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Copyright © 1994 Andre Tabayoyon
Attorneys for Defendants
CENTRAL DISTRICT OF CALIFORNIA
CHURCH OF SCIENTOLOGY Case No. CV 91 6426 HLH (Tx) I, ANDRE TABAYOYON, declare as follows: INTRODUCTION 1. I am over the age of 18 years. 2. I have been retained as an expert consultant and expert witness by Dr. Geertz's counsel in the case captioned Church cf Scientology International v. Steven Fishman and Uwe Geertz, No. CV 91-6426-HLH (Tx) currently pending in the United States District Court, Central District of California. The statements herein are of my own personal knowledge or reasonably based on information and belief, and if called upon as a witness, I can testify competently thereto. 3. This declaration is submitted in support of defendant Dr. Uwe Geertz's motion for costs, attorneys' fees and sanctions. 4. In preparation for this declaration, inter alia, read the declarations submitted by David Miscavige ("Miscavige") , Marc Yeager, Ray Mithoff, Guillaume LeServe and Norman Starkey in an effort to persuade this Court that CSI has complied with the orders of the Magistrate Judge and this Court to attend depositions. 5. Since being designated as an expert witness herein, I have become aware of the presence of myself being under surveillance. On a trip to Arizona I was followed by a van and a car. In Mesa, Arizona I was followed to breakfast and the person was even aware that we knew he was watching us. While in Newport Beach we were followed to and from Mr. Berry's office daily. I am currently in my home and there is a blue late model pontiac waiting to follow me wherever I go. PERSONAL SCIENTOLOGY BACKGROUND 6. Before I became a Scientologist, I enlisted in the United States Marine Corps. I served one tour of duty in Vietnam. I was in the infantry and assigned as a scout to secure sites, often behind enemy lines, from which Marine snipers would eliminate targets using specially constructed sniper rifles. It was also my responsibility to get the highly trained and therefore very valuable snipers back safely to allied lines. Because of the high likelihood that I would be operating for extended periods of time behind enemy lines, I received escape and evasion training both in the Philippines and in Vietnam. In addition to escape and evasion training, I also received instruction on how to resist anticipated brainwashing and coercive persuasion techniques likely to be employed if I was captured alive. Because of the covert nature of the operations to which I was assigned, I was also trained how even the most innocent utensils could be used to end my own life and thereby prevent any captors from extracting information that might compromise my mission or my country. My missions required that I kill a number of Vietnamese, including some at close range, some of whom died in my arms. These events left a lasting and negative impression on me. 7. After returning from Vietnam, I was plagued by nightmares and other disabling memories of my experiences as a front line combat fighter. When I returned post traumatic stress syndrome was not well understood. The military and veteran's hospitals provided almost no assistance to me or a number of my companions who suffered from similar problems. I was determined not to descend into the depths of degradation that followed from the abuse of narcotics and other drugs, whether legal or illegal. 8. While I was in this unsettled state, I was recruited into Scientology. The attraction was, in part, the promise that Scientology would provide me with the means to deal with these disturbing memories and nightmares. 9. Various forms of coercive persuasion are used in all areas of Scientology. A working term in Scientology is registration ("reg") cycle. During a reg cycle, parishioners are coercively persuaded to do something which a senior Scientologist believes will be good for Scientology. In my 21 years of membership in Scientology, I personally observed how auditors and others identify a person's "hot button." I saw how auditors used many individual's hot buttons in the various types of interviews (ethics, chaplin, registration, counseling, etc.) to coerce the parishioner into donating money, doing the next service, joining the Sea Org, going to the RPF and agreeing to forego spending time with their children and families in order to devote greater time and effort to the good of Scientology. 10. After joining Scientology, I became a member of the Sea Organization ("Sea Org"). A Hubbard Communications Office policy letter defines the Sea Org as: "The elite religious fellowship within the Church of scientology. The Sea Org is not incorporated and is not part of any corporation. Its membership is involved in Churn management and the delivery of the higher level services of the Church." Finance Series 11R. Exhibit A. 11. The indoctrination I received in the Sea Organization was extensive. It fully acquainted me with the coercive methods that Scientology uses on its staff and public. My training included the following courses which had the content as indicated below: (a) FLAG EXECUTIVE BRIEFING COURSE - All the policy ever written by Hubbard about the running, debugging, and if needed, the creation of a complete organization using thought reform ideas and practices in conjunction with coercive persuasion on the staff and public. (b) ORG EXECUTIVE COURSE - All the policy ever written by Hubbard about the running, debugging, and if needed, the creation of a complete organization using thought reform ideas and practices in conjunction with coercive persuasion on the staff and public. (c) SEA ORG OFFICER TRAINING - This course covered all of the Flag Orders, Flag Ship Orders, Central Bureau Orders, mission school tech and included all of the policy written by Hubbard about creating, running and debugging a complete Scientology organization using thought reform concepts and practices in conjunction with coercive persuasion on both staff and public Scientologists. (d) REHABILITATION PROJECT FORCE INDOCTRINATION TRAINING - (e) REHABILITATION PROJECT FORCE SECTION OFFICER HAT - (f) REHABILITATION PROJECT FORCE MASTER AT ARMS HAT - I learned in the above course(s) how to use thought reform processes to make persons amenable to persuasion. (g) REHABILITATION PROTECT FORCE TECH IN CHARGE HAT - I learned how to administer various thought, ideological and social reform procedures to reorient now compliant subjects of thought reform- to accept Scientology goals as articulated by Hubbard and/or Miscavige. (h) REHABILITATION PROJECT FORCE QUAL IN CHARGE HAT - This training taught me how to recognize misapplication of thought, ideological and social reform procedures so as to maximize the effect that coercive persuasion had on subjects under my supervision. (i) REHABILITATION PROJECT FORCE CASE SUPERVISOR TRAINING - I was taught how to use thought reform procedures to change the most fundamental aspects of a subject's personality and exact a commitment from the subject to further Scientology's goal of clearing planet Earth. (j) REHABILITATION PROJECT FORCE AUDITOR TRAINING - I learned how to use thought reform to coerce subjects into confessing their crimes and sins against Scientology as a step towards their "rehabilitation" as dedicated Scientologists. (k) ROLL BACK TRAINING - I received training on how to trace rumors, statements of disaffection or anti-Scientology thought back to its source so that it could be obliterated and sources of disaffection eliminated. (l) BLACK PR RUNDOWN TRAINING - This training was to teach you how to find out who is spreading negative information and to fully handle him with coercive mind practices. I learned how to ferret out negative information about Scientology; once found out, those who are guilty become targets for internal "Fair Game" tactics such as the RPF's RPF. RPF or general mental abuse. (m) TRUTH RUNDOWN TRAINING - I learned how to use thought reform to correct improper conduct by persons spreading rumors or black PR about Scientology. (n) INTROSPECTION TRAINING - I learned Scientological techniques to reach persons who had suffered psychotic breaks during the thought reform process. Persons in this condition were not capable of relating to the real world. For the most part, introspection training focused on limiting the stimuli to which the victims were exposed with the hope that over time they would recover. (o) FALSE PURPOSE RUNDOWN TRAINING - These are a whole series of thought reform practices used to change people's way of thinking. I learned how to supervise auditors reforming thoughts of people, while on the RPF. (p) FALSE DATA STRIPPING TRAINING - This is a technique to ferret out and remove out tech (Non-orthodox Scientology) ideas and to replace the out tech ideas with Hubbard's information. (q) EDUCATION PROCESS KTL -This is a major training ordeal where the person is completely re indoctrinated in the basic grammar and use of the English language to communicate Scientological principles concisely and correctly. (r) TOO GRUESOME TRAINING - This training teaches a supervisor how to instill complete terror and abject fear in subordinates so that the subordinates will comply with the supervisor's orders without question. I have been a member of various Churches of Scientology for 21 years from 1971 to 1992. During this time, I received extensive and intensive training as a Scientologist. 13. I was also a member of the Sea Organization ("Sea Org") , which I joined in 1972. The Sea Org is a fraternal organization of Scientologists zealously dedicated to the protection and advancement of Scientology and its leaders. Sea Org members are expected to get their assignments completed regardless of the obstacles. The staff of CSI, RTC and all Scientology organizations above Class IV Orgs are Sea Org members. 14. Hubbard established the Sea Org as an international solution to periodic insolvencies which had afflicted various Scientology organizations during the first decades of Scientology's existence. 15. Within Scientology, Sea Org members have unquestioned authority over the affairs of Scientology organizations. This authority is exercised in a number of ways. First, Sea Org members can be sent into any Scientology Organization, or business owned by a Scientologist, organization or a mission. Historically, Guardian Office Missions and Sea Org Missions were one and the same. When Sea Org members are on a mission, they have full ethics powers to take whatever steps are necessary for the greater good of Scientology. CMO Int Messengers (commodores messenger organization International Messengers) are always on Mission so they had full authority to issue whatever orders they deem appropriate. CMO Int Messengers had the full authority of Hubbard when he was alive. Hubbard was then Commodore of the Sea Org. Now they have the full authority of Miscavige. 16. The Sea Organization is to Scientology what the Communist Party was to Soviet Russia and the Gestapo was to Nazi Germany. Indeed, Sea Org members were not allowed to read communist doctrines, or magazines and books about mind control and thought reform because of the similarity to the Sea Org life that these documents present. 17. I signed the standard Sea Org contract requiring me to serve the Sea Org for one billion years. This I would do by serving the Sea Org in every one of my future lives with 21 year vacations at the commencement of each life, so that the contract would not be void for incapacity due to youthfulness or infancy. 18. As a Sea Org member, I received thousands of hours of training in basic Sea Org policy. In 1977 I was assigned to the Rehabilitation Project Force for 18 months. In 1980 I was assigned to the RPF for another 2 1/2 years. In 1987 I was again assigned to the RPF for another 18 months. Accordingly, I spent approx. six years in total on the RPF. During these six years I also spent time --19 full days-- on the RPF's RPF. The RPF's RPF is designed to totally destroy any individual determinism to not want to do the RPF. RPF is a totally involuntary type gulag or concentration camp. In order to get out, and stay out, you must prove that you have altered the ideals, morals, social and emotional and attitudinal values of another member of the RPF of a long duration as evidenced by the physical actions and motions of the person so altered. One must also prepare written evidence in the form of success stories of how wonderful and voluntary the RPF was. During my six years in the RPF, I spent five hours a day studying and receiving instruction in Scientological matters. During the fifteen years I spent with the Sea Org, when I was not on RPF, I spent two and a half hours a day studying and receiving instruction in Scientological matters. Applying simple math, I estimate conservatively that I received over 28,000 hours of Scientology study and Scientology instruction. My exposure to Scientology thought reform processes was enhanced by other processes to which all Sea Org members are exposed. These included: (1) indoctrination at daily musters; (2) briefings; (3) missions; (4) Scientology justice actions; (5) crusades; (6) security or sec checking; and (7) auditing. Auditing is the central practice of Scientology. It involves the E Meter which is a simple electrogalvanometer similar to, but not the same as, a lie detector. One holds two tin cans attached to the E meter and goes into a hypnotic state at the command of the auditor. These hypnotic states include those called reverie and revivification. 19. I also studied and received instruction about Scientology Policy, and Sea Org policy called Flag Orders. Information which appeared in green printing on white paper and is called Hubbard Communications Office Policy Letters ("HCO PLs"). I also studied and received instruction about Scientology Technical Policy. This information appeared in red printing on white paper and is called Hubbard Communications Office Bulletins ("HCOBs.") I also spent hundreds of hours listening to lectures taped by Hubbard. These tapes included the Flag Executive Briefing Course tapes, the OEC tapes, the Human Evaluation tapes and the Establishment Officer tapes to name a few. 20. During my 21 years as a Scientologist, I also had many occasions to see how these Scientology policies were applied in many different contexts. The Hubbard Technology, often called Tech, was used to supposedly help people. It was also used coercively to control the behavior of people and to punish them for real or imagined transgressions against Scientology. 21. During my tenure with the Sea Org, I held many posts. The various posts or positions I held during my association with Scientology included:
a. Commanding Officer, Master at Arms; CONSTRUCTION PROJECTS AT HEMET BASE While I was on various posts at Gold, near Hemet California, I was also responsible for the following construction projects. a. Constructing a full scale replica of a clipper ship complete with sauna and jacuzzi. This was in the desert; b. Construction of kitchens and dining facilities in all the office facilities at the Hemet base; c. A 20 Or 48 microphone battery lecture recording room; d. An orchestra size music recording studio; e. A film studio; f. A complete 32 seat theater; g. A complete film editing facility; h. A complete sound editing facility; i. A complete sound to film facility; j. Two voice over studios; k. A complete management office facility for CMOI; l. A complete audio facility which had four individual recording booths and three lecture mixing studios; m. A 60' x 150' file archives facility; n. A 65' x 165' tapes archives facility; o. a 150' x 350' three story manufacturing facility; p. A dining facility that could accommodate 1,100 people for a minimum of three sittings per day; q. A 200' x 500' construction and maintenance facility which houses the planning and buildings areas; r. A complete apartment complex for celebrities; s. A complete office facility for Miscavige; t. A complete lounge facility for Miscavige; u. A complete dressing room for Miscavige; v. A complete sound room for Miscavige; w. A complete exercise room for Miscavige; x. A complete security lighting system for the perimeter of the Hemet base; y. A complete deep well pump which provides 800 gallons per minute to a 16" pipe supply system for the entire Hemet base; z. A 1,000,000 gallon reservoir; aa. A 1.8 mile exercise course; ab. A nine hole golf course. ac. Several miles of paved roads. ad. Underground high voltage (12,500 volts) System ae. An emergency generation station with 750 KW or power for indefinite time. af. A complete sewer system with 2 evaporation ponds to handle 4500 people. ag. A 115 million gallon lake. ah. A tennis court for Celebs and Miscavige ai. Berthing facility for children at the Happy valley base. aj. A large well for Happy Valley facility. 23. In these various Scientology posts, I observed how the inner most parts of Scientology worked. I observed, participated in and was victimized by coercive and manipulative thought control processes designed to shape the thinking of the individuals upon whom these procedures were imposed. These practices are particularly prevalent in the Rehabilitation Project Force ("RPF") , a brainwashing and penal operation very similar to what I had been trained to expect from the Viet Cong, North Vietnamese and Red Chinese during my tour of duty in Vietnam. 24. I knew L. Ron Hubbard ("Hubbard") personally. I worked directly for Hubbard, the founder of the Scientology belief system. Hubbard was Miscavige's predecessor as head of Scientology. 25. I worked personally with Hubbard on the ship called the Apollo, from 1971-73. I personally observed Hubbard running all aspects of Scientology and Sea Org and Guardian Office ("GO") networks. Indeed, at the time I believed Hubbard has saved my life. I had been "overboarded" or thrown aboard. Hubbard then ordered that I be pulled out. Thereafter I believed Hubbard had saved my life and I became very dedicated to both him and Scientology. I served as both steward and butler for Hubbard. Accordingly, I was often alone with him -- even when he was self injecting himself in the arm with a needle and solution. This he did frequently. I would also lay out the pills he took from 10 different numbered bottles. 26. I know Miscavige. I have also worked directly for him for many years. Miscavige is a second generation Scientologist. He was born into Scientology, a high school drop out and became one of Hubbard's Commodores Messengers as a teenager. In this capacity, I have been informed and believe that he was responsible for many multi-million dollar illegal international currency transfers. He did this as an innocent looking young courier. Miscavige has never known of a life outside of Scientology. 'He is as close to a 'Rondroid' (L.R. Hubbard droid) as it is possible to be. He rules Scientology like David Koresh ruled Waco and the Branch Davidians. He endorses Hubbard's goal of Scientology taking over the entire planet including all heads of government and news media. See Exhibit____. Hubbard said "take all of the people, put them in Scientology and have them run under the processes of Scientology." Hubbard's plan is for Scientology to interface with planet earth for one person to be in charge and for the whole planet to be under a Scientology seven Division org board. 27. Miscavige is now the 'ecclesiastical' head of Scientology. He is commander of the Scientology Sea Organization ("Sea Org"). He is also Chairman of The Board ("COB") of the Religious Technology Center ("RTC"). SCIENTOLOGY IS ARMED AND DANGEROUS 28. In 1991 I had to prepare the base so that it could be defended against the possibility of being taken over by the authorities in a time of crisis. There are approx. 750 people at the base. I was in charge of a project designing the base security system, the perimeter fence, the ultra razor barriers, the lighting of the perimeter fence, the electronic monitors, the concealed microphones, the ground sensors, the motion sensors and hidden cameras which were installed and all over the area -- even outside the base. 29. Church monies were used to purchase semi-automatic assault rifles (HK 91 assault rifles capable of firing 300-350 rounds of ammunition a minute, 45 caliber pistols, .380 automatic weapons and twelve gauge shotguns were stockpiled. These weapons were not registered. Church monies were also used to buy the ammunition. 30. Church monies were also used to purchase a large amount of pounds of gunpowder for the construction of various types of explosive devices to be used in the defense of the base. 31. The motorcycle guards were trained to carry loaded cocked 45 caliber pistols. The eagle scout, mounted high above the base, was trained to carry a high powered rifle with a telescopic scope. There is also a 1,000 millimeter telescope up with 'eagle'. 32. I developed three classifications of intruder and established the level of deadly force to use for each. In addition to firearms, the guards were taught how to effectively wield little batons. The basic things like striking to the center of the heart, the center of the solar plex and then to the side of the head, etc. 33. At church expense, I trained the security guards and other base personnel in the use of these weapons and explosives. I also trained them in the close quarter use of fatal force. We built a combat range for training purposes and I instructed Scientologists on various ways of shooting people. I also trained them in night vision and ambush techniques. We used a ravine that was a natural round shield so the noise would not cause any noisy inquiries. DELIBERATE MISUSE OF THE HUBBARD TECH TO HARM SCIENTOLOGISTS WHO HAVE FALLEN OUT OF FAVOR WITH MISCAVIGE: BLACK DIANETICS REVERSE PROCESSING AND STEVEN FISHMAN. 34. During the more than two decades of experience I had in Scientology, I observed on many occasions the Hubbard Tech being used as intended to assist persons to come to grips with themselves and events, persons and things around them. However, I also observed the Hubbard Tech being deliberately misused to punish Scientologists who were out of favor with either Hubbard or Miscavige. When the Hubbard Tech is deliberately misused to cause harm, the practice is called Black Dianetics or Reverse Processing. It is my opinion that Fishman was the victim of Black Dianetics and was only saved, by the intervention of Dr. Geertz, from an imminent suicidal incident. The basis of my opinion in this regard is as follows: (a) Fishman was not a Scientology minister or minister in training yet he was sold E Meters; (b) Fishman was an illegal p.c. (preclear) because of his past psychiatric counselling; (c) Fishman was sold Scientology materials such as the whole track tapes, the Philadelphia tapes, the history of man book, auditing materials and how to use the E Meter book. This was the application of Black Dianetics because: (a) Fishman was not properly trained in the use of the E meter; (b) My experience as an RPF case supervisor in handling cases such as Fishman leads me to the opinion that Fishman was being encouraged to use the tech on himself rather than under the supervision of supervisors and auditors. This would, in MY opinion, only lead to disastrous and/or suicidal consequences. Indeed, L. Ron Hubbard in 'Some Notes on Black Dianetics' states "a person can drive himself mad on Dianetics without any trouble" ... "with Black Dianetics you could tailor make any kind of insanity you want to. The person might not manifest this the next day, maybe not for thirty days. Maybe three months later he is walking down the street and feeling a little bit tired when somebody honks just right or something of the sort, all of a sudden he goes crazy and there he is -- insane! It's a wonderfully smooth way of committing murder." Emphasis added. Exhibit. 35. My observations were direct and personal. I am a highly trained RPF auditor. When I had responsibilities for overseeing how the Scientology auditing technology is applied to cases of Scientologists assigned to the RPF, I received orders directly from Miscavige, Marc Yeager, Ray Mithoff, Sandi Wilhere and Hansuli Stalli, and others, to misuse the Hubbard Tech to create extreme mental and emotional distress and insanity in persons I was instructed to 'security or sec check'. We used the Hubbard Tech, including security checking on the E-Meter, in conjunction with well used coercive mind control techniques of sleep deprivation, starvation, dehydration and denial of decent accommodations. As an example of the appalling conditions to which RPFers are sometimes exposed, on one occasion when I was on RPF, my sleeping facility was a slab inside the vault of the morgue of the old Cedars Sinai Hospital. While on the RPF at Gold, I also occupied the chicken coop dormitory. This was an old chicken coop which still smelled of chicken coop droppings. However, it was not only RPFers who were deprived of adequate food and sleep. At Gold, hundreds of Sea Org members would be deprived of adequate sleep and put on a diet of rice and beans sometimes for six weeks at a time-and their weekly pay of approximately S30.00 would be cut in half. This would be punishment for lower ethics conditions such as poor production. However, when this occurred, David Miscavige would still eat his bacon, eggs, sandwiches and steak dinners. 36. The response of human beings to these conditions is somewhat predictable. I saw many people undergo psychotic breaks. By psychotic breaks I mean being reduced to incoherent babbling, stripping off clothes, crawling around on the ground, banging heads, limbs and other body parts against furniture and walls, barking, losing all sense of one's identity and intense and persistent suicidal ideation. This is what Scientology calls the PTS type III phenomena. There is a policy which describes this. Exh O. I have seen many PTS type III cases. It is my opinion that Fishman has been deliberately driven PTS type III by Black Dianetics and/or reverse processing. 37. I participated in deliberately inflicting this process on others in Scientology. I was a Case Supervisor on the RPF. This means that I saw the auditing folders of all the persons assigned to the RPF while I had this responsibility. I saw that the Tech was regularly misapplied for harmful purposes. The case notes prepared by auditors during auditing sessions were altered or deleted by senior executives. This prevented a subsequent auditor from properly assessing and handling the individual. It is like flying blind without instruments. The potential for doing something seriously harmful is therefore greatly enhanced. 38. I was advised by Richard Aznaran, Sinar Parman and Annie Breeder that Hubbard was an unhandled PTS III when he died. According to Sinar Parman, Hubbard was a psychopathic insane person screaming about BT's and clusters at the top of his lungs. 39. I was also ordered to audit a number of persons, including Stacy Young, while they were on the RPF. The files I was provided relating to Stacy showed that I would be auditing a stable, well adjusted person. When Stacy was led into the auditing room, I was confronted with a disheveled, irrational and incoherent person whom I hardly recognized. Stacy spent the first half hour or so of the session babbling and crying hysterically. Her folder had obviously been altered to maximize the likelihood that further auditing would harm her. 40. What I know from training and experience to be Black Dianetics and reverse processing were also inflicted on me. I survived the processing without experiencing a psychotic break. I believe the extensive survival training I received as a Marine is allowed me to escape the extreme degradation and self-degradation I saw others experience. SCIENTOLOGY RELATED MURDERS AND SUICIDES 41. I also observed a number of individuals go crazy when exposed to the Hubbard Tech even absent malicious intent on the part of the persons applying the Tech. For example, I saw John Colletto go psychotic after he was exposed to the OT III level (Operating thetan level III) materials. He got a pistol. In my presence, he shot his wife in the head. She died instantly. Then John ran a short distance before turning the pistol on himself and committing suicide. Moreover, John Travolta's auditor told me of two occasions on which John Travolta went into deep depression after auditing and therefore suffered a psychotic break. 42. I personally observed a number of other Scientologists go crazy and commit suicide as a result of the auditing processes. Bob Shaffner and I were serving sentences on the RPF's RPF together. Although inmates are not allowed to speak to each other while on the RPF's RPF, Bob made it a point to tell me two or three times daily that he was going to kill himself because of what he experienced during RPF's RPF & OT III auditing. One day we were working on dangerous machinery and Bob suddenly thrust his finger into the machine which cut his finger off. Scientology management was fully aware of Bob's condition. He was placed on the risk of suicide list. Because he was suicidal, his berthing quarters while in the RPF were limited to first floor facilities. Whatever was done, if anything, to help Bob failed. He successfully committed suicide several years later. 43. I saw the Scientology thought reform procedures applied to a large number of Scientologists who were placed on RPF or the RPF's RPF. These procedures brought about long-lasting changes in the attitudes, values, personalities and behaviors of the subjects. Some of the victims I processed were Tom Ashworth, Clarisse Brousseau, Betsy Byrne, Al Crevello, Steve Crevello, Julie Fisher, Janadair Hockaday, Fred Houch, Annie Logan, Jim Logan, Judy More, Toni Prybilsky, Tom Saeker, Johnny Schleshenger, Homer Schomer, Jeff Wrothwiler, Stacy Young and many others. 44. I observed, participated in and was victimized by the use of thought reform on RPF as a means to impose the "Fair Game" law on dissident Scientologists. Despite claims to the contrary Fair Game has never been, and will never be, cancelled. The words Fair Game used in any issue is cancelled. However, the actions of handling suppressives with trickery, lies, deceit and even destruction have not been cancelled and are still being used today. INSTRUCTIONS TO CAUSE SUICIDE 45. I received instructions directly from Ray Mithoff to use the Hubbard Tech of thought reform to drive Tom Ashworth to a psychotic break. The express object of the exercise was to drive Tom crazy and to commit suicide. Tom went PTS Type III and attempted suicide. Later, Tom escaped from RPF and was caught, brought back against his will, isolated with 2 guards and more thought processes were used on him to calm him down rather than have him kill himself. 46. I also saw and heard the Hubbard Tech of thought reform used to drive Gary Epstein to a PTS Type III psychotic break as punishment for his refusal to comply with orders he received from the Wayne Marple mission. 47. I saw these same techniques used on persons who had not violated any Scientology laws or requirements. The techniques were used to compel persons to go up the Scientology Bridge to total freedom. Advancing up the Bridge requires attending courses and auditing or processing. Both the courses and auditing becomes more expensive the further up the Bridge a Scientologist goes. So, these thought reform techniques are callously employed to generate ever increasing sums of income for Scientology. USE OF ARMED GUARDS TO KEEP SCIENTOLOGISTS FROM LEAVING HEMET BASE. 48. At various times while I was stationed at the Gold base near Hemet, I was assigned to different security functions. Persons assigned to the security details were in constant radio contact with other security personnel. We watched persons who were suspected of being disaffected with Scientology and Miscavige closely (i.e. Vaughn Young and Terry Gamboa). We were required to confirm that the suspects were under surveillance to our seniors regularly. We also had an armed look- out, code-named "Eagle," who was located so that he could watch over the entire Hemet base and keep the occupants under surveillance with a powerful telescope. When Miscavige wanted to give the persons working at Hemet the impression that they were not being watched and to test out his theories as to who was likely to blow their post, we would be withdrawn from view and our surveillance responsibilities turned over to "Eagle." 49. We also had well established and intensively drilled procedures to follow if anyone appeared inclined to take unauthorized leave from the Gold base. If disaffected members tried to leave in a vehicle, it was security's job to get into the vehicle with the subject. If they tried to leave on foot, we were trained to follow them while remaining in radio contact with Gold base near Hemet. 50. If it was determined that a disaffected member was trying to leave, we were instructed to call in private investigators who had been retained by Scientology lawyers to deal with these problems. Once the private investigators were briefed, they took command of the situation. The private investigators would give us instructions. Once the private investigators were involved, our role was limited to acting as the private investigators' eyes and ears. We would be sent to places where the disaffected members were likely to go. We would alert the private investigators if we located the disaffected members. Once we located the disaffected members, the private investigators took care of the rest. 51. I was personally involved in efforts to retrieve Sinar Parman, Jeff Walker and Julie Fisher. The efforts to retrieve Sinar Parman and Julie Fisher were successful. We were unsuccessful in our efforts to return Jeff Walker to the Gold base. As soon as he was off the base he contacted the California Highway Patrol. He informed the Highway Patrol that he did not want to return to Hemet base. To get this point across to the Scientologists at Hemet base, Jeff returned to the Hemet base with a Highway Patrol escort he picked up his belongings and announced unequivocally that he wanted to leave and that he would take all appropriate action to preserve his freedom. He left the Hemet base under escort from the Highway Patrol. 52. Over the years I was at Gold base, a significant number of people at the base announced, or by their conduct indicated, to me that they wanted to leave. Julie Fisher stated repeatedly that she wanted to leave. She said that she did not want to remain at Gold base. My instructions were to keep her on the base. Mark Fisher, who was severely beaten by Miscavige, repeatedly told Miscavige and others that he did not want to be at the Hemet base. As Miscavige and others beat Mark in my presence, Mark kept saying that his attackers could beat him all they wanted but he still wanted to leave. Finally, Miscavige expressed his contempt and disgust at Mark and left the guard house where Mark was being held. 53. I also saw armed guards at the "berthing" (staff) quarters at Gilman Hot Springs. The armed guards were stationed to prevent staffers from leaving or "blowing" their posts during the night. 54. The function of the guards is not only to keep Scientologists in but to keep "wogs" out. Wogs are non-Scientologists. In 1991 a process server tried to get onto the base. He was beaten up and arrested by security guards who put him in handcuffs. The Police arrived and took the handcuffs off him saying "you guys can't do this, Man, you guys are getting carried away. The process server later sued and the case was settled. The security guard, Danny Dunnigan, was so confused about what his senior told him to testify to that he perjured himself about four times in the Courtroom. 55. I also have personal knowledge about the guarding of other people being involuntarily detained by Gold Security, a division of CSI, at the heavily fortified and armed Gilman Hot Springs base (Gold) and at Happy Valley which is another Scientology base 11 miles away. THE INTERSTATE KIDNAPPING, IMPRISONMENT AND SECURITY CHECKING OF ANNIE BROEKER 56. In addition, I have personal knowledge in connection with the retrieval and return of persons who have tried to flee and leave the Scientology organization. This includes the involuntary detention of Annie Broeker. I learned that Annie blew her post when Gold Security approached me to ask if I had seen her. The security personnel asked me if I had seen Annie. They informed me that she was not at her work assignment and not at her berthing. Several days later, I asked what had happened with Annie. Russ Andress told me not to ask about Annie. Later, I saw Annie at Happy Valley. Persons who are believed to present an embarrassment to Scientology are detained at Happy Valley. The inference that Annie was being detained was underscored by the fact that she was not on post and was not wearing her uniform. Furthermore, when I saw here she was accompanied by the Director of Inspection and Reports and the Master at Arms, who, at that time, was my son, Casavius Tabayoyon. From my personal experience, persons being kept under circumstances similar to those described above are being watched and will be detained, if they try to leave. At a briefing, Miscavige said that Marty Rathbun and another person from his staff had to hire a plane to retrieve a staff member who had fled (Annie Broeker). This briefing was in relation to how bad we (Golden Era Crew) were doing our jobs. It is significant, in my opinion that the recently filed declaration of Marty Rathbun indicated that he has been out of the U.S. jurisdiction since late last year. SCIENTOLOGY SECURITY GUARDS ACT LIKE THE MILITARY POLICE 57. As added measure to the situation of the crew being in Doubt, a security watch system was ordered into existence at the berthing locations of the Hemet base. When the crew were about to go home at night, the guards were to be at their positions at the berthing areas. Berthing is where the staff or crew sleep at Hemet and other Scientology premises. Berthing is similar to bunking on a ship. I was put in charge of six of the security guards. The shore story was that these guards were a neighborhood watch to protect the staff when they went home, but in fact the guards were there to prevent staff members from going to Vons or a late-night restaurant. They were to insure that staff members got off the bus and went directly to their berthing and. went to bed. Shore stories were also introduced on the Apollo. A shore story was a false story told to local port authorities so they would not discover that we were Scientologists and order us to leave the port. 58. Another duty of the "berthing" guards was to prevent staff from "blowing", which is the Scientology term for someone who leaves Scientology to become a member of the real world again. If staff members did blow, we were to get in the vehicle with them and detain them, and if we were stopped by the police, the "shore story" was to be that the person was having mental difficulties and we were going to assist them to get back home. We were to make it look like we were trying to help them, not hinder them. Another duty was to call the base when everyone was secured and a full head count was done. As a watch in-charge of the night berthing watch security guards, I was responsible for roving the town of Hemet to look for staff who were not in their berthing rooms when they were supposed to be. The berthing guards are CSI employees. Miscavige personally issued the berthing guard orders. MISCAVIGE IS THE MANAGING AGENT OF CSI: INDEED HE IS A MANAGING AGENT OF ALL SCIENTOLOGY ORGANIZATIONS. 59. I have personal knowledge that Miscavige issues oral and written orders and instructions to Scientologists irrespective of either ecclesiastical lines of authority or corporate lines of is authority or demarcation. Miscavige uses this omnipotent authority to exercise personal control over any and all Scientology organizations whenever he elects to do so. I observed that in running the various Scientology organizations, Miscavige constantly crosses all corporate and ecclesiastical command lines without regard to the fact that there are numerous Scientology related corporations of which he is neither an employee, officer nor director. He does not have to be to control any Scientology organization. He is above all Scientology organizations as the ecclesiastical head of Scientology, COB RTC and Commander of the Sea Org. In this capacity, Miscavige acts as the managing agent of each Scientology organization. 60. During my tenure at the Hemet base, Miscavige was always the senior officer - over all Scientology organizations having business at the base. While Hubbard was alive, Miscavige's orders had the same effect as Hubbard's. Only Flag Orders issued by Hubbard could supersede Miscavige's orders. Once Hubbard died, there was no authority senior to Miscavige's. 61. I personally observed Miscavige take over this position of ultimate power over all of Scientology after Hubbard died. I observed Miscavige when he was COB RTC ordering into Golden Era Studios ("Gold") , a CSI division, and ordering into the Commodore's Messenger Organization International ("CMO Int") , another CSI division planetary dissemination organization, etc. Both of these Sea Org units are corporately part of CSI. RTC, CMO Int and Gold are all located at a large compound outside of Hemet, California. It is called Gold. As I learned, the Scientology corporate structure was only for the benefit of the outside "wog" world. It didn't have any bearing on how Scientology operated. 62. When Hubbard was alive it was common knowledge and I also observed it personally that he was in direct control, via Miscavige and Pat Broeker, of CM0 Int and Gold, and the rest of Scientology. After Hubbard died Miscavige ousted Pat Broeker and Vicki Aznaran, who were then in control of Scientology. After that, it was my experience that Miscavige had complete control over Scientology just as Hubbard had when he was alive. Miscavige took over Hubbard's place as managing agent of all Scientology organizations. 63. The following are several examples of the power Miscavige has over Scientology regardless of corporate boundaries: (a) I was on a project in 1983-84 when Hubbard was still alive and he was planning to move to Gold properties at Hemet, so we were renovating Hubbard's living and working quarters at the Hemet compound so that he could live and work there. I often spoke with Miscavige about progress on these projects and received numerous orders on this project directly from him. At that time Miscavige's corporate title was Chairman of the Board of Author Services, Inc. ("COB ASI"). I was a staff member of the Flag Operations Liaison Office Western United States ("FOLO WUS") , a division of CSI. I was ordered to the Hemet compound by Deputy Senior Messenger Janadair Swanson, who was employed by CMO Int to work on CMO Int's project for renovating Hubbard's house. Miscavige ordered me to be in charge of the ceiling of the dining room in the house. Many living and working quarters were being renovated and Miscavige was overall in charge as Special Projects Operations ("Special Project OPS"), which was what he was called inside Scientology organizations. He would approve or reject the final product. (b) Later in 1985 I undertook a project as a Golden Era Productions employee (Golden Era is part of CSI) to construct Hubbard's studio. I received many orders directly from Miscavige who now claims never to have any authority with regard to CSI. One order that is clear in my mind concerns the main shell of the music studio. We had just completed the main shell, but when Miscavige inspected it he decided it would be too small. He ordered that it be re-engineered so it would be bigger. This order was given to me verbally and in writing from Miscavige via the Deputy Senior Messenger of the Household Unit. This re-engineering cost CSI an additional $449,000.00 which came from cash reserves of CSI located in the main Los Angeles branch of the Sumitomo Bank. (c) When a Portland, Oregon, jury awarded Julie Christofferson $39 million in damages against the Church of Scientology of California, Miscavige ordered that every available Scientologist be sent to Portland to protest the Court's decision outside the courthouse. This became known as the Portland Crusade for Religious Freedom and and it involved tens of thousands of Scientologists. On one day I counted 12,000 people. On another day there were 11,000 people outside the courthouse. I was the Executive Director of the Portland Crusade. I received direct orders from Miscavige on what actions to take for the Crusade even though I was employed by CSI, a non-profit corporation, and he was COB ASI, a for-profit corporation. Miscavige was personally involved with the finances for the crusade submissions to Miscavige were known as "writing it up to Department 21". There were many other people who also received direct orders from Miscavige, completely regardless of to what Church of Scientology corporation they belonged. This was battle. This was war. Eventually the desired effect was achieved. Christofferson was bought off and gagged and the documents sealed. (d) Later, the judge declared a mistrial in the Christofferson case. The Portland Crusade was over. Then I discovered that the crusade had accumulated over $500,000 of debt. Miscavige ordered a full inspection of the financial records. Once he had confirmed that the records were in order, he ordered the $500,000.00 debt paid off out of various Scientology organization accounts. (e) Once the Portland Crusade was over, I went back to building Hubbard's studio. We completed the studio. At a special ceremony, we received acceptance of our work by Miscavige and Hubbard. This established that the project was completed. (f) During the time of the construction of the Golden Era studio, I read several written orders from Hubbard about the ongoing renovations of his home and studio, as well as other aspects of the daily operations of Gold, CMO Int and RTC. Miscavige was directly responsible for the implementation of these orders. (g) Miscavige also crosses corporate lines to berate and scream intimidating obscenities and profanities at persons not of RTC. Once I did not achieve my target and Miscavige came at me, stood twelve inches from my face, and called me a "mother fucker" and a "son of a bitch" for about 10 minutes. I've also been at Sea Org musters where Wendell Reynolds shouted "You're all a bunch of treasonous sons of bitches!" 64. I did many construction projects at the Hemet (Gilman Hot Springs or Gold) compound for Gold, CMO Int and RTC, and in every one of these projects, I received at least one order directly from Miscavige on each particular project. On some projects, I received daily visits from Miscavige. During each visit, he issued several orders. STEVEN FISHMAN 65. I recall meeting Steven Fishman during the L.A. Crusade in 19-. Miscavige also ordered this operation. The LA Crusade was also known as the Battle of L.A. The purpose was to assemble so many may Scientologists outside the LA Superior Court during the Wollershiem trial that the judge and jury would be intimidated. There were also operations carried out to try and intimidate Judge Swearinger and plaintiff's counsel Charles O'Reily. At the LA Crusade, Fishman was with a woman by the name of Debbie Truax. Debbie told me that Fishman was working on a confidential project with her and the OSA staff (Office of Special Affairs). My position was D/Executive Director (Deputy Executive Director) for the L.A. crusade. My duties included overseeing to the productions of the crusade. The executive director of the Battle of L.A. was BilI Dendin. I was not able to help Debbie, Fishman and OSA because I had other projects for which I was responsible. So, our meeting was brief. During the LA Crusade, or Battle of LA, I also saw Fishman at the second floor of the CMO PAC building ("The Commodore's Messenger Organization Pacific Area Command Building). We didn't speak to each other at that time. 66. About one year later, I was at a staff briefing, where Wendal Reynolds was removed from his post for his condonement of the Registration Cycle of Steven Fishman. Miscavige gave the briefing about how Steven Fishman claimed he had been defrauded because he had caught on to the fact that there would not be any leather bound reel to reel tape, so various Scientology organizations would now be forced to make refunds of many tens of thousands of dollars. This was a major upset or flap because refunding money to people is so contrary to Scientology principles that persons who have to refund money are severely disciplined. The briefing focused on the demotion of Reynolds and others who failed to convince Mr. Fishman to leave the money with Scientology. THE SALE OF E METERS TO STEVE FISHMAN 67. While I was at the Hemet base, I became aware that Golden Era Productions had sold Steven Fishman one or more E-Meters despite the fact that Scientology records did not show that Fishman was qualified to purchase or use the E-meter. Records did not show that he was trained as an auditor or as a Scientology minister. The information I saw indicated to me that Fishman was sold one or more E-Meters as a means to generate money for Scientology. These sales occurred despite the fact that Scientology management was aware that a person like Fishman who lacked appropriate training and who had a history of psychological illness was highly likely to experience a PTS Type III reaction to self auditing. They were also aware that there was a significant possibility that a person who induced a PTS Type III condition as the result of self auditing would kill himself or others. 68. Based on my training in Scientology thought reform procedures, I know that the nature of the materials sold to Fishman were such that if he were to attempt to apply them to himself, the results were likely to be extremely injurious. Because the information available indicated that Fishman was an illegal pre-clear, he was not eligible for the auditing or processing that would provide him with the techniques to deal with the mentally overwhelming consequences of what he would do to himself. Hubbard and other senior Scientologists had described the practices to which Fishman was subjected as equivalent to giving a person who had never seen a gun before a loaded gun with the safety off and encouraging the person to play with it. This is clearly stated in 'the article on Black Dianetics by Hubbard... (note quotes from this can be used here) 69. It is my expert opinion that Steve Fishman was a staff member in a Scientology organization, with a position on the org board and a senior within a division on the seven division Org board which is used in organizations to lay out the personnel and functions of the class IV org. According to a letter of appointment and a letter from a staff meeting, Fishman had a desk and a position in the Miami Organization. The contents verify that Fishman was part of the Communication system, was posted on the Organization board, had a desk and a letter of appointment. I have spent 5 years of my 21 years in Sea Org as a personnel officer, 2 years as Organizing officer and 2 years as an executive Establishment officer and make the above statement of opinion from knowledge of the inner workings of the organization basic establishment actions. MISCAVIGE HAS UNBRIDLED TO PUNISH, IMPRISON AND DECLARE SCIENTOLOGISTS 70. In 1989, I personally observed Miscavige ordering the entire membership of the Gold compound near Hemit, including all of the above- mentioned Scientology units (which are corporately part of RTC and CSI, although the corporate distinction is not a part of the reality of daily life at the compound), to apply the ethics condition of Confusion (see next paragraph for an explanation of this term) as a punishment for a mud slide which damaged Tom Cruise's private apartment at the base. Tom Cruise has his own personal Sea Org member assigned as a valet or steward to clean his apartment and care for his needs when he is at the Gold base. 71. In Scientology, punishment is assigned by way of what are called "Lower Ethics Conditions." To quote the Scientology Technical Dictionary, "(confusion, treason, enemy, doubt, liability, non- existence, danger, emergency, normal affluence, power change, power.) The state or, condition of a person can be plotted on this scale of conditions which shows the degree of success or survival of that person, group or activity at any time." The condition of confusion is the lowest, most degraded ethics condition a person can be in, according to Hubbard's writings. When a person is in Confusion, they are only allowed minimal sleep and food. Persons in Confusion have to work very hard to show that they are trying to get out of that condition before they are allowed to be "upgraded." I observed that Miscavige assigned people lower conditions frequently, regardless of the specific Scientology corporation to which they belonged. 72. In 1987, I observed Miscavige order Vicki Aznaran incarcerated at a place called Happy Valley. Happy Valley is a ranch 11 miles away from the Gold base near Hemet. It was then one of the Rehabilitation Project Force ("RPF") Scientology correction and detention facilities. Vicki had been the senior executive in RTC. Miscavige won a power struggle and took her off that post. He ordered her into the RPF which was part of Gold, a unit in CSI. 73. I was at the Happy Valley complex when Vicki was driven up. She arrived in one car. Miscavige arrived in another car right behind her. After Vicki and Miscavige had left the respective cars in which they arrived, I heard Miscavige scream at Vicki, "You're going to do the f --- ing RPF." I did not see or hear Vicki make any response. I saw her go into the berthing facility. 74. A short time later, I spoke to Miscavige during his inspection of the stairs and patio of a building which was under construction at the base. He was wearing a new captain's uniform, a rank to which he appointed himself. I complimented Miscavige on his new uniform. Miscavige told me that Vicki, Jessie Prince and Spike Bush had been consigned to RPF. He said, "I'm almost positive they won't make it through the RPF. They're criminals." 75. Vicki spent 120 days on the RPF. As Director of Renovations and Construction Gold, a CSI department at the Gold base, I was in charge of supervising the work performed by the RPF at the time. Miscavige instructed us to keep a close watch kept on Vicki because he feared she would try to escape. 76. For 12 hours every day, for the duration of her stay, except for the few occasions when she was too ill to move, I saw her run around a pole ("the running program"). This is one of the most severe forms of RPF. It is reserved for persons deemed to be in a very low ethics status. It is often regarded as a program to contain persons regarded as crazy by the Scientology hierarchy. In addition to the running program Vicki was also working on other projects for an additional 5 hours a day. 77. Eventually Vicki successfully escaped from the RPF. She is now suing Scientology. MISCAVIGE IS THE HEAD OF SCIENTOLOGY AND IS INVOLVED IN THE DAY TO DAY MAINTENANCE OF CSI 78. I also observed Miscavige promote himself to the Sea Org Rank of Captain and assume the duties of Chairman of the Board of the Religious Technology Center ("COB RTC") with no authorization from Hubbard or anyone else, after Hubbard died. 79. When Hubbard died he left Pat and Annie Broeker in charge. Then Annie went to the RPF and Pat Broeker went missing, and the Hubbard order for Pat and Annie to be in charge was canceled by Miscavige, who then made himself COB RTC. 80. I was at a staff briefing of all the crew at the Hemet compound (including RTC, CMO Int, International Finance ("Int Finance"), Hubbard Compilations Unit ("R Comps") , Translation Unit ("TU") , Hatting Project, Hubbard Technology, Research and Compilations Unit ("RTRC"), Household Unit ("HU"), CMO Gold and Gold) when Miscavige announced that the ongoing strategy to handle the Cult Awareness Network ("CAN") was to send Scientologists, some of whom were totally undercover, in to join CAN, and that we were suing CAN for discrimination whenever they refused to allow a Scientologist to join. He said the plan was to have so many scientologists in CAN that the majority of CAN members would be Scientologists, and they would have no way of knowing who was and was not a Scientologist. 81. I observed Miscavige approve and disapprove daily film rushes on the films that were being produced by Golden Era Studios. Golden Era or Gold is part of CSI. He also approved Renovations ("Renos") schedules, in which all the staff at the Hemet compound were involved, including not only RTC but also CSI Sea Org units. 82. I also observed Miscavige brief the CSI crow at the base on how upset he was with the CSI crew for the way they had replied to a survey. CSI staff were asked where they wanted to live, and a lot of the CSI staff answered they would like to live off the base (the Hemet compound) for personal reasons. Miscavige began screaming and spat at the entire crew and said, "I spit on you" and "F--- you". He said no one who answered negatively was in a higher condition than Doubt (another lower ethics condition only slightly less degraded than Confusion). This briefing from COB was a general order to the whole base, including CSI, that if you didn't want to live at the base then you were in a doubt condition. 83. Miscavige, at this same briefing or muster, also picked out several particular staff members' surveys and read them to the crew so the crew could see how terrible these people were because they wanted to go to Vons market, or to movies or to have some time off from their post and duties. 84. The next day at the canteen (a private store on the Hemet compound) there were professionally made signs above the doors that said Vons and a Vons grocery cart. One staff member came in and decided it was a ridiculous thing and decided to take the signs down. Chris Guider, who worked directly for Miscavige, found out about it and this person was thrown into the lake. This is a practice called "overboarding." It started on the Apollo where I participated in the overboarding of many Scientologists who had angered Hubbard. Indeed, I was thrown overboard myself and only survived because of Hubbard's last minute decision to have me plucked from the seas. Now overboarding is down at the lake on the base. I have seen dozens of people thrown fully clothed into the water (even in winter) because they did not meet their production quotas or statistics. 85. I have observed Miscavige (COB RTC) do inspections of CSI's renovation projects, the result of which was a list of additional projects and orders for the staff. 86. One specific time was when I was a Gold staff member (part of CSI) and was working in the garage at the Hemet Compound, Miscavige came in and told me exactly how he wanted the windows handled in the planning area. He followed up this inspection by coming back with all his top execs and screaming and yelling at me because all the things he had ordered in a previous inspection were not completed. Attached hereto as 87. I know Miscavige's handwriting. Exhibit A is a copy of a 5 page document bearing Miscavige's handwriting. Exhibit A is from Jim Mortland, the Renos Construction Chief Gold (Part of CSI) to COB RTC (Miscavige) via COB ASST RTC (who was Miscavige's wife Shelly). Miscavige signed and dated the document on 12/6/90 and all of the handwriting is his reply except the initials and date COB ASST RTC which are those of his wife. A translation of the handwriting is attached hereto as Exhibit B. A copy of Exhibit A also went to D/CO Reserves CMO Int (part of "CSI"), INT Landlord (part of "CSI") and CO IGOLD (part of CSI). Miscavige added, above in handwriting, IG (Inspector General of RTC) and IG Admin (Inspector General Administration of RTC) and CO CMO INT (which is part of CSI). Accordingly, Miscavige has added two more of his juniors. 88. Exhibit - clearly demonstrates that Miscavige personally inspected the work being done by a CSI employee, requested a report and then directly issued further orders to the CSI employee. Furthermore, at the end of his handwritten reply, Miscavige requests information regarding additional projects. 89. Attached hereto as Exhibit C is a document entitled Non Existence Golden Era Productions Coordination Council. This means the Golden Era Production Coordinator Council was coming out of non- existence and into existence. Exhibit C demonstrates that at the Hemet or Gilman Hot Springs base, there is a Coordination Council comprised of representatives of different Scientology corporations. 90. In that regard, Miscavige is the ecclesiastical head of the Church and sits atop the ecclesiastical command chart which prevails over any corporate command lines and permeates all ecclesiastical and corporate entities. For example, he has total authority over the Gold base at Hemet and the old Cedar Sinai Complex in Los Angeles even though dozens of Scientology corporations are housed at those locations. So many that they created the Pacific Area Command (PAC) and Gold Coordination Council to provide Unified control and command. Miscavige runs everything and even approves music scores, videos and building plans. 91. Miscavige issues orders to individuals and groups including the Coordination Council set forth in Exhibit C. The Coordination Council itself issues orders to any part of Gold (which is part of CSI) It cannot issue orders to Miscavige. Nobody issues orders to Miscavige. His authority and control is absolutely total over every aspect of Scientology and every Scientologist's personal life. 92. Miscavige can order a mission of one or more people to go into any Scientology entity, private businesses owned by Scientologists and even Scientology families. Indeed, he can order spouses to disconnect from each other and/or their children. For example, my 21 year old son Casavius is still in Scientology. Since my wife and I left Scientology, he has disconnected from us. Scientology will never let him speak to us or see us. There is no way for us to contact him or visit him at Hemet. We have tried many times to do so. When we first left Scientology we kept a very quiet low profile, partly because of repressed memories and partly because we didn't want to do anything to cause our son hardship in the group. We can stay silent no longer. I am also aware of other "disconnections" such as Matias Patel whose husband was head of Scientology's finance police force in Europe. 93. I have also seen 15 to 20 lawyers at a time arrive for meetings with Miscavige. On one occasion I was working in the mini conference room. There were about 20 lawyers plus David Miscavige, Michael Rinder, Heber Jentzsch, all the inspector generals and the CO CMO INT. Clearly this was a commingling of CSI and RTC business. 94. There is no doubt in my mind that Miscavige's control of Scientology, and the Management Structures of the Church, make him the managing agent of the Church, and a managing agent of CSI, just as Hubbard was before him. 95. CSI, by its disobedience to this Court's discovery orders, has been able to conceal the information that otherwise would have been disclosed during the depositions of Miscavige, Jonno Epstein, Norman Starkey, Guillaume LeSevre, Marty Rathbun, Ray Mithoff and Kurt Weiland. 96. Representations by CSI that these persons are not part of CSI are simply not true. 97. In addition, Miscavige knows about Steven Fishman and his extensive purchases of Scientology materials. In the summer of 1987, at one of the regular weekly briefing sessions during which Miscavige addressed all persons at the Gold base, regardless of corporate affiliation, he informed all of those mustered that Steven Fishman, a public Scientologist who had made large purchases of Scientology materials, had demanded a refund because Gold had sold Fishman a large number of leather-encased clearsound reel to reel audio tapes of Hubbard lectures and Gold had not delivered them. Moreover, although they had sold Fishman the tapes, Gold was not going to deliver them and had no intention of ever doing so. This was the first item on Miscavige's agenda. Miscavige announced that Gold did not make that product, never intended to make that product and had in fact not made the promised product. Because this was a major public relations flap, a mission was established to deal with the problem. The mission busted Wendell Reynolds from Commanding Officer of Gold to pot washer. Janelle Allbach, the person who sold Fishman $80,000.00 of non-existent product, and Fronz Schuler were also removed from their posts because of the negative repercussions. In addition to hearing Miscavige's explanation of what happened at the muster, I also saw the ethics order issued on Allbach. It also mentioned the Fishman reg cycle and the scam that had been perpetrated on him by unethical Scientologists. In taking these actions, Miscavige was operating within the Scientology commend chart but was crossing Scientology corporate lines and issuing orders that apply to corporations, organizations and missions where he held no corporate post or other position. Corporations, corporate posts and corporate Positions are meaningless in Scientology and the Church. THE EPSTEIN, LESEVRE, RATHBUN, STARKEY, MITHOFF AND WEILAND DECLARATIONS FILED IN CONNECTION WITH PLAINTIFF'S AND NON-PARTIES NOTICE OF COMPLIANCE WITH DISCOVERY OBJECTIONS ARE MISLEADING 98. Jonno Epstein is the Chief Financial Officer of CSI. In my experience, regardless of which Scientology organization I worked for, whenever I needed funds to complete projects, I contacted Jonno Epstein. So, I know that he holds the Scientology purse strings and authorizes the writing of checks for whichever Scientology entity requires money. This has led me to conclude that Epstein is the Chief Financial Officer of other Scientology entities also. 99. In addition, I have personal knowledge of financial fraud involving Jonno Epstein and his wife Leslie. While on the RPF in 1987-1988, I was supervising the thought reform progress of Leslie. She had confessed to embezzling $24,000.00 dollars from the Church and spending it for her own personal use. She "handled" the situation by writing a note to her husband Jonno to pay the owed monies from book commission she should've received from Scientology. Weeks later I observed Leslie to be very happy and joyous. I asked what had occurred she said that, her idea to pay back the money she had embezzled was now approved and Jonno had transferred the money to reserves. Accordingly, the $24,000 stolen from the Church on this occasion, for her own personal inurement, was never repaid and was covered up with money from another book bonus. 100. Guillaume LeSevre is the Executive Director International (ED INT). The post is the work-horse manager over Scientology International CSI. The ED INT receives all public mail from Scientologists who used to write to "Ron" and now write to the ED INT. The last Church post that Hubbard held was that of ED INT. He resigned from it in 1966 and it was vacant until Miscavige appointed Bill Franks to the post in 1982. 101. LeSevre is the Church Official that the Church identifies as having management knowledge. He should have knowledge of the major purchases of books, tapes and E-meters by Fishman. 102. Marty Rathbun is the Inspector General Ethics ("IG ETHICS"). Accordingly, he ran all of the Church's Offices of Special Affairs of CSI. This includes all legal cases, private investigations, investigations, public relations and the execution of 'Fair Game'. 103. Rathbun is relevant to the inquiry as to whether Fishman was 'set up' and 'off loaded' by the Church. OSA, and therefore Mr. Rathbun, also received all of the data about Scientology related deaths, suicides and financial frauds. 104. Norman Starkey was the trustee of the Hubbard estate including Authors Family Trust B. It held the copyrights to all the Scientology materials. RTC only holds the trademarks. All of the Scientology books that Fishman purchased from Scientology were copyrighted by the Hubbard trusts. Norman had no authority in C.S.I. Despite this, I observed Norman (who was ASI), yelling and screaming at Arthur Hubbard (who was CSI). Arthur told me on several occasions of his dislike of his father (Hubbard) always trying to run his life. Arthur got so upset with his fathers constant intervention into his life that Arthur decided to leave the Sea Org. He was recovered by Miscavige and Starkey and was immediately sent to the RPF where he spent many months. In 1986 Arthur escaped the RPF and was again reprieved. Norm Starkey ordered the confinement of Arthur Hubbard at Happy Valley in 1986 after Arthur was back in the RPF he was given special thought reform process which drove him crazy and he again left the Sea Org, this time never to return. 105. Ray Mithoff is the senior-most person dealing with the technology of Scientology which includes auditing and the handling of Potential Trouble Source Type 3 cases ("PTS type 3"). A person who is PTS Type 3 has suffered a psychotic break, may hear voices, may have suicidal tendencies and will not know what is going on. I have personally observed numerous PTS type 3 cases in Scientology -- often in the course of auditing. Mr. Mithoff can verify PTS- Type 3 symptoms. He can verify handling appropriate procedures such as the introspection rundown and isolation watch. He can identify and describe actual cases and which deaths and suicides are directly attributable to Scientology auditing. From what Mr. Berry has told me about Fishman and his behavior, it is my opinion, as an experienced RPF auditor and RPF case supervisor, that he may have gone PTS-Type 3-especially if he had an extensive psychological background and was self-auditing without training. 106. Kurt Weiland is the Commanding Officer of the Office of Special Affairs International (CO OSA INT). Heber Jentzsch, the President of CSI, takes orders from, and reports to, Kurt Weiland, who is his senior. Kurt Weiland's job position ("Post") is within CSI. He directly supervises legal actions, investigations and public relations. Kurt Weiland is senior to the Director of Investigations which is CSI's spy section engaging in covert intelligence operations, intimidation and harassment -- often through private investigators such as Eugene Ingram. Kurt Weiland reports to Mike Rinder who is on the Watchdog Committee as WDC OSA. Rinder reports to the Chairman of the Watchdog Committee who is Mark Yeager. Yeager reports to Miscavige. Thus, the President of CSI (Rev. Heber Jentzsch) is only a mid-level official with no significant power of authority. The purpose is to contain the Courts and litigants at Heber Jentzsch's figure head level. CULLING OF PRE CLEAR [PC] FILES 107. In 1988 I case supervised Tom Ashworth who had gone PTS type III, slashed his wrists and later tried to escape with some upper level materials he had somehow obtained. I ordered a C/S 53 FIN and a LCRE. Tom Ashworth's pre clear folder was sent up to Ray Mithoff who was then RTC Inspector General for Tech. I was CSI. The folder came back with everything regarding the psychotic break removed from the folder. THE TIME ARTICLE IS NOT NOT OF AND CONCERNING CSI 108. As indicated above, I have 21 years of experience with the Scientology organization. Throughout that time the words Scientology, Church of Scientology, Scientologist and church were widely used. These words are generic in nature. They do not refer to any particular organization or person within the Scientology corporate hierarchy, the Scientology Command Chart or the Scientology belief system. 109. I reviewed the alleged "of and concerning' language which CSI sets forth in its complaint in this action. There is nothing in the two paragraphs in question that even remotely references CSI. 110. Within Scientology organizations, and as used by persons who adhere to the Scientology belief system, the term Scientology refers to a belief system based on Hubbard's Tech which is applied by Scientologists to ecclesiastical and secular matters. Scientology is defined by the Tech Dictionary as: Scientology does not refer to any corporate entity. The Tech Dictionary does not provide any corporate association for the word Scientology. 111. Within Scientology organizations, and as used by persons who adhere to the Scientology belief system, the term Scientologist has always referred to an individual person who embraces the Scientology belief system. It does not refer to any corporate entity. The Tech Dictionary does not provide any corporate association for the word Scientologist. 112. The term church is used throughout Scientology organizations, and by adherents to the Scientology belief systems, to refer to all scientology organizations. The term church does not imply or specify any particular organization within the Scientology corporate hierarchy or the Scientology Command Chart. 113. Accordingly, the relevant references to 'Scientology' and 'the church' are to the Church of Scientology and Scientology generally and without reference to any of the hundreds of Scientology corporations. INUREMENT TO SELECTED SCIENTOLOGISTS 114. I spent more than ten years stationed at the Gilman Hot Springs Scientology base near Hemet, California. It is known as 'Gold.' The Gold is a fortified and armed facility operated by various Scientology organizations. It is under the direct control of Miscavige who also has an expensive residence there. These organizations include the Church of Scientology International ("CSI") and the Religious Technology Center ("RTC"). Gold is administered, in part, by The Gold Coordination Council. Exhibit ____. While I was stationed at Gold, I was personally involved with numerous renovations and construction projects. These included: (a) The renovation of Hubbard's personal living quarters in approx. 1983; (b) The renovation of Hubbard's office, which included installing cinematography and audio sound equipment of production studio quality in approx. 1983/84; (c) Constructing Hubbard's laundry facility which included installing two large washing machines, two large dryers, a complete dry cleaning machine and all attachments and an 18' x 12' storage closet in approx. 1983/84. 115. I witnessed money from various non profit Scientology organizations, and labor provided by various non profit Scientology organizations being used for the personal benefit it of Miscavige, Tom Cruise, other Scientology senior executives and other Scientology celebrities (such as John Travolta, Chick Corea and Priscilla Presley). 116. I also saw monies and/or personnel from various Scientology non profit religious organizations being used for the personal benefit of Miscavige. We constructed a music room for him, a lounge, a dressing room, a personal exercise room and personnel storage rooms. The approximate cost of this was between $250,000, $300,000. This does not include the cost of labor since RPFers, or slave labor was used on these projects for personal enurement of Miscavige. 117. Miscavige, other senior Scientologists and certain celebrities would also use the movie theater we constructed on the base to view first run movies provided to him by his acquaintances in the movie industry. The cost of this was easily $150,000. This cost does not include labor (again slave labor) or expensive film projection equipment. 118. During the 1980's, Miscavige befriended the actor Tom Cruise and they spend a lot of time together on the Hemet base. Their special chef, Sinar Parman, would prepare them fancy meals. Often they would hang out alone in the space designated for L. Ron Hubbard on the Clipper Ship we built in the desert. This space had a small kitchen, a little dining room, a little bar and a bed. They also had the exclusive use of the officers lounge. On other occasions Miscavige and Cruise would work out in the expensive gym we built for exclusive and restricted use. No one else was allowed to talk to Tom Cruise when he was on the base. One time one of the gardeners spoke to him and this caused a major flap on the base. At Gold, Miscavige is known by his initials DM and Tom Cruise by his initials TC. From the late 1980's until I left the Gold, Tom Cruise was provided a personal and exclusive apartment and storage facilities by the Scientology organization and at Scientology's expense. Tom Cruise kept two Yamaha motorcycles, a Mercedes Benz automobile and a large motor home at Gold. These were stored in what used to be Hubbard's garage and parking lot. Obviously, Miscavige and Cruise have developed a special relationship. One is a young world domineering celebrity. The other is a young domineering cult leader who seeks to 'clear' the world and to rule it according to Scientology beliefs and practices. 119. When Tom Cruise got married to Nicole Kidman, they and David Miscavige went to a Colorado Ski Resort for the marriage ceremony. A Sea Org staffer (Sinar Parman) was taken along to do personal cooking for Tom Cruise and Miscavige at the expense of Scientology not for profit religious organizations. This left only 3 cooks at Gold to cook for 800 people three times a day. 120. I personally participated in the construction of an apartment at the Gold base, using extensive funds from various non profit Scientology religious organizations, for the personal and exclusive use of Tom Cruise. This was done on the orders of David Miscavige. Even though Miscavige has claimed to be Chairman of the Board of RTC, here he is directing the expenditure of CSI money and the deployment of CSI labor -- both paid and slave. Other apartment cottages were built for the use of John Travolta, Kirstie Alley, Edgar Winters, Priscilla Presley and other Scientology celebrities who are carefully prevented from finding out the real truth about the Scientology organization. The labor used to construct Tom Cruise's apartment was provided by Gold, a division of CSI, and persons from a myriad of Scientology organizations serving time in the RPF. The RPF (Rehabilitation Project Force) is the Scientology gulag or concentration camp. Using RPFers to renovate and reconstruct Tom Cruise's personal and exclusive apartment at the Scientology Gold base is equivalent to the use of slave labor for Tom Cruise's benefit. The Tom Cruise apartment at the Gold base is located at the golf course end of the Gold base, closest to State Street. When Tom Cruise visits the Gold base, and stays in his personal apartment, he is cared for by a Sea Org steward. 121. We also had to renovate the Tom Cruise apartment at the Hemet Base after it was damaged by a mud slide. The repairs had to be performed on an emergency basis. Both the Gold crew and the RPFers were placed on extended hours to restore the apartment. Again, Tom Cruise was benefiting from the use of what is essentially prison slave labor being worked almost around the clock. 122. Tom Cruise also enjoyed use of facilities constructed on the Gold base that were not available to any Scientology staff except the senior most Scientologists on the base, particularly Miscavige and his lieutenants. For example, I saw Tom Cruise use the exercise room which was off limits to at least 98 percent of the staff. Tom Cruise also had unrestricted access to the Ship which has a sauna, jacuzi and a large Olympic sized swimming pool. With regard to the Miscavige/Cruise gym this was built in conjunction with the estates facility in approx. 1989. The gym building cost approx. $150,000 (again using slave labor) and contains a complete lineup of the most modern weight training equipment. It is one of the most incredible gyms imaginable and is for the exclusive use of Tom Cruise, David Miscavige and other specially and specifically approved by him. It also has an incredible shower area. 123. To assure that Tom Cruise's stays at the Hemet base were enjoyable, special provisions were made for him and restrictions were imposed on the staff at the Hemet base. Millions of Church dollars were spent so that millionaire Tom Cruise could regularly visit the Scientology base and be friends with Miscavige. For example, Tom Cruise received special meal services, special room services and the Hemet base staff was restricted in its access to Hemet base facilities. Indeed, a girl by the name of Jennie Matsamura was assigned to take care of him and his renovated cottage. The Hemet base staff was barred from going where Tom Cruise might be present. Construction and renovation work that was done on the base for Tom Cruise's benefit often had to be torn up and redone because the coloring was slightly off or there were a few inches of group that didn't quite match in color. Once we had to pour a concrete walkway so that Tom Cruise would not have to walk on the desert soil. Before the concrete dried it rained. The concrete was spoiled. Miscavige went into a fury over that. 124. On one occasion, prior to a Cruise/Kidman visit, Miscavige decided to redo the meadow in beautiful flowers; Tens of thousands of dollars were spent on the project so that Cruise and Kidman could romp there. However, Miscavige inspected the project and didn't like it. So the whole meadow was plowed up, destroyed, replowed and sown with plain grass. 125. Tom Cruise also received his upper level auditing at the Gold base. All of his auditor training was provided under the auspices of RTC and delivered by RTC. Officially, RTC has no auditing service delivery capability. It exists solely to enforce the Scientology trademarks. This is yet another example of how the purported corporate compartmentalization exists only for the "WOG" world and has no meaning within Scientology. At the time I left Gold, Tom Cruise had completed Dianetics, Level O-IV, the Key to life course, the Life orientation course and he was audited up to OT III. 126. OT III deals with body thetans ("bts") and clustered body thetans ("clusters") . In essence, OT III deals with "the incident" which Hubbard claims to have been the most engramic incident responsible for the current state of man. According to OT III, 75 million years ago, the solution to overpopulation in a space confederacy (consisting of 26 planets) was solved. Now, each leaf on the Sea Org symbol represents one of those planets. Each of these planets had approx. 150-200 billion citizens each. The overpopulation solution was to disembody all the spirits ("mass murder") with the use of glycol (alcohol and sugar) injected into the spinal cord causing an immediate freezing up of the body and the unconsciousness of the being (soon to become a bt or cluster) . The frozen bodies were then collected and transported to earth (called Teegach by Hubbard) in space ships resembling Boeing 707 jetliners. The bodies were piled up, as in the Nazi massacres, on the top of various mountain sites around the then earth. Inside these mountains were 17 strategically placed enormous atomic bombs -- bigger than any built this century. After the citizens who had been selected to be part of the solution were placed on the mountains, the hydrogen bombs were ignited from a remote space station (lunar moon) by the officers of Xenu who ruled the space confederacy. After the explosions the now disembodied thetans were electronically trapped and transported to areas now known as Hawaii and Las Palmas where there were pre-constructed implant stations. Then there was a long and arduous process of packaging the disembodied thetas (spirits) into clusters with ideas, morals, social values, emotions, sensations, pains and attitudes of what we now observe as human life. The clusters were then dispersed over planet earth through the medium of ice. The ice then melted and the first stage of implant command became activated. This is known as 'Survival' in Dianetics. The bts or clusters then seek a human body. When the bt or cluster occupies the body it will either begin running or operating the body or the engramic commands earlier received in the implants take place. This will occur over and over again in what is known as the life cycle -- each time resetting the implant and restarting its effect with a death or end of cycle.' This technology can be used for tailor made psychosis, neurosis and general madness. Indeed, implant technology of this sort can be used for many purposes. Using implant technology, Hubbard teaches how you can cause someone to do whatever you want them to do, starting at the prenatal stage. 127. The purpose of auditing at the OT III level, such as Tom Cruise has received, is to contact and audit the bts and clusters so that the bts and clusters leave the body of the auditor. The purpose of this is to free the person from the determinism of the bts and clusters. However, the bts and clusters that are released by the solo auditor are now back at the beginning of their implant which they received 75 million years ago. Survival then retriggers the basic implant which then picks up a body, or attaches to one that is already occupied, and re begins the whole cycle. 128. The ultimate goal of auditing is the return of self determinism and abilities of the person being audited. In other words, to return the person to the state they were in 75 million years ago before Xenu handled the over-population problem. 129. Tom Cruise also audited Kevin Catano up to grade IV. Kevin Catano was a member of the Sea Org security force at Gold. Usually a Sea Org member in the security force would be audited only by a Sea Org member -- not a public scientologist let alone Scientology celebrity. 130. Tom Cruise's p.c. (pre-clear) folder was kept in the Gold case supervision (c/s) office which I had access to as a security missionaire. It contains supposedly confidential information derived during auditing sessions. However, the contents of such pre-clear folders have been culled and used against people. it is my opinion, based on my Scientology training, education and experience, that such information is collected by the Scientology organization in order to be able to exert control and influence over people such as Tom Cruise or John Travolta should they ever attempt to leave the Scientology organization. 131. In 1989/1990 we also constructed a tennis court at Gold for the exclusive list of Celebrities and Miscavige. Non profit Scientology religious organization funds were used for this inurement project. The tennis court cost at least $200,000 to build. The rubber coating alone, on the tennis court, cost $80,000. Then there was the landscaping and rose garden around the tennis court. FINANCIAL FRAUD 132. I received money from Scientology reserves in excess of one million dollars. I used these monies to build a sound studio. 133. In 1990 Jan/Feb, I became aware of the fact that some friends of mine came subject to severe ethics handlings. The first was Mike Silverman, he was assigned to the RPF's RPF for credit card scams and a lot of other financial scams he was involved in. It is my opinion that Mike was the scapegoat and everyone concerned with the credit card scam was not sent to the RPF'S RPF. Also it is my experience that the Church kept all the monies gotten from the scam and made the public persons involved through coercive ethics application such as lower conditions, pay the credit card depts and the church kept the money. The second friend who was subjected to severe ethics action was Joe Bueno. Joe and I spent months together in the RPF (Scientology's thought reform prison camp). I saw an ethics order on Joe Bueno which stated he was the originator of the credit card abuse system and he arranged special credit card loans. Jonno Epstein, Marc Yeager claim no knowledge of this credit card cycle. Their' claim is just not true, as the Watch Dog chairman Marc Yeager is briefed on the "income sources that are in operation in Scientology. Just as Jonno Epstein is briefed of all the "income sources" in operation so for them to claim no knowledge is like saying there is no sky, or there are no fish in the ocean, complete nonsense. 134. I was also directed by L. Ron Hubbard to go to a bank in Zurich, Switzerland, withdraw $14 million and to return with it to Lisbon, Portugal. Two other Sea Org members went on this mission with me. When we went to the bank, they brought the money out in a cart and we sat there and counted it three times. We then put it in a suit case, got a taxi cab, then an air flight and handed the money over as ordered. we were then debriefed. 135. Attached hereto and marked as Exhibit D is a copy of & letter dated December 6, 1989 signed by Captain Marc Yeager concerning the American Express credit card fraud being carried out within the church of Scientology. 136. Attached hereto and marked as Exhibit E is a COPY of an internal Church of Scientology Communication dated December 16, and referring at paragraph "4/" to the American Express Credit Card Fraud Scheme being conducted within the Church of Scientology. 137. Attached hereto and marked as Exhibit F is a copy of a Church of Scientology document dated January 7, 1990 and being a probational suppressive person declare regarding Jon Lundeen and stating in paragraph 6 that for the last 15 years, he had been continuously involved in financial irregularities ranging from forgery and fraud to petty theft in connection with his Church of Scientology duties. 138. Attached hereto and marked as Exhibit G is a copy of internal Church of Scientology Communication identifying Joe Bueno as being a person who was "blackmailing" full time. 139. Attached hereto as Exhibit H is a Church of Scientology communication dated January 20, 1990 being a copy of a non enturbulation order regarding Joe Bueno and identifying him as being engaged in church related financial irregularities including loan arranging, abusive credit cards, etc. 140. Attached hereto and marked Exhibit I is a copy of a Church of Scientology communication dated dated January 20, 1990 being a RPF assignment of Mike Silverman for committing numerous, gross financial irregularities on his Church of Scientology Post and also identifying him to be a source of instigating the misuse of credit cards for church services. 141. Attached hereto and marked as Exhibit J is a copy of a Church of Scientology communication dated January 31, 1990 and being a suppressive person declare re Terry Block for committing severe financial irregularities and identifying at least 50 instances of illegal conduct on his behalf in connection with his Church of Scientology duties. 142. Attached hereto and marked as exhibit R is a copy of a Church of Scientology communication dated January 30, 1990 and being a suppressive person declare re Michael Silverman and identifying him as being involved in church related financial irregularities over the past 14 years stating that he had committed numerous gross financial irregularities. 143. Attached hereto as Exhibit L is a copy of an internal Church of Scientology communication dated January 31, 1990 regarding the Church related American Express credit card fraud and the handling of that situation by various people involved in it. 144. Attached hereto and marked as Exhibit M is a copy of an internal Church of Scientology communication regarding the handling of problems relating to Scientologist credit cards which had been the subject of the Church related American Express credit card fraud. 145. Attached hereto and marked as Exhibit N is a copy of a Scientology communication dated 29 January 1990. Paragraph 2 states in pertinent part, that "there has been gross criminality found on the reg lines in all PAC Orgs." PAC is the Pacific Area Command of the Church. VERIFICATION OF THE BONA FIDES OF OTHER EXPERTS 146. I was on the RPF with Robert Vaughn Young and others. I was personally charged with verifying that Young's mind control program directed by my seniors was actually done. This program included application of Black Dianetics auditing procedures. As a case supervisor I spent between 20 and 30 hours verifying the mind control program that was imposed on Young and then reviewing the results of the brainwashing. 147. I was also on the RPF with Stacy Young and supervised the administration of various Black Dianetics procedures on her. Part of this program included a "gang bang sec check," which Rick Aznaran and I performed at the instruction of Sr C/S Int Ray is Mithoff. SCIENTOLOGY FINANCIAL FRAUD IN THE FORM OF CONCEALING INFORMATION FROM THE INTERNAL REVENUE SERVICE 148. In December of 1992, Miscavige directed that we hide a large number of sea containers of financial records relating to the Church and himself. The sea containers were to be hidden from the Internal Revenue Service ("IRS" IRS investigators were scheduled to visit the Hemet base to inspect the records of various Scientology organizations in connection with the IRS's investigation of the various church of Scientology entities that had applied for Section 501(c)(3) tax exempt status. (A sea container is a large transferable metal storage container, measuring approximately 40' x 8' x 8'6". These containers can be transported on flat bed trucks, flat bed railroad cars and container ships.) 149. The procedures for concealing the information contained in the sea container were set out in a written TRS handling program. It outlined the steps to be taken to secure the Hemet base and make sure that the IRS examiners did not see any information that Miscavige did not want the examiners to see. 150. There were a total of 20 sea containers involved in this concealment. We consolidated them down to 12 sea containers. I was also ordered to grade the land on which these containers had sat so that there was no proof of them ever having been there. 151. One of these sea containers of documents was mistakenly removed from the base unbeknownst to either me or Miscavige. At the time unused sea containers were being shipped from Gold base to their owners. Inexplicably, one of the sea containers containing concealed tax information was picked up and taken from the Gold base by the owner's employees who believed that the sea container was empty. When Miscavige learned that there had been a mistake in connection with the hiding of this sea container of financial documents, he was outraged. He flew into a tirade. He blamed me for the error and accused me of trying to destroy him. It ended up on a ship at San Pedro and was off- loaded before the ship's departure. My Decision to Leave Scientology Miscavige then told me that I was making it impossible for him to function at the base. By this time I had reached my limit as to the amount of abuse I was willing to take. I decided to flee from Scientology. I left ("'blew") my "post" at the Hemet base. When I left, I was able to locate my wife and we left together. I was not able to locate my 21 year old son. He is still on staff. We have been unable to communicate since. My wife and I then successfully avoided the efforts of Scientology personnel in RTC and CSI to get us back to the Hemet base. I declare under penalty of perjury under the laws of the United States of America and of the State of California that the foregoing is true and correct. Executed in Los Angeles, California this 5th day of March, 1994. Andre Tabayoyon |