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NURIK & KYLE, P.A.
Attorneys for Defendant
2937 S.W. 27th Avenue
Suite 203
Miami, Florida 33133
(305) 441-2400

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

CASE NO. CR-88-0616-DLJ

UNITED STATES OF AMERICA,

Plaintiff,

v.

STEVEN FISHMAN,

Defendant.

____________________________________________/

 

DECLARATION OF VICKI AZNARAN

I, VICKI AZNARAN declare as follows under penalty of

perjury:

I joined the Church of Scientology in 1972. In 1978,

after approximately four years as staff members, my husband

and I joined the Sea Organization. From 1978 to early 1987,

my husband and I worked most of our waking hours, with very

few days off, at our various assignments within Scientology.

I eventually became President of Religious Technology Center

and,supposedly, the top "ecclesiastical" authority within

Scientology. Richard was a high-level security officer.

During this period my husband and I became intimately

familiar with the structure and activities of various

 

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Scientology organizations. Among other things, I was

briefed on and was sometimes a participant in meetings

involving litigation tactics and various means used to

attack and fight "enemies" of Scientology. In numerous

instances I was in the chain of command for approval for

such activities. From 1984 to 1987, I held the office of

Inspector General, one of the highest worldwide offices in the

organization and so was privy to the most arcane practices

of the group.

The legal strategy of Scientology and the existence of

numerous potential legal problems, some of which are set

forth below, were known to me when I was a staff member in

Scientology. Enemies of Scientology are deemed to be

"suppressive persons" (" SPs"). One becomes a "suppressive

person" by doing a suppressive act, such as suing

Scientology as a litigant or lawyer. In the jargon of

Scientology, when one is " declared" this means that one has

been declared a "suppressive person" and, therefore, may be

harassed, hurt, damaged or destroyed without regard to

truth, honesty or legal rights. It is considered acceptable

within Scientology to lie, cheat, steal and commit illegal

acts in the name of dealing with a " suppressive person."

This practice or policy is sometimes referred to as the

policy of "fair game." In the jargon of Scientology, a

person who is "declared" is understood to be a suppressive

person. This means that the person is " fair game." The fair

 

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game policy was issued in the 1960s. It was never cancelled.

A document was issued for public relations reasons that

purportedly cancelled "fair game"; however, that document

stated that it did not change the manner of handling persons

declared "SP." In reality, the purported cancellation of

fair game is at most a matter of semantics. Enemies of

Scientology are treated as "fair game."

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 L. Ron 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.

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

 

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attacks against Bent Corydon after Scientology became aware

that he was writing a book against Hubbard.

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 state:

"The purpose of the suit is to harass
and discourage rather than to win...The
law can be used very easily to harass,
and...will generally be sufficient to
cause [the enemy's] professional
decease. If possible, of course ruin him
utterly." Hubbard, "Magazine articles on
Level O Checksheet" American Saint Hill
Organization 1968.

As President of RTC and a Sea Organization member, I

attended meetings concerning the numerous legal actions

involving Scientology organizations. During this time

period, I had personal access to all legal documents having

to do with RTC. I received a report every day on my computer

that included a synopsis of each ongoing legal case

involving Scientology. I received, or so I was told, copies

of every major motion filed in cases involving Scientology.

I was on the "approval lines" for legal documents dealing

with RTC. During this time period, I had the option of

attending legal meetings, although some were mandatory. I

attended many litigation meetings and became generally aware

of Scientology's dirty tricks and legal maneuvers. On

specifics, I frequently deferred to in-house and outside

counsel; however, at least in theory, I was the head of RTC

 

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and had access to any business or litigation "secrets" of

Scientology.

It is the stated policy and practice of Scientology to

use the legal system to abuse and harass its enemies. This

crude, fundamental directive of Scientology is no secret.

The policy is to do anything and everything possible to

harass the opposing litigant without regard to whether any

particular motion or maneuver is appropriate or warranted by

the facts or applicable law. That policy was followed in

every legal case I was involved with or learned about while

a member of the Sea Organization. The management of

Scientology consistently expressed and demonstrated a

complete disdain for the court system, viewing it as nothing

more than a method to harass enemies. Some examples of this

are set forth below.

During litigation between Gerald Armstrong and

Scientology, which was before Judge Breckenridge of Superior

Court for Los Angeles County, the court ordered the

production of Armstrong's pre-clear (" PC") folders. These

are files maintained by Scientology on those who submit to

interrogation sessions in a process called auditing. During

the course of that litigation I was ordered to go through

Armstrong's folders and destroy or conceal anything that

might support Armstrong's claims against Scientology. This

practice is known within Scientology as "culling PC folders"

and is a common litigation tactic employed by Scientology.

 

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During other litigation in Los Angeles known to me as

the Wollersheim case, I was told that the judge had ordered

the production of Wollersheim's folders. As ordered, I

"culled" these files. In other words, I removed contents

that might have been damaging to Scientology or might have

supported Wollersheim's claims against Scientology. For

example, I removed evidence of events involving his family,

the anguish this caused him, evidence of disconnection from

family and evidence of fair game.

I was involved in numerous meetings concerning what is

known to me as the Christofferson case in Portland, Oregon.

This case was tried twice. In the first case, a Scientology

witness by the name of Martin Samuels was coached and

drilled for hours on how to lie convincingly or avoid

telling the truth. Before or during the second trial he

admitted to this course of conduct. In this litigation, a

Scientologist by the name of Joan Shriver produced

responsive documents that may have been incriminating. This

was a serious breach of policy for which she was punished.

These documents were ordered produced on such short notice

that apparently files were not thoroughly "culled." In

another case, an attorney was severely criticized and almost

fired for failing to properly coach and feed the desired

answers to Heber Jentzsch. Mr. Jentzsch was, for public

relations reasons, the purported head of the Church of

Scientology International. During his deposition, Mr.

 

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Jentzsch was unable to answer fundamental questions

concerning the management of Church of Scientology

International.

In later 1979 and early 1980, there was a massive

document destruction program undertaken to destroy any

evidence showing that L. Ron Hubbard ("LRH") controlled

Scientology. I participated in this activity in Clearwater,

Florida and am informed that there was also intensive

document destruction at facilities in Gilman Hot Springs,

California. From at least that point onward there was a

continuous effort to hide or destroy any evidence of

Hubbard's control. For example, during an IRS investigation

in 1984 and 1985, while in bed with pneumonia, I was ordered

out of bed by Norman Starkey, who told me that they had

received a tip from a Los Angeles police officer advising

them of a pending IRS raid in Los Angeles. Mr. Starkey

ordered me to go to a computer facility and insure that all

information on the computers in Los Angeles that might show

Hubbard's involvement and control of Scientology's money was

destroyed except for one copy of each document. These copies

were to be saved on computer disks which were to be hidden

in secure storage places. At the time I was also instructed

to destroy anything that would show the control of Mr.

Starkey or Mr. Miscavige over Scientology.

In or about 1981, while working in a Scientology

organization known as the Guardian's Office, I had access to

 

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and observed various written and oral communication

pertaining to illegitimate activities participated in by the

Guardian's Office. The Guardian's Office attempted to

infiltrate both governmental and private agencies including

the IRS, the Department of Justice, and the American Medical

Association and the National Institute of Mental Health. The

purpose of this was to steal documents pursuant to Hubbard's

"Snow White" program. The goal of this program was to

eliminate any negative reports about Hubbard and Scientology

that may have been held by these various agencies.

While involved in Scientology I became aware of various

operations directed against an author who had written a

negative book about Scientology. The author, Paulette

Cooper, was subjected to various forms of harassment. One

operation included an attempt to frame her. A false bomb

threat was written. Scientology agents lifted a fingerprint

from Cooper's apartment. These fingerprints were then

transferred to the bomb threat letter. Ms. Cooper was

subjected to an investigation and was not cleared until an

FBI raid resulted in the seizure of Scientology documents

that exposed the operation as a frame-up. There was at

least one other operation directed against Ms. Cooper. The

substance of it was to plant a boyfriend to reinforce and

play upon her suicidal tendencies in the hopes that she

would commit suicide.

In 1976 and 1977, the then-Mayor of Clearwater,

 

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Florida, Gabe Cazares, was involved with litigation against

Scientology. Arrangements were made to have an attorney by

the name of Merril Vanniere, a Scientologist, represent Mr.

Cazares and sabotage his case. This plot was also exposed by

documents obtained in an FBI raid of a Scientology facility.

Also, in response to Mr. Cazares' litigation against

Scientology, an attempt was made to implicate Mr. Cazares in

a staged hit-and-run accident.

During an IRS criminal investigation in the 1984 to

1985 time period, the IRS ordered production of various

communications between Hubbard and Author Services, Inc.

(ASI). The ASI staff worked literally day and night for

several days reviewing documents so that unfavorable

documents could be destroyed or otherwise concealed from the

IRS. Lyman Spurlock and Marion M. Dendue, Scientologists

involved in this operation, informed me of this operation.

Also during this IRS investigation, my husband, Rick

Aznaran, was ordered to remove and conceal any incriminating

documents from certain locations. He was also directed to

make the computer network "raid proof." This involved

creating a system where incriminating documents could be

deleted from computer storage rapidly and before the IRS

could obtain control over the computers.

I have examined certain documents regarding Steven

Fishman's experience with Scientology, have had

conversations with Mr. Fishman's counsel, and have reviewed

 

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the 1151- page autobiographical account of Mr. Fishman's

Scientology experience entitled "The Lonesome Squirrel."

Based upon my 15 years of experience in Scientology and my

review of the Fishman materials, I offer the following

conclusions:

1. I believe Mr. Fishman's assertions that he was a

member since 1979 and that he was as actively involved as he

states. This belief is based on my experience that only a

committed member of long standing would know the details of

the inner workings of the group; Mr. Fishman has such

knowledge. Awareness of certain confidential projects could

be achieved only by a member who was trusted by the

hierarchy; Mr. Fishman had such awareness. Involvement in a

group that thrives on secrecy and excludes most members from

participation in high-level projects means that any member

who exceeds a certain level of involvement enjoys the trust

of the leadership; such trust would be earned only by

extended membership. Mr. Fishman enjoyed that trust. His

accounts of meetings with high-level officials and his

knowledge of the operations and functions of the hierarchy

are so detailed and accurate that they couldn't have been

gained except through direct personal experience.

2. Refutation by Scientology officials of Mr.

Fishman's membership prior to February 8, 1986, and their

disclaimer of his involvement and their lack of any records

pertaining to such membership is perfectly consistent with

 

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their standard procedure in protecting themselves. As noted

above, I was personally involved in the destruction of

records when it suited their purpose. Scientology propounds

the belief that any action whatsoever taken to protect the

organization is justified, as the group takes precedence

over the individual. Any member performing criminal acts for

the benefit of the group was kept at arm's length; if

apprehended, the member was disavowed by Scientology. This

procedure was used even on the wife of the founder of

Scientology. Given the serious potential threat that Mr.

Fishman's defense posed to the group, I find Mr. Fishman's

account of certain members of Scientology's involvement in

the plan to fabricate the threats against Mr. Fishman and

his counsel and to thereby undermine Mr. Fishman's

credibility and render him useless as a witness against

Scientology to be consistent with their modus operandi.

I declare under penalty of perjury under the laws of

the State of Texas that the foregoing is true and correct.

Executed this 18th day of July, 1990, in Dallas,

Texas.

  [signed]
VICKI AZNARAN

 

 

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