DECLARATION OF VICKI J. AZNARAN
("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
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 bacame 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 Scientology organizations.
Among other things, I was briefed on and 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. 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.
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,
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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."
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 game policy was
issued in the 1960s. It was never cancelled. A documents 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."
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
that all of Scientology should be more aggressive in their fair
game attacks upon and injuries inflicted on Scientology's
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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 fold.
Corydon by name I knew and believe that everyone at that meeting
knew that Corydon was included in Miscavidge's directive because
he was one of the best known and most troublesome defectors from
all types of attack be used, including physical attacks,
defamation, and efforts to cause Corydon to go into bankruptcy.
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
litigation purely for harassment without regard to the merits of
a claim to cause enemies to fold. Hubbard's writings state:
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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 corporation."
corporations are independent entities permits Scientology to
harass its enemies by filing multiple lawsuits all directed by
the same people 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.
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.
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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.
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").
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
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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.
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.
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
Technology Center (hereinafter "RTC"). As President of RTC and a
Sea Organization member, I attended many meetings concerning the
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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 and had access to any business or
litigation "secrets" of Scientology.
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 fcts or applicable
law. That policy was followed in every legal case I was involved
with or learned about while a member of the Sea Organiziation.
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.
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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 be damaging to Scientology or helpful
to Armstrong's case. As ordered, I went through the files and
destroyed contents 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
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 support 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.
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
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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. Jentzsch was unable to answer fundamental
questions concerning the management of Church of Scientology
Cooley, a Scientologist lawyer, Lyman Spurlock and Norman
Starkey, all high ranking Scientologists, announced that they
were going to contact Judge Mariana Pfaelzer. Earlier that day
Judge Pfaelzer had denied a Scientology motion for a temporary
restraining order. After losing on the application there was a
meeting to determine what to do about the situation. At the
meeting Mr. Cooley had a file that purportedly contained
background and personal information on Judge Pfaelzer. During
the meeting Mr. Cooley and others announced that they were going
to attempt to meet with Judge Pfaelzer that evening, at her house
if necessary, concerning the litigation in which the temporary
restraining order had been sought. Thereafter, Mr. Cooley and
two others left with their file on Judge Pfaelzer. They returned
several hours later at which time I was told that their attempts
to contact Judge Pfaelzer had been unsuccessful.
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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 alos 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 discs 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.
was filed in a case brought by L. Ron Hubbard, Jr. in Riverside,
California. The circumstances were as follows: The document
purported to be an affidavit of L. Ron Hubbard. The signature of
Hubbard was purportedly notarized by David Miscavige. It is my
understanding that this affidavit caused the case to be
dismissed. Subsequently, I was told by Pat Broeker, who had been
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living with Hubbard at the time, and by Miscavige, that Miscavige
had not seen Hubbard between 1980 and Hubbard's death in 1986.
Accordingly, the affidavit was apparently signed, notarized and
dated during a time period when Hubbard was in seclusion and not
seen by the person who purportedly notarized the signature of
organization known as the Guardian's Office, I had access to 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
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 agent 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
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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
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.
also learned of various attempts to influence judges or force
their removal from cases. For example, a private investigator
named Dick Bast obtained a statement from a prostitute concerning
involvement with a certain judge in Washington, D.C. who was
sitting on a Scientology case. This was then publicized. The
judge did not continue on the case. The same investigator, Dick
Bast was also hired for the purpose of attempting to force the
removal of a judge in Tampa, Florida. This involved what I know
as the Burden case, which was civil litigation brought by
attorney Michael Flynn. Dick Bast secured a yacht and attempted
to get the judge on board for the purpose of filming him under
compromising circumstances. The judge declined to go yachting
and the operation was unsuccessful. Approximately $250,000.00
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was spent on the operation.
Scientologist, that his private investigator, Gene Ingram, " fed"
a confession to Ala Tamimi when visiting him in an Italian
prison. This false confession was, in substance, that Tamimi had
been involved in a bad check scam involving an account of L. Ron
Hubbard. This false confession implicated attorney Michael Flynn
in the check scam. Michael Flynn was at the time considered a
major enemy of Scientology because he represented numerous
clients with claims against Scientology. This purported
confession was used to slander and attack Michael Flynn. Michael
Flynn has also been sued by Scientology as part of its "strategy"
for handling enemies.
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.
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Miscavige, Starkey, Spurlock, and McShane, members of top
management, and others. In Scientology jargon, "squirrels" are
people who use or practice some procedures also used by
Scientology but who do not submit to the total control of the
Scientology organization and, perhaps most importantly, who do
not pay a percentage of their auditing or counseling fees to
Scientology. At this meeting, David Miscavige ordered that
public Scientologistis be organized and motivated to physically
attack squirrels and disrupt their operations. This was stated
to be pursuant to the standard guidelines of Scientology.
Pursuant to such directives, efforts were undertaken to
intimidate and disrupt these persons and their organizations.
and correct to the best of my belief.
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