First Affidavit of Robert Vaughn Young

[Modemac]

CD - 22
14 October 1994

Copyright (C) 1994 Robert Vaughn Young
Redistribution rights granted for non commercial purposes.

GRAHAM E. BERRY, State Bar No. 128503
GORDON J. CALHOUN, State Bar No. 84509
LEWIS, D'AMATO, BRISBOIS and BISGAARD
221 N. Figueroa Street, Suite 1200
Los Angeles, California 90012
Telephone: (213) 250-1800

Attorneys for Defendant
UWE GEERTZ, PH.D.

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

CHURCH OF SCIENTOLOGY
INTERNATIONAL, a California
non-profit religious
organization,

Plaintiff,

vs .

STEVEN FISHMAN AND UWE GEERTZ,

Defendants.
Case No. CV 91 6426 HLH (Tx)

DECLARATION OF ROBERT VAUGHN
YOUNG IN SUPPORT OF COST BILL
FOR DR. GEERTZ'S MOTION FOR
AWARD OF COSTS, EXPENSES,
ATTORNEY'S FEES AND SANCTIONS

Date: APRIL 4, 1994
Time: 10:00 a.m.
Courtroom: 7

[Filed and served
concurrently with Dr
Geertz's Bill of Costs ]

DECLARATION OF ROBERT VAUGHN YOUNG

I, Robert Vaughn Young, declare that I am over 18 years of age and am a
resident of Newport Beach, California.

INTRODUCTION

I have been retained as an expert consultant and expert witness by Dr.
Uwe Geertz's counsel in the case captioned Church of Scientology
International v. Steven Fishman and Uwe Geertz. *CV-6426-HLH (Tx)
currently pending in the United States District Court, Central District of
California. The statements herein are of my own personal knowledge or
reasonably based upon information and belief, and if called upon as a
witness, I can testify competently thereto.

This declaration is submitted in support of Defendant Dr. Geertz's motion
for costs. fees. expenses and sanctions following the dismissal of this
action with prejudice by the court on February 22, 1994.

My credentials as an expert on Scientology includes over 20 years as a
staff member in the organization. In those 20 years, I have held nearly
every type of position at every echelon. I have worked at the local, the
regional, the national and the international levels. I have been a
Scientology representative and spokesman before governmental bodies,
the media andthe courts. I have trained others on how to handle the
media and governmental agencies. I have been the most senior public
relations executive for Scientology world wide. I worked for years at the
echelon that handles critics, "enemies," the media, judges, the courts
and the government. I have been privy to documents and tactics of the
most secret nature, including illegalities committed by Scientology
executives and the means of cover-up. I have been called on many
occasions to personally handle "hot" situations of the most sensitive
nature ranging from the mysterious death of the son of Scientology
Founder Ron Hubbard ("Hubbard") to the death of Hubbard himself. I have
been privy to financial schemes and scams involving tens of millions of
dollars. I also know how Scientology manipulates the law to avoid any
revelation of the truth.

SCIENTOLOGY ADVOCATES USING THE COURTS NOT TO SEEK JUSTICE BUT TO
HARASS AND RUIN PEOPLE

Plaintiff Church of Scientology International's ("CSI") request that this
case be dismissed is in keeping with one of their most senior scriptures,"
to use to courts to harass and ruin people rather than win. It has been a
primary tactic since Hubbard gave the edict in 1955 when he wrote the
purpose of bringing a lawsuit:

"The purpose of the suit is to harass and discourage rather
than to win. The law can be used very easily to harass, and
enough harassment on somebody who is simply on the
thin edge anyway, well knowing that he is not authorized,
will generally be sufficient to cause his professional
decease. If possible, of course ruin him utterly."

(From Hubbard's 1955 "The Scientologist: A Manual of Dissemination of
Material." Emphasis added. Attached as Exhibit A) The basic reason that
Scientology does not use the courts for justice is because Hubbard
believed the Scientology justice system he invented was vastly superior
and that his system should become the planetary standard.

DR. GEERTZ IS THE TARGET OF SCIENTOLOGY'S VOW TO DESTROY "THE PSYCHS"

The key to understanding the mystery of the current lawsuit and its
tortuous route will be found in the above Hubbard directive plus one
further element: Defendant Dr. Uwe Geertz is a psychologist. Scientology
has vowed to destroy and take over the field of mental health. Thus Dr.
Geertz is the target of Scientology's equivalent of "The Final Solution,"
where a profession has become a universal scapegoat.

PSYCHS ARE SCIENTOLOGY'S SCAPEGOATS FOR EVERYTHING INCLUDING SEX

It is drilled into every Scientologist's head that all troubles and problems -
Hubbard's, Scientology's, America's, the world, this corner of the galaxy
and literally the entire universe - are due to psychiatrists and
psychologists, known collectively as "the psychs." In fact, Hubbard said
the ONLY cause of crime is the "psychs." He even goes so far as to say
"there are no laws at all which protect them" from being attacked. (See
Hubbard's "The Cause of Crime," Attached as Exhibit B. See also
declaration of Stacy Young also filed this date.)

The "psychs" are Hubbard's scapegoat for all historical ills going back
not merely scores of years but hundreds, thousands and even millions of
years. In Hubbard's paranoid view, everything from rock and roll to the
Third Reich and even sex itself were vile inventions of 'psychs'. (See
"Pain and Sex." Attached as Exhibit C.) As incredible as that may seem,
Hubbard actually believed that sex was literally invented by "psychs"
millions of years ago. While he doesn't come out and say it, the
implications are clear: all sex - even the attraction between couples - is
bad.

The intensity of Hubbard's anti-sex (and especially anti-female) attitude is
not known to many Scientologists. Starting in 1981, I had full access to
Hubbard's most private papers, diaries and letters. I continued to have
unlimited access to it for years as part of the work to write a biography of
Hubbard and was able to read letters to and from his parents, wives.
mistresses, friends and business associates. There were hundreds of
thousands of pages of material - much of it originals or carbon copies in
his own handwriting - that detailed his views about his life, his wives, his
family and sex. Much of this was written in the 1930s and 1940s but
extended into the 1970s. Some of these papers were diatribes against
females and were covered with red-ink drawings of genitalia around the
margins of the pages. He also graphically described what he wanted to
do to women, including hurting and raping them. Suffice it to say that it
was x-rated and sadistic. This was my initiation into the dark side of
Hubbard's views. (these papers were subsequently locked away so no
Scientologist will even know they exist, let alone allow anyone to see
them.)

Hubbard's anti-female attitude appeared first, in private writings in the
1930s and 1940s. His views of "the psychs" developed after the
publication of his first Scientology books in 1950 when he was courting
"the psychs" for approval of his system. When he was rebuked and
criticized, he became incensed and began to blame them for his troubles
with the press and his customers.

Thus Dr. Geertz is viewed as a part of the international (and intergalactic)
conspiracy that must be annihilated before Hubbard and Scientology can
reign on Earth.

CSI'S CASE IS PART OF THE "FAIR GAME DOCTRINE" AND "PSYCHS" ARE FAIR
GAME

CSI has a Fair Game Doctrine where any "enemy" can be "destroyed."
This doctrine is practiced against apostates, critics, the press and has
even been used against courts. It has been practiced against Dr. Geertz
(starting with this lawsuit that put him into bankruptcy) and his counsel in
this case (ranging from an investigation that this court ordered stopped to
vandalism of Mr. Graham Berry's property.

I will show how the Fair Game Doctrine started. how it has continued to
this day and how this court has been exposed to these end-
justifies-the-means methods. I will present this using the writings (now
called "scriptures") of Hubbard. These are the iron-clad policies
ofScientology.

"FAIR GAME": THOSE THAT HAVE NO RIGHTS; THEY AND/OR THEIR PROPERTY CAN
BE DESTROYED

The doctrine of Fair Game was codified on March 7, 1965, when Hubbard
issued titled "Suppressive Acts: Suppression of Scientology and
Scientologists: The Fair Game Law" (Attached as Exhibit D) Hubbard
wrote,

By FAIR GAME is meant, without rights for self, possessions or position,
and no Scientologist may be brought before a Committee of Evidence or
punished for any action taken against a Suppressive Person or Group
during the period that person or group is 'fair game'. A revision of
December 23 1965, changed it to read, "By- FAIR GAME is meant, may
not be further protected by the codes and disciplines of Scientology or
the rights of a Scientologist." As to what was a "suppressive person,"
Hubbard gave the definition:

A SUPPRESSIVE PERSON or GROUP is one that actively seeks to
suppress or damage Scientology or a Scientologist by Suppressive Acts.

SUPPRESSIVE ACTS are acts calculated to impede or destroy
Scientology or a Scientologist and which are listed at length in this policy
letter. (Caps in original. Some of the suppressive acts listed included
"public disavowal of Scientology; public statements against Scientology;"
asking for a refund of fees paid; and "writing anti-Scientology letters to
the press." Even turning a Scientologist into the proper authorities can
gain one the label of a suppressive. The issue also prohibits "1st degree
murder, arson, disintegration of persons or belongings not guilty of
suppressive acts." (Emphasis added.) In other words, killing suppressive
persons or destroying their property promotes Scientology and is
therefore ethical within the Scientology belief system.

WHY SCIENTOLOGISTS CANNOT GIVE UNBIASED TESTIMONY

The material just quoted also shows why Scientologists cannot give
unbiased testimony. If the testimony is viewed as critical of Scientology
or a Scientology executive, it would be a "public disavowal" and a "public
statement against Scientology" and would be a suppressive act. The
person could then be kicked out of Scientology and be made Fair Game
and sued. Since Scientologists don't want this to happen to them, they
will not make any critical remarks or remarks that may be deemed
critical. This is why Scientology officials have insisted that only active
Scientologists can be experts - because they will be biased to
Scientology rather than responding fully and honestly to the Court.

AN EXAMPLE OF HUBBARD IMPLEMENTING FAIR GAME

Scientologists like to find instances where Hubbard applied a doctrine so
they can imitate it. Hubbard gave an example of how Fair Game should
be applied shortly after he created the doctrine. Hubbard gave specific
orders on how to apply the Fair Game doctrine in HCO Executive letter
27 September 1965 or. "Amprinistics " (attached as Exhibit E) This was
what he called a "splinter" group, a group that was using Scientology
"technical" methods without his control. Hubbard's three-page issue
blasts the Amprinistics leaders with a variety of sexual charges (one of
his favorite topics for accusations) and says what should be done:

"They are each fair game, can be sued or harassed. Horner
can be barred out of any Commonwealth Country or
England as he was the subject of a deportation order from
England and his file has come alive again in the Home
Secretary's Office. Harry Thompson's wives and victims are
always looking for him to have him arrested. Watson is a
set-up for arrest as a homosexual. Any meeting held by
them should be torn up. The names of any persons
attending should be collected and they should be labeled
SP [suppressive person] as they have left Scientology.
These people are SP because they are seeking to avoid
auditing and retain their withholds. Once labeled, these
persons will not then be covered by amnesty and will never
be admitted to further training and processing. Persons
messing themselves up with Amprinistic [techniques]
should be refused any assistance. If these persons move
into your area act through any agency you can to have
them deported or arrested on whatever grounds. England is
currently too hot for them so they may tour about. Horner's
UK deportation order, Thompson's police record and
Watson's homosexuality make them very vulnerable to
deportation or arrest.

NOTE FROM SLOTH: The endquote mark of the last paragraph got lost in my version,
this represents my best guess as to where it ends.

Hubbard does not stop there. He goes on to issue a five-step order that
includes:

"(2) Harass these persons in any possible way....

"(4) Tear up any meeting held and get the names of those
attending and issue SP orders on them and you'll have lost
a lot of rats.

This order is has never been canceled and is still "scripture" as an
example how to attack "enemies." In fact, as an example of how Fair
Game was being implemented against another defendant, attached as
Exhibit F is a declaration from former member David Mayo who describes
how he was held captive for six months and was told he would "never
leave the property alive." (See pages 4-8) He describes the duress and
threats as he became the target of the Fair Game Doctrine (or "Fair
Game Law.")

HOW SCIENTOLOGY USES INVESTIGATION AND THE MEDIA TO ATTACK AND HARASS
CRITICS

In 1966, Hubbard began to codify those sections of Scientology that
would implement Fair Game. For example, on February 17, 1966, he
created the Public Investigation Section with a policy letter of that name
and date. (Attached as Exhibit G) He said it would serve "the useful
functions of an intelligence and propaganda agency. It finds the data and
sees that it gets action." The statistic of the unit included "the number of
derogatory news stories appearing that week related to enemies of
Scientology."

Hubbard also urged the priority of finding evidence of "murder, assault,
destruction, violence, sex and dishonesty, in that order. Investigations
which can uncover these factors in the activities of individuals or a group
attacking Scientology are valuable in the degree that they contain a
number of these factors." And note that Hubbard's use of such evidence
is not for law enforcement but to the media. "In that way," he wrote, "we
then Get rid of suppressive groups by investigation and disclosure."
(Emphasis added.)

The next day, on February 18, 1966, Hubbard wrote "Attacks on
Scientology" (Attached as Exhibit H) in which he again urged the use of
investigations. Suppressives, he said, have by definition comitted
criminal' acts. "These people who attack have secrets. And hidden
crimes. They are afraid." He thus urged they be investigated as this, he
said, would cause the attacker to withdraw.

A week later, on February 25, 1966, he wrote another "Attacks on
Scientology" policy letter (Attached as Exhibit I) in which he urged, to
"Start feeding lurid, blood sex crime actual evidence on the attackers to
the press.

See also Hubbard's "How To Do a Noisy Investigation" of 5 September
1966 (Attached as Exhibit J). The target is "attackers of Scientology".

FAIR GAME DOCTRINE SPECIFICALLY INCLUDES THE FILING OF LAW SUITS

On October 18, 1967, he issued "Penalties for Lower Conditions"
(Attached as Exhibit K) whereby Fair Game was automatically issued on
anyone (including staff members) who was an "enemy." Such people
were, he said, "Fair game. They may be deprived of property or injured by
any MEANS by any Scientologist without any discipline of the
Scientologist. May be tricked, sued or lied to or destroyed." (Emphasis
added.)

CANCELLATION OF FAIR GAME ONLY MEANT NOT USING THE WORDS ANY MORE
BECAUSE IT CAUSED "BAD PUBLIC RELATIONS"

In the late 1960s, Hubbard was having growing public relations problems.
One problem was Fair Game. To deal with it, Hubbard wrote an issue
that is often cited by CSI as evidence that Fair Game was canceled. But
a careful reading will show that nothing has changed but semantics. The
issue is "Cancellation of Fair Game" dated 21 October 1968. (Attached
as Exhibit L) The entire text of the policy letter (P/L) is as follows:

"The practice of declaring people FAIR GAME will cease.
FAIR GAME may not appear on any Ethics Order. It
causes bad Public relations. [Emphasis added.] This P/L
[policy letter] does not cancel any policy on the treatment
or handling of an SP. [suppressive person]

L. Ron Hubbard Founder

THUS THE SO-CALLED "CANCELLATION" OF FAIR GAME DID NOT CANCEL THE USE
OF FAIR GAME TACTICS

The original directive that CSI uses to say the Fair Game Doctrine was
canceled expressly establishes that the only change was to stop using
the words "Fair Game.". Hubbard was quite clear that tactics were not to
change. only the use of the words in public. As further evidence of Fair
Game continuing, Hubbard later wrote "Confidential: Targets, Defense" on
February 16, 1969, (Attached as Exhibit M) in which he listed "vital
targets on which we must invest most of our time..." The first and most
important: "T1. Depopularizing the enemy to a point of total obliteration."

MILITARY TACTICS ARE TO BE USED IN FAIR GAME

On the same day, February 16, 1969, he wrote "Confidential: Battle
Tactics" (Attached as Exhibit N) where he urged the use of military
tactics and strategy in dealing with the "enemy." He wrote,

"A good general expends the maximum of enemy troops
and the minimum of his own. He makes the war costly to
the enemy, not to himself. One cuts off enemy
communications, funds, connections. He deprives the
enemy of political advantages, connections and power. He
takes over enemy territory. He raids and harasses._All on a
thought plane--press, public opinion, governments, etc.
(Emphasis added.)

FAIR GAME TACTICS EXPLAIN THIS LAWSUIT

When the Fair Game Doctrine and Scientology's "Final Solution" attitude
towards "psychs" (psychologists and psychiatrists) are understood, this
lawsuit can be understood. It will also be seen that what was at issue
was not the deposition of the "celebrities" but those of the executives
who were in non-compliance with this Court's Order. The reason was
simple: they are the ones who directed this entire campaign.

HOW SCIENTOLOGY ATTORNEYS ARE USED TO CLAIM "ATTORNEY WORK PRODUCT"

Surveillance is one of the standard tactics used by Scientology and CSI.
It is often done by staff from the Office of Special Affairs ("OSA").
Tougher or more important assignments are given to private investigators
who are paid by attorneys so the investigation can be called "attorney
work product." This practice was because the 1977 FBI raid shattered
Scientology's intelligence network.

The court should note that it has been told that such practices were done
by a previous Scientology administration that has been eradicated. This
is not true. I am attaching the billings of a private investigator who was
doing surveillance on author Omar Garrison and apostate Gerry
Armstrong in 1982. (Attached as Exhibit O) These were billed to attorney
John Peterson. ("Peterson") However this investigation was being
directed by David Miscavige ("Miscavige") who at the time (mid-1982)
was my senior in an organization called Author Services, Inc. ("ASI") ASI
was a for-profit group that was purportedly a literary agency handling
Hubbard's books. We did handle Hubbard's works but our real function
was to serve as Hubbard's personal arm into the non-profit Church of
Scientology. This investigation by Tin Goose of Omar Garrison and Gerry
Armstrong was paid for by Church of Scientology funds on Miscavige's
orders while Tin Goose reported directly to Miscavige. Peterson was
merely the "cutout," to make it appear that it was attorney work product
and to keep it away from ASI.

HOW MISCAVIGE USED A "DOUBLE-BLIND" TO GO AFTER AN ATTORNEY

In 1982 a "double-blind" system was initiated by Miscavige when he was
directing the campaign against Boston attorney Michael Flynn. ("Flynn")
Flynn had been representing plaintiffs in suit against Scientology and
Hubbard, and Miscavige was demanding that Flynn be destroyed. (This is
the Fair Game Doctrine although the words were never used, per
Hubbard's orders.) Peterson was told to hire another attorney who had no
connection or any knowledge of Scientology. That fresh attorney was to
hire the private investigators to undertake certain harassing actions on
Flynn. The purpose of the double-blind was if the investigator was caught
and traced to an attorney, it would not be one hired by a Scientology
group and any illegalities could be protected twice as attorney work
product.

With the formation of the firm of Bowles and Moxon (attorneys for plaintiff
in this case), investigations were moved to them rather than attorneys
like Peterson because Bowles & Moxon are Scientologists and can be
manipulated and threatened. Peterson was not a Scientologist and could
not be so controlled.

EXPERTS AND COUNSEL ON THIS CASE WERE KEPT UNDER SURVEILLANCE

The court was advised of the investigation of counsel Graham Berry and
ordered that it be stopped. (It was not because CSI cannot stop. Such
investigations are required by Hubbard's "scriptures.") A similar
investigation and surveillance was done of other experts on this case
including myself and my wife. This went on for months. We have been
tailed on the freeways, in shopping malls and even while a hundred miles
from home on a day off. (In one instance, a tail I accosted confessed that
he was tailing me and that he was Scientology staff.) Our trash has also
been pilfered and former employers and associates interviewed. All of this
is inkeeping with the Fair Game Doctrine, hoping that they will find
something to intimidate the person with. (If that doesn't happen, then
something is concocted. They are now doing that with me, asserting that
I assaulted a Scientologist in the city of Hemet. Their insistence that I be
charged is being led - appropriately enough - by one of their key public
relations people, Ken Hoden, who gets his orders from David Miscavige
("Miscavige") who is the head of the Scientology empire. At this writing,
nothing has come of their baseless allegations.)

EXAMPLE OF TARGETING A PERSON IN LITIGATION WITH SCIENTOLOGY

Attached as Exhibit P is a Scientology program ("Julie's Background")
designed to deal with a court problem in 1979. Julie Christofferson. She
had sued the church and this program was written to document that the
people involved in the Christolfferson case are criminals with criminal
backgrounds and criminal records and that they engage in a criminal
conspiracy to defraud the organization under the guise of "home and
mother." Julie appears to be pure as the driven snow, so considerable
background data [Scientology's euphemism for covertly obtained data] on
her is needed to give us direction in locating the real facts of interest
about her.

Those "real facts of interest" are stated in the next paragraph as to what
Scientology wants on the plaintiff. The criminal background, drug history,
record of arrests, former employment, perversions of Julie, fully known
and documented, as needed.

The program then goes on for pages to tell how to do this. There is
nothing to indicate there is anything to find, merely the Hubbard-driven
assumption that anyone who sues Scientology or attacks Scientology
must by definition be a criminal. The program was written on Hubbard's
direction.

CSI'S REFUSAL TO COMPLY IS BECAUSE OF CSI'S COMPLETE DISDAIN FOR ANY
SYSTEM OTHER THAN HUBBARD'S

CSI's general non-compliance with the orders of this Court was because
of the disdain that Hubbard and the current leadership have for this and
any court as well as the law. Time and again Hubbard wrote how his
system of "justice" was superior to any system. Additionally Hubbard
and Scientology were constantly being challenged by the courts. In
Hubbard's view, neither he nor Scientology should have to answer to
anyone.

ACCORDING TO THE SCIENTOLOGY BELIEF SYSTEM. THE COURTS ARE PART OF A
CRIMINAL PLAN DIRECTED BY "THE PSYCHS"

Another reason Hubbard and Scientology hold the courts in such disdain
is Hubbard's view that the purpose of the justice system is to support
psychologists and psychiatrists. This is done by "psychs" creating
criminals who keep the courts alive who feed them back as a self-
perpetuating system, funded entirely by the government. Hubbard wants
to have the criminals fed to Scientology and to replace the legal system
of justice with Hubbard's system, thus collecting the money that he felt is
going to the psychiatrists and psychologists. (See attached as Exhibit Q
"The Criminal Mind and The Psychs," attached as Exhibit R "The Cause
of Crime," attached as Exhibit S "Criminals and Psychiatry," and
attached as Exhibit C "Pain and Sex.")

THE ORDERED DEPOSITIONS SHOULD HAVE PROCEEDED

The Court ordered David Miscavige, Norman Starkey, Mark Yager, Ray
Mitoff, Lyman Spurlock, Marty Rathbun, Greg Wilhere and Jonathan
Epstein to deposition. Most have, in turn, filed declarations to explain
why they know nothing that is germane to this case. To the contrary,
these are the executives who know more about this case than any other
people.

Despite Miscavige's protests, he runs all of Scientology, regardless of
corporate lines. In Scientology, there is only Scientology. Corporate lines
are set up as ways to deflect the courts, the IRS and the authorities.
When it comes to everyday work, Miscavige is appraised of every part of
Scientology, from the church to the secular. He also issues orders to all
sectors and approves all major transactions. His role is as the head of
Scientology is well known within Scientology. It is only when it comes to
matters such as this suit that he and his lieutenants must suddenly
conjure up the corporate lines and claim ignorance.

MISCAVIGE KNEW OF FISHMAN AND CROSSED CORPORATE LINES TO DEAL WITH
FISHMAN'S MONEY

Additionally, Miscavige knows about Defendant Steve Fishman
("Fishman") and the amounts of money that Fishman contributed to
Scientology. Miscavige had people removed from their positions because
of the Fishman's money and now Miscavige claims he knows nothing.
ButMiscavige knew of the massive amounts of money the Fishman had
contributed. Miscavige gave a briefing at Golden Era Studios near Hemet,
California, in 1987 to hundreds of staff (that included staff from non-CSI
corporations) about Fishman's contribution of about $80,000 for a library
of "leather-bound" tapes. In that briefing, Miscavige screamed and cursed
at the head of Golden Era Studios (Wendall Reynolds) because there
were no such tapes to be sold. Miscavige (who is Chairman of the Board
of the Religious Technology Center, a non-CSI entity) removed Reynolds
from his position on the spot and assigned Reynolds to the gulag known
as the Rehabilitation Project Force where he worked at hard labor for over
two years. (I was sentenced to the same gulag for 14 months. Reynolds
was there when I arrived.) Thus Miscavige not only knows of Fishman but
has admitted it to hundreds of others. His claim he knows nothing is
false testimony, as many can testify.

The others (Starkey, Yager, Mitoff et al) are Miscavige's immediate
lieutenants who carry out his orders into their various sectors. They too
know about the lack of corporate integrity and any role that Fishman
played in Scientology. They also know about the various Hubbard
directives I have quoted from.

FISHMAN WAS BEING URGED TO INVEST IN "SPECIAL PROPERTIES," WHICH IS
NOTHING BUT A FINANCIAL SCAM

The idea of "leather-bound tapes" is part of a line of "special properties"
that was created by Miscavige in 1982 when he was Chairman of the
Board at Author Services, Inc. ("ASI") I joined ASI in February, 1982, and
left it in 1989. One of ASI's functions was to make millions of dollars for
Hubbard. One way was by investments of Hubbard's fortune, which
Miscavige directed, even though Miscavige had no investment
background. Miscavige poured millions of dollars into oil speculation and
lost it without telling Hubbard. (At one point the estimate was that
Miscavige had lost about $50 million of Hubbard's.) "Special Properties"
was Miscavige's idea on how to recoup the millions before Hubbard (and
the IRS) found out. The idea was to create "leather-bound special
editions" and other items that could be sold at outrageous prices as an
"investment". Those who bought books at thousands or even tens of
thousands of dollars were then told a few months later how their
"investment" had increased. Meanwhile, on the open market, the books
were worth perhaps a hundred dollars, which was why Miscavige
prohibited the open sale of these "Special Properties." (ASI now denies
that there ever was a line of properties for investment.") This was how
Fishman came to spend an astounding $80,000 for a set of
"leather-bound" tapes, which didn't even exist, and why Miscavige knew.

CSI HAS MISREPRESENTED ITS ROLE IN RELATION TO THE "CELEBRITIES"

CSI's claim that it didn't want to put its "celebrities" through a hardship is
patently ridiculous. In my 20+ years in Scientology (which included
working with many of them), I never once heard anything like this. To the
contrary, it was just the reverse: "celebrities" would complain how they
were being used, how they were being ordered to promote Scientology
and being made to make media appearances when there was a legal
problem or a problem in the media. The fact that these "celebrities" did
not appear for their ordered depositions shows the control that CSI has
over them. Now CSI turns it upside down again, claiming their welfare is
why they want to drop a three-year old suit that has cost millions of
dollars.

THE DEPOSITIONS OF THE "CELEBRITIES" DID NOT INVOLVE CONFIDENTIAL
MATERIAL

CSI has made it a point that several "celebrities" will be exposed to
"confidential" material if forced into deposition. I know what material CSI
was referring to and those materials had nothing to do with the ordered
depositions. The "confidential" material is what is called "upper level"
material in Scientology. This material is reserved for certain steps in
Scientology "counseling," and had nothing to do with the ordered
depositions of "celebrities," none of whom are even familiar with them.

At no time has attorneys for Dr. Geertz asked me for any assistance in
handling this material, as to what it might mean, how they might ask
questions about it, how they might use it or how the material might be
presented to a person in any deposition, let alone indicate in any way
that they intend to use those materials with those "celebrities." Nor are
attorneys for Dr. Geertz capable of doing this without expert help for the
material in question is highly arcane, complex and bizarre and will make
absolutely no sense to anyone outside of Scientology. Thus the idea that
attorneys for Defendants will somehow expose these "celebrities" to this
"upper level" material is merely a sham and an excuse. What was feared
was that the other depositions would occur, namely that of Miscavige,
Starkey, Yager, etc.

CSI's attempt to use their own refusal to comply with the court as the
reason for dismissal is a classical Scientology through-the-looking-glass
strategy.

DENIAL OF LEGAL LIABILITY WAS A TACTIC TAKEN ORIGINAL WITH HUBBARD

It was a long a well-known fact to Scientology executives that Hubbard
ran Scientology, even though he had made public claims he was not.
That was why there were programs to make it appear that Hubbard had
no legal connection to the church. That tactic is what is now being used
for Miscavige who has taken over Hubbard's position at the top of
Scientology, even though Miscavige runs it just as Hubbard did. (See
Exhibit T for "Operation Bulldozer Leak", a program designed to create
that impression.)

CSI HAS NOT REFUTED YOUNG'S STANDING AS AN EXPERT

In the declarations filed to claim discovery is complete, CSI has tried to
refute my standing as an expert, even going to far as to twist the facts.
For example, Miscavige tries to refute my claim that I arrived on the
scene of Hubbard's before the authorities by saying that I arrived with
some gardeners and cooks. This is not only not true but ridiculous since
I arrived in the same entourage as Miscavige himself, two private
investigators and attorney Earl Cooley who handled the disposition of
Hubbard's body. Miscavige knows that I was a top Hubbard aide who was
privy to considerable material and so do many others. He (Miscavige) can
no more tell the truth about my role than he can about his, that he runs
all of Scientology. I stand by my declarations and the documents
supplied with them and am confident that the Court can winnow the
wheat from the chaff.

HUBBARD'S DEATH CREATED A POWER STRUGGLE THAT MISCAVIGE WON

Hubbard died in hiding in January, 1986. He had been in hiding for several
years. Even though we were in weekly written communication with him at
Author Services, Inc., it was our task to pretend we were not, to keep the
authorities from knowing how to reach him. During this time, Hubbard's
closest confidant was Pat Broeker who was living with him as his aide.
When Hubbard died, a power struggle erupted between Broeker and
Miscavige as to who would run Scientology. Miscavige won. Those on
Broeker's side were purged. That included me. I was sent to a desert
gulag for 14 months. Broeker's wife Annie gave in and arrived while I was
there. She later escaped once and was captured and returned and kept
under 24- hour guard. Pat disappeared and no one has heard of him
since. It is not known if he is alive.

HUBBARD'S AND OTHER MYSTERIOUS DEATHS IN SCIENTOLOGY

When it comes to the issue of deaths in Scientology, there are some
important ones to use as a measure, starting with that of its founder,
Hubbard, who died in January, 1986. I arrived at his secret ranch near
San Luis Obispo, California, within hours of his death, well before the
authorities. I went with Miscavige, attorney Earl Cooley, two private
investigators and a few other key, selected staff. It was our collective
task to take command of the situation. The greatest fear was that there
would be a panic in the Church of Scientology if the circumstances of
Hubbard's death were known. For example, while Hubbard's condition
deteriorated in the final weeks, his personal physician (Dr. Gene Denk)
was sent to Reno to gamble, leaving Hubbard with no medical attention.
Or that Hubbard's primary source of Scientology help was a person who
had taken LSD over 1000 times. Or that the story that Hubbard decided
to "leave the body" (Scientology's way of saying "died") was dreamt up at
the next morning to calm Scientologists. Or that the body was quickly
disposed of to avoid any autopsy that would reveal "medicines" that he
had been taking. Thus the actual truth of Hubbard's death has yet to be
told.

Hubbard's son Quentin also died under mysterious circumstances in
1976. He had disappeared from his home in Clearwater, Florida, and was
found unconscious in a car next to the Las Vegas airport. (Coroner's
report is attached as Exhibit U. He died unidentified, as a "John Doe.")
The engine of the car was on and a hose ran from the exhaust pipe
(although it appeared to have fallen off when the authorities arrived) to the
window, making it appear to be a suicide. But, like his father's death,
there were a number of nagging questions. For example, Quentin was
found unkempt with a beard stubble, a state that no one who knew
Quentin could accept. (He was ultra-meticulous in his appearance.) Or
that the license plate of the car was missing and found under a rock
some distance away. Or that his wallet was gone, making identification
impossible. Or that a near-empty bottle of liquor was found, as if he had
been drinking, when Quentin did not. Or that there were needle marks on
his arms, when he did not use drugs.

Another mysterious but key death was that of Flo Barnett, Miscavige's
mother-in-law. She died in 1985 of three shots to the chest and one to
the temple from a semi-automatic rifle. Two suicide notes were found.
Although she was only 5'3" tall (and weighed only 114 pounds), the
examiner determined she shot herself three times in the chest (with a
rifle) before shooting herself through the head. (See coroner's report
attached as Exhibit V.) What the authorities didn't know was that she
had left Scientology and was associating with apostates, to the anger of
her son-in- law Miscavige.

Defendant Uwe Geertz was prepared to present information about other
mysterious deaths, murders and suicides of Scientologists and former
Scientologists.

CSI DID NOT COMPLY WITH DISCOVERY

One unfamiliar with Scientology systems might think there would be no
other information to be provided but as a 20-year veteran and one
intimately familiar with the unchanging system, I can attest there is
considerable information that was not provided although requested by Dr.
Geertz.

CSI has repeatedly protested how many documents and people it made
available to Dr. Geertz. Being intimately familiar with Scientology files
and data-gathering procedures, I can say that CSI has not turned over
large volumes of requested material and personnel to Dr. Geertz that are
germane to this case. For example, there are extensive files (including
computerized) that would enable a person to determine the effect of
adverse press. These are kept and maintained on weekly basis. I
personally know of them for I have worked with and have seen these files.
They have been kept by Scientology for decades. These were not
provided to Dr. Geertz. Nor were other material that would have been
collected on Dr. Geertz. such as reports from private investigators, credit
checks, all standard actions in Scientology proceedings. Nor has CSI
supplied material regarding their investigation of Fishman's role in
Scientology even though CSI's corporate secretary Lynn Farny said he
had seen and reviewed such material.

Nor has CSI supplied those personnel that would know most about the
truth or falsity of the facts in question in the Time magazine article.
Those people are Miscavige, Yager, Willhere and Mitoff, Epstein,
Spurlock and Starkey would know about Fishman's financial roles and
Scientology financial scams.)

IT IS ROUTINE TO ALTER SCIENTOLOGY RECORDS AND FILES TO AVOID THE
AUTHORITIES

As early as 1971, I was introduced to the practice of altering Scientology
records and files to thwart the authorities. This occurred when I worked
as the Temporary Assistant Guardian in San Francisco. Under me was
the Intelligence Bureau which was where Scientology was running its
spies and agents. One day I received an order from the Guardian's Office
United States (in Los Angeles) and was told to do a "clean-up" on any
reference to Marsha Williams because she was going to become staff of
the Intelligence Bureau in Los Angeles and possibly become an agent.
What a "clean-up" meant was that I was to find and remove any reference
to her anywhere in the San Francisco organization, where she had
served, so there would be no record of her in the organization. This was
to thwart any investigation of her or any trace on her by any authorities. I
removed her name from various records and files and sent the material to
Los Angeles. I later saw her in Los Angeles, as Intelligence staff, when I
joined the US Guardian's Office.

After the Federal Bureau of Investigation ("FBI") raided three Church of
Scientology locations in 1977 to obtain documentation regarding
violations of the law, I worked with scores of other people to quickly
destroy any further evidence to keep it from falling into the hands of the
authorities. We were all verbally briefed how we had to go through files
and look for (1) any documents showing illegal activity and (2) any
documents to show that Hubbard was running Scientology (which he was
but we were trying to tell the authorities that he wasn't) and to destroy
these documents. In this campaign, the amount of documents that were
destroyed were in cardboard boxes stacked down halls. I do not know
the page count but the stack was about four feet wide, four feet high and
about 60 feet long. And this was from the location with the least amount
of files. And there was no doubt that we were doing this to destroy
incriminating evidence. In fact, several of us questioned this and were told
to shut up and keep shredding paper.

Circa 1983 when I worked at Hubbard's "literary agency" Author Services,
Inc., we were told there was a threat of an IRS raid on us and we had to
move documents. These went to another floor in the building where we
kept watch on them. There were about 50 bankers boxes of files that we
were keeping hidden from the authorities who were also serving
subpoenas to get records. Our task was to keep these other records
secret. The files were kept on that other floor for a couple of months.

This last instance is cited in particular to anticipate the reply of CSI that
the earlier examples were from an earlier regime that has been
overthrown. This is not true. In fact, the 1983 instance at ASI was
conducted by Miscavige who currently runs all of Scientology.

Thus the cleaning up of files to remove embarrassing or incriminating
material was routine and the non-appearance of Fishman's name in
certain groups is not indicative that he was not there.

CONTRARY TO THEIR DECLARATIONS, CSI IS STILL USING THE ORIGINAL GUARDIAN
OFFICE STAFF

On a number of occasions, CSI has tried to disassociate itself from the
Guardian's Office that was raided by the FBI in 1977 and the Guardian
Office staff that went to jail, including Hubbard's wife, Mary Sue. It has
been CSI's contention that those associated with the crimes were
purged. This is not true.

The precise target of the FBI raid was the Snow White Program in the
Intelligence Bureau of the Guardian's Office. In 1989 the Snow White
Program was still active and one of its key staff was Grace Marie Haddy.
(See "Non-Existence Formula" dated 12/16/89 from Show White Pgms
Chief OSA US attached as Exhibit W) Grace Marie Haddy was a key
executive of the intelligence bureau and was privy to all communications
detailing the illegalities that subsequently sent the 11 executives to jail.

Handling CSI's case before this court is Kendrick Moxon ("Moxon") who
was named as an unindicted co-conspirator when Mary Sue and the
others were indicted. Moxon was head of the Guardian Office Legal
Bureau in Washington, D.C. (See the "Stipulation of Evidence" attached
to the declaration of Vicki Aznaran, also filed 3/9/94 which includes a
description of Moxon's role in obstructing the investigation of the
Department of Justice.)

THIS CASE DOES NOT CONCERN PLAINTIFF CSI

With over 20 years as a staff member in various Scientology entities,
both inside the Church of Scientology and in secular Scientology groups,
I can say with confidence that after reading the article in Time magazine
and the section for which Fishman and Dr. Geertz are being sued, I did
not think of CSI. Although I was well aware that CSI existed, it would
have been one of the last entities that would have come to mind. The
article and the sections in question are about Scientology as a subject
and practice, including the secular side of Scientology. (The secular side
of Scientology is a multi-million dollar activity that has been kept hidden
from the court. This side promotes that Hubbard's writings - the same
ones used in this case as scriptures" are non-religious and "secular" and
can be used in commercial enterprises to help the business or a client.
This is the Jekyll & Hyde syndrome of Scientology, how they pretend to
be a religion or a business, according to the potential customer or
situation.)

CSI'S CASE DOES NOT HAVE MERIT FOR SEVERAL COGENT REASONS

Besides the fact that the Time article is not about CSI, there are
additional reasons why CSI's case has no merit. Some of these have
already been covered. (1) CSI refused to comply with discovery. (2) CSI
never intended to complete discovery because the suit was brought
solely for malicious reasons (to punish a member of a group Scientology
has promised to destroy, according to the Fair Game Doctrine.) (3) CSI
is not the true plaintiff. Being familiar with the ecclesiastical and
corporate structures of Scientology, I know by reading the passages at
issue that Dr. Geertz was not speaking of Plaintiff Church of Scientology
International ("CSI"). However that is one of the roles that CSI has, to
intervene, because it has the manpower to wage lawsuits and to carry
out the Fair Game Doctrine via the Office of Special Affairs. (4) There is a
likelihood that what Dr. Geertz said is true, that Fishman was told to
"end cycle" and to kill Dr. Geertz. CSI's refusal to provide information and
deponents has prevented an adequate defense. But based on my 20
years in Scientology and seeing the level of criminality that was able to
permeate the organization - always kept from the view of all but a select
few - I cannot discount his allegations. (5) Even if Defendants statements
are false, CSI was not hurt. By their own admission, CSI has no
members that can be wronged. Additionally by Scientology's own
writings, no press ever hurts them, especially anything in Time
magazine. To the contrary, they have claimed that they grow in the face
of such adverse publicity. Thus CSI must either admit that they were not
harmed or admit that their Hubbard's claims of Scientology's infallibility
are false.

The simple truth of this case boils down to this: the suit was brought
under the "anti-psych" Fair Game doctrine by an entity without members
and without standing (CSI) because it has an anti-"psych" arm whose
function is to take over the field of mental health and destroy Hubbard's
enemies. I know because I worked at that echelon for nearly 20 years
and know it and the tactics intimately.

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

Executed in Los Angeles, California, this 9th day of March, 1994.

Robert Vaughn Young

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