221 N. Figueroa Street, Suite 1200
Los Angeles, California 90012
Telephone: (213) 250-1800
Attorneys for Defendant
UWE GEERTZ, PH.D.
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
CHURCH OF SCIENTOLOGY
INTERNATIONAL, a California
non-profit religious
organization,
Plaintiff,
vs .
STEVEN FISHMAN AND UWE GEERTZ,
Defendants.
Case No. CV 91 6426 HLH (Tx)
DECLARATION OF ROBERT VAUGHN
YOUNG IN SUPPORT OF COST BILL
FOR DR. GEERTZ'S MOTION FOR
AWARD OF COSTS, EXPENSES,
ATTORNEY'S FEES AND SANCTIONS
Date: APRIL 4, 1994
Time: 10:00 a.m.
Courtroom: 7
[Filed and served
concurrently with Dr
Geertz's Bill of Costs ]
DECLARATION OF ROBERT VAUGHN YOUNG
I, Robert Vaughn Young, declare that I am over 18 years of age and
am a resident of Newport Beach, California.
INTRODUCTION
I have been retained as an expert consultant and expert witness by
Dr. Uwe Geertz's counsel in the case captioned Church of Scientology
International v. Steven Fishman and Uwe Geertz. *CV-6426-HLH (Tx)
currently pending in the United States District Court, Central District of
California. The statements herein are of my own personal knowledge or
reasonably based upon information and belief, and if called upon as a
witness, I can testify competently thereto.
This declaration is submitted in support of Defendant Dr. Geertz's
motion for costs. fees. expenses and sanctions following the dismissal of this
action with prejudice by the court on February 22, 1994.
My credentials as an expert on Scientology includes over 20 years as
a staff member in the organization. In those 20 years, I have held nearly
every type of position at every echelon. I have worked at the local, the
regional, the national and the international levels. I have been a Scientology
representative and spokesman before governmental bodies, the media andthe
courts. I have trained others
on how to handle the media and
governmental agencies. I have been the most senior public relations
executive for Scientology world wide. I worked for years at the echelon that
handles critics, "enemies," the media, judges, the courts and the government.
I have been privy to documents and tactics of the most secret nature,
including illegalities committed by Scientology executives and the means of
cover-up. I have been called on many occasions to personally handle "hot"
situations of the most sensitive nature ranging from the mysterious death of
the son of Scientology Founder Ron Hubbard ("Hubbard") to the death ofHubbard himself. I have been privy to financial schemes and scams
involving tens of millions of dollars. I also know how Scientology
manipulates the law to avoid any revelation of the truth.
SCIENTOLOGY ADVOCATES USING THE
COURTS NOT TO SEEK JUSTICE BUT
TO HARASS AND RUIN PEOPLE
Plaintiff Church of Scientology International's ("CSI") request thatthis case be dismissed is in keeping with one of their most senior
scriptures," to use to courts to harass and ruin people rather than win. It
has been a primary tactic since Hubbard gave the edict in 1955 when hewrote the
purpose of bringing a
lawsuit:
"The purpose of the suit is to harass and discourage rather
than to win. The law can be used very easily to harass, and enough
harassment on somebody who is simply on the thin edge anyway,
well knowing that he is not authorized, will generally be sufficient to
cause his professional decease. If possible. of course ruin him
utterlv." (From Hubbard's 1955 "The Scientologist: A Manual of
Dissemination of Material." Emphasis added. Attached as Exhibit A)
The basic reason that Scientology does not use the courts for justice
is because Hubbard believed the Scientology justice system he invented was
vastly superior and that his system should become the planetary standard.
DR. GEERTZ IS THE TARGET OF
SCIENTOLOGY'S VOW TO DESTROY "THE PSYCHS"
The key to understanding the mystery of the current lawsuit and its
tortuous route will be found in the above Hubbard directive plus one further
element: Defendant Dr. Uwe Geertz is a psychologist. Scientology has
vowed to destroy and take over the field of mental health. Thus Dr. Geertz
is the target of Scientology's equivalent of "The Final Solution," where a
profession has become a universal scapegoat.PSYCHS ARE SCIENTOLOGY'S SCAPEGOATS
FOR EVERYTHING INCLUDING SEX
It is drilled into every Scientologist's head that all troubles and
problems - Hubbard's, Scientology's, America's, the world, this corner of
the galaxy and literally the entire universe - are due to psychiatrists and
psychologists, known collectively as "the psychs." In fact, Hubbard said the
ONLY cause of crime is the "psychs." He even goes so far as to say "there
are no laws at all which protect them. . ." from being attacked. (See
Hubbard's "The Cause of Crime," Attached as Exhibit B. See also
declaration of Stacy Young also filed this date.)
The "psychs" are Hubbard's scapegoat for all historical ills going
back not merely scores of years but hundreds, thousands and even millions
of years. In Hubbard's paranoid view, everything from rock and roll to the
Third Reich and even sex itself were vile inventions of 'psychs'. (See "Pain
and Sex." Attached as Exhibit C.) As incredible as that may seem, Hubbard
actually believed that sex was literally invented by "psychs" millions of
years ago. While he doesn't come out and say it, the implications are clear:
all sex - even the attraction between couples - is bad.
The intensity of Hubbard's anti-sex (and especially anti-female)attitude is not
known to many
Scientologists. Starting in 1981, I had full
access to Hubbard's most private papers, diaries and letters. I continued to
have unlimited access to it for years as part of the work to write a
biography of Hubbard and was able to read letters to and from his parents,
wives. mistresses, friends and business associates. There were hundreds of
thousands of pages of material - much of it originals or carbon copies in his
own handwriting - that detailed his views about his life, his wives, his
family and sex. Much of this was written in the 1930s and 1940s but
extended into the 1970s. Some of these papers were diatribes against
females and were covered with red-ink drawings of genitalia around the
margins of the pages. He also graphically described what he wanted to do to
women, including hurting and raping them. Suffice it to say that it was x-
rated and sadistic. This was my initiation into the dark side of Hubbard's
views. (these papers were subsequently locked away so no Scientologist
will even know they exist, let alone allow anyone to see them.)
Hubbard's anti-female attitude appeared first, in private writings in
the 1930s and 1940s. His views of "the psychs" developed after the
publication of his first Scientology books in 1950 when he was courting
"the psychs" for approval of his system. When he was rebuked andcriticized, he
became incensed and began
to blame them for his troubles
with the press and his customers.
Thus Dr. Geertz is viewed as a part of the international (and
intergalactic) conspiracy that must be annihilated before Hubbard and
Scientology can reign on Earth.
CSI'S CASE IS PART OF
THE "FAIR GAME DOCTRINE"
AND "PSYCHS" ARE FAIR GAME
CSI has a Fair Game Doctrine where any "enemy" can be
"destroyed." This doctrine is practiced against apostates, critics, the press
and has even been used against courts. It has been practiced against Dr.
Geertz (starting with this lawsuit that put him into bankruptcy) and his
counsel in this case (ranging from an investigation that this court ordered
stopped to vandalism of Mr. Graham Berry's property.
I will show how the Fair Game Doctrine started. how it has
continued to this day and how this court has been exposed to these end-
justifies-the-means methods. I will present this using the writings (now
called "scriptures") of Hubbard. These are the iron-clad policies ofScientology.
"FAIR GAME": THOSE THAT HAVE NO RIGHTS;
THEY AND/OR THEIR PROPERTY
CAN BE DESTROYED
The doctrine of Fair Game was codified on March 7, 1965, when
Hubbard issued titled "Suppressive Acts: Suppression of Scientology and
Scientologists: The Fair Game Law" (Attached as Exhibit D) Hubbard
wrote,
By FAIR GAME is meant, without rights for self, possessions
or position, and no Scientologist may be brought before a
Committee of Evidence or punished for any action taken against a
Suppressive Person or Group during the period that person or group
is 'fair game'.
A revision of December 23 1965, changed it to read, "By- FAIR
GAME is meant, may not be further protected by the codes and disciplines
of Scientology or the rights of a Scientologist."
As to what was a "suppressive person," Hubbard gave the definition:
A SUPPRESSIVE PERSON or GROUP is one that actively
seeks to suppress or damage Scientology or a Scientologist bySuppressive Acts.
SUPPRESSIVE ACTS are acts calculated to impede or
destroy Scientology or a Scientologist and which are listed at length
in this policy letter. (Caps in original.
Some of the suppressive acts listed included "public disavowal of
Scientology;
public statements against Scientology;" asking for a refund
of fees paid; and "writing anti-Scientology letters to the press." Even
turning a Scientologist into the proper authorities can gain one the label of a
suppressive. The issue also prohibits "1st degree murder, arson,
disintegration of persons or belongings not guilty of suppressive acts."
(Emphasis added.) In other words, killing suppressive persons or destroying
their property promotes Scientology and is therefore ethical within the
Scientology belief system.
WHY SCIENTOLOGISTS CANNOT GIVE
UNBIASED TESTIMONY
The material just quoted also shows why Scientologists cannot give
unbiased testimony. If the testimony is viewed as critical of Scientology or
a Scientology executive, it would be a "public disavowal" and a "publicstatement
against Scientology" and
would be a suppressive act. The person
could then be kicked out of Scientology and be made Fair Game and sued.
Since Scientologists don't want this to happen to them, they will not make
any critical remarks or remarks that may be deemed critical. This is why
Scientology officials have insisted that only active Scientologists can be
experts" - because they will be biased to Scientology rather than
responding fully and honestly to the Court.
AN EXAMPLE OF HUBBARD
IMPLEMENTING FAIR GAME
Scientologists like to find instances where Hubbard applied a
doctrine so they can imitate it. Hubbard gave an example of how Fair Game
should be applied shortly after he created the doctrine. Hubbard gave
specific orders on how to apply the Fair Game doctrine in HCO Executive
letter 27 September 1965 or. "Amprinistics " (attached as Exhibit E) This
was what he called a "splinter" group, a group that was using Scientology
"technical" methods without his control. Hubbard's three-page issue blasts
the Amprinistics leaders with a variety of sexual charges (one of his favorite
topics for accusations) and says what should be done:
"They are each fair game, can be sued or harassed. Hornercan be barred out of
any Commonwealth Country
or England as he
was the subject of a deportation order from England and his file has
come alive again in the Home Secretary's Office. Harry Thompson's
wives and victims are always looking for him to have him arrested.
Watson is a set-up for arrest as a homosexual. Any meeting held by
them should be torn up. The names of any persons attending should
be collected and they should be labeled SP [suppressive person] as
they have left Scientology. These people are SP because they are
seeking to avoid auditing and retain their withholds. Once labeled,
these persons will not then be covered by amnesty and will never be
admitted to further training and processing. Persons messing
themselves up with Amprinistic [techniques] should be refused any
assistance. If these persons move into your area act through any
agency you can to have them deported or arrested on whatever
grounds. England is currently too hot for them so they may tour
about. Horner's UK deportation order, Thompson's police record and
Watson's homosexuality make them very vulnerable to deportation
or arrest.
Hubbard does not stop there. He goes on to issue a five-step orderthat includes:
"(2) Harass these persons in any possible way....
"(4) Tear up any meeting held and get the names of those
attending and issue SP orders on them and you'll have lost a lot of
rats.
This order is has never been canceled and is still "scripture" as an
example how to attack "enemies." In fact, as an example of how Fair Game
was being implemented against another defendant, attached as Exhibit F is a
declaration from former member David Mayo who describes how he was
held captive for six months and was told he would "never leave the property
alive." (See pages 4-8) He describes the duress and threats as he became the
target of the Fair Game Doctrine (or "Fair Game Law.")
HOW SCIENTOLOGY USES INVESTIGATION
AND THE MEDIA TO ATTACK
AND HARASS CRITICS
In 1966, Hubbard began to codify those sections of Scientology that
would implement Fair Game. For example, on February 17, 1966, he
created the Public Investigation Section with a policy letter of that name and
date. (Attached as Exhibit G) He said it would serve "the useful functions ofan
intelligence and propaganda
agency. It finds the data and sees that it gets
action." The statistic of the unit included "the number of derogatory news
stories appearing that week related to enemies of Scientology."
Hubbard also urged the priority of finding evidence of "murder,
assault, destruction, violence, sex and dishonesty, in that order.
Investigations which can uncover these factors in the activities of individuals
or a group attacking Scientology are valuable in the degree that they contain
a number of these factors." And note that Hubbard's use of such evidence is
not for law enforcement but to the media. "In that way," he wrote, "we then
Get rid of suppressive groups by investigation and disclosure." (Emphasis
added.)
The next day, on February 18, 1966, Hubbard wrote "Attacks on
Scientology" (Attached as Exhibit H) in which he again urged the use of
investigations. Suppressives, he said, have by definition comitted criminal'
acts. "These people who attack have secrets. And hidden crimes. They are
afraid." He thus urged they be investigated as this, he said, would cause the
attacker to withdraw.
A week later, on February 25, 1966, he wrote another "Attacks on
Scientology" policy letter (Attached as Exhibit I) in which he urged, to"Start
feeding lurid, blood sex crime
actual evidence on the attackers to the
press.
See also Hubbard's "How To Do a Noisy Investigation" of 5
September 1966 (Attached as Exhibit J). The target is "attackers of
Scientology".
FAIR (GAME DOCTRINE
SPECIFICALLY INCLUDES
THE FILING OF LAW SUITS
On October 18, 1967, he issued "Penalties for Lower Conditions"
(Attached as Exhibit K) whereby Fair Game was automatically issued on
anyone (including staff members) who was an "enemy." Such people were,
he said, "Fair game. They may be deprived of property or injured by any
MEANS by any Scientologist without any discipline of the Scientologist. May
be tricked, sued or lied to or destroyed." (Emphasis added.)
CANCELLATION OF FAIR GAME ONLY MEANT
NOT USING THE WORDS ANY MORE BECAUSE
IT CAUSED "BAD PUBLIC RELATIONS"
In the late 1960s, Hubbard was having growing public relationsproblems. One
problem was Fair Game. To
deal with it, Hubbard wrote an
issue that is often cited by CSI as evidence that Fair Game was canceled.
But a careful reading will show that nothing has changed but semantics. The
issue is "Cancellation of Fair Game" dated 21 October 1968. (Attached as
Exhibit L) The entire text of the policy letter (P/L) is as follows:
"The practice of declaring people FAIR GAME will
cease. FAIR GAME may not appear on any Ethics Order.
It causes bad Public relations. [Emphasis added.]
This P/L [policy letter] does not cancel any policy on the
treatment or handling of an SP. [suppressive person]
L. Ron Hubbard Founder
THUS THE SO-CALLED "CANCELLATION"
OF FAIR GAME DID NOT CANCEL
THE USE OF FAIR GAME TACTICS
The original directive that CSI uses to say the Fair Game Doctrine
was canceled expressly establishes that the only change was to stop using
the words "Fair Game.". Hubbard was quite clear that tactics were not to
change. only the use of the words in public.
As further evidence of Fair Game continuing, Hubbard later wrote"Confidential:
Targets, Defense" on
February 16, 1969, (Attached as Exhibit
M) in which he listed "vital targets on which we must invest most of our
time..." The first and most important: "T1. Depopularizing the enemy to a
point of total obliteration."
MILITARY TACTICS ARE TO BE
USED IN FAIR GAME
On the same day, February 16, 1969, he wrote "Confidential: Battle
Tactics" (Attached as Exhibit N) where he urged the use of military tactics
and strategy in dealing with the "enemy." He wrote,
"A good general expends the maximum of enemy troops and
the minimum of his own. He makes the war costly to the enemy, not
to himself. One cuts off enemy communications, funds, connections.
He deprives the enemy of political advantages, connections and
power. He takes over enemy territory. He raids and harasses._All on
a thought plane--press, public opinion, governments, etc.
(Emphasis added.)
FAIR GAME TACTICS
EXPLAIN THIS LAWSUIT
When the Fair Game Doctrine and Scientology's "Final Solution"attitude towards
"psychs" (psychologists
and psychiatrists) are understood,
this lawsuit can be understood. It will also be seen that what was at issue
was not the deposition of the "celebrities" but those of the executives who
were in non-compliance with this Court's Order. The reason was simple:
they are the ones who directed this entire campaign.
HOW SCIENTOLOGY ATTORNEYS ARE USED
TO CLAIM "ATTORNEY WORK PRODUCT"
Surveillance is one of the standard tactics used by Scientology and
CSI. It is often done by staff from the Office of Special Affairs ("OSA").Tougher or more important assignments are given to private investigators
who are paid by attorneys so the investigation can be called "attorney work
product." This practice was because the 1977 FBI raid shattered
Scientology's intelligence network.
The court should note that it has been told that such practices were
done by a previous Scientology administration that has been eradicated. This
is not true. I am attaching the billings of a private investigator who was
doing surveillance on author Omar Garrison and apostate Gerry Armstrong
in 1982. (Attached as Exhibit O) These were billed to attorney John
Peterson. ("Peterson") However this investigation was being directed byDavid Miscavige ("Miscavige")who at the time (mid-1982) was my senior
in an organization called Author Services, Inc. ("ASI") ASI was a for-profitgroup that was purportedly a literary agency handling Hubbard's books. We
did handle Hubbard's works but our real function was to serve as Hubbard's
personal arm into the non-profit Church of Scientology. This investigation
by Tin Goose of Omar Garrison and Gerry Armstrong was paid for by
Church of Scientology funds on Miscavige's orders while Tin Goose
reported directly to Miscavige. Peterson was merely the "cutout," to make it
appear that it was attorney work product and to keep it away from ASI.
HOW MISCAVIGE USED A "DOUBLE-BLIND"
TO GO AFTER AN ATTORNEY
In 1982 a "double-blind" system was initiated by Miscavige when he
was directing the campaign against Boston attorney Michael Flynn.
("Flynn") Flynn had been representing plaintiffs in suit against Scientologyand Hubbard, and Miscavige was demanding that Flynn be destroyed. (This
is the Fair Game Doctrine although the words were never used, per
Hubbard's orders.) Peterson was told to hire another attorney who had no
connection or any knowledge of Scientology. That fresh attorney was to hire
the private investigators to undertake certain harassing actions on Flynn.
Thepurpose of the double-blind
was if the investigator was caught and traced to
an attorney, it would not be one hired by a Scientology group and any
illegalities could be protected twice as attorney work product.
With the formation of the firm of Bowles and Moxon (attorneys for
plaintiff in this case), investigations were moved to them rather than
attorneys like Peterson because Bowles & Moxon are Scientologists and can
be manipulated and threatened. Peterson was not a Scientologist and could
not be so controlled.
EXPERTS AND COUNSEL ON THIS CASE
WERE KEPT UNDER SURVEILLANCE
The court was advised of the investigation of counsel Graham Berry
and ordered that it be stopped. (It was not because CSI cannot stop. Such
investigations are required by Hubbard's "scriptures.") A similar
investigation and surveillance was done of other experts on this case
including myself and my wife. This went on for months. We have been
tailed on the freeways, in shopping malls and even while a hundred miles
from home on a day off. (In one instance, a tail I accosted confessed that he
was tailing me and that he was Scientology staff.) Our trash has also been
pilfered and former employers and associates interviewed. All of this is
inkeeping with the Fair Game
Doctrine, hoping that they will find something
to intimidate the person with. (If that doesn't happen, then something is
concocted. They are now doing that with me, asserting that I assaulted a
Scientologist in the city of Hemet. Their insistence that I be charged is
being led - appropriately enough - by one of their key public relations
people, Ken Hoden, who gets his orders from David Miscavige
("Miscavige") who is the head of the Scientology empire. At this writing,nothing has come of their baseless allegations.)
EXAMPLE OF TARGETING A PERSON
IN LITIGATION WITH SCIENTOLOGY
Attached as Exhibit P is a Scientology program ("Julie'sBackground") designed to deal with a court problem in 1979. Julie
Christofferson. She had sued the church and this program was written to
.document that the people involved in the Christolfferson case
are criminals with criminal backgrounds and criminal records and
that they engage in a criminal conspiracy to defraud the organization
under the guise of "home and mother." Julie appears to be pure as
the driven snow, so considerable background data [Scientology's
euphemism for covertly obtained data] on her is needed to give usdirection in
locating the real facts of
interest about her.
Those "real facts of interest" are stated in the next paragraph as to
what Scientology wants on the plaintiff.
The criminal background, drug history, record of arrests, former
employment, perversions of Julie, fully known and documented, as
needed.
The program then goes on for pages to tell how to do this. There is nothing
to indicate there is anything to find, merely the Hubbard-driven assumption
that anyone who sues Scientology or attacks Scientology must by definition
be a criminal. The program was written on Hubbard's direction.
CSI'S REFUSAL TO COMPLY IS BECAUSE OF
CSI'S COMPLETE DISDAIN FOR ANY SYSTEM
OTHER THAN HUBBARD'S
(CSI's general non-compliance with the orders of this Court was
because of the disdain that Hubbard and the current leadership have for this
and any court as well as the law. Time and again Hubbard wrote how his
system of "justice" was superior to any system. Additionally Hubbard and
Scientology were constantly being challenged by the courts. In Hubbard's
view, neither he nor Scientology should have to answer to anyone.ACCORDING TO
THE
SCIENTOLOGY
BELIEF SYSTEM. THE COURTS
ARE PART OF A CRIMINAL PLAN
DIRECTED BY "THE PSYCHS"
Another reason Hubbard and Scientology hold the courts in such
disdain is Hubbard's view that the purpose of the justice system is to
support psychologists and psychiatrists. This is done by "psychs" creating
criminals who keep the courts alive who feed them back as a self-
perpetuating system, funded entirely by the government. Hubbard wants to
have the criminals fed to Scientology and to replace the legal system of
justice with Hubbard's system, thus collecting the money that he felt is
going to the psychiatrists and psychologists. (See attached as Exhibit Q
"The Criminal Mind and The Psychs," attached as Exhibit R "The Cause of
Crime," attached as Exhibit S "Criminals and Psychiatry," and attached as
Exhibit C "Pain and Sex.")
THE ORDERED DEPOSITIONS
SHOULD HAVE PROCEEDED
The Court ordered David Miscavige, Norman Starkey, Mark Yager,
Ray Mitoff, Lyman Spurlock, Marty Rathbun, Greg Wilhere and JonathanEpstein to
deposition. Most have,
in turn, filed declarations to explain why
they know nothing that is germane to this case. To the contrary, these are
the executives who know more about this case than anv other people.
Despite Miscavige's protests, he runs all of Scientology, regardless
of corporate lines. In Scientology, there is only Scientology. Corporate lines
are set up as ways to deflect the courts, the IRS and the authorities. When it
comes to everyday work, Miscavige is appraised of every part of
Scientology, from the church to the secular. He also issues orders to all
sectors and approves all major transactions. His role is as the head of
Scientology is well known within Scientology. It is only when it comes to
matters such as this suit that he and his lieutenants must suddenly conjure
up the corporate lines and claim ignorance.
MISCAVIGE KNEW OF FISHMAN AND
CROSSED CORPORATE LINES TO
DEAL WITH FISHMAN'S MONEY
Additionally, Miscavige knows about Defendant Steve Fishman
("Fishman") and the amounts of money that Fishman contributed toScientology. Miscavige had people removed from their positions because of
the Fishman's money and now Miscavige claims he knows nothing. ButMiscavige knew
of the massive
amounts of money the Fishman had
contributed. Miscavige gave a briefing at Golden Era Studios near Hemet,
California, in 1987 to hundreds of staff (that included staff from non-CSI
corporations) about Fishman's contribution of about $80,000 for a library of
"leather-bound" tapes. In that briefing, Miscavige screamed and cursed at
the head of Golden Era Studios (Wendall Reynolds) because there were no
such tapes to be sold. Miscavige (who is Chairman of the Board of the
Religious Technology Center, a non-CSI entity) removed Reynolds from his
position on the spot and assigned Reynolds to the gulag known as the
Rehabilitation Project Force where he worked at hard labor for over two
years. (I was sentenced to the same gulag for 14 months. Reynolds was
there when I arrived.) Thus Miscavige not only knows of Fishman but has
admitted it to hundreds of others. His claim he knows nothing is false
testimony, as many can testify.
The others (Starkey, Yager, Mitoff et al) are Miscavige's immediate
lieutenants who carry out his orders into their various sectors. They too
know about the lack of corporate integrity and any role that Fishman played
in Scientology. They also know about the various Hubbard directives I
have quoted from.FISHMAN WAS BEING URGED TO INVEST IN
"SPECIAL PROPERTIES," WHICH IS NOTHING
BUT A FINANCIAL SCAM
The idea of "leather-bound tapes" is part of a line of "special
properties" that was created by Miscavige in 1982 when he was Chairman
of the Board at Author Services, Inc. ("ASI") I joined ASI in February,1982, and left it in 1989. One of ASI's functions was to make millions of
dollars for Hubbard. One way was by investments of Hubbard's fortune,
which Miscavige directed, even though Miscavige had no investment
background. Miscavige poured millions of dollars into oil speculation and
lost it without telling Hubbard. (At one point the estimate was that
Miscavige had lost about $50 million of Hubbard's.) "Special Properties"
was Miscavige's idea on how to recoup the millions before Hubbard (and
the IRS) found out. The idea was to create "leather-bound special editions"
and other items that could be sold at outrageous prices as an "investment".
Those who bought books at thousands or even tens of thousands of dollars
were then told a few months later how their "investment" had increased.
Meanwhile, on the open market, the books were worth perhaps a hundred
dollars, which was why Miscavige prohibited the open sale of these "Special
Properties." (ASI now denies that there ever was a line of properties for
investment.") This was how Fishman came to spend an astounding
$80,000 for a set of "leather-bound" tapes, which didn't even exist, and why
Miscavige knew.
CSI HAS MISREPRESENTED ITS ROLE
IN RELATION TO THE "CELEBRITIES"
CSI's claim that it didn't want to put its "celebrities" through a
hardship is patently ridiculous. In my 20+ years in Scientology (which
included working with many of them), I never once heard anything like this.
To the contrary, it was just the reverse: "celebrities" would complain how
they were being used, how they were being ordered to promote Scientology
and being made to make media appearances when there was a legal problem
or a problem in the media. The fact that these "celebrities" did not appear
for their ordered depositions shows the control that CSI has over them. Now
CSI turns it upside down again, claiming their welfare is why they want to
drop a three-year old suit that has cost millions of dollars.
THE DEPOSITIONS OF THE "CELEBRITIES"
DID NOT INVOLVE CONFIDENTIAL MATERIAL
CSI has made it a point that several "celebrities" will be exposed to
"confidential" material if forced into deposition. I know what material CSI
was referring to and those materials had nothing to do with the ordered
depositions. The "confidential" material is what is called "upper level"
material in Scientology. This material is reserved for certain steps in
Scientology "counseling," and had nothing to do with the ordered
depositions of "celebrities," none of whom are even familiar with them.
At no time has attorneys for Dr. Geertz asked me for any assistance
in handling this material, as to what it might mean, how they might ask
questions about it, how they might use it or how the material might be
presented to a person in any deposition, let alone indicate in any way that
they intend to use those materials with those "celebrities." Nor are attorneys
for Dr. Geertz capable of doing this without expert help for the material in
question is highly arcane, complex and bizarre and will make absolutely no
sense to anyone outside of Scientology. Thus the idea that attorneys for
Defendants will somehow expose these "celebrities" to this "upper level"
material is merely a sham and an excuse. What was feared was that the
other depositions would occur, namely that of Miscavige, Starkey, Yager,
etc.
CSI's attempt to use their own refusal to comply with the court as
the reason for dismissal is a classical Scientology through-the-looking-glass
strategy.
DENIAL OF LEGAL LIABILITY
WAS A TACTIC TAKEN ORIGINAL WITH HUBBARD
It was a long a well-known fact to Scientology executives that
Hubbard ran Scientology, even though he had made public claims he was
not. That was why there were programs to make it appear that Hubbard had
no legal connection to the church. That tactic is what is now being used for
Miscavige who has taken over Hubbard's position at the top of Scientology,
even though Miscavige runs it just as Hubbard did. (See Exhibit T for
"Operation Bulldozer Leak", a program designed to create that impression.)
CSI HAS NOT REFUTED YOUNG'S
STANDING AS AN EXPERT
Tn the declarations filed to claim discovery is complete, CSI has
tried to refute my standing as an expert, even going to far as to twist the
facts. For example, Miscavige tries to refute my claim that I arrived on the
scene of Hubbard's before the authorities by saying that I arrived with some
gardeners and cooks. This is not only not true but ridiculous since I arrived
in the same entourage as Miscavige himself, two private investigators and
attorney Earl Cooley who handled the disposition of Hubbard's body.
Miscavige knows that I was a top Hubbard aide who was privy to
considerable material and so do many others. He (Miscavige) can no more
tell the truth about my role than he can about his, that he runs all of
Scientology. I stand by my declarations and the documents supplied with
them and am confident that the Court can winnow the wheat from the chaff.
HUBBARD'S DEATH CREATED A
POWER STRUGGLE THAT MISCAVIGE WON
Hubbard died in hiding in January, 1986. He had been in hiding for
several years. Even though we were in weekly written communication with
him at Author Services, Inc., it was our task to pretend we were not, to
keep the authorities from knowing how to reach him. During this time,
Hubbard's closest confidant was Pat Broeker who was living with him as
his aide. When Hubbard died, a power struggle erupted between Broeker
and Miscavige as to who would run Scientology. Miscavige won. Those on
Broeker's side were purged. That included me. I was sent to a desert gulag
for 14 months. Broeker's wife Annie gave in and arrived while I was there.
She later escaped once and was captured and returned and kept under 24-
hour guard. Pat disappeared and no one has heard of him since. It is not
known if he is alive.
HUBBARD'S AND OTHER
MYSTERIOUS DEATHS IN SCIENTOLOGY
When it comes to the issue of deaths in Scientology, there are some
important ones to use as a measure, starting with that of its founder,
Hubbard, who died in January, 1986. I arrived at his secret ranch near San
Luis Obispo, California, within hours of his death, well before the
authorities. I went with Miscavige, attorney Earl Cooley, two private
investigators and a few other key, selected staff. It was our collective task to
take command of the situation. The greatest fear was that there would be a
panic in the Church of Scientology if the circumstances of Hubbard's death
were known. For example, while Hubbard's condition deteriorated in the
final weeks, his personal physician (Dr. Gene Denk) was sent to Reno to
gamble, leaving Hubbard with no medical attention. Or that Hubbard's
primary source of Scientology help was a person who had taken LSD over
1000 times. Or that the story that Hubbard decided to "leave the body"
(Scientology's way of saying "died") was dreamt up at the next morning to
calm Scientologists. Or that the body was quickly disposed of to avoid any
autopsy that would reveal "medicines" that he had been taking. Thus the
actual truth of Hubbard's death has yet to be told.
Hubbard's son Quentin also died under mysterious circumstances in
1976. He had disappeared from his home in Clearwater, Florida, and was
found unconscious in a car next to the Las Vegas airport.
(Coroner's report
is attached as Exhibit U. He died unidentified, as a "John Doe.")
The engine
of the car was on and a hose ran from the exhaust pipe (although it
appeared to have fallen off when the authorities arrived) to the window,
making it appear to be a suicide. But, like his father's death, there were a
number of nagging questions. For example, Quentin was found unkempt
with a beard stubble, a state that no one who knew Quentin could accept.
(He was ultra-meticulous in his appearance.) Or that the license plate of the
car was missing and found under a rock some distance away. Or that his
wallet was gone, making identification impossible. Or that a near-empty
bottle of liquor was found, as if he had been drinking, when Quentin did
not. Or that there were needle marks on his arms, when he did not use
drugs.
Another mysterious but key death was that of Flo Barnett,
Miscavige's mother-in-law. She died in 1985 of three shots to the chest and
one to the temple from a semi-automatic rifle. Two suicide notes were
found. Although she was only 5'3" tall (and weighed only 114 pounds), the
examiner determined she shot herself three times in the chest (with a rifle)
before shooting herself through the head. (See coroner's report attached as
Exhibit V.) What the authorities didn't know was that she had left
Scientology and was associating with apostates, to the anger of her son-in-
law Miscavige.
Defendant Uwe Geertz was prepared to present information about
other mysterious deaths, murders and suicides of Scientologists and former
Scientologists.
CSI DID NOT COMPLY WITH DISCOVERY
One unfamiliar with Scientology systems might think there would be
no other information to be provided but as a 20-year veteran and one
intimately familiar with the unchanging system, I can attest there is
considerable information that was not provided although requested by Dr.
Geertz.
CSI has repeatedly protested how many documents and people it
made available to Dr. Geertz. Being intimately familiar with Scientology
files and data-gathering procedures, I can say that CSI has not turned over
large volumes of requested material and personnel to Dr. Geertz that are
germane to this case. For example, there are extensive files (including
computerized) that would enable a person to determine the effect of adverse
press. These are kept and maintained on weekly basis. I personally know of
them for I have worked with and have seen these files. They have been kept
by Scientology for decades. These were not provided to Dr. Geertz. Nor
were other material that would have been collected on Dr. Geertz. such as
reports from private investigators, credit checks, all standard actions in
Scientology proceedings. Nor has CSI supplied material regarding their
investigation of Fishman's role in Scientology even though CSI's corporate
secretary Lynn Farny said he had seen and reviewed such material.
Nor has CSI supplied those personnel that would know most about
the truth or falsity of the facts in question in the Time magazine article.
Those people are Miscavige. Yager, Willhere and Mitoff, Epstein, Spurlock
and Starkey would know about Fishman's financial roles and Scientology
financial scams.)
IT IS ROUTINE TO ALTER SCIENTOLOGY
RECORDS AND FILES TO AVOID THE AUTHORITIES
As early as 1971, I was introduced to the practice of altering
Scientology records and files to thwart the authorities. This occurred when I
worked as the Temporary Assistant Guardian in San Francisco. Under me
was the Intelligence Bureau which was where Scientology was running its
spies and agents. One day I received an order from the Guardian's Office
United States (in Los Angeles) and was told to do a "clean-up" on any
reference to Marsha Williams because she was going to become staff of the
Intelligence Bureau in Los Angeles and possibly become an agent. What a
"clean-up" meant was that I was to find and remove any reference to her
anywhere in the San Francisco organization, where she had served, so there
would be no record of her in the organization. This was to thwart any
investigation of her or any trace on her by any authorities. I removed her
name from various records and files and sent the material to Los Angeles. I
later saw her in Los Angeles, as Intelligence staff, when I joined the US
Guardian's Office.
After the Federal Bureau of Investigation ("FBI") raided threeChurch of Scientology locations in 1977 to obtain documentation regarding
violations of the law, I worked with scores of other people to quickly
destroy any further evidence to keep it from falling into the hands of the
authorities. We were all verbally briefed how we had to go through files and
look for (1) any documents showing illegal activity and (2) any documents
to show that Hubbard was running Scientology (which he was but we were
trying to tell the authorities that he wasn't) and to destroy these documents.
In this campaign, the amount of documents that were destroyed were in
cardboard boxes stacked down halls. I do not know the page count but the
stack was about four feet wide, four feet high and about 60 feet long. And
this was from the location with the least amount of files. And there was no
doubt that we were doing this to destroy incriminating evidence. In fact,
several of us questioned this and were told to shut up and keep shredding
paper.
Circa 1983 when I worked at Hubbard's "literary agency" Author
Services, Inc., we were told there was a threat of an IRS raid on us and we
had to move documents. These went to another floor in the building where
we kept watch on them. There were about 50 bankers boxes of files that we
were keeping hidden from the authorities who were also serving subpoenas
to get records. Our task was to keep these other records secret. The files
were kept on that other floor for a couple of months.
This last instance is cited in particular to anticipate the reply of CSI
that the earlier examples were from an earlier regime that has been
overthrown. This is not true. In fact, the 1983 instance at ASI was
conducted by Miscavige who currently runs all of Scientology.
Thus the cleaning up of files to remove embarrassing or
incriminating material was routine and the non-appearance of Fishman's
name in certain groups is not indicative that he was not there.
CONTRARY TO THEIR DECLARATIONS,
CSI IS STILL USING THE ORIGINAL
GUARDIAN OFFICE STAFF
On a number of occasions, CSI has tried to disassociate itself from
the Guardian's Office that was raided by the FBI in 1977 and the Guardian
Office staff that went to jail, including Hubbard's wife, Mary Sue. It has
been CSI's contention that those associated with the crimes were purged.
This is not true.
The precise target of the FBI raid was the Snow White Program in
the Intelligence Bureau of the Guardian's Office. In 1989 the Snow White
Program was still active and one of its key staff was Grace Marie Haddy.
(See "Non-Existence Formula" dated 12/16/89 from Show White Pgms
Chief OSA US attached as Exhibit W) Grace Marie Haddy was a key
executive of the intelligence bureau and was privy to all communications
detailing the illegalities that subsequently sent the 11 executives to jail.
Handling CSI's case before this court is Kendrick Moxon ("Moxon")who was named as an unindicted co-conspirator when Mary Sue and the
others were indicted. Moxon was head of the Guardian Office Legal Bureau
in Washington, D.C. (See the "Stipulation of Evidence" attached to the
declaration of Vicki Aznaran, also filed 3/9/94 which includes a description
of Moxon's role in obstructing the investigation of the Department of
Justice.)
THIS CASE DOES NOT CONCERN
PLAINTIFF CSI
With over 20 years as a staff member in various Scientology entities,
both inside the Church of Scientology and in secular Scientology groups, I
can say with confidence that after reading the article in Time magazine and
the section for which Fishman and Dr. Geertz are being sued, I did not
think of CSI. Although I was well aware that CSI existed, it would have
been one of the last entities that would have come to mind. The article and
the sections in question are about Scientology as a subject and practice,
including the secular side of Scientologv. (The secular side of Scientology is
a multi-million dollar activity that has been kept hidden from the court. This
side promotes that Hubbard's writings - the same ones used in this case as
scriptures" are non-religious and "secular" and can be used in commercial
enterprises to help the business or a client. This is the Jekyll & Hyde
syndrome of Scientology, how they pretend to be a religion or a business,
according to the potential customer or situation.)
CSI'S CASE DOES NOT HAVE MERIT
FOR SEVERAL COGENT REASONS
Besides the fact that the Time article is not about CSI, there are
additional reasons why CSI's case has no merit. Some of these have already
been covered. (1) CSI refused to comply with discovery. (2) CSI never
intended to complete discovery because the suit was brought solely for
malicious reasons (to punish a member of a group Scientology has promised
to destroy, according to the Fair Game Doctrine.) (3) CSI is not the true
plaintiff. Being familiar with the ecclesiastical and corporate structures of
Scientology, I know by reading the passages at issue that Dr. Geertz was not
speaking of Plaintiff Church of Scientology International ("CSI"). Howeverthat is one of the roles that CSI has, to intervene, because it has the
manpower to wage lawsuits and to carry out the Fair Game Doctrine via the
Office of Special Affairs. (4) There is a likelihood that what Dr. Geertz said
is true, that Fishman was told to "end cycle" and to kill Dr. Geertz. CSI's
refusal to provide information and deponents has prevented an adequate
defense. But based on my 20 years in Scientology and seeing the level of
criminality that was able to permeate the organization - always kept from
the view of all but a select few - I cannot discount his allegations. (5) Even
if Defendants statements are false, CSI was not hurt. By their own
admission. CSI has no members that can be wronged. Additionally by
Scientology's own writings, no press ever hurts them, especially anything in
Time magazine. To the contrary, they have claimed that they grow in the
face of such adverse publicity. Thus CSI must either admit that they were
not harmed or admit that their Hubbard's claims of Scientology's
infallibility are false.
The simple truth of this case boils down to this: the suit was brought
under the "anti-psych" Fair Came doctrine by an entity without members
and without standing (CSI) because it has an anti-"psych" arm whose
function is to take over the field of mental health and destroy Hubbard's
enemies. I know because I worked at that echelon for nearly 20 years and
know it and the tactics intimately.
I declare under penalty of perjury under the laws of the United States of
America and the State of California that the foregoing is true and
correct.
Executed in Los Angeles,
California, this 9th day
Robert Vaughn Young
of March, 1994.