Highly commended - Special Unit
Martin Ottmann
15 September 1983
SPECIAL UNIT CONDITIONS ORDER 24
ALL STAFF
HIGHLY COMMENDED
SPECIAL UNIT
CMDR LARRY BRENNAN and his team at Special Unit are all VERY HIGHLY
COMMENDED for the win over the squirrels in Perth, Australia. These
squirrels were rapidly defeated in the Supreme Court and ordered to
pay damages to the Church for their malicious actions.
Larry and his team are dedicated and ON SOURCE and are KEEPING
SCIENTOLOGY WORKING Internationally. Their hard work is very
appreciated. They are each awarded a $ 50 bonus.
COMMANDER VICKI AZNARAN
A/D/Inspector General
VA:iw
Desktop Stud
It is important to bear mind as well, in spite of the obvious value of this
document, that it is dated 1983, and possibly the church's financial
situation has changed since that time.
Certain people, not to mention names, from the local neighborhood, have
recieved bonuses in excess of $1,000,000.00 for less demanding work, than
that accomplished by the highly commended Sea Org Members mentioned in this
envy ridden document written by a staff member there to both awe and inspire
the church and its peers..
Desktop Stud
++++++++++++++++++++++++++++++++++++
Desktop Stud
"Martin Ottmann" <martin...@yahoo.com> wrote in message
news:71d327bb.02123...@posting.google.com...
Shy David
Ottmann) wrote:
Affidavit of Vicki Aznaran 7 Mar 1994
This affidavit is also available from ftp.primenet.com, www.sky.net
and ftp.lightlink.com. The HTML conversion was done by Bob Bingham.
----------------------------------------------------------------------
GRAHAM E. BERRY, State Bar No. 128503
GORDON J. CALHOUN, State Bar No. 84509
LEWIS, D'AMATO, BRISBOIS & BISGAARD
221 N. Figueroa Street, Suite 1200
Los Angeles, California 90012
Telephone: (213) 250-1800
Attorneys for Defendants
UWE GEERTZ, PH.D.
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
CHURCH OF SCIENTOLOGY No. CV 91-6426 HLH (Tx) INTERNATIONAL,
DECLARATION OF VICKI AZNARAN
Plaintiff, RE: MOTION FOR COSTS
VS. Date: APRIL 4, 1994
Time: 10:00 a.m.
STEVEN FISHMAN and UWE GEERTZ, Courtroom: 7
Defendants.
1. I, Vicki Aznaran, declare and say: I am over the age of eighteen
and a resident of Texas. I have personal knowledge of the matters set
forth in this declaration and if called upon to do so, I could and
would competently testify thereto.
2. Attached hereto as Exhibit A is a true and correct copy of a
declaration I executed July 18, 1990 for use in the case United States
of America v. Steven Fishman, Case No. XR-88-0616-DLT.The contents of
that declaration (Exhibit A) were true and correct when executed and
they remain true and correct as of the date of execution of this
declaration. The contents of Exhibit A are expressly incorporated
herein and made a part hereof.
MY BACKGROUND IN SCIENTOLOGY
3. I joined the Church of Scientology in 1972. In 1978, after
approximately four years as staff members, my husband and I joined the
Sea Organization. From 1978 to early 1987, my husband and I worked
most of our waking hours, with very few days off, at our various
assignments within Scientology.I eventually became President of
Religious Technology Center and, supposedly, the top "ecclesiastical"
authority within Scientology. Richard was a high-level security
officer. During this period my husband and I became intimately
familiar with the structure and activities of various Scientology
organizations. Among other things, I was briefed on and was sometimes
a participant in meetings involving litigation tactics and various
means used to attack and fight "enemies" of Scientology.
In numerous instances I was in the chain of command for approval for
such activities. From 1984 to 1987, I held the office of Inspector
General one of the highest worldwide offices in the organization and
so was privy to the most arcane practices of the group.
4. Between its incorporation in 1982 and 1987 when I left Scientology,
I was on the staff of the Religious Technology Center, (RTC). I held
the position that is now being held by David Miscavige. Since 1978, I
was a high ranking member of the Sea Organization, an elite
organization within Scientology. At the time I left Scientology I was
highly trained as a technical expert (Class 9 auditor) and an
administrator (Data Series evaluator course and organization executive
course). To complete the Organization Executive Course, one must study
all policy letters written by Hubbard which comprise a-large hardbound
volumes.
VAUGHN AND STACY YOUNG'S BACKGROUND IN SCIENTOLOGY
5. During my tenure as Inspector General of RTC, I knew both Vaughn
and Stacy Young well. They were well known to me because of their
Scientology staff positions. Vaughn Young was posted as L. Ron
Hubbard's personal public relations officer in Special Project which
later became ASI (Author Services, Inc.) Special Project as well as
ASI were headed by David Miscavige and Norman Starkey. LRH's personal
public relations officer has traditionally been a high ranking
position in Scientology. Vaughn Young was also charged with writing
Hubbard's biography after Gerald Armstrong (Sea Organization staff
member who was working on the biography along with author Omar
Garrison) left Scientology. This was during the period that Vaughn
worked as Hubbard's PR. Vaughn Young worked as Hubbard's PR after
Hubbard's death as well. Vaughn Young was summoned to Hubbard's ranch
after his death, just as Miscavige was. Miscavige was not summoned
prior to Hubbard's death. Hubbard only summoned Ray Mithoff just prior
to his death, and of course, Annie and Pat Brocker, who lived with
Hubbard exclusively during his last six years. In fact, Miscavige, and
a host of other staff members, myself and Vaughn Young included, who
were summoned to the ranch by the Brockers, were not those that
Hubbard wished to see before he died, as he summoned the only ones
that he wished to see. Miscavige was quite deflated over it. It is
apparent from Miscavige's declaration that he took it to mean Vaughn
Young and the others who came after Hubbard was gone, were not of any
significance.
6. In the early 1980's, Stacy Young was posted in Special Project as
the organizing officer. Special Project was headed by David Miscavige.
It had about 15 staff members total. Organizing Officer is a high
ranking post in any Scientology Organization. It is a member of the
executive council. Stacy Young was later posted at various posts in
OSA doing work as a PR. ASI was not a large organization, about 15
staff. At the time I was in RTC, ASI was a very high level
organization, placed above RTC in the chain of command. The staff of
ASI received their orders from L. Ron Hubbard, and his aide who lived
with him, Pat Brocker. When I was a staff member of a Scientology
mission from 1973 to 1978, I knew of Vaughn Young because he was a
very high profile spokesman for Scientology and the Guardian's Office.
SCIENTOLOGY OFFICIALS AVOIDING SERVICE OF PROCESS
7. It is routine policy for the upper executives of Scientology to
avoid service of process. This is why mere mid level executives, such
as the Reverend Heber Jentzsch, are appointed to corporate posts such
as President of Church of Scientology International. Corporate posts
have nothing to do with either power or the command chart in
Scientology. This policy was in place throughout my tenure in the
Commodore's Messenger Organization (from 1978 until 1987). This policy
is designed to keep those who knew Scientology's secrets from being in
a position where the secrets might be revealed. Hubbard went into
seclusion for his last years allowing only Pat and Annie Brocker
access to him, just for the purpose of avoiding service in lawsuits
and subpoenas in criminal matters. All security personnel are trained
to keep any and all process servers away from Scientology executives.
When David Miscavige was one of the targets of an IRS CID
investigation (there were several individuals targeted), he expressed
great concern over having to go to jail. Due to his diminutive size,
he was very concerned that he would be sexually harassed while in a
jail with common criminals." At this time he devised several schemes
to flee the country should the IRS decide to make arrests. Avoiding
service of process is a tactic that Miscavige is well acquainted with.
(See Attached Exhibit D). I recognize Exhibit B as being a copy of the
Scientology internal document Project Quaker with which I was familiar
whilst serving in various Scientology posts.
MISCAVIGE AS READ OF SCIENTOLOGY AND MANAGING AGENT OF THE VARIOUS
SCIENTOLOGY CORPORATIONS INCLUDING CSI.
8. David Miscavige was the Chairman of the Board of Author Services,
Inc., ("ASI") in 1984 and 1985. ASI was incorporated to be the funnel
through which profits from Scientology were channelled to L. Ron
Hubbard and, therefore, it was very important within Scientology.
Miscavige represented Hubbard in all aspects of controlling
Scientology. He attended regular meetings with myself and other top
officials of Scientology organizations to review the status of all
Scientology's activities, including its litigation and dirty tricks
campaigns against Scientology's enemies.
9. During the time I held the post of Chairman of the Board of RTC,
David Miscavige held the post of Chairman of the Board of ASI. During
this time, he maintained control of the executives at the top of
Scientology's command channels, Marc Yager, CO CMO Int and head of the
Watchdog Committee, Guillaume Lesevre, ED International, Ray Mithoff,
Senior C/S International, myself as Inspector General and COB of RTC.
Miscavige became head of RTC in March of 1987, at this point he moved
Marc Yager and Ray Mithoff from their positions in CSI into RTC. He
also moved Mark Rathbun, LRH Legal IC or Special Project L, and Greg
Wilhere from their positions in ASI into RTC. I now see from the
declarations of Marc Yager and Ray Mithoff, that Miscavige has now
placed them back into CSI. This is but one small illustration of his
ongoing control over the CSI corporation.
10. Miscavige has, since 1981, been the decision maker over what
lawsuits are filed by Scientology and how any lawsuits Scientology is
engaged in are to be litigated. He does this without regard to the
particular Scientology corporate entity (s) involved in the
litigation. Miscavige has never allowed anyone else to make the final
decisions concerning such matters. During my tenure as Inspector
General of RTC, as well as the head of the 040 mission which took over
the US Guardian's Office, as outlined in Miscavige's declaration, I
attended many meetings and saw countless orders from Miscavige
concerning Scientology's litigation. During all trials, Miscavige
receives daily transcripts and issues orders directly to the
attorneys, no matter which particular Scientology corporate entity has
been chosen to bring the litigation or which entity has been sued. The
heads of CSI would never be allowed to independently bring or initiate
a lawsuit. During my tenure in RTC, Miscavige received a "legal daily
report", of which I received a copy. This report contained summaries
of everything that occurred on any of Scientology's lawsuits.
Miscavige would issue orders and call meetings concerning these
matters on a regular basis. Litigation is very costly and can result
in severely adverse PR. Therefore, Miscavige was never willing for the
decisions concerning it to be turned over to anyone else.
THE DEATH OF FLO BARNETT
11. Flo Barnett's suicide was a scandal within the inner circles of
Scientology. This was not due to the fact that she supposedly
committed suicide, but due to the fact that she had become a member of
a declared enemy group, David Mayo's Advanced Ability Center. She was
receiving auditing and assistance from this group and at the time of
her death, possessed a pack of the NED for OTS (secret upper level
auditing procedures) which were believed to have come from David
Mayo's group. Flo Barnett's membership in this group made her a
suppressive person as she was actively "squirreling" and a member of a
suppressive group. The fact that David Miscavige was linked to her by
familial ties was extremely repugnant to him and to his wife, Michelle
Miscavige. David Miscavige's comment upon her death was that "the
bitch got what she deserved." His wife Shelly, did not appear to feel
any different about it than David. I asked Shelly if she was doing
alright since receiving this bad news. She said that personally she
was doing just fine and that this was an excellent opportunity to find
out where the NED for OTs materials had come from and to use it as
leverage against Mayo. She also stated that it was not surprising that
this happened to her mother since she had been "squirelling". The
circumstances of the deaths of both Flo Barnett and Yvonne Jentzsch
are very relevant to the issues in this case, as I understand them to
be.
THE PURPORTED PURGE OF THE SCIENTOLOGY CRIMINALS
12. Hendrick Moxon, currently an attorney for Scientology in this very
case, and a member of the Sea Organization, was a prominent
participant in the criminal activities of the Guardian's Office. Prior
to becoming an attorney at Scientology's expense, he was a Guardian's
Office staff member in Washington, D.C. Moxon was involved in the
Scientology conspiracy to infiltrate the U.S. government. This
conspiracy was uncovered by the F.B.I. in 1977. Scientology then
stipulated to their crimes which included Moxon's involvement in those
crimes. Nine senior Scientologists, including Hubbards' wife, went to
jail as a result of these criminal activities conducted by, and on
behalf of, the Church of Scientology. I became familiar with certain
documents, which are attached hereto, while being in charge of the
1981/82 040 mission to take over the USGO. Moxon was involved in the
criminal activity, attempted cover-ups and obstruction of justice. The
US government subsequently prosecuted 11 top officials of Scientology
and named Moxon as an unindicted co-conspirator. (See Exhibit C, pages
212-214). This is but one small example to illustrate that Miscavige
has not and will never offload the criminal element from Scientology's
ranks. Miscavige is well aware of Moxon's status and maintains him as
a high level legal staff in the Sea Organization.
As a practicing Scientologist and in-house Scientology lawyer,
Kendrick Moxon's first duty is to protect Miscavige and Scientology.
This duty is paramount to any duty he might otherwise owe the Court or
the law.
13. Scientology was created by L. Ron Hubbard in the 1950's. The
policies and beliefs of Scientology were established by L. Ron
Hubbard. L. Ron Hubbard created the Guardian's office based on his
beliefs and ideals. The Guardian's Office was headed by his wife, Mary
Sue Hubbard. During the late 1960's and the 1970's, many, many crimes
were committed internationally by the Guardian's Office. Hubbard was
well aware of the Guardian's Office activities and this is apparent
from the reams of paper containing his various orders to the
Guardian's Office.
The policies and beliefs and ideals that established Scientology and
the Guardian's Office are still in place today, just as they were in
the 1950's, 1960's, 1970's and 1980's. These have not changed as it is
against the very heart of Scientology to change or alter any of
Hubbard's teachings and belief. The activities of the Guardian's
Office have not disappeared any more than Scientology's "enemies"
have. These activities are carried on by the staff of the Office of
Special Affairs ("OSA") and their hired private investigators who
ostensibly work for Scientology lawyers, and are thus protected by the
attorney work product privilege.
Scientology learned the hard way to keep its criminal activities at
arm's length. An example of this is private investigator, Eugene
Ingram, who was hired by Miscavige, to get the evidence on adverse
attorney, Michael Flynn, for supposedly forging a check on L. R.
Hubbard's account. Ingram paid money to Ala Tamimi, a criminal in
jail, for a statement saying he was hired to forge the check by
Michael Flynn. I was then informed by Mark Rathbun, then Miscavige's
legal executive in ASI, that Ingram bribed Tamimi in order to get
Michael Flynn charged criminally. After this incident failed, I
learned that Ingram was spending quite some time living in Mexico in
order to avoid the authorities investigating the matter.
MISCAVIGE STRIKING SCIENTOLOGY STAFFERS
14. Contrary to the claims in his February 4, 1994, declaration
Miscavige has struck staff members when they do things he dislikes.
In 1981, I witnessed him hitting John Axel, a Sea Org member in the
mouth in 1982. Miscavige had two other tall male staff members to back
him up when he hit John Axel. This despite the fact that John Axel is
a fairly small and very mild-mannered individual. Miscavige also does
such things as set up photos of staff members who have fallen into
disregard and use them as targets for pistol shooting.
I witnessed him doing this with the Golden Era Musicians, Of which
Fernando Gamboa was one of his targets.
THE DEATH OF HUBBARD
15. When I arrived at Hubbard's ranch, in San Luis Obispo, following
his death, I was informed by Miscavige that Hubbard was dead and that
he did not want to see "any grief bullshit about it."
Earl Cooley, Esq. and others convinced the San Luis Obispo coroner not
to do an autopsy on Hubbard's body which was cremated approximately 24
hours after death. Miscavige then announced to the Scientology world
that Hubbard had "dropped the body" and would continue his work
elsewhere. Scientologists believe that upon death the person drops the
body, picks up another body and continues to serve Scientology. This
is how the billion year Sea Organization employment contract is
performed.
16. I was aware just before Hubbard's death, that certain IRS
indictments were about to be handed down against Hubbard. Miscavige
reportedly said that "the only way to stop it now is if the old man
[Hubbard] dies."
17. I was one of the small group summoned to the Hubbard ranch after
he died. Vaughn Young and David Miscavige were also summoned to the
ranch.
THE DEATH OF MIKE RINDER'S BABY
18. Mike Rinder, a member of the CMO International and his wife,
Kathy, had a newborn baby in Clearwater, Florida in the early
eighties. Mike Rinder was in Gilman Hot Springs, California at the
time. This baby died when only a few days old. The baby had received
Hubbard's baby care technology. After the baby died, Rinder asked to
receive some time off to go to be with his wife and family.
When Miscavige was told of this, he responded that time off was
"bullshit" and Rinder did not need time off, he just needed to work as
his stats ("statistics") were down. Besides the baby would get another
body and there was nothing to be so upset about.
END OF CYCLE PROCESSING
19. The term "End of Cycle" does exist in Scientology. it means to
terminatedly end something. There are many Scientology processes and
routines that incorporate this concept. The idea that someone ends
cycle when they die is a Scientology concept and is expressed in
Hubbard's writings. (See attached Exhibit D)
THE TIME MAGAZINE ARTICLE WAS NOT OF AND CONCERNING CSI
20. I have read the Time Magazine article entitled "Scientology
Thriving Cult of Greed and Power" published on May 6, 1991. In
particular, I have read two paragraphs of that article concerning
comments allegedly attributed to Steven Fishman and Dr. Uwe Geertz.
There are references to "Scientology" and "the church" in these two
paragraphs. I have also been advised by Graham E. Berry, Esq., that
the Church of Scientology International alleges that the words
"Scientology" and "the Church" were "of and concerning" Church of
Scientology International ("CSI"). This allegation is absurd and
false. CSI is a management church only. It has no members. In essence,
it is a trademark/copyright licensing vehicle and a financial conduit.
Moreover, the corporations of Scientology are a carefully contrived
sham and shell structure intended to confuse and divert litigants, the
courts and the I.R.S. Indeed, Mission Corporate category sort out
("MCCS"), of which the MCCS tapes were a part, (see the Zolin case)
was part of the creation of this corporate shell game.
21. Accordingly, it is absurd to allege that the words "Scientology"
and "the church", as used in the relevant sections of the Time
Magazine article, refer to anything other than Scientology or the
Church generally and/or generically. Certainly, they are not of and
concerning CSI.
SUPPRESSIVE PERSONS AND FAIR GAME
22. The legal strategy of Scientology and the existence of numerous
potential legal problems, some of which are set forth below, were
known to me when I was a staff member in Scientology.. Enemies of
Scientology are deemed to be "suppressive persons" ("SPs"). One
becomes a "suppressive person" by doing a suppressive act, such as
suing Scientology as a litigant or lawyer. In the jargon of
Scientology, when one is "declared" this means that one has been
declared a "suppressive person" and, therefore, may be harassed, hurt,
damaged or destroyed without regard to truth, honesty or legal rights.
It is considered acceptable within Scientology to lie, cheat, steal
and commit illegal acts in the name of dealing with a "suppressive
person."
23. This practice or policy is sometimes referred to as the policy of
"fair game." In the jargon of Scientology, a person who is declared is
understood to be a suppressive person ("SP") . This means that the
person is "fair game." The fair game policy was issued in the 1960s.
It was never canceled. A document was issued for public relations
reasons that purportedly canceled "fair game"; however, that document
stated that it did not change the manner of handling persons declared
"SP." In reality, the purported cancellation of fair game is at most a
matter of semantics. Enemies of Scientology are treated as fair game.
24. Because of my position and the regular reports that came across my
desk I know that throughout my presidency of RTC, fair game actions
against enemies were commonplace. In addition to the litigation
tactics described below, fair game activities included burglaries,
assaults, disruptions of enemies' businesses, spying, harassive
investigations, abuse of confidential communications in parishioner
files and so on. I specifically recall seeing one report regarding
attacks against Bent Corydon after Scientology became aware that he
was writing a book against Hubbard.
FRIVOLOUS SCIENTOLOGY LITIGATION
25. Other Hubbard writings encourage Scientologists to pursue
litigation purely for harassment without regard to the merits of a
claim to cause enemies to fold. Hubbard's writings state: "The purpose
of the suit is to harass and discourage rather than to win ... The law
can be used very easily to harass and ... Will generally be sufficient
to cause (the enemy's) professional decease. If possible, of course
ruin him utterly." (Hubbard, "Magazine articles on Level 0 Checksheet"
American Saint Hill Organization 1968.)
26. As President of RTC and a Sea Organization member, I attended
meetings concerning the numerous legal actions involving Scientology
organizations. During this time period, I had personal access to all
legal documents having to do with RTC. I received a report every day
on my computer that included a synopsis of each on-going legal case
involving Scientology. I received, or so I was told, copies of every
major motion filed in cases involving Scientology was on the "approval
lines" for legal documents dealing with RTC.
During this time period, I had the option of attending legal meetings,
although some were mandatory. I attended many litigation meetings and
became generally aware of Scientology's dirty tricks and legal
maneuvers. On specifics, I frequently deferred to in-house and outside
counsel; however, at least in theory, I was the head of RTC and had
access to any business or litigation "secrets" of Scientology.
27. It is the stated policy and practice of Scientology to use the
legal system to abuse and harass its enemies. This crude, fundamental
directive of Scientology is no secret. The policy is to do anything
and everything possible to harass the opposing litigant without regard
to whether any particular motion or maneuver is appropriate or
warranted by the facts of applicable law. That policy was followed in
every legal case I was involved with or learned about while a member
of the Sea Organization. The management of Scientology consistently
expressed and demonstrated a complete disdain for the court system,
viewing it as nothing more than a method to harass enemies. Some
examples of this are set forth below.
SCIENTOLOGY DESTROYS EVIDENCE AND REWRITES HISTORY
28. During litigation between Gerald Armstrong and Scientology, which
was before Judge Breckenridge of Superior Court for Los Angeles
County, the court ordered the production of Armstrong's preclear
("PC") folders - These are files maintained by Scientology on those
who submit to interrogation sessions in a process called auditing.
During the course of that litigation I was ordered to go through
Armstrong's folders and destroy or conceal anything that might support
Armstrong's claim against Scientology. This practice is known within
Scientology as "culling PC folders" and is a common litigation tactic
employed by Scientology.
29. During other-litigation in Los Angeles known to me as the
Wollersheim case, I was told that the judge had ordered the production
of Wollersheim's folders. As ordered, I "culled" these files. In other
words, I removed contents that might have been damaging to Scientology
or might have supported Wollersheim's claims against Scientology. For
example, I removed evidence of events involving his family, the
anguish this caused him, evidence of disconnection from family and
evidence of fair game.
30. I was involved in numerous meetings concerning what is known to me
as the Christofferson case in Portland, Oregon. This case was tried
twice. In the first case, a Scientology witness by the name of Martin
Samuels was coached and drilled for hours on how to lie convincingly
or avoid telling the truth. Before or during the second trial, he
admitted to this course of conduct. In this litigation, a
Scientologist by the name of Joan Shriver produced responsive
documents that may have been incriminating. This was a serious breach
of policy for which she was punished. These documents were ordered
produced on such a short notice that apparently files were not
thoroughly "culled". In another case, an attorney was severely
criticized and almost fired for failing to properly coach and feed the
desired answers to Heber Jentzsch. Mr. Jentzsch was, for public
relations reasons, the purported head of the Church of Scientology
International. During his deposition, Mr. Jentzsch was unable to
answer fundamental questions concerning the management of Church of
Scientology International.
31. While involved in Scientology I became aware of various operations
directed against an author who had written a negative book about
Scientology. The author, Paulette Cooper, was subjected to various
forms of harassment. One operation included an attempt to frame her. A
false bomb threat was written on her stationery. Ms. Cooper was
subjected to an investigation and was not cleared until an FBI raid
resulted in the seizure of Scientology documents that exposed the
operation as a frame-up. There was at least one other operation
directed against Ms. Cooper. The substance of it was to plant a
boyfriend to reinforce and play upon her suicidal tendencies in the
hopes that she would commit suicide.
32. In 1976 and 1977, the then Mayor of Clearwater, Florida, Gabe
Cazares, was involved with litigation against Scientology.
Arrangements were made to have an attorney by the name of Merrit
Vanniere, a Scientologist, represent Mr. Cazares and sabotage his
case. This plot was also exposed by documents obtained in an FBI raid
of a Scientology facility. Also, in response to Mr. Cazares'
litigation against Scientology, an attempt was made to implicate Mr.
Cazares in a staged hit and run accident.
33. In later 1979 and early 1980, there was a massive document
destruction program undertaken to destroy any evidence showing that L.
Ron Hubbard ("LRH") controlled Scientology. I participated in this
activity in Clearwater, Florida and am informed that there was also
intensive document destruction at facilities in Gilman Hot Springs,
California. From at least that point onward there was a continuous
effort to hide or destroy any evidence of Hubbard's control. For
example, during an IRS investigation in 1984 and 1985, while in bed
with pneumonia, I was ordered out of bed by Norman Starkey, who told
me that they had received a tip from a Los Angeles police officer
advising them of a pending IRS raid in Los Angeles.
Mr. Starkey ordered me to go to a computer facility and insure that
all information on the computers in Los Angeles that might show
Hubbard's involvement and control of Scientology's money was destroyed
except for one copy of each document. These copies were to be saved on
computer disks which were to be hidden in secure storage places. At
the time I was also instructed to destroy anything that would show the
control of Mr. Starkey or Mr. Miscavige over Scientology.
SCIENTOLOGY INFILTRATES THE U.S. GOVERNMENT
34. In or about 1981, while working in a Scientology organization
known as the Guardian's Office, I had access to and observed various
written and oral communication pertaining to illegitimate activities
participated in by the Guardian's Office. The Guardian's Office
attempted to infiltrate both governmental and private agencies
including the IRS, the Department of Justice, the American Medical
Association and the National Institute of Mental Health. The purpose
of this was to steal documents pursuant to Hubbard's "Snow White"
program. The goal of this program was to eliminate any negative
reports about Hubbard and Scientology that may have been held by these
various agencies.
FISHMAN ALLEGATIONS ARE CREDIBLE
35. I have examined certain documents regarding Steven Fishman's
experience with Scientology, have had conversations with Mr. Fishman's
counsel, in his criminal prosecution and I have reviewed the 1151-page
autobiographical account of Mr. Fishman's Scientology experience
entitled "The Lonesome Squirrel." Based on my 15 years of experience
in Scientology and my review of the Fishman materials, I offer the
following opinions and conclusions.
A. I believe Mr. Fishman's assertions that he was a member since 1979
and that he was actively involved as he states. This belief is based
on my experience that only a committed member of long standing would
know the details of the inner workings of the group; Mr. Fishman has
such knowledge. Awareness of certain confidential projects could be
achieved only by a member who was trusted by the hierarchy; Mr.
Fishman had such awareness. Involvement in a group that thrives on
secrecy and excludes most members from participation in high level
projects means that any member who exceeds a certain level of
involvement enjoys the trust of the leadership such trust would be
earned only by extended membership. Mr. Fishman apparently enjoyed
that trust. His accounts of meetings with high level officials and his
knowledge of the operations and functions of the hierarchy are so
detailed and accurate that they couldn't have been gained except
through direct personal experience.
B. Refutation by Scientology officials of Mr. Fishman's membership
prior to February 8, 1986 and their disclaimer of his involvement and
their lack of any records pertaining to such membership is perfectly
consistent with their standard procedure in protecting themselves. As
noted above, I was personally involved in the destruction of records
when it suited their purpose. Scientology propounds the belief that
any action whatever taken to protect the organization is justified, as
the group takes precedence over the individual. Any member performing
criminal acts for the benefit of the group was kept at arm's length;
if apprehended, the member was disavowed by Scientology. This
procedure was used even on the wife of the founder of Scientology.
Given the serious potential threat that Mr. Fishman's defense posed to
the group, I find Mr. Fishman's account of certain members of
Scientology's involvement in the plan to fabricate the threats against
Mr. Fishman and his counsel and to thereby undermine Mr. Fishman's
credibility and render him useless as a witness against Scientology is
consistent with their modus operandi.
I declare under penalty of perjury under the laws of the United States
of America that the foregoing is true and correct.
Executed this 7th day of March, 1994 at Dallas, Tx.
========
GRAHAM E. BERRY, State Bar No. 128503
GORDON J. CALHOUN, State Bar No. 84509
LEWIS, D'AMATO, BRISBOIS & BISGAARD
221 N. Figueroa Street, Suite 1200
Los Angeles, California 90012
Telephone: (213) 250-1800
Attorneys for Defendants
UWE GEERTZ, PH.D.
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
CHURCH OF SCIENTOLOGY No. CV 91-6426 HLH (Tx) INTERNATIONAL,
DECLARATION OF VICKI AZNARAN
Plaintiff, RE: MOTION FOR COSTS
VS. Date: APRIL 4, 1994
Time: 10:00 a.m.
STEVEN FISHMAN and UWE GEERTZ, Courtroom: 7
Defendants.
I, Vicki Aznaran, declare and say: I am over the age of eighteen and a
resident of Texas. I have personal knowledge of the matters set forth
in this declaration and if called upon to do so, I could and would
competently testify thereto.
2. Attached hereto as Exhibit A is a true and correct copy of a
declaration I executed July 18, 1990 for use in the case United States
of America v. Steven Fishman, Case No. XR-88-0616-DLT.The contents of
that declaration (Exhibit A) were true and correct when executed and
they remain true and correct as of the date of execution of this
declaration. The contents of Exhibit A are expressly incorporated
herein and made a part hereof.
MY BACKGROUND IN SCIENTOLOGY
3. I joined the Church of Scientology in 1972. In 1978, after
approximately four years as staff members, my husband and I joined the
Sea Organization. From 1978 to early 1987, my husband and I worked
most of our waking hours, with very few days off, at our various
assignments within Scientology.I eventually became President of
Religious Technology Center and, supposedly, the top "ecclesiastical"
authority within Scientology. Richard was a high-level security
officer. During this period my husband and I became intimately
familiar with the structure and activities of various Scientology
organizations. Among other things, I was briefed on and was sometimes
a participant in meetings involving litigation tactics and various
means used to attack and fight "enemies" of Scientology.
In numerous instances I was in the chain of command for approval for
such activities. From 1984 to 1987, I held the office of Inspector
General one of the highest worldwide offices in the organization and
so was privy to the most arcane practices of the group.
4. Between its incorporation in 1982 and 1987 when I left Scientology,
I was on the staff of the Religious Technology Center, (RTC). I held
the position that is now being held by David Miscavige. Since 1978, I
was a high ranking member of the Sea Organization, an elite
organization within Scientology. At the time I left Scientology I was
highly trained as a technical expert (Class 9 auditor) and an
administrator (Data Series evaluator course and organization executive
course). To complete the Organization Executive Course, one must study
all policy letters written by Hubbard which comprise a-large hardbound
volumes.
VAUGHN AND STACY YOUNG'S BACKGROUND IN SCIENTOLOGY
5. During my tenure as Inspector General of RTC, I knew both Vaughn
and Stacy Young well. They were well known to me because of their
Scientology staff positions. Vaughn Young was posted as L. Ron
Hubbard's personal public relations officer in Special Project which
later became ASI (Author Services, Inc.) Special Project as well as
ASI were headed by David Miscavige and Norman Starkey. LRH's personal
public relations officer has traditionally been a high ranking
position in Scientology. Vaughn Young was also charged with writing
Hubbard's biography after Gerald Armstrong (Sea Organization staff
member who was working on the biography along with author Omar
Garrison) left Scientology. This was during the period that Vaughn
worked as Hubbard's PR. Vaughn Young worked as Hubbard's PR after
Hubbard's death as well. Vaughn Young was summoned to Hubbard's ranch
after his death, just as Miscavige was. Miscavige was not summoned
prior to Hubbard's death. Hubbard only summoned Ray Mithoff just prior
to his death, and of course, Annie and Pat Brocker, who lived with
Hubbard exclusively during his last six years. In fact, Miscavige, and
a host of other staff members, myself and Vaughn Young included, who
were summoned to the ranch by the Brockers, were not those that
Hubbard wished to see before he died, as he summoned the only ones
that he wished to see. Miscavige was quite deflated over it. It is
apparent from Miscavige's declaration that he took it to mean Vaughn
Young and the others who came after Hubbard was gone, were not of any
significance.
6. In the early 1980's, Stacy Young was posted in Special Project as
the organizing officer. Special Project was headed by David Miscavige.
It had about 15 staff members total. Organizing Officer is a high
ranking post in any Scientology Organization. It is a member of the
executive council. Stacy Young was later posted at various posts in
OSA doing work as a PR. ASI was not a large organization, about 15
staff. At the time I was in RTC, ASI was a very high level
organization, placed above RTC in the chain of command. The staff of
ASI received their orders from L. Ron Hubbard, and his aide who lived
with him, Pat Brocker. When I was a staff member of a Scientology
mission from 1973 to 1978, I knew of Vaughn Young because he was a
very high profile spokesman for Scientology and the Guardian's Office.
SCIENTOLOGY OFFICIALS AVOIDING SERVICE OF PROCESS
7. It is routine policy for the upper executives of Scientology to
avoid service of process. This is why mere mid level executives, such
as the Reverend Heber Jentzsch, are appointed to corporate posts such
as President of Church of Scientology International. Corporate posts
have nothing to do with either power or the command chart in
Scientology. This policy was in place throughout my tenure in the
Commodore's Messenger Organization (from 1978 until 1987). This policy
is designed to keep those who knew Scientology's secrets from being in
a position where the secrets might be revealed. Hubbard went into
seclusion for his last years allowing only Pat and Annie Brocker
access to him, just for the purpose of avoiding service in lawsuits
and subpoenas in criminal matters. All security personnel are trained
to keep any and all process servers away from Scientology executives.
When David Miscavige was one of the targets of an IRS CID
investigation (there were several individuals targeted), he expressed
great concern over having to go to jail. Due to his diminutive size,
he was very concerned that he would be sexually harassed while in a
jail with common criminals." At this time he devised several schemes
to flee the country should the IRS decide to make arrests. Avoiding
service of process is a tactic that Miscavige is well acquainted with.
(See Attached Exhibit D). I recognize Exhibit B as being a copy of the
Scientology internal document Project Quaker with which I was familiar
whilst serving in various Scientology posts.
MISCAVIGE AS READ OF SCIENTOLOGY AND MANAGING AGENT OF THE VARIOUS
SCIENTOLOGY CORPORATIONS INCLUDING CSI.
8. David Miscavige was the Chairman of the Board of Author Services,
Inc., ("ASI") in 1984 and 1985. ASI was incorporated to be the funnel
through which profits from Scientology were channelled to L. Ron
Hubbard and, therefore, it was very important within Scientology.
Miscavige represented Hubbard in all aspects of controlling
Scientology. He attended regular meetings with myself and other top
officials of Scientology organizations to review the status of all
Scientology's activities, including its litigation and dirty tricks
campaigns against Scientology's enemies.
9. During the time I held the post of Chairman of the Board of RTC,
David Miscavige held the post of Chairman of the Board of ASI. During
this time, he maintained control of the executives at the top of
Scientology's command channels, Marc Yager, CO CMO Int and head of the
Watchdog Committee, Guillaume Lesevre, ED International, Ray Mithoff,
Senior C/S International, myself as Inspector General and COB of RTC.
Miscavige became head of RTC in March of 1987, at this point he moved
Marc Yager and Ray Mithoff from their positions in CSI into RTC. He
also moved Mark Rathbun, LRH Legal IC or Special Project L, and Greg
Wilhere from their positions in ASI into RTC. I now see from the
declarations of Marc Yager and Ray Mithoff, that Miscavige has now
placed them back into CSI. This is but one small illustration of his
ongoing control over the CSI corporation.
10. Miscavige has, since 1981, been the decision maker over what
lawsuits are filed by Scientology and how any lawsuits Scientology is
engaged in are to be litigated. He does this without regard to the
particular Scientology corporate entity (s) involved in the
litigation. Miscavige has never allowed anyone else to make the final
decisions concerning such matters. During my tenure as Inspector
General of RTC, as well as the head of the 040 mission which took over
the US Guardian's Office, as outlined in Miscavige's declaration, I
attended many meetings and saw countless orders from Miscavige
concerning Scientology's litigation. During all trials, Miscavige
receives daily transcripts and issues orders directly to the
attorneys, no matter which particular Scientology corporate entity has
been chosen to bring the litigation or which entity has been sued. The
heads of CSI would never be allowed to independently bring or initiate
a lawsuit. During my tenure in RTC, Miscavige received a "legal daily
report", of which I received a copy. This report contained summaries
of everything that occurred on any of Scientology's lawsuits.
Miscavige would issue orders and call meetings concerning these
matters on a regular basis. Litigation is very costly and can result
in severely adverse PR. Therefore, Miscavige was never willing for the
decisions concerning it to be turned over to anyone else.
THE DEATH OF FLO BARNETT
11. Flo Barnett's suicide was a scandal within the inner circles of
Scientology. This was not due to the fact that she supposedly
committed suicide, but due to the f act that she had become a member
of a declared. enemy group, David Mayo's Advanced Ability Center. She
was receiving auditing and assistance from this group and at the time
of her death, possessed a pack of the NED for OTS (secret upper level
auditing procedures) which were believed to have come from David
Mayo's group. Flo Barnett's membership in this group made her a
suppressive person as she was actively "squirreling" and a member of a
suppressive group. The fact that David Miscavige was linked to her by
familial ties was extremely repugnant to him and to his wife, Michelle
Miscavige. David Miscavige's comment upon her death was that "the
bitch got what she deserved." His wife Shelly, did not appear to feel
any different about it than David. I asked Shelly if she was doing
alright since receiving this bad news. She said that personally she
was doing just fine and that this was an excellent opportunity to find
out where the NED for OTs materials had come from and to use it as
leverage against Mayo. She also stated that it was not surprising that
this happened to her mother since she had been "squirelling". The
circumstances of the deaths of both Flo Barnett and Yvonne Jentzsch
are very relevant to the issues in this case, as I understand them to
be.
THE PURPORTED PURGE OF THE SCIENTOLOGY CRIMINALS
12. Hendrick Moxon, currently an attorney for Scientology in this very
case, and a member of the Sea Organization, was a prominent
participant in the criminal activities of the Guardian's Office. Prior
to becoming an attorney at Scientology's expense, he was a Guardian's
Office staff member in Washington, D.C. Moxon was involved in the
Scientology conspiracy to infiltrate the U.S. government. This
conspiracy was uncovered by the F.B.I. in 1977. Scientology then
stipulated to their crimes which included Moxon's involvement in those
crimes. Nine senior Scientologists, including Hubbards, wife, went to
jail as a result of these criminal activities conducted by, and on
behalf of, the Church of Scientology. I became familiar with certain
documents, which are attached hereto, while being in charge of the
1981/82 040 mission to take over the USGO. Moxon was involved in the
criminal activity, attempted cover-ups and obstruction of justice. The
US government subsequently prosecuted 11 top officials of Scientology
and named Moxon as an unindicted co-conspirator. (See Exhibit C, pages
212-214). This is but one small example to illustrate that Miscavige
has not and will never offload the criminal element from Scientology's
ranks. Miscavige is well aware of Moxon's status and maintains him as
a high level legal staff in the Sea Organization.
As a practicing Scientologist and in-house Scientology lawyer,
Kendrick Moxon's first duty is to protect Miscavige and Scientology.
This duty is paramount to any duty he might otherwise owe the Court or
the law.
13. Scientology was created by L. Ron Hubbard in the 1950's. The
policies and beliefs of Scientology were established by L. Ron
Hubbard. L. Ron Hubbard created the Guardian's office based on his
beliefs and ideals. The Guardian's Office was headed by his wife, Mary
Sue Hubbard. During the late 1960's and the 1970's, many, many crimes
were committed internationally by the Guardian's Office. Hubbard was
well aware of the Guardian's Office activities and this is apparent
from the reams of paper containing his various orders to the
Guardian's Office.
The policies and beliefs and ideals that established Scientology and
the Guardian's Office are still in place today, just as they were in
the 1950's, 1960's, 1970's and 1980's. These have not changed as it is
against the very heart of Scientology to change or alter any of
Hubbard's teachings and belief. The activities of the Guardian's
Office have not disappeared any more than Scientology's "enemies"
have. These activities are carried on by the staff of the Office of
Special Affairs ("OSA") and their hired private investigators who
ostensibly work for Scientology lawyers, and are thus protected by the
attorney work product privilege.
Scientology learned the hard way to keep its criminal activities at
arm's length. An example of this is private investigator, Eugene
Ingram, who was hired by Miscavige, to get the evidence on adverse
attorney, Michael Flynn, for supposedly forging a check on L. R.
Hubbard's account. Ingram paid money to Ala Tamimi, a criminal in
jail, for a statement saying he was hired to forge the check by
Michael Flynn. I was then informed by Mark Rathbun, then Miscavige's
legal executive in ASI, that Ingram bribed Tamimi in order to get
Michael Flynn charged criminally. After this incident failed, I
learned that Ingram was spending quite some time living in Mexico in
order to avoid the authorities investigating the matter.
MISCAVIGE STRIKING SCIENTOLOGY STAFFERS
14. Contrary to the claims in his February 4, 1994, declaration
Miscavige has struck staff members when they do things he dislikes.
In 1981, I witnessed him hitting John Axel, a Sea Org member in the
mouth in 1982. Miscavige had two other tall male staff members to back
him up when he hit John Axel. This despite the fact that John Axel is
a fairly small and very mild-mannered individual. Miscavige also does
such things as set up photos of staff members who have fallen into
disregard and use them as targets for pistol shooting.
I witnessed him doing this with the Golden Era Musicians, Of which
Fernando Gamboa was one of his targets.
THE DEATH OF HUBBARD
15. When I arrived at Hubbard's ranch, in San Luis Obispo, following
his death, I was informed by Miscavige that Hubbard was dead and that
he did not want to see "any grief bullshit about it."
Earl Cooley, Esq. and others convinced the San Luis Obispo coroner not
to do an autopsy on Hubbard's body which was cremated approximately 24
hours after death. Miscavige then announced to the Scientology world
that Hubbard had "dropped the body" and would continue his work
elsewhere. Scientologists believe that upon death the person drops the
body, picks up another body and continues to serve Scientology. This
is how the billion year Sea Organization employment contract is
performed.
16. I was aware just before Hubbard's death, that certain IRS
indictments were about to be handed down against Hubbard. Miscavige
reportedly said that "the only way to stop it now is if the old man
[Hubbard] dies."
17. I was one of the small group summoned to the Hubbard ranch after
he died. Vaughn Young and David Miscavige were also summoned to the
ranch.
THE DEATH OF MIKE HINDER'S BABY
18. Mike Rinder, a member of the CMO International and his wife,
Kathy, had a newborn baby in Clearwater, Florida in the early
eighties. Mike Rinder was in Gilman Hot Springs, California at the
time. This baby died when only a few days old. The baby had received
Hubbard's baby care technology. After the baby died, Rinder asked to
receive some time off to go to be with his wife and family.
When Miscavige was told of this, he responded that time off was
"bullshit" and Rinder did not need time off, he just needed to work as
his stats ("statistics") were down. Besides the baby would get another
body and there was nothing to be so upset about.
END OF CYCLE PROCESSING
19. The term "End of Cycle" does exist in Scientology. it means to
terminatedly end something. There are many Scientology processes and
routines that incorporate this concept. The idea that someone ends
cycle when they die is a Scientology concept and is expressed in
Hubbard's writings. (See attached Exhibit D)
THE TIME MAGAZINE ARTICLE WAS NOT OF AND CONCERNING CSI
20. I have read the Time Magazine article entitled "Scientology
Thriving Cult of Greed and Power" published on May 6, 1991. In
particular, I have read two paragraphs of that article concerning
comments allegedly attributed to Steven Fishman and Dr. Uwe Geertz.
There are references to "Scientology" and "the church" in these two
paragraphs. I have also been advised by Graham E. Berry, Esq., that
the Church of Scientology International alleges that the words
"Scientology" and "the Church" were "of and concerning" Church of
Scientology International ("CSI"). This allegation is absurd and
false. CSI is a management church only. It has no members. In essence,
it is a trademark/copyright licensing vehicle and a financial conduit.
Moreover, the corporations of Scientology are a carefully contrived
sham and shell structure intended to confuse and divert litigants, the
courts and the I.R.S. Indeed, Mission Corporate category sort out
("MCCS"), of which the MCCS tapes were a part, (see the Zolin case)
was part of the creation of this corporate shell game.
21. Accordingly, it is absurd to allege that the words "Scientology"
and "the church", as used in the relevant sections of the Time
Magazine article, refer to anything other than Scientology or the
Church generally and/or generically. Certainly, they are not of and
concerning CSI.
SUPPRESSIVE PERSONS AND FAIR GAME
22. The legal strategy of Scientology and the existence of numerous
potential legal problems, some of which are set forth below, were
known to me when I was a staff member in Scientology.. Enemies of
Scientology are deemed to be "suppressive persons" ("SPs"). One
becomes a "suppressive person" by doing a suppressive act, such as
suing Scientology as a litigant or lawyer. In the jargon of
Scientology, when one is "declared" this means that one has been
declared a "suppressive person" and, therefore, may be harassed, hurt,
damaged or destroyed without regard to truth, honesty or legal rights.
It is considered acceptable within Scientology to lie, cheat, steal
and commit illegal acts in the name of dealing with a "suppressive
person."
23. This practice or policy is sometimes referred to as the policy of
"fair game." In the jargon of Scientology, a person who is declared is
understood to be a suppressive person ("SP") . This means that the
person is "fair game." The fair game policy was issued in the 1960s.
It was never canceled. A document was issued for public relations
reasons that purportedly canceled "fair game"; however, that document
stated that it did not change the manner of handling persons declared
"SP." In reality, the purported cancellation of fair game is at most a
matter of semantics. Enemies of Scientology are treated as fair game.
24. Because of my position and the regular reports that came across my
desk I know that throughout my presidency of RTC, fair game actions
against enemies were commonplace. In addition to the litigation
tactics described below, fair game activities included burglaries,
assaults, disruptions of enemies' businesses, spying, harassive
investigations, abuse of confidential communications in parishioner
files and so on. I specifically recall seeing one report regarding
attacks against Bent Corydon after Scientology became aware that he
was writing a book against Hubbard.
FRIVOLOUS SCIENTOLOGY LITIGATION
25. Other Hubbard writings encourage Scientologists to pursue
litigation purely for harassment without regard to the merits of a
claim to cause enemies to fold. Hubbard's writings state: "The purpose
of the suit is to harass and discourage rather than to win ... The law
can be used very easily to harass and ... Will generally be sufficient
to cause (the enemy's) professional decease. If possible, of course
ruin him utterly." (Hubbard, "Magazine articles on Level 0 Checksheet"
American Saint Hill Organization 1968.)
26. As President of RTC and a Sea Organization member, I attended
meetings concerning the numerous legal actions involving Scientology
organizations. During this time period, I had personal access to all
legal documents having to do with RTC. I received a report every day
on my computer that included a synopsis of each on-going legal case
involving Scientology. I received, or so I was told, copies of every
major motion filed in cases involving Scientology was on the "approval
lines" for legal documents dealing with RTC.
During this time period, I had the option of attending legal meetings,
although some were mandatory. I attended many litigation meetings and
became generally aware of Scientology's dirty tricks and legal
maneuvers. On specifics, I frequently deferred to in-house and outside
counsel; however, at least in theory, I was the head of RTC and had
access to any business or litigation "secrets" of Scientology.
27. It is the stated policy and practice of Scientology to use the
legal system to abuse and harass its enemies. This crude, fundamental
directive of Scientology is no secret. The policy is to do anything
and everything possible to harass the opposing litigant without regard
to whether any particular motion or maneuver is appropriate or
warranted by the facts of applicable law. That policy was followed in
every legal case I was involved with or learned about while a member
of the Sea Organization. The management of Scientology consistently
expressed and demonstrated a complete disdain for the court system,
viewing it as nothing more than a method to harass enemies. Some
examples of this are set forth below.
SCIENTOLOGY DESTROYS EVIDENCE AND REWRITES HISTORY
28. During litigation between Gerald Armstrong and Scientology, which
was before Judge Breckenridge of Superior Court for Los Angeles
County, the court ordered the production of Armstrong's preclear
("PC") folders - These are files maintained by Scientology on those
who submit to interrogation sessions in a process called auditing.
During the course of that litigation I was ordered to go through
Armstrong's folders and destroy or conceal anything that might support
Armstrong's claim against Scientology. This practice is known within
Scientology as "culling PC folders" and is a common litigation tactic
employed by Scientology.
29. During other-litigation in Los Angeles known to me as the
Wollersheim case, I was told that the judge had ordered the production
of Wollersheim's folders. As ordered, I "culled" these files. In other
words, I removed contents that might have been damaging to Scientology
or might have supported Wollersheim's claims against Scientology. For
example, I removed evidence of events involving his family, the
anguish this caused him, evidence of disconnection from family and
evidence of fair game.
30. I was involved in numerous meetings concerning what is known to me
as the Christofferson case in Portland, Oregon. This case was tried
twice. In the first case, a Scientology witness by the name of Martin
Samuels was coached and drilled for hours on how to lie convincingly
or avoid telling the truth. Before or during the second trial, he
admitted to this course of conduct. In this litigation, a
Scientologist by the name of Joan Shriver produced responsive
documents that may have been incriminating. This was a serious breach
of policy for which she was punished. These documents were ordered
produced on such a short notice that apparently files were not
thoroughly "culled". In another case, an attorney was severely
criticized and almost fired for failing to properly coach and feed the
desired answers to Heber Jentzsch. Mr. Jentzsch was, for public
relations reasons, the purported head of the Church of Scientology
International. During his deposition, Mr. Jentzsch was unable to
answer fundamental questions concerning the management of Church of
Scientology International.
31. While involved in Scientology I became aware of various operations
directed against an author who had written a negative book about
Scientology. The author, Paulette Cooper, was subjected to various
forms of harassment. One operation included an attempt to frame her. A
false bomb threat was written on her stationery. Ms. Cooper was
subjected to an investigation and was not cleared until an FBI raid
resulted in the seizure of Scientology documents that exposed the
operation as a frame-up. There was at least one other operation
directed against Ms. Cooper. The substance of it was to plant a
boyfriend to reinforce and play upon her suicidal tendencies in the
hopes that she would commit suicide.
32. In 1976 and 1977, the then Mayor of Clearwater, Florida, Gabe
Cazares, was involved with litigation against Scientology.
Arrangements were made to have an attorney by the name of Merrit
Vanniere, a Scientologist, represent Mr. Cazares and sabotage his
case. This plot was also exposed by documents obtained in an FBI raid
of a Scientology facility. Also, in response to Mr. Cazares'
litigation against Scientology, an attempt was made to implicate Mr.
Cazares in a staged hit and run accident.
33. In later 1979 and early 1980, there was a massive document
destruction program undertaken to destroy any evidence showing that L.
Ron Hubbard ("LRH") controlled Scientology. I participated in this
activity in Clearwater, Florida and am informed that there was also
intensive document destruction at facilities in Gilman Hot Springs,
California. From at least that point onward there was a continuous
effort to hide or destroy any evidence of Hubbard's control. For
example, during an IRS investigation in 1984 and 1985, while in bed
with pneumonia, I was ordered out of bed by Norman Starkey, who told
me that they had received a tip from a Los Angeles police officer
advising them of a pending IRS raid in Los Angeles.
Mr. Starkey ordered me to go to a computer facility and insure that
all information on the computers in Los Angeles that might show
Hubbard's involvement and control of Scientology's money was destroyed
except for one copy of each document. These copies were to be saved on
computer disks which were to be hidden in secure storage places. At
the time I was also instructed to destroy anything that would show the
control of Mr. Starkey or Mr. Miscavige over Scientology.
SCIENTOLOGY INFILTRATES THE U.S. GOVERNMENT
34. In or about 1981, while working in a Scientology organization
known as the Guardian's Office, I had access to and observed various
written and oral communication pertaining to illegitimate activities
participated in by the Guardian's Office. The Guardian's Office
attempted to infiltrate both governmental and private agencies
including the IRS, the Department of Justice, the American Medical
Association and the National Institute of Mental Health. The purpose
of this was to steal documents pursuant to Hubbard's "Snow White"
program. The goal of this program was to eliminate any negative
reports about Hubbard and Scientology that may have been held by these
various agencies.
FISHMAN ALLEGATIONS ARE CREDIBLE
35. I have examined certain documents regarding Steven Fishman's
experience with Scientology, have had conversations with Mr. Fishman's
counsel, in his criminal prosecution and I have reviewed the 1151-page
autobiographical account of Mr. Fishman's Scientology experience
entitled "The Lonesome Squirrel." Based on my years experience in
Scientology and my review of the Fishman materials, I offer the
following opinions and conclusions.
A. I believe Mr. Fishman's assertions that he was a member since 1979
and that he was actively involved as he states.This belief is based on
my experience that only a committed member of long standing would know
the details of the inner workings of the group; Mr- Fishman has such
knowledge. Awareness of certain confidential projects could be
achieved only by a member who was trusted by the hierarchy; Mr.
Fishman had such awareness. Involvement in a group that thrives on
secrecy and excludes most members from participation in high level
projects means that any member who exceeds a certain level of
involvement enjoys the trust of the leadership such trust would be
earned only by extended membership. Mr. Fishman apparently enjoyed
that trust. His accounts of meetings with high level officials and his
knowledge of the operations and functions of the hierarchy are so
detailed and accurate that they couldn't have been gained except
through direct personal experience.
B. Refutation by Scientology officials of Mr. Fishman's membership
prior to February 8, 1986 and their disclaimer of his involvement and
their lack of any records pertaining to such membership is perfectly
consistent with their standard procedure in protecting themselves. As
noted above, I was personally involved in the destruction of records
when it suited their purpose. Scientology propounds the belief that
any action whatever taken to protect the organization is justified, as
the group takes precedence over the individual. Any member performing
criminal acts for the benefit of the group was kept at arm's length;
if apprehended, the member was disavowed by Scientology. This
procedure was used even on the wife of the founder of Scientology.
Given the serious potential threat that Mr. Fishman's defense posed to
the group, I find Mr. Fishman's account of certain members of
Scientology's involvement in the plan to fabricate the threats against
Mr. Fishman and his counsel and to thereby undermine Mr. Fishman's
credibility and render him useless as a witness against Scientology is
consistent with their modus operandi.
I declare under penalty of perjury under the laws of the United States
of America that the foregoing is true and correct.
Executed this 7th day of March, 1994 at Dallas, Tx.
=====
Affidavit of Vicki Aznaran, 29 Jun 93
---------------------------------------------------------------
SUPPLEMENTAL DECLARATION OF VICKI AZNARAN
I, Vicki Aznaran, declare:
1. I joined the Church of Scientology of California ("Scientology")
in 1972, and was a member until I left in April 1987. From 1984 until
1987, I was Inspector General of the Religious Technology Center, an
affiliated Scientology organization. At that time, this was one of
the highest worldwide offices in Scientology. One of my offices was
located at 4751 Fountain Avenue, Los Angeles.
2. By virtue of my high position, I was "in the loop" to receive
communications about some of Scientology's most secret operations. The
facts set forth in this declaration are based on my personal
knowledge, which came from many sources, including numerous
discussions and meetings with top Scientology "intelligence officials"
and other Scientologists and reading documents which passed across my
desk or came to my computer.
3. During the 1984-87 period, Scientology operated a number of "dirty
tricks" operations out of the office of Special Affairs (OSA),
including one called MFTC (for "Mission Find The Crimes") and the
"WOLLY" unit (which targeted Lawrence Wollersheim, his attorneys, and
his case). The orders for these operations would go directly from OSA
to private investigators, although Scientology deceitfully tries to
cloak such operations under "attorney-client privilege".
4. MFTC and the WOLLY unit each had about 8-10 staff, and engaged in
whatever dirty tricks were necessary to attack people and entities
which were considered to be "enemies" of Scientology. The dirty
tricks they used included destruction of
----------------------------------------------------------------------
evidence, theft of documents, illegal surveillance or bugging,
blackmail, bribery, physical assault and other intimidation, securing
perjured testimony. MFTC's mssion was to find or manufacture crimes
for "enemies" of Scientology.
5. Before and during the trial in Wollersheim v Church of Scientology
of California, MFTC and WOLLY ran a number of operations directed
against Wollersheim, his counsel, and the Court. One of these
operations was an attempt to put pressure on Bill Swearinger, the son
of the trial judge in the Wollersheim case, based on his alleged
homosexuality. The idea ws to dig up, or manufacture (perhaps by
setting the son up in a compromising sexual position with a minor
boy), dirt on the son which could be used to pressure the Judge to
rule favorably for Scientology, or else to get the Judge disqualified.
6. Attached as Exhibit A is a true copy of an internal Scientology
memorandum, dated 6/21/86, which discusses this "Swearinger
Investigation". I received a hard copy of this document at about that
time, and I believe I also received a copy of this document on my
computer. The Linda referred to on the first page is Linda Hamil, who
at the time ran the MFTC. The Marty referred to on the first page is
Marty Rathbun, a top Scientology "intelligence" official, who ran this
operation.
7. Scientology's "ambush interview", discussed in Exhibit A, makes
the Mike Wallace/60 Minutes interview called by the same name look
tame. The "ambush interview" generally involves doing whatever it
takes -- threats, physical force, bribery, or whatever -- to get an
unprepared and unsuspecting target to say what is wanted.
----------------------------------------------------------------------
8. I understand that Lynn Farny has submitted a declaration stating
that Scientology complied with Judge Swearinger's order in the
Wollersheim case to produce Wollersheim's pre-clear files. This is
false. As I stated in my Fishman declaration, I personally culled and
destroyed (shredded) from these files evidence which would help
Wollersheim and hurt Scientology in the case. I was personally
ordered to do so by David Miscavige, the head of Scientology, and
Marty Rathbun. The culling and destruction took place at the Fountain
Avenue building in Los Angeles. I was assisted in the document
destruction by then Scientologist Jessie Prince. Lynn Farny was a low
level Scientology official, and was not at the meetings where this was
discussed. However, Lynn Farny is not telling the truth, because as a
Scientology staff member he knows it is Scientology policy never to
turn over information in litigation without first culling out
(deleting and destroying) material that will harm Scientology. It is
also, however, Scientology policy to lie to cover up such misdeeds.
9. Attached as Exhibit "B" to this declaration is a true copy of a
document called "TR L", which is a Scientology training drill to teach
Scientologists to lie convincingly.
10. I understand Scientology is trying to vacate Wollersheim's
judgment on grounds that Judge Swearinger was biased against
Scientology and his bias infected the jury. This is a typical
Scientology tactic which it frequently uses in trials as insurance
when Scientology loses an important case. Scientology will do things
to set up a mistrial, such as calling jurors in the middle of the
night and hanging up, threatening them, etc. Then Scientology claims
that it has been the victim of the opposition's dirty tricks and the
jury has become biased against Scientology.
11. Scientology also ran operations against Wollersheim's counsel,
Charles O'Reilly, and his law firm. This included bugging O'Reilly's
house, placing an agent in the clerical staff in O'Reilly's law firm,
and attempting to set him and his bodyguards up with girls. The
purpose was to discover attorney- client strategy and secrets and get
or manufacture information which could compromise O'Reilly.
12. Attached as Exhibit "C" is a true copy of portions of the
transcript of my deposition on August 2 and 3, 1989, in RTS v. Scott
and RTC v. Wollersheim, OSDC-CDCal, CV 85-711 and 85-7197 JMI (Bx).
I declare, under penalty of perjury under the laws of the State of
California, that the foregoing is true and correct. Executed this 29th
day of June, 1993
[signed] Vicki Aznaran
======
Affidavit of Vicki Aznaran, 27 Jan 92
-----------------------------------------------------
AFFIDAVIT
I, Vicki J. Aznaran, of Mesquite, Texas, U.S. Citizen, Passport No.
03197042, do herewith depose and swear:
1. That from the approximate dates of 1984 until 1987 I held the
positions of President and Chairman of the Board of Directors in the
Scientology organization called the Religious Technology Center, INC,
(RTC) which is now the senior governing entity of the International
Church of Scientology, the Church of Scientology of California, and
all affiliated organizations within the U.S., as well as senior
governing entity for all foreign Scientology organizations and the
civil associations of Scientology such as those called Dianetica or
Narconon in Spain.
2. That despite efforts to cloak the fact, the true role of the
Religious Technology Center, Inc. is that role explained above, and it
holds this managerial position within the matrix of all of the
interrelated organizations of Scientology: The Church of Scientology
International, Inc., The Church of Scientology of California, Inc.,
The Church of Spiritual Technology, Inc., Authors Services, Inc.,
Missions International de Scientology, Inc., Relig ous Technology
Center, Inc., Authors Family Trust, Asociacion Civil de Dianetica,
Asociacion Civil de Narconon.
3. That these various organizations exist in this manner to provide an
"arm's length" appearance in order to protect the current board of
directors from actual legal culpability for any illegal acts committed
by or through the churches of Scientology or any of their other
affiliated organizations, as well as to confuse any issues,
investigations or litigation which might expose the illicit actions of
any individual Scientology orqanization or member thereof.
4. That as a former senior executive of this body, from 1984 until
1987, I have observed and have certain knowledge of the activities of
RTC and of its finances as well as its manner of incorporation and
related documents.
5. That during the period of my employment by the RTC I reported to
David Miscavige, who was at that time Trustee of the corporation.
Miscavige maintains absolute control over all officers and board
members of this corporation, controlling these other members of the
board of directors by fact of his possessing undated, signed
resignations of each member, the holding of which gave and gives him
complete control over each member of the board.
6. That also, to my certain knowledge, David Miscavige conceived,
planned and ordered the implementation of the basic strategic and
tactical actions of the church against those whom he considered to be
causing legal or public relations conflicts against any church or
against his personal and absolute control of Scientology. He also
ordered the allocation of and made available funding for the financing
of these actions, which included the declaring of those whom he
considered to be his "enemies' as Suppressive Persons, the
implementation of the policies known as "Fair Game" against these
persons once so declared, the infiltration of private and governmental
environments which he deemed hostile to his absolute control over
Scientology, the organization of vigilante groups within the
organizations of Scientology to be used against those individuals whom
he deemed to be his enemies.
7. That following Miscaviges' orders, I transferred monies to Spain,
and witnessed briefings by Miscavige to Heber Jentszch, who was in
fact the "puppet" president of the church, but who actually is a
camouflage for Miscavige, concerning covert operations taking place
in Spain against former Scientologists and concerninq false testimony
and concerning the attempt to offset a rumored investigation by the
spanish authorltles lnto the activities of Scientology in Spain, the
very investigation which resulted in the surprise arrest of Jentszch
himself in November of 1988. These operations included orders for
investigations by the private detectives employed by the Scientology
organizations to obtain information by any means possible to
incarcerate the leaders of a reform movement who had not been silenced
previously by Miscavige's policies and declarations, with the express
intent of obtaining their incarceration.
8. That during this same period and as part of these same operations,
a plan was formulated to destroy the reform movement in europe by
completely eliminating the leaders of this reform movement, William
Robertson, John Caban and others, by any means possible. This included
the infiltration of the reform group in Spain by covert agents of RTC,
Kurt Weiland and William Knight, continued investigation and
harassment by detectives employed by the scientology organizations in
Spain and by recruiting others who would help to splinter the reform
movement and to render it ineffective.
9. That additional orders were given to institute any action necessary
including false denunciations, assaults by covert agents apparently in
bad standing with the church, to infiltrate, offset and attack those
leaders of the reform movement who were thought. to be responsible for
reporting Scientology activities to the spanish authorities and
undermining Miscaviqes intentions.
10. That the policies known as "Fair Game" are, as described in the
writings of L. Ron Hubbard, ethics policies, and other organizational
policies are in fact continued as originally written by Hubbard, and
that it is the purpose of the RTC to see that all of his policies are
followed exactly as intended. It was common knowledge that the
"Cancellation of Fair Game" referred only to the use of the term,
since it had obtained bad public relations for Scientology, and that
the same tactics and actions which referred to those so-called
Suppressive Persons were and are continued in effect.
11. That the organization known as the Guardian's Office, while
apparently abandoned, in fact was moved from the position as a
separate organization or network, and incorporated within the
organizational structure of Scientology, and all of the purposes and
most of the Guardian personnel have remained the same. Again, the
purpose of these changes were to obtain complete control by Miscavige
over all Scientology organizations, and to obtain a more favorable
image after Hubbard's wife was found guilty of crimes as head of the
Guardian's Office.
12. Since my departure from the church my husband and I have been
repeatedly threatened and harassed by members of Scientology, and we
are now in fear for our safety.
Many of the statements made above contain information which has been
testified. to by others and/or are matters of publlc record within
other areas of litigation within the United States.
I swear under penalty of perjury under the laws of the state of Texas
that the contents of this affidavit are true to the best of my
knowledge and recollection.
Date 1 - 27 -92 Vicki J. Aznaran (signature)
1-27-92
signature
Notary Public
Dallas County, Texas
USA
=======
First declaration of Vicki Aznaran from 19 May 1994
This file is also available from www.sky.net and ftp.lightlink.com.
((Editor's comments in double parenthesis - Homer))
VICKI AZNARAN AFFIDAVIT II WRITTEN 5/19/94
Copyright (C) 1994 Vicki Aznaran Redistribution rights granted for non
commercial purposes.
----------------------------------------------------------------------
DECLARATION OF VICKI J. AZNARAN
I, VICKI J. AZNARAN, hereby declare as follows:
1. I am over 18 years of age and a resident of the State of Texas. I
have personal knowledge of the matters set forth herein and, if called
upon to do so, could and would competently testify thereto.
2. From 1972 until 1987, I was a member of various Church of
Scientology ("Church") entities. During that time I held a number of
important positions in the corporate and ecclesiastical hierarchy of
the Church. I was also a devout believer in the religion of
Scientology. In March of 1987, my husband Richard Aznaran and I left
our positions with the Church and returned home to Texas from
California. At the time we left, Richard and I voluntarily executed
certain releases and waivers in full settlement of any and all
disputes we had with the Church. In April of 1988, notwithstanding
our execution of those releases and waivers, Richard and I filed a
lawsuit against several Church entities and individuals in the United
States District Court for the Central District of California.
3. During the time I was a senior Church executive, I gained first
hand knowledge of the manner in which some apostate former Church
members had pursued civil claims against the Church, and obtained
successful verdicts or judgments or favorable settlements
notwithstanding the merits. The courts consistently allowed the
Church's adversaries leeway to introduce allegations without regard to
the normal rules of procedure and evidence. At the time, this was a
source of great concern to me, both as a Scientologist and a Church
executive, particularly since my staff duties included
responsibilities regarding certain areas of litigation.
4. Thus, having participated in Scientology litigation both as a
Church executive and as a litigant against the Church, I bring two
distinct, but related, perspectives to this declaration from my
personal knowledge and observation. First, at the time my husband and
I brought our own suit I understood that the legal system could be
used to pursue my position. Later, upon having sued various
Scientology churches and having allied myself with other litigants and
their counsel suing Scientology churches, I observed first hand the
ways in which the legal system is successfully used by litigants and
counsel opposing the Church.
5. The fundamental premise upon which the Church's adversaries and
their lawyers operate is the likelihood that courts and juries are
willing to believe any allegation made against the Church by a former
member, without regard to plausibility, contrary evidence or the true
facts. That concept was most succinctly expressed, on videotape, by
anti-Scientology litigant, Gerald Armstrong, when he stated that a
lack of documents or evidence was no impediment to litigating against
the Church when the litigant can "just allege it." The active pursuit
of that litigation approach has now led to the formation of a small
group of disaffected Scientologists who are now employed by an even
smaller number of attorneys who are making a practice of litigating
against the Church. This stable of witnesses can be relied upon to
furnish "corroboration" for any allegation which an attorney wishes to
make against the Church in pleadings at deposition, in affidavits, and
ultimately in trial testimony.
6. The process or "just alleging it" begins with the complaint. For
example, in the complaint which was filed on our behalf against the
Church, there were numerous allegations which were either false or
which we could not substantiate. When I was initially deposed in our
case, I conceded that numerous portions of the complaint should not
have been drafted by counsel in the fashion they were. Thus, for
example, in deposition in June, 1988, I testified that the allegation
in paragraph 7 of our complaint, that the "[Church] organizations were
created solely for the purpose of making money from the sale of
copyrights of the book Dianetics..." was not true. I testified that I
did not create corporate structures within the Church and that I do
not know where this allegation in paragraph 16 of our complaint came
from.
7. There were several other improper or incorrect allegations which
should not have appeared in the complaint that I had to acknowledge in
deposition. As another example, the complaint alleged in paragraph 16
that I worked for Author Services, Inc., in managing the sales of
copyright of the book Dianetics. In deposition I testified that I
never worked for Author Services, Inc. and was not aware of any such
sale of copyrights.
8. Paragraph 16 of the complaint included the allegation that I had
been employed as a "missionaire" to remove assets of Defendant Church
of Scientology of California to overseas trusts where they could not
be accessed. This allegation was false, and it was not an allegation
that either my husband or I requested be included in the complaint. I
was definitely not employed for that reason, and I have never claimed
that I was.
9. It was also alleged in paragraph 16 of the complaint that I was
employed as a "missionaire" to "set up sham corporate structures to
evade prosecution generally." This allegation is also false. I was
never employed for that purpose. I had never even heard of that
allegation until I read it in the filed complaint. I did not make
that allegation, and I do not know where it came from.
10. Paragraph 12 of the complaint contains the false allegation that
my husband and I were forced to "involuntarily abandon [our]
identities, spouses, and loyalties..." My depostion testimony
established that this was not the case. For example, my husband used
to engage in his hobby of target shooting during his years in the
Church. We had pets, including a German shepherd which my husband
trained in his spare time. I took riding lessons. I also trained in
karate, because I was interested in learning that discipline. These
were all ways in which my husband and I expressed our individuality
while on staff and demonstrate no abandonment, forced or otherwise, of
our individual interests.
11. My husband and I both testified to numerous separate, factual
errors in the complaint. Our attorney firm, Cummins & White, and
later our subsequent counsel, Ford Greene, were aware of these errors
to which we testified. Even though we asked them to, no attempt to
file a corrected or amended complaint was ever made, nor did any such
correction ever occur.
12. The abusive device most consistently utilized by litigants and
counsel adverse to the Church occurs in connection with the filing of
declarations or affidavits. It is common knowledge among the stable
of disaffected ex-Scientologists who supply such sworn statements that
the attorneys dictate the desired content of such testimony with the
primary, often sole, purpose of presenting inflammatory accusations
that prejudice the Church in the eyes of the court. In such
declarations or affidavits, context, the truth, and relevance to the
issues in the case are disregarded altogether. As time has passed and
this technique has evolved, anti-Church litigants and their counsel
have become more and more emboldened in making such declarations and
affidavits because the tactic has proven to be so effective in
poisoning courts and juries against the Church.
13. The most common and probably the most devastating manifestation
of this tactic is the use of allegations concerning the so-called
"Fair Game" policy of the Church. The term "Fair Game" has been
misrepresented and repeatedly used by the Church's litigation
adversaries as a means to create prejudice against the Church. To
accomplish that end, counsel fashions a declaration in which the
witness identifies an ugly event -- real, imagined, or just plain
invented -- and then alleges that it was a deliberate act which was
committed by the Church. The idea is to create the false impression
that the Church is committing acts of retribution in pursuit of "Fair
Game."
14. A central element of exploiting the "Fair Game" tactic is to make
certain that the allegations are crafted so they cannot be objectively
disproved. In other words, the declarant makes an allegation of a bad
or harmful or harassing act that cannot be documented in a tangible
form and then alleges that it was done by the Church pursuant to the
Fair Game "policy". By so doing, the declarant has put the Church in
the impossible position of trying to prove a negative and trying to
prove it without documentation. It becomes a matter of the
declarant's word against that of the Church, and by making the act
alleged sufficiently despicable, the result is prejudice against the
Church.
15. The Fair Game policy was a policy to forward Scientology's belief
that any attacks on Scientology by those seeking to destroy it were to
be vigorously defended by legal means and never ignored. It was not a
policy condoning or encouraging illegal or criminal activities. The
policy was misinterpreted by others and was thus canceled. It has
since been used by litigants over the years as a vehicle to give
credibility to allegations to try to prejudice courts against
Scientology. An event happens such as someone's wife dies in a car
accident, and the allegation is made that this is a murder committed
by the Church pursuant to "Fair Game" policy. This technique is known
to those who attack the Church and so they continue to use this term
to try to prejudice the courts. These people feel comfortable making
scandalous allegations, knowing that the Church does not have such a
policy. I am unaware of any allegations of "Fair Game" being made by
persons who have simply left the Church. Rather, the charges of Fair
Game are invariably made by parties who have subsequently become
involved in litigation with the Church and who have started working
with other anti-Scientology litigants familiar with this tactic.
16. It has been my experience that these litigants and lawyers become
emboldened because the history of Scientology litigation demonstrates
that virtually any charge leveled against the Church in litigation by
an avowed enemy, no matter how outrageous or unfounded, will be
accepted and believed. Based on my experience it is a matter of
common knowledge that efforts by the Church to refute such prejudicial
allegations have commonly not been believed in the courts.
17. Thus, it has become a routine practice of litigants to make
accusations against the Church, including even false allegations of
threats of murder, which would be summarily thrown out of court as
unsupported and scandalous in other litigation. They do it because it
works, and they do it by deliberately mischaracterizing the term "Fair
Game". They do it as an intentional means to destroy the reputation
of the Church in the context of litigation so what they can win money
or force the Church to settle.
18. The term "fair game" has become a catch phrase for those who
attack the Church. When I was in the Church I never heard it referred
to as a policy to be used, the only time it was discussed was in
reference to litigation in which it was being alleged by Church
adversaries. When I was in the Church, I knew that litigants opposing
the Church were constantly making fair game allegations against us and
that those allegations were nonsense. I also know the frustration
those allegations caused because of the willingness of courts and
juries to embrace them. From my experience in litigating against the
Church, I can see that nothing has changed in this regard. I also
know from my experiences in suing the Church and from my association
with other litigation adversaries of the Church that they know that
"Fair Game" as they portray it is not Church policy. "Fair Game"
exists only as a litigation tactic employed AGAINST the Church.
19. There are other things I have seen and experienced in
anti-Scientology litigation that seem very unusual to me. There is a
group or "team" of anti-Scientology witnesses who are being paid for
their testimony, and based on my experience, this testimony is being
altered and falsified, either by the witnesses themselves or the
attorneys. For example, Graham Berry, counsel of record for a
defendant in the case of CSI V. FISHMAN, filed numerous declarations
from ex-Scientologists after the lawsuit was dismissed which had been
purchased for many thousands of dollars. Mr. Berry told me that
these payments were made possible because his client had insurance
coverage.
20. In February of 1994, Mr. Berry called my husband and me and
offered to hire us at the rate of $125 per hour for us to study
materials in the FISHMAN case and to write declarations supporting
issues Mr. Berry wished us to support in the FISHMAN case. Mr. Berry
gave us an advance of $2,500, which we were expected to bill against
services rendered. He told us that because his client in the FISHMAN
case had insurance coverage, the insurance money enabled him to do
this. He said he was able to get the insurance company to pay our
salaries by naming us as "experts", which also enabled the use ((of))
our declarations without regard to whether we were actually witnesses
to the events at issue in the FISHMAN case, which we were not.
21. Mr. Berry told us he had assembled a team of former
Scientologists for use in litigation, all of whom were employed by him
in the FISHMAN case as so-called experts. Although we were not eager
to get involved in FISHMAN's litigation, we agreed to do ((so))
because the $2,500 advance by Mr. Berry was attractive. Mr. Berry
sent us some documents from the court record in the FISHMAN case,
which I read, since I was being paid $125 per hour to do so.
22. I know from subsequent conversations I have had that Andre
Tabayoyon is similarly employed, as are Vaughn and Stacy Young and
others, each paid to create declarations for Mr. Berry when he needs
them. On the basis of my knowledge of the Church and the declarants,
I can state that these individuals are not "experts' in any recognized
sense of the word as I understand it. They are nothing more than
witnesses who are being paid to make sworn statements against the
Church. More than just being paid, they are actually employed by Mr.
Berry as a source of signed declarations of testimony or as a "source"
of allegations, the need for such is decided by him.
23. Later in February 1994, Mr. Berry called us again. He said that
the Church had dismissed the FISHMAN case and he needed declarations
from us on an immediate basis for use in his motion to recover
attorneys fees and costs. I thought this was odd, since it seemed to
me that one would support such a motion with receipts, bills,
invoices, and such. Even though it seemed senseless to provide
declarations after the case was dismissed, I told him I would provide
a declaration because he had already paid and I would rather have done
this than return the money he had paid us. He then told us what areas
of testimony he wanted us to cover in the declarations. Accordingly, I
transmitted to Mr. Berry's firm EIGHT-page declaration which I had
prepared on my word processor and signed on the last page bearing the
date of February 24, 1994.
24. I recently learned that Mr. Berry actually filed a NINETEEN-page
declaration purportedly signed by me. Mr. Berry attached my
signature to a declaration which I never saw or authorized.
25. Passages inserted without my knowledge or authorization in the
version of my declaration filed by Mr. Berry include statements that
are untrue and/or about which I have no personal knowledge. Not only
did I not make these statements, I never heard of them before. The
following are some examples of these falsities:
a) In my declaration there are statements concerning "Project Quaker"
which are false. In fact I have never heard of "Project Quaker" and
the statement in the version of my declaration Mr. Berry filed
(paragraph 7) was not in the declaration I sent to Mr. Berry. It
could not have been as I have never heard of "Project Quaker";
b) The statements in the filed declaration concerning the death of
Michelle Miscavige's mother were added to without authorization by me.
This included mention of the death of Heber Jentzsch's wife which is
not something I had ever spoken to Mr. Berry about, and I have no
knowledge and never heard anything that indicated there was anything
unusual about Mr. Jentzsch's wife death. She died of natural causes.
The statement concerning Flo Barnett's death were not put in context
and were not meant to imply that there was any wrongdoing surrounding
her death.
In approximately September 1985, when I was the Deputy Inspector
General of Religious Technology Center ("RTC"), I learned that Mary
Florence Barnett, Mrs. Miscavige's mother, had committed suicide. She
had been involved with a group of disaffected former Scientologists
who practiced altered versions of Scientology. I only know that after
hearing about her death both David and Shelly Miscavige were very
upset over the fact that Flo Barnett had killed herself. I also wish
to make known that I have seen mention in an affidavit by Vaughn Young
that David Miscavige ordered the matter "hushed up." This was stated
in the context of indicating wrongdoing on Mr. Miscavige's part and
insinuating he had some participation in the matter. A careful and
literal reading of the statment shows that Mr. Young never actually
says he knows Mr. Miscavige was involved in this suicide, or that
there was any evidence of such, but by innuendo his statement still
leaves this impression. To my knowledge there was never any order by
David Miscavige or anyone else to keep the matter quiet. If any such
order existed it would most likely have been given to me. And since I
took actions to make the matter quite well known and never heard
anybody, let alone David Miscavige, ask for the matter to be hushed
up, I know this statement and the innuendo to be false;
c) the entirety of paragraph 16 on page 10 of the declaration filed by
Mr. Berry concerning L. Ron Hubbard and the IRS was written by
someone other than me and was inserted into my declaration without my
knowledge or authorization. This entire paragraph makes unfounded and
outrageous allegations intended to create the impression that David
Miscavige or any other Scientologist would want Mr. Hubbard to die in
order to avoid supposed IRS problems. This is unthinkable to any
Scientologist, and I never heard this or any similar statement made by
anyone in the Church.
d) Paragraph 15 of the declaration claims that "Earle Cooley Esq. and
others convinced the San Luis Obispo coroner not to do any autopsy on
Hubbard's body" implying there was something hidden or covered up
about Mr. Hubbard's death. This is false. It was not written by me
and I know of no such thing. I was in a position to have knowledge of
this matter and I know that Mr. Hubbard died of natural causes and
the statement attributed to me is a complete fabrication.
e) There is also a statement made in paragraph 18 that Mike Rinder's
child received "Hubbard's baby care technology." The implication is
that the child's death had something to do with Scientology which I
never believed to be the case. I did not make this statement and have
no information that this was the case.
f) In fact, paragraphs 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32,
33, 34, 35A and 35B were not in the version of the declaration that I
sent to Mr. Berry to be filed. He added them after the fact, and I
never saw them before this declaration was filed and I never gave
authorization for Mr. Berry to add any of these things to my
declaration.
g) The statements concerning the Church of Scientology International
("CSI") and whether the Time article concerned CSI, and the corporate
structure of the Church (paragraph 20) were also not in the version I
signed and sent to Mr. Berry. And again, I know the statement to be
entirely false.
h) One other point I wish to clarify concerning the use of "End of
Cycle." There is nothing in Scientology writings which relates the
term "End of Cycle" to connote murder or suicide. To my knowledge,
this characterization of the term "End of Cycle" was invented by
Steven Fishman. I have never heard this term used by the Church to
mean "suicide" or "murder" and even though I am a disaffected
ex-Scientologist, I know it to be a false allegation. Its only use is
to smear the Church for litigation purposes as detailed earlier. I
earlier verbally told Mr. Berry this when he first contacted me for
this exact information.
26. I gave no authorization for my declaration to be changed after I
sent the signed copy of it to Mr. Berry and the charges made to my
declaration were made without my knowledge or consent. Mr. Berry
never contacted me after he filed the manufactured 19 page version of
my declaration. Had I not later obtained a copy of the declaration
filed by Mr. Berry from another source, I never would have found out
about any of these alterations.
I declare under the penalty of perjury under the laws of the United
States of America, and under the laws of each individual state
thereof, including the laws of the states of California and Texas,
that the foregoing is true and correct.
Executed this 19th day of May, 1994 in Dallas, Texas.
VICKI J. AZNARAN
======
Second declaration of Vicki Aznaran from 19 May 1994
DECLARATION OF VICKI J. AZNARAN
I, VICKI J. AZNARAN, hereby declare as follows:
1. I am over 18 years of age and a resident of the State of Texas. I
have personal knowledge of the matters set forth herein and, if called
upon to do so, could and would competently testify thereto.
2. From 1972 until 1987, I was a member of various Church of
Scientology ("Church") entities. During that time I held a number of
important positions in the corporate and ecclesiastical hierarchy of
the Church. I was also a devout believer in the religion of
Scientology. In March of 1987, my husband Richard Aznaran and I left
our positions with the Church and returned home to Texas from
California. At the time we left, Richard and I voluntarily executed
certain releases and waivers in full settlement of any and all
disputes we had with the Church. In April 1988, notwithstanding our
execution of those releases and waivers, Richard and I filed a lawsuit
against several Church entities and individuals in the United States
District Court for the Central District of California.
3. During the time I was a senior Church executive, I gained first
hand knowledge of the manner in which some apostate former Church
members had pursued civil claims against the Church, and obtained
successful verdicts or judgments or favorable settlements
notwithstanding the merits. The courts. consistently allowed the
Church's adversaries le eway to introduce allegations without regard
to the normal rules of procedure and evidence. At the time, this was a
source of great concern to me, both as a Scientologist and a Church
executive, particularly since my staff duties included
responsibilities regarding certain areas of litigation.
4. Thus, having participated in Scientology litigation both as a
Church executive and as a litigant against the Church, I bring two
distinct, but related, perspectives to this declaration from my
personal knowledge and observation. First, at the time my husband and
I brought our own suit I understood that the legal system could be
used to pursue my position. Later, upon having sued various
Scientology churches and having allied myself with other litigants and
their counsel suing Scientology churches, I observed first hand the
ways in which the legal system is successfully used by litigants and
counsel opposing the Church.
5. The fundamental premise upon which the Church's adversaries and
their lawyers operate is the likelihood that courts and juries are
willing to believe any allegation made against the Church by a former
member, without regard to plausibility, contrary evidence or the true
facts. That concept was most succinctly expressed, on videotape, by
anti-Scientology litigant, Gerald Armstrong, when he stated that a
lack of. documents or evidence was no impediment to litigating against
the Church when the litigant can "just allege it." The active pursuit
of that litigation approach has now led to the formation of a small
group of disaffected Scientologists who are now employed by an even
smaller numb er of attorneys who are making a practice of litigating
against the Church. This stable of _ witnesses can be relied upon to
furnish "corroboration" for any allegation which an attorney wishes to
make against the Church in pleadings, at deposition, in affidavits,
and ultimately in trial testimony.
6. The abusive device most consistently utilized by litigants and
counsel adverse to the Church occurs in connection with the filing of
declarations or affidavits. It is common knowledge among the stable of
disaffected ex-Scientologists who supply such sworn statements that
the attorneys dictate the desired content of such testimony with the
primary, often sole, purpose of presenting inflammatory accusations
that prejudice the Church in the eyes of the court. In such
declarations or affidavits, context, the truth, and relevance to the
issues in the case are disregarded altogether. As time has passed and
this technique has evolved, anti-Church litigants and their counsel
have become more and more emboldened in making such declarations and
affidavits because the tactic has proven to be so effective in
poisoning courts and juries against the Church.
7. The most common and probably the most devastating manifestation
of this tactic is the use of allegations concerning the so-called
"Fair Game" policy of the Church. The term "Fair Came" has been
misrepresented and repeatedly used by the Church's litigation
adversaries as a means to create prejudice against the Church. To
accomplish that end, counsel fashions a declaration in which the
witness identifies an ugly event -- real, imagined, or just plain
invented -- and then alleges that it was a deliberate act which was
committed by the Church. The idea is to create the false impression
that the Church is committing acts of retribution in pursuit of "Fair
Game.
8. A central element of exploiting the "Fair Game" tactic is to make
certain that the allegations are crafted so they cannot be objectively
disproved. In other words, the declarant makes an allegation of a bad
or harmful or harassing act that cannot be documented in a tangible
form and then alleges that it was done by the Church pursuant to the
Fair Game "Policy." By so doing, the declarant has put the Church in
the impossible position of trying to prove a negative and trying to
prove it without documentation. It becomes a matter of the declarant's
word against that of the Church, and by making the act alleged
sufficiently despicable, the result is prejudice against the Church.
9. The Fair Game policy was a policy to forward Scientology's belief
that any attacks on Scientology by those seeking to destroy it were to
be vigorously defended by legal means and never ignored. It was not a
policy condoning or encouraging illegal or criminal activities. The
policy was misinterpreted by others and was thus canceled. It has
since been used by litigants over the years as a vehicle to give
credibility to allegations to try to prejudice courts against
Scientology. An event happens such as someone's wife dies in a car
accident, and the allegation is made that this is a murder committed
by the Church pursuant to "Fair Game" policy. This technique is known
to those who attack the Church and so they continue to use this term
to try to prejudice the courts. These people feel comfortable making
scandalous allegations, knowing that the Church does not have such a
policy. I am unaware of any allegations of "Fair Came" being made by
persons who have simply left the Church. Rather, the charges of Fair
Care are invariably made by parties who have subsequently become
involved in litigation with the Church and who have started working
with other anti-Scientology litigants familiar with this tactic.
10. It has been my experience that these litigants and lawyers become
emboldened because the history of Scientology litigation demonstrates
that virtually any charge leveled against the Church in litigation by
an avowed enemy, no matter how outrageous or unfounded, will be
accepted and believed. Based on my experience it is a matter of common
knowledge that efforts by the Church to refute such prejudicial
allegations have commonly not been believed in the courts.
11. Thus, it has become a routine practice of litigants to make
accusations against the Church, including even false allegations of
threats of murder, which would be summarily thrown out of court as
unsupported and scandalous in other litigation. They do it because it
works, and they do it by deliberately mischaracterizing the term "Fair
Came". They do it as an intentional means to destroy the reputation of
the Church in the context of litigation so that they can win money or
force the Church to settle.
12. While I was in the Church I witnessed the "Fair Game" allegations
made by Gerry Armstrong and Larry Wollersheim in their litigation
against the Church. My position in the Church at the time gave me
broad access to what was occurring and I. would have known were the
allegations made by Armstrong and Wollersheim true. Wollersheim, for
example, made the allegation that a pipe bomb was found on his
parent's lawn and, without any corroboration, blamed the Church. I
know from my own personal knowledge that this outrageous allegation of
Church involvement is absolutely false. During the Wollersheim trial,
rumors began to spread throughout the trial courtroom that Judge
Ronald Swearinger had been followed, his tires had been slashed, and
his pet dog had drowned, and that the Church was responsible for that
supposed activity. All of those allegations of Church complicity were
false, as well, as I now personally attest. Armstrong alleged the
Church was trying to kill him and this allegation also was just made
up. I know of its falsity of my own personal knowledge. Both Armstrong
and Wollersheim continue to make the same type of outrageous
allegations of Fair Game to forward their litigation to this day, due
in no small measure to the fact that they practiced Fair Came so
effectively in their earlier, victorious litigation against the
Church.
13. The term "fair game" has become a catch phrase for those who
attack the Church. When I was in the Church I never heard it referred
to as a policy to be used, the only time it was discussed was in
reference to litigation in which it was being alleged by Church
adversaries. When I was in the Church, I knew that litigants opposing
the Church were constantly making fair game allegations against us and
that those allegations were nonsense. I also know the frustration
those allegations caused because of the willingness of courts and
juries to embrace them. From my experience in litigating against the
Church, I can see that nothing has changed in this regard. I also know
from my experiences in suing the Church and from my association with
other litigation adversaries of the Church that they know that "Fair
Game" as they portray it is not Church policy. "Fair Game" exists only
as a litigation tactic employed against the Church.
I declare under the penalty of perjury under the laws of the United
States of America, and under the laws of each individual state
thereof, including the laws of the states of California and Texas,
that the foregoing is true and correct.
Executed this 19th day of May, 1994 in Dallas, Texas.
Vicki Aznaran
======
Third declaration of Vicki Aznaran from 19 May 1994
--------------------------------------------------------------
DECLARATION OF VICKI J. AZNARAN
I, VICKI J. AZNARAN, hereby declare as follows:
1. I am over 18 years of age and a resident of the State of Texas. I
have personal knowledge of the matters set forth herein and, if called
upon to do so, could and would competently testify thereto.
2. From 1972 until 1987, I was a member of various Church of
Scientology ("Church") entities. During that time I held a number of
important positions in the corporate and ecclesiastic hierarchy of the
Church.
3. Religious Technology Center ("RTC") is the owner of the trade
secret rights in certain confidential scriptures of the Scientology
religion referred to collectively as the Advanced Technology or the
"Upper Level Materials." These confidential materials are commonly
known individually as Power, SOLO Course, R6EW, Clearing Course, OT I
- OT VIII and several higher OT levels which to my knowledge have not
yet been released. Training in these highly confidential scriptures is
available only in certain Churches of Scientology and only to
Scientologists who have completed the required levels of, spiritual
training which, as a matter of ecclesiastic doctrine, are a
prerequisite to accessing the Advanced Technology. The Upper Level
Materials are trade secrets and are treated as such. RTC and the
Churches which offer the services based upon these confidential
religious writings go to great lengths to protect the secrecy and
confidentiality of the Advanced Technology. They are kept under lock
and key and the copies of the materials are numbered and monitored
through a logging system to ensure that only Scientology parishioners
who have attained the requisite level of spiritual awareness are
allowed access to the Upper Level Materials. Even then, such
parishioners do not gain access to these scriptures until they have
signed secrecy and confidentiality agreements. Moreover, parishioners
who have access to these materials are not permitted to copy them,
make notes from them, or remove them from designated rooms.
4. The Advanced Technology is otherwise not available to anyone. Thus,
as to any version of any of the scriptures that comprise the Advanced
Technology, if the material in question is in anyone's hands other
than pursuant to the prescribed procedures, it must either have been
stolen or otherwise misappropriated in violation of a covenant of
confidentiality.
5. RTC and the Church take special care to protect and enforce its
intellectual property and trade secret rights and to prosecute any
theft, infringement, or unauthorized disclosure of the Upper Level
Materials. When I was President of RTC information came to my
attention which implicated David Mayo in the receipt of certain of the
Upper Level Materials stolen from a Church in Denmark. That
information led to the filing of the consolidated cases called
Religious Technology Center v. Scott, et al. and Religious Technology
Center v. Wollersheim, et al., Nos. CV 85-711 and CV 85-7197 were
filed against David Mayo and others in the United States District
Court for the Central District of California ("the consolidated
cases").
6. After I left the Church, I met with Jerold Fagelbaum, one of the
attorneys for David Mayo in the consolidated cases, in late June or
early July 1988 when he cane to Dallas to gather information from me
that would be of use to him in the litigation with RTC and the other
Church plaintiffs. I have also executed a declaration for Mr.
Fagelbaum's use in the consolidated cases in October of 1988 and have
had my deposition taken in the consolidated cases. At no time in my
interview with Mr. Fagelbaum, or in any of the above testimony -- or
at any other time -- did I claim to have seen any handwritten
manuscripts of those portions of the Upper Level Materials stolen in
Denmark. What I did testify to is that I had seen the original version
of these materials. They were all in typed form. Some of the typed
originals had some minor handwritten notations on them. I never saw
any original version of these materials which was handwritten by
anyone let alone David Mayo.
7. However, I see from reviewing documents in the consolidated cases,
that on several occasions Mr. Fagelbaum has argued that I had seen
such handwritten manuscripts. This just is not true. Mr. Fagelbaum has
also argued several times that I knew that materials from Mr.
Hubbard's spiritual counseling folders were used in the creation of
New Era Dianetics for Operating Thetans. This is also not true and I
never told that to Mr. Fagelbaum, nor testified to such a fact. The
truth is that I saw the original versions of these materials and the
information which Mr. Hubbard used to create them. I never saw
anything that would have come from Mr. Hubbard's spiritual counseling
folders.
a. Mr. Fagelbaum has also argued that I said that the Church was
engaged in massive document destruction in order to give the
impression that documents related to this case were destroyed. I never
said that. During the time I was President of RTC, we fully complied
to all discovery requests. I have never received an order from David
Miscavige, Norman Starkey or Lyman Spurlock to destroy any documents
related to litigation and I have no reason to believe that the Church
would destroy any documents related to the consolidated cases,
especially regarding the authorship of the New Era Dianetics for
Operating Thetans materials. All the documents I saw relating to the
authorship of these materials showed that L. Ron Hubbard was the
author and not David Mayo. I can see from Mr. Fagelbaum's arguments
and papers that he created the impression that documents related to
this case were destroyed in order to win the case, and that he used my
testimony entirely unrelated to this matter as the prime support and
corroboration of this false claim. He has misinterpreted what I said,
and taken my testimony entirely out of context, as I never alleged any
such thing, and in fact know the opposite to what he has argued is the
truth.
I declare under the penalty of perjury under the laws of the United
States of America, and under the laws of each individual state
thereof, including the laws of the states of California and Texas,
that the foregoing is true and correct.
Executed this 19th day of May, 1994 in Dallas, Texas.
Vicki Aznaran
=======
Fourth declaration of Vicki Aznaran from 19 May 1994
------------------------------------------------------------
DECLARATION OF VICKI J. AZNARAN
I, VICKI J. AZNARAN, hereby declare as follows:
1. I am over 18 years of age and a resident of the State of Texas. I
have personal knowledge of the matters set forth herein and, if called
upon to do so, could and would competently testify thereto.
2. From 1972 until 1987, 1 was a member of various Church of
Scientology ("Church") entities. During that time I held a number of
senior positions in the corporate and ecclesiastic hierarchy of the
Church.
3. From 1981 onward I knew both Vaughn and Stacy Young, whom I met and
had contact with as a result of my work as a staff. r,ember in the
Church of Scientology. I am familiar with their positions in the
Church.
4. In my staff capacities in the early 1980s, and later in my
executive positions in the Religious Technology Center, I was directly
or closely involved in meetings with senior staff members of various
Church corporations. These senior staff made significant or major
decisions which affected the future of the Church. I know that neither
Vaughn nor Stacy Young were included in such senior decision-making
processes. They were never senior or key Church executives.. They were
not consulted regarding, nor were they privy to, the meetings where
major issues were discussed and decisions made.
5. I am informed that the Youngs have made claims to specialized
knowledge about the corporate status and structure of the Church. Such
claims are false. Neither of the Youngs were in a position to have
detailed knowledge of the corporate and fiscal structures and
operations of any Church of Scientology. In fact, Vaughn Young worked
in the area of Public Relations for the entire time that I was
acquainted with him. Stacy was primarily a writer in the Church public
relations department.
6. Another false allegation is Vaughn Young's claim to be not only
knowledgeable about but personally affected by a dispute in 1986 and
1987 between David Miscavige and Pat Broeker concerning Scientology
scriptures. I was with Broeker during this period and was aware of
this situation. To my knowledge Vaughn Young was not in a position to
know what happened during this dispute.
7. That Vaughn and Stacy Young are experts is not true. They are being
called experts not due to expertise in Scientology but in order to
collect insurance money for their testimony. When Graham Berry
retained me for $2,500 to write declarations, he made it clear to me
he would get me classified as an "expert" so the insurance company
would pay.
8. What this creates, and what the Youngs are part of, is a stable of
people who, for pay, write declarations. The Fishman case is a good
example. Neither the Youngs nor I have ever met Steve Fishman.
9. Stacy Young apparently claims special expertise regarding
Scientology scriptures. This is just another part of the sham that has
been erected around this litigation. She doesn't hold herself out as
an "expert" in her life outside of this litigation. It is only when
testimony is needed for Mr. Berry th at the "expert" title is used.
10. To give an example of how this "expert" plan works, Vaughn Young
claims, as an "expert," that Steven Fishman was known and discussed by
senior Church executives and staff. For years in the inid-1980s I was
one of the highest ranking executives in all of the Churches of
Scientology. Furthermore, I never heard David Miscavige or Marc Yager,
whom I had regular contact with, ever mention his name. Thus it is
inconceivable to me that Vaughn Young would have heard any Church
staff member or executive talk about Fishman. He was not in a position
to know and I was.
11. The Youngs rely on innuendo to make allegations under the guise of
"expert knowledge." Here are some specific exanples: a) that End of
Cycle within the Church means committing suicide. There is no such
policy and in fact this is totally contrary to Church policy and they
know this; b) that members of the Church are involved in murder of
adversaries. This never occurred at any tire and it is a lie that
anyone connected with he Church would recognize including the Youngs;
c) Vaughn Young implied that there might be something suspicious about
the death f L. Ron Hubbard. This is fictitious scandal. I was a senior
executive and can state that L. Ron Hubbard's death was not by
anything other than natural causes; d) inferring that the death of Flo
Barnett was covered up by Mr. Miscavige. There was never ny question
that the cause of her death was due to self-inflicted gunshot wounds.
Additionally, the facts are that there was never any order by David
Miscavige or anyone else to keep the matter quiet. If such an order
existed, I would have known about it: e) an additional forum in which
this false information is spread in FACTNET. This is a computer base
which seeks to create the impression that Scientology is somehow
responsible for the deaths of certain individuals. Anyone who knows
Scientology or has been involved with it knows this is not realistic.
12. The above are examples of the falsehood and innuendo created by
the stable of false "expert" witnesses that has been created here.
I declare under the penalty of perjury under the laws of the United
States of America, and under the laws of each individual state
thereof, including the laws of the states of California and Texas,
that the foregoing is true and correct.
Executed this 19th day of May, 1994 in Dallas, Texas.
Vicki Aznaran
======
Fifth declaration of Vicki Aznaran from 19 May 1994
-----------------------------------------------------------
DECLARATION OF VICKI J. AZNARAN
I, VICKI J. AZNARAN, hereby declare as follows:
1. I am over 18 years of age and a resident of the State of Texas. I
have personal knowledge of the matters set forth herein and, if called
upon to do so, could and would competently testify thereto.
2. On May 4, 1994, my husband and I each executed a series of
declarations under penalty of perjury addressing a variety of issues.
Among those declarations are one of mine that demonstrates that
perhaps the most common litigation ploy that is used against Churches
of Scientology is for opponents to submit false, inflammatory and
accusatory declarations which make wild accusations irrespective of
their falsity, lack of relevance, or lack of first hand knowledge.
3. I am executing this declaration on May 19, 1994 because I am
certain that litigation opponents of the Church will react to one or
more of my other contemporaneously dated declarations in precisely the
fashion I describe in the preceding paragraph. Someone who knows
nothing whatsoever of what transpired or why my husband and I have
executed the May Lq1 1994 declarations will accuse us of "selling out"
or being "bought out" or being forced by the Church to swear to
matters that are not true.
4. Whoever makes any of those allegations or any similar allegations
has no factual basis to make such a claim and has no knowledge of any
of the pertinent facts. Their allegations are lies. The fact that they
would make such an allegation at all is merely corroboration of my
declaration of this date that litigation opponents of the Church will
"just allege it" even if they have no competent evidence or facts. It
is merely more evidence that they engage in a pattern of just alleging
anything which forwards their positions, regardless of their truth.
The statements I have made in my declaration are factual-and true and
people who played no part in my independent decision to sign this and
my other May ICT 1994 declarations know no facts to the contrary.
5. I have written this declaration as I know, both from my experience
when a member of the Church, and since leaving the Church, that Church
adversaries have routinely falsely alleged such actions against the
Church. I also know both from my experience within the Church and from
my experience since leaving, that these allegations are false and
intended to incite prejudice against Scientology, which is then forced
to defend itself and to attempt to overcome such charges.
I declare under the penalty of perjury under the laws of the United
States of America, and under the laws of each individual state
thereof, including the laws of the states of California and Texas,
that the foregoing is true and correct.
Executed this 19th day of May, 1994 in Dallas, Texas.
Vicki Aznaran
----
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