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MARCH 09, 1994


I, Stacy Brooks Young, declare as follows:

1 . I am over the age of 18 years.

2 . I have been retained as an expert consultant and expert
witness by Dr. Uwe Geertz's counsel in the case captioned Church
of Scientoloqy International v. Steven Fishman and Uwe Geertz,
#CV-6426-HLH (TX) currently pending for purposes of hearing the
accompanying motion in the United States District Court, Central
District of California. The statements herein are of my own
personal knowledge and if called upon as a witness, I can testify
competently thereto.

3 . 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.

4 . As a result of my nearly 15 years in Scientology, I am
qualified to discuss the policies, procedures and practices of
Scientology, including the issue of "of and concerning,"
plaintiff CSI's assertion that it moved to dismiss this case
because of "harassment" by Dr. Geertz's counsel, Scientoiogy's
hatred of psychology, Scientology's practice of harassing its
critics, the treatment Steven Fishman received at the hands of
this organization, and the fact that Miscavige and his
lieutenants are managing agents of CSI.

My Extensive Historv in the Upper Echelons of Scientology
Manaqement Qualify Me as an Expert.

5 . I was a member of the Church of Scientology for nearly
15 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.

6. 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"), former Scientologists and/or
critics, known as enemies or suppressives, and the administrative
and management procedures of the organization.

7. 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.

8. 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).

9. 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.

10. 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.

11. 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. 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

12. The route out of the physical universe trap is called
"The Bridge to Total Freedom.11 Every Scientologist is at one
stage or another on this Bridge, and they are expected to get
everyone else moving 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.

13. 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 ltpreclear,'t
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).

14. 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 Federation, 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 llimplantW was
completed, these disembodied beings were transported to Hawaii
and Las Palmas where they were packaged up into "clusters."
Attached hereto as Exhibit 1 is a copy of the OT 3 materials.

15. 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 "BT's" 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. (See Exhibit 2, "What the Church of Scientology
Doesn't Want You to Know, It by Jeff Jacobsen and Robert P.J. Day,
and "The Total Freedom Trip," by Jon Atack, for more information
about the practices of Scientology.)

16. 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 ttsolo auditing," a process in which they audit their own
BTs.) I also did many security checks on staff members. A
security check is a method of inducing a person to confess to
crimes, particularly crimes against Scientology.

17. 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

18. 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.

19. 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.

20. 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 functions 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.

21. 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.

22. Several months later Special Project became what is now
Author Services, Inc. ("ASI"), 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 AS1 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

23. 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 AS1 to
the Religious Technology Center (RTC) in 1987, because it was
more defensible to run Scientology from a non-profit corporation
than from a for-profit corporation. At that point he appointed
himself Chairman of the Board of RTC ("COB RTC"), which is his
current title.

24. Although AS1 was established as a for-profit,
non-religious corporation, in reality while DM was COB ASI the
staff of AS1 ran the entire Scientology network. AS1 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.

25. 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.

26. 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.

27. 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.

28. 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.

29. 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 llchurchlq or the various "secular" arms of
Scientology. This distinction means nothing within Scientology;
it was created purely to facilitate dissemination of Scientology
and to fend off Scientology's V*enemies,lV such as the IRS.

30. From May 1983, when I was allowed off the RPF, until
July 1984 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 the 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.

31. 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

32. 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.

33. 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.

34. 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 de1
Mar, California, which is part of Newport Beach.

CSI Had no Standing to File This Case.

35. As described above, I spent nearly 13 years at the
highest echelons of Scientology management. My experience
includes substantial time in the Guardian's Office("GO"), its
succesor, the Office of Special Affairs ("OSA"), and also at
Author Services, Inc. ("ASI").

36. The GO/OSA branch of Scientology is responsible for
dealing with all matters outside the confines of the cult itself,
particularly public relations, litigation, gathering of
intelligence information on critics, carrying out harassment and
intimidation campaigns on critics, etc. The GOjOSA branch is
also responsible for maintaining the facade of corporate
integrity for the benefit of the courts, the Internal Revenue
Service ("IRS") and other governmental agencies.

37. AS1 is a for-profit corporation with offices in
Hollywood, California. AS1 manages all of L. Ron Hubbard's
("Hubbard") literary affairs. AS1 was first created in 1982. To
this day ASI accepts only proven members of the Sea Organization
("Sea Org"), an unincorporated organization which, under the
leadership of David Miscavige ("Miscavige"), actually runs all of

38. When AS1 was created, it managed the entire Scientology
empire. Miscavige arrogated the corporate title of Chairman of
the Board of ASI ("COB ASI") to himself.

39. In 1987, Miscavige moved his base of operations from
the AS1 facility in Hollywood to the high-security Scientology
compound near Hemet, California. In conjunction with this move,
Miscavige gave himself the new title of Chairman of the Board of
Religious Technology Center ("COB RTC"). In reality, Miscavige's
power is such that he can give himself whatever title he wants in
whatever corporation he chooses.

40. I know from my personal experience in GO/OSA and in AS1
that the corporate structure of Scientology is purely to obtain
legal and tax advantages. When Hubbard was still alive, the
complex corporate structure also served as a shield to protect
Hubbard from litigation and criminal charges. The corporate
integrity has certainly never been a matter of interest to anyone
outside of the GO/OSA or its senior echelons, such as RTC or ASI.
The corporate structure is not a matter of interest or concern
within the cult itself. Most Scientologists do not think of
Scientology in corporate terms at all. Instead of thinking of
plaintiff Church of Scientology International ("CSI") or any
other corporate entity when Scientology is mentioned,
Scientologists think of all the organizations which apply the
Hubbard Technology. Those organizations which apply the Hubbard
Technology include the geographically located Churches of
Scientology (e.g., Church of Scientology of San Francisco, Church
of Scientology of Miami, etc.), the geographically located
missions (e.g., Church of Scientology, Mission of Ft. Lauderdale,
etc.), the management organizations (e.g., RTC and CM0 Int), the
public self-improvement organizations which apply the Hubbard
Tech (e.g., WISE, Narconon, Sterling Management, etc.), the front
groups with political action agendas (e.g., Citizens Commission
for Human Rights, etc.), and the autonomous, extra-corporate
organizations for administrative and money management (e.g., Sea
Org and Flag Banking Office, etc.)

41. In short, even dedicated Scientologists would not think
of CSI when they read about "Scientology" or "Scientologists "
such as in the two paragraphs of the May 1991 Time Magazine
article which are the subject of this litigation. Additionally,
even a Scientologist would not think of CSI if he or she read
something about the "church" in material referring to
Scientology. Certainly no one outside of the Scientology cult
would think of CSI when reading about llScientology,"
"Scientologists," or the "church, " for the obvious reason that no
one outside of Scientology is likely to have heard of CSI as
distinct from Scientology as a general, generic amalgam of
organizations. Indeed, since CSI was created in late 1981 and
throughout my tenure at the upper echelons of Scientology, I
found that only a small circle of Scientologists, in OSA and the
senior management such as RTC and ASI, made reference to CSI on a
regular basis. These are the persons who need to maintain the
facade of corporate separateness to the outside world so as to
obtain various tax and litigation advantages.

42. For CSI to claim that the words "Scientology,"
"Scientologist" and/or "the church," as they appear in that
portion of the Time Magazine article which mentions Dr. Geertz
and Mr. Fishman, are "of and concerning I1 CSI is disingenuous in
the extreme. Based on my education, training and experience in
Scientology, the words 'lScientology,'l '*Scientologist" and "the
church" as they appear in the Time Magazine article can only be
reasonably understood to refer to Scientology generally,
generically and without particular reference to any one of the
hundreds of Scientology corporations that have been established
for various purposes over the years. The vast majority of the
corporate entities do not appear on the Scientology command
chart. The fact that separate corporations exist on paper has no
effect on the daily life of Scientologists or the operation of
Scientology. The corporate boundaries are ignored.

43. When I was a staff member in the GO, AS1 and later OSA,
it was common knowledge that the corporate structure was a
contrivance created purely because of the tactical benefits it
bestowed on Scientology for purposes of interfacing with the
"Wog" world. All Scientologists, particularly Sea Org members,
regard the Sea Org as an elite group of superior beings whose job
it is to get everyone else in the world into Scientology.
Meanwhile, Sea Org members and Scientologists generally refer
laughingly to unenlightened non-Scientologists as "wogs."

44. To get along with these wogs and keep them from
hindering the forward progress of Scientology, it is necessary to
create the appearance that Scientology operates by the same rules
as the rest of society. A large part of OSA's role is to
maintain this facade through public relations and legal actions.
In fact, Scientologists think it is quite funny when wogs accept
the facade as real. The arrogance of Scientology's senior
management, and the contempt in which it holds any court or other
wog body which falls for the mascarade is astounding.

45. The contempt became apparent to me in conversations I
had with other staff, in comments made by Miscavige, Norman
Starkey, Lyman Spurlock, Steve Marlowe, and other executives
during staff meetings, and in instructions I was given about how
to position certain agencies and individuals when I wrote stories
for Scientology propaganda publications, including FREEDOM

46. I was in the FREEDOM Magazine department of the public
relations division of OSA US during the trial of Wollersheim v.
Church of Scientoloqy of California, in 1985. At the time, OSA
US was still, for corporate purposes, part of the Church of
Scientology of California (tVCSCVV).

47. One afternoon, I was informed, along with the other
staff members of the FREEDOM office, that our office was to be
moved to another location across the street, outside the big blue
Scientology complex which used to be Cedars of Lebanon Hospital
at Sunset and Berendo in Hollywood, California. We were
instructed to move to an office on the second floor of a building
on Catalina Street. I was told that the FREEDOM office and the
Treasury office of OSA US were to move,out of the Scientology
Complex because it looked like Lawrence Wollersheim was going to
win his suit against CSC and the corporation had to be gutted of
all its assets before the decision was handed down. All that
would be left of CSC would be a shell consisting of a Treasury
office and the FREEDOM office. When Wollersheim tried to collect
from CSC, he would discover that there were no assets at all in

48. We did move our office to the building on Catalina.
The Treasury office also moved. I was told by the Treasury
Secretary, Rhea Smith, that all of the assets of CSC had been
taken out of the CSC accounts. The motto of OSA US during the
Wollersheim trial was "Not One Thin Dime," meaning Scientology
would never pay even a dime to Lawrence Wollersheim. The OSA US
Staff were briefed on the gutting of CSC at a staff meeting, and
all of the staff cheered because now Wollersheim couldn't get his
hands on any money even if he won his suit.

49. This gutting of CSC to hide assets from a litigant and
then cheering about it at a staff meeting is an example of the
contempt in which the Scientology Command holds the U.S. justice
system. The corporate structure of Scientology is created and
re-created depending upon the convenience of the moment, as
illustrated in the above example.

50. The idea that the remarks attributed to Fishman and
Geertz in the Time Magazine article upon which CSI's claims are
pruportedly based refer to CSI rather than to Scientology
generally is absurd. Inside the Scientology empire no one takes
the corporate structure seriously. The corporate structure is a
contrivance to enable Scientology to interface to its advantage
with the rlwogll world. This Court should not be fooled by the
corporate sleight of hand which was attempted in this case.
"Scientology, I1 lqScientologistll and "the church" refer to the
overall, generic empire of Scientology, not to CSI, and no one
even within Scientology would think of CSI when reading those
words, much less the general public.
It is CSI That is Harassincy, Not the Defendants
51. CSI asserted that this case must be dismissed to
protect several Scientology celebrities who were noticed for
brief depositions not to exceed two hours each. CSI claims that
these celebrities were served for the express purpose of
harassment and abuse. CSI asserted that it feared these
celebrities would be exposed to confidential upper level
materials if CSI allowed them to be deposed. CSI further asserted
that "CSI has seen its religious tenets and scriptures assailed;
it has been compelled to produce or offer for deposition the
religion's most senior ecclesiastical leaders so they can be
reviled; and it has endured a transparent campaign to harass CSI
into default." CSI cited this as its excuse to move to dismiss
this entire case.

52. Nothing could be further from the truth. The CSI managing
agents and the other Scientologists who have been deposed in
this case have been interrogated only about the use and misuse of
L. Ron Hubbard's technology ('*Tech") for secular purposes. The
fact that the same Tech is also used for so-called religious
purposes does not make inquiry about the Tech a reviling of the
Scientology belief system or its most senior members.

53. Even I, who spent many years helping to create this
kind of utterly hypocritical rhetoric for the Church of Scientology
I am stunned at this latest fantasy concocted by CSI.

54. Dr. Geertz's attorneys have never expressed in my
presence any intention whatsoever to bring up Scientology's
confidential upper level materials during the deposition of the
Scientology celebrities. I have been advising Graham Berry and
Gordon Calhoun, Dr. Geertz's attorneys, as an expert consultant
on Scientology Tech matters. I would know from the type of advice
and guidance they have sought from me whether they intended to
inquire about the "religioustt or llecclesiasticalV1 uses of the
Tech as opposed to the secular use of the Tech. Their inquiries
have been limited to secular uses of the Tech. Why should they
ask these people about Scientology's confidential upper level
materials? There would be no point in bringing up those
materials. For the Scientologists to assert a concern over this
is simply another example of their assuming that others will use
their own harassing tactics. In fact, I advised Dr. Geertz's
attorneys to depose the Scientology celebrities about the lack of
corporate boundaries in Scientology. Miscavige, COB RTC, insists
upon treating all the celebrities with kid gloves and personally
oversees their progress in Scientology, sending RTC, Cmo Int or
Gold specialists to take care of their needs regardless of any
supposed corporate structure.

55. What is astonishing to me is the incredible arrogance
of CSI in accusing Dr. Geertz and his counsel of exactly those
actions in which CSI regularly engages. It is not the defendants
Dr. Geertz and Mr. Fishman who have been conducting an all-out
campaign of harassment, assault and vilification; it is CSI that
has been doing so. Indeed, the leadership of CSI has no choice
but to do so. CSI's leadership is bound to do so by Scientology
doctrine. CSI's leadership would be acting heretically or
unorthodoxly if it did otherwise. Founder L. Ron Hubbard, whose
edicts on these subjects are V1sacred scripture" which must be
implemented without question or reservation, gave specific
instructions to harass and destroy anyone perceived as an enemy
of Scientology. There are many, many policy statements by
Hubbard, which bind all Scientologists, that go into this. What
follows are only a few examples.

CSI Is Bound by Its Own Scripture to Harass Its Critics

56. Hubbard wrote "The Scientologist: A Manual af Disseminatian
of Material" (attached as Exhibtit 3, see p. 157) in
1955. He gave the following instructions for dealing with anyone
who sought to compete with orthodox Scientology:
"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

57. Hubbard also urged Scientologists to employ private
detectives to investigate anyone who criticized Scientology. He
added, in language particularly apropos to this lawsuit:
. . . we should be very alert to sue for slander at the
slightest chance so as to discourage the public press
from mentioning Scientology."

58. In 1959 Hubbard published the "Manual of Justice" for
Scientology (attached as Exhibit 4). This document instructs
Scientologists as follows:

"People attack Scientology; I never forget it, always even the score....

"When we need somebody haunted we investigate.... When
we investigate we do so noisily always. And usually
investigation damps out the trouble even when we
discover no really pertinent facts. Remember that by
investigation alone we can curb pushes and crush
wildcat people and unethical 'Dianetics and
Scientology' organizations....
"Of twenty-one persons found attacking Dianetics and
Scientology... eighteen of them under investigation
were found to be members of the Communist Party or
criminals, usually both. The smell of police or private
detectives caused them to fly, to close down, to
confess. Hire [private detectives] and damn the cost
when you need to."

59. As author Jon Atack wrote in his well-researched book,
A Piece of Blue Sky: Dianetics, Scientoloqy and L. Ron Hubbard
"A mood was being created in which staff members would
become 'deployable agents,' as sociologist Roy Wallis
called Hubbard's henchman in his excellent study of
Scientology. After all, Hubbard never gave any
indication of the possibility that a complaint against
him or against Scientology could be justifiable. The
tactic of 'noisy investigation' originated in the
Manual, and came to mean harassment by defamation.
Hubbard certainly did not mind if the defamation was
grossly exaggerated, or even a total fabrication. If
you throw enough mud, some will stick. The Manual of
Justice suggests outright blackmail." (The section of
the book which contains this passage is attached as
Exhibit 5.)

60. In 1960 Hubbard wrote another policy called "The
Department of Government Affairs" (attached as Exhibit 6), which
stated, in part:
Only attacks resolve threats.
"In the face of danger from Govts or courts there are
only two errors one can make: (a) do nothing and (b)
defend. The right things to do with any threat are to
(1) Find out if we want to play the offered game or
not, (2) If not, derail the offered game with a feint
or attack upon the most vulnerable point which can be
disclosed in the enemy ranks, (3) Make enough threat or
clamor to cause the enemy to quail, (4) Don't try to
get any money out of it, (5) Make every attack by us
also sell Scientology and (6) Win. . . .
"The goal of the department is to bring the government
and hostile philosophies or societies into a state of
complete compliance with the goals of Scientology. This
is done by high level ability to control, and in its
absence, by low level ability to overwhelm. Introvert
such agencies. Control such agencies. Scientology is
the only game on Earth where everybody wins. There is
no overt in bringing good order."

61. In other words, only activities which promote the
expansion of Scientology or which attack and injure its critics
are good or ethical by Scientology standards. Any attack or
injury to the enemies of Scientology is justified. The end,
universal acceptance of the Scientology belief system, justifies
the means, attacking or injuring enemies of Scientology,
particularly psychiatrists, psychologists and those who have
criticized Scientology.

62. In another policy statement called "Attacks on
Scientology (Additional Policy Letter)" (attached as Exhibit 7)
Hubbard instructed Scientologists to:
"(1) Spot who is attacking us."
"(2) Start investigating them promptly for FELONIES or
worse using our own professionals, not outside
"(3) Double curve our reply by saying we welcome an
investigation of them."
"(4) Start feeding lurid blood, sex, crime actual
evidence [sic] on the attackers to the press."

63. Each of the documents authored by Hubbard are still
part of the Scientology doctrine today. In fact, these documents,
along with many others, comprise the heart and soul of the
activities of the Office of Special Affairs (formerly the
Guardian's Office).

64. In Scientology, Hubbard's instructions must be followed
exactly, with no deviation. These documents and others with
similar instructions to harass have been followed in this lawsuit
and all the other lawsuits in which Scientology has been

65. The Scientologists accuse defendants Dr. Geertz and Mr.
Fishman of harassing tactics. Yet it is the Scientologists who
are compelled by their most fundamental scriptures to harass
perceived enemies of Scientology unceasingly, including judges,
defendants, their counsel and the Scientology experts retained in
this case.

66. The Hon. Ronald E. Swearinger became a target of
Scientology harassment while he was presiding over the case of
Larry Wollersheim v. Church of Scientoloqv of California, #C 332
027. In the document attached as Exhibit 8, "Linda" is Linda
Hamel, who was In-Charge of the V'Mission Find the Crimes" ("MFTC
I/C) in OSA, which was run directly by "Marty," who is Marty
Rathbun, Inspector General for Ethics in RTC.

67. My husband Robert Vaughn Young and I have been harassed
and intimidated repeatedly since we became experts in this case.
Scientology operatives have stolen our trash. They have
slandered us to former associates. They have called us at all
hours of the night. High-level OSA operative Kurt Weiland sent
my husband a threatening letter. We have been followed and
surveilled on several occasions when we were able to spot the
person following or surveilling us; we have no idea how much more
surveillance we have been subjected to by operatives skilled
enough to avoid being spotted. On one occasion we were followed
more than 100 miles from our home by a Scientology agent. My
husband spotted the agent and stopped our car, at which point the
agent pulled in behind us and stopped his car as well. My
husband walked over and asked him outright if he was a
Scientologist, whereupon he admitted that he was from the
high-security Scientology compound in Hemet and that he was following
us under orders from Scientology Command.

68. These actions are imbedded in the doctrine of
Scientology. Scientologists have no choice but to adhere to these

CSI is Accusinq the Defendants of Its Own Criminal

69. L. Ron Hubbard invented a name for someone who accuses
others of crimes that he himself has committed. In fact, Hubbard
wrote a bulletin about this, which he called "The Criminal Mind."
Ironically, Hubbard described himself and his alter ego, the Sea
Organization, when he wrote that "THE CRIMINAL ONLY SEES OTHERS

70. The thinking behind CSI's motion to dismiss is best
explained by quoting Hubbard himself:
"Apparently they add it up this way: 'If I accuse him
of robbing, then it would be assumed by others that I
have not robbed a bank.' By loudly voicing a
condemnation of a crime, the criminal, with a crooked
think, supposes people will now suppose he is above
bank robbery and won't suspect him." (A copy of "The
Criminal Mind" is attached as Exhibit 9.)

Scientoloqy Doctrine Requires That Psychiatrists and
Psychologists Must be Destroyed

71. There is another aspect of the Scientology doctrine
which is highly relevant to this case, because Dr. Geertz is a
psychologist. Scientologists are taught that psychiatrists and
psychologists are the root of all evil in the world. According to
Hubbard, psychiatry and psychology are behind a massive
conspiracy to destroy Scientology and, with it, man's only hope
for salvation. Therefore, all psychiatrists and psychologists,
including Dr. Geertz, are Fair Game as far as Scientologists are

72. Hubbard taught that the world must be protected from
psychologists and psychiatrists at all costs. Hubbard wrote many,
many scriptures and recorded many lectures in which he vilified,
ridiculed, attacked, and blamed all the ills of the world on the
mental health profession.

73. The vitriol in Hubbard's attacks has three sources.
First, much to Hubbard's surprise and chagrin, the mental health
profession did not embrace either Hubbard or Dianetics, Hubbard's
"Science of Mental Health." Second, and even more offensive to
Hubbard, was the fact that his often dangerous techniques were
labeled as quackery. Third, and perhaps most important, Hubbard
regarded the mental health profession as a well-established and
deeply entrenched competitor for monies which might otherwise
flow to him and to Scientology.

74. The following sampling makes clear the degree of
Hubbard's loathing and contempt for these professions, and shows
that Scientologists will stop at nothing short of total
obliteration of these professions.

75. In 1970 Hubbard wrote "The Psychiatrist at Work"
(attached as Exhibit. 10). He attacks psychiatry as follows:
" . . . psychiatry is making insane people.
"This is why the insanity statistic is soaring and why
the crime statistic is on a wild climb....
"The psychiatrist has masters. His principal
organization, World Federation of Mental Health, and
its members, the National Associations of Mental
Health, the 'American' Psychiatric Association and the
'American' Psychological Association, are directly connected
to Russia. . . .
"It goes without saying that the savagery and fraud of
psychiatry must cease and that auditors must encourage
in state and public and through all their connections
displacing psychiatric abuses with sane auditing."

76. Obviously, psychiatrists and psychologists were evil
because their services competed with Scientology auditing. In a
1971 document by Hubbard called 18Confidential" (attached as
Exhibit ll), he wrote:
"Policy is that we assign any case or upset in
Scientology to past damage and interference with the
person by medicine or psychiatry. They were sent to us
after medicine or psychiatry had already destroyed
them. We cannot be blamed for psychiatric or medical
"By continually repeating this, make the AMA, Nats
[National Associations of Mental Health], etc. very
wary of using our name on these psychiatric and medical
failures. Both subjects are guilty and the statement is
demonstrably true. Use it often. Make it known to the
enemy that this is our policy as a restraint on their
fetid imaginations: 'Every time you attack us we will
disclose more records of your failures."'

77. In another 1971 document of the same date, entitled
"For Public Advicest" (attached as Exhibit 12), Hubbard wrote:
"It is time we begin to label Psychiatry for what it
is, the greatest failure of the Nineteenth Century.
Every notorious criminal and defector of the Twentieth
Century was in psychiatric hands before the crime.
Burgess, MacLean, the Texas Tower murderer, Manson and
all the rest were psychiatric failures first. Every
infamous modern assassin was a psychiatric failure.
Psychiatric victims are endless trouble to our society.
We are tracing social turmoil, unrest, widespread drug
addiction to psychiatry.
"We wish to issue a public warning that psychiatry
kills. We in Scientology stand ready to help anyone,
and help Governments rid themselves of psychiatric
crime. There is urgency in this. In too many cases we
are asked to repair persons already maimed beyond human
tolerance by psychiatric interference and brutality. We
blame psychiatric failure for the state of modern
society. We will do all we can to help, but Nineteenth
Century Psychiatry must go. We have never had a failure
or upset that psychiatry had not first ruined."

78. In 1980 Hubbard wrote I'Criminals and Psychiatry"
(attached as Exhibit 13). In it Hubbard said:
"Almost every modern horror crime was committed by a
known criminal who had been in and out of the hands of
psychiatrists and psychologists, often many times....
"The most charitable look at this would be that the
psychologists and psychiatrists are simply incompetent.
But other more sinister implications can be drawn.
"Developed in the latter part of the nineteenth
century, they appeared on the militaristic scene of a
rearming and conquest-minded Germany. At that time, the
archcriminal Bismarck was laying the groundwork for the
slaughters of World War I and World War II. It fitted
with the philosophy of militarism that man was an
animal and that there was neither soul nor morality
standing in the way of the wholesale murder of war.
'IUp until that time the Church had some influence on
the state and possibly some power in restraining
bestiality and savagely insane conduct, but small as it
might have been, it was incompatible with the unholy
ambitions of the militarists. That man was only an
animal after all, soulless and entitled to no decency,
bound to be a popular doctrine. That insanity
consisted of urges to harm others would have been a
very unpopular idea to government heads who had noth
else in mind. . . .
"Spawned by an insanely militaristic government,
psychiatry and psychology find avid support from
oppressive and domineering governments....
"The credence and power of psychiatry and psychology
are waning. It hit its zenith about 1960; then it
seemed their word was law and that they could harm,
injure and kill patients without restraint. The
appearance of an actual technology of the mind-Dianetics
and Scientology-- has played no small part in
acting as a restraint. At one time they were well on
their way to turning every baby into a future robot for
the manipulation of the state and every society into a
madhouse of crime and immorality. . . .
"The world is turning, things change. And there may
come a day when the mad dogs of the world are not given
over to the charge of mad dogs. But that will be to the
degree that you successfully carry forward Dianetics
and Scientology."

79. In a 1981 document called "Dianetics and Scientology
Compared to 19th Century Practices" (attached as Exhibit 14),
Hubbard wrote:
"A comparison between Dianetics and Scientology and
psychology and psychiatry is nonsense.
"The two 19th century subjects, psychology and psychiatry,
do not achieve ANY good results. On the contrary they are
destructive beyond belief. They make crackpots, sexpots and
vegetables when they do not outright kill....
"The character of the Governments themselves is
established by their tolerance and use of psychology
and psychiatry. In no human race of any civilized
repute has any law condoned broad mayhem and murder of
their populations. Yet under modern governments
psychology and psychiatry not only have carte blanche
but also get insistence on their use....
"IS this a civilized world we're living in?
"I'm afraid it only will be when Dianetics and
Scientology can bring wisdom enough to Man to blunt his
furious efforts to do himself in."

80. In 1982 Hubbard wrote "The Criminal Mind and the
Psychs" (attached as Exhibit 15), which states, in part:
'IIt has often been noted (and routinely reported in the
papers) that criminals 'treated' by psychologists and
psychiatrists go out and commit crimes.
"It could be suspected that these 'practitioners' used
pain-drug-hypnosis and other means (under the guise of
treatment) to induce the criminal to go out and commit
more crimes. And possibly they do....
"So let us look at psychs again -- what they call
'treatment' is a suppression (by shocks, drugs, etc.)
of the ability to think. They are not honest enough,
these psychs, being just dramatizing psychotics
themselves for the most part, to publish the fact that
all their 'treatments' (mayhem, really, when it is not
murder) make people more stupid....
"The answer to crime is rising IQ. But only the
Scientologist can do that."

81. In another 1982 document called "The Cause of Crime"
(attached as Exhibit 16), Hubbard wrote:
" . . . So what IS the cause of crime? The treatment, of
course! Electric shocks, behavior modification, abuse
of the soul. These are the causes of crime. There would
be no criminals at all if the psychs had not begun to
oppress beings into vengeance against society.
"There's only one remedy for crime--get rid of the
psychs! They are causing it!...
"The psychs should not be let to get away with
'treatment' which amounts to criminal acts, mayhem and
murder. They are not above the law. In fact, there are
no laws at all which protect them, for what sane
society would sanction crime against its citizens even
as science? They should be handled like any other
criminals. They are at best dramatizing psychotics and
dangerous, but more dangerous to society at large than
the psychotics they keep in their offices and loony
bins because they lie and are treacherous. Why the
government funds them I do not know. They are the last
ones that should be let loose to handle children."

82. In another 1982 document entitled "Pain and Sex"
(attached as Exhibit 17), Hubbard announced that psychiatrists
and psychologists (collectively called I1psychstV) had been behind
all of our troubles for millennia (and he also revealed his
bizarre view of sexuality):
"There are two items in this universe that cause more
trouble than many others combined.
"One is PAIN.
"The other is SEX....
"Despite the false data of Freud, psychologists,
psychiatrists and other criminals, they are not native
to a being. They are only artificial wavelengths. They
have exact frequencies that can be manufactured....
"Destructive creatures who do not want people big or
reaching-- since they are terrified of punishment due to
their crimes--'invented pain and sex to shrink people
and cut their alertness, knowingness, power and
"Pain and sex were INVENTED tools of degradation....
"Combined, pain and sex make up the insane
Jack-the-Rippers (who killed only prostitutes) and the
whole strange body of sex murder freaks, including
Hinckley [who shot President Reagan], and the devotees
of late night horror movies. Under the false data of
the psychs (who have been on the track a long time and
are the sole cause of decline in this universe) both
pain and sex are gaining ground in this society and,
coupled with robbery (which is a hooded companion of
both), may very soon make the land a true jungle of
"Go into any asylum or a prison and look at the
increasing institutional population and know what you
are looking at. In the main, these are pain and sex
addicts, decadent and degraded and no longer capable.
They were sent on that route down through the ages by
the psychs and here they are still in the psych's
hands! And do they get well or go straight? Oh no.
Whether in prisons or insane asylums, they just get
worse. And the psychs in both places rub their bloodied
hands as they turn their products loose again upon the
remaining population! It's no accident. And the
stocks-in-trade of psychs are PAIN and SEX."

83. There are many, many more documents and tapes which
comprise Scientology doctrine about the evils of psychiatry and
psychology. As far as the Scientologists are concerned, the world
would be much better off if all the psychiatrists and
psychologists were to disappear, leaving Scientology to move into
the field of mental health and take it over. The Scientologists
actually believe that this would be the best thing that could
happen to humankind.

84. Furthermore, as far as the Scientologists are
concerned, anyone who would subject himself voluntarily to years
of hypnosis, as Mr. Fishman did, is already so far gone that
there is really nothing that can help him. Orthodox Scientology
holds that a person as damaged by psychology as Scientologists
believe Mr. Fishman to be might as well drop his current body,
pick up another body and start over again.

85. So these two people, Dr. Gee&z and Mr. Fishman, are so
degraded by choice of profession and decision to seek help from a
conventional mental health professional that each of them is
infinitely expendable in the eyes of Scientology. See Exhibit 2
for an example of the kind of treatment a psychiatrist who
publicly criticizes Scientology can expect from a Scientologist.
Fishman's Experience in Scientoloqy Drove Him to a Psvchotic

86. I have read Steven Fishman's book, The Lonesome
Sauirrel, 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

87. 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 hereto as Exhibit 19 is
a copy of Hubbard Commincation policy letter entitled llIllegal
PCs, Acceptance 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,
prints and E-Meters, clearly being led to believe that he would
be welcomed into the privileged circle of dedicated

88. It is highly significant that he was induced to
purchase three E-meters (electro-psychometers), the device used
in Scientology auditing. 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.

89. 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 and RTC. 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 or more, 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 It 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.

90. 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, particularly because they also
sold him E-Meters. Indeed, it is clear that Fishman was
overwhelmed by the Scientology materials he was given, to the
point of an actual psychotic break.

91. 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

92. 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.

93. There are different types of PTSness. Some of these are
listed in an October 27, 1964, policy by Hubbard known as
l'Policies on Physical Healing, Insanity and Troublesome
Attached hereto as Exhibit 20 is a copy of Hubbard Comminication
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 Scientology ltconsiderable
trouble. It They include people who have sued the church, newspaper
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.

94. 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.)

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

96. 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.

97. This created an explosive situation, one which clearly
could lead to a psychotic break in Fishman. Even as recently as
September 1993, Ray Mithoff, Senior Case Spervisor International,
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 copy of Scientology's report on this incident is attached
hereto as Exhibit 21. 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, 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 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.

98. 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 copy of a Hubbard Comminications Office
Bulletin entitled "Seach and Discovery" and describing these PTS
types is attached hereto as Exhibit 22.

99. 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.

100. 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 the person thinks). 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.

101. 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

102. 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.

103. A number of things can trigger a psychotic break, or
cause a person to Itgo 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 Later he
made it clear that what is 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 and through
him at once.

104. 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.

105. 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

106. 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 23.

107. 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.

108. Hubbard explained how to do it in the following passage
from t'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!"

109. 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 has 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."

110. 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 24.

111. 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 25.

112. All of these instructions just quoted are part of the
Scientology "scriptures. I1 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

113. 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. (See Exhibit 26.) A
copy of this 'declare' is attached hereto as Exhibit 27 (see item
7) - Hubbard mde it clear that he did not take suicide seriously
in a taped lecture called "Create and Confront," given on January
3, 1960, as part of the "State of Man" lecture series. See
Exhibit 28 for a transcript of "Create and Confront,"
particularly pages 93 and 94.

114. 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.

115. In the tape "Some Notes on Black Dianetics," Hubbard
himself described the dangers of self-auditing: 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
simpler and quicker."

116. 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 high-security
international headquarters of Scientology.

117. 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

118. 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 Introspection Rundown is
attached hereto as Exhibit 29.

119. The first step is to isolate the person completely from
everyone except the people assigned to watch over the person.
This is called lVIsolation 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. None of the people assigned to watch her had
any formal training in dealing with psychosis.

120. 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.

121. 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 30. 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.

122. 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.

123. 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 Category Sort-out that 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

124. 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 she wanted
to kill herself, and that she had no idea who she was or what
she was doing. This went on for several months.

125. 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.

126. Maggie Butterworth, former OSA operative 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
used to be one of the most senior technical experts in
Scientology (Miscavige reportedly demoted her to kitchen maid

127. 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 an
unimportant department where people could keep an eye on her and
make sure she remained loyal to Scientology.

128. 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
ttchaplainu 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.

129. 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 selltt she experienced at the hands of Scientology salesmen
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

130. Finally they convinced Robert that Dorothy needed to
fly back to San Francisco. Upon arriving in San Francisco,
Dorothy was taken to a ttmountain 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.

131. 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 Robe.& 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.

132. 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 Geary D.D.S. executed September
5, 1993 is attached hereto as Exhibit 31.

133. 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 now has 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 who at last report had been demoted to cook in
the communal kitchen at Hemet; and, of course, Miscavige, 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.

134. 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.

CSI's Real Motive in Filins for Dismissal Was To Protect Its
Managing Agents

135. CSI claims to be concerned about allowing several
Scientology celebrities to be deposed. CSI says it does not want
these people to be harassed by Dr. Geertz's attorneys. In truth,
if it served CSI's purposes to have these celebrities deposed
would order the deponents to appear and not think twice about
This much-touted concern for the celebrities is purely show. What
CSI is actually worried about is that the tables have been turned
on it in this case. The Scientologists can dish it out, but they
cannot take it. They have finally met their match. Dr. Geertz's
attorneys Graham Berry and Gordon Calhoun have educated
themselves, with the help of several former Scientologists, about
how this organization really operates, and they are not letting
CSI get away with its usual harassment and intimidation tactics.
This is the real reason CSI filed for dismissal.

136. Dr. Geertz's attorneys have parted the flimsy curtain
of a corporate veil honored almost always in breach to reveal the
true structure of authority in Scientology, the Sea Organization,
and the people who really run Scientology, starting with
Miscavige, the managing agent of the entire organization, and his
key lieutenants, including Norman Starkey, Greg Wilhere, Mark
Yager, Marty Rathbun and Ray Mithoff. Under Miscavige's
direction, this organization has systematically violated the
civil and human rights of its members, secure in the knowledge
that because it calls Scientology a religion, it is protected by
the First Amendment. Suddenly CSI is confronted by counsel
assisted by experts who are fully aware that the Tech is applied
both secularly and ecclesiastically. The veil provided by the
misuse of First Amendment claims that every action by a
Scientologist is religious and beyond scrutiny by the civil
justice system has been parted. CSI's management has been
delivered a clear and compelling message. CSI's management knew
it could not maintain its facade of respectability and
religiosity if CSI allowed this case to continue. That is why CSI
moved to dismiss it on the eve of trial.

137. Miscavige has filed a declaration in which he denies
being the managing agent of the Scientology empire. He words his
denial carefully, using the language of the corporate shell he
created to shield his true position from the Courts. But the
truth is that he does run it, either directly or via his key
lieutenants. This is common knowledge within the upper echelons
of the Sea Organization. Miscavige's position of power (and the
power of his lieutenants) in Scientology is what was being
protected by the filing of CSI's motion to dismiss. Therefore,
the truth about Miscavige and the henchmen who carry out his
orders bears telling.

Miscavige is the Managing Agent of Plaintiff CSI

138. As stated earlier, I was a Scientologist for nearly 15
years, from January 1975 until July 1989. I was in the GO and its
successor (a name change only), OSA, for most of that time. I
also worked in another part of Scientology called Author
Services, Inc. ("ASI"). I was a Sea Organization ("Sea Org")
member during my tenure on all of these posts.

139. All of the positions I held from 1978 until 1989
enabled me to observe firsthand the line of command and the
organizational structure of Scientology. There is no question
whatsoever that Miscavige now holds the same position of absolute
power over Scientology, cutting across all corporate boundaries,
that Hubbard had before he died. Just as Hubbard was the managing
agent for the original mother church, CSC, Miscavige is the
managing agent for the current mother church, CSI, via his
position as Chairman of the Board of the Religious Technology
Center ("COB RTC").

140. I first became aware of Miscavige in 1981, when a coup
took place within Scientology. Until then there had been two arms
of Scientology. The Guardian's Office was run by Mary Sue Hubbard
and took care of everything external to the organization, such as
public relations, government relations, litigation, and anything
else that might hinder the expansion of Scientology. The other
branch, the Commodore's Messenger Organization ("CMO"), ran
Scientology itself under the direct command of Hubbard (known as
the Commodore). Reality was directly contrary to Hubbard's
repeated claims that he had resigned all management
responsibility in 1966. The CM0 directed all internal operations
via an unincorporated group of highly dedicated Scientologists
known as the Sea Org.

141. In 1981, I was a senior executive in the United States
Guardian Office ("USGO"). One evening we were informed that the
GO was being taken over by the CMO. From that time on Miscavige
has had complete control over all branches of Scientology.

Miscavige Wields His Power Through a Small Circle of

142. Miscavige wields his power through a small circle of
trusted Sea Org lieutenants who obey him unquestioningly. Until
July 1989 when I left, his most senior aides were in RTC and
included Greg Wilhere, who was the Inspector General ("IG");
Marty Rathbun, who was the Inspector General for Ethics ("GG
Ethics"); Ray Mithoff, who was the Inspector General for
Technology ("IG Tech"); and Marc Yager, who was the Inspector
General for Administration ("IG Admin"). Another top aide was
Norman Starkey, who was corporately the trustee of Hubbard's

143. Rased on testimony generated in this and other
cases with which I am familiar in my capacity as a consultant and
expert and conversations with high-ranking Scientologists who
have left since I left in 1989, Miscavige has reorganized his
command structure and done away with the IG Ethics, Tech and
Admin posts. Miscavige has moved Ray Mithoff back to his old
position of Senior Case Supervisor International ("Senior C/S
Int") in CSI. He has moved Marc Yager back to his old position as
Commanding Officer of the Commodore's Messenger Organization
International ("CO CM0 Int") in CSI. From the most recent declarations
of Marty Rathbun and Greg Wilhere, it appears that
Miscavige has removed both of them from their posts. They are now
on the ship, the Freewinds, probably on the Rehabilitation
Project Force ("RPF"), which is the Scientology version of a
prison camp. For some reason Miscavige wanted both of them out of
the country as this case approached trial. This is probably
because both Wilhere and Rathbun have committed acts which may be
violations of criminal and civil law on Miscavige's orders. Many
of the people designated to be trial witnesses by Dr. Geertz's
counsel were witnesses to these'unlawful transgressions. If
Miscavige's lieutenants were to testify, they would have faced
exposure to perjury charges. They are also aware of many wrongful
acts which run afoul of criminal and civil law of which Miscavige
is directly guilty. There is a possibility that Miscavige's
lieutentants, when faced with the prospect of personal criminal
liability for perjury for false testimony designed to protect
Miscavige, would instead abandon their mentor when placed under
oath and reveal what they know, particularly if granted immunity.

144. Miscavige has other top aides in CSI whom he orders
either directly or via the RTC command lines. These CSI aides
include the Watchdog Committee ("WDC"), which is'a group of Sea
Org members who manage all of the different branches of
Scientology, both secular and non-secular. Other top CSI aides
include Kurt Weiland, who is the Commanding Officer of the Office
of Special Affairs International ("CO OSA Int"); Guillaume
Lesevre, who is the Executive Director International ("ED Int");
and Heber Jentzsch, who is a PR front man with the title of
President of the Church of Scientology International ("President
CSI"). In reality, Heber has no administrative power at all and
his duties are solely to deal with media and other PR groups.

145. The authority of the above-named individuals comes
solely from Miscavige. Any one of them can vanish overnight. Any
one or all of them can be sent to the prison camp known as the
RPF if Miscavige even suspects disloyalty. (This is undoubtedly
what happened to Wilhere and Rathbun.) Miscavige's authority
over RTC, CSI and (via these two corporations) the rest of
Scientology, is absolute.

146. Since Miscavige took over the Guardian's Office in
1981, he has had virtually total control over the entire
Scientology organization, including all branches of Scientology
management and extending out to every single person in the world
who is a Scientologist. No one can challenge his authority.
Miscavige can expel anyone from Scientology literally with a snap
of his finger. In fact, "The Sea Organization Expansion News"
contains a graphic picture of Miscavige "declaring a former
Mission Holder suppressive." (See Exhibit 32.)

147. Miscavige derived his power directly from Hubbard,
which is why his power was and now is so absolute. Hubbard went
into hiding in 1976 to avoid the IRS. Several government agencies
around the world and in the U.S. and a number of former
Scientologists sued Hubbard. Miscavige gradually took over as
Hubbard's eyes and ears until finally, by 1981, Hubbard allowed
him to take over entirely.

Miscavige First Ran Scientoloqy from Author Services, Inc.

148. In 1981 Miscavige called himself Special Project
Operations ("Special Project Opsll). He set up offices in the CM0
building across the street from the big blue building in Hollywood.
From this position, he ran the entire Scientology
operation. He had several people working directly with him in a
unit called Special Project, including Norman Starkey, Terri
Gamboa, Lyman Spurlock, my husband Robert Vaughn Young, myself,
and others. These people ran all the PR, Legal and Intelligence
functions that had previously been run by the Guardian's Office
line of command. The primary focus was the Mission All Clear, or
the MAC Unit, in the Legal Division of the Guardian Office. The
purpose of this unit was to extricate Hubbard from all the
lawsuits that had been filed naming him as head of the church.
Miscavige was personally charged with extricating Hubbard from
pending litigation so Hubbard could come out of hiding.

149. Because Miscavige had the direct communication line to
Hubbard, he also had authority over all of the internal
Scientology management personnel. All communications from Hubbard
came through Miscavige, and all communications to Hubbard went
through Miscavige. There were only two other people more senior
than Miscavige, Pat and Annie Broeker. Their status arose
because they were actually with Hubbard. An order from Pat or
Annie had as much authority as an order from Hubbard because they
were so close to him.

150. But Pat and Annie were sequestered off at the Creston,
California, ranch. Miscavige was at the center of and actually
directing Scientology activities. He used his position of high
visibility within the Scientology command structure to run
Scientology from the moment he became Special Project Ops.

151. In May 1982, Miscavige and the rest of the staff of
Special Project moved to a suite of offices on Sunset Boulevard
and adopted the corporate mantle of ASI.

152. Miscavige appointed himself COB of ASI. This title was
for consumption by the general public. Miscavige continued to
identify himself as Special Project Ops in correspondence with
church personnel. Miscavige appointed Terri Gamboa Executive
Director of ASI. He gave Norman Starkey the title Legal Affairs
Director. Lyman Spurlock became Corporate Affairs Director.
Miscavige gave Robert Vaughn Young the title Public Affairs
Director, and so on. Miscavige assigned me the job of Organizing
Officer of ASI. As such, I was responsible for making sure the
staff were doing their jobs properly. If the staff failed in any
way, I was charged with correcting them.

153. During this time, and from 1981 until Hubbard died in
1986, I observed firsthand Miscavige systematically replacing
Hubbard as head of Scientology. Publicly, ASI was promoted as a
glitzy Hollywood literary agency dealing exclusively with the
works of Hubbard. But behind the scenes, Miscavige was running
all of Scientology from the AS1 offices.

154. As an AS1 staff member, I was instructed, and all those
who worked in AS1 were also instructed, that making large amounts
of money for Hubbard was an integral part of running Scientology.
Hubbard's written communications to ASI staff revealed that he
felt nothing but contempt for his reation, the church of
Scientology. He made it clear that he felt perfectly justified
in taking as much money out of the church as DM and the other AS1
staff could get away with. (Hubbard dictated all of his
communications and the dictation was then transcribed and
distributed by Miscavige. Both the dictation tapes and the
dispatches still exist, although CSI will undoubtedly deny it.)
Hubbard made it very clear that Miscavige's success or failure
would be based on how much money he could make for Hubbard,
whether it came from church coffers or other sources.

155. Accordingly, Miscavige made sure that qas much money as
possible was taken from church accounts. Fran Harris thought up
labels, known in Scientology as llsignificances,VV which were
attached to huge lump sums which Miscavige then ordered to be
transferred from nonprofit church accounts into AS1 accounts
every week. These labels were designed to conceal from the IRS
and other governmental agencies the true nature of the transfers.

156. There was never any question that the staff at the
non-profit organizations would transfer the money as directed. Each
of these organizations and therefore each of the staff members
was junior to Miscavige. If Miscavige ordered it done, it had to
be done. If anyone having responsibility over the financial
accounts of the junior organizations refused to follow orders
from Miscavige he or she was subject to immediate banishment to
the RPF. I was told by my superiors, including Miscavige, that
Miscavige was acting as Hubbard's deputy, and that anything
Miscavige ordered should be treated as an order directly from
Hubbard himself.

157. The only thing that ever slowed these transactions down
was making sure the significance attached to the transfer would
appear legitimate to the IRS. Miscavige made Lyman Spurlock
responsible for working out the legal details of these transfers.
I often had to sit down with Lyman and help him calm down after
he had been ordered to legitimize some of Fran Harris's
money-making ideas. Lyman told me that he had had many serious
disagreements with Fran about the legality of at least some of
her schemes. In my experience, when Lyman expressed his doubts to
Miscavige, Miscavige always sided with Fran. Miscavige's
instructions usually concluded with an order to Lyman to "make it

158. Miscavige also assigned Lyman the task of sorting out
all of the Scientology corporations so they would be legally
defensible in the eyes of the IRS and other governmental
agencies. It was at this point that the huge conglomeration known
as Church of Scientology of California ("CSC"), the predecessor
"mother church," was split up into many different corporations.
Lyman worked out the whole shell, including all the relationships
between the different echelons.

159. Lyman arranged for the Religious Technology Center
("RTC") to have contracts with every single corporation that uses
Hubbard and Scientology trademarks and copyrights in any way,
including the management organizations, the service
organizations, the businesses that,use Hubbard's books, and so
on. The real purpose of all of these contracts was to have a
legal means by which to collect monies from these entities, and
to put anyone out of business who refused to tow the line of
Scientology orthodoxy as dictated by Hubbard or any of his

160. Since Hubbard's death, Miscavige has assumed the power
and authority to put out of business any Scientologist who
refuses to tow the orthodox Scientology line as he dictates it.

161. I worked directly with Miscavige while I was at ASI. I
was horrified to discover that the senior-most person in
Scientology, who had daily contact with Scientologists and the
public, was a ruthless, vicious, megalomaniacal tyrant. I had
never worked with Hubbard personally, but I learned from others
who had that Hubbard was the same way. I was told that Hubbard
was prone to the same petulant temper tantrums that were daily
occurrences with Miscavige.

162. Miscavige's style of management was exemplified by
screaming profanities and terrorizing the staff. This is entirely
consistent with the Hubbard Tech which features "Ethics
Presence." Senior managers are taught to manage by instilling
fear and terror in their subordinates. As the most senior
manager, Miscavige had to instill terror in all his subordinates
in order to be in compliance with orthodox Scientology management

163. One day Miscavige gave me an insight into why he acted
the way he did. He knew I did not approve of his cursing at the
top of his lungs. We were having an executive meeting, and in the
middle of a sentence he suddenly turned to me, very seriously,
and said, "You think I yell loudly, but you've never heard anyone
yell until you've heard LRH [Hubbard]. I'll never be able to
scream the way he does. But Stacy, that's the only way to get
compliance. It This was confirmation that he was acting
deliberately and calculatingly in accordance with the dictates of
the Hubbard Tech.

164. I realized then that Miscavige was trying to become as
much like Hubbard as he could, and that he was preparing to take
Hubbard's place when Hubbard died.

165. Anyone who disagreed with Miscavige or challenged his
authority in any way was branded by Miscavige as a traitor who
was out to destroy Scientology. This was why David Mayo was
ousted, along with most of his staff. Many others were thrown out
in 1981 and 1982 and replaced with people who would obey
Miscavige's orders unquestioningly. Ray Mithoff, who replaced
Mayo, is today one of Miscavige's top lieutenants. John Nelson,
head of the CM0 and director of all the Scientology
organizations, was also ousted by Miscavige and replaced by a
loyal follower, Marc Yager. Today Yager is another one of
Miscavige's top people.

166. Hubbard was still alive when I was at ASI in 1982, and
every staff member in ASI was required to report to Hubbard every
week on the status of his or her sector of Scientology. No one
slept from Tuesday to Friday because Miscavige ordered that no
one could leave until he had approved their weekly report to
Hubbard. Miscavige repeatedly rejected the reports, insisting
that they be rewritten until they were perfectly worded to appear
that Miscavige had everything fully under control. No one was
allowed to send any communication to Hubbard that wasn't edited
by Miscavige (which meant that Hubbard effectively did not really
know what was going on from 1981 until his death). This grueling
schedule left the entire staff in terrible shape physically, and
extremely vulnerable to Miscavige's brutal, coercive

167. At that time the AS1 offices were on the ninth floor of
an office building in downtown Hollywood, yet people could hear
Miscavige screaming down on the street, a block away. It was
disgusting to see how he treated anyone he viewed as not fully
"with him."

Miscavige's Treatment of his Staff Was Horrifying

168. Jim Isaacson, for example, was in charge of investing
Hubbard's money, and he was expected to show a profit on a weekly
basis. Anyone familiar with the investment business knows this is
not a realistic expectation, but Jim's job depended upon his
showing an increasing profit every week. Predictably, Jim was not
doing well at all. He was not eating or sleeping. Miscavige was
screaming mercilessly at Jim every day. Jim was near the
breaking point.

169. One day Miscavige found out that Jim had lost a large
amount of money by investing incorrectly in the gold market.
Miscavige summoned two of his top lieutenants, Norman Starkey and
Terri Gamboa. Miscavige and Starkey literally dragged Jim into
the conference room.

170. My office was right across the hall so I heard
everything that went on. For the next three and a half hours
Miscavige screamed profanities and wild, paranoid accusations at
Jim, demanding to know who had sent him to destroy Scientology,
was he working for the IRS, was he working for the FBI, what
other enemy agents were working with him inside Scientology,
etc., etc., ad nauseam. I heard Jim repeatedly deny the
accusations, and Miscavige's response was to scream at him even

171. Finally Miscavige threw open the door and stormed into
my office. He ordered me to go in and get the information out of
Jim and not let him leave until he'd confessed everything. I'd
never seen anyone behave like Miscavige before. (As stated above,
while I was on this post and later while I was in the RPF, I
learned from others that Miscavige's behavior mimicked

172. Miscavige was very frightening. When he was worked up
his conduct was consistent with what I later learned was a
psychotic episode. Miscavige appeared to be completely out of
control. He screamed profanities at the top of his lungs directly
in my face. Others who went past my office kept their eyes
averted and walked by as quickly as possible. Finally, he marched
down the hall (with Norman and Terri following) and slammed the
door of his office.

173. When I went into the conference room I found Jim
collapsed on the table. His eyes were glazed and he was shaking
uncontrollably. Rather than complying with Miscavige's order to
continue the interrogation, I did my best to calm Jim down, as he
was clearly terrified, and told him to go home and get some
sleep. Jim was on the RPF within days.

174. Part of Jim's terror arose from the fact that Miscavige
had already sent Jim's wife, Joyce, to the RPF for refusing to go
along with his brutal treatment of staff. I knew about this
because I replaced Joyce. I was dispatched to the RPF shortly
thereafter because I objected to the same abuses.

175. No one could speak out against Miscavige's terror
tactics because there was no way to have a discussion with him on
the subject. The RPF filled up with people who tried to stand up
to him. He surrounded himself with people who were willing to do
whatever he ordered. I tried several times to protest and ended
up in more and more trouble as the weeks went on. Finally
Miscavige lost his temper at me one night and threw me into my
office, locked the door, and screamed at me until finally I felt
I would lose my mind if he did net stop. I had not slept for
several days, and I snapped.

Staff Who Were Critical of Miscavige Were Sent to the RPF

176. The next day I didn't go to work, saying I was sick. I
was afraid to tell anyone what had happened for fear that
Miscavige would separate me from my husband (another common
tactic he uses, as did Hubbard, to control people). Unfortunately
I confided in someone I thought I could trust that Miscavige was
a brutal, tyrannical bully. That person immediately reported me
to Miscavige. That night at four in the morning there was a loud
knock on my door. It was the Scientology security police. They
took me to the RPF. That is how absolute Miscavige's power is,
and how immediate is the punishment for anyone who doesn't
completely submit to his authority.

177. Miscavige charged me with being an agent who had been
sent in to destroy Scientology. He claimed that I was working for
Michael Flynn, an attorney who was successfully litigating
against Scientology at that time. He ordered me to submit to what
was known as a "gang-bang set check." Two very large, strong men,
Andre Tabayoyon and Rick Aznaran, locked me in a room and
interrogated me for hours. During the interrogation, they
screamed and swore at me. They accused me of all sorts of crimes
against Scientology. They demanded that I confess to being an
enemy agent.

178. Miscavige had also ordered me to do the "Running
Program" as part of the requirements for getting off the RPF.
This consisted of running around an orange pole for 12 hours a
day. I was supposed to do this until I had some sort of
realization about what was wrong with me, whereupon, presumably,
I would stop being critical of him.

179. After one of the gang-bang set check sessions, I was
extremely upset. I was not paying sufficently careful attention
to where I was placing my feet as I ran around the orange pole. I
ran straight-legged into a pothole about a foot deep and smashed
one of my sacroiliac disks. This put me flat on my back. I was
unable to walk. I was under orders from a doctor not to move
because he thought there was a danger that I might suffer
paralysis from movement before the swelling in the disk subsided.
I paid for the doctor myself, since Miscavige had ordered that no
one give me any assistance whatsoever and, indeed, I was not paid
at all for several months on the RPF.

180. Despite my medical condition, diagnosed by a
Scientologist doctor, Miscavige issued orders that I be sent to
Florida to get me as far away from my husband as possible.
Miscavige said he was afraid I would turn my husband against him.
A Commodore's Messenger burst into my room one evening and
ordered me to pack immediately so that I could catch a flight to
Clearwater that night. I was to be transferred to the RPF at the
Flag Land Base, another Scientology compound. I protested, she
continued to insist that I get up until I was finally able to get
her on the phone with the doctor, who told her the church would
be responsible if I ended up paralyzed.

181. Although Miscavige allowed me to remain in Los Angeles,
I was imprisoned, under guard, on the seventh floor of the
building, so that I could not escape and reach my husband. We
were not allowed to see each other at all for three months, and
even our letters to each other were intercepted. Neither of us
knew what had happened to the other and it was agonizing for both
of us. I was under threat of expulsion and I believed that if I
were expelled I would never see my husband again. I was deathly
afraid that Miscavige would lie to my husband about me and turn
him against me. I finally convinced Miscavige that I was not a
threat to him, and my husband and I were allowed to see each
other again.

Miscavige Rules Via the Sea Organization; There is No
Corporate Integrity

182. Horror stories like this could be told by any
Scientology staff member who has worked in close proximity with
Miscavige. The only people who will talk about him, however, are
those who have left, because as long as they are inside he
virtually holds the power of life and death over them. He can
separate them from the spouses, separate them from their
children, keep them from sleeping, keep them from eating anything
but rice and beans, imprison them for years in the prison camps
known as the RPF. Miscavige's power is absolute, and it has
nothing to do with corporate boundaries. As did Hubbard before
him, he wields his power via the Sea Organization, which is an
unincorporated, fiercely dedicated, group of Scientologists. It
is the Sea Org that actually runs all of Scientology.

183. Miscavige simply uses the corporations, as Hubbard did,
to manipulate the courts, the IRS and other government agencies.
The corporations were only created to fool the outside world, the
"wag world," as Sea Org members contemptuously call it. Inside
Scientology, the only boundaries are the ones Miscavige chooses
to create, just as it was with Hubbard before him, and everyone
knows it. In fact, now that Hubbard is dead, what Miscavige wants
is senior even to what Hubbard policy says. Miscavige can violate
policy and break the law whenever he wants to and no one can stop
The 1982 Mission Holders' Meeting Illustrates the Emptiness
of the Corporate shell

184. Miscavige and his RTC and CSI lieutenants can walk into
any Scientology organization and order anything they want or shut
it down at whim. Nowhere has there been a clearer illustration of
the emptiness of Scientology's corporate shell than the infamous
Mission Holders' meeting in 1982. A transcript of this meeting is
attached as Exhibit 33. Although Miscavige's profanity and many
of his and his lieutenants' less elegantly phrased comments have
been edited out, several things are still clear.

185. Miscavige, who at the time was officially COB ASI, was
head of Scientology and senior to everyone else there. The other
speakers included Lyman Spurlock, Corporate Affairs Director at
ASI; Norman Starkey, Legal Affairs Director at ASI; Ray Mithoff,
Senior Case Supervisor International in CSI; Marc Yager, CO CM0
Int in CSI; Guillaume Lesevre, ED International in CSI; Steve
Marlowe, then Inspector General of the Religious Technology
Center (he was later sent to the RPF and replaced by Vicki
Aznaran, who in turn was busted and replaced by Greg Wilhere, who
has since been busted and, apparently, replaced by Miscavige
himself, holding the position of Inspector General as well as
that of CCB RTC); and Wendell Reynolds, International Finance
Dictator in CSI (he was later busted and spent several years on
the RPF).

186. Miscavige, an employee and director of ASI, and his
lieutenants, whose employment spanned RTC, AS1 and CSI, were
speaking directly to a group of people who held the franchise
rights to various missions (missions being the lowest
organizations on the Scientology totem pole). Yet there was no
concern for corporate integrity that day in San Francisco. These
Scientology leaders, on Miscavige's orders, expelled several
mission holders on the spot that day for being unhappy about what
they were hearing, destroying their business with a snap of the
finger. On Miscavige's orders the mission holders were ordered to
pay large sums of money for a promotional campaign for the
original Dianetics book, under threat of being investigated for
crimes against Scientology if they refused. They were ordered to
pay large sums of money for many other "crimes," real or
imagined, under threat of losing their business if they refused.
The result was hundreds of thousands of dollars paid into CSI and
RTC accounts from these missions.

187. Hundreds of people, including many mission holders,
were expelled from the church during that time. All people who
criticized Miscavige or refused to comply with his orders,
regardless of status or organizational affiliation, were subject to
expulsion. Miscavige quickly made it clear that he could order
any Scientologist, anywhere in the world, to do anything he
wanted. See Exhibit 32 for a copy of "The Sea Organization
Expansion News," "The Sea Org Moves In!" copyrighted by CSI,
which includes a photoyraph of Miscavige expeiling a Mission
Holder. There is also another photograph which shows Marc Yager,
Miscavige, Norman Starkey, Guillaume Leserve and Ray Mithoff,
among others, all identified by their Sea Org ranks even though
Miscavige and Starkey were AS1 (non-church) staff at the time.
This is further evidence that these men are managing agents of
CSI, which was why Dr. Geertz wanted them deposed in this case.

Miscavige Personally Ordered and Oversaw the Portland

188. I was in the Office of Special Affairs United States
(OSA US) in Los Angeles in 1985 when a jury awarded Julie
Christofferson $39 million in damages for being harmed by
Scientology. We had all expected to win the case. After all,
Miscavige and his top aides had been up in Portland running the
whole thing directly. How could we lose? There was champagne and
a huge, sumptuous buffet waiting for us, as soon as we received
word on the victory.

189. Instead, we got word that there was a $39 million
decision against the church. It was devastating. Dead silence
fell throughout OSA US's offices. For an hour, no one knew what
to do. It was the most humiliating defeat Scientology had ever

190. And then suddenly all the OSA staff were summoned into
one of the legal offices. Miscavige and Norman Starkey, who was
Legal Affairs Director, ASI, at that time, were on the speaker
phone. The decision was an outrage, Miscavige told us. He told us
he would not permit it to stand. Every Scientologist from around
the world was ordered to Portland, immediately. We were to spread
the word by whatever means possible, arrange transportation,
raise the money, do whatever we had to do to get the
Scientologists there. This was the beginning of what became known
as the Portland Crusade.

191. The staff of OSA did nothing but run various aspects of
the Portland Crusade until the judge finally declared a mistrial
several months later. The entire operation was overseen by
Miscavige and his top staff. Planes were chartered to fly
Scientologists from Europe to Portland; donations were raised to
print a special edition of the church publication, FREEDOM, about
the "Religious Freedom Crusade" and distribute it door to door to
every home in Portland. Miscavige even ordered students to leave
their Scientology courses (unheard of in Scientology) to go to

192. The best time to observe how the Scientology command
lines really work is during a disaster. The Christofferson loss
of 1985 was the biggest disaster Miscavige had ever had to deal
with, and all semblance of corporate integrity fell by the
wayside in an instant.

Miscavige Crossed All Corporations When Hubbard Died

193. The corporate structure was completely ignored again
when Hubbard died in January 1986. I was ordered to ASI and
briefed, along with a roomful of others from OSA US (Church of
Scientology Western United States, or "CSWUS"), OSA Int (CSI),
CM0 International (CSI), Gold (CSI) and elsewhere, by Miscavige
on what had happened. Then, although he had no corporate
authority over any of these organizations or staff, he went
around the room and gave each of us our instructions as to what
we must do in the transition to the post-Hubbard era of

194. When Hubbard died, I was employed by an organization
called North Star. This was a non-church corporation I formed to
put FREEDOM Magazine, which I edited, at arm's length from the
various Churches of Scientology for tax purposes. I created a
separate corporation based on the advice of Scientology's lead
tax attorney, Chris Cobb, Esq.

195. Although North Star was established as a subsidiary
corporation of CSI, in reality North Star was supposed to receive
its operating instructions from OSA US (CSWUS). We did receive
instructions from executives at OSA, but we also received
instructions directly from ASI, including Miscavige himself. He
assigned us to do a research project for the Hubbard biography.
At the time, we were receiving direct orders from both OSA and

196. Miscavige ordered me to write the copy for a eulogy of
Hubbard. I worked directly with Norman Starkey and Miscavige to
finalize the copy, and Miscavige gave the final approval. Then,
under orders from Miscavige, I worked with Jonathan Epstein, a
financial banking officer who was part of CSI, to arrange for
several hundred thousand dollars to be pulled from various
reserve accounts in a number of different corporations. These
funds paid for the eulogy to be placed in major newspapers around
the country as full-page ads.

197. After the ads were placed, Miscavige then ordered me to
create a booklet about Hubbard to be used for promotional
purposes. Again he ordered Jono Epstein (CSI) to pull funds from
various church corporations to pay for a massive distribution of
the booklet. Copies of the booklet were inserted in several major
newspapers in major cities. Thousands of copies were mailed out.
The cost for this project came to approximately $2 million and
was funded by reserve accounts from several church corporations,
as ordered by Miscavige.

Today Miscavige Has Completely Consolidated His Power

198. With Hubbard dead Miscavige moved quickly to
consolidate his power. In early 1987 he removed his only
remaining challengers, Pat and Annie Broeker. He also switched
his base of operations from ASI to RTC. It was a bloody coup.
Miscavige applied the scorched-earth policy to all who had ever
had a kind word for the Broekers. My husband, who had worked with
Pat Broeker, was sent to the RPF along with Vicki Aznaran, Greg
Ryerson, Jesse Prince, Spike Bush, and many others. Only those
who had remained steadfastly loyal to Miscavige were allowed to
keep their jobs.

199. Today, the only people who survive are those who kowtow
to Miscavige unreservedly and completely. He has truly become
Hubbard's successor. He curses like him, screams like him, thinks
like him, and rules with a ruthless, iron hand and a contempt for
the outside world just the way Hubbard did when he was alive.

200. Just as Hubbard did, Miscavige has created many
corporate layers between him and the courts, the IRS, other
governmental agencies and the outside world in general, and he
deals them like so many cards when it is convenient. But it is
Miscavige who really holds the power, and because he is COB RTC,
RTC is the only Scientology entity with any real power.

201. See Exhibit 34 for RTC Executive Directive No. 450,
dated 6 September 1991, from Miscavige to all Scientologists.
The first 22 pages of this document provide a valuable glimpse of
the world according to Miscavige, bizarre paranoia and all.

202. On page 22, Miscavige announces a general amnesty for
all Scientologists, meaning that anyone who has gotten into
trouble in the past is forgiven and can get back on the "Bridge
to Total Freedom." This amnesty cuts across all corporate
boundaries. The document behind it, Inspector General Network
Bulletin No. 14, is from one of Miscavige's lieutenants, former
Inspector General for Ethics RTC Marty Rathbun. This document
explains to all Scientologists how to apply the amnesty. It also
cuts across all corporate boundaries.

203. CSI is only a lackey corporation. The function of the
staff members of CSI is to carry out Miscavige's orders. If a CSI
staff member refuses to comply with Miscavige's orders he or she
is removed from post and sent to the RPF. CSI has no more
independent authority than any other church or non-church
corporation in the Scientology network. Its authority (indeed,
its existence) is solely in the hands of Miscavige. If he decided
to rearrange the corporate structure again he could do away with
CSI altogether and create an entirely new corporation in its
place. This is the extent of his power over the Scientology
network, including CSI and RTC.

204. There is no one else who can represent Scientology.
Everyone else is only speaking in Miscavige's place. He is
telling them what to say and what not to say, and if they make a
mistake, they will feel his wrath. If they make a big mistake,
they will go to the RPF. If they ever told the courts what they
really know, Miscavige would have them expelled from Scientology
and labelled Fair Game, like many others before them.

205. In short, the only person who is in a position to talk
about all of the inner workings of the Church of Scientology is
Miscavige, because he is the only person who will not be punished
for doing so. There is no one above him to punish him. He alone
can tell the whole truth. His lieutenants know the truth but can
tell what they know only if Miscavige gives them permission to do

Miscavige's Key Lieutenants Are Also Managing Agents of CSI

206. As COB RTC Miscavige controls Scientology via several
key lieutenants who have absolute authority to carry out his
orders. Although their official positions may have changed
corporately as described above, they still wield the same degree
of power. If any of these people have been removed from their
positions recently, they can still testify about the power they
had before they were removed, and furthermore, they can testify
that it was on Miscavige's authority that they were removed.
These lieutenants include Greg Wilhere, who held the position of
Inspector General RTC; Marty Rathbun, who held the position of
Inspector General for Ethics RTC; Ray Mithoff, who held the
position of Inspector General for Technology RTC and has
apparently since been moved to Senior Case Supervisor
International in CSI; and Marc Yager, who held the position of
Inspector General for Administration and has apparently since
been moved to Commanding Officer Ccmmodore's Messenger
Organization International in CSI. Another top aide is Norman
Starkey, who is the trustee of Hubbard's estate and the Executive
Director of ASI. He is also a troubleshooter for Miscavige.
Norman must be obeyed when he is operating under Miscavige's

Ray Mithoff is a Managing Agent of CSI

207. Senior C/S Int Ray Mithoff is a managing agent of CSI.
He has command lines via CSI to all churches, missions and any
other organizations that deal with the auditing and study
technology of Scientology. His primary contact points are the
Senior Case Supervisors in the various organizations. In CSI
these are in CM0 Int, Gold and OSA Int. All directives concerning
the technology must be authorized by Senior C/S Int, who in turn
must get approval from Miscavige.

Marc Yager is a Managinq Accent of CSI

208. CO CM0 Int Marc Yager is a managing agent of CSI. He is
responsible for managing all of Scientology administratively and
has command lines via CSI to all churches, missions and other
Scientology organizations, including OSA via WDC OSA (Mike
Rinder). His primary contact points are the executive directors
of each organization, called commanding officers in the upper
management Sea Org units. In CSI he orders via WDC and ED Int.
All directives concerning the administration of Scientology must
be authorized by CO CM0 Int, who in turn must get approval from

Marty Rathbun was a Managing Asent of CSI

209. When Marty Rathbun was Inspector General for Ethics, he
was a managing agent of CSI. He oversaw all ethics matters in
Scientology. Within each Scientology organization he had
authority over all actions taken by ethics officers. He also ran
the Office of Special Affairs, which deals with all matters
external to Scientology such as public relations, litigation,
intelligence actions, and so on. OSA also has an internal
security function within the Scientology organizations, and I/G
Ethics commanded all of those functions as well. He ran all OSA
activities via OSA Int, which is in CSI. All directives
concerning ethics matters within Scientology organizations, and
all directives concerning OSA activities of any kind, had to be
approved by I/G Ethics, who in turn had to have the approval of

Norman Starkey is a Managing Agent of CSI

210. Norman Starkey, Trustee of Hubbard's estate, is a
managing agent of CSI. Starkey has been one of Miscavige's most
senior lieutenants for many years. In 1981 Miscavige put Starkey
in charge of'the Guardian's Office, running all the Scientology
litigation in the world, particularly any litigation that
threatened Hubbard. As Special Project Legal, Starkey was one of
the people most senior to the Guardian's Office, which later
became OSA Int, which is part of CSI.

211. In 1982 Norman Starkey became Legal Affairs Director at
Author Services, Inc. (ASI) directly under Miscavige. Miscavige
was COB AS1 at the time and ran all of Scientology from this
for-profit corporation, a corporation which supposedly had no
ties whatsoever to the Church of Scientology. It had no corporate
ties, but in reality AS1 ran the entire church from 1982 until
1987, when Miscavige decided to move over to RTC and become COB
RTC. This was done because it was more defensible to run the
church from a nonprofit corporation than from ASI.

212. When Miscavige moved over to RTC, Starkey was trustee
of Hubbard's estate. He ran ASI and CST for Miscavige with no
position other than his initials, "NFS." He continued to send
orders into the church, but via a unit called Corporate Liaison
to dilute the connection.

213. In March 1985 Starkey filed a declaration in The
Founding Church of Scientoloqv of Washington, D.C., Inc. V.
Director, Federal Bureau of Investigation, et al. in which he
attempted to cover up Hubbard's role as managing agent of
Scientology (attached as Exhibit 35). As part of his declaration
he provided a white-washed version of how Author Services, Inc.
was established, describing it as if he and Terri Gamboa just
thought of the idea one day out of the blue, as opposed to
Hubbard ordering every last detail of the company and how it
would operate. He also attempted to distance ASI from the network
of Scientology organizations, falsely stating that ASI was not in
the business of managing the Church of Scientology, although all
aspects of Scientology management were at that time run out of
Miscavige's office at ASI.

214. But in paragraph 7 of his declaration Starkey made a
startling admission, namely that the Sea Organization called upon
him "from time to time" to render his services "to the
propagation of this religion."

215. What this means, and what is still the case, is that as
the senior officer of the sea Org, Miscavige can order Starkey to
carry out whatever orders he deems appropriate, including but not
limited to directing the affairs of CSI and, via CSI, other
Scientology organizations.

216. As the head of ASI, Starkey ran programs and projects
that were initiated by his juniors at AS1 who were ordering
church personnel in writing, in person, and on the phone on how
to conduct business within the church to produce income for ASI
(and, therefore, Hubbard). All of this was done with the
knowledge and consent, if not under the direct orders of
Miscavige. Regular reports were made by ASI staff to Starkey
regarding the programs, projects and orders he issued that
involved CSI staff and operations.

217. CSI President Heber Jentzsch received orders regularly
from Miscavige and Starkey on how to conduct his office and how
to conduct public relations actions as if they were his own ideas
(so as to hide the command lines from Miscavige and Starkey).

218. Church staff also know that disclosure of the
relationship between Starkey and CSI or any admission that AS1
was in direct command would have been reason to remove them from
their position and have them transported to the Rehabilitation
Project Force. (People on the RPF are kept under 24-hour guard to
keep them from escaping.)

Miscavige Ordered This Case Dismissed To Protect Himself

219. Dr. Geertz and Mr. Fishman would have won this case on
its merits had it gone forward. Instead, the Scientologists
staged an elaborate charade to avoid having the truth come out
not only at trial but also in depositions of Niscavige and !iis
key lieutenants. They thought they would be able to win this case
easily and then use it in their $485 million suit against Time

220. But they have finally met their match. Dr. Geertz's
attorneys Graham Berry and Gordon Calhoun educated themselves,
with the help of several former high-level Scientologists, about
how the organization actually works. They discovered what the
structure of the organization really is, that the Sea
Organization runs Scientology, and that Miscavige runs the Sea
Organization. They successfully pierced the corporate veil, and
the Scientologists saw that if they allowed this case to go to
trial, their carefully created public persona would explode into
a thousand pieces and they would be exposed for the criminal
conspirators they really are. This is why they sought to have
this case dismissed. It had nothing to do with any concern for
the Scientology celebrities whatsoever.

221. Miscavige feared that his own perjury and criminal
actions would be exposed, and he ordered the attorneys on this
case to do whatever they had to do to get rid of it before he had
to testify either in deposition or at trial. No one but Miscavige
has the authority to have ordered the Scientology attorneys to
file for dismissal. Without any doubt, Miscavige personally
orchestrated the dismissal of this case. See Exhibit 36, "Report
of the Board of Inquiry into Scientology," by Kevin Victor
Anderson, Q.C., the lieutenant governor of the State of Victoria,
in the Commonwealth of Australia. It is a th0ro.ughl.y researched
report on the dangers of Scientology, and includes an account on
pages 134 and 135 of a woman who was "processed into insanity."
This report led to Scientology being banned in Victoria for a
number of years. Although the ban was later lifted, the report
remains an excellent overview of the Scientology cult.
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 Corona de1 Mar, California, this 9th day of
March, 1994.


Stacy Brooks Young