Affidavit of Janie Peterson

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Tilman Hausherr

Apr 5, 1996, 3:00:00 AM4/5/96

SCHAICK, et al )
Plaintiffs )
v. ) NO. 79-2491-G
CALIFORNIA, et al, )
Defendants )


I, Janie Peterson, being first duly sworn, depose and say:

1. I joined the Church of Scientology in March 1975 and was a member
until July 1980, during which time I spent 2 1/2 years as a staff

2. When I was introduced to "auditing" I was told that all the
information revealed in auditing sessions was strictly confidential
between the auditor and the "pre clear" and that this was treated the
same as a parishioner giving a confession to a minister or priest.

3. After joining staff to work in the division that delivered the
auditing, I became aware of the practice of many other people having
access to and going through the auditing folders. These include but are
not limited to: all technical division staff, students, ethics
Guardian Office personnel; if on staff - the person's seniors, other
auditors, case supervisors, "word-clearing" personnel and others.

4. While acting as "Technical Secretary" I witnessed an out-of-state
person named Morris Deutsch (I am not sure of spelling) from New
Mexico's auditing folders, being sent to Las Vegas, Nevada to be gone
through by the Guardian Office, as he was a "suppressive" person and an
"enemy" of Scientology and the Las Vegas Guardian Office, was, at that
time responsible for New Mexico also.

5. During my time in Scientology, I witnessed out-of-state
"missionaires" for the Church of Scientology of California come into the

Las Vegas organization and go through auditing folders of people who
they were trying to recruit for the "Sea Org" and/or people they were
suspicious of for any reason. This would include people who had parents,

spouses, friends, etc. that did not want them in Scientology. They had
complete access to all auditing files and it was firmly established that

we were to cooperate with them either in person, on the telephone, telex

or any other means of request for information from a person's auditing
folder. This occurred on many occasions while I was in charge of the
auditing and the auditing folders.

6. Guardian's Office staff and intelligence personnel from the Guardian

Office had a series of files kept on Scientologists and reports, by
other Scientologists, or auditing information from auditing folders,
basically anything suspicious about a person who had voiced any
disagreement with Scientology or L. Ron Hubbard or executives was kept
in these files. I personally saw these files and knew that auditing
information was being filed in these files and this was not known to the
people receiving auditing.

7. The Church of Scientology of California completely runs
Scientology at all levels. The United States Guardian Office runs every
Guardian Office in the country, including Clearwater, Florida. The
executive management structure is in Clearwater, Florida. Another
management structure is in Los Angeles, California (FOLO) and that this
is also part of the Church of Scientology of California. These run the
organization throughout the U.S.

8. The above-described actions regarding the use of auditing
information, access to auditing folders, Guardian Office staff using
auditing information is standard procedure and is followed throughout
the U.S. at the direction of the Church of Scientology of California.

9. While working on staff in the Guardian Office, I witnessed staff
going through the auditing folders of staff members and public people.
This was a regular practice. I was aware that certain information people

would reveal in auditing would be sent to the Church of Scientology of
California, the United States Guardian Office and Clearwater, Florida,
if requested or needed.

10. While working in the Guardian Office, I personally saw a man I
believed to be sent to Las Vegas by L. Ron Hubbard actually xerox
copying Mr. Ernie Hartwell's auditing reports from his auditing folder.

11. I also saw auditing information from the auditing folder of Tonja

Burden that was sent to Carol Garrity, a Guardian Office staff member,
from the United States Guardian Office in California and Florida and
Carol had an order from her senior in the "USGO" to get said auditing
information published in the news media. Miss Burden was at that time
engaged in litigation against Scientology and L. Ron Hubbard and she was
considered a top enemy of Scientology.

12. This practice of using auditing information for other purposes
than were stated at the time the person received his/her auditing was
standard and done routinely during all my years in Scientology.

13. I am aware of Lavenda Van Schaick's auditing folders being
gathered in Las Vegas and gone through by Guardian Office staff members
at the time Mrs. Van Schaick retained the services of Attorney Michael
Flynn in Boston. This was done to gain information about Mrs Van

14. Outer "missions" under the control of "Class 4" organizations
routinely sent auditing information from persons' auditing folders who
were under "ethics" actions or were in some kind of trouble regarding
Scientology in the areas where the missions were. If needed, this
auditing information would be sent to the Church of Scientology of
California and the United States Guardian Office, which is part of the
Church of Scientology of California.

15. A Guardian Program entitled "Shake and Bake" was written by the
tip management of the United States and England Guardian Office to
"handle" Lavenda Van Schaick so that she would not continue with
litigation against Scientology and L. Ron Hubbard. I saw this program
and part of it was an "information-gathering" section on Mrs Van
Schaick, including going through her auditing information.

16. Due to all of the above actions, when I thought about leaving
Scientology and pursuing my legal remedies, I was in fear that these
actions would be done to me and that my personal life and the
information I gave during my auditing would be used to blackmail me and
be taken to the news media for publication.

17. During auditing a person reveals his most personal thoughts,
feelings, actions and those of his families, friends and anyone
influencing his life.

18. I am also aware of a Guardian's Office operation to get Michael
Flynn disbarred and thereby eliminate him as a representative of
individuals who have been victimized by the Church of Scientology. I
observed "operations" being planned and executed to infiltrate Mr.
Flynn's law office with a "plant" named William Broderick. This
operation was called "Operation Oscar". The purpose of that operation
and others that were being planned was to get someone inside Mr. Flynn's
office for the purpose of gathering information.

Signed under the pains and penalties of perjury this 25th day of May,

Janie Peterson

SUBSCRIBED and SWORN to before me this 25th day of May, 1982.


Glossary: FOLO - Flag Organization Liaison Office
USGO - United States Guardian's Office

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