Sunday, 26 October 2014

Let's Push Some Buttons...

LRH was charismatic...if he wasn't... he would not have pulled it off...he could be Prince Charming himself...but he was an absolute bastard...chain lockering, overboarding  and systematically, alienating everyone that gave him any Father loved this man...L. Ron Hubbard...still loving the alien... 

and it was his Father tried to kill him through his mind...he was already dead and miraculously cremated...but my Father tried to kill him his own mind because of what he had done...he tore are family apart and made it non existant...I am also non existant...just a mere footnote in the anals of scientology...

It's alright, because being a footnote is better than being a traitor...there are already far too many of them... 

From: Reposter 
Newsgroups: alt.religion.scientology
Subject: March 9, 1994 Declaration of Stacy Brooks Young
Date: 9 May 2002 12:26:48 -0700
Organization: Newsguy News Service []
Lines: 2251
X-Newsreader: Direct Read News 2.91
Xref: alt.religion.scientology:1514194



               I, Stacy Brooks Young, declare as follows: 

               1 . I am over the age of 18 years. 

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

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

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

My Extensive History in the Upper Echelons of Scientology
Management Qualify Me as an Expert.

5 . I was a member of the Church of Scientology for nearly 15 years, from
January 1975 until July 1989. From October 1975 until I left, I was a member of
the Sea Organization, the most dedicated group of Scientologists in the entire
organization. I spent most of my time from 1978 until 1989 in a highly
confidential section of Scientology management which was known as the Guardian
Office until 1982 and is today called the Office of Special Affairs. This
section of Scientology is responsible for dealing with all external public
relations, all matters relating to civil litigation or criminal matters, all
governmental relations such as the IRS, and all critics of Scientology.

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

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

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

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

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

11. All Scientologists consider that Scientology is the only way for Mankind to
go free. For a Scientologist this means getting "exterior" to the physical
body ("exteriorization") and, indeed, to the entire physical universe. In fact,
L. Ron Hubbard created a new category of humanity for those who go through
all the levels of Scientology processing; they transcend the state of Homo
Sapiens and become what he called Homo Novis (similar to Nietsche's
Superman). Scientologists expect that once they have attained this state they
will be free to travel throughout the galaxies, freeing others who are in the
               of the physical universe. 

12. The route out of the physical universe trap is called "The Bridge to Total
Freedom." Every Scientologist is at one stage or another on this Bridge, and
they are expected to get everyone else moving on this Bridge as well. The idea
is for everyone on Earth to get exterior to the physical universe. The only
people who aren't included are "suppressives," meaning those who have been
critical of Scientology.

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

14. At the level of OT 3, one is allowed access to handwritten notes by Hubbard
which detail a terrible disaster that happened in this sector of the universe
75 million years ago. The head of the Galactic Federation, whose name was Xenu,
solved a massive overpopulation problem by rounding up billions upon
billions of people and transporting them in blocks of ice to several volcanoes
on Earth, which was known as Teegeeack at the time. They were dumped near
the volcanoes and subjected to H-bomb explosions. At the same time, they were
subjected to a series of images which were electronically driven, or
"implanted," into their minds. After the "implant" was completed, these
disembodied beings were transported to Hawaii and Las Palmas where they were
packaged up into "clusters." Attached hereto as Exhibit 1 is a copy of the OT 3

15. According to Hubbard, the OT3 implant is rigged to kill anyone who finds out
about it before they have received the lower levels of Scientology
processing. Needless to say, it is a major revelation to discover that one is
covered from head to foot with these disembodied beings, called "body thetans"
or "BT's" in Scientology. One has literally millions, or even billions of these
BTs, and they have to be audited on very precise processes to get them to wake
up and disengage themselves (or "blow") from the person's body. The idea is that
once all of these BTs have been gotten rid of, one will be able to
exteriorize from the body at will. These BTs can cause illness and even insanity
if they become upset, so it is important to get rid of them as quickly as
possible and to make sure one has done a very thorough job of it. (See Exhibit
2, "What the Church of Scientology Doesn't Want You to Know," by Jeff
Jacobsen and Robert P.J. Day, and "The Total Freedom Trip," by Jon Atack, for
more information about the practices of Scientology.)

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

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

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

19. At the end of 1977 I transferred to the United States Guardian's Office
("USGO") in Los Angeles. I was a staff member in the USGO from January 1978
through January 1982. The Guardian's Office was the part of Scientology that
handled Public Relations, Intelligence and Legal matters for Scientology.

20. Because of my technical background, I was posted as the Organizing Officer
("Org Officer") for the Public Relations Bureau and, later, as the Org Officer
for the entire Guardian's Office. As the Org Officer my functions included the
handling of all personnel and organizational matters, such as correcting a staff
member who made mistakes, taking care of staff members who were sick or upset or
in trouble, recruiting new people for staff, and promoting or demoting
staff members as needed. I was also responsible for the establishment and proper
administration of all the Guardian's Office personnel throughout the
United States. Because the Guardian's Office oversaw certain aspects of the
administration of all other Scientology organizations, I became very familiar
with the overall structure of Scientology and how the various organizations
interact with each other and with the outside world.

21. In early 1982 I was assigned to a unit known as Special Project as a Public
Relations Assistant under my husband, Robert Vaughn Young. In this
position I became familiar with the L. Ron Hubbard archives material, which was
the complete collection of all of Hubbard's personal papers, including
diaries, letters, and notes that he had kept from a very early age.

22. Several months later Special Project became what is now Author Services,
Inc. ("ASI"), a for profit company whose ostensible purpose was to be L. Ron
Hubbard's literary agency. I was taken out of public relations and made the
Organizing Officer for ASI in April 1982. In this position I worked directly for
David Miscavige, who was Chairman of the Board of ASI ("COB ASI"), to carry out
his orders concerning the staff of ASI.

23. David Miscavige, known as DM, has been the head of Scientology since 1981.
His loyalty to L. Ron Hubbard and Scientology is absolute, and he is
utterly ruthless about maintaining his power. He moved the seat of power from
ASI to the Religious Technology Center (RTC) in 1987, because it was more
defensible to run Scientology from a non-profit corporation than from a for
profit corporation. At that point he appointed himself Chairman of the Board of
               RTC ("COB RTC"), which is his current title. 

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

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

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

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

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

29. As a result of this experience I am familiar with the absolute control which
the highest levels of Scientology management have over the behavior and
thought processes of every Sea Org member. There is only one way for a good Sea
Org member to behave and think, and any deviation from this is punished
immediately and severely. In turn, it is the responsibility of all members of
Sea Org management to bring about the same pattern of behavior and thought in
all Scientologists under their authority, regardless of whether those under
their authority are part of the "church" or the various "secular" arms of
Scientology. This distinction means nothing within Scientology; it was created
purely to facilitate dissemination of Scientology and to fend off
               Scientology's "enemies," such as the IRS. 

30. From May 1983, when I was allowed off the RPF, until July 1984 I was posted
as Course Supervisor at the International Training Organization (ITO) in
Los Angeles. From this position I trained hundreds of fledgling Scientology
executives from all over the world on the administrative and management
policies of L. Ron Hubbard known as the Organization Executive Course, or OEC.
As a result of this experience I am very familiar with the administrative
policy of Scientology and know that Hubbard formulated it to facilitate the
establishing and organizing of his worldwide network of Scientology

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

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

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

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

CSI Had no Standing to File This Case.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

50. The idea that the remarks attributed to Fishman and Geertz in the Time
Magazine article upon which CSI's claims are pruportedly based refer to CSI
rather than to Scientology generally is absurd. Inside the Scientology empire no
one takes the corporate structure seriously. The corporate structure is a
contrivance to enable Scientology to interface to its advantage with the "wog"
world. This Court should not be fooled by the corporate sleight of hand
which was attempted in this case. "Scientology," "Scientologist" and "the
church" refer to the overall, generic empire of Scientology, not to CSI, and no
even within Scientology would think of CSI when reading those words, much less
the general public.

It is CSI That is Harassing, Not the Defendants

51. CSI asserted that this case must be dismissed to protect several Scientology
celebrities who were noticed for brief depositions not to exceed two hours
each. CSI claims that these celebrities were served for the express purpose of
harassment and abuse. CSI asserted that it feared these celebrities would be
exposed to confidential upper level materials if CSI allowed them to be deposed.
CSI further asserted that "CSI has seen its religious tenets and scriptures
assailed; it has been compelled to produce or offer for deposition the
religion's most senior ecclesiastical leaders so they can be reviled; and it has
a transparent campaign to harass CSI into default." CSI cited this as its excuse
to move to dismiss this entire case.

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

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

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

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

CSI Is Bound by Its Own Scripture to Harass Its Critics

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

"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."

57. Hubbard also urged Scientologists to employ private detectives to
investigate anyone who criticized Scientology. He added, in language
               apropos to this lawsuit: 

". . . we should be very alert to sue for slander at the slightest chance so as
to discourage the public press from mentioning

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

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

"When we need somebody haunted we investigate.... When we investigate we do so
noisily always. And usually
investigation damps out the trouble even when we discover no really pertinent
facts. Remember that by investigation
alone we can curb pushes and crush wildcat people and unethical 'Dianetics and
Scientology' organizations....

"Of twenty-one persons found attacking Dianetics and Scientology... eighteen of
them under investigation were found to
be members of the Communist Party or criminals, usually both. The smell of
police or private detectives caused them to
fly, to close down, to confess. Hire [private detectives] and damn the cost when
you need to."

59. As author Jon Atack wrote in his well-researched book, A Piece of Blue Sky:
Dianetics, Scientology and L. Ron Hubbard Exposed:

"A mood was being created in which staff members would become 'deployable
agents,' as sociologist Roy Wallis called
Hubbard's henchman in his excellent study of Scientology. After all, Hubbard
never gave any indication of the possibility
that a complaint against him or against Scientology could be justifiable. The
tactic of 'noisy investigation' originated in
the Manual, and came to mean harassment by defamation. Hubbard certainly did not
mind if the defamation was grossly
exaggerated, or even a total fabrication. If you throw enough mud, some will
stick. The Manual of Justice suggests outright

(The section of the book which contains this passage is attached as Exhibit 5.)

60. In 1960 Hubbard wrote another policy called "The Department of Government
Affairs" (attached as Exhibit 6), which stated, in part:

                         Only attacks resolve threats. 

"In the face of danger from Govts or courts there are only two errors one can

                                  (a) do nothing and 

                                  (b) defend. 

                         The right things to do with any threat are to 

(1) Find out if we want to play the offered game or not,

(2) If not, derail the offered game with a feint or attack upon the most
vulnerable point which can
                                  be disclosed in the enemy ranks, 

(3) Make enough threat or clamor to cause the enemy to quail,

                                  (4) Don't try to get any money out of it, 

(5) Make every attack by us also sell Scientology and

                                  (6) Win. . . . 

"The goal of the department is to bring the government and hostile philosophies
or societies into a state of complete
compliance with the goals of Scientology. This is done by high level ability to
control, and in its absence, by low level
ability to overwhelm. Introvert such agencies. Control such agencies.
Scientology is the only game on Earth where
everybody wins. There is no overt in bringing good order."

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

62. In another policy statement called "Attacks on Scientology (Additional
Policy Letter)" (attached as Exhibit 7) Hubbard instructed Scientologists to:

                         "(1) Spot who is attacking us." 

"(2) Start investigating them promptly for FELONIES or worse using our own
professionals, not outside agencies."

"(3) Double curve our reply by saying we welcome an investigation of them."

"(4) Start feeding lurid blood, sex, crime actual evidence [sic] on the
attackers to the press."

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

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

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

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

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

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

CSI is Accusinq the Defendants of Its Own Criminal Activities

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

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

Scientology Doctrine Requires That Psychiatrists and
Psychologists Must be Destroyed

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

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

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

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

75. In 1970 Hubbard wrote "The Psychiatrist at Work" (attached as Exhibit. 10).
He attacks psychiatry as follows:

                         " . . . psychiatry is making insane people. 

"This is why the insanity statistic is soaring and why the crime statistic is on
a wild climb....

"The psychiatrist has masters. His principal organization, World Federation of
Mental Health, and its members, the
National Associations of Mental Health, the 'American' Psychiatric Association
and the 'American' Psychological
                         Association, are directly connected to Russia. . . . 

"It goes without saying that the savagery and fraud of psychiatry must cease and
that auditors must encourage in state and
public and through all their connections displacing psychiatric abuses with sane

76. Obviously, psychiatrists and psychologists were evil because their services
competed with Scientology auditing. In a 1971 document by Hubbard
               called "Confidential" (attached as Exhibit ll), he wrote:

"Policy is that we assign any case or upset in Scientology to past damage and
interference with the person by medicine or
psychiatry. They were sent to us after medicine or psychiatry had already
destroyed them. We cannot be blamed for
                         psychiatric or medical failures. 

"By continually repeating this, make the AMA, Nats [National Associations of
Mental Health], etc. very wary of using our
name on these psychiatric and medical failures. Both subjects are guilty and the
statement is demonstrably true. Use it
often. Make it known to the enemy that this is our policy as a restraint on
their fetid imaginations: 'Every time you attack
                         us we will disclose more records of your failures."' 

77. In another 1971 document of the same date, entitled "For Public Advicest"
(attached as Exhibit 12), Hubbard wrote:

"It is time we begin to label Psychiatry for what it is, the greatest failure of
the Nineteenth Century. Every notorious
criminal and defector of the Twentieth Century was in psychiatric hands before
the crime. Burgess MacLean, the Texas
Tower murderer, Manson and all the rest were psychiatric failures first. Every
infamous modern assassin was a psychiatric
failure. Psychiatric victims are endless trouble to our society. We are tracing
social turmoil, unrest, widespread drug
                         addiction to psychiatry. 

"We wish to issue a public warning that psychiatry kills. We in Scientology
stand ready to help anyone, and help
Governments rid themselves of psychiatric crime. There is urgency in this. In
too many cases we are asked to repair persons
already maimed beyond human tolerance by psychiatric interference and brutality.
We blame psychiatric failure for the
state of modern society. We will do all we can to help, but Nineteenth Century
Psychiatry must go. We have never had a
failure or upset that psychiatry had not first ruined."

78. In 1980 Hubbard wrote "Criminals and Psychiatry" (attached as Exhibit 13).
In it Hubbard said:

"Almost every modern horror crime was committed by a known criminal who had been
in and out of the hands of
                         psychiatrists and psychologists, often many times.... 

"The most charitable look at this would be that the psychologists and
psychiatrists are simply incompetent. But other
                         more sinister implications can be drawn. 

"Developed in the latter part of the nineteenth century, they appeared on the
militaristic scene of a rearming and
conquest-minded Germany. At that time, the archcriminal Bismarck was laying the
groundwork for the slaughters of World
War I and World War II. It fitted with the philosophy of militarism that man was
an animal and that there was neither soul
nor morality standing in the way of the wholesale murder of war. Up until that
time the Church had some influence on the
state and possibly some power in restraining bestiality and savagely insane
conduct, but small as it might have been, it
was incompatible with the unholy ambitions of the militarists. That man was only
an animal after all, soulless and entitled
to no decency, bound to be a popular doctrine. That insanity consisted of urges
to harm others would have been a very
unpopular idea to government heads who had nothing else in mind. . . .

"Spawned by an insanely militaristic government, psychiatry and psychology find
avid support from oppressive and
                         domineering governments.... 

"The credence and power of psychiatry and psychology are waning. It hit its
zenith about 1960; then it seemed their word
was law and that they could harm, injure and kill patients without restraint.
The appearance of an actual technology of the
mind Dianetics and Scientology-- has played no small part in acting as a
restraint. At one time they were well on their way
to turning every baby into a future robot for the manipulation of the state and
every society into a madhouse of crime and
                         immorality. . . . 

"The world is turning, things change. And there may come a day when the mad dogs
of the world are not given over to the
charge of mad dogs. But that will be to the degree that you successfully carry
forward Dianetics and Scientology."

79. In a 1981 document called "Dianetics and Scientology Compared to 19th
Century Practices" (attached as Exhibit 14), Hubbard wrote:

"A comparison between Dianetics and Scientology and psychology and psychiatry is

"The two 19th century subjects, psychology and psychiatry, do not achieve ANY
good results. On the contrary they are
destructive beyond belief. They make crackpots, sexpots and vegetables when they
do not outright kill....

"The character of the Governments themselves is established by their tolerance
and use of psychology and psychiatry. In
no human race of any civilized repute has any law condoned broad mayhem and
murder of their populations. Yet under
modern governments psychology and psychiatry not only have carte blanche but
also get insistence on their use....

                         "IS this a civilized world we're living in?

"I'm afraid it only will be when Dianetics and Scientology can bring wisdom
enough to Man to blunt his furious efforts to
                         do himself in." 

80. In 1982 Hubbard wrote "The Criminal Mind and the Psychs" (attached as
Exhibit 15), which states, in part:

"It has often been noted (and routinely reported in the papers) that criminals
'treated' by psychologists and psychiatrists
                         go out and commit crimes. 

"It could be suspected that these 'practitioners' used pain-drug-hypnosis and
other means (under the guise of treatment) to
induce the criminal to go out and commit more crimes. And possibly they do....

"So let us look at psychs again -- what they call 'treatment' is a suppression
(by shocks, drugs, etc.) of the ability to think.
They are not honest enough, these psychs, being just dramatizing psychotics
themselves for the most part, to publish the
fact that all their 'treatments' (mayhem, really, when it is not murder) make
people more stupid....

"The answer to crime is rising IQ. But only the Scientologist can do that."

81. In another 1982 document called "The Cause of Crime" (attached as Exhibit
16), Hubbard wrote:

" . . . So what IS the cause of crime? The treatment, of course! Electric
shocks, behavior modification, abuse of the soul.
These are the causes of crime. There would be no criminals at all if the psychs
had not begun to oppress beings into
                         vengeance against society. 

"There's only one remedy for crime--get rid of the psychs! They are causing

"The psychs should not be let to get away with 'treatment' which amounts to
criminal acts, mayhem and murder. They are
not above the law. In fact, there are no laws at all which protect them, for
what sane society would sanction crime against its
citizens even as science? They should be handled like any other criminals. They
are at best dramatizing psychotics and
dangerous, but more dangerous to society at large than the psychotics they keep
in their offices and loony bins because
they lie and are treacherous. Why the government funds them I do not know. They
are the last ones that should be let loose
                         to handle children." 

82. In another 1982 document entitled "Pain and Sex" (attached as Exhibit 17),
Hubbard announced that psychiatrists and psychologists (collectively
called "psychs") had been behind all of our troubles for millennia (and he also
revealed his bizarre view of sexuality):

"There are two items in this universe that cause more trouble than many others

                         "One is PAIN. 

                         "The other is SEX.... 

"Despite the false data of Freud, psychologists, psychiatrists and other
criminals, they are not native to a being. They are
only artificial wavelengths. They have exact frequencies that can be

"Destructive creatures who do not want people big or reaching-- since they are
terrified of punishment due to their
crimes--invented pain and sex to shrink people and cut their alertness,
knowingness, power and reach....

                         "Pain and sex were INVENTED tools of degradation.... 

"Combined, pain and sex make up the insane Jack-the-Rippers (who killed only
prostitutes) and the whole strange body of
sex murder freaks, including Hinckley [who shot President Reagan], and the
devotees of late night horror movies. Under
the false data of the psychs (who have been on the track a long time and are the
sole cause of decline in this universe) both
pain and sex are gaining ground in this society and, coupled with robbery (which
is a hooded companion of both), may
                         very soon make the land a true jungle of crime. 

"Go into any asylum or a prison and look at the increasing institutional
population and know what you are looking at. In
the main, these are pain and sex addicts, decadent and degraded and no longer
capable. They were sent on that route down
through the ages by the psychs and here they are still in the psych's hands! And
do they get well or go straight? Oh no.
Whether in prisons or insane asylums, they just get worse. And the psychs in
both places rub their bloodied hands as they
turn their products loose again upon the remaining population! It's no accident.
And the stocks-in-trade of psychs are
                         PAIN and SEX." 

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

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

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

Fishman's Experience in Scientoloqy Drove Him to a Psychotic Break.

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

87. It is utterly forbidden for anyone with a serious psychiatric background,
including an extensive history of hypnosis such as Fishman had, to be allowed
to have any Scientology processing at all. Attached hereto as Exhibit 19 is a
copy of Hubbard Commincation policy letter entitled llIllegal PCs, Acceptance
of High Crime PL." I have been advised by Mr. Berry that it was well known by
Scientology operatives that Fishman was not eligible for processing because
of his history of therapy with Dr. Uwe Geertz; yet he was induced to buy more
than $100,000 worth of Scientology books, written materials, prints and
E-Meters, clearly being led to believe that he would be welcomed into the
privileged circle of dedicated Scientologists.

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

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

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

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

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

93. There are different types of PTSness. Some of these are listed in an October
27, 1964, policy by Hubbard known as "Policies on Physical Healing,
Insanity and Troublesome Sources." Attached hereto as Exhibit 20 is a copy of
Hubbard Comminication Office Policy letter entitled "Policies on Physical
Healing, Insanity and Troublesome Sources". Ten types of PTSness are listed in
this policy letter, each one of which has to do with types of people who
have caused Scientology "considerable trouble." They include people who have
sued the church, newspaper reporters, family members who are hostile to
Scientology, etc. They are listed as Type A through Type J, thus the policy has
been nicknamed the "A to J policy." When someone is labelled as being any
of these types of PTS, he or she is barred from getting any Scientology
processing (auditing) or training, because people who fall into these categories
historically caused trouble for the organization, either by bringing legal
action against it or by giving negative information to the press.

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

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

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

97. This created an explosive situation, one which clearly could lead to a
psychotic break in Fishman. Even as recently as September 1993, Ray Mithoff,
Senior Case Spervisor International, the most senior Scientology technical
expert in the world, supervised the auditing of a person in England who had had
a psychotic break as a result of her experiences with Scientology. A copy of
Scientology's report on this incident is attached hereto as Exhibit 21. This
person had a psychiatric history, and the mixing of psychiatric techniques with
those of Scientology had caused the psychotic episode. So it was
obviously known that Fishman risked a Type 3 psychotic break if he were allowed
training or auditing, yet he was sold thousands of dollars worth of
materials anyway, including an E-meter with a solo auditing capacity permitting
him to self audit. Thus, either intentionally or out of greed and negligence,
Scientology created a situation in which Fishman would almost certainly suffer a
psychotic break and become a Type 3 PTS, as explained below.

98. The types of PTSness described earlier, Types A through J, relate to
different types of threat a person can pose to Scientology. There are also three
of PTSness, known as Type 1, Type 2 and Type 3, which relate to a person's own
state of mind and physical health. A person will manifest PTSness through a
range of conditions, all the way from a minor cold to a more serious illness
(all illness is a sign of PTSness) to full-blown insanity. All PTSness is the
of being connected to one or more suppressive people, suppression being defined
as "a harmful intention or action against which one cannot fight back." A
copy of a Hubbard Comminications Office Bulletin entitled "Seach and Discovery"
and describing these PTS types is attached hereto as Exhibit 22.

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

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

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

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

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

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

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

106. In a September 17, 1951, tape called "Some Notes on Black Dianetics,"
Hubbard stated:

"A person can drive himself quite mad with Dianetics without any trouble. What
you have concentrated on in your study of
Dianetics has been the process of making people well. That is your emphasis
line. But don't think for a moment that that is
any more than half of it. There is as much data on how to make people insane,
uncomfortable, sick or dead as there is on
                         how to make them well."

A copy of the transcript of this taped lecture is attached hereto as Exhibit 23.

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

108. Hubbard explained how to do it in the following passage from "Some Notes on
Black Dianetics":

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

109. In that same lecture Hubbard provided a blueprint for getting someone
incarcerated, just as Fishman was, without anyone ever finding out that the
               person was set up: 

"We find that nobody can protest an implanted engram [meaning a hypnotic command
given to a person such as was
portrayed in "The Manchurian Candidate"] except the person into whom it has been
implanted. He is the only one who can
protest this. He is the only one who can sign out a warrant. Even if he goes
insane, nobody can sign out a warrant. So he
could say, 'Well, it was Bill and I know it was Bill and I saw Bill and Bill has
taunted me with it since,' and so forth, but if
he has been pronounced insane... he has lost his civil rights and he can't issue
a warrant. In other words, this is legal
murder, legal punishment and so forth. Because the law does not know anything
about this, no laws exist to prevent it or
                         inhibit it." 

110. In another tape called "The Complete Auditor, Part I," delivered on June
28, 1951, Hubbard said:

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

A copy of the transcript of this taped lecture is attached hereto as Exhibit 24.

111. In still another tape, called "Outline of Therapy," Hubbard stated:

"Out of Scientology you could formulate a very fine type of thought warfare.
Works much better than an atom bomb. An
atom bomb just kills people, but you could take thought warfare and you could
enslave them utterly. You could make
                         complete slaves out of them." 

A copy of the transcipt of this taped lecture is attached hereto as Exhibit 25.

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

113. Hubbard himself ordered that "reverse processes" (or Black Dianetics) be
run on people he felt were particularly dangerous to Scientology. In a 1968
issue he declared several people fair game (meaning they could be lied to,
tricked or destroyed), and instructed that they be run on reverse processes if
ever came into an org. Additionally, he ordered that "Any Sea Org member
contacting any of them is to use Auditing Process R2-45." This was a reference
the use of a .45 semi-automatic pistol. Hubbard defined R2-45 as a very fast way
of getting someone exterior to their body. (See Exhibit 26.) A copy of this
'declare' is attached hereto as Exhibit 27 (see item 7) - Hubbard mde it clear
that he did not take suicide seriously in a taped lecture called "Create and
Confront," given on January 3, 1960, as part of the "State of Man" lecture
series. See
Exhibit 28 for a transcript of "Create and Confront," particularly pages 93 and

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

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

116. When I was in Scientology I was assigned to keep watch over a young girl in
her early twenties who became Type 3 PTS after being forced to sever all
communication with her family, because they were upset about her involvement in
Scientology. This incident occurred in Hemet, California, at the
               high-security international headquarters of Scientology. 

117. One day this girl approached me and began to babble, making no sense at
all. Recognizing the symptoms of someone who was going Type 3, I
immediately alerted one of the security guards so that she could be put under
watch. Sure enough, within an hour she was in a full blown psychotic break.
She did not know who she was or where she was and she began to get violent. She
lost touch completely with the real world and began to hallucinate,
               imagining conversations, events, people, and whole scenarios. 

118. L. Ron Hubbard wrote a series of issues detailing what to do when someone
"goes Type 3." These issues comprise what is called the Introspection
Rundown, a rundown being a series of specific actions to take to achieve a
specific result in Scientology processing. Hubbard felt that the Introspection
Rundown was a major breakthrough in the handling of psychosis, and that people
in mental institutions could be cured by following these steps. A copy of
               the Introspection Rundown is attached hereto as Exhibit 29. 

119. The first step is to isolate the person completely from everyone except the
people assigned to watch over the person. This is called "Isolation Watch." I
was assigned to watch this girl, so I studied the issues to ensure I would
handle her correctly. We were not to say a word around her. She was to have
complete silence to allow her to calm down (to allow her body thetans to go back
to sleep, although she could not be told about this, since she was not up
to that level in her processing). This went on for many days as she was in a
serious psychotic incident. None of the people assigned to watch her had any
               formal training in dealing with psychosis. 

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

121. She was never referred to any mental health practitioner, because
Scientologists believe that all psychiatrists and psychotherapists are
completely evil.
Hubbard preached the evils of psychiatry so thoroughly that no one in
Scientology would ever consider letting a mental health practitioner examine
anyone, even someone who is in the middle of a psychotic episode. See several
examples of Hubbard's writings on psychiatry attached hereto as Exhibit 30.
This girl was not even given anything to calm her down except a mixture of
calcium and magnesium which was supposed to relax her and let her sleep. It
did not have that effect; this girl could hardly sleep at all and soon became
exhausted, which simply compounded the problem.

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

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

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

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

126. Maggie Butterworth, former OSA operative David Butterworth's wife, was
usually assigned to supervise any Scientologist in Los Angeles that had a
psychotic break, and I believe that she was in charge of Cat Morrow, in close
liaison with Sandi Wilhere, a highly trained case supervisor in CSI who used to
be one of the most senior technical experts in Scientology (Miscavige reportedly
demoted her to kitchen maid recently).

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

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

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

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

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

132. By the time the Gearys' attorney helped them both to disentangle
themselves, they had given Scientology close to $180,000. As Robert Geary
described it, "This was money we obviously could not afford to spend and without
extreme undue influence there is absolutely no way we would have ever
spent such sums. I have read a considerable amount about mind control and now
realize that my wife and I were under mind control." A copy of the
declaration of Robert Geary D.D.S. executed September 5, 1993 is attached hereto
as Exhibit 31.

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

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

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

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

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

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

Miscavige is the Managing Agent of Plaintiff CSI

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

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

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

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

Miscavige Wields His Power Through a Small Circle of Lieutenants

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

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

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

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

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

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

Miscavige First Ran Scientoloqy from Author Services, Inc.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Miscavige�s Treatment of his Staff Was Horrifying

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

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

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

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

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

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

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

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

Staff Who Were Critical of Miscavige Were Sent to the RPF

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

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

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

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

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

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

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

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

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

The 1982 Mission Holders' Meeting Illustrates the Emptiness of the Corporate

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

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

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

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

Miscavige Personally Ordered and Oversaw the Portland Crusade

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

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

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

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

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

Miscavige Crossed All Corporations When Hubbard Died

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

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

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

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

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

Today Miscavige Has Completely Consolidated His Power

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

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

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

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

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

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

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

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

Miscavige's Key Lieutenants Are Also Managing Agents of CSI

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

Ray Mithoff is a Managing Agent of CSI

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

Marc Yager is a Managinq Accent of CSI

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

Marty Rathbun was a Managing Asent of CSI

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

Norman Starkey is a Managing Agent of CSI

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

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

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

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

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

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

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

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

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

Miscavige Ordered This Case Dismissed To Protect Himself

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

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

221. Miscavige feared that his own perjury and criminal actions would be
exposed, and he ordered the attorneys on this case to do whatever they had to do
to get rid of it before he had to testify either in deposition or at trial. No
one but Miscavige has the authority to have ordered the Scientology attorneys to
file for dismissal. Without any doubt, Miscavige personally orchestrated the
dismissal of this case. See Exhibit 36, "Report of the Board of Inquiry into
Scientology," by Kevin Victor Anderson, Q.C., the lieutenant governor of the
State of Victoria, in the Commonwealth of Australia. It is a thoroughly
researched report on the dangers of Scientology, and includes an account on
pages 134 and 135 of a woman who was "processed into insanity."

This report led to Scientology being banned in Victoria for a number of years.
Although the ban was later lifted, the report remains an excellent overview of
               the Scientology cult. 

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

               Executed in Corona de1 Mar, California, this 9th day of 
               March, 1994. 


               Stacy Brooks Young

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