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DECLARATION OF VICKI AZNARAN

 

I, Vicki Aznaran, declare:

1. I was involved with the Church of Scientology

("Scientology") for approximately 15 years. I submit this

Declaration on personal knowledge of the facts contained herein

and if called upon as a witness I could and would competently

testify thereto.

2. I was one of the highest ranking members of Scientology

and was involved in upper management. From 1978 through 1987 I

was a member of an organization known as the Sea Organization

("Sea Org"), an elite organization within Scientology. The Sea

Org has considerable influence and control over other Scientology

organizations; it sends its officers to individual organizations

with unlimited power to handle ethics, tech and administration.

In this regard, a Sea Org member may order a non-Sea Org member on

virtually any subject, and the non-Sea Org member must obey. For

example, sea Org "missions" are frequently sent to non-Sea Org

organizations when those organizations are not sending enough

money or public to the Sea Org organizations. These Sea Org

members on "mission" can take any action they deem necessary in

that non-Sea Org organization to accomplish their ends. They can

control the funds of that organization and its personnel. They

can remove personnel and post personnel. They can transfer funds

to the Sea Org organizations or spend funds as they see fit.

3. Generally, Sea Org members hold the management posts in

other organizations within Scientology. In order to be employed

at a middle management level or above, one must be in the Sea

 

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Organization. In order to be employed at the organizations that

make the most money (known as the Sea Org Organizations), such as

the Flag Service Org in Clearwater, the Advanced organization of Los

Angeles, the Advanced Organization of the U.K., the Advanced

Organization of Denmark and the Advanced Organization in

Australia, one must be a Sea Org member. Additionally, in order

to be employed in the organizations that control the Scientology

network, such as the Religious Technology Center, one must be a

Sea Org member. From 1984 through early 1987 I was president of

Religious Technology Center ("RTC"). By contrast, Scientology

management often designates for publicity and other reasons

various officers of Scientology organizations who are figure-head

officers only and possess little, if any, actual power over the

organization they purportedly serve. For example, Hebert Jentzsch

was at one time named the titular head of the Church of

Scientology International. However, during one of Mr. Jentzsch's

depositions he was unable to answer fundamental questions

concerning the management of the Church of Scientology

International ("CSI") and could not name the directors of CSI nor

the other officers. During the time I was in the Religious

Technology Center, from 1982 until 1987, Mr. Jentzsch had nothing

to do with the running of CSI. Mr. Jentzsch was a figure head and

public relations man. It was never intended that he would be

involved in the administration of CSI whatsoever. There is an

order from Hubbard which states that the officers of corporations

should be just figure heads; the directors have more power, and

then you have trustees who are over the very top corporations who

can remove directors. These trustees hold the power as regards

 

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Scientology's money, assets, personnel, etc. The top trustees of

Scientology when I was a director of RTC were David Miscavige,

Lyman Spurlock and Norman Starkey. Patrick Broeker and Ann

Broeker were also senior trustees over Scientology in 1982 and for

some time thereafter. Miscavige convinced the Broekers to turn

over their trusteeships to him in order to avoid the IRS criminal

investigation that was ongoing. This left Miscavige, Spurlock and

Starkey as the trustees that could control Scientology.

4. Lyman Spurlock and Norman Starkey also are both

high-ranking Scientologists. At times, both within and outside my

capacity as president of RTC, I have taken direct orders from Mr.

Spurlock and from Mr. Starkey.

5. Both Mr. Spurlock and Mr. Starkey are members of the Sea

Org. In addition, both these men hold other posts within

Scientology. For example, Mr. Starkey was president of Author

Services, Inc. ("ASI"), executor of the Estate of L. Ron Hubbard

and Trustee of the Author's Family Trust-B. Mr. Spurlock at

various times was the Investment Officer International for the

Church of Scientology, an executive of ASI, and president of

Church of Spiritual Technology ("CST"). Both men have served

together as officers of Galaxy Productions, Inc.

6. Mr. Spurlock controlled virtually all tax matters for

the Religious Technology Center, CSI, ASI, CSC and CST. During

the time I was an officer and director of RTC, I was asked to sign

letters for RTC which had been drafted by Mr. Spurlock or at his

request. Mr. Spurlock dealt with the tax attorneys who

represented RTC. Sometimes I would be informed of actions he had

taken regarding RTC tax matters after the fact, and sometimes

 

 

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was never informed. Mr. Spurlock met with the Internal Revenue

Service on more than one occasion to negotiate matters for RTC.

He did this entirely on his own and made his own decisions

regarding RTC's tax matters and tax exempt status. Mr. Spurlock

and Mr. Starkey frequently issues orders to me concerning

litigation and tax matters concerning RTC, CSI, CSC and other

Scientology entities. Mr. Spurlock also set up the current

corporate structure of Scientology. This includes the set up of

RTC, CSI and CST. Mr. Spurlock set up these structures and, along

with Miscavige and Starkey, chose the directors, trustees and

officers.

7. Mr. Starkey gave orders concerning litigation matters

for Scientology. In 1982 Norman Starkey and David Miscavige

ordered me to get Dick Story of the Guardians Office World Wide to

hire a private investigator named Dick Bast to compromise Judge

Krentzman, who was the judge on a case against Scientology in

Florida. Judge Krentzman had been giving Scientology unfavorable

rulings in the case. From 1981 up until the time I left, Starkey,

Spurlock and Miscavige closely supervised all litigation brought

either for or against the various Scientology corporations. The

settlement initiated by Scientology for all of the cases that

Michael Flynn had brought against them was ordered by Miscavige,

Starkey and Spurlock with no consultation with the various

corporations who were sued, such as Church of Scientology of

California. In fact, this settlement was considered top secret

and the officers and directors of the various corporations who

were supposedly settling with Mr. Flynn did not even know the

specifics of the settlement. The various officers of the

 

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Scientology corporations know that they do not, in fact, make

decisions about their respective corporations. They are told and

understand that they sign what they are told to and that this is

done in order to comply with the suppressive government

requirements and avoid having to pay taxes to the suppressive IRS.

In 1982 Mr. Spurlock ordered the then-head of international

management, John Nelson, to buy into a gold mine in Canada using

several million dollars worth of church funds. Mr. Nelson

disagreed and said that he thought it was a bad investment.

Mr Spurlock made the transaction anyway, as he controlled

Scientology's funds. Mr. Spurlock's position at the time was

Deputy Executive Director for Client Affairs at Author Services

Inc., a for-profit organization which had been represented to the

IRS as having no control whatsoever over tax exempt church funds.

Mr. Spurlock's gold mine venture lost a considerable sum of money

for Scientology. Mr. Spurlock also ordered Scientology

management, specifically Marc Yager and Wendell Reynolds, to buy

into oil wells in Oklahoma. Mr. Yager expressed to me that he had

reservations about this venture, but complied anyway. This

venture also lost quite a bit of money for Scientology.

Additionally, Starkey and Miscavige bought into the oil venture

(with their personal funds) in Oklahoma and were able to get

much better deal for themselves due to putting Hubbard's and

Scientology money into the venture.

8. Additional facts indicative of the management authority

possessed and used by both Mr. Spurlock and Mr. Starkey over the

entities involved in the Scott/Wollersheim consolidated lawsuits

(i.e., Church of Scientology International ("CSI"), Church of

 

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Scientology of California ("CSC"), Religious Technology Center

("RTC") and Church of Spiritual Technology ("CST") include the

following:

A. Mr. Spurlock ordered that the original Scott suit

be brought. He was involved in all of the major strategy

meetings with attorneys concerning both the Scott and

Wollersheim cases and, in fact, began planning the suit

against David Mayo in 1982, shortly after Mayo opened his

Church.

B. Mr. Starkey was also involved in all major meetings

with attorneys concerning the Scott/Wollersheim cases. He

made active decisions and ordered the attorneys as to actions

they were or were not allowed to take in regards to these

facts. In fact, Mr. Starkey and Mr. Spurlock accompanied an

attorney for Scientology, Mr. Earle Cooley, one night on what

was described by them as an attempt to visit the residence of

Judge Mariana Pfaelzer Scientology after she had ruled against

Scientology at a hearing. He went with Mr. Cooley in order

to express their views to Judge Pfaelzer and persuade her to

rule favorably for Scientology. Mr. Starkey and Mr. Spurlock

stayed up all night that night working on drafting papers for

the Scott/Wollersheim cases.

9. One of the reasons why Scientology elects to manage its

far-flung enterprises in this manner is to try to sheild its

management from legal process. Front men are designated to hold

figure-head posts, while the real management power is held by

others outside the corporate structure. To this end, Scientology

will go to extreme lengths to conceal upper management personnel

 

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from service of process, subpoenas and depositions. When alive

L. Ron Hubbard was protected in this manner. In addition

personnel have been driven around the city in covered vans to

protect their identities and whereabouts. Moreover, when deemed

necessary, personnel are sent out of this country in order to

avoid legal process.

For example, in 1984 when the IRS was conducting

criminal investigation against various Scientology entities, the

personnel who had knowledge of criminal behavior as regards

Scientology funds were hidden or sent away. Fran Harris, who was

involved with Bridge Publications and Church and L. Ron Hubbard's

funds, was sent to Denmark for a year. Mark Ingber, WDC member

for Finance, was also sent to Denmark for a year. Wendel

Reynolds, who had similar knowledge, was put away on the RPF in

Happy Valley. Miscavige, Starkey and Spurlock took great

precautions with their travels, offices and residences so that

they could not be found or served. Miscavige has been known to

actually rent clandestine quarters away from any Scientology

facility, paid for with Scientology funds, simply so that he could

hide out from process servers.

10. Both Mr. Spurlock and Mr. Starkey have been afforded

this "protection" by Scientology. It is doubtful that either will

be deposed if personal service of a subpoena upon them is deemed

necessary prerequisite. Scientology will take all measure

necessary to keep these men cloistered from view and immunize

from service.

11. On the other hand, it is clear that when Scientology

wants help from Mr. Spurlock and Mr. Starkey both men stand ready

 

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to assist. Accordingly, whenever declarations are needed by

Scientology in any of their lawsuits or other legal proceedings

Scientology has no difficulty in obtaining the assistance of both

Mr. Starkey and Mr. Spurlock. In this regard, Miscavige took off

for over two months and lived in Portland, Oregon in order to

oversee and direct the attorneys for Scientology on a daily basis

during the entire trial in the case of Julie Christofferson

Titchbourne, which she had brought against Scientology. Mr.

Spurlock also spent most of his days in Portland during the

trial. During the Wollersheim trial, Miscavige, Starkey and

Spurlock supervised the attorneys representing CSC on a daily basis

throughout the nearly three-month trial in Los Angeles.

Miscavige, Starkey and Spurlock stay briefed on a daily basis on

all legal matters of any consequence involving any Scientology

entity. All papers filed by the Scientology entities involved in

the consolidated Scott/Wollersheim cases had to be sent via

Spurlock and Miscavige for authorization before they could be

filed.

12. In addition, without revealing any privileged

communications, I am able to state that both Mr. Spurlock and Mr.

Starkey have been involved directly in the management of CSI, CSC,

RTC and CST, and have participated in meetings in which decisions

affecting these consolidated Scott/Wollersheim cases have been

made. We have worked together in the past and I know that no

major decision affecting these entities or these cases are made

without their knowledge, participation and/or consent. Based upon

all the information personally available to me, I am of the

 

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opinion that both Mr. Starkey and Mr. Spurlock are managing agents

of CSI, CSC, RTC and CST.

13 . I have reason to believe that documents which would

normally reflect traditional criteria of the managing agent

relationship between Scientology and Messrs. Spurlock and Starkey

have been either destroyed or concealed by Scientology. For

example, at Mr. Starkey's direction, I destroyed such information

as it related to the involvement and control over Scientology by

L. Ron Hubbard, Mr. Starkey and Mr. David Miscavige.

I declare under penalty of perjury under the laws of the

United States that the foregoing is true and correct.

Executed this 27th day of October 1988, in Dallas, Texas.

  [signed]
Vicki J. Aznaran

 

 

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