GRAHAM E. BERRY, State Bar No. 128503
GORDON J. CALHOUN, State Bar No. 84509
LEWIS, D'AMATO, BRISBOIS & BISGAARD
N. Figueroa Street, Suite 1200
Los Angeles, California 90012
Telephone: (213) 250-1800
 
Attorneys for Defendants
UWE GEERTZ, PH.  D.
 
                      UNITED STATES DISTRICT COURT
                     CENTRAL DISTRICT OF CALIFORNIA
 
CHURCH OF SCIENTOLOGY                  Case No. Cv 91 6426 HLH (Tx)
INTERNATIONAL, a California
non-profit religious                   DECLARATION OF MARY TABAYOYON
organization,                          RE: MOTION FOR COSTS
Plaintiff,                             Date:  APRIL 4, 1994
                                       Time:  10:00 a.m.
VS.                                    Courtroom: 7
 
STEVEN-FISHMAN AND UWE GEERTZ,
Defendants.
 
 
     DECLARATION OF MARY TABAYOYON
 
     I, Mary Tabayoyon, declare as follows:
 
     1. I became a Scientologist in 1967.  I became a member of the
elite Sea Organization (Sea Org) in 1971.  I remained in the Sea Org
until I left Scientology in December 1992.
 
     2. One of my first positions in the Sea Org was receptionist under
Heber Jentzsch, at the Celebrity Center in Los Angeles, run by Yvonne
Gilliam Jentzsch.
 
     3. In 1972, I was transferred to the Flagship Apollo.  While on the
ship, I was on the personal staff of Mary Sue and L. Ron Hubbard in the
household Unit ("HU").
 
     4. In March of 1973 my husband Andre, and I were transferred to the
Advanced Organization Los Angeles (AOLA).  We were transferred because I
was pregnant and children were not allowed on the ship.  I spent
approximately 10 years at AOLA.
 
     5. In July of 73, our son Casavius was born.  He has been in
Scientology and he was ever since birth.  He now has disconnected from
us due to the fact that we left the Sea Org and are no longer in
agreement with several of the tenets of the Sea Org.
 
     6. In late 1984, I was transferred to the highly confidential
location in Hemet, California, commonly referred to as "UPLINES."  Sea
Org members who work at this location call it, "the Base".  The Sea Org
units that were at the base were Golden Era Productions ("Gold".  Golden
Era Productions produces all of the Scientology films tapes, E-meters,
music and promotions), Commodores Messengers Organization International
(CMOI), Watch Dog Committee (WDC), Religious Technology Center (RTC),
and Commodores Messenger Org Golden Era Productions (CMO GOLD).  I spent
the last eight years of my tenure in the Sea Org at this base in Hemet.
 
 
     BEGINNING IN 1986, MEMBERS OF THE SEA ORG WERE FORBIDDEN TO HAVE
ANY MORE CHILDREN IF THEY WERE TO STAY ON POST AND THE HUBBARD
TECHNOLOGY WAS APPLIED TO COERCIVELY PERSUADE US TO HAVE ABORTIONS SO
THAT WE COULD REMAIN ON POST.
 
     7. On September 28, 1986, Gillaume Leserve, the Executive Director
International ("ED Int"), put out an order binding on all Sea Org
members.  Within the Sea Org, these binding orders were called Flag
orders.  The September 28, 1986 Flag Order No. 3905 forbade Sea Org
members from having any more new children.  The reason given by ED Int.
was that the Sea Org simply did not have the time, money and resources
to raise children properly.  In the event Sea Org members elected to
disobey this Flag Order, they would be exiled to a non Sea Org
Scientology organization of the Class IV level until the Child reached 6
years of age.  Once the unauthorized child achieved 6 years of age, the
parents could return to the Sea Org.
 
     8. On April 3, 1991, an addition to this Flag Order was issued.
Part of that supplement provided that anyone who did get pregnant would
be sent to a non-expanding Class IV Org.  The Commanding Officer of
CMOI, Marc Yager, endorsed application of this supplement to all crew at
the base and added to it.  It stressed that Sea Org members were the top
echelon of the Sea Org.  As such Yager admonished us that we had the
responsibility on our shoulders for the expansion of Scientology and
freeing mankind.  Scientology's Senior management determined, we, at
this high level, could not afford the time and resources it would take
to raise children.  Having children was found to undermine our
production and our purpose.  It became an Ethics matter.  An Ethics
matter is an offense against Scientology.  An ethics matter arises when
a Scientologist does something which detracts from the spreading of
Scientology.  Ethics matters are dealt with through Scientology rituals
administered to those who have "wandered off the straight and narrow".
(See definition of "out ethics", attached as Exhibit 1).
 
     9. Furthermore, Sea Org members would be exiled, would be sent to a
non-Sea Org, lower organization called a Class IV Org to serve as a
staff member.  The only concession to our years of devoted service was
the fact that we were entitled to keep our membership in the Sea Org.
 
     10.  The Flag Order established that Sea Org members who disobeyed
it and chose to have children would not be allowed to choose which Class
IV organization they would serve.  Rather, Scientology's senior
management would send the offending Sea Org members to a Class IV
organization that was failing.  This is a severe punishment.  In a
failing Class IV Org an exiled Sea Org member would have to fend for
himself or herself and try and raise a child on the nominal compensation
provided to the staff of a failing Class IV Org.  In addition, the
exiled Sea Org members would be obligated to revive the failing Org or
suffer more Ethics conditions.
 
     11.  While at the base, I knew of several instances of staff
getting pregnant and being coerced to get an abortion.  Some instances
were relayed to me by the victims themselves and others were relayed to
me by another.  In two instances, the couples to keep their child
despite extensive course of ethics method and thus were banished to a
failing Class IV organization.  In every instance they had to go through
ethics handling designed to prevent them that it would be far more
advantageous to Scientology and the Sea Org for each of them to have an
abortion.  Some of these women went through extensive pressure methods
to convince them to have an abortion.  The severity of the Ethics
handling was directly proportional to the prospective mother's desire
and insistence to keep the child.  I myself got pregnant in 1993 and
gave up my child due to my greatly misguided obligation and dedication
to the Sea Org.
 
     12.  During the year and a half before I discovered I was pregnant,
I was incessantly drilled, along with all other Gold crew, on becoming
perfect and on purpose Sea Org member who would always follow Command
Intention.  Command intention basically means the intention of the
highest in command over all of Scientology and Sea Org.  Like LRH, Mark
Yager and David Miscavige were expressed in various forms of publication
I was indoctrinated that I should never put my own personal desires
ahead of the accomplishment of the purpose of the Sea Org.  I was
indoctrinated to believe that I should never put my own personal desires
ahead of the accomplishment of the purpose of the Sea Org.  Although I
would have dearly loved to have had my child and the idea of abortion is
abhorrent to me, I did not dare to say it would be nice to keep my baby.
 
     13.  I told the Medical Officer (Martine Collins) of my pregnancy.
She immediately went into action to arrange for my abortion.  She told
me, that I would naturally be expected to pay for it myself, since it
was considered Out Ethics to get pregnant.  (Out Ethics in Scientology
simply means your reasoning facilities are no longer thinking in a
direction designed to promote Scientology and must be corrected).
 
     14.  Medical Office Collins told me to call for the appointment to
have an abortion myself.  She told me not to give the address of the
base as my address or to acknowledge I was from the base.  She said the
reason for this was because there were too many woman going there from
the base for abortions and it was probably becoming "out PR" (out Public
Relations, which means your public relations have gone bad).
 
     15.  The day after I returned from my abortion, I was weak and sore
and had cramps.  I proposed a light work load that I felt I could
accomplish.  My Senior, Megan Rae, refused this and instead gave me a
target that literally would have taken about many people to accomplish
in one day.  I attempted to let her know what an impossible task it was
and that her order must have been a joke.  I soon learned that she was
completely serious.  My obvious protest on this was met with the barked
threat, "If you use this abortion cycle to dramatize inefficiency and
thus not accomplish your production targets, I will have you comm-eved."
A commev is short for Committee of Evidence.  It is one of the severest
Ethics actions you can level at someone.
 
     16.  A friend of mine, Betty Hardin, who works in the treasury
division of Golden Era Productions, told me that she used to transport
the pregnant women at the base to Riverside, California for their
abortions.  For about a year, she transported women almost weekly to the
Planned Parenthood Center, in Riverside, so that they could have their
abortions and follow up check ups that were needed.  She said it just
became routine.  Pregnant Sea Org members were sent to the Planned
Parenthood Center to get their abortions.  When they returned to the
base they went to Ethics.
 
     17.  The term "Ethics" is used to name the place you go to have
your ethics be back put in.  To explain this in regular terms, you are
sent to ethics any time you've gone off the rails, like went against
Command Intention, mistakenly or purposefully, and the ethics officer
would then work with you until you were again unswervingly dedicated to
advancing Scientology and had made up the "damage".  I will explain more
about Ethics and its methods later.
 
     18.  Betty Hardin said, once formerly pregnant women were back from
having their abortions, they would be sent to Ethics and made to do
"lower conditions".  Lower conditions are, from the lowest on up;
Confusion, Treason, Enemy, Doubt, and Liability.  Each one of these
lower conditions have an exact set of steps you follow. once you get
through all the steps of all the lower conditions, successfully, and
only the Ethics officer can officially determine if you have gotten
through it correctly, and thus let you go on to the next higher
condition, you are a gung-ho Sea Org member again with new and
revitalized determinism to never make a mistake again that would cause
or threaten any harm to your group.
 
     19.  My senior made me do the steps of the condition formula called
"Danger", which is the next higher condition higher than liability.
This was to handle my ethics on the fact I got pregnant.  The reason I
didn't have to do treason and all the lower conditions is I professed
that the Scientology auditing I had prior to my pregnancy had healed my
body to such a degree that I was able to get pregnant despite the fact
that a doctor told me years earlier that I probably would never have any
more children.  This wasn't altogether true but it was my only solution
to avoid going to Ethics and being put through those lower conditions
again.  I knew eventually in my future confessional, it would come up
and I would have to come clean on it and then do the lower conditions,
but I simply was not up to it at that time.  This was really quite
unusual for me too, as I had made it a constant necessity in my life to
always be very truthful.
 
     20.  Also, to preserve my own integrity and dignity in my own mind,
I professed to myself and to a couple of friends that my husband and I
had a real fear of either me or my baby not living through a birth due
to complications in an earlier unsuccessful delivery I went through.
But the truth was and is, had I been in my normal frame of mine, I would
never have considered abortion.  My husband and I still wish to have
another child.
 
     21.  I asked Betty how many women she had actually taken to
Riverside to have their abortions.  She didn't want to tell me.  From
the way she had been talking, it sounded like quite a few, so I asked,
conservatively, "Was it more than 20?"  She waived her arm and said very
emphatically, "Oh yes!"
 
     22.  Betty also told me how she finally flat out refused to be the
driver anymore and it was getting to be quite an embarrassment as there
were often anti-abortionists petitioning going on in front of the
Planned Parenthood center and they kept seeing her bringing woman to get
abortions.
 
     23.  The following are the brief stories of women I knew who had
abortions after undergoing coercive ethics sessions and being threatened
with exile to a Class IV organization.  Because this topic wasn't
something that we were supposed to talk about, for the sake of Public
Relations, within and outside the Base to protect the women involved
from retribution and to preserve their privacy, I have not given their
names.
 
     A. Case I:  She was my friend and also worked in my department at
the time of her pregnancy and abortion.  She appeared very upset about
it and really wouldn't talk about it at first.  I got her to talk about
it one day when we were alone.  She said she would have loved to have
kept her baby but after she got through her ethics cycle (which I
remember lasted for at least a week) she realized she wasn't ready to
have a child.  (She was 20 years old).  She said her husband was
completely thrilled she was pregnant and wanted so much to keep the
baby.  He was very adamant on keeping the baby.  But after the ethics
cycle he looked at the fact that he would probably never be able to come
back to the base and he would lose his beloved job and position in Gold.
He would have to go to a Class IV Org.  At any rate, the ethics actions
convinced them to be "good Sea Org members" and abort the child so they
could stay "On Purpose" in the Sea Org.  "On Purpose" in the Sea Org
just means you are being and doing what is needed and wanted in
furthering the purpose of the Sea Org. 1 (Note:  I will later explain
the coercive methods of the ethics techniques in Scientology).
 
     B. Case II:  Her husband worked in the same area I did at the time
of her first pregnancy.  He confided in me as a friend, that his wife
was pregnant and had decided to keep the baby again!  She had been
talked out of it once already by ethics but now decided again to keep
it..  I talked to her later and asked her if she was pregnant.  She said
yes and that she was going to keep it.  She said it very adamantly.  I
said good.  We discussed the reference in Hubbard's book, Dianetics. the
Modern Science of Mental Health, where Hubbard it very clear that he is
against abortions.  (See Exhibit 2) She was clearly glad to have someone
on her side.  Sometime later, I heard she went ahead and had the
abortion.  She also landed on the Rehabilitation Project Force ("RPF").
The RPF is basically a prison camp in the Sea Org.  Some months later, I
was told she got pregnant again.  The fact she became pregnant against
while on RPF is remarkable because RPFers' living quarters are
segregated from those of other Sea Org members on the base (including
spouses) and by her husband was under guard because he was believed to
be security risk during her incarceration.  This time rather than submit
to an abortion she successfully escaped from the base and never returned
to the Sea Org.  We later found out that she went to England and had her
baby there.  I read the letter Tina sent her sister.  She had sent
pictures of her beautiful baby girl.  She was a very proud mother and
very much in love with her baby.
 
     C. Case III:  I was told that sometime in 1986, Case III got
pregnant.  It was a huge flap because she had always, up to that time,
been a top Commodores messenger (meaning L. Ron Hubbard's messenger).
She and her husband were very determined to keep the baby.  She was put
through very extensive ethics, with heavier and heavier threats and
penalties until She finally submitted and had her abortion.  Around
1990, I saw that he had gotten pregnant again.  Coincident with her
pregnancy I saw her off post and only doing manual labor.  Her husband
told me that they were determined to keep their baby.  Months later they
both successfully escaped.  They have not returned to the Sea Org, and I
understand that she and her husband have been blessed with an adorable
son.
 
     D. Case IV:  I was told she was pregnant.  She went through Ethics
Procedure and had an abortion.
 
     E. Case V:  She appeared to be going through hell.  She often
looked as though she'd been crying.  She often looked to be in a state
of emotional collapse.  I tried to be extra friendly and tried to get
her to talk, but she just put on a smile and changed the subject.  She
and her husband were taken off post and put through extensive ethics
handlings because they were determined to have the baby.  Then one day I
saw them both looking happy and back on post.  I asked the husband about
what had happened with their baby.  He said they had both gone through
the lower ethics condition formulas and came out of "Doubt", and she had
gone ahead and gotten an abortion.  Months later I saw her looking like
she was in shock and mentally destroyed after being thrown in the lake
with about 6 other Qual staff for not making a target of what they were
assigned to accomplish that day.  She later blew with another man who
was also on staff in the same division.
 
     F. Case VI:  I was told Case VI got pregnant and had her abortion
while married to one of Scientology's senior managers.  I saw her break
up with and divorce her husband.  Later, she married another Sea Org
member at the base.  After that she was sent to the RPF.
 
     G. Case VII:  I was told Case VII got pregnant and was made to get
an abortion by the use of ethics procedures.  She mentally collapsed.
Having the abortion destroyed her emotionally.  She has never been the
same since the abortion.  She used to be happy and fun to fool around
with but after her abortion, it was hard to ever get her to cheer up and
joke around anymore.  This was related to me by Case VII's best friend.
 
     H. Case VIII:  This couple managed to maintain their own sense of
integrity and not give up their child.  They were undergoing Ethics
handlings for about a month before they were finally allowed to go to a
Class IV Organization, and thus keep their baby.  Ethics was trying to
coerce then into having an abortion.  They were considered in Treason
when they left, and they were talked about spitefully at staff meeting,
basically being labeled, deserters.  It was as if they left the Sea Org
which is considered about the worst crime you can commit amongst, Sea
Org members.
 
     I. Case IX:  This couple opted to leave, due to her pregnancy.
They were sent to the Santa Barbara Class IV Organization in total
disgrace for choosing to leave the Sea Org group and go off and have a
baby.  They were also spoken very critically of at a staff meeting.
 
     I spoke to the husband before they left, in order to get his
viewpoint on leaving.  He said it was partly for personal reasons, in
that he felt that this way he would have a chance to possibly make it go
right to get through his OT III (one of the most advanced levels in
Scientology) review, and finally get through OT III.  He said he'd been
stuck in it for 3 years and hadn't been able to get the auditing due to
lack of staff auditors.  He said, it was literally driving him nuts and
felt his only hope was to make it go right on his own to get this.
 
     About four years later, I saw them at the Advance Organization of
Los Angeles ("AOLA").  AOLA is where Scientologists attend advanced
levels in Scientology).  They were both extremely thin.  Their daughter,
who was now about 4 years old was also extremely thin.  The mother had
some sort of skin disease that covered half her face.  The marriage was
destroyed and they were getting a divorce.  She tried to keep up a good
front.  But she did tell me that the Santa Barbara Org was very broke.
This meant they were also very broke and barely making it.  Class IV org
staff members are paid out of the receipts from sales of Scientology
literature and courses as the org.  Seeing them in this way really
convinced me that anyone would be a fool to go to a Class IV Org to have
their baby.  It seemed to have caused them untold hardships.  This
lasting impression I formed was one of the things that affected my
thinking about a year later, when I discovered my own pregnancy.  It's
interesting that the only other alternative in keeping your baby, other
than go to a failing Class IV Organization was to actually route out of
the Sea Org entirely.  It's hard to describe how completely unthinkable
this would be to someone as completely indoctrinated and dedicated to
the Sea org as my husband and I were.  A way to describe it is with the
analogy of the feeling you would get if someone put a gun in your hand
and told you to go shoot your family.  You would feel that there is just
no way in the world, for whatever reason whatsoever, that you would ever
do that.
 
     J. Case X:  She apparently didn't put up much of a resistance to
getting an abortion because her pregnancy was making her constantly very
ill.
 
     24.  I can see now that the act of getting my abortion along with
the harsh treatment from my seniors afterwards, began jolting me out of
the indoctrinated state of blind dedication to the Sea Org.  Another
thing that jolted me was, just before going back to the Riverside
Planned Parenthood, for a check up, 2 weeks after my abortion, I was
getting administered to me something called, False Data Stripping.  This
action was opening my eyes to some real craziness that were going on at
the Base, to which I had previously cast a blind eye.  The biggest
craziness being the fact that, Miscavige, the highest leader in
Scientology, was regularly (about once a month or so) angrily yelling at
us in staff meetings about how inept and incompetent and inefficient we
all were.  Sometimes he would even say, "WOG's could do better."  (WOG
is a derogatory term used in the Sea org to mean someone in the outside
world who probably hasn't even heard of Scientology.)
 
     25.  These same Miscavige had the crew of Gold at their various
posts and functions performing their duties.  The video portrayed Gold
Crew as demigods, in their levels of proficiency, perfection and skills.
 
     26.  Another oddity was I would sometimes note how poorly many of
the lower Sea Org Organizations were doing and some of the lower Class
IV Organizations.  Despite this, Miscavige would portray the
International Scientology Scene as doing fantastically well and booming,
at all the major Scientology events where he and all his immediate
juniors called IG's (Inspector Generals) would talk.  Each portraying
their area of responsibility as doing fabulously well!
 
     27.  I was never able to complete the false data stripping, because
I had to leave in the middle of it to go to my doctor appointment for a
check up (which was 2 weeks after my abortion).  This was lucky as I had
been able to complete all the "false data stripping" steps, I would have
made complete sense out of everything again and been well on my way of
getting back to my thoroughly indoctrinated, very dedicated Sea Org self
again.
 
     28.  My husband picked me up after my check-up.  It was then that
he told me of his big argument be had just had with Miscavige and how
Miscavige had greatly insulted him.  After he told me the whole scene
that occurred, he told me, if he had it his way he would just get in our
pick-up and leave the Sea Org right now.  I daily basis and that "this
is a better utilization of productive time.
 
     32.  Attached hereto as Exhibit C is a copy of a communication from
Fred Swan to Scientology Administration dated November 9, 1989 and
complaining about the Executive Directive on family time.  Specifically,
the communication complains of being deprived of the one-hour per day
that parents had been previously permitted to spend with their children.
 
     33.  Attached hereto as Exhibit D is a copy of a Scientology
Executive Directive dated November 21, 1989 regarding pregnant couples
in the Pacific Area Command of the Sea Org.  Such couples were to be
reposted to "a small and failing Org."
 
     34.  Attached hereto as Exhibit E is a November 27, 1989
Scientology personnel order regarding Jill Graham.  She was in violation
of Scientology policy by having a child and remaining on the advance
organization of Los Angeles staff instead of being transferred to a more
menial post.
 
     35.  Attached hereto as Exhibit F is a letter dated December 5,
1989 from Ken Shapiro to Scientology administration regarding the order
that parents stop spending time with their children.  He complains that
it is not enough that a parent can only see his/her child once every two
weeks.
 
     36.  Attached hereto as Exhibit G is a communication dated December
8, 1989 from Scientologist Mya and Leif Bergman regarding the
cancellation of Scientology time.  It complains about the Scientology
canceling the one hour per day that Sea Organization members are
permitted to spend with their children.
 
     37.  Attached hereto as Exhibit H is a Scientology communication
dated December 30, 1989 regarding Karen (Jentzsch) Barter.  In pertinent
part, at the bottom of the second page there is a statement "Dear Sue:
Do you know anything in regards to getting Karen Barter handled on
wanting to have another child?"
 
     38.  Attached hereto as Exhibit I is a Scientology communication
dated January 29, 1990 disciplining Yolanda Avila for objecting to the
cancellation of family time and calling for a board of investigation
that had the result of creating enturbulation or upset in the Pacific
Area Command of Scientology.  Furthermore, that "there has been cross
criminality found on the reg lines in all PAC Orgs."  (Para. 2).
 
     ETHICS, SECURITY CHECKING AND RPF
 
     39.  Actually, Ethics is the method of keeping everyone's mind
controlled into thinking and seeing one way only to the point of
ignoring major faults in the Scientology leaders, the organizations and
the Hubbard technology itself.
 
     40.  Once LRH has led you to a certain frame of mind of wanting a
higher IQ, higher ability levels, higher awareness levels and spiritual
freedom, he then lassos and corrals you in with such bulletins as the
one called, "Keeping Scientology Working."  (See Exhibit 3).  In this
Policy Letter LRH, very poetically, stresses that Scientology is
humankind's only hope to shed the spiritual chains he's had "for the
last trillenia."  And it's the first chance humankind has had to do so
in all that time and in fact, it could very well be humankind's last
chance.  LRH goes on to implore Scientologists to bear the
responsibility with him of taking this one chance of hope for humankind
and leading them all down the road of Scientology towards their
spiritual freedom.  Hubbard stresses, to not do so is to condemn
yourself and all mankind to the worst of hells.  LRH ordered this
bulletin to be one of the very first bulletins on every course in
Scientology and must be thoroughly read and understood completely.
 
     41.  Once you have bit the bait and have completely joined
Scientology, you are channeled in that vein of thinking, from there on
out with the use of Ethics procedures.  (See Exhibit 4.)
 
     42.  So from there on out, any Scientologist who does or says
anything that shows he isn't being a totally dedicated Scientologist,
starts to receive ethics procedures.
 
     43.  The severity of the ethics action applied to a Scientologist
who exhibits unorthodox behavior depends upon degree of departure from
Scientology ideals.  The severity of ethics actions are increased on the
individuals until he gets back in that corral and channeled again in the
"correct, Scientologist way of thinking."
 
     44.  For example, a student decides to go play basketball rather
than go to course that day.  The supervisor would probably just admonish
him and try to clear up what he "obviously didn't understand in his
course materials."  If this doesn't make him apologize and swear he'll
never do it again, she would send him to "Ethics."  (Ethics is also the
term used to mean the location on the premises where ethics procedures
are administered by staff called "ethics officers.")
 
     45.  Once a Scientologist is assigned to Ethics, he or she is
interrogated by one or more ethics officers until the officer is
satisfied that all non-orthodox thinking has been eliminated.
 
     46.  For example, to start with, the ethics officer will let the
student tell him his story about why he went and played basketball, and
he'll read the supervisor's report.  He'll then ask the student what
"condition" he is in.
 
     47.  In Scientology there are 10 "conditions" in life.  A person
will always be found to be in one of these "conditions."  There is a
step by step "formula" to follow to successfully come out of one
condition and move up to the next.  The names of these conditions from
lowest to highest are (1) confusion, (2) treason, (3) enemy, (4) doubt,
(5) liability, (6) danger, (7) emergency, (8) normal, (9) affluence,
(10) power.
 
     48.  If the student can't see why he should have to do one of the
lower conditions and if the ethics officer can't convince him even with
denigration, intimidation and incrimination, he would order the student
to write up all the bad things he's done, especially to Scientology.
The belief in Scientology is if a person has that much resistance to
following the rules of getting his mind reconditioned in ethics he must
have done harmful acts, especially to Scientology.  (Following the steps
of the formulas of the lower conditions would have made him resolute to
never go play basketball or anything else when he's scheduled to attend
Scientology courses.
 
     49.  If the recalcitrant student refuses to write up any bad deeds,
the ethics officer will order the student to get a "Security check".  A
security check ("sec check") is a list of questions which ask in various
ways whether the student did any harmful acts.  In a security check, the
student would be placed on an E-Meter, so his physical reactions to the
questions can be measured.  The sec checker is trained to get the person
to talk and admitting to their harmful deeds.
 
     50.  If all goes well, the student is likely to feel some relief by
getting some harmful deed off his chest.  He is likely now to cooperate
with the ethics officers and agree and decide he probably had gone into
the condition of "doubt."
 
     51.  The steps of the formula of the doubt condition make you
decide what group or type of people you want to befriend and be part of
exclusively.  In this case, the student needs to decide between the
group of Scientology and the group of "those type of people who
irresponsibly will just go off and play basketball when they should be
on course."
 
     52.  The steps you do to help you decide between the two groups is
basically to look at the intentions and productivity of both groups.
Then join or remain in and befriend the one that does the greatest good
for the greatest number of people.  Then you announce the facts to both
sides.  This can be a notice on the notice board saying you were doubt
but you've come out of it and have decided to join the group of
scientology and that you denounce the group of irresponsible people who
     . . . . Then you do everything in your power to improve the actions
and statistics of the group in which you've decided to remain.
 
     53.  As you can see from the way this formula is constructed, every
Scientologist would choose the side of Scientology.  Notice well that
you can only choose one side and it has to be wholly to the exclusion of
the other side.  After doing scores of these doubt formulas which most
long-term Scientologists have, you end up forfeiting your prior goals
and ideals and natural tendencies that were part of your natural
personality and devoting all of your time and energy to Scientology
alone.
 
     54.  Once the ethics officer deems the student has done the steps
of the formula for doubt correctly and came up with the correct answer,
he authorizes the student to move up to the next condition, which is
liability.
 
     55.  The liability formula basically has you discover who your
friends are.  Nor surprisingly, the ethics processing does not let you
advance until you conclude that your only friends are Scientologists.
The ethics procedures requires the student to conclude that he or she
must deliver an effective blow to the enemies of Scientology -- which in
this hypothetical case is the type of irresponsible person who would put
something else in life, like basketball, ahead of going to course.
important than going to course."  This might talk a couple of his old
friends into feeling irresponsible and get them on course.
 
     56.  Then the student must make up the damage he or she has done by
contributing far beyond the normal demands of the group member.
 
     57.  Then the reformed student must ask every group member to agree
to consider you a group member again.  So in the student's case, he'd
write up what he did on this formula and what amends he did and have
each person in the course room sign it saying they agreed to let him
back in the group.
 
     58.  As you can see this puts an extra seal on his resolution to
never be the "irresponsible" type again and puts him in a frame of mind
that to be really good and ethical, is to really devote all his time and
energy to Scientology.
 
     59.  Then the student must complete the "non-existent" condition
formula which makes the student more compliant and coordinated within
the group.
 
     60.  The process to rectify the out-ethics action of playing
basketball when the student should have been attending a course next
involves successfully completing the "danger" situation.  Here the
ethics officer has the student examine habits and routines and
"irresponsible tendencies" in life and to formulate and adopt firm
policy which will detect and prevent those habits and tendencies from
occurring again.  In the student's case this might be something like,
"every time I get a feeling like I don't want to go to course and would
rather go fool around with my friends, I will call the course supervisor
and tell her my feeling, so then she can get me to change my mind right
away."
 
     61.  Now the student has a future prevention policy to handle
himself if he even thinks of playing basketball or other things when he
is supposed to be on his course.
 
     62.  The next condition on the pathway back to a normal ethics
condition is emergency.  To complete this condition, the Scientologist
must produce fast and furiously, stiffen the student's discipline and
burning the midnight oil.
 
     63.  After the student successfully completes the emergency ethics
condition, he or she moves up to "normal" which says to not change
anything -- keep doing what you're doing that's causing your good
productivity in Scientology.
 
     64.  Then next up is the condition of affluence which applies if
your statistics skyrocket, which shows your productivity for Scientology
and yourself is continuously very high.
 
     65.  If everything continues to go well for an extended period of
time, you can do the "power" condition.  Completing the power condition
requires the student to write in detail everything that the student did
to maintain his or her high productivity.  This allows the student to
pass this information about how he or she achieved the condition of
power on to others so they can follow in the student's footsteps.
 
     66.  At this point, the student has gone from denying that he or
she did anything wrong, to confessing ethical breaches whether real or
imagined, to seeking forgiveness from other Scientologists for confessed
out ethics behavior, to paying penance for the alleged misdeeds, to
rededicating oneself to Scientology to boosting production, an
achievement for which the Hubbard tech is given credit, to becoming so
much a part of the system that the student authors a write-up to assist
others to achieve the same success.
 
     67.  You now have this student locked in that corral for good.  He
not only will happily put the chains and locks back in place on the gate
if they get loose or fall off, he is happily influencing everyone else
in that corral to follow in his footsteps.
 
     68.  Another key function of Ethics methodology is to seek out
those Scientologists who are connected in some way to people who are
against Scientology in any way.  The reason for this is, that
antagonistic person may cause trouble for Scientology in some way or may
upset the Scientologist by telling him bad things about Scientology or
Hubbard.  The Scientologist may even leave the organization and turn
against Scientology.
 
     69.  Once an Ethics officer finds out about a Scientologist being
connected to someone who is antagonistic in any way towards Scientology,
he labels that Scientologist a Potential Trouble Source ("PTS").  Then
that Scientologist won't be allowed to take any further Scientology
services until he has handled the antagonistic connection.  This is done
by causing the antagonistic element to changing his mind and either
agree to like Scientology or at least agree to it being okay for the
Scientologist to continue on up the Bridge.
 
     70.  In some cases the antagonistic person won't change his mind
and the Scientologist then needs to disconnect from the antagonistic
person.  Normally, the Ethics Officer will instruct the Scientologist to
write a letter denouncing the antagonistic person and cutting off all
future ties and contact with that person.
 
     71.  Basically this whole procedure fixes it so no one from outside
the corral in which the Scientologists are located, can come and
convince any of them that the "grass is greener on the other side" or
anything of that sort.  So this ethics procedure, again, helps to keep
the Scientologists happy to be in the corral.
 
     THE USE OF ETHICS IN THE SEA ORGANIZATION
 
     72.  The Sea Org is an elite group of people who have dedicated
their heart and soul and life, for the next billion years to the freeing
of humankind throughout the universe from the spiritual enslavement to
which they have been subjected.  This is what the Sea Org members truly
believe and they believe Scientology is mankind's ONLY hope for
spiritual and mental freedom.  The vast bulk of Sea Org members receive
virtually no material benefit for their service and receive only $30.00
a week as compensation for their efforts.  Sea Org members live in a
communal circumstance where food and berthing is provided.
 
     73.  The Spartan conditions under which virtually all Sea org staff
lives contrast sharply with the circumstances of the highest echelon of
Sea Org & Scientology.  Most of those in the highest echelon had their
own cars.  Miscavige, the managing agent of CSI and other Scientology
organizations, and his wife always had the most expensive cars.
 
     74.  Ethics procedures are used much more extensively and
profusely.  As you see, once you have those certain Scientologists who
are willing to spend their entire lives in the corral, they get moved
into another higher corral where they train to lasso and herd others
into the lower corral and keep them there by using ethics procedures.
 
     75.  Ethics is used to such an extent in the Sea Org that Sea Org
members are willing to put on blinders so they can avoid ever thinking
or doing anything else but Scientology and their own job and their
purpose of freeing mankind.  Oddly enough, however, when you are
"deserving" enough to be promoted to a post at the base, you no longer
get the briefings that hype you up on freeing mankind.  All you hear
from the top executives of Scientology -- at the base briefings is
hyping you up to expand scientology and make money, you rarely hear
anymore hype about "freeing humankind" at the base.
 
     76.  The reason staffers on the base want those blinders on is it's
so easy for your senior or an ethics officer to put you in a lower
Ethics condition.  If you are in a lower condition you won't get to have
time off (which you only get every other Sunday from noon on) and you'll
lose a lot of sleep by having to do amends late into the night or all
nighters, as you of course had to do amends on your own time.  As it is,
you're lucky to get 7 hours of sleep a night.  And you usually have
already been involved in doing all nighters trying to get some project
done in time.  Plus when a staffer is in a lower condition, he or she is
effectively shunned by other crew members who are obliged to not be
friendly until a staffer is out of the lower Ethics conditions.
 
     77.  Also, you take someone like me, who has been trained on nearly
ALL ethics technology in regards to security checking.
 
     78.  There is a datum that Hubbard provides in several bulletins
which is, if you are critical of an individual or group, and the
criticism is not borne out in fact then there is a harmful act that you
have committed on that person or group.  Spotting the harmful act and
getting it off your chest will give you relief.  If that's all there is,
you will no longer feel critical.  But if you decide not to tell,
several mental consequences occur:  (a) is your mind gets all tripped up
in thoughts of who may have somehow found out about it and wondering
whether or not they know, (b) you start to pull in on yourself harmful
acts.
 
     79.  Any trained, committed Scientologist would try always to take
every opportunity to disclose even the smallest of harmful acts, to
avoid those consequences.  It's interesting to note that I believed
every word of the Hubbard tech so much that I did experience those two
phenomena every time I did the smallest of misdeeds.  It's like someone
with a hypnotic command.
 
     80.  This compulsion went so far that every time something bad
happened to me -- like getting yelled at unjustly for example and it was
a rare day that that didn't happen), I would feel I must have done
something bad to be pulling this treatment in on myself.
 
     81.  I would search my mind to find out what I did.  If I couldn't
find anything (which was after the case because I was compulsive about
following every rule and being super good so that I wouldn't experience
those consequences), I would have to assume it was something I did early
on that I have hidden from even myself.
 
     82.  I had had so many security checks and had told every
imaginable smallest damaging thing I'd ever done, over and over, I
really started to think that since this lifetime has been gone over with
a fine tooth comb I must have a multitude of crimes in previous lives
that I hadn't properly exposed to scrutiny of the Ethics Officer.  To
help account for the bad experiences I was having in the present, I,
like a number of other Scientologists, began inventing atrocious acts
committed in prior lifetimes.  I conjured these up to explain why I was
so unhappy and always being yelled at despite my efforts to do
everything perfect.
 
     83.  The trick is to get Sea Org members so introverted and also so
consumed with the huge amounts of production that is demanded of you for
which you will receive very unwanted penalties if you don't meet the
production demand, that you just don't have the breathing space to
observe and honestly critically think about anything.
 
     84.  For example, I would see a friend of mine being screamed at
and wholly denigrated by a very high exec. for some mistake he made.  I
would feel very sorry for my friend.  But I had been trained to refuse
to even consider that this type of verbal and emotional abuse was wrong.
By definition, the high executive's conduct was beyond reproach.  In
fact, I was conditioned to believe that it was necessary to yell at
people to get good production done.  This conflict between my natural
inclinations and the Scientology doctrine, which I then wholly embraced,
added to my introversion because I didn't have it in me to yell like
that.  So, by definition under the Scientology belief system there must
have been something wrong with me.  I truly often felt my inability to
verbally abuse my subordinates was a major character flaw fault in me as
all major execs would regularly verbally and emotionally abuse me and
their other juniors.
 
     85.  Hubbard's tech provided an answer demonstrating why I was
wrong and the senior executives were right by engaging in is abusive
behavior.  Hubbard said that if you have a person who always tries to
conduct him or herself politely and courteously, you will normally find
humongous crimes, like blowing up planets on his or her time track.
(Time track is the recording of all your lives which includes billions
of years).  In other words, the senior executives must have led
exemplary past lives, while I must have been a criminal of intergalactic
proportions.  There was no way that an arch criminal like me could
properly confront Scientology's senior executives about what I regarded
as abusive behavior.
 
     86.  Ethics is used much more profusely at the base than at all the
lower Sea Organization units that dealt directly with the public.
 
     87.  The majority of what I've just gone over being expressed from
the intensity of how I experienced it at the base/ For example, yelling
was restrained as much as possible at those lower units so as not to
upset the public.  You wanted to display a pleasant atmosphere.
 
     88.  The only public who have witnessed all the yelling and
screaming at the base are contracted construction workers.  Several of
these were pretty shocked at how people who claimed to be religious
fraternity were regularly screaming at each other vehemently and believe
me the language they use at the base is extremely foul.  I am not
exaggerating.
 
     THE PRACTICE OF SOCIALLY DEMORALIZING STAFF IN FRONT OF THE CREW
WAS ALSO A PRACTICE AT THE BASE MUCH MORE SO THAN IN THE LOWER SEA ORG
UNITS.
 
     89.  At staff meetings, the executives who headed the various
divisions in Gold were made to get up and tell what their division
accomplished that week and to tell what they were supposed to have
accomplish and didn't.  (This is while the commanding officer is glaring
at them).  If they left out some juicy tidbit of something they messed
up on, the C.O.  (Commanding officer) reams them out and tells them to
tell everyone.  Usually they get interrupted when trying to explain
their error and the C.O. will make them sit down while he angrily tells
the crew what horrible deeds were done.  In truth it usually was the
fact that although his Division really tried hard to make their
production demands (which often meant several all nighters) they didn't
make it.  Sometimes production lagged because Miscavige didn't approve
the final production and it had to be redone.  This sort of thing
occurred with nearly half the divisions heads at every staff meeting
which took place at the end of each week.  Often individual staff
members were pointed out as the main people who let the group down and
they were made to stand up and tell what their failure was.
 
     90.  This kind of public ridicule also occurred frequently at our
daily musters.  We mustered at least 3 times a day.  A muster is where
the crew (all 300 of us) stands in lines in accordance to what division
they are in with the head of each department and is division in front of
their respective units.  Everyone gets accounted for at each muster.  I
really can't think of anyone at the base, who didn't get yelled at and
ridiculed on a routine basis.  (That is of course, except the top leader
of Scientology, David Miscavige who had no one higher up to yell at him
after Hubbard died and the 2 or 3 people who had more authority than him
were removed by Miscavige due to their purported crimes that he claimed
to have discovered.)
 
     91.  Another Sea Org. tradition that is practiced at the base and
not at lower Sea Org. units is the practice of throwing people into the
lake.  This is done with the whole crew present (or in some cases just
the whole division).  It is done as a ritual with the chaplin on one
side and about 2 ethics officers to push them in.  The Chaplin says
something like, "I condemn your souls to the Sea in hopes you will arise
a better Thetan (Thetan is the word for Spirit in Scientology).
 
     92.  Sea Org members are not allowed to watch or own a television.
This was a direct order from LRH in around 1960 or so.  They also never
have a chance to read the news.  It is frowned upon if they do read the
news.  This successfully cuts Sea Org members off from the
communications of the outside world.
 
     93.  In 1969 or 1970 at American St.  Hill Organization, I was
briefed with other public on the new operation every scientologist was
to participate in to terminatedly expose and get rid of the psychiatric
profession.  The strategy was to spread the word everywhere we went at
every opportunity about the psychiatric death camps -- whenever you
bring up the subject of psychiatry always refer to it as "psychiatric
death camps."  If thousands of 'scientologists did this on a regular
basis it would eventually be something that the majority of the public
at large would associate in their minds, i.e., whenever they think of
psychiatry they would automatically think the idea of "psychiatric death
camps."  It was made into a big deal and all at ASHO was required to
attend and the room was decorated with ribbons and so forth.  The whole
message was this was a very exciting beginning of the biggest project
levied against psychiatry ever and the job was given to all
Scientologists to bring that profession to an end.  Before the verbal
briefing by a speaker started, we listened to a tape from LRH on how
suppressive psychiatry was and they dealt mainly in killing people or at
best destroying them forever.  It was our duty to bring them down in
order to protect the public at large from them and instead drive the
public into Scientology so they could once and for all regain their
spiritual freedom.  At the end everyone clapped and cheered and were
very excited with their new mission.
 
     94.  All of Steven Fishman's use of scientology terms are very
accurate and he uses terms that only someone who had worked on staff for
quite a while would use.  I analyzed his writings to see if his terms
seemed out of place or not used properly but he used them naturally and
well.
 
     95.  Reading over Fishman's declarations, none of it is surprised
me.  The whole atmosphere I had lived in for 20 years was "smashing the
enemy in any way you can is a win for Scientology and humankind."  USGO
or OSA were the organizations that were there to ruin the enemy and keep
all entheta of their "goings on" off the regular staff members lines so
we could devote all attention in doing our posts.
 
     96.  The enemy included government agencies, the media,
psychiatrists, psychologists, AMA, any ex Scientologist who claim
publicly in any way that scientology doesn't work or who simply leaves
Scientoloqy or Sea org and refuse to return.  These people are labelled
Suppressive Persons.
 
     97.  While at Gold I became witness to a death of one of CMOI staff
at the base.  There was a pilot being conducted by one of the Units of
CMOI "RPRC."  Martine Collins, the medical officer told me about the
pilot which was intended to prove the brain facility by cleaning it.
Everyday, she would give the man a few drops of hydrogen peroxide.  One
day I saw this man sitting in the Qual building babbling nonsensibility.
I approached him to try and grasp what he was trying to say.  (This
middle aged man was usually very bright and coherent.)
 
     I declare under penalty of perjury under the laws of the United
States of America and of the State of California that the foregoing is
true and correct.  Executed in Los Angeles, California this 5th day of
March, 1994.
 
     Mary Tabayoyon