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I, Vicki Aznaran, declare as follows under penalty of

perjury under the laws of the State of California:

1. I have read Bent Corydon's Fourth Amended

Complaint and am familiar with many of the people, entities and

facts alleged therein.

2. From 1983 through early 1987 I was the President

of the Religious Technology Center, (RTC). The position of RTC in

Scientology was described at the Mission Holders Conference of

October 17, 1982 (see transcript attached hereto as Exhibit A)

and is graphically represented on a chart prepared by Lymon

Spurlock for presentation at that meeting. That chart is attached

hereto as Exhibit A - A. According to the chart RTC is at the

top of Scientology.

3. Because of my extensive indoctrination and

experience as a Scientologist and my years in RTC, I know from

personal knowledge that in the mind of Scientology one of the

foremost enemies is a Squirrel. Squirrels are defined in

Hubbard's Technical Dictionary as a person "altering Scn

[Scientology] or who "engages in offbeat practices".

This is particularly odious to Scientology because if

counsellors who have broken from "standard practice" (ie. under

the control of Scientology's leaders) provide services to

customers ("parishioners") who have left the oppressive

environment of the Church, the profitability of Scientology is

threatened. Thus, squirrels are despised and persecuted in




4. I first met David Miscavige in 1978 when I was

Deputy Special Unit Representative under Pat Broeker. Based on my

personal knowledge at the time I became president of RTC I

believe he was one of the most powerful individuals in

Scientology which included, in addition to L. Ron Hubbard and

Miscavige, Pat and Anne Broeker, Norman Starkey and Lymon

Spurlock. After Hubbard's death in 1986 Miscavige successfully

ousted the Broekers from power and consolidated his position as

the most powerful individual in Scientology.

5. David Miscavige was the Chairman of the Board of

Author Services Inc., ("ASI") in 1984 and 1985. ASI was

incorporated to be the funnel through which profits from

Scientology were channelled to Hubbard and, therefore, it was

very important within Scientology. Miscavige represented Hubbard

in all aspects of controlling Scientology. He attended regular

meetings with myself and other top officials of Scientology

organizations to review the status of all Scientology's

activities including its litigation and dirty tricks campaigns

against Scientology's enemies.

6. At one meeting in 1984 or 1985 Miscavige told

those present that all of Scientology should be more aggressive

in their fair game attacks upon and injuries inflicted on

Scientology's enemies, especially squirrels. At that time Bent

Corydon was a hated squirrel who vexed Scientology's leadership

by his refusal to give up his outspoken position. He had been in

litigation with Scientology for several years and refused to




7. Although I never heard Miscavige order an attack

against Corydon by name I knew and believe that everyone at that

meeting knew that Corydon was included in Miscavige's directive

because he was one of the best known and most troublesome

defectors from Scientology.

8. Similarly, there could be no doubt that Miscavige

meant that all types of attack be used, including physical

attacks, defamation, and efforts to cause Corydon to go into

bankruptcy. Miscavige had been known to personally use violence

against recalcitrant followers: slapping, striking, and spitting

them in the face. Also, economic pressure, preferably to force

people to bankruptcy, was always high on the list of acceptable

Scientology attacks against enemies. None of this had to be

expressly be stated to be understood because Scientology

"scripture" directs that enemies be subjected to fair game by all

Scientologists, that is, Scientology "scripture" contains a " fair

game" policy that dictates that enemies may be

"Deprived of property or injured by any

means by any Scientologist, without

discipline of the Scientologist. May be

tricked, sued lied to or destroyed."

HCO Policy Letter October 18, 1967

A true copy of HCO Policy Letter October

18,1967 is attached hereto as Exhibit A - B.

9. Because of my position and the regular reports that

came across my desk I know that throughout my presidency of RTC



that fair game actions against enemies were commonplace. In

addition to the litigation tactics described below, fair game

activities included burglaries, assaults, disruption of enemies'

businesses, spying, harassive investigations, abuse of

confidential communications in parishioner files and so on. I

specifically recall seeing one report regarding attacks against

Bent Corydon after Scientology became aware that he was writing a

book against Hubbard.

10. Other Hubbard writings encourage Scientologists to

pursue litigation purely for harassment without regard to the

merits of a claim to cause enemies to fold. Hubbard's writings


"The purpose of the suit is to harass
and discourage rather than to win...
The law can be used very easily to harrass,
and ... will generally be sufficient
to cause [the enemy's] professional decease.
If possible, of course ruin him utterly."
Hubbard, "Magazine Articles on Level 0
Checksheet" American Saint Hill Organization
1968. A true copy of the excerpt from "Magazine
Articles on Level 0 Checksheet" is attached
hereto as Exhibit A - C. See page 55.

Pursuant to this statement it has become the practice of

Scientology's management to use litigation for harassment and to

cause the financial ruin of adversaries as part of the fair game

policy. This is made even worse by the fact that Scientology has,

in name only, many "independent corporations".


The false representations that the numerous Scientology

corporations are independent entities permits Scientology to

harass its enemies by filing multiple lawsuits all directed by



the same people and all raising the same issues against the same

defendants, while their lawyers fraudulently claim that the

entities they are representing are independent. At the same time

Scientology makes it a practice to refuse to produce almost all

discovery, with the objective of increasing the litigation costs

and causing delay. Furthermore Scientology often resorts to the

destruction of evidence. I know this on personal knowledge

because I participated in the destruction of files of ex-

Scientologists who were in litigation with the Church.

11. Ultimate control of all Scientology corporations

rested with Miscavige, Norman Starkey and Lymon Spurlock and,

until they were deposed, Pat and Annie Broeker (except that,

prior to his death, Hubbard could himself intervene regarding any

order). This control was not limited to so-called

"ecclesiastical" matters but extended to all operations, all

finances and all planning of all Scientology entities and totally

ignored theoretical corporate independence. This control was

enforced in several ways. For example there was the ever present

threat that if you disobeyed "Command Intention" (orders from

above) you would be declared the target of the fair game policy.

In addition, if any person within Scientology believes that any

other person is "off-policy" or acting in some way contrary to

Scientology's purposes, they are encouraged to send to higher-ups

a statement called a "Knowledge Report" to expose that person.

12. Although Author Services Inc. (ASI) has never to

my knowledge appeared on any command chart distributed to

Scientologists, ASI is an integral part of Scientology and was



for some time the controlling entity over all of Scientology

along with RTC. Some of the facts on which I base this statement

are stated in the next few paragraphs.

13. ASI was incorporated at about the same time as the

massive restructuring of all Scientology organizations by high

ranking Scientologists. The incorporators and original officers

were all Scientologists, and ASI was specifically created to be

the entity through which Hubbard could, and did, exercise control

over Scientology money and receive huge payments.

14. At the October 1982 Mission Holders' Conference in San

Francisco, the mission holders were ordered to increase their

weekly payments (called "tithes") from 10% to 15% of their gross

income. The additional 5% was to be used for a massive public

relations campaign to increase the publicity for Hubbard's

science fiction books. This was part of an overall plan to

dramatically increase the visibility of Hubbard's name so that

the market would be more receptive to a new public relations

blitz promoting DIANETICS, the first stage in the selling of

enormously expensive Scientology counselling and courses. The 5%

payment increase was ordered by and its use controlled by ASI

with the aid of Bridge Publications Inc. ("BPI").

15. The Scientology Managing Agents (Hubbard,

Miscavige, Starkey, Spurlock and their handmaiden organizations:

the Commodore's Messenger Organization, the Sea Organization,

ASI, RTC, CSC and SMI) had de facto controlling power over all

Scientology entities through the exercise of the coercive threat

of the fair game policy. It was this threat that kept most

Scientologists in line. This power could be maliciously exercised



as, for example, at the Mission Holder's Conference of 1982 when

a mission holder named Gary Smith was summarily declared a

suppressive person (thus subjecting him to fair game) because

he refused to move from a rear seat in the conference room to a

front seat.

16. ASI claims to represent not only Hubbard but other

writers but its only real motive and activity is the promotion of

Hubbard's writing, the expansion of Scientology and personal

aggrandizement and power of the personalities who control

Scientology. The only other writers it represented at all prior

to my departure from Scientology in 1987 are those included in

the annual volume of new writers of science fiction called

Writers of the Future. This was its only non-exclusively Hubbard

project and this project was mandated to be implemented by

Hubbard to promote him as a patron of the arts.

17. As part of their attempt to expand and complete their

control of Scientology and to gain control of valuable assets

belonging to the missions, the managing agents ordered the

independently incorporated missions to adopt new Articles and By-

laws prepared by them under which the missions would have to

submit to control by the managing agents acting principally

through the Sea Org, RTC, CSI, and SMI, and the Commodore's

Messenger Organization. While most missions succumbed to this

power play, some, such as the Church of Scientology Mission of

Riverside (COSMOR), under the leadership of Bent Corydon, did


18. The effort to "regularize" control over the



missions and all of Scientology by the managing agents is

documented by the transcript of the Mission Holder's meeting of

October 17, 1982. That meeting was audio-taped and a transcript,

including three charts showing the control changes, were sent out

to all mission holders after the meeting. A complete copy of the

transcript is attached hereto as Exhibit D.

The transcript shows that RTC had authority (shown on the

authority lines on Chart No. 3) to issue orders to CSI and SMI

and the missions, that CSI also had direct power over both SMI

and the missions, and, that SMI also had direct power over the


Sworn to under penalty of perjury this 26th day of

Sept. 1989.







Dallas County

State of Texas


On this 26th day of Sept 1989, personally appeared

Vicki Aznaran, known to me or proved to me on the basis of

satisfactory evidence to be the person whose name is subscribed

to the instrument above and executed the same.

For witness whereof I have hereunto set my hand and affixed

my official seal the day and year first written above.


Notary Public in and for
the State of Texas. My
Commission expires on



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