of the group for over 2 years and we have noticed very definite personality changes and signs of brainwashing during that time, becoming more pronounced recently. She is the eldest of our 4 children and this problem has proven to be a terrible blow to our entire family. I suffered a mental breakdown in September of 1981, attempted suicide and was hospitalized. I have been under the care of a psychiatrist since that time. My husband, Sam, has also been plagued by stomach problems, periods of depression and otheb mental and physical manifestations. Our other 3 children likewise have felt the blow of this upon the family unit. To give you a little of our background, Sam has been an attorney in Ft. Lauderdale, Florida for 22 years. I am a former school teacher and administrator and am currently engaged in real estate investments. Debbie is 23 years old and our other children are 20, 19 and 17. We are of the Jewish faith and have always worked hard to give our children a stable, sound upbringing. We have been active in our Temple and in the community. Debbie graduated from high school with honors and went on to the University of Florida, where she spent 2 years as a pre-med student, earning a 3.9 average. She then decided to go into the Physicians's Assistant program at Emory University in Atlanta. After a very short time there she transferred to Life Chiropractic College (also in Atlanta) and spent just a few quarters there before dropping out of school altogether. 2 She became affiliated with the Church of Scientology while a student at Emory, when she took a study skills course from them and then went on to take a communications course. What started out as a seemingly beneficial program to aid her in her college studies turned out to be a nightmare. As time went on she became more and more involved with the Church and refused to listen to our admonitions against it or read the many newspaper and magazine articles we sent to her concerning its dangers. She then decided to give up her college studies to become a Scientology auditor (counselor). When we realized that Debbie would not or could not listen to us, we contacted a great number of people throughout the country who are knowledgeable in cult activities and brainwashing. We were finally put in touch with an ex-Scientologist who had been a member of the Church for 9 years (along with his wife) and we have been trying to reach our daughter through his guidance. The first thing our counselor did was to provide us with a tremendous amount of factual material concerning the Church and its activities. These are documents that have come out of the Church itself, government documents from the files of the F.B.I. and other agencies (which were used by the federal government in its successful prosecution of 9 top Scientologists), newspaper and magazine articles, etc. All of the information is authentic and accurate. It was his feeling that if Debbie would merely read over these materials with us she would realize that she has been fed a great deal of misinformation and that she has been the object of a very cunning system of mental programming. For many months our daughter refused to share this information with us unless she could have her attorney and 3 the director of her Scientology mission present. We had been in touch with this director, who approved her reading the papers and who promised that he would ask Debbie to do so. We were also in touch with her employer (a Scientologist who runs a laundry ticket business for people in the Church who need money to sustain themselves), with directors of other Scientology missions in our part of the country and with their office in Coral Gables, Florida. All of these people stated that they thought that Debbie should meet with us and go over the information that concerned and frightened us so much. She still refused to do this. We then attempted to contact people in the media and in government, as well as ex-Scientologists and their families, so as to persuade Debbie to consent to shch a meeting and also to educate others to the dangers of this destructive cult. We have written many letters, made numerous phone calls and taken out newspaper ads all over the country. These tactics appeared to have had some success as she informed us in March of 1983 that she would be willing to meet with us in April, when her job schedule would allow her the time to do this. We agreed to go up to Atlanta for this. She had made such promises before and then cancelled her plans at the last minute, so we desperately hoped that this time she would follow through. We proceeded to make very elaborate plans in order to insure that this meeting was absolutely to be a voluntary one and that Debbie knew that she was free to leave at any time she wished. In fact, we asked her to sign a statement at the beginning of our meeting saying that she was with us of her own free will, that she was under no coercion of any kind and that she completely understood the conditions that had been set forth. We arranged for a meeting place that 4 was centrally located. We made plans to tape the entire conversation so that if there were questions from either party as to what had been said they could easily be answered. Reservations were made in a centrally located hotel with an appropriate meeting room and also for airplane transportation for my husband, myself and our counselor (we made it very clear to Debbie that our advisor was to be used strictly as a resource person and counselor). The purpose of the meeting was to share information with her, not to persuade her in any way. The Georgia Bureau of Investigation was informed as to each detail of our plans so that we could call on them in case of any harrassment from the Church. We saw Debbie two times just prior to this planned meeting and each time we went over the ground rules with her and she promised that she would meet with us and that the conditions met with her approval. Sure enough, just one day before were to leave for Atlanta, Debbie showed up at our office in Ft. Lauderdale and cancelled the entire meeting, stating that she was not only unwilling to meet with the three of us, but would not even meet with just my husband and myself. There was no way that we could persuade her otherwise, and we were just heartbroken when she turned her back and walked out on us. She had been lying to us about her job for a number of weeks and said that she had never wanted to meet with us to read the Scientology information in the first place. I still don't understand why she drove all the way down here to tell us this when she could have done it more easily on the telephone and why she ever consented to meet with us at all. In any event, our agreement was broken once again. Our family is trying to save Debbie from a curse that has seriously affected her and all of us, and will continue to do so for the rest of our lives. We hope that in so doing we can prevent other young people from falling into the same trap. We will continue to write letters and make phone calls in an effort to help others and perhaps, in that way, we will be helping Debbie also. We assure her over and over again that we love her and will always be here for her to come home to. ** AFFIDAVIT ** DONNA WHITFIELD 19 Pineway Boulevard Cloyis, New Mexico 88101 February 26, 1986 On or about February 13, 1986, my husband, Jack Whirfield was contacted by telephone at approximately 5:00 p.m. The men contacting my t]usband were identified as A1 Bei and his associate and asked my husband if they could come by and ask him some questions, to which my husband agreed. At approximately 5:15 p.m., Mr. Bei and his associate, which I do not recall his name, showed up at our place of business, located at 1820 East Brady Avenue, Cloyis, New Nexico. I was in nly nearby office doing some work and I overheard some of the questions that these men were asking my husband and I went in and stood by th'e door and listened further. Then, I questioned these gentlemen as to who they were and why they were asking these questions pertaining to my husband's brother, Jerry Whitfield. Mr. Bei at that time pulled out an inventigator's badge and stated that he was an investigator that was working for an attorney in Los Angeles, Calif. Mr. Bei further stated that this information that he requested was not intended to harm anyone, but only to keep people from the expense of having to go to Los Angeles because of being subpoenaed by this lawyer that he and his friend were working for. The questions that these men were asking pertained to Jerry Whirfield, such as his past wives and how long he was married to each one, and where they live now. If Jerry had any children and where they are and how old they are. Where Jerry was born and raised. If he had ever been in any kind of trouble in school or later in life. If Jerry was a likeable guy. What year he graduated from high school. What he did after he finished high school. Where he went to college. What types of jobs that Jerry has held in the past. Just anything' and everything about Jerry personally. I asked these men if they had anything' to do with the Church of Scientology. (I knew that Jerry had belonged to the church and possibly still did belong to the Church of Scientology.) These men stated that they didn't know anything about the Church of Scientology, but they asked if Jerry had been a member of the Church of Scientology. I hereby declare that the above information is true and correct to the best of my knowledge. ** AFFIDAVIT ** BILL LENDRIET 8814 Sylmar Avenue Panorama, California 91402 August 13, 1989 I herewith state my personal experience with the Church of Scientology. I joined the Church in the summer of 1968 at the Phoenix Mission, in Phoenix, Arizona. At that time I started to receive auditing and training and the results, then, were phenomenal and the fees were nominal. I remained in association with the Pboenix Mission until June of 1973, when my wife and I moved to Los Angeles, CA. At that time my wife was on Advance Organization lines while I was on lines with the American St. Hill Org. In Los Angeles, my wife and I received a considerable amount of training and auditing. In 1976 my wife, later myself, went to Tampa, Florida, and Clearwater and received processing. The reason I present tile above is to indicate that I was fully involved with the Church of Scientology for nearly 15 years, and I had spent in excess of $75,000 for services and training. In early 1983 I went to Flag in Clearwater to receive training for which I had paid long in advance, the N.O.T.S. solo course. Instead of receiving the training, there were coercive tactics used to try and make me purchase processing I did not need or want, to the amount of thousands of dollars. I had arrived on a Saturday and I left on Monday morning because they denied me the training I had come for. I resigned from the so-called Church of Scientology in August of 1983. It was no longer the group of people I had known. In the spring of 1983 dozens, no, hundreds of the most able and qualified personnel were summarily "Excommunicated" from the Church. I bring the above to the attention of anyone involved with your case to point out that I was indeed involved and dedicated to the Church during the years from 1968 through 1983. I resigned of my o~n volition after learning first hand that the vaunted Guardian's Office of the Church of Scientology misused its authority and violated the privacy of numerous parishioners. Not mine but various individuals I knew personally. That demeaning act ~as a deliberate act of Betrayal. During the last 3 or 4 years of my involvement I saw that money had become the dominant thrust of the Church. I believe that the TRUE nature of the so-called Church of Scientology should be broadcast to prevent anyone from being lured into that money trap. ** AFFIDAVIT ** YOLANDA HOWELL 9020 S.E. Taylor Street Portland, Oregon 97216 August 30, 1989 Dear Margery, I read of your plight in the Free Spirit. I, too have a Scientology horror story to relate. I, also, would seek some sort of recompense (if it were possible to replace the lost lives, dreams, relationships, income potential, etc.) but have not known where to turn as I was told my "statute of limitations" was up. I was in such a state of shock I couldn't even talk about it for the period of the statute of limitations! In a nutshell, as I believe you need these statements to be brief, I will relate my tale as f611ows: 1. In May of 1973, at 21 years of age, I joined the Church of Scientology, Mission of Salt Lake City, Utah. 2. In November 1973, after unsatisfactory (and very strange) "marriage counseling," I divorced my husband of five years. I had three children, aged 4, 2, and 9 months. We sold our two-year-old house and all of our possessions and my ex took all of the money so he could get "audited." 3. In June of 1974 I was convinced to join the Sea Organization at AOLA, in Los Angeles, where I would be "trained as an auditor in the most ethical organization on earth, receive at least $5 an hour (good ~ages back then!) after I was trained, receive a very nice apartment for myself and my children to live in, and be supplied with clothing and food for myself and my children. My children would attend school in a very upstat nursery." I quit a college accounting program I was on to pursue this situation that seemed designed for a single mother. 4. After one night in a one-room "apartment," my children were taken away from me and put in tlle Cadet Org which, at that time, was a filthy, poorly managed, nursery for Sea Org Members' children. I was escorted to the Excalibur where I received my Product 0 training. I returned two weeks later to find all of my personal belongings had been rifled, things stolen, and I was to sleep on a couch without blankets in a foyer of the staff house. 5. In addition to my own schedule of 22 hours a night (we had "all-hands" every night) it became apparent that my children were not being fed, occasionally, at the Cadet 0rg. I approached the HAS to see about my getting on Welfare to ensure my children got fed, and I was reprimanded. I became so totally exhausted physically and mentally, that I hallucinated (I have never done any hallucinogenic drugs--I smoked marijuana a little in 1972). I felt my mental health suffered greatly during this time. 6. My parents came to visit, saw the conditions, and talked me into leaving the Sea Org, which I did during a rare weekend off that I had been given to prove to my parents how "normal" everything was in the Sea Org. We got to my Uncle's in Nevada and I panicked: I thought that if I blew and got declared "SP" I would die as a being and be unable to care for my children. I told my parents to take my children back to Salt Lake City, and I would return to AOLA and properly route out. I told them I thought this probably took about three days. 7. For several days I attempted to see the MAA or HAS to route out, and was put off. I finally got to see the HAS and, essentially, he put me off and sent me back to post. I thought he was "working" on it. This went on for three weeks. I was in a terrible condition of grief from missing my children, confusion at the things I was exposed to in the organization, and despair at ever being allowed to "properly route out." I was terrified of the MAA (Margaret George). She screamed almost incessantly, calling- people "SP's" ana soon I didn't kno~v how so many good Scientologists could also be considered "SP." I finally got to see her and she yelled at me; she told me I had finally gotten what I wanted. I asked what she meant and she said that I had never wanted my children anyway. 8. Meantime, my ex-husband called (we had been on very good terms when I left for the Sea Org. I have known him since I was 12 years old and he had never deceived me before) and told me that my parents had told him that they had to get back to work and could not watch my children anymore. He offered to watch the children until I got back. (Eleven years later, when I could finally talk about the occurrences, my parents informed me that this was not true: they had hired a permanent baby-sitter for my children during the day while they worked. They said that my ex-husband had called them and said that I had told him he could have the kids! They had repeatedly been unable to 4 contact me by phone, and I was disallowed from private conversations with them except for one time). 9. After six weeks I was taken into "session," caused to rockslam, and told I was being routed out for evil intentions. I flew back to Salt Lake City with a ticket my mother had left at the airport for me. 10. When I returned to Salt Lake City, I immediately called my ex-husband to let him know I was back. He seemed very cool and aloof on the phone. I went to the mission thinking- my ex-husband had the children there, or something. I had no idea anything was amiss. I was physically grabbed and forced by the Ethics Officer, the minute I walked through the door, into an inner office, where the Deputy Executive Director (David West) acted as a "mediator" while my ex-husband threatened me physically with a raised chair to "cave my head in." I was still physically and mentally exhausted, and this next situation threw me into total shock. As I said, my ex-husband and I had been on good terms, and suddenly was threatening to kill me in front of witnesses! I asked him what ~-as wrong and he said that he didn't want me back in town because he was getting married and he was afraid that he still loved me. Attempting to appease him, I congratulated him and reassured him: I had only come to gøet my children. 11. He then informed me that I could not have them back (I had legal custody). I was numb and could barely argue. I couldn't believe this was happening. I was told by Dave West that I have 5 been so third-parried while I was gone that he didn't want any Scientologist talking to me. In fact, he didn't even want me on the same street as Scientologists (SLC is not a very large town, and I lived a short distance from the mission. One day I was spotted drinking an orange soda at Dee's restaurant and I received a vicious call from Dave West telling me not to be on 2nd South--a main street in Salt Lake City!) 12. I pleaded with Dave and my ex to let me at least see my children. Dave West and my ex-husband then told me to come up with $1,500 for auditing and then I could see my kids. (Just this year my youngest daughter told me that'her father once told her that he once had been very much in love with me, but that was before Dave West, his auditor, set him "straight" on me! Apparently the whole incident was designed and guided by Dave West, the Deputy Director! As my ex-husband was being trained to be the registrar, I suppose he saw it as a good way to start his career.) 13. I was instructed not to tell anyone of what they had said, or I would be declared an SP and would not ever get to see my children! 14. To get the money, I badgered family members, causing my once close family to separate from me, and begged in Sugarhouse Park from total strangers for, not a few dollars, but the full amount! Finally, my mother loaned it to me, although she still did not understand what was going on. I was then allowed to see my children, once. I was not allowed back at the mission, however, because, after they had my money, I was told I needed $1,600 more to pay off my Sea Org freeloader debt!!!! I talked about this only in session for years, and never was any ethics action called by an auditor on David West or my ex. The entire topic was never actually directly addressed in session! In spite of the fact that I did every ethics condition assigned to me to try to get my kids back and suffered every demeaning blo~ to my ego they hurled, underwent auditing for 10 years to find out what I did to "pull this in," I was never allowed to get my kids back, or even to talk about it. I later found out from Phil Parks of the Salt Lake Missions that David West had told everyone I had blown the Sea Org (and thus was declared an SP so they weren't to talk to me). Phil Parks, and the others, to this day still believe the slander that ~›as spread by my ex and Dave West. For up to seven years I ran into people I didn't even know in Scientology who had "heard" about me. When I asked them ~hat they had heard, invariably they couldn't remember, but it was "bad," or heard I abandoned my children and was starving them to death and my ex-husband had to go get them from me, etc., etc. Four of these people were Sue Cooper-Kimball Piper, Dee Barber, Gina Godwin, and Annie McGregor. I was so slandered and so affected by the loss of my children that my income-producing potential suffered (it is very hard to explain to non-Scientologists, especially in Utah where a lot of value is placed on the family, that your children do not live with you. I was deeply ashamed of this, but could not tell anyone ~hat had happened. The question about children invariably came up in job interviews and I am certain that both my emotional responses to this area of questioning and my debilitated operational level because of this situation decreased certain chances for advancement. I felt that I had to try to make Scientology look good, no matter ~hat. I had to be an excellent Scientologist, or I never would get my kids back!) The slander was so complete and I was so devastated, that I have never recovered. My son, my baby, is dead now, hit by a car at five years of age while crossing a busy street "protected by postulates." My son never knew I was his mother. He just thought I was some strange lady that came to visit that everybody called "Mom." When I was in high school, I was in the upper 3% in the nation for SAT scores. My IQ has al~ays tested high--122 to 144. I had a lot of potential and willingness. Unfortunately, I also had an equal measure of naivety. Scientology took advantage of my better hature, convinced me I was a totally worthless person, and destroyed my family life. There is more to this story, but, after 15 years I still can hardly stand to recall it, in spite of my being "OT." David West was, as last I knew, the Senior CS for NOTs, AOLA. I wish you the best, Margery Wakefield. ** AFFIDAVIT ** JIM BEEBE P.O. BOX 352 Warrenville, Illinois 60555 August 29, 1989 Dear Margery: I have just read of your plight which has resulted from your most courageous decision to speak out about tile Church of Scientology. As an ex-Scientologist I am writing to offer whatever support I can. I find it utterly appalling that a Federal Court has ordered you not to speak out about Scientology. What this means is that the Church of Scientotogy has effectively bought you off. And they used the Federal Courts to do it. It's absurd that the Church of Scientology still gets away with calling itself a 'Church' I have wondered about other ex-Scientologist that won lawsuits against Scientology. They were never heard from again. I guess that they are under Court Orders not to speak. I find this absolutely horrifying. Those of us who have escaped from the clutches of the vicious and destructive Church of Scientology are duty bound to inform the Public and the Courts of the true nature of this Organization. As you well know, Scientology has millions of our dollars at their disposal and will spend any amount to legally and illegally harass anyone who opposes them. I divorced my first wife and left my family because of Scientology. At that point I was almost completely 2 brain~vashed into the Scientology mindset. They led me and everyone else on with false hopes and promises. I was constantly harassed for money. The constant barrage of propaganda from L. Ron Hubbard via books, course, & tapes, had convinced me that following him was the only hope that we had of escaping from the physical universe. Hubbard, himself, in his courses, actually encouraged lying and deceit. I saw many vicious and destructive things in Scientology. I remember that I was shocked when the 'Fair Game Policy' was isseud by Hubbard. The Fair Game Policy said that anyone who opposed Scientology could be lied to, deceived, ruined or destroyed in any fashion. I saw people who were ordered by th~ Church to Disconnect from husbands, wives, family members and/or friends. This meant that they could never communicate with them again in any way. I saw people who were coerced into selling their homes to get more money for Scientology. Many were forced to cash in Insurance Policies and/or borrow money from relatives. I saw many, many deceptive actions perpetrated by the Church of Scientology. I saw them use lawyers and the Courts to harass and intimidate people. The saddest thing, Margery, is that I met a number of people of good intent in Scientology. We were completely taken in and deceived by L. Ron Hubbard and the higher echelon of Scientology. To this day, many of the lower level Scientologists are not a~are of the deception that they are involved with. Many ex-Scientologists are still afraid to speak out. 3 They know what lengths the Church will go to in order to silence them. In my own case I woke up little by little and realized that I had been duped and brainwashed and I finally managed to break away from the insanity of Scientology. I most sincerely applaud your decision to speak out. Certainly the Federal Gag Order must be unconstitutional. How can it be that you won a Court Decision against the insane and vicious Church of Scientology but you can't speak out about it? We who were involved with Scientology have a tough job informing the Public and the Courts of the true nature of Scientology. How do we tell them that what Scientology is really trying to do is to gain total control over people. They want control of their money, their lives, their businesses, their schools, their communities, and their governments. What you are doing is very, very important. My very best regards. UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS LA VENDA VAN ) SCHAICK, et al ) ) Plaintiffs ) ) CIVIL ACTION v. ) NO. 79-2491-G ) CHURCH OF SCIENTOLOGY OF ) CALIFORNIA, et al, ) ) Defendants ) AFFIDAVIT OF CAROL GARRITY I, Carol Garrity, being first duly sworn, depose and say: 1. I was a member of the Church of Scientology from April 1975 through July 1980 and during that time I became a staff member and worked full time for the Scientology Organization from August 1976 through July 1980. 2. Between November 1978 and July 1980 I was a member of the "Guardian's Office" of the Church of Scientology. The Guardian's Office, more commonly referred to as the "G.O." by Scientologists, is responsible for intelligence gathering, covert operations and activities, spying and public relations. The Guardian's Office administers "front" groups such as schools and drug programs which are designed to make money. I have personal knowledge of the foregoing matters and participated in various "operations" - 1 - conducted by the G.O." 3. The Guardian's Office headquarters in the United States is in California. However, the Guardian's Office has the power to go into a local Scientology Church and literally take over any section of it or the entire local church if necessary. This is covered in a policy letter written by L. Ron Hubbard, entitled "The Guardian" There is another G.O. headquarters at the Flag Land Base in Clearwater, Florida. 4. The Guardian's Office activities are conducted pursuant to various Scientology policies including "Fair Game Doctrine" which states: "Fair Game, may be deprived of property or injured by any means by any Scientologist. May be tricked, sued or lied to or destroyed." 5. I have personal knowledge that the Scientology organization has actively and covertly conducted operations against Attorney Michael Flynn in an attempt to get him disbarred and to destroy him and thereby eliminate him as a representative of those individuals victimized by the Scientology organization. Attorney Flynn was classified as a top "Enemy" of the Church of Scientology and I was sent numerous "orders" to "attack" him in the news media with a "black PR" campaign. - 2 - 6. One such operation occurred between January and July 1980, when the Guardian's Office conducted a series of covert operations to infiltrate the law office of Michael J. Flynn by placing a "plant" whose code name was "Oscar" and whose real name was William Broderick. I am aware that other "operations" were proceeding against Attorney Flynn to get someone "inside" his office. 7. Prior to July 18, 1980, as an Assistant Guardian, I had numerous conversations with Attorney Steven Burris in Las Vegas, NV, who represents the Church of Scientology there. Conversations related to the intent of the Church to find some basis to bring law suits against Michael Flynn and those in his office and also law suits against LaVenda Van Schaick, Ernest and Dell Hartwell and Eddie Walters. These lawsuits were to be brought against these people pursuant to the policy of the Church of Scientology which states that lawsuits are to be used to harass and attack people who seek to expose Scientology. 8. In one of my conversations with Attorney Burris in July 1980, he asked me to sign an affidavit in connection with a proposed suit against Van Schaick, the Hartwells and Kevin Flynn. I told him that I could not verify the information in the affidavit. Attorney Burris told me that he was aware of the covert agent used by the Church of Scientology. Attorney Burris asked me if I was "compelled to tell the truth" in the affidavit. I told Attorney - 3 - Burris that I had always told the truth and he said that he would get someone else for the affidavit. 9. The Guardian's Office devised a covert operation to stop Attorney Flynn's client, LaVenda Van Schaick, from speaking out against the Scientology organization. The program was code named "Shake and Bake" and pursuant to the program, G.O. agents, including Gary Klinger, were sent to Massachusetts to interrogate Ms. Van Schaick and to use various means to have her divorce her husband and fire Attorney Flynn, including the use of her auditing information. 10. The Guardian's Office perused Ms. Van Schaick's auditing files, which contained the most personal and intimate details of her life, and extracted confidential disclosures for the purpose of using it against her in "Operation Shake and Bake". 11. The practice of reviewing confidential auditing files and extracting private and intimate details of an individual's life is a common Scientology practice. The data gleaned from an unsuspecting individual's file is commonly transmitted to "Flag" in Clearwater, Florida and to the California headquarters for extortion and blackmail. This practice occurs regularly. I have personal knowledge of auditing information being sent to Clearwater and California for this purpose. - 4 - 12. On one specific occasion, I received a Guardian's Office order concerning Tonja Burden's auditing information. I was sent from the Guardian Office's main headquarters in Los Angeles, a document from Tonja's preclear folder called a "Wants Handled" list. This was a list of things that Tonja wished to improve herself with through auditing. I was also sent a list of "overts" and "withholds" which means transgressions against L. Ron Hubbard, Scientology, etc. The purpose of a person writing their "wrongs" is the general concept of confession. This list is only to be used to help the person face their errors, wrongs, etc. and thereby free the person by having "confessed". These lists are to be held in strict confidence. I was sent a huge stack of Tonja's "overts and withholds" write-ups to take to the Review Journal newspaper, along with the auditing list from her preclear folder. The purpose of the above orders were to disgrace, embarrass, humiliate Tonja and make her lose her credibility with the public and the press, as she had filed a lawsuit against Hubbard and Scientology and according to Scientology policy, anyone who does this is an evil person called a "suppressive person" and must be dealt with accordingly. I carried out my orders, however, her auditing information was not printed in the papers, as the news media thought it was a disgusting breach of privacy, which it was. 13. When I was first introduced to "auditing" or counselling in the Church of Scientology, I was told that the information or "confessions" I gave to my auditor would be held in strict - 5 - confidence and that the only persons who had access to my auditing files were the auditor and the "case supervisor" - the person in Scientology who "programmed" the cases and decided what auditing the person should have and buy. This representation is made to anyone who undertakes "auditing" and it is shown to them in writing in the "Auditor's Code". 14. After I joined staff at the Las Vegas Organization, I had many occasions to witness that many other people within Scientology had access to the auditing files. These people could go to the technical division and take the folders and read them and study them and send information from the folders to other Scientology executives if they were ordered to, or chose to do so. This included information being sent to the Church of Scientology of California in Clearwater, which was regularly done. It was a regular practice in the Church of Scientology that the Guardian's Office had access to any person's auditing folders at any time the G.O. chose to take them. 15. The Guardian's Offices throughout the United States including Clearwater, Florida are run by the United States Guardian's Office which is part of the Church of Scientology of California. The top executives and management are at the Church of Scientology of California, both in Clearwater, Florida and Los Angeles, California. - 6 - 16. The routine use and circulation of auditing information is done throughout the United States and outer "missions" send information from a person's auditing folders to the nearest "Class 40rg" for ethics use or intelligence use in the Guardian Office intelligence files. 17. When "missionaires" from the Church of Scientology of California would come to Nevada, we were under instructions to give them full back-up and cooperation and this included revealing to them personal information about Scientologists and their auditing folders and intelligence folders, if needed and requested. 18. During executive meetings at the Church of Scientology, on many occasions the executives would sit and discuss information about staff members and public-paying person's auditing information. 19. While on staff in the organization, I was in charge of the division that sold all the auditing and training and books and I was routinely given information from people's auditing folders so that I could get them to buy more and more auditing. This was a standard practice and this information would also be given to "indicate" to the potential buyer what auditing they should buy next, to "cure" whatever "insanity" it was they were trying to get help with. - 7 - 20. All of the above actions uniformly betray the trust that a person gives to Scientology and their auditor when getting auditing, and this creates a terrible fear about the possibility of leaving Scientology and having your innermost thoughts, feelings, desires, actions about yourself and others revealed to anyone including your parents, spouse, relatives and the news media. 21. When I thought of leaving Scientology after I realized I had been tricked and lied to, these actions had me terribly fearful that this type of blackmail would be inflicted on me. 22. I left the Church of Scientology on July 18, 1980 after being a staff member for approximately four years. I had become upset and in fear when I learned that the top leaders of Scientology had been convicted of felonies in late 1979 and I did not agree with their conduct of breaking and entering, harassing enemies of the Church, spying on ex-members and other enemies of the Church and trying to infiltrate enemies and all the other unlawful and underhanded conduct conducted by the Church. 23. I had also been told that the alleged crimes top Church leaders had committed were false and that the people were innocent and being framed and suffering from "religious persecution". It was uniformly stated to all Church members that the Church never broke the law and didn't harass critics or enemies. - 8 - 24. I hired an attorney in Las Vegas, Nevada to represent me and my husband when we left Scientology so that we would have in writing and on record the exact date we left and also to demand the unused monies on account at the various organizations. My attorney had a letter hand-delivered to the Church of Scientology of Nevada on July 21, 1981 advising them of our intentions and that any attempt to contact us would result in a restraining order as we wanted no contact from any of them. 25. On day later, Maddie Reese, a top Guardian's Office staff member from Los Angeles called Jane Peterson's house, another former G.O. member, asking for me. Jane advised her that I was not taking any calls from any of them and not to call back. 26. I began to receive telephone calls at all hours of the day and night with people either being silent or hanging up. 27. My husband and I then received a new unlisted telephone number and shortly thereafter, the calls began again. Sometimes whoever was calling would ask for a person unknown to me and I would advise them of that and they would call back over and over and ask for the person. 28. My husband and I moved to a house on February 1, 1981 and received a listed number and the calls continued. - 9 - 29. In mid-March, 1981 I went home to discover my home had been entered, every door in the house opened and my dog had been put outside in the backyard. The sliding glass screen door had been pulled off and was laying across the porch. The police came and could not find a forced entry and a report was not filed. 30. My husband and I filed a complaint against the Church of Scientology, L. Ron Hubbard and Mary Sue Hubbard in Federal Court in Los Angeles on July 1, 1981. 31. I arrived home after work on my wedding anniversary, July 21, 1981, to find that my home had been broken into and my husband's sports bike had been stolen. Said bike was valued of approximately $2,000.00. The fingerprint people could find no prints other than one partial footprint in the backyard and that an oily substance had been sprayed on the windows, sliding glass door and door knobs to apparently cover prints. A few days later we discovered my husband's stereo turntable missing and again found the oily substance. 32. I began receiving phone calls from a girl asking "are your parents there"? I would say she had the wrong number but she would continue to call back. This was very upsetting as I have never recovered from my parents' deaths and this was one of the main things Scientology was supposed to help me with in my auditing (counselling). - 10 - Later the same girl started calling and asking for my dad. Finding my father dead and the related circumstances of his illness and his death has always been very hard for me to accept and I revealed this whole situation over and over in my auditing in Scientology. 33. To this day I still receive calls where the person either remains silent or hangs up when I answer. These seem to occur shortly after I arrive home from work, even after I work overtime. 34. On July 28, 1981, exactly one week after the July 21, 1981 break-in, I went home to find my home had been broken into again. This time it was totally ransacked, drawers dumped, closets gone through and basically a total mess. This time the back bedroom window had been broken out. We could find nothing stolen on this occasion. The same officer who had arrived the other two times came again this time and filed a police report. 35. On September 29, 1981, again I went home to find that my home had been broken into. The side door screen had been ripped out and the window opened and this was the point of entry. This time all my jewelry, wedding rings, keepsakes from my mother and father, my father's keepsakes from the war and college were all stolen. My husband's camera equipment was stolen along with some money and other things. The house had been totally and completely ransacked, every drawer, box, closet in the house dumped on the - 11 - floor. The back rooms were also ransacked and everything dumped. My briefcase with all of my Scientology papers and correspondence from my attorneys, lawsuit information had been gone through. The fingerprint people found no prints, however, did take pictures of the rooms and the briefcase. I have talked to my neighbors and this is not happening to them. The police have no leads and none of the stolen goods have shown up around town that they know of. The police do not know of another house on our block that has been broken and entered this many times in this short a time period. The previous owner of the house resided there for approximately twelve (12) years with only one minor occurrence. My husband and I have lost money due to insufficient insurance coverage on the jewelry which we were not aware of and we have had to invest in solid doors, bolt locks and other locks and have ordered iron bars for every window in the house. The last three break-ins have all occurred on a Tuesday, starting with our wedding anniversary. 36. Nothing like this ever happened to me before I left Scientology in July 1980. 37. The psychological damage done to me while in Scientology combined with the above harassment, break-ins, and strange occurrences have caused great mental stress and upset. 38. My friend, Jane Peterson, who was also a Guardian Office staff member and left Scientology, has received numerous death - 12 - threats, both oral and written, since she left Scientology and this is very upsetting and frightening to me also. 39. I am aware that many similar operations were conducted against Tonja Burden while I was working for the G.O. I am aware that a G.O. agent, Bill Broderick was placed in a position to spy on Tonja Burden and that the G.O. acquired an apartment in Tonja Burden's apartment building to spy on her and harass her. This is common practice of the G.O. against its enemies. Signed under the pains and penalties of perjury this 21st day of May, 1982. Carol Garrity SUBSCRIBED AND SWORN TO BEFORE ME THIS 21ST DAY OF MAY, 1982. (CARRIE B. STEWART) NOTARY PUBLIC - 13 - ** AFFIDAVIT ** January 9, 1990 I, Margery Wakefield, do hereby state that the settlement agreement that I signed with the "Church" of Scientology in the summer of 1986 was signed under duress, without proper representation, with misrepresentation, and was signed during a time that I was not competent to understand or negotiate such an agreement. 1. It was signed under duress in that I was told by my attorney at the time that I had to sign it, that I had three days to sign it and return it to him by mail, that the lawyers were not going to take my case to court, that no other lawyer would take my case, and that unless I signed the agreement I would "never get a penny". I was also under pressure from my family, particularly my father, to sign the agreement. I owed him $20,000 and, knowing that he was terminally ill, there was pressure for me to repay him the money before he died. 2. It was signed without proper representation in that the agreement was sent to me in Upper Michigan where I had gone (to my parent's cottage) to recover from a recent psychiatric hospitalization. I was not present at the settlement hearing. The settlement agreement was not gone over with me by a lawyer before I had to sign it. I did not understand the legal language in the agreement. To this day, I still do not understand the language in this agreement. 3- It was signed with misrepresentation because I was told by my lawyer at the time that even if there was a gag order, I could continue to speak or write anything I wanted to because the Scientologists would never prosecute me because they would not want the publicity. I was told, before the agreement had even been drafted, that even if there was a gag order in the agreement, I could ignore it. 4. I was not competent to sign the agreement in 1986 because of the severity of the psychological difficulties that I was having at the time. I had been discharged from a psychiatric hospital in June of 1986, and had gone north to my parents' cottage to recuperate. While I was at ~y parents', I was experiencing psychological distress to the extent that at one point I had to be taken to the emergency room at the local hospital - a thirty mile drive, to be treated for psychological decompensation (a symptom of my psychosis). In my opinion, I was psychotic at the time this agreement was signed. I do suffer from borderline schizophrenia, which has been confirmed in the court record by Dr. Eugene Dagon, and during the summer of 1986, I was suffering from an acute episode of this illness. Our family doctor, Dr. Joseph Baron, treated me in the emergency room and once in his office, and is sending a statement based on his records of these events. Signed: Margery Wakefield (EXHIBIT 3) UNITED STATES DIbTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS LA VENDA VAN SCHAICK, et al ) ) ~aintiffs ) CIVIL ACTION v. ) NO. 79-2491-G CHURCH OF SCIENTOLOGY OF ) CALIFORNIA, et al, ) Defendants ) AFFIDAVIT OF CAROL GARRITY I, Carol Garrity, being first duly sworn, depose and say-: l'r---1--was a ~,,~,,~,,,~. 42 ~he Ch..rch cr from April 1975 through July 1980 and during that time I became a staff member and worked full time for the Scientology Organization from August ~976 through'July 1980. 2. Between November 1978 and July 1980 I was a ,,,~,,b=r of ~- "GuardieD'.~ Office" of the Church of Scientology. The Guardian's Office, more commonly referred to as the "G.O." by Scientologists, is responsible for intelligence gathering, covert operations and activities, spying and public relations. The Guardian's Office adminsters ~front" groups such as schools and drug programs which are designed to make money. I have personal knowledge o'f the foregoing matters and participated in various "operations" conducted by the "G.O." 3. .The Gua~dian's Office headquarters in the United States is in Californiaú However, the Guardian's Office has the power to go into a local Scientology Church and literally take over any section of it or the entire local church if necessary. This is covered in a policy 'letter w_ritten by T_-=-Rn_n F,_~b_Kara-~ ent~tl_e_a "-~he_guarH~an"~ There is another G.O. headquarters at the Flag Land Base in Clearwater, Florida. 4. The Guardian's Office activities are conducted pursuant to various Scientology policies including "Fair Game Doctrine" which states: "Fair Game, may be deprived of property or injured by any means by any Scientologist. May be tricked, sued or lied to or destroyed." 5. I have personal knowledge that the Scientology -2- organization has actively and covertly conducted operations against Attorney Michael Flynn in an attempt to get him disbarred and to destroy him and thereby eliminate him as a representative of those individuals victimized by the Scientology organization. Attorney Fly~n was classified as a top "Enemy" of the Church of Scientology and I was sent numerous "orders" to "attack" him in the news media with a "black PR" campaign. 6. One such'operation occurred between January and July 1980, when the Guardian's Office conducted a series of covert operations to infiltrate the law office of Michael J. Flynn by placing a "plant" whose code name was "Oscar" and whose real name was William Brode'rick. I am aware nhaZ orlr~'~el"~t rr~ere proceedi~a~ ~ih~ A~torney Flynn to get someone "inside" his office. 7. Prior to July 18, 1980, as an Assistant Guardian, I had numerous conversations with Attorney Steven Burris in Las Vegas, NV, who represents the Church of Scientology there. Conversations related to the intent of the Church to find some basis to bring law suits against Michael Flynn and those in his office and also law suits against LaVenda Van Schaick, Ernest and Dell Hartwell and Eddie Walters. These lawsuits were to be brought against these people pursuant to the policy of the Church of Scientology which states that lawsuits are to be used to.harass and attack -3- people who seek to expose Scientology. 8. In one of my conversations with Attorney Burris in July 1980, he asked me to sign an affidavit in connection with a proposed suit against Van Schaick, the Hartwells and Kevin Flynn. I told him that I could not verify the information in the affidavit. Attorney Burris told me that he was aware of the covert agent used by the Church of Scientology. Attorney Burris asked me if I was "compelled to tell the truth" in the affidavit. I told Attorney Burris that I had always told the truth and he said that he would get someone else for the affidavit. 9. The Guardian' s 'O~fi6e"d~is~'~' c6vert'operation to stop Attorney Flynn's client, LaVenda Van Schaick, from speaking out against the Scientology organization. The program was code named "Shake and Bake" and pursuant to the program, G.O. agents, including Gary Klinger, were sent to Massachusetts to interrogate Ms. Van Schaick and to ú use various means to have her divorce her husband and fire Attorney Flynn, including the use of her auditing information. 10. The Guardian's Office perused Ms. Van Schaick's -4- auditing files, which contained the most personal and intimate details of her life, and extracted confidential disclosures for the purpose of using it against her in "Operation ' Shake and Bake". 11. The practice of reviewing confidential auditing files and extracting private and intimate details of an individual's life is a common Scientology practice. The date gleaned from an unsuspecting individual's file is commonly transmitted to "Plag" in Clearwater, Florida and to the California headquarters for extortion and blackmail. This practice occurs regularly. I have personal knowledge of auditing infomration being sent ,to Clearwater and California for this purpose. -.- 12. On one specific occasion, I rece'?~d a ~uardian~'s Office order concerning Tonja Burden's auditing information. I was sent from the Guardian Office's main headquarters in Los Angeles, a document from Tonja's preclear folder called a "Wants Handled" list. This was a list of things that Tonja wished to improve herself with through auditing. I was also sent a list of "overts" and "withholds" which means transgressions against L. Ron Hubbard, Scientology, etc. The purpose of a person writing their',~"wrongs" is the general concept of confession. This list is only to be used to help the person face their errors, wrongs, etc. and ~hereby free the person by having "confessed" These lists are to be held in strict confidence. I was sen~ a huge stack of Tonja's "overts and withholds" writeups to take to the Review Journal newspaper, along with the auditing list from her preclear folder. The purpose of the above orders were to disgrace, embarrass, humilitate Tonja and make her 'lose her credibility with the public and the press, as she had filed a lawsuit against Hubbard and Scientology and according to Scientology policy, anyone who does this an evil person called a "~uppressive person" and must be dealt with accordingly. I carried out my orders, however, her auditing information was not printed in the papers, as the news media thought it was a disgusting breach of privacy which it was. 13. '~nen I was ~irst introduced to "auditing" or counselling in the Church of Scientology, I was told that the information or "confessions" I gave to my auditor would be held in strict confidence and that the only persons who had access to .my auditing files were the auditor and the "case supervisoz4__~t~e]9ersorr-f-n--Scien~olo~_y wh~-~a-c~a-ammed-' ti,~ cases and decide~ what auditing the person should have and buy. This representation is made to anyone who undertakes "auditing" and it is shown to them in writing in the "auditor's code". 14. After I joined staff at the Las Vegas Organization, I had many occasions to witness that many other people within Scientology had access to the auditing files. These people could go to the technical division and take the folders and read them and study them and send information from the folders to other Scientology executives if they were ordered to, or chose to do so. This included information being sent to the Church of Scientology of California in Clearwater, which was regularly done. It was a regular - 6 - practice in the Church of Scientology that the Guardian's Office had access to any person's auditing folders at any time the G.O. chose to take them. 15. The Guardian's Offices throughout'the United States including Clearwater, Florida are run b~ the United States Guardian's Office which is part of the Church of Scientolog~ of California. The top executives and management are at the Church of Scientology o~ California, both in Clearwater, Florida and Lds Angeles, California. 16-~ T~-routi~e-use--ane-circulation-of--auditing ........ infomation is done throughout the United States a~d outer "missions" send information from a person's auditing folders to the nearest "Class 40rg" for ethics us~ intelligence use in the Guardian Office intelligence Eiles. 17. When "missionnaires" from the Church of Scientology of California would come to Nevada, we were under instructions to give them full back-up and cooperation and this included revealing to them personal information about Scientologists and their auditing folders and intel- -7- ~ ligence'folders, if needed and requested. 18. During executive meetins at the ChurCh of Scientology, on many occasions the executives would sit and discuss information about staff members and publicpaying person's auditing information. 19. While on staff in the organization, I was in charge of the division that sold all the auditing and training and books and I was routinely given information from people's auditing folders so that I could get them to buy mo~e and' more ~uditin~.'~'This was'a'Jstandard-'Practice and this information would also be given to "indicate" to the potea~-iat-buyer-what-aud~t~ing--th~y--should buy next, .to ""cure" whatever "insanity" it was they were trying to get h~Ip with. 20. All of the above actions uniformly betray the trust that a person gives to Scientology and their auditor when getting auditing, and this creates a terrible fear about the possiblity of leaving Scientology and having your innermost throughts, feelings, desires, actions about yourself and others revealed to anyone including your parents, spouse, relatives and the news media. -8- 21. When I thought of leaving Scientology after I realized I had been tricked and lied to, these actions had me terribly fearful that this type of blackmail would be inflicted on me. 22. I left the Church of Scientology on July 18, 1980 after being a staff member for approximately four years. I had become upset and in fear when I learned that the top leaders of Scientology had been convicted of felonies in late 1979 and I did not agree with their conduct of breaking and entering, harassing enemies of the Church, spying on ex-members and other enemies of the ChurCh and trying to infiltrate enemies and all the other unlawful and underhanded conduct conducted by the Church. 23. I had also been told that the alleged crimes top Church leaders had c~,.~Htted were false and that the people were innocent and being f~amed and suffering from "religious persecution". It was unformly stated to all Church members that the Church never broke the law and didn't harass critics or enemies. ~. 24. I hired an attorney in Las Vagas, Nevada to represent me and my husband when we left Scientology so that we would have in writing and on record the exact date we left and also to demand the unused monies on account a~ the various organizations. My attorney had a letter handdelivered to the Church of Scientology of Nevada on July 21, 1981 advising them of our intentions and that any att~a~pt to contact us would result in a restraining order as we wanted no contact from any of them. 25. One day later, Maddie Reese, a top Guardian"s Office staff member from Los Angeles called Jane Peterson's house, another former G.O. member, asking for me. JEne advised her that I was not taking any calls from 'any of them and not to call back. 26. I began to receive telephone calls at a~l hours of the day and night wi~h people eith'er being silent or hanging up. 27. My husband and I then' received a new unlisted telephone number and shortly thereafter, the calls began again. Sometimes whoever was calling would ask for a per-' son unknown to me and I would advise them of that and they would call back over and over and ask for the person. -10- 28. My husband and I moved to a house on February 1, 1981 and received a listed number and the calls continued. ' 29. In mid-March, 1981 I went home to discover my home had been entered, every door in the house opened and my dog had been put outside in the backyard. The sl'iding.glass 'screen door had been pulled off and was laying across the porch. The police came and could not find a forced entry and a report was not fil~. 30. My husband and I filed a complaint against the Church of Scientol_ogy, L. Ron Hubb_a_rd and Mary Sue Hubbard in federal court in Los Angeles on July 1,'1981. 31. I arrived home after work on my wedding anniversary, July 21, 1981, to find that my home had been broken into and my husband's sports bike had been stolen. Said bike was valued at approximately $2,000.00. The fingerprint people could find no prints other.than one partial footprint in the backyard and that an oily sUSstance had been sprayed on the windows, sliding glass door and door knobs to apprently cover prints. A few days later we discovered my husband's stereo turntable missing and again -11- found the oily substance. 32. I began receiving phone calls f~om a girl asking "are your parents there"? I would say she had the wrong number but she would continue to call back. This was very upsetting as I have never recovered from my parents' deaths and this was one of the main things Scientology was supposed to help me with in my auditing (counseling). Later the same girl started calling and asking for my dad. Finding my father dead'and the related circumstances of his illness and his death has always been very hard for me to accept and I ~vealed this whole situation over and over in my auditing in Scientology. 33. To this day I still receive calls where the person either remains silent' or hangs up when I answer. These seem to occur shortly after I arrive home from work, even after I work overtime. 34. On July 28, 1981, exactly one week after the July 21, 1981 breakin, I went home to find my home had been been broken into again. This time it was totally ransacked, -12- drawers dumped, closets gone through and basically a total mess. This time the back bedroom window had been broken out. We could find nothing stolen on this occasion. The same officer who had arrived the other two times came again this time and filed a police report. 35. On September 29, 1981, again I went home to find that my home had been broken into. The side door screen had been ripped out and the window opened and this was the point of entry. This time all my jewelry, wedding rings, keepsakes from my mother and father, my father's keepsakes from the war and college were all stolen. My husband's camera equipment was stolen along with some money and other things. The house had been totally.and-completely ran.sacked, every drawer, box, closet in the house dumped on the floor. Tha back rooms were also ransacked and everything dumped. My briefcase with all of my Scientology papers and correspondence from my attorneys, lawsuit information had been gone through. The fingerprint people found no prints, however, did take pictures of the rooms and the briefcase. I have talked to my neighbors and this is not happening to them. The police have no leads and none of the stolen goods have shown up around town that they know of. The police do not know of another house on our block that has been broken and -13- entered this many times in ~this.shortøa time period. The previous owner of the house resided there for approximately :'twelve-.(12~ years-with only one minor occurence. My husband and I have lost money due to insufficient insurance coverage on the jewelry which we were not aware of and we have had to invest in solid doors, bolt locks and other locks and have ordered iron bars for every window in the house. The last three breakins have all occurred on a Tuesday, starting with our wedding anniversary. 36. Nothing like this ever happened to me before I left Scientology in July 1980. 37 The pFycholo cal ~ ..... done Scientology combined with the above harassment, breakins, and strange occurences have caused great mental stress and upset. 38. My friend, Jane Peterson, who was also a Guardian Office staff member and left Scientology, has received numerous death threats, both oral and written, since she left Scient01ogy and-this is very upsetting and frightening to me also. -14- 37. I am aware that many similar operations were conducted against Tonja Burden while I was working for the G.O. I am aware that a G.O. agent, Bill Broderick was placed in a position to spy on Tonja Burden and that the G.O. acquired an apartment in Tonja Burden's apartment building to spy on her and harass her. This is common practice of the G.O. against its enemies. Signed under the pains and penalties of perjury this (-~./.~' day of ~/;(~ ~/ , 1982. SUBSCRIBED AND SWORN TO BEFORE ME NOTARY PUBLIC ' ,~~~.i~' t-lct:~/P',bH:-~t3te of Nevada CLAF;K COUNTY ' ~.'-'~;" Car:i: D. Stewart "~ "~ My Appoint,'ner. t b. pires klay 23. 1985 -15- ** AFFIDAVIT ** GREG MARLOWE 2361~ E Orange Grove Boulevard 2 ú Pasadena, California 91104 September 12, 1989 I, Greg Marlowe, was a member of the Pasadena organization of the Church of Scientology from 9/75 - 2/78, and will attest that said group is a destructive group which caused me great mental anguish, disrupted my family life, interrupted my education, and caused me great monetary loss. I am pleased that Ms. Wakefield is speaking publicly concerning this dangerous, mind-bending, unethical group. I paid approximately $8000 in fees to this group under the pretense that scientology ~ould increase my IQ, memory, and creativity, rid me of all anxieties, cure me of headaches, increase my communication level, etc. These goals were never achieved. I initially joined the group with the idea that I would be learning communication skills. The drills I underwent are, I believe, really designed to subvert a person's decision making process by instilling a light hypnotic trance, and reducing a person's ability to make critical judgments concerning scientology. I was not taught any conmlunication skills in this course, but instead was indoctrinated with the tenets of this group while doing hundreds of hours of repetitive, mind-bending drills. The group operates within a coercive environment, to say the very least. Being- young (21) and spiritually seeking, I was attracted by this seemingly innocent group and their heady promises. It ~›as demanded that a great deal of my spare time be spent studying the group's tenets, or receiving counseling, and I was eventually spending about 35 hours a week with them once I became fully indoctrinated. I was harangued and admonished if I appeared even a few moments late, and was often given menial chores to do as punishment. A supervisor literally screamed at me over the 2 phone when I informed her I would not be coming in once because of illness. We were told repeatedly that we would die a terrible death if we ever left the group. I was told repeatedly that I must handle or disconnect from my father because he was critical of the group. My association with scientolo9y caused untold strain in my relationship with my family. I eventually decided to leave because my life was so unhappy within this group. I had given up college to pursue scientology, but discovered nothing but broken promises and false dreams. I was told that I had committed cr~mes against the group, and in order to leave, was required to undergo a security check, or interrogation. I was asked, while attached to a lie-detector type device (E-meter) a barrage of very bizarre questions, such as "Had I ever had an unkind thought about the founder?", "Was I working for the FBI?", "Was I involved in incest?", and many other questions, just as strange. Material from this interrogation ~as then used as leverage to attempt to make me stay with the group. I have documentation that this is done on a regular basis. I was next given a court of ethics, and berated before this group by people who I thought were my friends. I was told by one Bruce Dodds that I would be beaten up if I left without their permission. I was required to do 25 hours of menial labor before I would be free to leave. I stayed with this group so long because of the great investment of time and money. I found it hard to believe that I was being conned. There is also a tremendous amount of peer pressure. Everyone is expected to give testimonials telling ho~ the technics of the group are helpful, and actually, some of them are. But they are not worth the price extracted. Almost every aspect of the env'ironment is controlled by this group. For example, questioning of their technics is not allowed. We were constantly told that something was wrong with us if we questioned or doubted. The group and founder definitely seem to believe that they are above the law. I have documentation that proves their involvement in numerous criminal activities including fraud, extortion, money-laundering, and racketeering. I hope and pray that Ms. Wakefield Will be allowed to continue speaking out about this destructive and criminal group. ** AFFIDAVIT ** TRUMAN BOLINGER McCormick Ranch 8600 East San Felipe Drive Scottsdale, Arizona 85258 September 17, 1989 Dear Ms. Wakefield: I read with great interest a story in "The Free Spirit" about your attempt to speak out against the Church of Scientology. I would like to compliment you on your efforts to stand up for your First Amendment Rights and speak out publicly against the very destructive "Church of Scientology". I joined the Ctlurch of Scientology in the fall of 1978 and was a member until sometime in the fall of 1984 at which time, I was expelled and declared a suppressire person. Up until that time, I had gone "clear", did L10, Lll and L12 and achieved OT III along with taking several courses. My problems started after I had completed a course called, "Keeping Scientology Working", and was on another study course called "The Professional TR Course" at the Phoenix Org. I discovered that my twin did not understand how to "Handle Organizations" but to my horror, I found out that the course supervisors, auditors and the C.S. at the Phoenix Org. also did not understand how to "Handle Organizations". I then ~ent to Flag at Clearwater, Florida, to get myself through the course and per what I had learned on the course of "Keeping Scientology Working" to get this hugh MU matter straightened out. To my unbelievable horror, I discovered the same MU with Class VIII auditors and the course supervisor and senior course supervisors at Flag. It is difficult to put down on paper the harassment, mental anguish, unnecessary sec checks and frustration that I had to face at the Phoenix Org. and at Flag. The mecca of flubbest perfection. While in Scientology, there are many techniques and data which have the potential to assist an individual to become more independent and self determined, but the dangerous side of the "Church of Scientology" is that it can make the individual permanently dependent on the church. It probably is very difficult for an individual who has not had the experience of belongin~ to such an organization as the likes of "The Church of Scientology" to really understand the dark side and anguish that such a group can perpetuate on its own members. It was very hard for me to grasp that fellow members and good friends could not perceive the reality of the outness and wrong doings of what was right there in front of them. This horrible phenomenon of blindness was happening so commonly with course supervisors, auditors, C.S. at the Phoenix Org. and so broadly at Flag with their course supervisors, Class VIII auditors and Senior C.S., that it was very terrifying for me to stand up against this authority. It might be said that a "Good Scientologist" has little or no mind of his/her own. That he/she can reason with for he has abandoned his own ideas and information for just the data that "The Church of Scientology" has written. A "Good Scientologist does not question church authority". To a "Scientologist" anyone declared an S.P. is immediately and unquestionably considered insane. To witness good friends suddenly turn their backs on you and 3 refuse any communication from you is ~lmost unbelievable to witness and experience. I found it very difficult even several years after my destructive experiences with the church of Scientology to write about the mental anguish that w~s brought upon me. While I was a member of the church, I handed out at least 1000 booklets called "The Road to Happiness", a book on common sense and moral codes. I recently went down to the Phoenix Org. to buy some of these booklets and they refused to sell any to me and I was asked to leave because they didn't want to speak with me. It is my understanding that the FirSt Amendment gives us all the right to free speech and I can not believe that any agreement knowingly or unknowingly signed by anyone could supersede his First Amendment Rights. I think the exposure of the dangerous organization known as "The Church of Scientology" is well worth anyone's time and efforts. Therefore, I congratulate you on your stand. AFFIDAVIT ** BOB PENNY 6962 Miro Court Longmont, Colorado 80501 September 12, 1989 I WaS asked for a brief statement describing my experience with the Church of Scientology, as a former member. I come from a background of undergraduate and graduate study in anthropology and sociology, 1961-1970, at Brandeis University, Wast~ington University in St. Louis, and the University of California at Davis. By 1970 I had found fixing cars more rewarding than the life of professional academics, and spent roughly a decade doing that. In the early 1980's I began writing computer soft~~are and, together with my wife, started a company to market and continue developing the product I had created. That company is still my work. In 1973 I encountered the Church of ScientologyCurious and otherwise at loose ends (marital breakup, changes of residence and occupation, becoming single parent to my oldest son), I spent eleven months in L.A. studying that subject. While returning to Colorado from that trip I met the woman ~;ho was to become my second wife. She learned of Scientology from me, and got into it on her o~n before coming to Colorado to join me. She "went native" in that group, and ~anted its viewpoints to be the conceptual and normafire basis of our life ~o~ether. I had left L.A. with reservations, after such experiences as observing unattended babies crawling on urine-soaked carpets (at a place called the "Cadet 0rg"), and hearing recruiters clearly advocate breaking promises to friends, families, and employers ("we can handle that"). Most unsettling of all, however, was my observation that bein~ a Scientologist seemed to include becoming a master of facile justifications of such things. The "group think" could justify anything. But I rationalized that only shared conceptual framework could serve, at least as a starting point for communication between two people committed to each other; that the "bad parts" would get sorted out. I did not understand fanaticism or the obeyance of thought it can produce. I was deeply committed to my wife, and to the marriage, so I set out in good faith to make my own best use of Scientology's conceptual framework. I failed to appreciate, until too late, the extent to which that ~roup demands total conm~ittment to itself and conformity across all areas of life and 'thought. There is no "backstage", no home to go home to (ref. Charles Schultz's "Peanuts" cartoon: "home is where you'd rather be when you don't know the answers"). For me, that was a lonely and frustrating time of intellectual and social isolation, during ~hich pursuit of alternatives per se violated norms of a group which had become inseparably connected with the marriage. Obviously something was wron~ but there was no avenue to communicate, explore or handle it; any viewpoint other than Church dogma was unacceptable. That one available avenue (which I kept trying to make work) led nowhereo I became more and more weird, negative, uncommunicative, unpleasant, unhappy, undesirable. I stayed very busy writing software, which fortunately is a successful and rewarding activity for me. I stayed in Scientology through 1986 with irregular participation. I became a "Class IV Auditor and Case Supervisor" and did volunteer work for most of a year as a Case Supervisor. I was never officially a staff member. My last formal connection was at the Church's base in Florida 3 during 1986, when I reached the fairly high status they call "0T V" Costs for the two of us had exceeded $100,000. During- that last four-month stay, though I was there as participant, not observer, I could not help but observe how the magic tricks were done, i.e., the social control mechanisms which produce "OTs" and other kinds of group members. The divorce came in November 1987 (there are two children, seven and ten, joint custody). By the start of 1988 I was no long'er in any way a member or adherent of the Church of Scientology. What I learned about during that time was the "selling" of special frames of reference in which 'public standards of evidence, evaluation, ethics, and rationality cease to apply. One learns to "make exception for" what otherwise would be seen as speculative, wrong, immoral, or nonsensical (to justify "how it could be that way") and so avoid conflict with viewpoints presented seriously by persons who are or appear to be one's friends. The opening wedge is just a little bit at first, nothing to fight about. Then follows a process of entrapment in which various "tricks" (which I have documented elsewhere), each building on the last, widen the gap and induce ever-deeper participation in the special frame of reference -- all the while discouraging open recognition of ~hat has occurred. The coup de grace is "closure" -- attempts not just to inculcate special viewpoints, but additionally and by similarly covert methods to disconnect the person from and discredit his past beliefs and loyalties and attach him unconditionally to the group ("you're either totally with us or totally against us"). Anything, apparently, can be 4 justified within the resulting moral and intellectual isolation. In my own case, I cannot say what problems would or would not have occurred had Scientology not been a factor. Neither I nor my former wife are perfect people. It is my conviction that the influence of Scientology eliminated whatever possibility there micjht have been of working through our problems and achieving a successful family and life. For more than a decade the realities of our lives were "translated" into the pseudo-psychology which is used to make it appear that Scientology possesses a "technology" Those distractions and misdirections pre-empted any effective address to our situation. Gall Sheehy's books ("Passages", "Pathfinders") indicate th~ kind of agenda pending after so long in never-never land. It's a long climb back, and all the old issues are still there awaiting real (rather than delusional) resolution. Those distractions and misdirections are not something abstract or theoretical. In March, 1984, I was virtually held prisoner in my o~n home for three days while two "Mafia-type" registrars worked to eliminate me as a factor in their (ultimately successful) attempt to coerce more than twenty thousand dollars from our fledgling company via my wife. Their technique was what was called, in the hippie days, a "mind luck": a constant and high pressure barrage of physical intimidations, asserted agreements, emergencies, plays on loyalty, sophistical arguments, accused betrayals, verbal attacks, insults, implied commitments, humiliations, threats, promises, orders, validations, invalidations, flattery, appeals to deeply felt needs, pleas, ridicule, exhaustion, misidentifications, asserted truths, plays on status, "trust me's .... anything to destroy my ability to maintain an independent position. 5 "Hard sell" is official Church policy. In the process of obtaining my wife"s complicity with this brutality one of the registrars told her "what have you got to lose?" That same registrar explained his actions to me in terms of "I'm just doing my job" It appears permissible to destroy anything (or someone else's) to produce a result desired by the Church. For a time I tried to explain away that event (and others) as just the isolated action of a couple of very sick people. But after my 1986 trip to Scientology's base in Clearwater, Florida I could no longer ignore that this sort of action is typical, and approved by the Church. I sa~ and experienced additional instances, and attempts were made to recruit me for similar activity. I saw that a major activity at the "religious retreat" isto train people in such actions and to "handle" their scruples. I encountered people convinced their most "ethical" action was to obtain as many credit cards as possible and max them all out buying Church services. I met a woman who had cjone through complex legal maneuvers to secure possession of a trust fund left by relatives to her children and donate it to the Church. A staple of lunchtime chatter was brags about how "I got my husband to send X amount of money" or "we trashed our business to buy services" or "we sold our house", etc. And always, the facile and sophistical justifications. My personal impressions of people I met who had done such things is that they were scared and confused, having been intimidated by high pressure sales tactics and having yielded to the invalidation of whatever else had been important to them (perhaps the latter having been redefined as "suppressire" and vanquished after a heroic struggle with help and support from Church personnel). They were hanging on desperately to the one thing they had left that people would validate and praise them for. The woman with the trust fund could not look me in the eye. I did not know, in 1973, about the Cult Awareness Network, the American Family Foundation or Margery Wakefield. Most Scientologists still do not know, and Scientology tries hard to keep it that way. The "closure" entrapments work when conceptual alternative and complete information are denied, suppressed, or simply not available. With better information it is at least possible that much pain, tremendous waste, and destruction of families could be avoided in many cases. The salesmen of Scientology, using the umbrella of "religion", seek to bypass issues of fraud, coercion, consumer liability, and "truth in advertising" which concern other salesmen. Opportunity thus exists for practices which would not be tolerated in more visible realms of public life. What protection do we have but the free and public testimony of those who have been there? ** AFFIDAVIT ** TOM WRIGHT 440 Forest Home Drive #20 Ithaca, New York 14850 August 29, 1989 Scientology, like other cults, is dangerous because after enough involvement in it, you begin to believe that the end justifies the means. Unfortunately, for the honest, decent members of Scientology, the professed beneficial goals of Scientology (a world without insanity, war, or crime) are not likewise held by the top management, including its founder L. Ron Hubbard. Scientology's purported goal appears to be merely a cover for the intention to gain lots of tax-free money. The 'means' I have seen employed include lying, coercion, guilt, promises of a better future (another lie), elitism, threat of having your future damned (which would be the denial of any future benefits of Scientology), Scientolog'y 'ethics' procedures, pushing the sale of professional counseling ("auditing") at exorbitant rates, etc. Scientology has a benign appearance. New or potential members are showered with affection and usually get good help from a couple cheap introductory courses. If these new members decide that only Scientology can help them, then they are encouraged to buy as many high-priced services as possible. When a Scientologist's excitement runs out, various means are used to keep him/her dedicated and buying more courses. There were some theories and techniques in Scientology which were used to help people with their personal difficulties. These techniques involved looking inside the self for the source and solution of the difficulty. This same principle of looking within was used to control members. If a member had done something 'wrong' (e.g., criticism of Church beliefs, methods, activities, etc., 2 tardiness, failure to bring in new recruits, lack of success at "donating" more money to Scientology), they were "helped" to look within themselves for the reason. That one might have a bad credit rating, or that the banks were tightening their loan policies, or some other outside influence made no difference when one was going for another "Scientology loan", for example. Any such related factors were labeled excuses by the Church - one was ordered to "clean up their thoughts and intentions", and then things would go right. Constant introversion of this nature caused people to police their own actions and thoughts, sometimes to the point of not acting and not thinking. When self-policing and staff "help" to look within failed to ensure proper behavior, the other various "means" (lying, guilt, threats, ethics, etc.) were employed to gain the desired "end."' Please realize two things about those people still in Scientology ~qho defend the righteousness of Scientology. They believe that the unreasonable demands put upon them by their superiors are necessary, justifiable, and ultimately beneficial, in the way that a successful athletic team appreciates how the coach pushes them beyond former limits. Also, according to Scientology doctrine, the future of the entire universe lies in their bands, and that only Scientology can save it from eventual obliteration. In dealing with the Scientologists, one must also realize that they are taught that the outside world (for example, the press, the government, mental health institutions, etc.) are totally against Scientology and its 'beneficence', and that these 'outsiders' spread lies about Scientology and its leaders. Thus, these believers discount and/or ridicule any depiction of Scientology as other than lily-white. They often cannot see what is often-times right in front of them - that Scientology was really set up to make millions of tax-free dollars for the top management of Scientology. The following are a few examples of things I experienced in Scientology that were not in the spirit of help and goodwill. Elitism - We ~ere told many times that because we were searchers, and found and recognized the one workable way, that we were better off or superior to those in the outside world, to whom we gave such charitable names as 'wogs', or 'raw meat' Pursuit of Money - The two most vital statistics of the Mission were GI (Gross Income), and VSD (Value for Services Delivered). I remember being told several times to speed someone through her course because she wouldn't buy the next course until she completed the one she w~s on. While on my post as a classroom assistant, I was told not to spend time helping a student who was unlikely to be able to afford expensive courses. In fact, I know of someone, who once he let it be known that he wasn't going to be able to afford anything more than the cheapest course, the Scientology registrars quit trying to induce him to join. My wife took out $50,000 in dollars of loans during the four years she was in Scientology, to finance courses she wouldn't receive until years in the future. Incidentally, professional auditing cost $200 per hour. One Scientology executive of our Mission was thrown out after she refused to get any more money out of students, like my wife, for one. Out of approximately twenty-five people who were involved with our Mission before it folded, ten went bankrupt or Chapter 13. 4 Guilt - I felt guilty that I wasn't performing the duties of my post well enough. L. Ron Hubbard's philosophy demanded that one be flubless, or mistakeless, on the job. He dictated that a staff member who was paying too much attention to other people's posts was almost certainly not up to par in their own work. This prevented me from speaking up about my doubts of others on staff, especially those in higher positions who seemed to be unethical. Staff members who got the most attention from their superiors were those staff members who were more directly involved with bringing in lots of money. I had lots of areas where I was told I was weak in, but I was simply allowed to 'slide'; my post in the classroom didn't bring in nearly as much money as the registrar's 15ositio, so even though I was told that I was always 'messing up' on the job, no one really cared to follow through and 'retrain' me. Coercion - I bodily transported an errant student back into the building to be 'handled' by the 'ethics officer' (He was later allowed to leave, because he was considered an evil influence.) If I or others didn't appear to agree with what a superior said, we were usually reprimanded and often sent to practice 'acknowledgements' (part of a Scientology communication drill), until we finally were worn down enough to listen and accept without judgement what was being said. I saw a registrar break Hubbard's rules of communication that I happened to be teaching while she insisted that a student obey her instructions to get more money (another bank loan) to buy another course. Rules could be broken by those higher up in the name of bringing in money. Often times staff directed us to be "break buddies" (to befriend a new student, especially on course breaks), in order to make the novitiate feel more comfortable and liked. In Scientology, a person's judgement was eroded and subjugated to what L. Ron Hubbard wrote, or to the Church's interpretation of it. Any time anyone questioned the writings, they were made to go back and restudy until it 'made sense' to them, or until they gave in and ceased to impose their own opinions. Although many of Hubbard's teachings outwardly pretended to promote optimum happiness and survival they could be twisted and perverted by the Church, staff, and Hubbard himself in order to get whatever'end was desired usually more money. One of tile things that was promised was that my communication would be a lot freer, and that I would feel more powerful. What actually' happened was that I was reluctant to speak about any of my doubts about what was going on in the Mission and I was also less communicative with people outside of Scientology because first, they were 'wogs', and second, they might have some distracting or dangerous opinions on life that would be in opposition to what I was trying to believe in through Scientology. I couldn't even talk to my own wife. My life in Scientology was inhibiting. I really wondered when my wife received lots of expensive auditing, and yet still had some physical maladies afterwards, which ~gere supposed to have been vanquished by auditing. Ethics - People had to endlessly write up their 'sins', 6 real or imagined, in order to straighten out (i.e., they had questioned Scientology authority.) "Amends projects", claimed to be for the purpose of repairing 'damage' you had inflicted on the group by your non-conformist ideas, often entailed giving more money to the Mission. TR's - (Training drills in communications) Supposedly designed to make people more at ease while confronting another person in any activity, often tended to introvert the participators and/or make them appear artificial. Harassment during these drills from the "coach" or supervisor often led to frustration, and even catatonia (which I experienced personally many times). Some of these drills led to the person accepting anything, good or bad, with no sense of voluntary judgement. In summary, I personally felt guilt and failure to perform to the standards Hubbard ~rote about in his voluminous bulletins on Scientology. I believe others felt the same inadequacy, which tended to make them more pliable in the hands of the 'authorities' of Scientology. What a relief it was when later I read that Hubbard himself could not get good, reliable results with his own technology. ** AFFIDAVIT ** KATHY RAINE 440 Forest Home Drive ~20 Ithaca, New York 14850 August 29, 1989 The following story of my life in Scientology is true. And it is not out of the ordinary. Many people I knew personally who were also in Scientology suffered similar outrages as mine - some worse. I was in Scientology for about four years. I was exposed to it in Connecticut. Recently out of college, with no career, and just having split from my long-time boyfriend, I was on my own and not very happy with my life. The Scientologists there appeared to be happy and fulfilled. They were also very friendly to me. At their Scientology Center, or Mission, as they are called, they gave me a mild sample of their counseling technique, called 'auditing', and I was hooked. It was a simple recall process, and what I remembered through it was my father's laughter - something I hadn't heard since he died 15 years earlier. Somehow, this emotional experience convinced me that Scientology had all the answers to life. The group in Connecticut split up shortly after I was exposed to it, and I made my way to Ithaca, NY, just as aimless and friendless as I was in Connecticut. Eventually I looked around for a Scientology group at nearby Cornell University, and was referred to one in Elmira, 45 minutes away. I soon moved there. It was in this Elmira group where I became deeply involved with the inner workings of Scientology's beliefs and its social structure. I think it's accurate to say that Scientology makes itself out to be a "helping" group, which attracts many people. Those who stay get sucked in by a multitude of mind control techniques that break down a person's free will. Of course the bottom line is you hand over your own power and believe that Scientology has the key to existence. And it quickly becomes a game of victims and masters, all down the line - 2 from the "Mission holder" (like the Executive Director) to the student. Scientology is a system of living that allows the fear and evil in people to rise to the surface and truly shine! Everyone in it becomes a mini-L. Ron Hubbard (maniacal founder of Scientology), with perverse power and money games mixed up with your psychological survival. Our group in Elmira followed Hubbard's precisely laid-out game plan. It was pure paranoia. According to Scientology, you were either being suppressed, or worse, you were a suppressor. Every bad thing that happened to you happened because you had "postulated" it some time in the past. If your life in Scientology became too tough at times, the staff of our 'Mission' said you were trying to get sympathy by playing the 'victim'. Hhbbard had a complete system of "ethics" set up, where if you stepped out of the arbitrary line, you had to pay - one way or another. "Ethics" was used to keep you in the group and keep you in line. The worst punishment to a brain-washed Scientologist is the threat of excommunication. So when the leader of our Scientology Mission said 'donate', we said How much? And it wasn't that simple. Money was obtained through the 'sale' of Scientology courses and counseling, at exorbitant fees. And it was never good enough to buy one course at a time, or as you needed it - No-o-o. We were constantly being pushed to buy more and more - with all the pressure of a professional sales pitch. All told, I spent $60,000 on Scientology - all of it pressured out of me. About $10,000 came from an insurance settlement, and the remaining $50,000 came from lending institutions. We were pressured to go to the banks and get the money all at once - right then and there - rather than make time payments to Scientology. Of course we were encouraged to lie to the loan officers as to the purpose of the loan, because they soon got wise to seeing 'Scientology courses' on the loan application. At least nine people from the Elmira Mission have gone bankrupt or Chapter 13. Most of us worked several jobs at once to pay for the debt. I had a full time job from 8:30 to 4:30, then I would work as a waitress from 5 pm to closing. Any time off was spent at the Mission studying, counseling, passing out literature, trying to bring people in, being punished, going to the banks, etc. I had no life of my own outside of work and Scientology. When my mounting bills outstripped my income, I quit waitressing and joined a sales crew (still holding down my 9 to 5 job), where a lot of other Scientologists also worked to make more money. We traveled approximately four hours a day ~o urban areas to sell discount books door to door. So I worked approximately 70 hours a week. All this still wasn't enough to cover my bills, as I was repeatedly being sent back to the banks to get more Scientology money. So my husband, who was a Scientology staff member (earning slave wages) would take a second job to help out, even though this was frowned upon by Mission staff. One morning he had gone out to cut lumber (without a partner), and he didn't show up for his Scientology job. They called me, and I was terrified that he might be lying dead under a fallen tree, or something. Just as I was leaving to search for him at his remote work site, in tears, I called the Mission just to check, and "Well, yes, he's here..." No one bothered to call me, and as he was being grilled later concerning his tardiness that day, the "ethics officers" told him he was lying about his watch stopping, and that I, his wife, was the real reason he screwed up. I was suppressing him by not being able to pay off my bills, and making him work outside the Mission. (His watch really had stopped.) Another pressure point they used to keep people in line was their spouses. Scientology constantly threatened to split up couples. Since both parties of most couples were Scientologists, if either "messed up" (e.g., couldn't come up with more money, failed in their studies, etc.), it could threaten the marriage. If either one were excommunicated, then the other wasn't allowed to see the "fallen" one, or else both parties were kicked out. I was always being subtly threatened that if I didn't do what they said, I could lose my husband. We were also discouraged from having' children, which would take time and money away from Scientology. One time the Mission holder's wife jumped on me for not being on the pill (99% success rate). My husband was'also told that I wouldn't make a fit mother yet. (Not until I had completed all my Scientology.) By the way, whenever we went home to our families for a visit (usually only once a year, at Christmas or Thanksgiving), we were watched suspiciously on our return for any signs of being polluted by the outside world. I could go on and on. Paradoxically, the deeper I got into Scientology, the happier I told myself I was (especially after all I had invested), but the truth was that I was living in pure hell, and I could have admitted it then and there if I thought it was safe enough to do so. As I was breaking out of the cult, and deprogramming, it was hard in that I had to shake off the feelings of self-doubt, guilt and shame that it had instilled in me, and the fear that Scientology still had some mysterious voodoo power and could come and get me if it wanted to. I am still paying off the loans I took out for Scientology. I still have nightmares about those years. Bit by bit I am rebuilding my life and gradually planning a future. ** AFFIDAVIT ** SANDRA K. WYNINGER 4163 Russell Avenue Los Angeles, California 90027 August 10, 1989 My name is SANDRA WYNINGER. Scientology teaches you to communicate and to understand life. I came from a family where communication and understanding of life were not abundant. So I was totally thrilled when I found Scientology. I dedicated my life to it - not in the way a Sea Org member would - but all my extra money and all my extra time went into doing my Scientology training and auditing. As a result my children really suffered because I wasn't there for them. I thought because I was helping "Clear the planet" that not being there for them would be alricght because I w'as helping Scientology create a saner, safer and fr'ee world to live in. But it doesn't justify the fact that I wasn't there for my children. I had the delusion that I was doing the best I could for my children and husband. After many years of struggling to get up to the point of doing my OT 3, I opened the pack, this confidential pack that I had worked for so many years to get to, only to find in my mind, that it was complete science fiction. There was no way I could agree to it. When I complained, I was taken into review. The OT 3 staff charged me $3,000 more just to complain, and finally it dawned on me, "There's not going to be any way of getting out of this graciously. If I go and tell them how I feel I could lose my husband, I could lose the respect of all the friends I had that I had made in Scientology because they would not want to associate with me" So I had to go out and say, "OK, I'm done, I'm through, it was wonderful, thank you very much". When I walked out of the Advanced Organization that night, it was the last time I ever ~alked in. To this day I've never walked back into the Advanced Organization of Los Angeles. That was in November 1983. When I walked out that night, David was there. I told him what I wanted to do, that I wanted to leave, and he was scared to death. He hand't done OT 3 yet. I basically had to deal with the fact that he might leave me because I no longer agreed with Scientology or OT 3. He could not remain a good Scientologist and go up the Bridge and have me as his wife. It took him about three days to think about it. There was really some tension there for three days until finally he decided that I had confirmed some things that he had been wondering- about. I still could not tell him what 0T 3 was. I could not sit down and tell'him that. It was like this thing that was so instilled in me. It was very sad that I went through all that. And then to have the courage to speak out in my small way and leave, the ripples of that weren't felt by anybody except my family. Except that now you have to be afraid of letting anybody know that you feel that way because if you speak out Scientology can harass you. They may not even do it in a legal way. They will do it ways that already happened to my husband David. A contractor, Bobby McGee, had David do work for him as a subcontractor and then never paid him. Mark Stevens, another Scientologist, had also worked with David for years. When David told him he was leaving Scientology, he came and got his tools and said. "I don't want to talk to you again". And he's never spoken to David since. That was about December 1983. I was the villain, of course. I was the Suppressire Person who had gotten David out of Scientology because I was the one who did OT 3. They thought if it hadn't been for me David would still be in Scientology. Of course I had people tell me that too, that I was the one who used up all of David's money to do the Bridge and then I left Scientology and got him out as well. So it was a real heavy guilt trip. I mean, how wrong can you be. I made it officially known I was leaving. I told my course Supervisors ~hen they called me and asked me why I had not been to course. I was real close to graduating Class Six, so you can imagine what this did to my supervisor. I was also on lines at Celebrity Center doing the Ethics Course. So I was auditing on OT 3, doing the Ethics Course and working on my Briefing Course. So where did I have time for my family? And I was also working. I went to Celebrity CeIlter on weekends, I audited at night. There was one period of time when I wasn't at ASHO that much, but when I wasn't auditing I was always at ASHO oil the Briefing Course. So I was always somewhere workincg to clear the planet. So that's what's really sad. You live in a country where the Constitution protects your freedom of speech unless you are speaking in a way that is true to you. But some other group like Scientology doesn't want you to speak that way and wants to shut you up. They do not want people to know that there are people out there like me who do not agree with OT 3, that didn't agree with the way people were being treated or with the harassment. One example of that is that I was ordered to go to Flag in February 1983 because I took the Richard Stewart course on Real Estate. How corrupt. How horrendous can that be. I went to Flag but I didn't go because I wanted to go. I was in the middle of auditing OT 2. I was told I could not have another session until I went to Flag. When I got to Flag I had an uncle who lived in Tampa and I said, "We don't have a lot of money and we are already stretched out to do OT 2 and now we had to pay plane fare and not work and do all this. I can stay with my uncle and not have the expense of staying at the Fort Harrison Hotel". "Oh no", I was told. "You have to stay here at the Hotel" Other people had the guts to say, 4 "I am here because I was ordered to be here", which is what I was, "And I will not stay in your facility. I will go to a motel or ~hatever". But I didn't have the guts to do that. And David said, "Don't embarrass me, don't embarrass me" . In 1977 I was auditing a staff member for my student completion requirements at ASHO. I had to go and find my preclear. It ~-as parent time so I had to go to the Cadet Organization to find the person. I was appalled that there were so many small children sleeping in one room. It was wall-to-~all children and the parents only saw their children for one hour per day. I left in 1977. We ~ere living' in ~outh Texas. David had a business down there. I wanted to do the Briefing Course so left my ctlildren ~ith my husband, their stepfather, while they were still in school, to come out and do the Briefing Course. So in a way it triggered my abandonment of my own children. But these children in the Cadet Org, their parents were only there for them for an hour each day, and even that was something that some of them did not want to do. The parents 11ad to be made to fulfill their family time. Some of the parents did not want to do that. So it really made me aware that these kids were being necjlected and certainly my kids were being neglected. It was also a time the parents could be free, and many times the kids were a long way away from where the parents worked. So it got to be easier for parents to skip family time with their children and take some free time for themselves. And that's when it got stricter that if families had kids, the parents had to show up for family time. So you would see the parents and children ~alking around with their ice creams acting like, "i'm beincj the parent" If you're clearing the planet and if you're wanting a saner world to live in, where does it start? Doesn't it start with your own children? In your own family? And having a peaceful family? And a loving family? I went on a w'hale watch with some kids from Scientology in the late 1970s; and I heard the guy who was working on the boat say, "i've never seen a more foul mouthed group of kids like this one. This is the worst group of kids I've ever seen" Scientology kids were notorious for having filthy mouths and filthy language. Because no one was there to really nurture them. That's what they heard. It was embarassinc] to have somebody in the "wog" world comment that that was the worst talking group of kids he had ever seen. So David and I moved back to Texas ~fter being on lines at Celebrity Center because we wanted to improve the condition of our lives. We thought that if we moved back we could get ahead. We were in Scientology when we were first out here. It seemed like every extra penny we got went to the Organization. So we could never get ahead. So if we moved back to Texas and established a home and established some money and saved some money then we could come back out and do the Briefing Course. So after about two years in Texas I said, "Enough time has gone by. I'm going to go back and I'm going to do the Briefing Course". And that was about the time the prices went up. So it also kicked in the thought that, "If I don't go do it now it's going to get more expensive", which is another reason they raise the prices. So I came out, rented a room, lived in one room, shared a bathroom just like a lot of other Scientologists living in a Scientology house with nothing' else but a bed and a dresser. And every night I was by myself. The kids and my husband weren't there. And I wasn't there for them either. So it ~e'as really tough. It was a real tough period. And I was late to class one morning and I had to 6 scrub toilets. And it was like, ... "Wait a second, I'm not with my family, i'm paying all this money, I'm doing all this stuff". Here I was on the Interneship - on the Interneship you had to be there early - and I was late and the Supervisor found something degrading for me to do because I was late. I think it was the unkindness that Scientologists had for each other and how they would treat each other that got to me. Like ordering us to go to Flag and the way they treated Richard Stewart and the way they treated the people that ~orked for Richard. I didn't want to continue my association with people that are so unkind to each other with a blind allegiance to an organization that perpetrates criminal activities while claiming to be'a bonafide religion. AFFIDAVIT OF STEVEN GARRITANO I, Steven Garritano, hereby depose and state under the pains and penalties of perjury: 1. I have personal knowledge of the facts sworn to herein and if called as a witness to testify thereto could do so of my own personal knowledge. 2. I was a member of the Church of Scientology of Boston in the State of Massachusetts for approximately three years. I left the Church on or about December 1979. As a result of such employment I was sent to the East Coast Headquarters of Scientology known as Flag located in Clearwater, Florida. I know from experience that Flag, owned by the Church of Scientology of California, communicates between churches and disseminates orders for the Church of Scientology of California through its agents, known as Flag Representatives ("Flag Reps") located in each Church. These "Flag Reps" operated and controlled the Church of Scientology of Boston while I was there. 3. As an employee of the Church attending Flag Headquarters I have personal knowledge of the following Flag Orders which applied to the Church of Scientology of Boston: a) Flag Order No. 3474 regarding the Treasury Bureau network personnel protection. This order concerned personnel transfers, removals or proposals for missions without first receiving permission from Flag Treasury and if this order was violated the appropriate actions would be taken against the offender. b) Flag Order No. 3474-1: Flag Service Consultant and Flag Collection officers stats. This order concerned the collection of monies by Flag Headquarters in Florida from the various churches including Boston and public individuals. c) Flag Order No. 3474-2: This order was entitled "Collections Officers Establishment Basics". The purpose of this order was also for collection of monies from churches and individuals, but additionally shows L. Ron Hubbard as the "Commodore" with the various Flag treasury offices under his control. d) Flag Order No. 3475 entitled "Flag Personnel Procurement Office". These involved orders by Hubbard concerning the recruiting of persons for rapid expansion which begins with "We are taking the planet..." e) Flag Order No. 3525 entitled "The Restricted List", use of. The purpose of this order was for security. f) Flag Order No. 228-R entitled "Purpose of the Sea Org Character of Missions". The -2- general income of the Sea Org is obtaine~ from a percentage of general income of Orgs and billings to Orgs for Mission Services." "Missions are staffed by Bureau One (Scientology covert operations office) by providing adequate personnel into the missionary unit". g) Flag Order No. 3444-R. This order was issued to place a Flag Officer in each of the churches in order to report statistics directly back to Flag Headquarters. h) Flag Order No. 3466-R-10. The communication lines in relation to the Scientology network across the country were established here with L. Ron Hubb~ard entitled "Commodore" at the top and all other offices below him, such as the Guardian's Office, the Commanding Officers of the Orgs, etc. 4. Based on my experience as an employee of the Church of Scientology in Boston and at Flag Headquarters in Florida, I know each church was set up in a military style using ranks and salutes. Pursuant to Hubbard's and the Church of Scientology of California's orders, each church was organized and set up exactly the same. Included in this uniformity were standard Church of Scientology of California publications and leaflets, instructions, and courses. All prices were standardized and uniformly applied. -3- 5. Each church including Boston had military liasons from the Church of Scientology of California, from Hubbard and Flag Headquarters in Florida, whose purpose was to guard over and see that all the duties of church personnel were carried out to t~.e letter. Some of those duties are to insure that proper amounts of money are being sent to the Church of Scientology of California, along with all statistics concerning finance, members, and growth of the church. Failure to comply with the order of Hubbard or the Church of Scientology of California resulted in severe punishment by placing persons in the "R.P.F." (Rehabilitation Project Force) in which they were forced to perform hard labor. 6. 'Hubbard and the Church of Scientology of California operate and control each church, including Boston, through the "Flag Reps" and the Guardian's Office. All decisions regarding personnel transfers, receipt and payment of money, sales, books and courses offered and purchase of property were directly made by the Church of Scientology of California. This was the routine practice in Boston while I was there. -4- AFFIDAVIT OF LUCY GARRITANO I, Lucy Garritano, hereby depose and state under the pains and penalties of perjury: 1. I have personal knowledge of the facts sworn to herein and if called as a witness to testify thereto could do so of my own personal knowledge. 2. I was a member of the Church of Scientology of Boston for six and one half years in the State of Massachusetts and was an employee of Scientology for approximately six years. I left Scientology in December, 1979. 3. Based on my experience in various positions with the Boston Church of Scientology, I had frequent contact with Scientology churches and headquarters in the United States. I observed that all churches were set up pursuant to Hubbard's orders in exactly the same way. Procedurally, Hubbard's orders for a military organization are carefully laid out in volumes of books entitled "Technical Bulletins" and the "Organization Executive Course" volumes. These volumes, along with other secret documents such as the Flag Orders, are in every church. Each local church is set up using military ranks and strictly controlled by placing military liasons known as "Flag Reps" and "Hubbard Area Secretaries" who reported directly to Hubbard, i'n each church. The highest position, aside from the military liasons, in the church is known as the Commanding Officer, who is kept under the direct and constant supervision of the Church of Scientology of California's military liasons. The Commanding Officer or any other executives of the local church staff cannot at any time hire or promote an employee, severely penalize or demote or dismiss an employee, spend any money, pay any bills, or make any rule or procedure for any department in the church without complete approvalby the Church of Scientology of California and Hubbard. 4. To insure that all orders of Hubbard and the Church of Scientology of California are carried out by these military liasons to the letter, Hubbard and the Church of Scientology of California set up a variety of networks within each church whose sole purpose was to report back to Hubbard and the Church of Scientology of California all financial data, statistics and information on personnel. These positions are known as "Flag Rep Network", the "Hubbard Communication Network" and the "Guardian's Office". Hubbard's Flag Rep Network reports to the Flag Headquarters in Clearwater, Florida. Its sole purpose is to direct all churches and insure the continued growth of the money supply of each church in the various cities in the country. If the Flag Network discovered one of the churches financial "stats" were down, the Church of Scientology of California would order.a Flag "Mission" to that "target". The Flag Mission could then implement new programs in order. to insure the growing money supply for that church. The Flag Rep for each church is also responsible for spying on all personnel to insure that they are doing their duties, pouring over the contents of all personal letters and documents, going through any staff member's desk drawers, files, clipborads and interrogating personnel if necessary. 5. In my own case as an employee, I became extremely nervous and scared whenever the Flag Rep would come and watch me, knowing he could put me in the "R.P.F." (the internal concentration camp of Scientology) if he believed I had committed any "crimes" against Hubbard. Each week I had to answer in writing approximately 300 items and questions for which my department was responsible to the "Flag Rep". The Church of Scientology of California Flag Rep officer is in the executive division and paid by the Boston Church. 6. The Hubbard Communication Network officer, who reports directly to Hubbard, is also paid by the Boston Church. The immediate headquarters of the Hubbard Communications Officer is the Church of Scientology of California, Cedars of Lebanon Complex, in Los Angeles. The primary purpose of the LRH Communications Officer is to insure that Hubbard's orders are carried out for that particular church. This officer as the "personal representative of L. Ron Hubbard" had virtually unlimited authority. 7. The Boston Guardian's Office's, acting as the agent for the Guardian's Office of the Church of Scientology of California, primary purpose was two-fold: First, to run any and all covert or overt activities for the Church of Scientology of California in the Boston area. Secondly, it acted within the church as the secret police and enforcer to insure, either physically or mentally, that all Hubbard's orders were carried out. 8. By maintaining strict standardization of all Scientology churches, Hubbard and the Church of Scientology of California are able to transfer in an orderly and regimented manner all funds, files, documents and persons. With this uniformity, agents of the church can locate on the streets and solicit "raw meat" (potential customers with money) and easily transfer them from the local churches to the more expensive churches located at Flag in Clearwater, Florida and Los Angeles, California. AFFIDAVIT OF JAMES GERVAIS I, James Gervais, hereby depose and state under the pains and penalties of perjury: 1. I have personal knowledge of the facts sworn to herein and if called as a witness,to testify thereto could do so of my own personal knowledge. 2. I was a member of the Church of Scientology for approximately seven years. I was in the Boston Church for six years, the Toronto Church, the St. Catherine's Church in the country of Canada, and the Tampa Church in the State of Florida and was an employee of Scientology in some of these places. I left Scientology in December, 1979. 3. As a result of being a member of the Boston, Toronto, St. Catherine's and Tampa churches, I observed that said churches were organized in exactly the same manner. Each was set up as laid out pursuant to Hubbard's orders and run by the Church of Scientology of California, which in turn was controlled by Hubbard. The uniformity of each of the churches started in the streets where members solicited "raw meat" (potential customers), using a carefully laid out procedure of Hubbard's. Once a customer w~s secured and brought into the church they were first convinced to purchase Church of Scientology of California publications written by Hubbard, then pursuaded to take various courses such as the Communications Course and auditing, whose curriculum is precisely administered pursuant to Hubbard's orders. From my experience all the prices of courses, books and instruction were set by the Church of Scientology of California and Hubbard. The Church of Scientology of California's strict standardization of all Scientology churches permitted the orderly ~ransfer of funds, files and persons. 4. In my own case, Scientology had my financial statement including a debit and credit balance of monies given, sent to whatever particular church requested them. In order to transfer my financial statement from one church to another, I observed that each church had to notify by coded telex the Church of Scientology of California and/or Florida for permission. 5. Each church maintains control of its patrons because it is set up as a mini-military dictatorship that answers to the Church of Scientology of California. Hubbard uses military rank to designate the positions of persons within the church. Control was administered by the local Guardian's Office which answered directly to the Guardian's Office of the Church of Scientology of California. Additionally, Hubbard had the Church of Scientology of California place persons in each church to report directly to Hubbard. This position was known as the Hubbard Area Secretary. A further safeguard position was added in each local church known as the "Flag Representative". The Flag Representative would report directly to the East Coast Headquarters located in Clearwater, Florida which in turn reported directly to Hubbard. '2-- \ Failure to comply with any of Hubbard's or the Church of Scientology of California 's orders led to immediate and severe punishment in the "R.P .F." The "R.P.F." or Rehabilitation Project Force, Was the internal concentration camp of Scientology, where they placed disaffected members to perform hard labor. / -3- ** AFFIDAVIT ** MICHAEI, DEARING 7856 Ross~vood Drive Citrus Heights, CaliforDia 95621 August ]0, ]989 My name is Michael Dearing. I'm writing this at Margery Wakefield's request. I currently work as a porcelain refinisher and have done so for six years. My history in brief regarding the Church of Scientology is as follows: I entered the Church in January of 1973 and did the Communications Course, received Life Repair and Dianetics auditing, became a Dianetic auditor, joined staff at COSMOD, became a certified Class IV auditor and an ordained minister. I supervised the Communications Course and audited public and staff up until June o~ 1983. Being a member of the Church of Scientology can be a bit confusing. One is treated with such delicate care at the outset and such enormous amounts of attention and this has a profound effect upon a person. You can't imagine that there is any hidden purpose behind this technique since it is often the first time you have been so intensely communicated to in all your life. The information you are exposed to makes a lot of sense and a lot of it is seen to be true. The supervisors and registrars appear to be extremely honest and operating from a higher position of purpose than the regular person doing his or her job. Actually, many of the staff truly feel they are carrying out the most important mission in this world as well as in this sector of the galaxy. They are involved in a crusade to save the planet and as a public person you are seen to be the next recruit. I know this because I was trained to be a supervisor on the introductory course at our mission. I was convinced I was engaged in the right thing for I had experienced gains; meaning I had become more comfortable in my life and now I wanted to help others experience the same. In order to do this, you must venture further up the Scientology "Bridge" and finally join staff. As a staff member you are required to devote most all of your time--for example, at the mission in Sacramento on 24th Street we showed up at 8:00 a.m. and stayed until 11:00 p.m. and many times until 4:00 a.m. We had minimal meal breaks and I grew very fatigued. Meetings I was part of drilled viewpoints that Scientology was the only solution people had, that I was one of a few most valuable people in the world and that Hubbard was never wrong. Demands to do my part to produce more income grew heavier as I continued. Soon most staff had to wear a facade of happiness, and demands by the Executive Director on the registrars to get money from the new Communications Course students or academy students caused them to promise nearly anything. 'At first a person is told that Scientology may help them, but we were only being careful because we "knew" Scientology could handle and solve anything--i was told of cases where Scientology cured cancer, leukemia, broken bones, withered arms, blindness and others. I shut my doubts out and denied any facts or ideas that Scientology ~asn't perfect and the road to total freedom which it purports to be. I did get out of the Church in 1983 after learning without a doubt that there was deceit regarding the money the Church had received. ** AFFIDAVIT ** LEE LAWRENCE Sr. 613 Oak Avenue Clearwater, Florida 34616 August 12, 1989 I have been a Scientologist for more than twelve years, and I nave three sons in Lneir LwenLles anO edlly Llilzbl~ WtiOm I introduced to Scientology several years ago. Though I have managed to get out, my sons are trapped in this evil cult. Every day I search my mind for something I can do to save them. To many members the so-called "Church" of Scientology appears to be innocent and well-meaning, devoted to the eradication of war, crime and insanity. It attracts caring people who want to help others and make a better world. The initiate is seduced with such sentiments, and with flattery and glowing promises, while he is encourhged or coerced to disconnect from any close friends or family who do not enthusiastically support Scientology. The growing dependence upon the Church is used to intimidate, coerce, exploit and defraud. With each surrender of his will the Scientologist is brought more firmly under control. Stripped of his money, he ends in economic, mental, emotional and physical subjugation, a slave in every sense of the word. In Clearwater there are perhaps a thousand or more such slaves employed by the Church. Typically paid less than one-tenth of the legal minimum wage for an employee of a business engaged in interstate commerce (which the Church of Scientology is), they may ~.~ork a hundred hours or more per week. They are so thoroughly indoctrinated that they are incapable of rational evaluation of their own welfare or situations. Those who want to leave are often unable to do so. With no money, fricjhtened and intimidated and knowing that 2 others have committed suicide, have died in accidents or perhaps been murdered, they cannot leave. Without contact with the outside world, they have no one to turn to for help or protection. Each year in Clearwater, public Scientologists (those not on Church staff) are defrauded of about a quarter billion dollars, HALF A BILLION world-wide. These victims have little recourse. Scientology justice is a joke. Legal justice is available only at great expense after years of obstruction. The Church can outspend anyone, and bribes, blackmails or destroys its accusers, in any way possible, to prevent exposure of its crimes. These evils are sanctioned as "freedom of religion", but Scientology is both much more and much less than a religion, a diabolical deception, designed to exploit and enslave billions of people throughout the world for the sole purpose of amassing vast wealth and power for a small, fanatic, criminal elite. This satanic cult is a spreading cancer in the body of human society on this planet, and the central malignant tumor is entrenched right here in Clearwater. L. Ron Hubbard, the founder of Scientology, got into satanic occultism in his teens, and later he recorded affirmations and repeatedly played them back to himself while under the influence of hallucinatory drugs such as mescaline and cocaine. Here is a word-for-word quotation of one of his evil affirmations: "All men shall be my slaves! All women shall succumb to my charms! All mankind shall grovel at my feet and not know why." This has been documented and accepted as evidence in court in California. We are faced with the manifestation of LRH's intention to secretly subjugate no less than all of mankind. We are dealing' with the legacy of a big thinker. LRH had an IQ of 200, which made people who were only fairly bright, like myself and many of your readers, putty in his hands. Please note the very important last words of this affirmation, "... and not know why." There is the cunning core of his scheme. Any petty tyrant can shoot people in the head to enslave the survivors, but LRH was clever - his slaves do not even know they are slaves - they think they have spiritual freedom while secretly they are mentally, emotionally and physically enslaved. In'order to escape to real freedom they must first fight against their own corrupted minds and emotions which have been long conditioned to resist just such an effort. And then, even if they should conquer these, they must still survive the efforts of the Church to track them down and destroy them after they have escaped to the outside world. I am well into the last quarter of my life, have no ongoing heavy family responsibilities, am not by nature much concerned with my physical safety and have no guilty secrets ~ith which I can be blackmailed, so I am not easily intimidated. I will tell the truth about Scientology to anyone who will listen. I feel obligated to compensate now for the damage my previous support of the Church and promotion of Scientology have done to my sons and others. Perhaps they will finish me off, but even that would be a victory of a sort. The publicity would be enormous, and hopefully ruinous to the Church. '/ ** AFFIDAVIT ** SUZETTE M. DEAR].NG 7856 Rosswood Drive Citrus Heights, CaliforDia 95621 August 10, 1989 My name is Suzette M. Dearing. I live in Citrus Heights, California and am a Technical Writer for a software company in E1 Dorado Hills. I have held my current position for two years. From January 1975 to July 1983 I was a staff member at the Church of Scientology, Mission of Davis (COSMOD) at Sacramento. At Ms. Wakefield's request, I am writing down what I know of the Church's illegal and bizarre activities. The thing that stands out most about my first years on staff is the sheer lack of sleep. We had staff meetings every Wednesday night that lasted from m'idnight until 3:00 4:00 in the morning. We were all required to work six to seven days a week from 9:00 AM until 11:30 PM (or later), in violation of local and state labor laws. However, the party line was that ~e were "volunteers" who were paid a "parsonage allowance", as opposed to salaried employees. (The "parsonage allowance" ranged, on average, from $0 on bad weeks to $100 on good weeks.) On Thursdays, then, we were forced to perform our duties on as little as three hours of sleep. During these staff meetings, the ED of the Mission, Reggie Caldwell, would alternately chain smoke and yell profanities at us, telling us ~~e were non-productive, that we had "evil intentions", etc. After a few months of this, I became quite ill and decided to quit. Staff members who wished to quit were seen by a person called an "Ethics Officer", whose job, in retrospect, was to brainwash us until we "saw the light" and decided to stay. I was told to remain in a small room, about 8' by 8' and write up my "0/Ws", a list of everything bad I had ever done in my entire life. When I thought I was complete, the Ethics Officer ~ould look over what I had written, and if I still felt I wanted to quit he would send me back to the small room to continue writing. I did this for a couple of days until I "decided" to remain on staff. Note that this was standard handling for anyone who wanted to quit staff. I tried to quit staff several times over the years, and was always forced into a small room to "confront my O/Ws" In the first years I was on staff (1975-1979) we were actively discouraged from seeking medical help if we were sic]<. It was felt that all illnesses were "spiritual" in nature. I remember one man named Tom S~evens, who had appendicitis that ~ent untreated for a couple of days until he finally had emercgency sur9ery. He was forced back on the job by the Church after only two days of recovery and performed his duties in considerable pain. On another occasion my supervisor, Cathy Moore, suffered a miscarriage and called me to her house to counsel her to make the miscarriage stop. Needless to say, it didn't and she eventually was hospitalized. I remember ~hen I was pregnant with my second child in 1983, I asked the director of the Church, Jeff Cota, if I could cut back my hours. I was very ill (during my fifth month I lost five pounds) and my physician was concerned about me. His response was that he was convinced that my difficulties were "spiritual" in origin and that he wanted me to receive counselling rather than go home and rest. I couldn't convince him otherwise. In the early 1980's the Church ~'ent into tile pharmaceutical business with a service called "The Purification Rundown" It involved exercise, stints in a sauna, and megadoses of vitamins. Niacin was believed to flush out effects of radiation and drug' poisoning. The pro~oram usually lasted 10 - 14 days, although some people had difficulty with the vitamins making them ill and spent longer on the service. Towards the end of my "Purif" I was taking about 2400 IUs of vitamin E, 200 mgs of Niacin and correspondingly high amounts of the other B vitamins, A, and C. A member of the Church would direct your vitamin dosage. At the time, this was a man named Chris Nesbitt. In 1982 our mission was visited by a group of people who called themselves the "International Finance Police (IFP)". At that time, the mother church was convinced that other churches and missions across the Dlanet were witholding tithes (our mission had to pay approximately 10% of the weekly gross income to the mother church). For a couple of wee]~s we were forced to work seven days a week, anywhere from 14 - 18 tlours a day in preparing our files to document everyone who had ever paid any money to us. They demanded thousands of dollars from us: I don't know how much we paid them. I know they demanded $15,000 a day for every day they were at our Mission. As a staff member I was making from $40 - 80 dollars a week. My husband was supplementing his income with a part time job so we could buy food and rent an apartment. I remember being really upset because my supervisor, Jeff Cota, would not let me go home and spend some time with my year-old infant. She spent her days and nights at a church-run day care center. The last thing' that happened at the Church was a big meeting the IFP held at the Sacramento Organization. They invited everyone who had ever been associated with the Church. They posted staff members as guards at all the building's exits to prevent people from leaving'. The upshot 4 was everyone who was not on staff had to either pay thousands of dollars to the Church in Clearwater, Florida for counselling or be expelled from the Church. Since I was familiar with the building I was able to sneak out; two ~eeks later I left the Church. I was always told by one of the senior staff members, Paul Armstrong, that if I quit staff and quit the Church my life would go to hell. He would attend meetings and tell us that, through his advanced training and counselling, he knew what hell was and gave us rather descriptive, horrifying descriptions to frighten us into staying in line. In 1982 he insisted that the "parishioners" at COSMD Sacramento and Davis chip in enough to make the payments on his brand-new Saab. All the staff and public people h~d to chip in and buy a $10,000 watch for Martin Samuels, who founded the missions and lived in a very expensive home in Oregon, built by staff members. Also, at that time, Jeff Cota, the director of our mission, lived in a very nice 2,000 square foot home in a suburb of Sacramento. At current prices, that house would run around $220,000. The mission was his and his wife's only source of income, yet somehow he could afford mortgage payments and a new car when my husband and I barely could make $200 rent payments and feed ourselves and a year-old baby and were using food stamps to buy groceries. Looking back on it, I think there was a lot of greed and graft and dishonesty on the part of these men, yet at the time we were told we were "flowing power" and making them more able to do their jobs. I am not personally aware of illegalities surrounding "reg cycles", which were when people called "registrars" signed people up for church services and had them pay. However, occasionally there would be mission policies issued cautioning the registrars against kiting checks and acting 5 as unlicensed loan broilers, so I am positive those activities were going on. I know that one registrar, Sherese Graves, acted as an unlicensed loan broker on at least two occasions. I realize this is not a formal deposition, however, all the above is true to the best of my knowledge. *** AFFIDAVIT *** Scott Yeager 4251 S.W. Stepl-lenson PorEland, Oregon 97219 I was involved in Scientology in Portland, OR from 1977 through 1982. I spent over 20,000 dollars with very few results. I spent the bulk of the money ($14,000) signing up for the Dianetic Clear Special Intensive through OT 3. OT 1 through OT 3 were never delivered because the money was used up at a rate of $300 per hour trying to fix past incorrect auditing through lengthy "Correction I, ists", "Repairs", and yes, even repairing the faulty repairs called "Reviews." In 1981 my wife Susan Yeager got acute lymphocetic leukemia. After her 3rd relapse in 1982 she was told by Bruce McKenzie, the Portland mission's ethics officer that I was the cause of her cancer. He told her that I was an SP (Suppresslye Person) and she got cancer because she was married to me. Note - I have never been declared an SP by the C.O.S. (Church of Scientology). Bruce told her that the only way she could live was by divorcing me. Several weeks later after getting auditing and being disconnected from me she was very sick and I was able to get her admitted to the City of Hope Hospital where she died in December, 1982. I attest that everything in this statement is true. ~*~ AFFIDAVIT *** April 13, 1990 I, Margery Wakefield, attest that the following facts are true. ! became involved with the "Church" of Scientology in October of 1968. I was a freshman at the University of Michigan in Ann Arbor. As a teenager I had suffered a nervous breakdown as a result of a traumatic childhood. When I was first approached by a Scientologist who was a fellow classmate at the University, I was told that Scientology could cure all my emotional problems. I was told that Scientology was the "psychology of the future", and that it was 1000 years ahead of psychiatry. I was told that what I had to do was to go to Los Angeles and to begin a series of courses in "auditing". The first of these courses cost me $500. At no time was Scientology advertised as being a religion. It was solely advocated to me as being a cure for psychological illness, for which ! would pay. The first time I heard Scientology referred to as a "church" was in 1971, after I had been in Scientology for three years. When I asked why Scientology was now being called a church, I was told that it was for tax purposes. I spent twelve years in Scientology. I progressed to the "secret upper levels" of Scientology which are chiefly involved with the exorcism of demons. I didn't realize when I got into Scientology that I would be involved in demonic and satanic practices when I got onto these upper levels. Nor was it told to me that L. Ron Hubbard, the founder of Scientology, was a practicing satanist, and that this was his religion, and the "religion" behind Scientology. The facts are carefully concealed from the beginning Scientologist. I believe that in Scientology I was ritualistically hypnotized. On the first class that I did, I had to do a drill called TR-O. In this drill I had to sit facing another person and stare at them in the eyes for two hours without blinking, and if I blinked or moved in any way, the two hours had to be done over again. Some days I did this drill for twelve or more hours a day. I told told that this drill was to improve my eye contact and would make me a better "auditor", or counselor. I did not know until after I got out of Scientology that I was being hypnotized. This drill was followed by thirteen other, similar drills in hypnosis and mind control. -2- In Scientology, when you get into trouble with your superiors, or you are not doing as much work as they want you to do (ie: your "statistics" are not high enough), then you are declared to be in a "lower condition". To get out of this condition, you have to deal a blow to an enemy of the group. In my case, at one point, I was trained how to break into buildings and I had to break into the American Psychiatric Association in Washington, D.C. and steal some documents that the Scientologists wanted, and I did this. Also, one another occasion, I was trained to prejure myself in court. I was going to be called as a witness in a case in Florida involving a judge, and I was coached on what to say. When I questioned this, I was told that it was for the "greatest good". In other words it was to be done for the good of Scientology. At one point, in the fall of 1977, I did volunteer work for the infamous Guardian's Office of Scientology, the branch of Scientology which deals in espionage and covert activities. I had to go through the auditing folders of a man who had defected and mark in red anything that he had ever said in auditing (which is supposed to be confidential), and I was to look especially for anything involving sexual practices or criminal activities and to mark them in red and circle them. This information could be used to blackmail him. ~At this~ same time, while doing work for the Guardian's Office, I t in on a meeting in the Guardoan's Office (now known as the O.S.A. - Office of Special Activities), and I heard two murders planned. One murder was of this man who had defected. He had been caught~ and they said they had him in a motel room, and the next day they were going to take him out to sea and ,''deep six" him - tie weights to him and dump him overboard. The second murder that I heard planned was of Paulette Cooper, who had written a book critical of Scientology, and they were planning to shoot her. To my knowledge this ~urder was not carried out, but at this meeting it was planned. While in Scientology, I witnessed many individuals who had become psychotic while doing the upper levels. When people become psychotic in Scientology, they are either "offloaded" (sent away), or they are put into Scientology's prison, the dreaded R.P.F. (Rehabilitation Project Force). On two occasions I was put in the R.P.F. for punishment of things that I had done. I had to wear an old uniform. We had to work hard ~or about twenty hours a day. We were not allowed to speak to anyone -3- unless we were spoken to, and then only in a military and formal manner. Sometimes we had to eat food that other people had left on their plates. Twice I was on the R.P.F. on a boat that the Scientologists had moored in Long Beach, California where they kept this prison. In 1980, I was "offloaded" from Scientology, and sent back to Wisconsin. In 1980 I was kept prisoner in the Fort Harrison in Clearwater, Florida. I was kept under guard night and day for about three weeks. Even when I slept there were guards stationed outside my room so that I could not escape. One day I was taken to the airport and told to pick any place out of the state of Florida and to go there and not come back. A guard was sent with ine on the plane to make sure I went to Wisconsin and didn't come back. ~t took me eighteen months to recover from the worst effects of Scientology. Eighteen months after ! was physically out of the organization, I snapped out of the hypnosis spontaneously one night. It was a dramatic experience. I felt like I just "woke up" even though I had been awake. I literally came ou'~ of a trance. I knew at once that I had been hypnotized for twelve years and I decided to co,,ne to Florida to ~ile a lawsuit against the cult. My lawsuit against Scientology was filed in 1~81 in Federal Court in Tampa, Florida, Case ~'~: 82-1313-Civ-T-10. My case continues to this day. Signed: 5128 Gainesville Dr., Tamp~, Florida 33617 813) 989-2468 ** AFFIDAVIT ** JERRY WHITFIELD 661N. Occidental Boulevard Los Angeles, California 90026 August 10, 1989 I was recruited into scientology under false pretenses. I worked fifty to seventy llours a week for less than minimum wage while L. Ron Hubbard was claiming he, too, was doing the same thing and getting the same pay, but was secretly taking sometimes more than a million dollars a week from the non-profit corporations of scientology, an activity the IRS calls inurement and has caused scientology to lose its tax exempt status for specific years. I have been harassed by people I do not know, threatened with bodily injury, kicked out of the place I was living, and lost my job; I have seen scientology repeatedly break the laws and lie about it. I have seen secret documents that teach them how to break laws and lie about it. Mind control techniques such as the ones the Chinese Conununists and the North Koreans used on their prisoners of ~var in the 50's were systematically used on me. I was involved in scientology from April 1974 until February 1984. I was a staff member at Narconon, a front group of scientology's designed to recruit drug addicts into scientology and thereby affording scientology good public relations and additional cheap labor. While a staff member, one of my jobs was to collect ~eekly statistics each Thursday. One of these statistics was number of new scientologists this week. Scientology claims to be a church and of a relicjious nature. Yet Narconon was in the business of getting people off drugs and establishing- prison programs for inmates. Often these programs were funded with state money. Each Narconon office had to pay 20% of its gross receipts weekly to scientology for "management consulting" Each Narconon was run by Narconon U S with its offices in Los Angeles. Narconon U S in turn took its orders from t~e Guardian's Office U S and the Guardian's Office U S followed the orders as sent down from the Guardian's Office World Wide located in Saint Hill, East Sussex, England. Both Guardian's Offices ~qere under the control of Mary Sue and L. Ron Hubbard as were the other churches of scientology throughout the world. In essence, money went from government agencies to Narconon to scientology, a violation of the principle of church and state. This occurred all the time I was a staff member at Narconon, from April, 1974 until August, 1977. Four of the agencies that gave money to Narconon were Michigan, Minnesota, Colorado, and California for prison programs established in the correctional facilities in those states. As Narconon staff members, we were, on numerous occasions, instructed to tell people at large that Narconon and scientology were separate corporations and had nothing to do with one another. We were told to' say Narconon was not affiliated with scientology and was in fact its own non-profit corporation. The truth of the matter is many at Narconon followed exact orders sent down by either the Guardian's Office U S or tile Guardian's Office World Wide, whether the lower workers at Narconon knew it or not. I worked at Narconon U S and saw the orders from World Wide come through Guardian's Office U S to Narconon U S. Not only did Narconon have to pay 20% of its gross income weekly to scientology but it had to buy books published by scientology as scientology saw fit. There were orders to do so. To this day, scientology publicly denies any affiliation with Narconon. To be a staff member for any scientology organization, one has to sign a contract, usually 2~2 year or 5 year, sometimes a billion year contract. I had signed a 2« year contract, and when it was complete, Narconon officials requested that I sign a 5 year contract and backdate it 2« years. I did not wish to continue working as in slavelike conditions, so I declined the opportunity. As a result, I was fired from a new job I had gotten (I worked with other 3 scientologists), kicked out of the room I was living in even though I paid rent on it (because only scientologists could live there, another example of the scientological attitude of being above the lairs of the land), and none of my friends were allowed to speak to me until "I repented and saw the error of my ways" Additionally, I was not allowed to continue scientology courses in which I was currently enrolled. Some of the reasons I became involved with scientology were the credentials of L. Ron Hubbard. I read on book jackets that he was an engineer, a physicist, a war hero, had twice been pronounced dead and recovered by using the dianetic techniques he developed to overcome the condition of being blinded, wounded and crippled at the end of WW II. Scientology and Dianetics are held up to be exact sciences and a branch of psychology according to the book Scientoloqy The Fundamentals of Thouqht. By using these same techniques, Hubbard had supposedly cured himself completely by 1949. I was also led to believe that scientology was a humane organization that wanted world peace, no criminality, no insanity, and a civilization wt]ere people could fully trust one another once people became "clear" I have since come to realize that a person ~vho believes himself clear is under mind control to one degree or another and may very well believe anything can be justified by the slogan "the greatest good for the greatest number" In 1984, I left scientology and began a long road back to normalcy. I began to find how mind control techniques were used extensively on me and how I was manipulated to recruit for scientology and work for them for over three years at less than $5.00 per ~veek, (that's not a typo; it's $5.00 per week) often fifty to seventy hours a week. In addition, I had to pay for my own room, board, transportation ~nd clothing. I was told I could go down with other scientologist staff members of Narconon to get food stamps and that would help out on my food, another way to get the government to subsidize scientology. Also, I continued to give scientology every spare cent I could make or go into debt for until 1983. Since 1984, I have found out that Hubbard was not a war hero, he was not an engineer, he was not a physicist, not wounded, blinded and crippled at the end of the WW II, and there is no evidence to support that he was ever twice pronounced medically dead before his last death in 1986. Since 1986, my wife and I have been followed, had people asking for our phone bills from Pacific Telephone to get the 714 and 818 area code numbers we'had called; I have been threatened with bodily injury, and my neighbors have been asked questions about me by private investigators. My fattter and my brother, who live over 1,000 miles from L. A., have been interviewed by private investigators regarding me. My father was asked information that only was known by myself and the "minister" of scientology to whom I disclosed this very personal and private information. I was assured repeatedly that all information I disclosed was strictly confidential and never to be revealed or used in any way to harm me, no matter how intimate it might be. During the "counseling sessions" delivered by scientology, I was repeatedly asked from time to time very personal questions such as "Have you ever done anything for which you can be blackmailed?", "Have you done anything which would make me think less of you?", "Have you ever done anything that you would be embarrassed for anyone to find out?", "Is there anything I have failed to find out about you?" But, A1 Bei, a private investigator who works for Ingram Investigations discussed these things freely with my father. He could have only gotten the information from scientology. I never told it to anyone else. This is in accordance with the "FAIR GAME" policy of scientology which states enemies of scientology may be tricked, sued, lied to or destroyed with impunity to the scientologist who has done it. I have also seen court exhibits showing' there are many secret policies of scientology. Some include diagrams on how to wire tap phones and use electronic surveillance, how to lie convincingly, ho~ to use the court system to harass an enemy or fair game, how to use private investigators to intimidate dissidents, and ho~ to go through files which were supposedly covered by the priest-penitent covenant and pull out embarassing or sensitive information on a person so that person ~ould no longer voice his opinion on scientology. Robert J. Lifton ~~rote a book in 19'62 about the mind control techniques used in North Korea in the 1950's on prisoners of war. Among them were the use of controlling the environment, changing- or loading the language, having a sacred science, planned spontaneity, confession, the person is less than the group, demand for purity, and dispensing of existence. Scientology used all eight of these techniques on myself extensively. I have spoken to many others who have had similar experiences. These techniques are very powerful and should not be discounted simply because a group calls itself a church and tries to hide behind the first amendment. ** AFFIDAVIT ** VALERIE STANSFIELD 4419 Stansbury Avenue Sherman Oaks, California 91423 August 1, 1987 During' my tenure in scientology from 1961 to 1983 my life became more and more controlled by the dictums of the administration - I learned the skills of artfully getting around their capricious authority, always hoping that things would get better. In March of 1983 I was attacked so viciously that I gave up and left. Since leaving I have had the opportunity to see documents that were interdicted to me while under their control, and I realize that the destructive acts I witnessed and experienced were deliberately planned, not the errors of an underling. Conduct and belief are two separate things. But the scientologists believe that their beliefs are facts, that only they know them and that therefore, it entitles them to do anything to preserve and expand their status - as only they can save mankind. In 1983 and subsequently, they systematically destroyed my business, as they did with Larry Wollersheim earlier (see the decision in Wollersheim vs. Scientology). A large percentage of the clients in my nutrition and exercise business were scientologists: they were called in and told that if they frequented my business any further they would be expelled from scientology. I was told to close down my business and pay them 11,000 for reconditioning in Clearwater or else I would be expelled. In May I was expelled in a scurrilous 7-page document that was entirely lies. My business declined until I became bankrupt. Later the person in charge of the mission against me left scientology, and when I spoke with him he said the only reason they'd wanted me out of business was that I was earning money that should have been going to them. (This man, Don Larson, has also testified, I am told, to the FBI and IRS in their well-warranted investigations of tortious conduct.) They did a similar action on a grander scale to a real estate magnate at the time, Richard Stewart: everyone who had taken his real estate courses had to travel to Florida to "Flag" in Clearwater and take a special course there for several hundred dollars or be suspended from scientology. This is religion? Later some people involved with ordering that, who were themselves attacked and left, admitted to me that was to raise money for Flag. Mr. Stewart to this day is afraid to speak up about any of this - they had a dozen of their uniformed guards enter his business premises and go through all his records and checkbooks, after which they fined him in the 5-figures. I was on his premises when they were there, and attest it is true. In May of '83 I was expelled, received several letters telling me I was doomed to the abyss of hell forever, and all my friends and asociates who were scientologists refused to speak to me. Just yesterday I ran into a man who had been a very close friend, a prominent LA artist, who looked at me and said "OH" and walked by unseeing. Last year I ran into someone I'd known who started shouting at me, "Walking Dead!" Since I left I have appeared on television, radio, and had meetings of ex-scientologists to show them videos, such as the video of the 1982 Clearwater hearings. I edited the 30 hours down to 3 so it could be seen. For two years we had a weekly support group of ex-scientologists, a much needed therapy. All had horror stories to tell. Now we have an annual gathering, and a newsletter with a circulation of thousands of ex-scientologists. They sent their "Minutemen" squad to shout at my house, pass out fliers on the street, flash photos, and throw eggs at my house. My friend in Pasadena had maggots thrown in her house, too. They sent an investigator to talk to my neighbors and insinuate ugly things about me. They called some of my friends and told them things about my past that had been confessed in religious ritual to one of their ministers. They have sued me twice, both for silly things just to bother me. As I was Fair Game their goal was to destroy me utterly. Burton gecl RS20:Ds 1 DECLARATION OF TONJA BURDEN 2 3 I, TONJA BURDEN, dec !are: 5 1. i have personal knowledge of the facts sworn to 6 herein and if called as a witness to testify thereto could do so Y of my own personal knowledge. 8 9 2. I became involved with the Church of Scientology of 10 California ("California") and the "Sea Org" in March 1983 at the 11 age of 13 when I ~›as recruited by its agents. The "Sea Org" is an 12 elite para-military organization of "Califo ' "with uniforms and rnla 13 military discipline. 14 15 3. In the summer of 1974, I was placed on board the 16 Appollo, L. Ron Hubbard's ("Hubbard") Flagship which carried about 17 300-500 people. After about three months of indoctrination, I 18 became Hubbard's personal messenger. 19 20 4. As Hubbard ' s personal messenger, I dressed and 21 undressed him, combed his hair, lit his cigarettes, caught the 22 ashes, prepared his shower and toiletries and took care of his 23 personal needs. 24 25 5. I carried messages between Hubbard, Mary Sue 26 Hubbard and the Te!ex machines and radio operators on the Appollo 27 and later after September, 1975 in Daytona and Clearwater, 28 Florida. '1-- 1 6. I personall'] delivered messages concerning "Opera- 2 tion Snowhite" "Operation Goldmine" and "Operation Freakout", and , 3 other Scientology covert operations. 5 7. I personally delivered messages concerning the 6 above operations to Hubbard, Mary Sue Hubbard and the Guardian's 7 Office and I personally filed messages concerning these and othez 8 operations in Hubbard's personal filing cabinet. 10 8. Prior to February - April, 1976, when Hubbard left 11 Clearwater, Florida, I carried numerous messages between Hubbard 12 and others concerning Paulette Cooper. These messages concerned 13 ~perations to attack and destroy Paulette Cooper. 14 15 9. Between February and April, 1976, when "Operatior 16 Freakout" was in the planning stages, I coded and decoded messages 17 concerning this operation. 18 19 10. I escaped from Scientology in November, 1977, bu~ 20 was later kidnapped in Las Vegas, Nevada by two of Hubbard's 21 agents and taken to Los Angeles where I was locked in a room and 22 "security checked" on an E-Meter. 23 2~ 11. Between September 1974 and December, 1977, I hav~ 25 personal knowledge that L. Ron Hubbard and Mary Sue Hubbarf ~6 operated and controlled the Church of Scientology of Californi~ ~7 and all other Scientology operations ~..~orldwide. 28 III '2-- 1 12. I have personal knowledge that Hubbard and Mary Sue 2 were personally involved in controlling covert operations against 3 Paulette Cooper for the purpose of destroying her. 5 I declare under penalty of perjury under the laws of the 6 State of California that the foregoing is true and correct. 7 8 Executed this 7th day of November, 1983, at Las Vegas, Nevada. 10 11 TONJA BURDEN 12 Declarant 13 14 15 16 17 18 19 20 21 22 23 25 26 2Z 28 Burden Decl p4 KB20:bs 1 DECLARATION OF TONJA BURDEN 2 3 I, MICHAEL J. FLYNN, declare: 5 t. I am counsel of record for Paulette Cooper in her 6 action against the Church of Scientology, L. Ron Hubbard and Mary 7 Sue Hubbard. 8 2. I serve as counsel in cases against the Church of 10 Scientology and/or L. Ron Hubbard in approximately 12 other 11 actions including the case of Tonja Burden v. Church of Scien- 12 tology of California, and L. Ron Hubbard and Mary Sue Hubbard, 13 U.S. District Court, Tampa, Florida, Civil Docket No. 80-501 Civ. 14 -T-K. 15 16 3. Since approximately September, 1979, I have made a 17 continuous search and investigation to ascertain the whereabouts 18 of L. Ron Hubbard, including the utilization of investigators, 19 sheriffs, attorneys, reporters, and informants. I have discovered 20 Hubbard ' s whereabouts through informants at various times since 21 February, 1979, including his presence at La Quinta, California in 22 the summer of 1979 and Gilman, Hot Springs, California in December 23 1979. 2~ 25 4. In the Toni a Burden case, supra, Judge Krentzman 26 has ordered the Church of Scientology of California 2Z ("California") , to produce the address of L. Ron Hubbard, but, 28 "California" , since July 1980, has blocked and frustrated all 1 efforts to obtain Hubbard's address. The Court now has under 2 consideration a motion to default "California". 3 5. In connection with an investigation as to the 5 whereabouts of Hubbard, ~l~e have procured thousands of documents from the U.S. District Court in Washington, D.C., which were 7 seized from "California", some of which contain elaborate plans to 8 conceal from the public, law enforcement agencies, etc., any knowledge of Hubbard's involvement with the Church of Scientology. 10 11 I declare under penalty of perjury under the laws of the 12 State of California that the foregoing is true and correct. 13 14 Executed this 7th day of November, 1983, at Boston, 15 Massachusetts. 17 MICHAEL J. FLYNN 18 19 20 21 22 23 24 25 26 27 28 -2- AFFIDAVIT OF LA VENDA VAN SCHAICK I, La Venda Van Schaick, hereby depose and state under the pains and penalties of perjury: 1. I have personal knowledge of the facts sworn to herein and if called as a witness to testify thereto could do so of my own personal knowledge. 2. I was a member of the Church of Scientology, Mission of Meadow, Las Vegas and the Las Vegas Org of the State of Nevada and was an employee of said Church for approximately nine (9) years. I left the Church on May 12, 1979. 3. As a result of such employment I was responsible for about four (4) years from 10/71 to 12/73 and 1/76 to 1/78, for the Hubbard Communication Office, first at the Las Vegas Org and later at the Mission of Meadows in Las Vegas. I know from experience that this Office handles communications between Orgs and its immediate headquarters in Los Angeles and the headquarters in Clearwater, Florida. 4. In my capacity as the Hubbard Communication Area Secretary, I had frequent contacts with the Guardian's Office personnel who included: Matty Reese, Chuck Reese, Susan Reed, Jack Gay and Bruce Hamilton. The Guardian's Office is the police and enforcement arm of the Church and its headquarters is now in Clearwater, Florida. As the result of such employment I had access to more than forty different files on members who were subjected to the "Fair Game" Doctrine and who were designated "enemies" by the Guardian's Office. An "enemy" or "SP" (Suppressive Person) as defined by the Church in its policy letter of October 18, 1967 is one who disagrees with Scientology policies and such a person may be "tricked", "lied to", "sued", or "destroyed". As the Hubbard Communication Area Secretary, I personally saw instructions from the Guardian's Office in Clearwater, Florida and from Los Angeles to put this order into effect while I was working at the Las Vegas Organization. 5. Pursuant to these orders, I personally observed "PC" folders being sent to the Guardian's Office in Clearwater, Florida. "PC" folders contain information that is revealed by Church members during a process called auditing. Auditing is a procedure similar to confession wherein a Church member will reveal to an "Auditor" the intimacies and secrets of a person's life. The Auditor will thereafter record the information and place it in the "PC". folders. The Church member is regularly promised that the information disclosed in auditing will never be revealed by the Auditor. The Church member pays $625 for 12 1/2 -2- hours of auditing and is promised a refund if he is disatisified. 6. The purpose of sending the PC folders to the Guardian's Office where a person had been designated SP or Fair Game was to use the contents of the folders to attack, threaten, blackmail and control the person and thereby prevent the person from seeking to collect refunds of moneys paid to the Church or to prevent the person from exposing the Church activities. The Church regularly and as part of its policy uses the material in these folders to blackmail and control its members in this way. I personally observed this done on numerous occasions contrary to the promises made to Church members. In one case, the Church declared a person named David SandweiSs an SP and threatened to expose auditing information revealed to his auditor by him if he sued for a refund or sought in any way to expose the Church problems. He thereafter committed suicide. 7. In my own case, after I left Scientology, and informed the Church that I intended to sue it for defrauding me of approximately $13,000, the Guardian's Office in Clearwater, Florida, routed the contents of my "PC" folder to the Church in Boston which wrote a letter to my attorney, Michael J. Flynn and without my permission, -3- disclosed the contents of my "PC" folder. The contents of this folder contained in part material that I had disclosed during auditing and it also contains falsehoods inserted by the Church. I did not give the Church permission to disclose this information and it was sent to Attorney Flynn for purposes of depriving me of my legal right to sue the Church. Thereafter, the Guardian's Office sent an individual named Gary Klinger to my home. At that time I took from him a document which I now have in my possession wherein it is stated that he is to threaten me with extortion and offer me $8,000 in exchange for documents of the Church, which the Church believes I now have in my possession. Based on my experience and knowledge of the Church, I believe that these orders came from Clearwater, Florida. 8. I know from my experience that it is Church policy to seek immediately, information on the financial resources of all new recruits and to obtain control over these resources by false representations made to the recruits. When the recruit thereafter questions representations made to him, it is Church policy to threaten the person with being declared an SP which would result in the forwarding of his "PC" folder to the Guardian's Office in Los Angeles and Clearwater, Florida, to be -4- used for the purposes previously described. 9. I also know from my experience in Scientology, that the Guardian's Office of each local organization is controlled' by and reports to the U.S. Guardian's Office in Los Angeles.. In turn, the U.S. Guardian's Office in Los Angeles reports directly to Clearwater, Florida. I also know that there is a telex connection between the U.S. Guardian's Office in Los Angeles and the Clearwater Headquarters of Scientology. I myself used the telex system in Las Vegas and sent and received messages which were all in code to Los Angeles and to Clearwater, Florida. The Guardian's Office issued a press release and wrote letters to the media containing information from my PC files. (See Exhibit 1 attached hereto.) 10. When I joined the Church of Scientology in 1971 and throughout the period I was involved in the organization up to May, 1979, I read numerous publications containing numerous representations issued by the Church of Scientology of California which I relied upon, paid money for, and which were the reason I worked for the organization and paid money to it. These representations are set forth in my Third Amended Complaint in condensed form, in Paragraphs 9 and 12, and some of the publications which I read and relied upon are quoted in part in Paragraph -5- 7 of the Third Amended Complaint. I specifically 'relied upon all of the representations in Paragraph 9 of the Third Amended Complaint about the academic credentials and background of L. Ron Hubbard as a graduate of George Washington University, Princeton University and a nuclear physicist. I specifically relied upon his naval background, that he was a 4 year, wounded, combat officer, who healed and cured his war wounds with Scientology, Dianetics and Auditing. I specifically relied upon the fact that the Church of Scientology was a scientific organization, that its publications such as set forth in Paragraph 7 said, it was anexact science, such as chemistry, biology, etc., which science was developed by a scientist and nuclear physicist, L. Ron Hubbard. I was specifically told that Scientology used the term "Church" and "Religion" only for "tax purposes" and "for the Government"; and throughout the period 1971-1979, everyone who was solicited by the "Church" in Las Vegas that I knew was told the same thing, namely that Scientology was only a "religion" for tax purposes, but it was not based on faith but on science as exact as physics. It was "Church" policy to tell new recruits called "raw meat" that a Catholic, Jew, Protestant, etc. could join the "Church" of Scientology because it was a "science", not a "religion". In fact, -6- there is a specific, written "Church" policy which states that the "religious nature" of Scientology, "is entirely a matter for accountants and solicitors" It was common knowledge and "Church" policy at the Las Vegas Org, at the Church of Scientology of California, "Flag" headquarters in Clearwater, Florida and wherever the Church operates, that the "religious thing", which was also referred to as the "Minister' s Mock Up" and was a cover to protect the "Church" from the government. I was also told that the "religious thing" only meant that Scientology obeyed the law and worked to help mankind, but no belief was necessary. 11. The representations made to me which are set forth in Paragraphs 9 and 12 of my Third Amended Complaint were made and I relied upon them in a wholly secular nonreligious context. I would never have paid money or joined the Church if I was told it was a "religion". Later, after being in the "Church" for many years it was common knowledge among the staff hierarchy and it was always "Church" policy coming down from our superiors that the primary objective was to tell people anything to get them into the "Org" and "get their money". 12. The position asserted by the Church of Scientology in Court that it is a religion and that its members, -7- including me, joined and paid money to it on the representation that the "scientific basis of auditing" etc. was really a matter of religion or faith is an utter falsehood. \ There was no religious context of any nature in the making of any of the 'representations, promises and "guarantees" made to me. 13. In the Clearwater hearings, I answered a question asked of me about whether the Church of Scientology held itself out to be a religion in the affirmative, which only meant in that context that the Church holds itself out to the government to be a religion for tax purposes. This is the policy of the Church. There is no reli~ous context to any promises or representations made during the solicitation process or while a member. 14. For example, the excerpted portions of various Scientology publications set forth in Paragraph 7 of my Complaint are merely a small number of examples of the type of representations made in Scientology publications to solicit people to buy them and take courses. Those representations and thousands of others are made on one uniform premise: "scientology is an exact science on the order of the physical sciences developed by a Scientist, L. Ron Hubbard." -8- 15. When I paid thousands of dollars to the "Church", contributed 5 years of work, I did so on the continuing representations that we were building a scientific organization, that I would be paid, that I would work directly with Hubbard, that my medical, dental, and living expenses would be provided, that my career and educational oppcrtunities would be expanded. This is what everyone is told. I did not pay $13,000 for courses on the representation that Scientology was a religious faith to which if I should make a contribution, I would be saved and would live "eternal life". This is the impression the lawyers are trying to create in the Courts. That is an outright fabrication. I paid money and other people paid money because we were "guaranteed" we would get specific, earthly benefits, like a higher I.Q. That is the only context in which Scientology sells its courses and solicits people on the street. No one would have paid anything if we told them they were buying "religion". The "re!igous" position now asserted before the Court, as Hubbard says "is entirely a matter for accountants and solicitors". We operated a business to make money, and sold specific books, courses and material for specific prices based on specific representations that Scientology would "scientifically guarantee" specific benefits, such -9- ** AFFIDAVIT ** HANA WHITFIELD 661N. Occidental Boulevard Los Angeles, California 90026 Au9ust 8, 1989 My name is HANA ELTRINGHAM WHITFIELD. I was in Scientology for 19~ years from March 1965 to August 1984. The majority of those years, particularly the last 10 were filled with great emotional, mental and physical trauma. This experience ~›as the most humiliating and degrading one I've ever experienced. I still suffer from frequent nightmares, emotional distress and severe headaches because of it. I first joined Scientology in March 1965 in johannesburg, South Africa. I read Hubbard's book, DIANETICS, THE MODERN SCIENCE OF MENTAL'HEALTH and it captivated me with its promise of being the first real science of the mind. It promised that man could free himself from all reactivity and achieve a God-like state called Clear. It promised that man would never again suffer any physical disease, infection, ache or pain and that he would thereafter always be in perfect mental, emotional and physical health. It promised higher I.Q. and much, much more. Toward the end of the same year, I was in England doing further studies in Scientology. In 1967 I was invited to join the elite of Scientology in a new project of Hubbard's - the SEA PROJECT. Hubbard started the venture for t~o main reasons - to escape the law and to run his international Scientology empire without interference. By October 1967, the Sea Project had been formulated by Hubbard into the SEA ORGANIZATION and those on board the first ships who wished to stay signed contracts for a billion years of duty to Hubbard and his cause. The first six months aboard the SY AVON RIVER (SY = Steam Yacht) with Hubbard were pleasant and exhilarating. The fearful moments I experienced were during Hubbard's frequent psychotic outbursts of fury, during which he screamed and threatened for minutes and sometimes for several txours without ceasing, and other occasions where crew were brutally punished for errors and mistakes. One such example had to do with 2nd Engineer, Terry Dickensen, a tall and kindly Australian. Terry had failed to install a Sharpes ship-to-shore radio on the AVON RIVER bridge according to Hubbard's schedule, and the Ethics edict Hubbard issued as a result horrified me to the core. It stated that Terry could not eat with the crew until the Sharpes had been obtained from New York and installed on the AVON RIVER bridge. Further, Terry was denied any sleep until the Sharpes was installed, no matter how long it took. If he did sleep, the penalty of not eating with the crew would become permanent. Furthermore, he would have to sleep on deck for all time without pillow or blankets. I was the Officer in cllarge of crew ethics and morals at the time and was expected to enforce the ethics order. It took five long, very long days and nights before the Sharpes arrived from New York and was installed. During that entire time, Terry and I did not sleep. I didn't sleep to be certain that Terry didn't. Terry never recovered from the experience and left the Sea Organization shortly thereafter, a broken man. A while later, Hubbard broke up a strong relationship I had with another Sea Org member. (I was not aware at the time that Hubbard routinely surrounded himself with women executives and bitterly resented one of them leaving the job to marry.) 3 In early 1968 "0T 3" was released. OT 3 is a secret upper level counseling procedure that says thousands of souls of people who died 75 million years ago are attached to your body. I was eligible to start on it shortly after its release. I remember my amazement ~,~ben I first read the materials and the story of OT 3. I thought it was a joke, or a figment of Hubbard's sci-fi imagination. However, I dutifully made myself read and reread and restudy the story and tried my hardest to counsel myself on the level honestly. (All adverse reactions to the counseling materials are thoroughly explained in Scientology - Hubbard states that those unable to audit the materials have drugs problems, have earlier auditing actions left incomplete, are connected to a suppressire person, have undisclosed misdeeds or a host of other ills). I finally completed the level later that year. Thus, thousands of souls from people who had been dead about 75 million years had been freed from my body to go, each one separately, incarnate and live his or her own life. It took me many, many years after I left Scientology to realize ~vhat a scam it and its auditing procedures are; to realize that the procedures all utilize techniques to induce increasingly deeper trance states and rapidly bring about "auditing junkies" who only live for their next "high". Victims of Scientology who continue in its altered states of consciousness wind up being programmed robots, spending all their time, energy and money in Scientology. Later in 1968, I was order to sail with the AVON RIVER from La Goulette, Tunisia to Melilla, Spanish Morocco, to ~ind up several incomplete projects left there during- a recent visit of the Flagship. The AVON RIVER was not sea worthy. She had a faulty boiler input pump and the high pressure cylinder rings in its steam engine kept breaking. As the Captain, I reported the fact to Hubbard. He immediately assigned the vessel and all crew a condition of Liability, (the ship being a liability as it could not sail). The entire crew and myself were up for seven days with only two to three hours of sleep each night, disassembling and cleaning the condenser, emptying and cleaning out the huge boiler, the steam lines from the boiler to the main encgine and lines from the engine to the condenser - a mammoth job. After seven days, I was threatened by one of Hubbard's aides with an even lower condition if we did not sail within 24 hours. To avoid additional duress and punishment, I had the engine room rapidly put toegerber again, had some old and very worn piston rings installed and allowed the AVON RIVER to sail so that ~e could get away from I,a Goulette 'and the crew could get some much needed sleep. In March 1969, I was assigned to the Advanced Organization in Los Angeles as its Commanding Officer and later that year assumed the position of Deputy Commodore. Both postings ~Tere made by Hubbard. It was a harrowing job. The streams of orders I received on a daily basis from the Flagship often contained ten to fifteen contradictory orders from Hubbard's senior management staff. Worse yet, the orders had to all be executed NOW, so attempting to query and coordinate them with management proved fruitless. In addition to the administrative dilemma I experienced at that time, Hubbard ordered me to return to OT 3 and continue auditing on the level. I did so hesitatingly, but complied as, of course, "Hubbard knew best" During the remainder of 1969 and the whole of 1970, I audited on the level almost daily. I gradually felt worse and worse mentally and emotionally and physically. I felt as if my personality was becoming fragmented, as if I was splitting' 5 up into hundreds of different "me's" I felt devoid of energy and will and interest in doing~ anything. I only wanted to ~et away and sleep and forget about Scientology and the Sea Org world I was living in. I was terribly worried and fearful about what ~as happening to me; but even though I reported it frequently, I was told by several case supervisors to just carry on. So I continued to believe that time and persistence would solve the difficult circumstances. They did not, of course ... and months later and well into 1970, I was no longer aware of my earlier consideration. I was only intent on doing what work I could get done and keeping my energy and will high enough to do it. I felt mentally and emotionally drained, dull and lifeless. I did not know why. It bothered me immensely. Upon return to the Flagship at the end of 1970, I was assigned as one of Hubbard's several executive aides. I fought on through the weariness and tiredness that I felt inside myself continually for the next few years, through the ups and downs of being in and out of favor ~ith Hubbard, the disgrace of another Co~m~ittee of Evidence and being forbidden by Hubbard ever again to hold an executive position. But that passed also and before I knew it, I was back in favor again. In early 1974, Hubbard instituted the Rehabilitation Project Force - also known as the "RPF" - on board the Flagship Apollo. To it ~as assigned anyone who Hubbard felt might be a plant or a covert operative against himself, or anyone ~ho had bad thoughts about him. The RPF was represented as a place, a group, where those assigned to it could rehabilitate themselves using Hubbard's techniques. In actuality, it was a type of slave labor camp ~hose members lived, ate and worked in squalid, 6 degrading conditions and who were utterly forbidden to talk to anyone but their own kind. They were completely segregated from normal crew. One evening I saw its members on the aft deck. They were eating with their hands out of buckets containing leftover food - they were standing around a large pot of leftovers shoveling them into their mouths with their hands as if they were starving. I developed a very real horror of the RPF and what it represented and a slowly growing fear of Hubbard and the organization from that point onward. During the early 70's, Hubbard supervised my auditing personally for several years. I was in session almost every day. I gradually became more and more convinced that I_ was the cause of the auditing "not working"'on me, that I was stopping it from being successful even though I did not know how I was doing it. It was firm policy that Hubbard could do no wrong- - ever, that the auditing techniques be had devised were never wrong - ever, and that the auditor applying them was rarely wrong. In the face of such totalist belief, which I completely believed at the time, the only possible cause of the failure was myself. Then one day in 1974 durin9 another round of auditing sessions ordered by Hubbard, I got a bad headache. Nothing that was done that day got rid of it. It continued thereafter ... and continued daily for the rest of the week ... and continued the next week ... and week after week thereafter ... and from that time on I had a headache almost constantly for 10 years. It would get so bad two or three times weekly that I was not able to work. The only ~ay I could tolerate the intense throbbin9 pain was to sit in my bunk with. my chin on my knees and wait out the one to three days it took for it to dull enough so I could return to work. Durin9 this period, I gradually got more and more 7 paranoid about my "evilness" Because the cause of the headaches could not possibly be Hubbard or his philosophy or his technology, it HAD to be myself. It HAD to be something I had done or said at some time in the past, or something bad or evil about myself that I had not yet had the courage to face up to. Hubbard ordered the auditing to be continued but it never got rid of the pain. Sometimes the headache improved slightly and at other times it worsened. But it never left. From late 1975 to March 1982, I lived and worked at the Fort Harrison Hotel, at 210 South Fort Harrison Avenue in Clearwater, Florida. The Sea Organization had moved ashore in late 1975 to its new headquarters in Clearwater, Florida. Hubbard orchestrated the entire move, including the use of front names so that Scientology could move into Clearwater incognito. His personal intelligence agency, the Guardian Office, which ran overt and covert operations against anyone who dared come up against Hubbard in any way, assisted with the deception during and after the move. From October 1975 onward, I held several senior positions at Flag, this being the name for the complex of organizations which existed at the Fort Harrison Hotel and other buildings close by. I was an Officer of the Flag Service Organization, the senior-most organization in the United States which counseled and trained Scientologists. As a staff member during this period, I was aware of the public outcry against Scientology from time to time. I and other staff at the Fort Harrison Hotel were briefed by senior Sea Organization or Guardian Office executives as to what was happening, who was at fault and why, and the positioning and conduct that we, as staff, were expected to uphold. During these years, I was completely unaware of the covert operations run by the Guardian Office against the Clearwater Mayor Mr. Gabriel Cazares, or against Scientologist Mike Meisner, or that Scientology senior management discussed murdering Mike Meisner and "deep sixing" him to prevent him from getting to the FBI and spilling his guts about the covert operations Hubbard's Guardian's Office and he had been running against every major branch of the United States Government including the FDA, the AMA and more, and the covert operatives placed in many government agencies including the Justice Department. I was also unaware of the covert plan and operation that cost Scientology $250,000.00 to compromise Florida judge Richie at a time when he was sitting on a case against Scientology. Fortunately, that Guardian' Office operation failed. During my years in Clearwater, I was aware the Scientology was deeply disliked and resented by the Clearwater public as evidenced by their protest marches around the Fort Harrison Hotel. I was told by Guardian Office representatives, as were all staff, that the resentment was being stirred up by Scientology's enemies such as the Mental Health institutions, the FBI and the CIA among others. I believed the information at the time as it was the only information I had. All staff were forbidden to read newspapers and magazines in a successful effort to preclude those that contained bad news about Scientology. We were also forbidden to watch TV, and TVs were being methodically stripped from all rooms in the Fort Harrison Hotel. My emotional and mental health continued to gradually worsen throughout the years in Florida and I battled to put up a "normal" front. I continued working to the best of my ability. Often I had to leave work due to the intensity of the pain. I started getting suicidal as I could see no other way out of the condition I was in and I was convinced the cause was within myself. From time to time and particularly when the headaches worsened, I mulled over how I would kill myself. I decided that to safeguard the good name of Scientology (I had no idea at that time how deeply and completely deceived I had been all those years about Scientology and Hubbard) I would end my life at some location distant to Clearwater and destroy all identification beforehand. I made these thoughts known to my auditors, and carried on as normally as I could outwardly. Then in 1978, I was assigned to the' Rehabilitation Project Force at the Fort Harrison, the Sea Organization's slave labor camp. I was assigned to it because I had evil thoughts about Hubbard and the Sea Organization. I was utterly shocked and devastated. I was escorted to the RPF location between two heavy men, both well over 6' tall. I was locked up for about 24 hours in ~ room with no windows. I was under continual guard during' that time and slept on a mattress on the floor without sheets or blanket. I was shocked and awake the entire night sometimes weeping and other times completely numb, devoid of all feeling or thought. I had a crazed urge to escape but knew I could not, that I had to finally confront myself and discover how evil and truly bad I was. I felt I was split into several people - one of them a kind, loving person who was in deep shock, the other a cold, calculating, evil-minded person who was intent on harming others for the fun of it, and yet another person who was terribly confused and did not know which of the other t~o was correctly me. I felt my mind was being ripped apart, that I could not think or feel anything. I forced myself blindly through the routine of having' to run 10 continually (RPF members were not allowed to walk at any time), of having to talk to non-RPF staff only when spoken to, of having to address everyone as "Sir", of having to do menial work of cleaning toilets, of having to wear old, torn and tattered blue overalls, of having' to be seen running in the Florida heat, perspiring and without makeup or hairdo, doing menial and embarrassing work in front of all the public - in pain all the time. I requested to go in front of a Review Board. The Board was disinclined to see me personally. It found my assignment correct and ordered I remain in the RPF. RPF members at that time were completely segregated from "normal" staff and slept, lived and' often ate in the Fort Harrison garage in the midst of continual exhaust fumes. They were not allowed to talk to, mix with or eat with "normal" staff. They wore old, tattered, ripped up navy jump suits or boiler suits and looked like derelicts from skid row. Women were not allowed to use any makeup or have any hairdos. No jewelry was allowed. Even in the incredible hot and humid Florida summers, women ~ere not allowed to wear short cut-offs but had to wear longer shorts or skirts or long trousers. No clothing lighter than the heavy material the jump suits were made from could be worn intitially. RPF members had to run all the time. They were not allowed to walk. They had to run while doing their cleaning assignments in bathrooms and toilets, while doing the garbage details or while going up and down the 12 flights of stairs in the Fort Harrison building carrying buckets, brooms and heavy cleaning equipment, and sometimes buckets full of heavy construction material. RPF members were not allowed to use the elevators, not even the service elevator. 11 To prevent zoning, health and other city inspectors from seeing the RPF conditions as they really existed, all RPFers were practiced and skilled in transforming their normal RPF sleeping areas into what looked like a regular furniture storage space, and doing so in a very short period of time. I often wished that someone from the city would spring a surprise visit on the Fort Harrison kitchen or garage or nursery but it never occurred. This is how we really lived in the RPF. Some of us slept on thin mattresses on the bare cement floor. Some had crude bunk beds. There was no place for clothes, so we lived out of suitcases and bags which were kept on the bare floors. Some privacy was maintained by' hanging sheets up between bunk beds and between floor mattresses. The women and men had separate bathrooms and toilets but they were small. We were not allowed to shower longer than 30 seconds. We had time only to run through the shower and out the other end. There was no spare time for talk or relaxation. We awoke at 6:30 A.M. or earlier at times, did hard labor and heavy construction work and cleaning until late afternoon. After 8 quick shower and change of clothing, we had to audit each other and "rehabilitate" ourselves until 10:30 P.M. or later each evening'. There were no days off, no vacations. We worked seven days a week, four weeks a month. We ate our meals in the garage or at times in the dining rooms AFTER normal meals had ended. Our food consisted of leftovers from staff. On occasions which seemed like Christmas, we were able to prepare ourselves fresh meals if leftovers were insufficient. The RPF maintained a very strict reform code which tolerated no insubordination or resistance of any kind whatsoever. Any instance of such was dealt with by 12 immediate push ups or running up and down the garage inumerable times. The slightest infraction earned hard and harsh penalties. Every rule had to be followed regardless of its correctness or applicability at any given point in time. Certain infractions caused the person responsible to be assigned to the RPF's RPF, a place in the lower boiler room under the Fort Harrison Hotel, among the boilers and hot water pipes which rumbled and hissed twenty-four tlours a day. The place was only dimly lit. It consisted of interconnecting- spaces through which one had to crawl on hands and knees at times past or underneath huge pipes and massive 10 foot high boilers. It was a dark, forbidding, somewhat scary place. One of my buddies'was assigned to the RPF's RPF for two months for refusing to divulge confidential information for which she had been bonded in the Guardian's Office. She was kept in that space excommunicado for the entire time, with limited bathing and toilet privileges, all the time being threatened and verbally harassed by RPF superiors. She finally emerged a broken, silent, sullen person who soon after managed to escape from the RPF and the Fort Harrison Hotel. Her name was Lynn Froyland. I have never seen her since she left. The RPF had been established for the stated purpose of "rehabilitation and redemption" It was made to appear as a constructive and positive activity, devised to help the individual at a time when he was unable to help himself. However, it was Hubbard's belief and practice that force, duress and punishment were necessary and vital to cut through human emotion and reaction so as to rescue the soul or thetan. I believed Hubbard. But I was experiencing such humiliation, such degradation and worthlessness in the RPF that Hubbard's theories began to make less sense to me. I 13 entered into a profound confusion and a deep emotional and mental instability which continued onward almost continually up to the time I left. To compound the situation, Hubbard states categorically that criticism is a sign that one has committed a harmful or destructive action on the person or area one is critical of. This belief has high credence in Scientology and is rigidly adhered to. It is common for staff and public to receive extensive confessional auditing and security checking if they are found to have the slightest criticism of Hubbard. I now know that this practice is a very effective thoughtstopping technique and that it is solely aimed at reforming the individual's thought patterns and his conduct and was never intended for his enlightenment. I'had no knowledge of this at the time I was in the RPF, and had I been told it at the time, I would have vehemently denied it as would all Scientologists. Throughout my period in the RPF, I felt more and more degraded and worthless the more I tried to reconcile the slavery of the RPF and its blatantly anti-social activities to Scientology being the only road to total freedom. I laboured hard during many auditing sessions to find the harmful actions I had committed to cause me to become so full of pain and negative emotion. Toward the end of 1978, I finally escaped. I left the RPF without approvaland flew to New York to friends. But within a week the senior Ethics person at Flag, Tom Provenzano, located me and by phone threatened me with a Suppressire Person declare and with being sued, followed and never being left in peace again for the rest of my life if I did not immediately return to Clearwater. I broke down completely. I flew back to Clearwater and to the RPF, but 14 only after Provenzano had promised me I could speak with him about my assignment to the RPF when I returned. Of course, no such thing occurred. I had no idea that his "promise" was made solely to get me back to Clearwater. Once back in the RPF I succumbed. I returned to working and running and sweating and pain. After a year, I finally graduated. I was a subdued quiet, obedient robot, a far more subservient and compliant one than at any time previously. The headaches were a continuing part of my day to day life. By that time the fear I was evil had somewhat subsided but not left. "Graduation" acted as a momentary panacea. I curried fayour with my superiors constantly as a way to survive. I refused to return to any executive position again and was finally approved to counsel or audit others. I audited continually and well for several years, and even earned an "Auditor of the Year" award in 1980 in Clearwater. The intensity of the head pains increased at times and diminished at others. I received auditing from time to time, always on the orders of others and none of it making any noticeable difference. The suicide tl~oughts continued as well. I desperately hunted for a way out of my situation. I desperately wanted time to sleep, rest, think and, above all, escape from the madness of the world I was in. I had no one to go to if I left, no money to go anywher with and no~here to go to anyway. My family lived overseas. I had no means to get to them and they had no means to assist me. If I left I knew I would be declared a Suppressire Person which ~ould automatically deny me contact with any of my Scientology friends. I was a resident alien in America and didn't know how to market myself to get a job. I felt utterly trapped by the circumstances I was in. 15 Then an old friend of mine with whom I had had a relationship in 1967, made contact with me in the middle of 1981. After meeting several times, he proposed marriage and I accepted. From that point on I made secret plans to leave the Fort Harrison and get back to a normal life. I finally left at the end of March 1982, after three harrowing months of security checking, being screamed at, being threatened, being asked angrily and threateningly over and over again while hooked up to Scientology's lie detector, whether I was in contact with the FBI, the CIA, the US Government, the Mafia, the Secret Sercie, the AMA, the FDA, the AFF, or with hundreds of named Scientology dissidents. I was accused of being in their pay. I was threateningly asked ~hether any of them ~ere paying me. I was angrily accused of being in phone communication with them. None of it was true. I painstakingly wrote down every misdeed I could ever remember committing and worked long hours late in the night, night after night for a week, "to make up the dreadful damage I had caused". I started making up, imagining greater and worse misdeeds in my written admissions to try to reach the "evil" in me again. Not even that worked. I left after realizing that enough was enough, and that I would no longer subject myself to the unbelievable abuses and threats which had been thrust at me both verbally and in writing all in the name of "saving my soul"; threats that I would be sued, I would be expelled, I would be declared a Suppressire Person, I would die, I would be ordered to a Committee of Evidence (a trial), that I had to work in the main kitchens, that I was being assigned to the RPF again, that my eternity would be taken away from me, and that I would never be left in peace again for as long as I lived. 16 I finally walked out of the Fort Harrison Hotel toward the end of March 1982, the threats of security checkers and ethics superiors echoing' in my footsteps. My marriage fell through. My fiance was terribly harassed and threatened by Scientologists from Clearwater and did not stand up to their pressure. I left him as cleanly and quickly as I could and made my way on my own. I had left staff and employment with Scientology and the Sea Organization, but I still considered myself a Scientologist and therefore followed a Policy of Hubbard's to be accepted back into Scientology in good standing. The program has five steps, steps A to E. I did them all extensively, and have copies of them as bubmitted. By the end of 1983, I was accepted back into Scientology in good standing. I thereafter worked for Sterling Management in 1984 for a short period, was horrified to find myself embroiled in similar situations as that at Flag, and after completing some assignments, left. In August 1984 I decided to leave Scientology forever, a decision I have been extremely and deeply thankful for. It's only been since late 1984, early 1985, that I started to learn about the dark side of Scientology and the skillful thought reform and mind control that it practices on all its adherents. I have now completed extensive dental work to remedy the years of sporadic and inadequate dental care allowed in the Sea Organization and I am under medical care for the headaches. My life is nosy worth living once more. I am one of the lucky ones. ================================================================= If this is a copyrighted work, you are acknowledging by receipt of this document from FACTNet that on the basis of reasonable investigation, you have not been to obtain a copy elsewhere at a fair price, and that you are and will abide by the following copyright warning. WARNING CONCERNING COPYRIGHT RESTRICTIONS: The copyright law of the United States (Title 17, United States Code) governs the making of photo copies or other reproductions of copyrighted material. Under certain conditions specified by law, libraries and archives are authorized to furnish a photocopy or other reproduction. 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