Title : Description : Keywords : Author : ----------------------------------------------- <* Q/ 1 Ford Greene California State Bar No. 107601 2 HUB LAW OFFICES 711 Sir Francis Drake Boulevard 3 San Anselmo, California 94960-1949 Telephone: (415) 258-0360 4 Attorney for ROBERT VAUGHN YOUNG 5 6 IN THE CIRCUIT.COURT OF COOK COUNTY, ILLINOIS 7 COUNTY DEPARTMENT, LAW DIVISION a CYNTHIA KISSER, No. 92 L a593 9 Plaintiff, 10 DECLARATION vs. ; OF ROBERT VAUGHN YOUNG 11 12 THE CHICAGO CRUSADER, et al. ; Defendants. 13 i 14 ) ROBERT VAUGHN YOUNG, declares as follows: 15 1. I am above the age of eighteen years old, am not a party 16 to this action, and if called upon to testify in open court would 17 testify as follows: 2. I am a resident of the State of California, City of 19 Corona Del Mar. 20 3. I have reviewed a copy of the amended complaint in the 21 above action filed on October 19, 1994. I understand that 22 Scientology wants to take my deposition. I am providing this 23 declaration to show that there is no basis for Scientology to 24 depose me. I have reviewed a copy of the Amended Verified 25 Complaint At Law filed herein on October 19, 1994, and am familiar 26 27 with the allegations set forth therein. I have no information pertaining to said allegations. 28 JB L4W OFFICES .d Greene, Fhquire #ir Francis Drake Blvd. 4nselmo. CA 94960 :4151 25.3.0360 ~Page 1. DEUARAIIOUOFROBERIVAIJCEll?YODUC ----------------------------------------------- . 1 4. I have never met Cynthia Kisser. I have spoken to her 2 on the telephone, but never had any communication with her 3 regarding the allegations in this lawsuit, or anything concerning 4 her personal life. 5 5. I am not a member of the Cult Awareness Network. 6 6. I possess no information whether or not Ms. Kisser has 7 ever been a "topless dancer in the Blue Note Bar in Tucson, 8 Arizona" or any place else, as alleged in paragraph 5 of count I 9 and paragraph 6-A of count II of said amended complaint. 10 7. I possess no information whether or not Ms. Kisser 11 was ever "fired" because "she caused numerous problems with co- 12 workers and customers" as alleged in paragraph 5 of count I and 13 paragraph 6-A of count'11 of said amended complaint. 14 8. I possess no information whether or not Ms. Kisser 15 had ever "picked up the mantle of Napi architect of the Holocaust 16 Reinhart Heydrich who in 1936 was ordered by-Hitler to rid the 1 7 Third Reich of 'sects and ~ults'~ as alleged in paragraph 6 of 18 Count I of said amended complaint. 19 9. I possess no information whether or not Ms. Kisser, or 20 individuals associated with the Cult Awareness Network kidnap 21 individuals as alleged in paragraph 6-B of Count II of said 22 amended complaint. 23 10. I possess no information whether or not Ms. Kisser, or 24 individuals associated with the Cult Awareness Network provide 25 individuals with drugs whose possession and distribution are 26 prohibited by law as alleged in paragraph 6-C of Count II of said 2-i amended complaint. 2E 11. I possess no information whether or not Ms. Kisser, or UB LAW OFFICES rd Greene, Esquire Sir Frmcic Drake Blw Anselmo,cA 94960 (415) 2saDm Page 2. DECLABATIOB OF ROBERT VADCBIM ----------------------------------------------- 1 individuals associated with the Cult Awareness Network are 2 associated with individuals who have been convicted of crimes 3 involving sexual perversions as alleged in paragraph 6-D of Count 4 II of said amended complaint. 5 12. I possess no information whether or not Ms. Kisser, or 6 individuals associated with the Cult Awareness Network are Nazi- 7 like, associated with Hitler and advocates of Holocaust type 8 solutions to the problems of "sects and cults" and are thereby 9 guilty of crime against humanity involving mass murder as alleged 10 in paragraph 6-E of Count II of said amended complaint. 11 13. I possess no information whether or not Ms. Kisser, "had 12 a previous career as a topless dancer at the Blue Note Lounge in 13 Tucson, Arizona. Now defends the pedophile crowd in Nebraska" as 14 alleged in paragraph 5 of Count IV of said amended complaint. 15 $4. I possess no information whether or not Ms. Kisser, or 16 individuals associated with the Cult Awareness Network have been 17 associated with Dahmer, the Milwaukee man accused of cannibalism 18 and dismemberment of his murder victims as alleged in paragraph 7- 19 A of Count IV of said amended complaint. 2c 15. I possess no information whether or not Ms. Kisser, or 21 individuals associated with the Cult Awareness Network "took to 22 the airwaves and newspapers to protect a pedophile ring in Omaha, 23 Nebraska as alleged in paragraph 7-B of Count IV of said amended 24 complaint. 2E 16. I possess no information whether or not Ms. Kisser, or individuals associated with the Cult Awareness Network have been 27 associated with psycho-killer Charles Manson and linked to the 2f infamous Son of Sam murders" as alleged in paragraph 7-c of Count NIB LAW OFFICES >rd Greene, Fsquire Sir Francis Drake Blw Amelmo. CA 94960 (415) 258.0360 Page 3. DECIARATIOU O F R O B ER T VADCEM YOUM ----------------------------------------------- 1 IV of said amended complaint. 2 17. I possess no information regarding the actions of 3 defendants in disseminating any and all of the foregoing 4 statements. 5 18. I possess no information regarding the manner in which 6 Ms. Kisser was damaged as alleged in the amended complaint. 7 19. I possess no- information whether or not Ms. Kisser 8 ever sought a retraction of any of the above statements as alleged 9 in said amended complaint. 10 20. I am providing this declaration in order to satisfy 11 Scientology's need to know whether or not I have any evidence 12 related to the above case. I do not. I believe that 13 Scientology's desire to take my deposition is part of an on-going 14 tactic of retribution in furtherance of its Fair Game Policv 15 because I am a former Scientologist who has taken a public stance 16 criticizing Scientology's practices, the character of its founder 17 L. Ron Hubbard and its present commandant, David Miscavige. 18 21. I have been previously deposed by Scientology on three 19 different occasions. If Scientology can provide some reasonable 20 basis for taking my deposition in this case, I would consider 21 making myself available for the same. In the absence of such 22 evidence of good faith, however, I believe that Scientology is 23 simply attempting to harass me. 24 /// 25 /I/ 26 /// 27 /// 28 /// IUB LAW OFFICES ml Greene. Esquire Sir Francis Drake Blvd Anselmo, CA 94960 (4 15) EwJ3flo Page 4. DECLARAIIO~ OF ROBERT V- YOUNG ----------------------------------------------- _‘_ . . 1 Pursuant to the laws of the State of California and Under 2 enalty of perjury, I hereby declare that the foregoing is true ? nd correct. 1 EXeauted on October 31, 1994 at Corona de1 Mar, California. 1.