------------------------------------------------------------------- F.A.C.T.Net, Inc. (Fight Against Coercive Tactics Network, Incorporated) a non-profit computer bulletin board and electronic library 601 16th St. #C-217 Golden, Colorado 80401 USA BBS 303 530-1942 FAX 303 530-2950 Office 303 473-0111 This document is part of an electronic lending library and preservational electronic archive. F.A.C.T.Net does not sell documents, it only lends them according to the terms of your library cardholder agreement with F.A.C.T.Net, Inc. ===================================================================== AFFIDAVIT OF EDWARD WALTERS I, Edward Walters, hereby depose and state under pains and penalties of perjury: 1. I have personal knowledge of the facts sworn to herein and if called as a witness to testify thereto could do so of my own personal knowledge. 2. I was a member of the Church of Scientology for approximately nine (9) years from 1970 through March of 19 79. 3. My position in the Church~f Scientology was that of Case Supervisor, a Class VIII Auditor and I was generally considered one of the highest "tech" people, knowledgeable about Scientology policy in the U.S., I was also directly responsible for the handling of preclear folders. 4. While a member of the Church of Scientology, I had frequent contact with Susan Reed, the Assistant Guardian, Matty Reese, the Assistant Guardian Public Relations Officer, and Chuck Reese, Assistant Guardian of Intelligence. Susan Reed often told me to be aware of "evil" and "suppressive" groups and organizations which were out to stop Scientology. She said "evil groups \ were as I remember, the United States Government, the American Medical Association, the Better Business Bureau, doctors, lawyers, and police agencies of any kind. She stated that the Guardian's Office was responsible for stopping these attacks against Scientology by any means available including electronic surveillance, infiltration, burglary and theft. The above named Guardian's Office personnel would tell me of the "wins" that they would have in their covert operations to stop or destroy those groups 'or individuals whom they considered to be suppr~ssive. At this time Susan Reed introduced me to a fellow in her office and who told me his name was Randy.. Randy said he was an intelligence agent working directly under Mary Sue and L. Ron Hubbard, and that he worked on the most sensitive and most secret of all Scientology's covert operations. He also stated that there was a need to do away with "suppressives" and groups attacking Scientology in whatever way necessary, including burglary, larceny, and "framing". He informed me how the Guardian's Office technology worked. For instance, he said that the Guardian's Office would plant dope on some "SP", then call the police and have the fellow arrested. The Guardian's Office would circulate word of the fellow's arrest and whatever the fellow said about Scientology would not be believed. It was in this -2- way that they framed some of the SP's. He then told me that if Susan Reed wanted me to contact him that I should call the Los Angeles Guardian's Office and ask for either "Randy", "Bruce", "Raymond" or "Bruce Raymond". He then told me I was not to reveal what he had told me or who he was to anyone and that grave consequences could result to me if I divulged any of this. 5. On several occasions I overheard phone conversations between the above named individuals and people in the United States Guardian's Office in Los Angeles with respect to illegal acts and covert operations requested to be done by the United States Guardian's Office in Los Angeles. 6. I know from my own personal experience that the Guardian's Office of each local'Org is controlled by and reports to the United States Guardian's Office in Los Angeles. The United States Guardian's Office in Los Angeles is operated by the Church of Scientology of California and is controlled by Mary Sue Hubbard and L. Ron Hubbard. I also know that there is a direct telex connection between the United States Guardian's Office and the Clearwater headquarters of the Church of Scientology and that this telex connection is used by the United States Guardian's Office to consult with Mary Sue and -3- L. Ron Hubbard, of Clearwater, Florida. The United States Guardian's Office in Los Angeles consults on a periodic basis with officials in Clearwater, Florida but would always consult with them in matters of special importance to the Church of Scientology. 7. I know from my experience and observation that the Guardian's Office has systematically, through the years, used "pre-c!ear" data as a tool against a pre-clear who would threaten to go to authorities or see a lawyer to sue or get his money back. I observed Matty and Chuck Reese of the Las Vegas Guardian's Office do this for many years and at tires, the had told me how "we stopped" or "we showed that lawyer what a client he really has and he backed off right away", etc. 8. While Case Supervisor in 1978 at the Celebrity Center Mission in Las Vegas, Bruce Hamilton of the Las Vegas Guardian's Office came to see me and asked me to go through my PC files and to provide him with any information which had been disclosed in auditing sessions which I thought would be helpful to control the person and would be "helpful to his cause". When I disagreed with these "gestapo type tatics" he told me that these orders came "directly from Los Angeles" or "this comes directly from Clearwater", and that if I didn't comply, it would be "treason". -4- 9. On a number of occasions I had been requested by individuals in Clearwater, Florida to forward preclear folders to them or people who were undertaking auditing. In accordance with these requests I have sent a number of pre-clear folders to the Clearwater headquarters and have received written receipts for them. I have a number of these receipts in my custody at this time. 10. I was a member of the Las Vegas Org throughout the period that La Venda Van Schaick was a member of the Church of Scientology in Las Vegas. I have personal knowledge of the solicitation techniques used on new members ("raw meat"). I have personal knowledge of the "Church" policy throughout the period 1971-1979 both in Las Vegas and throughout the U.S. with regard to the Church's "religious front" and with regard to the making of representations to raw meat to induce them to pay money or to join the organization. In Las Vegas and throughout the U.S. it was "Church policy" between 19711979 to state to everyone that the Church of Scientology was a law-abiding organization that operated only on scientific principles based on scientific validation of thousands of case studies over a period of 30 years by L. Ron Hubbard, a nuclear physicist, a combat veteran, -5- who healed war wounds with Dianetics. The scientific basis of Scientology, per policy, was held out to be more scientific than physics, etc. The representations made to people such as La Venda Van Schaick were made orally, in writing in small advertising flyers such as "What is Scientology" and through the sale of books and publications such as "Dianetics, The Modern Science of Mental Health". I was trained and others in the Org, called "body-routers" and "registrars" were trained to tell people that Scientology was a "science" not a , "religion" and that "Religion" was only used to deal with the Government, taxes etc. 11. It was common knowledge in the "Church" and it was "Church Policy" to use the "religious front" to deal with the Government, but to solicit new recruits and train members based on "scientific technology" devoid of religious significance or context. Representations made to induce people like La Venda Van Schaick to pay money and become members were uniformly made, per policy, in the context of "scientifically guaranteeing" them higher I.Q., cure of psychosomatic disease, increased educational and career opportunities, working with Hubbard, earning a salary, receiving courses and training, room and board, health care, etc. It was -6- "Church policy" not to inject "religion" into the foregoing representations. It was common knowledge to everyone in Scientology that I dealt with between 1971-1979 in Las Vegas including Barbara Glass and Robert Harvey, that (1) religion was used as a "front"; (2) that courses and books were sold to "make money" based on specific promises or guarantees which had no religious context; and (3) that elaborate plans were used to create the impression with the Government that Scientology was a religion pursuant to a policy called "The Minister's Mock-Up", based on the "religious image check sheet". This policy required someone in the Church to wear a "minister's costume" whenever the Church dealt with the Government. Between 1971-1979, I know of three instances where this was done: once when someone from the D.A. 's office came to the Org, once when a newspaper reporter came to the Org, and once when a magazine was preparing an article. 12. It is written "Church policy" to use the religious front for the Courts, the Government, lawyers, accountants, etc. In fact, the very effort presently made by Scientology lawyers in the Courts throughout the U.S. is based on Hubbard "tech" to present Scientology as a "religion". This is 180ø opposite to what in reality happens in the Org when Scientology is being "sold". If -7- we tried to sell Scientology as a "religion" on the street or to members for more courses, we would have been laughed out of town, and wouldn't have received a nickel. There is no religious context to the sale of Scientolo~ courses and books. After the F.D.A decision in the early 1970's, we were told to start putting "stickers" in the books which had something to do with a "religious disclaimer". However, it was Church policy to tell everyone that the "stickers" were just for the Government and didn't change anything. Scientology "tech" was an exact science, to be sold as such and not as a "religion". 13. The Church of Scientology of California totally controls every Scientology corporation in the U.S. primarily through the Guardian's Office. All directors of the corporations must resign in advance, and all policies issued by California must be rigorously adhered to, including but not limited to the policy of using religion as a front, but soliciting people and money based on the scientific basis and principles of / the organization. 14. The Church of Scientology has a very specific and deceptive policy of obtaining signatures on various forms, waivers, releases, etc. Often these forms are -8- signed just before or after auditing sessions, and the individual is told that it is just for the Government, or the individual does not even know what he is signing, or numerous documents are placed in front of an individual and signed without being read. This was a common practice. Signed under the pains and penalties of perjury this ~ ~ ~'~ ~ ~ ~ ' day of ~ , 1982. Edward Walters as cures from obesity, colds, headache, cancer, etc. Throughout 1979, when I discovered Hubbard was a fraud, I realized how much I had been defrauded. 16. I was required to sign many forms at the time I joined the "Church" and in later years. Most of the time I did not know what I was signing and the common "line" was that the forms were used to protect the "Church" from the Government. I was told that and I told other people the same thing. From the time I joined Scientology until the time I left, everyone I knew and dealt with was continually told and believed that the "Government" was our "enemy" to which we should always apply the Fair Game Law. To this day, I do not know what forms I signed, what their contents were, etc., but I do know that the Church applied the Fair Game Law to all of its "enemies" which includes using information and documents procured from Church members by any means possible, fraudulent or otherwise. 17. Upon information and belief I have been brutally and viciously harassed for almost 3 years pursuant to the Fair Game Doctrine by the Church of Scientology. Church agents contacted my place of employment as a result of which I lost my job. Church agents have called my friends and neighbors accusing me of child -10- beating, promiscuity, drug usage. I have been followed, threatened, harassed, sued twice (both dismissed), had my auditing information disclosed to the media. My lawyers have had documents stolen from them about my case. My child has been followed, kept under surveillance, called by telephone, contacted in person. Church agents have tried to influence my ex-husband to take my child away. "Operations"were implemented to "separate" me from my lawyer, my husband and my child. As a result of all of the above, I live in perpetual fear and I am presently in a condition of almost complete mental and emotional collapse. I donot presently feel that I can survive beyond September 1982 knowing that the Church will "attack" me ever more aggressively as the law suit continues. Church "policy" is very specific about "attacking" "enemies" and "traitors" of which I am one, and elaborate "operations" have to be implemented against me pursuant to "policy". These policies have never changed. 18. As the HCO Area Secretary in Las Vegas, I had personal knowledge that the Church of Scientology of California controlled and dominated every phase of the Church operation in Nevada including finances, solicitation policies, publications, prices, governing policies, criminal activities, etc. Control by Church of Scientology -11- of California was exercised by Flag agents, the Guardian's Office, and the Hubbard Communications Office. All members of all Boards of Directors were required to resign in advance of their appointment and the resignations were held by the Church of Scientology of California. 19. I did not discover the fact that Hubbard's academic credentials, naval background, professional qualifications asa nuclear physicist, research history, and case studies were all false, until 1979-1981. I did not discover the fact that there was, therefore, no scientific validation of Hubbard's claims and representations, and no scientific basis for making such representations until 1979-1981. I did not receive the benefits promised to me such as wages, health care, room and board or courses as represented between 1971 and 1979, but it was continually represented to me that those benefits were forthcoming right up to 1979, and in the last several years, 1976-1979, my mind was firmly indoctrinated with the fact that Scientology would provide all of the promised items. It was not until 1979-1981 that I learned that the financial control mechanisms established by Hubbard were such that the representations made to me between 1971-1979 were fraudulent when made, because Hubbard took all of the money and left each Org with only enough to continue in the manner it did for 7 years. -12- 20. The books that I was sold did not comply with the Judgment of the Court in the Article or Device case and I specifically never saw any publication which contained the "Warning" required by that case in 11 point leaded type on the title page on the cover page. I do recall the organization placing some "stickers" in some of the books about the religious nature of Scientology. However, these stickers were never placed in the books sold to me. The practice of putting the stickers in some of the books was not done until 1977-78, and I was told that it had something to do with the government and taxes. I have since learned from my attorney in the last several years about the required Federal Judgment. If I had known that a Federal Court in 1971 had said that Scientology representations in its publications were false, misleading, etc. and that Hubbard's credentials were all falsified, I would not have relied on the representations made to me. 21. If I had known that the Church of Scientology throughout the period 1968-79 was actively engaged in elaborate programs to break into, burglarize, and steal from state and federal agencies, defame and smear people with elaborate espionage programs to destroy anyone who stood in Hubbard's path, I would not have worked for the organization or given them money. -13- Signed under the pains and penalties of perjury this ' ~ day of ~_~ , . ' Y'~-~'- ' /c, .,.... <~ ~ ., ~ " La Venda V~n Sch~ick ' ' '~ ~ ~ Daniel Leipold Hagenbaugh & Murphy 2 701 South Parker Street, Suite 1200 Orange, California 92668 3 (714) 835-5406 4 Mark Goldowitz 1611 Telegraph Ave., Suite 1200 5 Oakland, California 94612 (510) 835-0850 Special Counsel for Defendant Lawrence Wollersheim 7 Lawrence Wollersheim 8 P.O. Box 10910 Aspen, Colorado 81612 9 (303) 650-3336 ~0 In Pro Per ~ SUPERIOR COURT OF THE STATE OF CALIFORNIA ]9. COUNTY OF LOS ANGELES ~3 CHURCH OF SCIENTOLOGY OF ) No. BC 074815 CALIFORNIA, ) ) DECLARATION OF VICKI ]4 Plaintiff, ) AZNARAN ]5 ) VS. ) ~6 ) LARRY WOLLERSHEIM, ) Date: June 24, 1993 ) Time: 9:00 a.m. ~7 Defendant. ) Dept: 14 ) ]8 ) 19 20 I, Vicki Aznaran, declare: The attached Declaration of Vicki Aznaran, which I signed on July 18, 1990, is a true copy of a declaration submitted in the USA v. Fishman case. I have personal knowledge of the 93 facts set forth therein, and they are true and correct. I declare under penalty of~e~jury that the foregoing is true and 24 correct. Executed this ~ ~day of44~, 1993 at Dallas, 25 Texas. , 9~6 ~;fck~i'A~na~ .... 27 1 NURIK & KYLE, P ú A ú 2 Attorneys for Defendant 2937 S.W. 27th Avenue 3 Suite 203 Miami, Florida 33133 ~ (305) 441-2400 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 7 CASE NO. CR-88-0616-DLJ 8 UNITED STATES OF AMERICA, 9 Plaintiff, 10 v. 1! STEVEN FISHMAN, 12 Defendant. 13 / l~ DECLARATION OF VICKI AZNARAN ~5 I, VICKI AZNARAN declare as follows under penalty of ~6 perjury: ~7 I joined the Church of Scientology in 1972. In 1978, ~8 after approximately four years as staff members, my husband ~9 and I joined the Sea Organization. From 1978 to early 1987, 20 my husband and I worked most of our waking hours, with very 2! few days off, at our various assignments within Scientology. 22 I eventually became President of Religious Technology Center 23 and,supposedly, the top "ecclesiastical" authority within 24 Scientology. Richard was a high-level security officer. 25 During this period my husband and I became intimately 26 familiar with the structure and activities of various 27 1 I Scientology organizations. Among other things, I was 2 briefed on and was sometimes a participant in meetings 3 involving litigation tactics and various means used to 4 attack and fight "enemies" of Scientology. In numerous 5 instances I was in the chain of command for approval for ~ such activities. From 1984 to 1987, I held the office of 7 Inspector General 0;~ e~ ~-h ~ highest worldwide officeS in the 8 organization and so was privy to the most arcane practices 9 of the group. 10 The legal strategy of Scientology and the existence of ]] numerous potential legal problems, some of which are set ~2 forth below, were known to me when I was a staff member in X3 Scientology. Enemies of Scientology are deemed to be 14 "suppressive persons" ("SPs"). One becomes a "suppressive ~5 person" by doing a suppressive act, such as suing ~6 Scientology as a litigant or la~er. In the jargon of 17 Scientology, when one is "declared" this means that one has 18 been declared a "suppressire person" and, therefore, may be 19 harassed, hurt, damaged or destroyed without regard to 20 truth, honesty or legal rights. It is considered acceptable ~1 within Scientology to lie, cheat, steal and comit illegal 22 acts in the name of dealing with a "suppressive person." This practice or policy is sometimes referred to as the 2~ policy of "fair game." In the jargon of Scientolo~, a ~5 person who is "declared" is understood :to be a suppressive ~6 person. This means that the person is "fair game." The fair 27 2 game policy was issued in the 1960s. It was never cancelled. A document was issued for public relations reasons that purportedly cancelled "fair game"; however, that document stated that it did not change the manner of handling persons declared "SP." In reality, the purported cancellation of fair game is at most a matter of semantics. Enemies of Scientology are treated as "fair game." David Miscavige was the Chairman of the Board of Author Services Inc., ("ASI") in 1984 and 1985. ASI was incorporated to be the funnel through which profits from Scientology were channelled to L. Ron Hubbard and, therefore, it was very important within SCientology. Miscavige represented Hubbard in all aspects of controlling Scientology. He attended regular meetings with myself and other top officials of Scientology organizations to review the status of all Scientology's activities, including its litigation and dirty tricks campaigns against Scientology's enemies. Because of my position and the regular reports that came across my desk I know that throughout my presidency of RTC that fair game actions against enemies were commonplace. In addition to the litigation tactics described below, fair game activities included burglaries, assaults, disruption of enemies' businesses, spying, harassive investigations, abuse of confidential communications in parishioner files and so on. I specifically recall seeing one report regarding 3 ! attacks against Bent Corydon after Scientology became aware 2 that he was writing a book against Hubbard. 3 Other Hubbard writings encourage Scientologists to pursue litigation purely for harassment without regard to 5 the merits of a claim to cause enemies to fold. Hubbard's 6 writings state: ? "The purpose of the suit is to harass and discourage rather than to win...The 8 law can be used very easily to harass, and...will generally be sufficient to 9 cause [the enemy's] professional decease. If possible, of course ruin him 10 utterly." Hubbard, "Magazine articles on Level O Checksheet" American Saint Hill ll Organization 1968. 12 As President of RTC and a Sea Organization member, I ]3 attended meetings concerning the numerous legal actions l~ involving Scientology organizations. During this time 15 period, I had personal access to all legal documents having 16 to do with RTC. I received a report every day on my computer ~7 that included a synopsis of each ongoing legal case IS involving Scientology. I received, or so I was told, copies ~9 of every major motion filed in cases involving Scientology. 20 I was on the "approval lines" for legal documents dealing 2! with RTC. During this time period, I had the option of 22 attending legal meetings, although some were mandatory. I 23 attended many litigation meetings and became generally aware 24 of Scientology's dirty tricks and legal maneuvers. On 25 specifics, I frequently deferred to in-house and outside 26 counsel; however, at least in theory, I was the head of RTC 27 4 and had access to any business or litigation "secrets" of Scientology. It is the stated policy and practice of Scientology to use the legal system to abuse and harass its enemies. This crude, fundamental directive of Scientology is no secret. The policy is to do anything and everything possible to harass the opposing litigant without regard to whether any particular motion or maneuver is appropriate or warranted by the facts or applicable law. That policy was followed in every legal case I was involved with or learned about while a member of the Sea Organization. The management of Scientology consistently expressed and demonstrated a complete disdain for the court system, viewing it as nothing more than a method to harass enemies. Some examples of this are set forth below. During litigation between Gerald Armstrong and Scientology, which was before Judge Breckenridge of Superior Court for Los Angeles County, the court ordered the production of Armstrong's pre-clear ("PC") folders. These are files maintained by Scientology on those who submit to interrogation sessions in a process called auditing. During the course of that litigation I was ordered to go through Armstrong's folders and destroy or conceal anything that might support Armstrong's claims against Scientology. This practice is known within Scientology as "culling PC folders" and is a common litigation tactic employed by Scientology. 5 1 During other litigation in Los Angeles known to me as 2 the Wollersheim case, I was told that the judge had ordered 3 the production of Wollersheim's folders. As ordered, I 4 "culled" these files. In other words, I removed contents 5 that might have been damaging to Scientology or might have ~ supported Wollersheim's claims against Scientology. For 7 example, I removed evidence of events involving his family, 8 the anguish this caused him, evidence of disconnection from 9 family and evidence of fair game. 10 I was involved in numerous meetings concerning what is ll known to me as the Christofferson case in Portland, Oregon. ~2 This case was tried twice. In the first case, a Scientology 13 witness by the name of Martin Samuels was coached and I~ drilled for hours on how to lie convincingly or avoid 15 telling the truth. Before or during the second trial he I~ admitted to this course of conduct. In this litigation, a ~7 Scientologist by the name of Joan Shriver produced 18 responsive documents that may have been incriminating. This ~9 was a serious breach of policy for which she was punished. 20 These documents were ordered produced on such short notice 2! that apparently files were not thoroughly "culled." In 22 another case, an attorney was severely criticized and almost 23 fired for failing to properly coach and feed the desired 24 answers to Heber Jentzsch. Mr. Jentzsch was, for public 25 relations reasons, the purported head of the Church of 2~ Scientology International. During his deposition, Mr. 27 6 28 Jentzsch was unable to answer fundamental questions concerning the management of Church of Scientology International. In later 1979 and early 1980, there was a massive document destruction program undertaken to destroy any 6~evidence showing that L. Ron Hubbard ("LRH") controlled Scientology. I participated in this activity in Clearwater, Florida and am informed that there was also intensive document destruction at facilities in Gilman Hot Springs, California. From at least that point onward there was a continuous effort to hide or destroy any evidence of Hubbard's control. For example, during an IRS investigation in 1984 and 1985, while in bed with pneumonia, I was ordered out of bed by Norman Starkey, who told me that they had received a tip from a Los Angeles police officer advising them of a pending IRS raid in Los Angeles. Mr. Starkey ordered me to go to a computer facility and insure that all information on the computers in Los Angeles that might show Hubbard's involvement and control of Scientology's money was destroyed except for one copy of each document. These copies were to be saved on computer disks which were to be hidden in secure storage places. At the time I was also instructed to destroy anything that would show the control of Mr. Starkey or Mr. Miscavige over Scientology. In or about 1981, while working in a Scientology organization known as the Guardian's Office, I had access to 7 ! and observed various written and oral communication pertaining to illegitimate activities participated in by the 3 Guardian's Office. The Guardian's Office attempted to 4 infiltrate both governmental and private agencies including 5 the IRS, the Department of Justice, and the American Medical 6 Association and the National Institute of Mental Health. The 7 purpose of this was to steal documents pursuant to Hubbard's 8 "Snow White" program. The goal of this program was to 9 eliminate any negative reports about Hubbard and Scientology 10 that may have been held by these various agencies. While involved in Scientology I became aware of various 12 operations directed against an author who had written a 13 negative book about Scientology. The author, Paulette 14 Cooper, was subjected to various forms of harassment. One 15 operation included an attempt to frame her. A false bomb 16 threat was written. Scientology agents lifted a fingerprint 17 from Cooper's apartment. These fingerprints were then 18 transferred to the bomb threat letter. Ms. Cooper was 19 subjected to an investigation and was not cleared until an 20 FBI raid resulted in the seizure of Scientology documents 21 that exposed the operation as a frame-up. There was at 52 least one other operation directed against Ms. Cooper. The 23 substance of it was to plant a boyfriend to reinforce and 24 play upon her suicidal tendencies in the hopes that she 25 would commit suicide. In 1976 and 1977, the then-Mayor of Clearwater, 8 Florida, Gabe Cazares, was involved with litigation against Scientology. Arrangements were made to have an attorney by the name of Merril Vanniere, a Scientologist, represent Mr. Cazares and sabotage his case. This plot was also exposed by documents obtained in an FBI raid of a Scientology facility. Also, in response to Mr. Cazares' litigation against Scientology, an attempt was made to implicate Mr. Cazares in a staged hit-and-run accident. During an IRS criminal investigation in the 1984 to 1985 time period, the IRS ordered production of various communications between Hubbard and Author Services, Inc. (ASI). The ASI staff worked literally day and night for several days reviewing documents so that unfavorable documents could be destroyed or otherwise concealed from the IRS. Lyman Spurlock and Marion M. Dendue, Scientologists involved in this operation, informed me of this operation. Also during this IRS investigation, my husband, Rick Aznaran, was ordered to remove and conceal any incriminating documents from certain locations. He was also directed to make the computer network "raid proof." This involved creating a system where incriminating documents could be deleted from computer storage rapidly and before the IRS could obtain control over the computers. I have examined certain documents regarding Steven Fishman's experience with Scientology, have had conversations with Mr. Fishman's counsel, and have reviewed 9 ! the 1151-page autobiographical account of Mr. Fishman's Scientology experience entitled "The Lonesome Squirrel." 3 Based upon my 15 years of experience in Scientology and my ~ review of the Fishman materials, I offer the following 5 conclusions: 1. I believe Mr. Fishman's assertions that he was a 7 member since 1979 and that he was as actively involved as he 8 states. This belief is based on my experience that only a 9 committed member of long standing would know the details of 10 the inner workings of the group; Mr. Fishman has such l] knowledge. Awareness of certain confidential projects could 12 be achieved only by a member who was trusted by the 13 hierarchy; Mr. Fishman had such awareness. Involvement in a l~ group that thrives on secrecy and excludes most members from 15 participation in high-level projects means that any member ~6 who exceeds a certain level of involvement enjoys the trust X7 of the leadership; such trust would be earned only by 18 extended membership. Mr. Fishman enjoyed that trust. His 19 accounts of meetings with high-level officials and his 20 knowledge of the operations and functions of the hierarchy 21 are so detailed and accurate that they couldn't have been 22 gained except through direct personal experience. 2. Refutation by Scientology officials of Mr. 2~ Fishman's membership prior to February 8, 1986, and their 25 disclaimer of his involvement and their lack of any records 26 pertaining to such membership is perfectly consistent with 27 10 I their standard procedure in protecting themselves. As noted 2 above, I was personally involved in the destruction of 3 records when it suited their purpose. Scientology propounds the belief that any action whatsoever taken to protect the 5 organization is justified, as the group takes precedence over the individual. Any member performing criminal acts for 7 the benefit of the group was kept at arm's length; if 8 apprehended, the member was disavowed by Scientology. This procedure was used even on the wife of the founder of 10 Scientology. Given the serious potential threat that Mr. ]1 Fishman's defense posed to the group, I find Mr. Fishman's 12 account of certain members of Scientology's involvement in 13 the plan to fabricate the threats against Mr. Fishman and his counsel and to thereby undermine Mr. Fishman's 15 credibility and render him useless as a witness against Scientology to be consistent with their rodus oDerandi. 17 I declare under penalty of perjury under the laws of the State of Texas that the foregoing is true and correct. Executed this / day of , 1990, in Dallas, VI~Ki ~ZN~LRAN ' 22 23 2~ 2S 27 11 SUPPLEMENTAD DECLARATION OF VICKI AZNARAN I, Vicki Aznaran, declare: 1. I joined the Church of Scientology of California ("Scientology") in 1972, and was a member until I left in April 1987. From 1984 until 1987, I was Inspector General of the Religious Technology Center, an affiliated Scientology organization. At that time, this was one of the highest worldwide offices in Scientology. One of my offices was located at 4751 Fountain Avenue, Los Angeles. 2. By virtue of my high position, I was "in the loop" to receive communications about some of Scientology's most secret operations. The facts set forth in this declaration are based on my own personal knowledge, which came from many sources, including numerous discussions and meetings with top Scientology "intelligence officials" and other Scientologists and reading ]ocuments which passed across my desk or came to my computer. 3. During the 1984-87 period, Scien~ology operated a ~umber of "dirty tricks" operations out of the Office of Special Affairs (OSA), including one called MFTC (for "Mission Find The Crimes") and the "WOLLY" unit (which targeted Lawrence Wollersheim, his attorneys, and his case). The orders for these operations would go directly from OSA to private investigators, although Scientologydeceitfully tries to cloak such operations under "attorney-client privilege". 4. MFTC and the WOLLY unit ~ach had about 8-10 staff, and engaged in whatever dirty tricks were necessary to attack people and entities which were considered to be "enemies" of Scientology. The dirty tricks they used included destruction of evidence, theft of documents, illegal surveillance or bugging, blackmail, bribery, physical assault and other intimidation, securing perjured testimony. MFTC's mission was to find or manufacture crimes for "enemies" of Scientology. 5. Before and during the trial in Wollersheim v Church Of Scientoloqy of California, MFTC and WOLLY ran a number of operations directed against Wollersheim, his counsel, and the Court. One of these operations was an attempt to put pressure on Bill Swearinger, the son of the trial judge in the Wollersheim case, based on his alleged homosexuality. The idea was to dig up, or manufacture (perhaps by setting the son up in a compromising sexual position with a minor boy), dirt on the son which could be used to pressure the Judge to rule favorably for Scientology, or else to get the Judge disqualified. 6. Attached as Exhibit A is a true copy of an internal Scientology memorandum, dated 6/21/86, which discusses this "Swearinger Investigation". I received a hard copy of this document at about that time, and I believe I also received a copy of this document on my computer. The Linda referred to on the first page is Linda Hamil, who at the time ran the MFTC. The Marty referred to on the first page is Marry Rathbun, a top Scientology "intelligence" official, who ran this operation. 7. Scientology's "ambush interview", discussed in Exhibit A, makes the Mike Wallace/60 Minutes interview called by the same name look tame. The "ambush interview" generally involves doing 26~hatever it takes -- threats, physical force, bribery, or whatever -- to get an unprepared and unsuspecting target to say what is wanted. 2_ 8. I understand that Lynn Farny has submitted a 2 declaration stating that Scientology complied with Judge 3 Swearinger's order in the Wollersheim case to produce 4 Wollersheim's pre-clear files. This is false. As I stated in 5 my Fishman declaration, I personally culled and destroyed 6 (shredded) from these files evidence which would help Wollersheim 7 and hurt Scientology in the case. I was personally ordered to do so by David Miscavige, the head of Scientology, and Marty 8 Rathbun. The culling and destruction took place at the Fountain 30 Avenue building in Los Angeles. I was assisted in the document destruction by then Scientologist Jessie Prince. Lynn Farny was a low level Scientology official, and was not at the meetings ~where this was discussed. However, Lynn Farny is not telling the truth, because as a Scientology staff member he knows it is Scientology policy never to turn over information in litigation without first culling out (deleting and destroying) material that will harm Scientology. It is also, however, Scientology policy to lie to cover up such misdeeds. 9. Attached as Exhibit "B" to this declaration is a true copy of a document called "TRL", which is a Scientologytraining 2~ ~dri11 to teach Scientologists to lie convincingly. ~ 10. I understand Scientology is trying to vacate |Wollersheim's judgment on grounds that Judge Swearinger was biased against Scientology and his bias infected the jury. This is a typical Scientology tactic which it frequently uses in trials as insurance when Scientology loses an important case. 26 Scientologywill do things to set up a mistrial, such as calling 27 jurors in the middle of the night and hanging up, threatening TOTAL P.ol WOLLY INVEST I/C < ..... 21-Jun-1986 10:37 To: WOLLY INVEST I/C From: MFTC I/C Re: Swearinger Invest for your info and whatever else you can do with this... 20-Jun-1986 20:56 I)ear Linda, What does JP want to do with Bill Swearinqer? What did Bowles say to him? Why would we want Bill S to have Royce confess? Confess ~o ~hat? When will the rest of the 13 original targets be done? ~IL Marry 20-Jun-1986 20:40 I)ear Si r, ~o~pl lance Report. ' W~at was ordered: I sent over a 18 step invest to revive the Swearinger Invest. In response yo~ merc'd' "'Ilk, I'll expect the results of all of this by Friday.' (In this same comm you asked for the Mayer invest which is forwarded in a separate Merc.) What ~as do~e: T~e results of the Swearin~er Invest are in the report below. ~e original targets are at the very end of this co~. This is DK. fill Li nda S~earinge~ Invest results: S~mmary: Five of the thirteen investigative steps were completed and resulted in a) two Swearinger neighbo~-s recalling a White Cherokee by Bill's house a few times in the last 6 months {that's what Royce drives} and b~ Bill Swearinger oalling up Tim Bowles wanting to end =y=le o~ it all once arid for all. Step by step results follow. 1. Learn was not yet interviewed as she has not yet been located. However we did find out that she has left the employment of Varsity Communications and ~e found her last name, tra~ed her through her parents and now have her unlisted phone number i~ Hollyw. ood. She has not been in yet but should be able to be reached either tonight or Saturday. The good ne~s is that she no longe~ works for the company so ~il.l ~ot be unde~ the thumb of Palmieri. ~/~. Perry and E~binder have not been at the offioe or at ho~e over the last ~ days so have not yet been confronted. ~. Ambush intervie~ of Steve Perry (aka Bubba}. He ~ould confirm t-elationship of Bill S. and Walker. ~. Photos were taken to Royoe's neighbors and none recalled having ~ee~ Bill, Non o~ Bill's distinotive ca~ in the vicinity. 5. Bill's neighbors ~ere shown Noyoe, Bubba and E~binder and did not ~e~ognize the~. They were also sho~n the photo of Royce's white Cherokee and t~o of his nearest neighbors independently recognized havir~ see~ suoh a ~ar parked adjacent to the stairs leading up to Bill's ho~se a few times over the last six months. One of theseneighbors, M~. Franklee (a film edito~ said that Bill frequently had parties ~here young boys were observed at Bill' s house but had no =Ltst inct memories o~' any faces. 6. We have not been able to confir~ where Casey was 9 - 10-11 May due~o terminals not being a~essible. '7. The line to the secretary to get further data from the oourt ~=pc~-te~ ran i~to a logisiti~s snag and will need to be done Monday. B. Tho~h Royce has refused to speak at all with F~'an~ovioh, a line to go i~ onto ~e-establish the oomm ~as ~orked out which ~an be done early ne~t week (~rancovioh will take ove~ a ~heck owed to ~oyoe which ~iil be ~oming in Monday or Tues,. ~. The ~oung mexican we'd seen ~ith SwearingOt last month has not been identified. The neighbor checked with (Pranklee) recalled having seen him about a month ago walking away from the house, upset, originating to this neighbor "I can't go on like this any more, I'm real,ly upset.' ~nd this neighbor hasn't seen him since. Checks were made at a local ~xican restaurant the two had stopped at when under surveillance, no data, and a number in Guatemala possibly associated with this kid was c~ecked but the only person at the number ~ith contacts in LA ~as out of to~n for a week. So the kid could not be located to interview. -18. Ti~e spots Hhere Bill was seen to stop on surveillance were checked for familiarity with Royce or his vehicle or friends and the~e was no recognition. The vicinity of an address where Royce had been seen dropping off two young men was checked and one neighbor, a foreigr, man (Mr. Behar) recognized having seen a car similar to Bill S~ear~nger's in the neighborhood. 11. Stuart and Steve's office was visited, they were not there but the current office manager related a sto~y consistent with Royce Walker's des~ril3tion of S~earinger and Walker only casually knowing each other. 1~. Royce & friend's photo was shown to the receptionist and security ~an at 69~ Hollywood (~here Swearin~er's office is located, but ~ot d~a~in~ attention to Swea~i~ger). No recognition. His old ~T-f.tc~e ~ross the street was also ~hecked, no reads. -11. It was found that Caryl Warner does still practice law and works ~ut of 69~ Hollywood - Suite 500 - a full schedule every day. However a check made on Thursday revealed that he was out until Monday so no pretext interview has yet been done. A definite impingemerit was made from the actions taken B~11S~earinger phoned Tim Bowles at ~:15 today and said the following: that A1Bei of Ingram investigations was asking his neighbors ~ his clients questions about the veracity of Royce Walker, was i~y upset~ and said he wants it to stop immediately. He wants to er.d cycle on this escapade on his knowledge of the Judge's prejudice "once and for all". He said he is not willing to submit to a deposition (because the federal judge ruled that such a depo i~ irrelevant). However, he said he is Nilling to meet ~ith us to tell us wh~t he knows. He insists there is no prejudice from his father. He termed our efforts 'shooting in a barrel with nonexistant fish", somwething like that. He said that if we can't come to an immediate resolution on i~hi~ is he going to take "self-help". He specificaly mentioned ~uyi~g a gun or drafting and fil ing a motion for protective order in the federal case. He said he couldn't wait until Monday, he i~e~jded to resolve it no~. It is of interest that A1Bei did not intervieH any of the lqei~hbors, that ~as done by Ma~k Marinc. A1 St. went to the 6922 Hollywood building (S~eartnger's office~ and A1 Bei Jr. went to Royce's office at 7715 Sunset. We don't kno~ ~ho any of Bill's cl~ents are (though one of the women t~tervie~ed by Marino could t~ve been a client}. Nexi a) Have the confrontation with Swearinger and get him to tell the truth about ~his matter. If he insists he is being truthful, have him drag in Royce to ~onfess, and Francovich can be there too. t'Th~ fol.lowing steps to be do~ but called off if step (a) resolves it a~ co~inuing would ~ pointless.] b) X~erview Leann (per last call her ~o~ate said she's expected to be there Saturday) ~ho is ~ longer part of the Varsity office. She'll be ~ked ~ut whether the boys ~nt to Palm Springs as well. c) Ingram to call Casey to ask him Just one more questin - the Palm Springs question he neglected to ask him during the intervi~. ~) P~.l ~ ~u~t reporter string via the secretary resour~. e) A~ i~terviews of Embinder and Bubba. f) Fra~ovich to recontact Roy~ ~ith check o~ed to him and get him in. f) Pull down Caryl Warner string through pretext interview. il_ Ambush interview on Leann, the secretary (she ~as the one other .l~erson mentioned in the depo of Walker as someone he talked to about Son. She will be gotten outside of the office as in the office someone .~i_U ~ontact Palmieri and she'll clam up.) .~. lqn~bu~-h ~nterview of Steve Perry (aka Bubba). He could confirm ~i~g of Bill S. and Walker. iS. ~q~ ~erv~e~ of Embinder as possible. ú 4. Phc~to of Bill and Ron taken to Royce's neighbors to see whether .~~ seen them around. 5. Photos of Royce, Bubba, Embinder and Casey shown to Bill Swearinger' s neighbors. 6. Find out where Casey Klinger was the weekend 9 - 10 - 11 May, i.e. whether he was in Palm Springs or not. (pretext has been worked out to get this.) If in Palm Springs, get identity of the two fags they were with. 7. Use secretary resource who has a good line already to the court reporters to find out anything further on the cash payment cycle, i.e. was the Judge irritated, who else may have been there, etc. ~). Francovich to re-establish comm line with Royce over some business dealing, and see what further can be obtained from this line, get him to cop out to what occurred (witness present). 9. Use our Spanish speaking PI (Joe) to suitably interview the young mexican (P. Garcia may be name) guy who was seen with Bill Swearinger at least three mornings, who may live with Swearinger, and get the data on Bill's relationship with Royce 18. Use the data we have on Bill's contacts (places he was observed ~oi.nO ~n~en under surveillance and known comm lines he has) to interview ~-he~e contacts with pictures of Royce and Bill re: their relationship. 11. Stuart and Steve (Bill's former employers and Royce's friend) ~=en w/photos to establish how many times and for what reason Royce visited Bill. 12. Suitably inquire (with photos) at Bill's current law office about Walker, does he show up there frequently etc. 13. Pull down strings on any possible relationship between Swearinger and Caryl Warner (work in same suite though different offices) - through pretext interview. ,Pzl.'l the above to be done by Friday, the analyzed and retargetted. EXHIBITB I]~FLLIGE::C-": SPECLa. LIST, T.'tAINIkr',, ROUTi::E - TR L Furpoet,: To trcin th,j ~tudcnt to give a fa.lse stat~.ent with Good TR-1. To train the studunt to outflow false d-~ta effectively. Position: Same ~ TR-1 C~-mand$: Part 1 "Te~ me a lie". C~mand ~ivcm ~ c6ach. Pa~ ~ ~ter~e ~)~e 2 WC by co~ch. , Trainir.,-~ Stress: In Part 1 coach gives c.o~,~and, student origir. ates a falsebc Coach fl~:s for out TR 1 or TP. O. In Part 2 coach asks. question= of the student on bJs bachground or a subject. Student' give~ =ntrue date of 'a plau~ sort %hzt the student backs up ~rith further exp.)or~tor-i data upon the. co~ch . further questi6ns. The coach f!ur~.s for out TR 0 an4 T~ 1,..an'~ for student ú -f~.blin~ on question ~:nswers.- The student should be coached on a ~radient until he/she can lie f~Lly. ' Short example: . Coach: %~n~re-do you c~e from? Student: I ccme frcm the H~usewives ~ittee Coach: But you said earlier tlmt ~u were sidle. Student: Well, act~y I was Pa-ied but ~ ~v. orccd~ ~ have 2 ',rids S~ t sub~bs ~here X ~ a housewife, in fa~'I'~. ~. m~b~ of the P.T.A COach: }~t to~ is it that you live Student: West ~hton . Coach: But there is no public school in West Br~ht.~ a P.T.A. m~b~. ~nch: Oh, and who is the C~an thee? etc. UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA RELIGIOUS TECHNOLOGY CENTER, a ) California corporation, et al., ) ) VERSUS ) CV 85-711 JMI (Bx) ) ROBIN SCOTT, an individual, ) CV 85-7197 JMI (Bx) et al. ) RELIGIOUS TECHNOLOGY CENTER, a ) California corporation, et al., ) ) VERSUS - ) ) LARRY WOLLERSHEIM, an ) individual, et al. , ) AND RELATED COUNTERCLAIMS ) ORAL DEPOSITION OF VICKI J. AZNARAN August 2, 1989 Pages. 130~252 ANSWERS AND ORAL DEPOSITION OF VICKI J. AZNARAN, a witness produced at the instance of the Defendants, taken in the above styled and numbered cause on the 2nd day of August, 1989, at 10:55 o'clock_ a.m., before KIM S. JOHNSEN, a Certified Shorthand Reporter in and for the State of Texas, at the offices of Clark, West, Keller, 'Butler &.Ellis,.4800 Renaissance Tower, 1201 Elm Street,' in the City Of Dallas, County of Dallas, State of Texas, in accordance with the Notice and Subpoena issued and the provisions set for_th: ~ (Defendants' Exhibit V. Aznaran Number ~ 1 16 was marked for identification.) ~' ~Looking) ~ 2 A. ' ~ ~ 3 Q. Ms- Aznaran, do you know what Exhibit 16 is? 4 A. Yes. It's an LRH executive directive. 5 Q. ~ave you ever seen it before? 6 A ú Yes - 7 Q. Did you see it when you were with the Church of 8 ScientologY? _. 9 A. Yes. 10 Q. May I see it for a moment? 11 A. (~anding) ú 12 MR. FAGELBAUM: Mark as Exhibit 17 a one-page 13 document bearing the notation TR-1. (Defendants' Exhibit V. Aznaran Number 14 17 was marked for identification.) 15 A. Okay ú 16 Q. Do you know what this document is? 17 A. Yes ú 18 Q. What is it? 19 A. It ' s known as TR lie. 20 Q. TR lie? 21 A. Yes ú 22 Q. L-i-e? 23 A. yes. 24 Q. Have you seen this document before? 25 A. Yes. i =-'.~- 1 Q. Where have you seen it? -.~ ~.~' " 2 A. I first saw it in a mission in Dallas, later saw it Z':.- ~ ... ~ ~_~ 3 in the Guardian's Office in Los Angeles. 4 Q. When you say "mission in Dallas," is that a ~ 5 Scientology mission in Dallas? 6 A. Yes. ,: 1 i 7 Q. And what is a TR lie? i 8 A. It's a training regimen where someone is trained to -~ ~l 10 MR. MOXON: I object to the question. She 11 answered before I could object on the basis of lack of 12 foundation. Move to strike. 13 0. Do you know what the purpose of this document was 14 !for? 15 MR. MOXON: Objection; lack of foundation. 16 A. I know what it was explained to me that it was for. ~,~ 17 O. Who explained it to you? 18 A. A member of the Guardian's Office named Danny 19 Ch adwe 11. 20 Q. When did this occur? 21 A. 1974 or 5, I'd say. 22 Q. And how was it explained to you at that time? 23 MR. HELLER: Objection; hearsay. 24 MR. MOXON: Same objection. 25 A. That the purpose of it was to teach you to be able "'-~ 1 to lie when you needed to when you were asked questions that ~, ' .-' ~ 2 you didn't want to answer about persons, such as reporters o~ ~. ! '~ 3 whatever. .__ -~ :mmssT 4 MR. MOXON: Move to strike. 5 Q. Who was exposed to this procedure in the Church of 6 Scientology? 7 MR. HELLER: Objection; calls for speculation. 8 MR. MOXON: I'll join in the objection. Also .... "" 9 lack of foundation. Tfl 10 A. I mean, I couldn't say over all the years who all 11 was exposed to this. 12 Q. Who was given this kind of training as a generic 13 class, not an individual? 14 MR. MOXON: Objection; lack of foundation. 15 MR. HELLER: And speculative. 16 A. People in B1 in the GO. 17 -- MR. MOXON: Move to strike. 18 A. And public relations staff and guardian area. 19 Scient ologist s, GAS is what they went by, GAS. 20 MR. MOXON:-. Move to strike. 21 Q. What are guardian area Scientologists? 22 A. These are Scientologists that did work in the field 23 for the Guardian's Office. 24 Q. And what is B1 of the GO? 25 A. Bureau 1 are the Intelligence Bureau. œ- 1 MR. HELLER: Sorry. :, . ú 2 A. In order to show compliance that it was occurring, .~_ ~- 3 and then I was involved in the approval of the new name for 4 it. 5 MR. HELLER: Objection; move to strike because 6 the answer is hearsay answer. 7 MR. MOXON: Join in the objection. ~ ~.~ = 8 Q. Now, was the process of TR-1 made available to ~ 9 personnel in OSA? 8~ 10 MR. KELLER: Objection; no foundation. .-~]~ ~ 11 MR. MOXON: Join in the objection. -~- 12 A. I think we could say the tech was certainly applied. 13 The -- this document did not exist laying around there. 14 MR. MOXON: Okay. And move to strike the first 15 part of that answer based on my objection and because it's 16 not responsive. 17 Q. Are you aware of the tech being applied of TR-1 to 18 personnel in the OSA? 19 A~ I'm aware of them applying it to others. 20 MR. HELLER: Objection; no foundation. Again, 21 move to strike. 22 MR. MOXON: Join. 23 Q. Bow were you aware of that? 24 A. Well, let's start -- we can start with depositions. 25 There are certain people offered up to be -- when a j 1 deposition is noticed for a corporation, there are certain ~. ~ 2 people offered up to go and have that deposition taken. ~ -~.-~- 3 Before they do that, they are coached on what they should 4 know and should and should not say. ~-! 5 Q. Did you personally observe that happening? ~: 6 A. Yes, I have. \'~ 7 Q. Rave you observed that happening in this case? ~ 8 MR. MOXON: Today. ~.a~,~ ~ 9 A. I don't know if it was in this case or not. 3E 10 Q. Do you know of personnel affiliated with RTC being ~ 11 afforded this opportunity? 12 MR. MOXON: Objection; vague and ambiguous, 13 lack of foundation. 14 MR. HELLER: And unintelligible. 15 A. Yes. 16 MR. MOXON: Also leading. ! 17 Q. who? 18 MR. MOXON: Move to strike. O~ject to the 19 pending question. 20 A. Jessie Prince. 21 MR.. MOXON: Move to strike. 22 Q. Do you know if Jessie Prince testified in the 23 hearing in this case? 24 A. As a matter of fact, he did. 25 Q. Was he given TR-1 training prior to his testimony? ~: 1 MR. MOXON: Objection; lack of foundation. ~: :' 2 MR. HELLER: I'll join in that objection. o~7~~ ~- , 3 A. He was drilled as to what to say and what not to ~'=. 4 say. .:! ~, ~ ú 5 MR MOXON: I want to caution the witness ~'~ 6 again. She 's obviously making some broad generalities that 7.~ : 7 are not responsive necessarily to the questions, but if she' s ?.~ 8 talking about attorneys speaking with some -- if she's o~M[' -~. 9 referring to attorneys speaking to a client before they go 9.~ 10 into a deposition, I'm not sure if that's what she's talking œ~ 11 about or if she's, you know, making up something new at this a88[- 12 point. But to the extent she's referring to some 13 attorney-client com~nication when she's making an inference 14 or opinion about it, I instruct her that it's a privileged 15 matter. 16 MS. MCRAE: I'll caution the witness. I 17 represent the witness, Mr. Moxon. 18 MR. HELLER: Well, it's not for you to caution 19 the witness. It's Mr. Moxon's privilege. It's his ciient 20 which is being breached. Assuming you are the most reputable 21 attorney in the world, it still is his job to caution the 22 witness and make sure there are no disclosures of that as 23 well as your job and as well, as I might say, Mr. Fagelbaum's 24 job. 25 I assume Mr. Fagelbaum is not going to get into it to : 1 make the determination in good faith, but in fact that's a '2_ 2 job of an officer of the court, most particularly Mr. Moxon' ~ ~ i~ -'~- 3 job .~_-_ ú 4 Q. Was Mr. Prince advised -- excuse me -- was Mr. 5 Prince drilled by somebody other than an attorney in this 6 case? 7 A. Yes, he was. t ~ 8 Q. Who was he drilled by? 9 A. Mysel f. li ' 10 Q. Was there anyone else present at that time? t 11 A. I believe Jeff Shriver was. 12 Q. Anyone else? 13 A. I don't think so. =. 14 Q. Did you follow the procedures set forth in TR-I? ~ 15 A. Not rotely, no. ~ 16 Q. To what extent were they followed? 17 A. Well, I worked out for him not to tell the truth 18 about what happened when he was signing certain documents 19 over in England. 20 Q. What specifically did you tell Mr. Prince not to 21 tell the truth about? 22 A. It was more a situation of Jessie and I working out 23 together what he was going to say. 24 Q. Okay. 25 A. And what he was not going to say. 1 Q. All right. Can you describe what that conversation 2 was? --~ 3 MR. SELLER: I'm sorry. Please repeat that. .__ e~ '. ~'~ 4 Q. Can you describe that conversation? ~ '- ~. !,i]~~~ 5 MR. KELLER: Object to the extent it calls for ~-, ~ 6 ~earsay. ., ..~ 7 MR. MOXON: Join in the objection. ,~.~. ~~ ~ ~ 8 A. There was a document signed by Jessie, handwritten ~- ~me$, 'f ~-~' 9 ]ocument agreeing to something. It was signed by him and __ ;~œ~-~-~ 10 another party in this -- on the other side in this lawsuit. ~', _'œ/~.+ 11 ~And we were concerned that this document would be if Jessie ~' 12 told exactly how this occurred that he signed that, that it '~3~ 13 would be seen as, I guess you'd say, a release so to speak or 14 something along that line. Jessie agreed that he would say 15 ~e did not have the authority to sign anything like that 16 ~hereas when he was sent to England he did have the '~ 17 authority, and he also, of course, had it as a senior :~ 18 executive in RTC. 19 Q. What was the purpose of sending Mr. Prince to 20 Europe? 21 A. England. 22 Q. Yes. 23 MR. MOXON: Object; lack of foundation. 24 A. To get the people, one or more of the other people 25 who were -- who were involved in the theft of the materials, 253 1 IN THE UNITED STATES DISTRICT COURT ~ FOR THE CENTRAL DISTRICT OF CALIFORNIA 2 RELIGIOUS TECHNOLOGY CENTER, A ) ~. California Corporation, et al.,)CV 85-711 JMI (Bx) 3 Plaintiffs, ) )CV 85-7197JMI (Bx) 4 vs. ) ) 5 ROBIN SCOTT, An Individual, ) et al. ) 6 Defendants. ) ) 7 RELIGIOUS TECHNOLOGY CENTER, A ) California Corporation, et al.,) 8 Plaintiffs, ) ) 9 vs. ) ) 10 LARRY WOLLERSHEIM, An ) Individual, et al., ) 11 Defendants. ) ) 12 AND RELATED COUNTER-CLAIMS ) ) 13 *********************************************** _ ORAL DEPOSITION OF VICKI J. AZNARAN = 14 AUGUST 3, 1989 15 16 ANSWERS AND DEPOSITION OF VICKI J. AZNARAN, 17 produced as a witness on behalf of the Defendants 18 and Counter-Claimants, taken in the above-styled 19 and -numbered cause on the 3rd day of August, 20 A. D.., 1989, before Lori A. Belvin, a Certified 21 Shorthand Reporter in and for the State of Texas, 22 in the conference room of CLARK, WEST, KELLER, 23 BUTLER & ELLIS, 4800 Renaissance Tower, City of 24 Dallas, County of Dallas, State of Texas, in 25 accordance with Federal Rules of Civil Procedure. COURT REPORTERS ASSOCIATED ~'I~~tF~ Dallas, Texas 75219 (214) 748.-3382 '2771 1 weapon? 2 MR. MOXON: I object. 3 MR. HELLER: Lack of foundation. I'm 4 not sure I see the relevance, and well given of 5 what I know of my clients' involvement in regards 6 to the counterclaim. 7 THE WITNESS: Yes. 8 Q. What was that policy? 9 MR. MOXON: Move to strike. Same 10 objection. 11 MR. HELLER: An objection on relevancy. 12 THE WITNESS: There was an order from 13 Hubbard -- actually more than one. One concerning 14 Michael Flynn and another one concerning 15 litigation in general, which state that lawsuits 16 can be used and should be used to deplete anyone 17 who sues you money and harass them and get them to 18 back off. 19 MR. HELLER: I move to strike. It's 20 hearsay. 21 MR. MOXON: I join. 22 Q. Did you have any discussions with Church 23 of Scientology management with respect to that 24 policy? 25 MR. MOXON: Same objection. Lack of COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748-3382 '278 1 foundation. 2 THE WITNESS: Yes. 3 Q. Who did you have such discussions with? 4 A. Pat Broeker, Ann Broeker, David 5 Miscavige, Lyman Spurlock, Marty Rathbun, 6 Marc Yager -- 7 MR. HELLER: I'm going to move to 8 strike. I move to strike based on relevance. 9 MR. FAGELBAUM: I don't believe the 10 witness has finished her answer yet. 11 MR. HELLER: Oh, I'm sorry. 12 THE WITNESS: Jesse Prince, Mark Ingber, 13 Wendell Reynolds, Steve Marlowe, Gary Reisdorf, 14 Bill Franks. That's all I can think of right 15 now. 16 Q. Did you ever have such discussions with 17 Norman Starkey? 18 MR. HELLER: Objection. Leading. 19 MR. MOXON: Objection. I join. 20 THE WITNESS: Not that I recall. 21 Q. Now, the people that you did identify 22 that you had such discussions with, did they all 23 approve of utilizing that church policy of using 24 litigation as a weapon? 25 MR. MOXON: Objection. Leading COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748-3382 ~80 1 and his group to spend money on litigation rather 2 than on their group or expanding their group. 3 MR. MOXON: I move to strike as the 4 reasons I've stated. It's also nonresponsive. As 5 we know, Mr. Fagelbaum, the litigation's being 6 paid for by Frank Gerbode, who's not yet a party 7 to this action. 8 MR. FAGELBAUM: I'm not going to respond 9 to your comments. If you want to make an 10 objection, make an objection. 11 MR. MOXON: I made an objection. I move 12 to strike the answer. 13 Q. While you were president of the RTC, 14 were you aware of any Church of Scientology policy 15 regarding compliance with discovery requests that 16 were issued in lawsuits? 17 MR. HELLER: I'm going to have to object 18 on relevance as well as lack of'foundation. 19 MR. MOXON: And ambiguity. I join in 2O it. 21 MR. HELLER: That's true. It's an 22 unintelligible question. 23 MR. MOXON: Also calls for a potentially 24 attorney/client communication, depending on the 25 witness' understanding of that ambiguous COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748-3382 '281 1 question. 2 Q. I'm only asking for information that was 3 provided to you by someone other than a lawyer? 4 MR. MOXON: That doesn't cure the 5 problem, Mr. Fagelbaum, as you know. 6 Communications can be -- can and were provided to 7 her indirectly from attorneys. 8 MR. FAGELBAUM: As you know, Mr. Moxon, 9 you can't immunize facts by feeding them through a 10 lawyer. 11 Q. You can answer. _ 12 MR. MOXON: So that means you're going 13 to ignore the privilege? 14 THE WITNESS: Yes, there was. 15 MR. MOXON: I move to strike. 16 Q. What was that policy? 17 MR. MOXON: Same objection. 18 THE WITNESS: Discovery requests as well 19 as orders to produce documents or something by a 20 judge were complied with only if what was being 21 produced would not be damaging. If it was -] 22 something damaging, then it was to be fought by 23 the attorneys or destroyed or whatever, so that it 24 wouldn't have to be produced. 25 MR. MOXON: I move to strike it. COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748~3382 '285 1 A. Marty Rathbun, Jesse Prince, David 2 Miscavige, Paul Kellerhaus, Pat Broeker, Lyman 3 Spurlock. That's all I can think of right now. 4 Q. Did you ever have such discussions with 5 Norman Starkey? 6 MR. HELLER: Leading. 7 MR. MOXON: Objection. Leading. 8 THE WITNESS: Not that I recall. 9 MR. HELLER: Let's take a very short 10 break. 11 MR. FAGELBAUM: Okay. 12 (Time Noted: 10:38 a.m.) 13 (Short recess.) 14 (Time Noted: 11:02 a.m.) 15 Q. Mrs. Aznaran, who is Paul Kellerhaus? 16 A. He is a security guard or he was a 17 security guard at Gilman Hot Springs. 18 Q. To your knowledge, has the policy that 19 you testified to concerning the Church of 20 Scientology's response to discovery requests been 21 applied in this lawsuit against David Mayo? 22 MR. MOXON: Objection. Leading 23 question. Lack of foundation. 24 MR. HELLER: I'll join in both 25 objections. COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748-3382 '286 1 THE WITNESS: Yes. 2 MR. MOXON: I move to strike. 3 Q. In what manner? 4 A. Larry Wollersheim is a part of this 5 counterclaim, is he not? Wasn't he served part of 6 this suit; is that correct? 7 Q. Larry Wollersheim is a defendant in this 8 lawsuit, and he's consulted. 9 A. In the counterclaim? 10 Q. Not in the counterclaim. One of the 11 lawsuits filed by the Church of Scientology. 12 A. Okay. So he's a part of this? 13 Q. Yes. 14 A. Okay. I and Jesse Prince removed 15 documents from his files that would be auditing 16 files, and personnel and ethics files that had to 17 do with his RPF assignment; letters from his 18 family; letters to his family; conditions 19 assignments; and HCO bulletins concerning upper 20 level materials. 21 MR. MOXON: I move to strike. 22 MR. HELLER: Are you finished? 23 THE WITNESS: Yes. 24 MR. HELLER: Move to strike as 25 completely nonresponsive. The scope of the COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748-3382 f '287 1t response has nothing to do with this lawsuit. 2~ Q. What was done with those documents that 3 were removed? 4 A. They were destroyed. 5 Q. By whom? 6 MR. HELLER: By whom? I didn't hear 7 that last question. 8 Q. By whom? 9 A. By me and Jesse and some probably by 10 Alison Andrus. 11 Q. Is that Jesse Prince? 12 A. Yes. 13 Q. And Alison Anders? 14 A. Andrus, A-n-d-r-u-s. 15 Q. What's Alison Andrus' post? 16 A. At that time she was my communicator or 17 secretary. 18 Q. By whose authority did you remove these 19 documents and destroy them? 20 .. A. By whose authority? 21 Q. Were you ordered to do that? 22 A. I was asked to do it, yes. 23 Q. By whom? 24 A. Marty Rathbun. 25 Q. Were you told at the time why that was COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748-3382 1 being done. 2] A. I believe it was because those files had 3 been ordered to be produced in the Wollersheim 4 case. 5 MR. MOXON: Objection. Speculation. 6 MR. HELLER: And it's hearsay, and, 7 again, the whole thing should be struck because 8 the predicate of the question was: Was it done in 9 this case. But clearly if the fact it ever 10 occurred, it has nothing to do with this case. 11 MR. MOXON: I join in the motion to 12 strike. 13 Q. The files you were referring to, the 14 Wollersheim files, were those his PC files? 15 Ai They were his auditing files, his 16 personnel files, and his ethics files. David 17 Mayo's PC files were also destroyed. 18 MR. MOXON: I move to strike. 19 MR. HELLER: It's nonresponsive. 20 Q. Did David Mayo have any auditing files? 21 A. He had a great number of them. 22 Q. Did David Mayo have any PC files? 23 A. That's -- I use the same, PC, auditing 24 files, same, same deal. 25 Q. Did David Mayo have any ethics files? COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748-3382 '289 1 A. Yes. 2 Q. During the pendency of this litigation, 3 were any of those files destroyed? 4 A. The auditing files were. 5 Q. Why were they destroyed? 6 A. So they wouldn't be available for any 7 production requests and have to be brought into 8 the courtroom. 9 Q. How do you know these documents were 10 destroyed? 11 MR. HELLER: I move to strike the prior 12 answer. It has no foundation and consequently 13 speculative. 14 MR. MOXON: I join the motion. 15 THE WITNESS: David Miscavige requested 16 that Jesse Prince and I have all the auditing ~ 17 files, PC files, if you will, destroyed of anyone ~' 18 we were in litigation with or were enemies that we ~_- 19 might end up in litigation with. -- 20 MR MOXON: I move to strike Hearsay ..~ 21 THE WITNESS: I then put together a ~_; 22 project to do that. Paul Kellerhaus saw to the ~- 23 execution of that project, and I think he .t-~ 24 destroyed two or three truckloads of files. -'~' 25 ~' MR MOXON: I move to strike !;-~ ' ' COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748-3382 [ '290 1 Speculation. Hearsay. 2 MR. HELLER: I join. 3 Q. Where did this document destruction take 4 place? 5 A. Documents were removed from Gilman Hot 6 Springs and taken to a place that's specifically 7 for the destruction of documents, you know, that 8 pulps them, and I don't know the name or location 9 of that place. I never went there. 10 Q. How did David Miscavige communicate his 11 request to you? ~ 12 A. In person verbally. 13 Q. Did he tell you at the time why he 14 wanted that done? 15 MR. MOXON: I object. It calls for 16 hearsay. 17 MR. HELLER: Same objection. 18 THE WITNESS: Yes, he did. 19 Q. What did he say? 20 MR. MOXON: Objection. Calls for 21 hearsay. 22 MR. HELLER: I join. 23 THE WITNESS: He said that we didn't -- 24 we had problems with these things having to be 25 produced in court. We didn't want them in the COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748~3382 '291 courtroom and to just get rid of them all now 2 before the problem ever came up again. 3 MR. MOXON: I move to strike. 4 Q. Are you familiar with L. Ron Hubbard's 5 handwriting? 6 A. Yes. 7 Q. Can you recognize it? 8 A. I believe so. 9 Q. Are you familiar with David Mayo's 10 handwriting? 11 MR. HELLER: I'm going to object to the 12 last answer for lack of foundation and this 13 question, as well. 14 THE WITNESS: Yes. 15 Q. Can you recognize it? 16 A. I believe I could. 17 Q. Have you seen examples of L. Ron 18 Hubbard's handwriting while you were with the 19 Church of Scientology? 20 A. Yes, I have. 21 Q. Have you seen examples of David Mayo's 22 handwriting while you were with the Church of 23 Scientology? 24 A. Yes. 25 Q. Are you familiar with an upper level COURT REPORTERS ASSOCIATED Dallas, Texas 75219 (214) 748-3382 DECLARATION OF MARGERY WAKEFIELD I, Margery Wakefield, having personal knowledge of the following, hereby declare: 1. I was a member of the Church of Scientology of CalifOrnia from October of 1968 until February of 1980. I joined the Church in Los Angeles, California, where I was primarily based although I also took courses and/or worked at Church organizations in St. Louis, Washington, D.C., Atlanta, Georgia and Miami, Florida. 2. While in Scientology I progressed to the level of OT 3 (an advanced level) and was also audited on New Era Dianetics for OT's, which is now OT 5. 3. During the summer and fall of 1979, I worked as a volunteer for the Church's "intelligence" operation, then called the Guardian's Office (G.O.) and now called the Office of Special Affairs, or O.S.A. I performed volunteer work for the G.O. at the Cedars location in Los Angeles and at the old Bank of Clearwater location in Clearwater, Florida. It is concerning some aspects of this volunteer work for the G.O. that this declaration is written. 4. In the fall of 1979, I was approached by a young woman from the G.O. in Clearwater and given a special project involving Pinellas County Circuit Court Judge Harry Fogle. I was told that Judge Fogle was ruling on an important case involving Scientology, although I was not told any -2- further details of the case, which would have been normal, as the G.O. operated on a need-to-know basis. My understanding was that this operation was being supervised by a G.O. agent named Milt Wolf. 5. My directions concerning Judge Fogle were as follows. I was sent with another Scientologist, pianist Mario Feninger, to attend Judge Fogle's Sunday school class at the Seminole United Methodist Church in Seminole, Florida. Mario gave a short talk on Scientology for Judge Fogle's comparative religion class. My directions were to befriend Judge Fogle after the class and get him to give me a tour of the church while engaging him in conversation. I was to try to get him alone in a room with me. 6. I was then instructed by G.O. personnel that I would be called into court where I would, under oath, make certain allegations concerning Judge Fogle: namely, that he had made sexual advances toward me, and also that he had made certain disparaging comments to me about Scientology. This was to be used to disqualify the judge from a case before him dealing with Scientology. I was coached by several different G.O. personnel who pretended to be the cross examining attorneys. 7. I was coached for my performance in court according to the Scientology policy called TR-L (for Training Routine Lie) which I was already familiar with as I had been introduced to it on one of my Scientology courses. TR-L teaches a -2- -3- Scientologist to lie with conviction under stressful circumstances. 8. I remember asking one of the G.O. staff members about the fact that they were teaching me to lie under oath, and I was quoted the Scientology policy called "the greatest good for the greatest number of dynamics," which simply means that whatever must be done to ensure the survival of the "third dynamic of Scientology" must be done regardless of the side effects. In other words, Scientology law is considered to be above and outside the jurisdiction of non-Scientology or "wog" law. Scientologists do not honor the Biblical oath, even though they may say that they do. This is TR-L in practice. 9. As instructed, I did meet with Judge Fogle in his Sunday school class. After the class, I did engage him in conversation, got him to give me a tour of the church, and was at one point alone in a room with him. As it happened, I never was called into the courtroom to testify against Judge Fogle, and I assumed that the situation had been taken care of in another way. 10. I was also engaged in another project at the Cedars building in Los Angeles and this project had to do with the Federal action involving the eleven Scientologists charged with burglarizing federal offices in Washington, D.C. -3- -4- 11. It was Standard Operating Procedure in Scientology to assign private investigators to collect information on each judge, and each lawyer and witness for the opposition in any important case. This information was then brought into the G.O. offices where a work station had been set up for each person being targeted for investigation. 12. All the information collected on one individual, for example a judge, was then laid out in chronological order in what was called a "time track." Bits and pieces of paper would be taped on a long sheet of paper. It was then the job of a writer to come in and write a narrative from this time track, and it was common knowledge that this narrative would be made available to the Scientology attorneys and it would be used for blackmail purposes when possible. 13. I was the writer assigned to complete a narrative on the U.S. Attorney's Office attorney named Raymond Banoun, which I did do. I was told to highlight with a yellow highlighter any mentions in the narrative of sexual misconduct, use of illegal substances or other crimes. 14. In another project in this same time frame, I was assigned the task of going through witness Michael Meisner's supposedly confidential preclear files and similarly tabbing any incidences of sexual irregularities, drug use, or criminal conduct to be used against him. -4- 15. I consider myself to have been an average Scientologist in the performance of these and other duties for the G.O. In one other case, I was included in a meeting where two murders were planned by Scientology personnel, and I was at that time in agreement with everything I heard planned in the meeting. 16. It is my opinion that I was brainwashed and under hypnosis by Scientology for twelve years. If I had been ordered to commit suicide by the organization I would have, without question. I think I might have taken a life if ordered. This was the strength of the mind control that I was under in Scientology. 17. Therefore, to perjure myself under oath when so ordered by the organization was not, to me, an unreasonable task, especially if I were led to believe that the security and/or survival of the organization was at stake. 18. I believe that most any ordinary Scientologist who was trained in Training Routine Lie would, upon command, lie in court, and would lie also about having been so trained. To put it simply, nothing such a Scientologist says in court can be believed or regarded to be true, as the Scientologist believes him or herself to be above, or outside the jurisdiction of "wog law." Such a Scientologist will not honor the Biblical oath because it has no meaning to him/her. -5- -6- 19. I believe my opinion can be substantiated by corroboration by other ex-Scientologists, particularly those who have had experience in working for the G.O./O.S.A. I declare under penalty of perjury, under the laws of the State of California, that the foregoing is true and correct. Executed the 23rd day of June, 1993, at Tampa, Florida. -6- 11/Feb/90 Dear Margery, You sent me a survey. I am sorry you have been through what you have. I went through a lot as did many of us but not to the extent that you have. I spent over $100,000 in Scientology and sometimes worked 3 jobs to pay for- it. I stupidly refinanced my house which I am still paying for. But I came to tenms with Scientology did not force me to do any of this. I will ingly gave the,'n the money because I believed them. They may have lied and they may believe sincerely that they ape right. I am the one who is nespc, nsible for making the mistake. But you know as wel 1 as I do some of it worked and very wel 1. 'that is what I refer to as the universal truth. Then there is Hubbard's think that he threw in and I bought it. Oh yeah I got thrown in ethic:ss and did 72 hr. sessio~s with a tooth brush cleaning the carpet at the old AO in Scotland and that was just after writing my success story for clear. When I get with some "old" Scientologissts we tel 1 war stories and laugh our heads off that we bought it hook ,1 ine and sinker. We got to give the old man or-edit, he was a gpeat communicatop. Anyway I was in for 17 yrs. and some 1 ittl e voice in my head kept me from joining staff. I sigr~ed the sea org contract and was real l y dedicated but I had an inside knowinghess that kept me surviving. I understand it all now and know what I was doing in Scientology so that is the price I paid for the job I did. I graduated from the BC so I was a Class VI. When I final l y got out of Scientology was when I finisshed New OT VII on the Key to Life course in LA. So I attested to the EP there and knew that nobody would ever- believe me but I put it on peEopd. Then I went to Flag and gave them the EP, had a floating TA and got back from the CS that I needed to buy '2 more intensaives of audited NOTs. I real ized then that I was out the top and knew more than they did and still do today. After being threatened with the ethics offic:er and signing release papers, etc., etc. I got the heck OLtt of there for good. I misssed the fun of it all and the auditing but I didn't need the BS f~-om them anymor-e. Laten I went to S'~anta Barbaria and was vepified by David Mayo that I indeed had the EP and was done. So now what about you? What level did you ~each? With the counse~ ins I have done since I have been out o~ Sciento]ogy I wou~d say thene is some un~lat things. F~ank]y I don't give two hoots o~ a ho]le~ i~ someone wants to say that is eva]uative. Sciento]ogy does not have the whole o~ co~pect sto~y on OT III or- how to run the NOTs data cor"r'ecztly. They cJon't even have the correct story. I can and have blown somebodie's entire N0"['s case in about 5 mins. AncJ believe me the~E' a whole lot of people out there who never' even walked in a Scientology doop who ~::now about the same thing. I was amazed. No wonde~~ we ne've~ al l owect to ~ead any othe~ stuff we would have found out the whole wor'ld knows and wouldn't have paid the pr-ice. ]: don't charge and sso if this is all the case for- you giVE' me a cal 1 and I can do it ove~ the phone or' if you ar-e even in this apea stop by and I'll take car. E, of it for' you. Norwalk, California March 1, 1990 To whom it may concern: In support of Lawrence D. Wollersheim's charges against the so-called 'Church' of Scientology, I herewith offer the following testimony. From April 1975 to April 1976 I was in charge of public relations for the cult of Scientology ~n Denver, Colorado. I appeared numerous times on television and radio to promote scientolo~y. I hosted an hour long scientology radio program on three different radio stations: KAAT, KTLA, and KWGN. For thousands of people in Colorado, I was scientology. I was keenly aware that in the accepted sense of the word, ~e were not even remotely a religion. There was however a sham widely in practice throughout the scientology network consisting of mock 'Sunday Services' wherein a 'minister' wearing the black garb and clerical collar of a catholic priest would ~et up and mouth a lot of pseudo-religious so~nding bromides, none of which I observed were ever practice~ in the cult itself. An odd looking cross, the brain cbild ~f l,. Ron Hubbard, was hauled out,dusted off and put on display, all for the purpose of reinforcing the religious image of the cult. This was a front. Veteren Scientolo~ists did not usually attend these mummeries except as shills to create the illusion of parisheathers at w~rshjp, a~d lll~,I~ ~;~ly 'if a I;~r.s;e nnmber of n~,~c public persons were expected. I recall once, while I was still in Los AnReles the head of our cult branch, Yvonne Gilham Jentzsch laughingly discussing putting up stained glass windows to further dupe the *Wogs. I joined scientoloRy June 5, 1970 to improve my abilities and my life. But the longer I stayed ]n the organization the worse I got. I had been brainwashed however to believe that only scientology held the key to my survival. In March of 1971 I attempted suicide for the first time. I ha~t been in the cult nine months. Increasingly I became antisocial and anti-American. I was inculcated with contempt for my government, other religions, and all persons not scientoloRists. Only after thirteen years did the veil at last drop from my eyes and I was able, with the help of friends, to see what scientolo~,y really was. On October 1, 1983 I left the cult: but it was ~oo late. by then I was a shattered suicidal wreck. In December of 1983 I wrote a formal letter of resignation disconnecting from the 'Church' of Scientology. *Contemptuous term for non-scientologists Norwalk, California March 1, 1990 To whom it may concern: In support of Lawrence D. Wollersheim's charges aRainst the so-called 'Church' of Scientology, I herewith offer the following testimony. From April 1975 to April 1976 I was in charge of public relations for the cult of Scientology in Denver, Colorado. I appeared numerous times on television and radio to promote scientology. I hosted an hour long scientology radio program on three different radio stations: KAAT, KTLA, and KWGN. For thousands of people in Colorado, I was scientology. I was keenly aware that in the accepted sense of the word, ~e were not even remotely a religion. There was however a sham widely in practice throughout the scientology network consisting of mock 'Sunday Services' wherein a 'minister' wearing the black garb and clerical collar of a catholic priest would get up and mouth a lot of pseudo-religious sounding bromides, none of which I observed were ever practiced in the cult itself. An odd looking cross, the brain child of L. Ron Hubbard, was hauled out,dusted off and put on display, all for the purpose of reinforcing the religious imaRe of the cult. This was a front. Veteren Scientologists did not usually attend these mummeries except as shills to create the illusion of parishoners at worship, and then only if a large number of new public persons were expected. I recall once, while I was still in Los Angeles the head of our cult branch, Yvonne Gilham Jentzsch laughingly discussing putting up stained glass windows to further dupe the *Wogs. I joined scientology June 5, 1970 to improve my abilities and my life. But the longer I stayed in the organization the worse I got. I had been brainwashed however to believe that only scientology held the key to my survival. In March of 1971 I attempted suicide for the first time. I had been in the cult nine months. Increasingly I became antisocial and anti-American. I was inculcated with contempt for my Rovernment, other religions, and all persons not scientologists. Only after thirteen years did the veil at last drop from my eyes and I was able, with the help of friends, to see what scientolo~y really was. On October 1, 1983 I left tbe cult; but it was coo late. By then I was a shattered suicidal wreck. In December of 1983 I wrote a formal letter of resignation disconnecting from the 'Church' of Scientology. *Contemptuous term for non-scientologists At that time I was employed in my family's business in Long Beach, California. My father (a non-scientologist) was president, my brother (a Scientologist) was second in command. As soon as I wrote my letter of resignation, the cult began to put pressure on my brother to disassociate from me and fire me from my job. My father at first refused, but my brother eventually gave him an ultimatum and he was obliged to fire his own son, which he did in March of 1986 As a result of these events I had a nervous breakdown. I became so emotionally undone that I couldn't hold even the most menial job. After three months I became penniless and homeless. I attempted suicide on June 30, 1986, and ended up in the county mental hospital, on Johnson Street in San Luis Obispo, California. 'Church' of Scientology policy had been carried out on me. My life was now 'ruined utterly' This cult has destroyed my ability to function in the every day world. I am suicidal often and must take pills to prevent deep depressions, a problem I never had before scientology. For the past three and a half years I have lived in a garage existing on food stamps. As regards the technology itself, I continued to believe it worked for about a year after I left the cult. I thus continued to receive scientology auditing in the field. On July 18, 1984 while being audited on NOTS I almost died. Only quick thinking saved my life. While a staff member at Celebrity Centre in Los Angeles 1971-73 where Mr. Wollersheim was also employed, a high ranking scientolo~ist namad Bill Howie cam._e ~1ose to dyin~ while on OT III. Around the same time I saw another staff member, Karen Fuller sitting quietly studying with some other students. Suddenly without a word she fell over in a death-like faint. She was also on OT III at the time. In 1974 I took over public relations at the scientology mission at Vancouver, Canada. I was told by several staff members that one Douglas Dewhurst a 'parishoner' had commited suicide in his car behind the mission on 6th Street. I affirm the allegations made by Lawrence D. Wollersheim as being consistent with my own experiences in the cult known as the 'Church' of Scientology. respectfully, Reuben Hart aka Robert M. Hart UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS LA VENDA VAN ) SCHAICK, et al ) ) Plaintiffs ) ) CIVIL ACTION v. ) NO. 79-2491-G ) CHURCH OF SCIENTOLOGY OF ) CALIFORNIA, et al, ) ) Defendants ) AFFIDAVIT OF JANIE PETERSON I, Janie Peterson, being first duly sworn, depose and say: 1. I joined the Church of Scientology in March 1975 and was a member until July 1980, during which time I spent 2 1/2 years as a staff member. 2. When I was introduced to "auditing" I was told that all the information revealed in auditing sessions was strictly confidential between the auditor and the "pre clear" and that this was treated the same as a parishioner giving a confession to a minister or priest. 3. After joining staff to work in the division that delivered the auditing, I became aware of the practice of many other people having access to and going through the auditing folders. These - 1 - include but are not limited to: all technical division staff, students, ethics personnel, Guardian Office personnel; if on staff - the person's seniors, other auditors, case supervisors, "word-clearing" personnel and others. 4. While acting as "Technical Secretary" I witnessed an out-ofstate person named Morris Deutsch (I am not sure of spelling) from New Mexico's auditing folders, being sent to Las Vegas, Nevada to be gone through by the Guardian Office, as he was a "suppressive" person and an "enemy" of Scientology and the Las Vegas Guardian Office, was, at that time responsible for New Mexico also. 5. During my time in Scientology, I witnessed out-of-state "missionaires" for the Church of Scientology of California come into the Las Vegas organization and go through auditing folders of people who they were trying to recruit for the "Sea Org" and/or people they were suspicious of for any reason. This would include people who had parents, spouses, friends, etc. that did not want them in Scientology. They had complete access to all auditing files and it was firmly established that we were to cooperate with them either in person, on the telephone, telex or any other means of request for information from a person's auditing folder. This occurred on many occasions while I was in charge of the auditing and the auditing folders. 6. Guardian's Office staff and intelligence personnel from the - 2 - Guardian Office had a series of files kept on Scientologists and reports, by other Scientologists, or auditing information from auditing folders, basically anything suspicious about a person who had voiced any disagreement with Scientology or L. Ron Hubbard or executives was kept in these files. I personally saw these files and knew that auditing information was being filed in these files and this was no~ known to the people receiving auditing. 7. The Church of Scientology of California completely runs Scientology at all levels. The United States Guardian Office runs every Guardian Office in the country, including Clearwater, Florida. The executive management structure is in Clearwater, Florida. Another management structure is in Los Angeles, California (FOLO) and that this is also part of the Church of Scientology of California. These run the organization throughout the U.S. 8. The above-described actions regarding the use of auditing information, access to auditing folders, Guardian Office staff using auditing information is standard procedure and is followed throughout the U.S. at the direction of the Church of Scientology of California. 9. While working on staff in the Guardian Office, I witnessed staff going through the auditing folders of staff members and public people. This was a regular practice. I was aware that - 3 - certain information people would reveal in auditing would be sent to the Church of Scientology of California, the United States Guardian Office and Clearwater, Florida, if requested or needed. 10. While working in the Guardian Office, I personally saw a man I believed to be sent to Las Vegas by L. Ron Hubbard actually xerox copying Mr. Ernie Hartwell's auditing reports from his auditing folder. 11. I also saw auditing information from the auditing folder of Tonja Burden that was sent to Carol Garrity, a Guardian Office staff member, from the United States Guardian Office in California and Florida and Carol had an order from her senior in the "USGO" to get said auditing information published in the news media. Miss Burden was at that time engaged in litigation against Scientology and L. Ron Hubbard and she was considered a top enemy of Scientology. 12. This practice of using auditing information for other purposes than were stated at the time the person received his/her auditing was standard and done routinely during all my years in Scientology. 13. I am aware of Lavenda Van Schaick's auditing folders being gathered in Las Vegas and gone through by Guardian Office staff members at the time Mrs. Van Schaick retained the services of - 4 - Attorney Michael Flynn in Boston. This was done to gain information about Mrs Van Schaick. 14. Outer "missions" under the control of "Class 4" organizations routinely sent auditing information from persons' auditing folders who were under "ethics" actions or were in some kind of trouble regarding Scientology in the areas where the missions were. If needed, this auditing information would be sent to the Church of Scientology of California and the United States Guardian Office, which is part of the Church of Scientology of California. 15. A Guardian Program entitled "Shake and Bake" was written by the tip management of the United States and England Guardian Office to "handle" Lavenda Van Schaick so that she would not continue with litigation against Scientology and L. Ron Hubbard. I saw this program and part of it was an "information-gathering" section on Mrs Van Schaick, including going through her auditing information. 16. Due to all of the above actions, ~hen I thought about leaving Scientology and pursuing my legal remedies, I was in fear that these actions would be done to me and that my personal life and the information I gave during my auditing would be used to blackmail me and be taken to the news media for publication. - 5 - 17. During auditing a person reveals his most personal thoughts, feelings, actions and those of his families, friends and anyone influencing his life. 18. I am also aware of a Guardian's Office operation to get Michael Flynn disbarred and thereby eliminate him as a representative of individuals who have been victimized by the Church of Scientology. I observed "operations" being planned and executed to infiltrate Mr. Flynn's law office with a "plant" named William Broderick. This operation was called "Operation Oscar". The purpose of that operation and others that were being planned was to get someone inside Mr. Flynn's office for the purpose of gathering information. Signed under the pains and penalties of perjury this 25th day of May, 1982. Janie Peterson SUBSCRIBED and SWORN to before me this 25th day of May, 1982. (PHYLLIS NORQUAY) NOTARY PUBLIC Glossary: FOLO - Flag Organization Liaison Office USGO - United States Guardian's Office - 6 - UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS LA VENDA VAN SCHAICK, ) ) Plaintiff ) ) ) CIVIL ACTION vs. ) NO. 79-2491-G ) ) ) CHURCH OF SCIENTOLOGY OF ) CALIFORNIA,~ et al, ) ) Defendants ) AFFIDAVIT OF GERRY ARMSTONG I, Gerry Armstrong, hereby swear under the pains and penalties of perjury as follows: 1) I have personal knowledge of the following facts: 2) I was a member of the Sea Organization of Scientology from February 1971 to December 1981, during which time I held many positions and was in many locations where I directly observed L. Ron Hubbard and other Scientology executives. At no time did I ever get the impression that Mr. Hubbard or any other senior executive considered that Scientology is a religion. My own understanding, held throughout all the time I spent in Scientology, and the policy expressed to me by other Sea Org members was that Scientology operated totally as a business, and its efforts to be recognized as a "religion" were only to evade taxation and government regulations. 3) In January 1980, I was assigned to a project to collect materials about L. Ron Rubbard for the purpose of providing documentation for a biography to be written by Omar V. Garrison. During the following two years I read several thousand pages of documentation, much of it written by Mr. Hubbard himself. Never before had anyone within Scientlogy ever had all this information assembled in one place or had the opportunity to view and assimilate the whole truth about L. Ron Hubbard. From these documents and other sources I learned that Mr. Hubbard had continually misrepesented himself and had lied about his past, his accomplishments and credentials. I learned also from the documents I collected that Mr. Hubbard had lied about how and why Scientology had been established as a "religion". In a despatch he wrote in early 1980 to the people in charge of the projects he had ordered to remedy his legal problems with the IRS and various damage claim cases, he stated that the creation of Scientology as a "religion" was not his idea but had come about when the membership of Scientology in the early 1950's, unbeknownst to him, had voted to form a "church". I personally saw and read that despatch. Mr. Hubbard's statement is a lie. In a letter to the head of Scientology in the US in early 1953, Mr. Hubbard stated: "We don't want a clinic. We want one in operation but not in name. Perhaps we could call it a Spiritual Guidance Center. Think up its name, will you. And we could put in nice desks and our boys in neat blue with diplomas on the walls and 1. knock psychotherapy into history and 2. make enough money to shine up my operating scope and 3. keep the HAS solvent. It is a problem in practical business. "I await your reaction on the religion angle. In my opinion, we couldn't get worse public opinion than we have had or have less customers with what we've got to sell. A religious charter would be necessary in Pennsylvania or NJ to make it stick. But I sure could make it stick. We're treating the present time beingness, psychotherapy treats the past and the brain. And brother, that's religion, not mental science." I found a great deal of similar evidence in the materials I assembled before I left Scientology. Mr. Hubbard's life has been a continuing pattern, since the early 1940's, of fraudulent business practices, tax evasion, flight from creditors and those seeking recompense, and then going into hiding, outside the reach of wronged individuals and legal jurisdictions. In short, it is the life of a con man. 4) In early 1980 I was also assigned to a mission, the purpose of which was to work out legal strategies, and get them implemented, which would allow Mr. Rubbard to still control all of Scientology via his Commodore's Messenger Organization while being shielded from any lawsuits or legal invlvements and responsibilities. One of the main problems which had to be resolved by this mission, and one of the arguments .used in various court cases as proof that Scientology was not a religion, was the fact that Scientlogy was set up so that funds inured to the benefit of L. Ron Hubbard. For years Mr. Hubbard had had his legal representatives claim that he was not paid by Scientology, other than a $35,000.00 annual consultant's fee, and royalties from sales of his books. Another claim was that he did not control Scientology monies. The fact is he had absolute control of all Scientology accounts. As late as 1980 I saw a despatch from him in which he ordered that unlimited Scientology funds were approved for a project to get him a Nobel Prize. Another fact is tht he received millions of Scientology dollars directly from a foreign corporation called Religious Research Foundation. Payments for auditing or courses at Flag by non-US Scientologists went into RRF accounts which Mr. Hubbard controlled absolutely and used totally for his own purposes. 5) I learned through my study of the documentation I assembled, and from more than ten years of observation of Mr. Hubbard and the Scientology movement, that Mr. Hubbard has cruelly deceived his followers to the point where they will themselves lie and attempt to deceive others about the truth cncerning him and Scientology. Scientology spokesmen and witnesses have stated that Mr. Hubbard doesn't control the organizations. The fact is he has absolute control, including financial control, and Scientologists know it. Between 1978 and 1980 I participated, along with at least 250 other Scientologists, in several massive operations to destroy or hide the evidences of Mr. Hubbard's control. Scientology spokesmen and witnesses have claimed that throughout 1980 and 1981 Mr. Hubbard could not be reached through the organization, or that organization executives did not know where he was. The fact is, the most senior executives were in continual communication with him throughout this period. Scientology spokesmen and witnesses have gone to great lengths to "prove" that Scientology is a valid religion, while knowing that it was simply a behavior therapy masquerading as a "church", and making a mockery of actual honest religious practices. In 1980, Wa.tchdog Committee, the senior CMO body, responsible only to Mr. Hubbard and senior to every Scientology organization, ordered that every Sea Org member had to complete the Minister's Course in two weeks or they would be assigned to the RPF. The reason given was to make every Sea Org member a "minister of the church of Scientology" and so avoid the US Selective Service draft then pending. What most Scientologists, and especially Sea Org members, don't know is that Mr. ~ubbard had duped 'them. My knowledge based on documentation and observation, is that the major reason for Mr ~ubbard's calling Scientology a "religion" in ú , addition to tax evasion, is to hide behind Constitutional guarantees for religions and so carry out his scheme of mind control to keep his followers duped. He has systematically and knowingly lied to and defrauded his followers, kept them from finding out the truth or becoming free with cruel and bizarre treatment, as for example with the RPF, and kept them economically and mentally suppressed,.while he made millions of dollars from their labor. 6) I am personally aware that Mr. Hubbard's policy of Fair Game is still a practice of Scientology. Since I left the organization with my wife in December 1981, I have been declared an enemy, and I believe my life and my wife's life, are in danger. Signed under the pains and penalties of perjury this 22'nd day of July, 1982. Y ARMSTRONG _ UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS LA VENDA VAN ) SCHAICK, et al ) ) ) CIVIL ACTION v. ) NO. 79-2491-G ) CHURCH OF SCIENTOLOGY OF ) CALIFORNIA, et al, ) ) Defendants ) AFFIDAVIT OF RONALD DeWOLF a/k/a L.RON HUBBARD, JR. I, Ronald DeWolf, formerly L. Ron Hubbard, Jr., ]~'efeby de~6s~ and state as follows unaer :he pa-n~ ~nu penalties of perjury: 1) I have personal knowledge of the facts set forth in this affidavit. 2) I am the oldest son of L. Ro~ H'dbbard, having been born on May 7, 1934 in Encinatas, California. 3) Between 1949 and 1959 my father and I worked together on a regular basis in organizing, developing and promoting many organizations and corporations. which collectively became known as the Church of Scientology. 4) My father promoted the Church of Scientology with the sale of his books and publications based on his Various theories relating to the "science of mind" as the most "exact science" ever developed. He represented in writing in most of the Church publications that he possessed degrees from George Washington University, Princeton University, that he was a nuclear physicist, that he served four years in combat, was seriously wounded and healed his war wounds with his theories on the "science of the mind", which is the foundation of Scientology. Throughout the development years of Scientology and to the present date, the Church of Scientology has made the foregoing representations and most individuals who have joined the organization that I personally know, relied specifically on my father's represented qualifications and credentials. The stated representations are all false. He never obtained degrees from those universities, or ever served in combat. He was relieved of duty three times as being unfit, and ended up in a psychiatric hospital at the end of the war. He is a fraud and has always been a fraud. 5) My father's fraudulent conduct is exemplified -2- in the structure of his corporations including the Church of Scientology of California. In connection with each and every corporation which we created under general heading of 'the ChurcH0f scientology, my' f~ther always required all of' the Directors and Officers of all corporations to give him undated signed resignations in advance which he held. In that manner, he always has retained complete control over every corporation including its bank accounts. In the early years, my father regularly emptied out these corporation bank accounts whenever the A.M.A., or a local district attorney, etc. posed a threat to one of his organizations. A copy of express instructions on this point in my father's handwriting is enclosed. 6) My father represented orally and in writ/a~g that his theories relating to the "science of the mind" were based on 30 years of case studies conducted on a scientific basis by him as a nuclear physicist and scientist. Most people that I knew who paid money to my father's corporation to learn about this science also relied on the above stated representations in addition to my father's credentials. Similarly, the above stated representations are false. My father wrote his books off the top of his head based on his -3- imagination. There were no case studies. He is not a nuclear physicist and flunked nearly all of his science related courses in high school and college. 7) My father obtained the rights to the E-meter in 1952 from Volney Mathison in the same manner that he does everything - through fraud and coercion. My father learned about the E-meter from Mathison who developed it and my father fraudulently extracted those rights from Mathison so that my father could use it in Scientology auditing. 8) My father has always used the confidential information extracted from people during auditing sessions to intimidate, threaten and coerce them to do what he wanted, which often meant getting them to give him money. My father routinely used false threats and auditing information particularly about crimes people had committed to extort money from them. 9) My father has always held out Scientology and auditing to be based purely on science and not-on religious "belief or faith. We regularly promised and distributed publications with "scientific guarantees". This was and has always been common practice. My father and I created a "re- ligious front" only for tax purposes and legal protection 'from frahd Claims'. we almost always to-ldnearly everyone that Scientology was really science, not a religion, but that the~religious- ~ont was or~a~ed-t~D.--deal--wi~h t4~e government. 10) My father's basic policies relating to "suppressive persons", "Fair Game", "attack the attacker", etc. have .always been and will always be an'integral part of Scientology. The organizational structure of Scientology and the theories of Scientology cannot operate and Scientology would not be scientology without such policies. The entire basis of my father's "science" is the suppressive person, '(~':~i')'doct~inG. ..... sci~toiog~"'i~"~not'sclentology'~i'th'out' this theory, just as nazism would not be nazism without the theories of Aryan supremacy and anti-semitism. My father and I discussed the basic theories of dealing with suppressive persons, such as what eventually became designated as the "Fair Game Doctrine", on many occasions. These policies have never changed. Signed under the pains and penalties of perjury // - RONALD DeWOLF ** AFFIDAVIT ** PAUL SIMMEL 167 Pekara Drive Deerfield, Illinois 60015 August 16, 1989 Very roughly, to date i've spent over fifteen years in Scientology: I am officially still a member. By 1981/82 I had reached one of the "highest" levels in Scientology processing known at that time: Full OT 7 (old OT levels). For those not familiar with "OT levels", they are secret bodies of knowledge which are supposed to answer the mysteries of life, combined with processing techniques, which, when completed, produce super beings. These "OT levels" can only be given after one has first completed many, sometimes hundreds of hours of earlier, "preparatory" processing. The whole idea in Scientology is to scrape, steal, beg and borrow one's way up the road to "OT" which promises eternal, superior spiritual pow'ers far advanced than anything known to man. The cost, in terms of money for those levels and those needed previously, for me, was roughly 20,000 or more dollars. In exchange for my money and time, instead of spiritual states of awareness beyond my wildest dreams, abilities far and above those of mere human beings, power to will and create that which I wanted or needed in life far easier than ever before, I got brainwashed. It had started from the very beginning, as far as I am concerned. I had in many ways lost my own will. I was literally a captured individual whose autonomy had been supplanted with subservience, afraid to communicate any real feelings, felt constantly that my setbacks in life were because of my having committed crimes in this and past lives, that the fault for not getting what was originally promised lay in me, not the Church or its system which purported "mental health." At 20 or 21 years of age, in hopes of alleviating the very real pain I was experiencing from splitting with a girl friend, I tried Scientology's first course: the Communications Course. It was very difficult, for I had been in chronic grief, day and night for months. After the course, my grief was not substantially lessened. I was told I needed processing at the cost (then) of $500 per twelve and a half hour block, and because I had no money for this I wanted to leave. I was told that if I left, my home and surroundings would destroy me. I was told that unless I had this processing and continued with Scientology I would soon deteriorate. Apparently these words had their effect, for a year or so later, I again found myself involved with Scientology. This time I was told Scientology t~aining represented a career for me. This was very appealing because I had been for the most part uneducated, and this proposition was seen as an opportunity to better myself. I was also told the courses were in some states acknowledged as college credit soon to be accepted nationwide. This was where L. Ron Hubbard's many impressive "credentials" were introduced: the many years he spent traveling in Asia; his war record; a nuclear physicist, etc. As an "auditor", I was told I could earn up to $50 an hour provided I had the proper Scientology training. Thousands of dollars and a year or two later, the career never materialized, though I had attempted to counsel in the field (outside Scientology organizations) with some, but little success. States were not recognizing Scientology training as legitimate in the education fields. Most press was negative, calling their practices cult-like. It soon became apparent that one really needed the organizational ties to make any progress, and that meant working for them. I tried this for six or so months, earned perhaps $10 per week for roughly seventy hours of work, and when I left the organization as a staff member I was required to pay for the training courses they required of me. There were many grueling hours during the period I had been a staff member, (two times in all) as well as a "paying public". Six days and evenings a week, sometimes thirty hours at a stretch, drills, reading, word-clearing (a form of control),