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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.

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 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.

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,

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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."

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 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."

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


At one meeting in 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

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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.

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 Miscavidge's directive because

he was one of the best known and most troublesome defectors from


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.

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


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

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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. A true copy of the excerpt from "Magazine
Articles on Level O Checksheet" is attached
hereto as Exh. __.

Pursuant to this statement is 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 corporation."

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 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.

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.

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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.

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").

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

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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.

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.

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


From 1984 through early 1987, I was President of Religious

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.

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 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.

During litigation between Gerald Armstrong and Scientology,

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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

by Scientology.

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 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.

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

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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


In November, 1985, I was present at a meeting whereat Earle

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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In late 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 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.

I have been informed and believe that an improper affadavit

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


In or about 1981, while working in a Scientology

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


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 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


In 1976 and 1977, the then Mayor of Clearwater, 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 the time period of my involvement with Scientology, I

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.

I have been informed by Mark (Marty) Rathbun, a high ranking

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.

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.

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In 1985, I attended a conference on "squirrels" attended by

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.


I declare under penalty of perjury that the above is true

and correct to the best of my belief.

Executed on July 19, 1990 at Los Angeles, Dallas,

California TX.







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