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JANUARY 03, 1994

I, Stacy Young, declare as follows:

1. I have been retained by Dr. Geertz's counsel, Graham Berry, as an expert consultant in this litigation and have been designated as one of Dr. Geertz's experts to testify at trial herein. The statements herein are of my personal knowledge or reasonably based on information and belief, and if called upon as a witness, I can testify competently thereto.
2. This declaration is submitted in connection with defendant Dr. Uwe Geertz's opposition to plaintiffs' motions for protective order regarding the taking of certain depositions in this litigation.

3. I was a member of the Church of Scientology for more than 14 years, from January 1975 until July 1989. From October 1975 until I left, I was a member of the Sea Organization, the most dedicated group of Scientologists in the entire organization. I spent most of my time from 1978 until 1989 in a highly confidential section of Scientology management which was known as the Guardian Office until 1982 and is today called the Office of Special Affairs. This section of Scientology is responsible for dealing with all external public relations, all matters relating to civil litigation or criminal matters, all governmental relations such as the IRS, and all critics of Scientology.

4. During my tenure in Scientology I acquired extensive knowledge of the Scientology counseling methods known as auditing, the methods of training staff members and public Scientologists, the methods of dealing with non-Scientologists (known as "external publics") and former Scientologists and/or critics, known as enemies or suppressives, and the administrative and management procedures of the organization.

5. My first experience with Scientology was at the Mission of Atlanta, Georgia, where I attended a series of introductory lectures about the mind. I received some basic auditing and took several basic courses.

6. I joined the Sea Organization ("Sea Org," or "SO") at the Advanced Organization in Los Angeles ("AOLA") in October 1975. To become a Sea Org or SO member one must sign a billion-year contract to confirm one's dedication to Scientology and "clearing the planet" (see explanation below).

7. All staff members involved in delivering the confidential upper levels of Scientology auditing and all staff members involved in Scientology management must be members of the Sea Org. They live communally and are under the absolute authority of the Sea Org command lines 24 hours a day. I was paid $24 per week - when I was paid.

8. The Sea Org has total authority over all Scientology and Scientology-related organizations, including all nonprofit and for-profit corporations. It cuts across all corporate boundaries and can take over any Scientology organization without notice. Any Scientologist who refuses to submit to Sea Org authority is declared a"suppressive person" and expelled from Scientology.

9. All Scientologists consider that Scientology is the only way for Mankind to go free. For a Scientologist this means getting "exterior" to the physical body ("exteriorization") and, indeed, to the entire physical universe, returning to Man's "native state" as a "static," which is "without mass, without wave-length, without time, and actually without position." In fact, L. Ron Hubbard created a new category of humanity for those who go through all the levels of Scientology processing; they transcend the state of Homo Sapiens and become what he called Homo Novis (similar to Nietsche's Superman). Scientologists expect that once they have attained this state they will be free to travel throughout the galaxies, freeing others who are in the trap of the physical universe. What will happen after that is somewhat vague, but no one has attained this state as yet anyway, so it doesn't really matter.

10. The route out of the physical universe trap is called "The Bridge to Total Freedom." Every Scientologist is at one stage or another on this Bridge, and they are expected to get everyone else on this Bridge as well. The idea is for everyone on Earth to get exterior to the physical universe. The only people who aren't included are "suppressives," meaning those who have been critical of Scientology. Suppressives don't deserve to go free. Hubbard did not consider that suppressives should be allowed to go free.

11. The Bridge is composed of a series of auditing processes, an auditing process being a set of specific questions and commands. The person who asks these questions and delivers these commands is called the "auditor." The person who answers the questions and carries out the commands is the "preclear," since the first major milestone on the Bridge is called "going Clear." After one attests to the state of Clear, one moves on to the confidential upper levels of auditing known as the "Operating Thetan" or "OT levels" ("thetan" being Hubbard's term for the person without his or her body).

12. At the level of OT 3, one is allowed access to handwritten notes by Hubbard which detail a terrible disaster that happened in this sector of the universe 75 million years ago. The head of the Galactic Fedgration, whose name was Xenu, solved a massive overpopulation problem by rounding up billions upon billions of people and transporting them in blocks of ice to several volcanoes on Earth, which was known as Teegeeack at the time. They were dumped near the volcanoes and subjected to H-bomb explosions. At the same time, they were subjected to a series of images which were electronically driven, or "implanted," into their minds. After the "implant" was completed, these disembodied beings were transported to Hawaii and Las Palmas where they were packaged up into "clusters." Attached hereto as exhibit "I" is a COPY of the OT 3 materials.

13. According to Hubbard, the OT3 implant is rigged to kill anyone who finds out about it before they have received the lower levels of Scientology processing. Needless to say, it is a major revelation to discover that one is covered from head to foot with these disembodied beings, called "body thetans" or "BTs" in Scientology. One has literally millions, or even billions of these BTs, and they have to be audited on very precise processes to get them to wake up and disengage themselves (or "blow") from the person's body. The idea is that once all of these BTs have been gotten rid of, one will be able to exteriorize from the body at will. These BTs can cause illness and even insanity if they become upset, so it is important to get rid of them as quickly as possible and to make sure one has done a very thorough job of it.

14. I was a staff member at the Advanced Organization of Los Angeles ("AOLA") from October 1975 through December 1978. AOLA is one of a handful of organizations around the world where people can go to receive the confidential upper levels of Scientology processing. I audited hundreds of hours on public preclears as well as staff members to prepare them for their upper levels, or OT levels. (When a person begins their OT levels they no longer have an auditor. They graduate to what is called "solo auditing," a process in which they audit their own disembodied beings, called body thetans or BTs. I also did many security checks on staff members. A security check is a method of inducing a person to confess to his or her crimes, particularly crimes against Scientology.

15. In 1977 I was posted as Interne Supervisor at AOLA. In this capacity I supervised auditors-in-training, known as internes, to certify them as qualified professional auditors. To perform this function I had to understand auditing procedures precisely, from the most basic processes to the advanced processes and procedures of Class 6 and Class 8, which are advanced levels of expertise, so that I could recognize whether or not the internes were conducting themselves as proper auditors.

16. As a result of my experiences at AOLA I acquired a high level of expertise as a "tech terminal," meaning one who is knowledgeable about the technical application of Scientology auditing and training methods.

17. at the end of 1977 I transferred to the United States Guardian's Office ("USGO") in Los Angeles. I was a staff member in the USGO from January 1978 through January 1982. The Guardian's office was the part of Scientology that handled Public Relations, Intelligence and Legal matters for Scientology.
18. Because of my technical background, I was posted as the Organizing Officer ("Org Officer")
for the Public Relations Bureau and, later, as the Org Officer for the entire Guardian's Office. As the Org Officer my Eunctions included the handling of all personnel and organizational matters, such as correcting a staff member who made mistakes, taking care of staff members who were sick or upset or in trouble, recruiting new people for staff, and promoting or demoting staff members as needed. I was also responsible for the establishment and proper administration of all the Guardian's Office personnel throughout the United States. Because the Guardian's Office oversaw certain aspects of the administration of all other Scientology organizations, I became very familiar with the overall structure of Scientology and how the various organizations interact with each other and with the outside world.

19. In early 1982 I was assigned to a unit known as Special Project as a Public Relations Assistant under my husband, Robert Vaughn Young. In this position I became familiar with the L. Ron Hubbard archives material, which was the complete collection of all of Hubbard's personal papers, including diaries, letters, and notes that he had kept from a very early age.
20. Several months later Special Project became what is now Author Services, Inc, a for-profit
company whose ostensible purpose was to be L. Ron Hubbard's literary agency. I was taken out of public relations and made the Organizing Officer for ASI in April 1982. In this position I worked directly for David Miscavige, who was Chairman of the Board of AS1 ("COB ASI"), to carry out his orders concerning the staff of ASI.

21. David Miscavige, known as DM, has been the head of Scientology since 1981. His loyalty to L. Ron Hubbard and Scientology is absolute, and he is utterly ruthless about maintaining his power. He moved the seat of power from ASI to the (RTC) in 1987, during a period of time when the IRS was investigating ASI's ties to the nonprofit corporations of Scientology. At that point he appointed himself Chairman of the Board of RTC, which is his current title.

22. Although ASI was established as a for-profit, non-religious corporation, in reality while DM was COB AS1 the staff of AS1 ran the entire Scientology network. ASI had complete control over the management of all Scientology orgs and missions, all Office of Special Affairs activities, all transfers of funds between church accounts and LRH accounts, every aspect of the life of anyone who was a Scientologist, whether staff or public. These powers were moved to RTC in 1987, as explained above.

23. Because of my experience in ASI I am familiar with the day-to-day activities and procedures of the highest levels of management of Scientology.

24. I have firsthand knowledge of the establishment of the corporate structure of Scientology as it now exists, having worked with the staff who were responsible for creating it. The purpose of this activity was to create an impenetrable, legally defensible network of corporations such that neither the IRS nor any other legitimate agency of government could "pierce the corporate veil" of Scientology organizations, thereby freeing Scientology management to transfer funds between organizations without concern for the law.

25. I am also familiar with the absolute authority which the highest levels of Scientology management exercise over every aspect of Scientology and,Scientology-related organizations, whether "church" or "secular," and the ruthlessness with which any sign of disloyalty or disaffection is handled.

26. In September 1982 I was assigned to the Rehabilitation Project Force ("RPF") , the Scientology version of a prison camp. I was assigned to the RPF because I was openly critical of DM's coercive and degrading treatment of staff members. I was on the RPF in Los Angeles for eight months.

27. As a result of this experience I am familiar with the absolute control which the highest levels of Scientology management have over the behavior and thought processes of every Sea Org member . There is only one way for a good Sea Org member to behave and think, and any deviation from this is punished immediately and severely. In turn, it is the responsibility of all members of Sea Org management to bring about the same pattern of behavior and thought in all Scientologists under their authority, regardless of whether those under their authority are part of the "church" or the various "secular" arms of Scientology. This distinction means lothing within Scientology; it was created purely to facilitate dissemination of Scientology and to fend off Scientology's "enemies," such as the IRS.

28. From May 1983, when I was allowed off the RPF, until July !984 I was posted as Course Supervisor at the International training Organization (ITO) in Los Angeles. From this position I trained hundreds of fledgling Scientology executives from all over: he world on the administrative and management policies of L. Ron Hubbard known as the Organization Executive Course, or OEC. As a result of this experience I am very familiar with the administrative policy of Scientology and know that Hubbard formulated it to facilitate the establishing and organizing of his worldwide network of Scientology organizations.

29. In August 1984 I was transferred back to the PR Division of the Guardian's Office, which by that time had been renamed the Office Of Special Affairs. My primary functions were as a writer and editor for FREEDOM Magazine, a Scientology publication created to serve as a vehicle for attacking individuals and groups who were perceived as threats to Scientology. I also wrote articles for other Scientology publications.

30. As a result of my experience as a writer for these different Scientology publications, I am familiar with Scientology's practice of changing its story for whatever public it is trying to manipulate. Often I rewrote the same basic story for each publication, completely changing the wording and overall thrust of the story to appeal to the different publics that were going to read it.

31. As a writer in OSA I was also responsible for writing rebuttals of negative stories about Scientology that were published in various newspapers across the country. I was also assigned to write rebuttals of books that were published that were negative about Hubbard and Scientology. As a result of this work I became very familiar with the policies and practices of Scientology with regard to individuals and groups that criticize the organization. I have personal knowledge that the practices which were formerly called "Fair Game" continue to be employed, although the term "Fair Game" is no longer used. These tactics are laid out in many of the key policies that are studied and applied by staff of OSA.

32. In July 1989 my' husband and I left Scientology. We lived in San Diego from 1989 until August 1991, at which time we moved to Newport Beach. We are currently living in Corona del Mar, California.

33. As a result of my experiences in Scientology I am qualified to discuss the policies, procedures and practices of this organization, including the treatment Steven Fishman received at the hands of this organization.

34. I have read Steven Fishman's book, The Lonesome Squirrel, and I have reviewed his testimony up to his sentencing. I have viewed a 1981 videotape of Fishman under hypnosis by Dr. Uwe Geertz, and I have viewed a 1989 videotape of Fishman being interviewed by his attorney Mark Nurik and Dr. Richard Ofshe in Fishman's home in Florida. Based on the review of these materials and my knowledge and experience in Scientology, I do not believe there is any doubt that Steven Fishman was driven to a psychotic break (known in Scientology as "Type 3 PTS," a term which I will explain below) by Scientologists, either deliberately or through greed and gross negligence of his welfare.

35. It is utterly forbidden for anyone with a serious psychiatric background, including an extensive history of hypnosis such as Fishman had, to be allowed to have any Scientology processing at all. Attached herto as Exhibit "2" is a copy of Hubbard Communication policy letter entitled "Illegal PCs. Accemre of High Crime PL. I have been advised by Mr. Berry that it was well known by Scientology operatives that Fishman was not eligible for processing because of his history of therapy with Dr. Uwe Geertz; yet he was induced to buy more than $100,000 worth of Scientology books, written materials and prints, clearly being led to believe that he would be welcomed into the privileged circle of dedicated Scientologists.

36. Furthermore, he was also induced to purchase three E-meters (electro-psychometers), the device used in Scientology audinting. E-meters are not used for anything else but auditing, and they are not supposed to be sold to anyone without proof that they are in training as an auditor.

37. But in the Scientology world there is a thing called statistics, and Fishman was an unsuspecting victim of this system. Every single staff member in a Scientology organization has a statistic which measures his or her production. These statistics are reported every Thursday to International Management in CSI. For Scientology staff members, their lives virtually revolve around making sure their statistics are rising every week. Many things depend upon this. If their stats are down they may not be paid that week. They may not be allowed to spend any time with their spouse or children. They may not be allowed any time off at all, and since they already work as much as 14 to 18 hours a day, one day or even half a day off becomes very important, even if it is only enough time to do laundry. If their stats continue to go down over a period of time, they risk being assigned to the Rehabilitation Project Force or "RPF," which is a Scientology prison camp. Needless to say, people can become quite desperate under these circumstances, and they will do just about anything to get their statistics up.

38. Nowhere in Scientology is the push for statistics more frenzied than in the departments responsible for bringing money into the organization. Unfortunately Fishman appears to have been the unwitting victim of a feeding frenzy which involved at least nine different Scientology corporations. These people discovered that Fishman had money and that he was willing to give it to Scientology. They took his money even though they knew he would never be able to receive any benefit from Scientology auditing, even though they knew he could harm himself with the materials they were selling him. Indeed, it is clear that Fishman was overwhelmed by the Scientology materials he was given, to the point of an actual psychotic break.

39. To understand how this could have occurred it is necessary to explain briefly how Scientology processing works. In essence, the theory behind auditing is that by confronting painful incidents in the past one can free up mental energy that has been locked up in these painful memories. L. Ron Hubbard created many auditing processes which are supposed to help an individual achieve greater sanity. But he made it clear that the processes must be done in a precise way with no deviation. There are severe penalties for anyone who deviates from the standard procedures. Hubbard made it clear that it can be very harmful psychologically and even physically to deviate from these procedures.

40. Certain situations can cause a person to have trouble in auditing. The most serious thing that can hinder a person's progress up the "Bridge to Total Freedom" (as the exact series of auditing processes is known) is becoming a Potential Trouble Source, or PTS. A PTS is someone who is being suppressed in some way by another person or entity.

41. There are different types of PTSness. Some of these are listed in an October 27, 1964, policy by Hubbard known as "Policies on Physical Healing, Insanity and Troublesome Sources." Attached hereto as Exhibit "3" is a copy of Hubbard Cominication Office Policy letter entitled "Policies on Physical Healing, Insanity and Troublesome Sources". Ten types of PTSness are listed in this policy letter, each one of which has to do with types of people who have caused reporters, family members who are hostile to Scientology, etc. They are listed as Type A through Type J, thus the policy has been nicknamed the "A to J policy." When someone is labelled as being any of these types of PTS, he or she is barred from getting any Scientology processing (auditing) or training, because people who fall into these categories have historically caused trouble for the organization, either by bringing legal action against it or by giving negative information to the press.

42. Steve Fishman was labelled Type A, which is "persons intimately connected with persons (such as marital or familial ties) of known antagonism to mental or spiritual treatment or Scientology." He was also labelled Type C, which is "persons who have ever threatened to sue or embarrass or attack or who have publicly attacked Scientology or been a party to an attack and all their immediate families should never be accepted for processing". Fishman was labelled Type C because he had paid a large amount of money for a set of Hubbard's taped lectures which he had never received, and he had threatened to sue CSI after trying for months to get his money back. (In Scientology one is never supposed to step outside of the Scientology "justice system"; anyone who does so, such as by filing a police complaint or a civil suit, is immediately disqualified for Scientology services.)

43. Furthermore, because of his background of hypnosis, Fishman could never be eligible for Scientology services.

44. Despite the fact that he was declared PTS A and C, and that it was known he had an extensive history of hypnosis by a psychologist, thereby barring him permanently from Scientology auditing and training, Fishman was sold over $100,000 of Scientology materials, including a huge collection of tape recorded lectures by Hubbard (which are not supposed to be listened to until one reaches a certain level of Scientology training), packs of material that are only supposed to be seen by people in certain staff positions, and, what is most shocking, three E-meters, one of which was specifically designed for use by auditors on the confidential upper levels of auditing. It is specifically designed for use in solo auditing, which is auditing of oneself. It is clear from his videotaped interview that this is precisely what Fishman used it for.

45. This created an explosive situation, one which clearly could lead to a psychotic break in Fishman. Even as recently as September 1993, Ray Mithoff, Inspector General for Technology, the most senior Scientology technical expert in the world, supervised the auditing of a person in England who had had a psychotic break as a result of her experiences with Scientology. A CODY of Scientologv's report on this incident is attached hereto as exhibit

46. This person had a psychiatric history, and the mixing of psychiatric techniques with those of Scientology had caused the psychotic episode. So it was obviously known that Fishman risked a Type 3 psychotic break if he were allowed training or auditing, could yet he was sold thousands of dollars worth of materials anyway, including an E-meter with a solo auditing capacity permitting him to self audit. Thus, either intentionally or simply out of greed and negligence, Scientology created a situation in which Fishman would almost certainly suffer a psychotic break and become a Type 3 PTS, as explained below.

46. The types of PTSness described earlier, Types A through J, relate to different types of threat a person can pose to Scientology. There are also three types of PTSness, known as Type 1, Type 2 and Type 3, which relate to a person's own state of mind and physical health. A person will manifest PTSness through a range of conditions, all the way from a minor cold to a more serious illness (all illness is a sign of PTSness) to full-blown insanity. All PTSness is the result of being connected to one or more suppressive people, suppression being defined as "a harmful intention or action against which one cannot fight back." A COW of a Hubbard Comminications office Bulletina entitled "Seach and discovery" and describina these PTS tvoes is attached hereto as Exhibit "5".

47. Type 1 PTS means that the suppressive person is actively suppressing the person in present time. To handle this a person is interviewed by someone who helps them spot who is suppressing them, whereupon the illness (a cold or whatever) is supposed to vanish.

48. Type 2 PTS means that the person was connected to the suppressive person earlier, either in this lifetime or an earlier lifetime (it might have been 150 years ago, or 76 trillion years ago - whatever is real to the person). Someone in present time reminds the person of the actual suppressive person, and this is making the person sick. Curing Type 2 PTSness requires extensive auditing, usually on the PTS Rundown.

49. Type 3 PTS is the Scientology term for a fullblown psychotic episode. It was my experience in Scientology that when a person has a psychotic break they lose touch with the real world and begin to hallucinate or imagine conversations, events, people, and whole scenarios. Even after they recover they are never sure what part of the experience was real and what they imagined.

50. The subject of Type 3 PTS cases is one of the dark secrets of Scientology. No one is supposed to talk about it outside of Scientology, and it is treated with utmost security when someone becomes Type 3 PTS. The reason for this is obvious: people are not supposed to be driven insane by Scientology, so it would be a public relations nightmare to try to explain it. But more importantly, the treatment of people who have psychotic breaks in Scientology is a clear abuse of the mental health laws, and if such treatment were brought to the attention of mental health officials there is little doubt that Scientology would be subjected to public scrutiny for its practices in this area.

51. A number of things can trigger a psychotic break, or cause a person to "go Type 3," as they say in Scientology. In his first book, Dianetics: The Modern Science of Mental Health, Hubbard's term for "mental voices" was "demon circuits." Later he made it clear that what ils actually occurring when someone has a psychotic break or "goes Type 3" is that all of his body thetans or BTs have become upset and are all talking to him at once.

52. In Fishman's case, it is unclear whether he was driven to this state of mind purely through fraudulent irresponsibility and negligence, or whether it was done more deliberately, as described in the following Hubbard lectures.

53. In a number of taped lectures Hubbard said that a person could be driven insane through the deliberate application of what he called Black Dianetics. This is his term for a method in which the normally therapeutic methods of Dianetics and Scientology are reversed and the person is deliberately driven mad.

54. In a September 17, 1951, tape called "Some Notes on Black Dianetics," Hubbard stated:
"A person can drive himself quite mad with Dianetics without any trouble. What you have
concentrated on in your study of Dianetics has been the process of making people well. That is
your emphasis line. But don't think for a moment that that is any more than half of it.
There is as much data on how to make people insane, uncomfortable, sick or dead as there is
on how to make them well."
A copy of the transcript of this taped lecture is attached hereto as exhibit 6.

55. It is possible that such techniques were used on Fishman, first to induce him to break the law for Scientology and then to try to get him to commit suicide, leaving a note absolving the church of all responsibility. Having failed to do this, church operatives could have deliberately driven him to the point of a psychotic break.

56. Hubbard explained how to do it in the following passage from "Some Notes on Black Dianetics": "With Black Dianetics, you could tailor make any kind of insanity you wanted to. The person might not manifest this the next day, maybe not the next week or maybe not for thirty days. Maybe three months later he is walking down the street and feeling a little bit tired when somebody honks an auto horn just right or something of the sort, and all of a sudden he goes crazy, and there he is - insane!"

57. In that same lecture Hubbard provided a blueprint for getting someone incarcerated, just as Fishman was, without anyone ever finding out that the person was set up: "We find that nobody can protest an implanted engram [meaning a hypnotic command given to a person such as was portrayed in "The Manchurian Candidate"] except the person into whom it has been implanted. He is the only one who can protest this. He is the only one who can sign out a warrant. Even if he goes insane, nobody can sign out a warrant. So he could say, 'Well, it was Bill and I know it was Bill and I saw Bill and Bill has taunted me with it since,' and so forth, but if he has been pronounced insane... he ha's lost his civil rights and he can't issue a warrant. In other words, this is legal murder, legal punishment and so forth. Because the law does not know anything about this, no laws exist to prevent it or inhibit it."

58. In another tape called "The Complete Auditor, Part I," delivered on June 28, 1951, Hubbard said:
"Any one of us could take a human being and, with malice aforethought, drive him stark, staring crazy with greater efficiency than even psychiatry does. What would you do to him? You would just reverse all the things that you know would help him: . . . slug him with some drugs, hit him in the face, take a hypodermic needle to him so that you give him very painful but unobservable somatics.... Then when he comes out of it say this had never happened to him, feed all the content back to him again by telling him about other people's engrams or even his own, convince him that he does not really know what his reality is and convince him that you are his friend. A person can't take this; he would spin. That would be an efficient job, but that could be done on a person who was pretty doggone sane!"
A Copy of the transcript of this taped lecture is attached hereto as exhibit "7".

59. In still another tape, called "Outline of Therapy," Hubbard stated: "Out of Scientology you could formulate a very fine type of thought warfare. Works much better than an atom bomb. An atom bomb just kills people, but you could take thought warfare and you could enslave them utterly. You could make complete slaves out of them."
A copy of the transcipt of this taped lecture is attached hereto as exhibit 8.

60. All of these instructions just quoted are part of the Scientology "scriptures." Every word Hubbard ever uttered is considered to be sacred doctrine, and Hubbard's instructions are taken quite literally by Scientologists. It would be entirely possible for Scientology operatives to take these instructions from Hubbard and use them to manipulate Fishman for their own ends.

61. Hubbard himself ordered that "reverse processes" (or Black Dianetics) be run on people he felt were particularly dangerous to Scientology. In a 1968 issue he declared several people fair game (meaning they could be lied to, tricked or destroyed), and instructed that they be run on reverse processes if they ever came into an org. Additionally. he ordered that "Any Sea Org member contacting any of them is to use Auditing Process R2-45." This was a reference to the use of a .45 semi-automatic pistol. Hubbard defined R2-45 as a very fast way of getting someone exterior to their body. A copy of this 'declare' is attached hereto as exhibit 9 (see item 7).

62. Even if no one deliberately set out to drive Fishman psychotic, selling him materials that would completely overwhelm him with incomprehensible information and then putting an E-meter in his hands was nothing short of criminal negligence. There is little doubt that Fishman used his E- meters to "audit" himself, an action that could easily drive him into a psychotic break.

63. In the tape "Some Notes on Black Dianetics," Hubbard himself described the dangers of self-auditing:" . . . in Dianetics you are playing around with highly explosive material. I would say that a person using Dianetics in certain ways might much more happily juggle two or three hand grenades with their pins pulled. For instance, take some of these people who run around self-auditing: why don't they just go get a gun? That is much simpler and quicker."

64. When I was in Scientology I was assigned to keep watch over a young girl in her early twenties who became Type 3 PTS after being forced to sever all communication with her family, because they were upset about her involvement in Scientology. This incident occurred in Hemet, California, at the international headquarters of Scientology.
One day this girl approached me and began to babble, making no sense at all. Recognizing the symptoms of someone who was going, Type 3, I immediately alerted one of the security guards so that she could be put under watch. Sure enough, within an hour she was in a full blown psychotic break. She did not know who she was or where she was and she began to get violent. She lost touch completely with the real world and began to hallucinate, imagining conversations, events, people, and whole scenarios.

65. L. Ron Hubbard wrote a series of issues detailing what to do when someone "goes Type 3." These issues comprise what is called the Introspection Rundown, a rundown being a series of specific actions to take to achieve a specific result in Scientology processing. Hubbard felt that the Introspection Rundown was a major breakthrough in the handling of psychosis, and that people in mental institutions could be cured by following these steps. A copy of the introsoection Rundonw is attached hereto as exhibit 10.

66. The first step is to isolate the person completely from everyone except the people assigned to watch over the person. This is called "Isolation Watch." I was assigned to watch this girl, so I studied the issues to ensure I would handle her correctly. We were not to say a word around her. She was to have complete silence to allow her to calm down (to allow her body thetans to go back to sleep, although she could not be told about this, since she was not up to that level in her processing). This went on for many days as she was in a serious psychotic incident.

67. She had no idea who she was. One moment she would think she was a butterfly: the next minute she would think she was Hubbard's daughter, Diana Hubbard. Then she would think she was a dog, and she would bark and growl. We had to be very careful to watch her so that she would not try to kill herself, and we also had to be sure she did not get violent and hurt us or become destructive of property.

68. She was never referred to any mental health practitioner, because Scientologists believe that all psychiatrists and psychotherapists are completely evil. Hubbard preached the evils of psychiatry so thoroughly that no one in Scientology would ever consider letting a mental health practitioner examine anyone, even someone who is in the middle of a psychotic episode. See several examples of Hubbard's writings on psychiatry attached hereto as Exhibit 11. This girl was not even given anything to calm her down except a mixture of calcium and magnesium which was supposed to relax her and let her sleep. It did not have that effect; this girl could hardly sleep at all and soon became exhausted, which simply compounded the problem.

69. After several weeks of this, the girl finally came out of the psychotic episode and was immediately sent back to her family to avoid a negative public relations situation or, possibly, a lawsuit.

70. A more serious incident occurred when a staff member with extremely confidential knowledge of the legal and corporate manueverings of Scientology became Type 3 PTS. Her name was Cat Morrow and she had been part of a project called MCSS, for Mission Corporate Categor Sort-outthat was supposed to create a corporate structure to protect Hubbard from civil or criminal action. Cat had information about inurement to Hubbard and about a conspiracy within the church to cover it up that would be disastrous if it were ever leaked. So when she had a psychotic break it was of the utmost importance that the situation be kept quiet.

71. Cat was taken to the home of a wealthy Scientologist outside of Los Angeles. The house was surrounded with woods and there were no other houses in sight. There Cat was kept under 24 hour watch, known as "Isolation Watch" because the person is isolated from everyone except those on the "watch." Although I was not assigned to watch her, I was told that Cat became extremely violent on several occasions, that she tried to jump through a plate glass window, that she repeatedly said he wanted to kill herself, and that she had no idea who she was or what she was doing. This went on for several months.

72. I was told that when Cat came out of the psychotic break she was audited on the Introspection Rundown. This is a series of questions and procedures designed to get the person to stop introspecting, based on Hubbard's belief that this would cure the psychosis. On someone who is OT3, as Cat was, the Introspection Rundown is audited on the body thetans that have gone out of control and caused the psychotic break. The theory is that once these body thetans are disengaged from the person's body, the person will be able to get back in control of his or her own mind again.

73. Maggie Butterworth, David Butterworth's wife, was usually assigned to supervise any Scientologist in Los Angeles that had a psychotic break, and I believe that she was in charge of Cat Morrow, in close liaison with Sandi Wilhere, a highly trained case supervisor in CSI who is one of the most senior technical experts in Scientology.

74. Cat Morrow's case was particularly sensitive not only because of the information that Cat had about the church's legal affairs but also because she was married to Jim Morrow, one of the key people involved in dealing with the IRS. Cat's psychosis could not be allowed to compromise Jim's position, so her situation required the highest security. Normally a staff member who goes Type 3 is routed off staff or sent to the RPF after coming out of the psychotic episode, but because Cat had dealt with such sensitive material she was quietly reassigned to a low security department where people could keep an eye on her and make sure she remained loyal to Scientology.

75. A woman named Dorothy Geary was driven into a psychotic episode under circumstances very similar to Steven Fishman's in that she and her husband were coerced into giving Scientology a tremendous amount of money for services they would never receive. Her husband Robert, a dentist in Ohio, attended a seminar given by Sterling Management Systems, which he later discovered was a front for Scientology. Robert and Dorothy were both coerced into buying Scientology training and processing after a Scientology "chaplain" orchestrated a breach between them which threatened their marriage. Dorothy was then coerced into going to San Francisco for processing, while her husband flew back to Ohio to continue his dental practice.

76. While Dorothy was in San Francisco she was induced to buy nearly $100,000 worth of Scientology materials and services. She was so overwhelmed from the processing she received and the "hard sell" she experienced at the hands of Scientology salesman that after approximately one month she had a psychotic break. She did not know where she was and was completely out of her mind. Her husband helped her to get home, but then two Scientologists came to live at the Gearys' house to try to bring Dorothy out of the psychotic episode. However, the only "treatment" they provided consisted of taking Dorothy for long walks.

77. Finally they convinced Robert that Dorothy needed to fly back to San Francisco. Upon arriving in San Francisco, Dorothy was taken to a "mountain retreat," where no one else would see what was taking place. Dorothy was kept there for two weeks, while her husband had no idea where she was. Scientologists were trying to induce Robert to buy more auditing while Dorothy was held in San Francisco.

78. Dorothy had been induced to buy boxes and boxes of Scientology books and materials, all of which had been shipped to their home in Ohio after she paid for them with credit cards. When Robert opened the boxes and read some of the more advanced Scientology materials, he realized what his wife had been subjected to and called his family doctor for advice. His doctor gave a probable diagnosis of an acute psychotic episode caused by trauma.

79. By the time the Gearys' attorney helped them both to disentangle themselves, they had given Scientology close to $180,000. As Robert Geary described it, "This was money we obviously could not afford to spend and without extreme undue influence there is absolutely no way we would have ever spent such sums. I have read a considerable amount about mind control and now realize that my wife and I were under mind control." A copy of the declaration of Robert Gearv D.D.S. executed September 5, 1993 is attached hereto as exhibit 12.

80. There are certain people within the Church of Scientology, particularly RTC and CSI, who have knowledge of many other cases of Scientologists having psychotic, Type 3 PTS episodes. These people include the following: Ray Mithoff, whose title was Inspector General for Technology in RTC when I left in 1989, although I have been told that he may now have the title of Senior Case Supervisor International in CSI; Gelda Mithoff, a highly trained auditor who has dealt directly with or supervised a number of "Type 3 handlings"; Greg Wilhere, whose title was Inspector General in RTC in 1989 and who is a highly trained auditor; Sandi Wilhere, a highly trained auditor and case supervisor in CSI; and, of course, David Miscavige (DM), who supervises virtually every aspect of Scientology, particularly anything that might threaten the public image of the church, such as Scientologists who have Type 3 psychotic breaks.

81. The above-named individuals would be able to provide full details of the symptoms and manifestations of Type 3 PTSness and would be able to verify that Steven Fishman would never have qualified for Scientology processing so should never have been allowed access to Scientology materials or E-meters, certainly not a solo meter. They can also verify that all of the individuals who sold these materials to Fishman did so despite the fact that Fishman had already been declared ineligible for Scientology processing. The only question that remains to be answered is whether Fishman was driven to a psychotic break deliberately, or whether it was done simply out of greed and blatant disregard for his well-being.

I declare under penalty of perjury under the laws of the United States and California that the foregoing is true and correct.

Executed this 3rd day of January, 1994, at Los Angeles, California.

Stacy Young