GRAHAM E. BERRY,
State Bar No. 128503
GORDON J. CALHOUN,
State Bar No. 84509
LEWIS, D'AMATO, BRISBOIS & BISGAARD
221 N. Figueroa Street, Suite 1200
Los Angeles, California 90012
Telephone: (213) 250-1800
Attorneys for Defendants
UWE GEERTZ, PH.D.
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
CHURCH OF SCIENTOLOGY
STEVEN FISHMAN and UWE GEERTZ
No. CV 91-6426 HLH (Tx)
RE: MOTION FOR COSTS
Date: APRIL 4, 1994
Time: 10:00 a.m.
1. I, Vicki Aznaran, declare and say: I am over the age of
eighteen and a
resident of Texas. I have personal knowledge of the matters set forth in
this declaration and if called upon to do so, I could and would competently
2. Attached hereto as Exhibit A is a true and correct copy
declaration I executed July 18, 1990 for use in the case United States of
America v. Steven Fishman, Case No. XR-88-0616-DLT.The contents
of that declaration (Exhibit A) were true and correct when executed and
they remain true and correct as of the date of execution of this declaration.
The contents of Exhibit A are expressly incorporated herein and made a
MY BACKGROUND IN SCIENTOLOGY
3. 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 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.
4. Between its incorporation in 1982 and 1987 when I left
Scientology, I was on the staff of the Religious Technology Center,
(RTC). I held the position that is now being held by David Miscavige.
Since 1978, I was a high ranking member of the Sea Organization,
an elite organization within Scientology. At the time I left Scientology
I was highly trained as a technical expert (Class 9 auditor) and an
administrator (Data Series evaluator course and organization executive
course). To complete the Organization Executive Course, one must
study all policy letters written by Hubbard which comprise a-large
VAUGHN AND STACY YOUNG'S BACKGROUND IN SCIENTOLOGY
5. During my tenure as Inspector General of RTC, I knew both
Vaughn and Stacy Young well. They were well known to me because of
their Scientology staff positions. Vaughn Young was posted as L. Ron
Hubbard's personal public relations officer in Special Project which later
became ASI (Author Services, Inc.) Special Project as well as ASI were
headed by David Miscavige and Norman Starkey. LRH's personal public
relations officer has traditionally been a high ranking position in
Scientology. Vaughn Young was also charged with writing Hubbard's
biography after Gerald Armstrong (Sea Organization staff member who
was working on the biography along with author Omar Garrison) left
Scientology. This was during the period that Vaughn worked as Hubbard's
PR. Vaughn Young worked as Hubbard's PR after Hubbard's death as well.
Vaughn Young was summoned to Hubbard's ranch after his death, just as
Miscavige was. Miscavige was not summoned prior to Hubbard's death.
Hubbard only summoned Ray Mithoff just prior to his death, and of course,
Annie and Pat Brocker, who lived with Hubbard exclusively during his last
six years. In fact, Miscavige, and a host of other staff members, myself and
Vaughn Young included, who were summoned to the ranch by the Brockers,
were not those that Hubbard wished to see before he died, as he summoned
the only ones that he wished to see. Miscavige was quite deflated over it.
It is apparent from Miscavige's declaration that he took it to mean Vaughn
Young and the others who came after Hubbard was gone, were not of any
6. In the early 1980's, Stacy Young was posted in Special Project
as the organizing officer. Special Project was headed by David Miscavige.
It had about 15 staff members total. Organizing Officer is a high ranking
post in any Scientology Organization. It is a member of the executive
council. Stacy Young was later posted at various posts in OSA doing
work as a PR. ASI was not a large organization, about 15 staff. At the time
I was in RTC, ASI was a very high level organization, placed above RTC
in the chain of command. The staff of ASI received their orders from L. Ron
Hubbard, and his aide who lived with him, Pat Brocker. When I was a staff
member of a Scientology mission from 1973 to 1978, I knew of Vaughn
Young because he was a very high profile spokesman for Scientology and
the Guardian's Office.
SCIENTOLOGY OFFICIALS AVOIDING SERVICE OF PROCESS
7. It is routine policy for the upper executives of Scientology
to avoid service of process. This is why mere mid level executives, such
as the Reverend Heber Jentzsch, are appointed to corporate posts such
as President of Church of Scientology International. Corporate posts
have nothing to do with either power or the command chart in Scientology.
This policy was in place throughout my tenure in the Commodore's
Messenger Organization (from 1978 until 1987). This policy is designed
to keep those who knew Scientology's secrets from being in a position
where the secrets might be revealed. Hubbard went into seclusion for his
last years allowing only Pat and Annie Brocker access to him, just for the
purpose of avoiding service in lawsuits and subpoenas in criminal matters.
All security personnel are trained to keep any and all process servers away
from Scientology executives. When David Miscavige was one of the
targets of an IRS CID investigation (there were several individuals
targeted), he expressed great concern over having to go to jail. Due to his
diminutive size, he was very concerned that he would be sexually
harassed while in a jail with common criminals." At this time he devised
several schemes to flee the country should the IRS decide to make arrests.
Avoiding service of process is a tactic that Miscavige is well acquainted
with. (See Attached Exhibit D). I recognize Exhibit B as being a copy of
the Scientology internal document Project Quaker with which I was
familiar whilst serving in various Scientology posts.
MISCAVIGE AS READ OF SCIENTOLOGY AND MANAGING
AGENT OF THE VARIOUS SCIENTOLOGY CORPORATIONS
8. 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.
9. During the time I held the post of Chairman of the
Board of RTC, David Miscavige held the post of Chairman of the
Board of ASI. During this time, he maintained control of the executives
at the top of Scientology's command channels, Marc Yager, CO CMO
Int and head of the Watchdog Committee, Guillaume Lesevre, ED
International, Ray Mithoff, Senior C/S International, myself as Inspector
General and COB of RTC. Miscavige became head of RTC in March of
1987, at this point he moved Marc Yager and Ray Mithoff from their
positions in CSI into RTC. He also moved Mark Rathbun, LRH Legal
IC or Special Project L, and Greg Wilhere from their positions in ASI
into RTC. I now see from the declarations of Marc Yager and Ray
Mithoff, that Miscavige has now placed them back into CSI. This is but
one small illustration of his ongoing control over the CSI corporation.
10. Miscavige has, since 1981, been the decision maker
over what lawsuits are filed by Scientology and how any lawsuits
Scientology is engaged in are to be litigated. He does this without
regard to the particular Scientology corporate entity (s) involved in
the litigation. Miscavige has never allowed anyone else to make the
final decisions concerning such matters. During my tenure as Inspector
General of RTC, as well as the head of the 040 mission which took
over the US Guardian's Office, as outlined in Miscavige's declaration,
I attended many meetings and saw countless orders from Miscavige
concerning Scientology's litigation. During all trials, Miscavige receives
daily transcripts and issues orders directly to the attorneys, no matter
which particular Scientology corporate entity has been chosen to
bring the litigation or which entity has been sued. The heads of CSI
would never be allowed to independently bring or initiate a lawsuit.
During my tenure in RTC, Miscavige received a "legal daily report",
of which I received a copy. This report contained summaries of
everything that occurred on any of Scientology's lawsuits. Miscavige
would issue orders and call meetings concerning these matters on a
regular basis. Litigation is very costly and can result in severely
adverse PR. Therefore, Miscavige was never willing for the decisions
concerning it to be turned over to anyone else.
THE DEATH OF FLO BARNETT
11. Flo Barnett's suicide was a scandal within the inner
circles of Scientology. This was not due to the fact that she supposedly
committed suicide, but due to the fact that she had become a member of a
declared enemy group, David Mayo's Advanced Ability Center. She was
receiving auditing and assistance from this group and at the time of her
death, possessed a pack of the NED for OTS (secret upper level
auditing procedures) which were believed to have come from David
Mayo's group. Flo Barnett's membership in this group made her a
suppressive person as she was actively "squirreling" and a member
of a suppressive group. The fact that David Miscavige was linked
to her by familial ties was extremely repugnant to him and to his
wife, Michelle Miscavige. David Miscavige's comment upon her
death was that "the bitch got what she deserved." His wife Shelly,
did not appear to feel any different about it than David. I asked Shelly
if she was doing alright since receiving this bad news. She said that
personally she was doing just fine and that this was an excellent
opportunity to find out where the NED for OTs materials had come
from and to use it as leverage against Mayo. She also stated that it
was not surprising that this happened to her mother since she had
been "squirelling". The circumstances of the deaths of both Flo Barnett
and Yvonne Jentzsch are very relevant to the issues in this case,
as I understand them to be.
THE PURPORTED PURGE OF THE SCIENTOLOGY CRIMINALS
12. Hendrick Moxon, currently an attorney for Scientology
very case, and a member of the Sea Organization, was a prominent
participant in the criminal activities of the Guardian's Office. Prior to
becoming an attorney at Scientology's expense, he was a Guardian's
Office staff member in Washington, D.C. Moxon was involved in the
Scientology conspiracy to infiltrate the U.S. government. This conspiracy
was uncovered by the F.B.I. in 1977. Scientology then stipulated to their
crimes which included Moxon's involvement in those crimes. Nine senior
Scientologists, including Hubbards' wife, went to jail as a result of these
criminal activities conducted by, and on behalf of, the Church of
Scientology. I became familiar with certain documents, which are attached
hereto, while being in charge of the 1981/82 040 mission to take over the
USGO. Moxon was involved in the criminal activity, attempted cover-ups
and obstruction of justice. The US government subsequently prosecuted
11 top officials of Scientology and named Moxon as an unindicted co-
conspirator. (See Exhibit C, pages 212-214). This is but one small example
to illustrate that Miscavige has not and will never offload the criminal
element from Scientology's ranks. Miscavige is well aware of Moxon's
status and maintains him as a high level legal staff in the Sea Organization.
As a practicing Scientologist and in-house Scientology lawyer, Kendrick
Moxon's first duty is to protect Miscavige and Scientology. This duty is
paramount to any duty he might otherwise owe the Court or the law.
13. Scientology was created by L. Ron Hubbard in the 1950's.
policies and beliefs of Scientology were established by L. Ron Hubbard. L.
Ron Hubbard created the Guardian's office based on his beliefs and ideals.
The Guardian's Office was headed by his wife, Mary Sue Hubbard. During
the late 1960's and the 1970's, many, many crimes were committed
internationally by the Guardian's Office. Hubbard was well aware of
the Guardian's Office activities and this is apparent from the reams of
paper containing his various orders to the Guardian's Office.
The policies and beliefs and ideals that established Scientology and the
Guardian's Office are still in place today, just as they were in the 1950's,
1960's, 1970's and 1980's. These have not changed as it is against the
very heart of Scientology to change or alter any of Hubbard's teachings
and belief. The activities of the Guardian's Office have not disappeared
any more than Scientology's "enemies" have. These activities are
on by the staff of the Office of Special Affairs ("OSA") and their
private investigators who ostensibly work for Scientology lawyers, and
are thus protected by the attorney work product privilege.
Scientology learned the hard way to keep its criminal activities at arm's
length. An example of this is private investigator, Eugene Ingram, who
was hired by Miscavige, to get the evidence on adverse attorney, Michael
Flynn, for supposedly forging a check on L. R. Hubbard's account.
Ingram paid money to Ala Tamimi, a criminal in jail, for a statement
saying he was hired to forge the check by Michael Flynn. I was then
informed by Mark Rathbun, then Miscavige's legal executive in ASI,
that Ingram bribed Tamimi in order to get Michael Flynn charged
criminally. After this incident failed, I learned that Ingram was
spending quite some time living in Mexico in order to avoid the
authorities investigating the matter.
MISCAVIGE STRIKING SCIENTOLOGY STAFFERS
14. Contrary to the claims in his February 4, 1994,
declaration Miscavige has struck staff members when they do things he
dislikes. In 1981, I witnessed him hitting John Axel, a Sea Org member in
the mouth in 1982. Miscavige had two other tall male staff members to
back him up when he hit John Axel. This despite the fact that John
Axel is a fairly small and very mild-mannered individual. Miscavige also
does such things as set up photos of staff members who have fallen
into disregard and use them as targets for pistol shooting. I witnessed
him doing this with the Golden Era Musicians, Of which Fernando
Gamboa was one of his targets.
THE DEATH OF HUBBARD
15. When I arrived at Hubbard's ranch, in San Luis Obispo,
following his death, I was informed by Miscavige that Hubbard was
dead and that he did not want to see "any grief bullshit about it."
Earl Cooley, Esq. and others convinced the San Luis Obispo coroner
not to do an autopsy on Hubbard's body which was cremated
approximately 24 hours after death. Miscavige then announced to
the Scientology world that Hubbard had "dropped the body" and
would continue his work elsewhere. Scientologists believe that
upon death the person drops the body, picks up another body
and continues to serve Scientology. This is how the billion year
Sea Organization employment contract is performed.
16. I was aware just before Hubbard's death, that certain
indictments were about to be handed down against Hubbard. Miscavige
reportedly said that "the only way to stop it now is if the old
man [Hubbard] dies."
17. I was one of the small group summoned to the Hubbard
ranch after he died. Vaughn Young and David Miscavige were also
summoned to the ranch.
THE DEATH OF MIKE RINDER'S BABY
18. Mike Rinder, a member of the CMO International and
his wife, Kathy, had a newborn baby in Clearwater, Florida in the
early eighties. Mike Rinder was in Gilman Hot Springs, California
at the time. This baby died when only a few days old. The baby had
received Hubbard's baby care technology. After the baby died, Rinder
asked to receive some time off to go to be with his wife and family.
When Miscavige was told of this, he responded that time off was
"bullshit" and Rinder did not need time off, he just needed to work
as his stats ("statistics") were down. Besides the baby would get
another body and there was nothing to be so upset about.
END OF CYCLE PROCESSING
19. The term "End of Cycle" does exist in Scientology.
means to terminatedly end something. There are many Scientology
processes and routines that incorporate this concept. The idea that
someone ends cycle when they die is a Scientology concept and is
expressed in Hubbard's writings. (See attached Exhibit D)
THE TIME MAGAZINE ARTICLE WAS NOT OF AND CONCERNING CSI
20. I have read the Time Magazine article entitled "
Thriving Cult of Greed and Power" published on May 6, 1991. In
particular, I have read two paragraphs of that article concerning comments
allegedly attributed to Steven Fishman and Dr. Uwe Geertz. There are
references to "Scientology" and "the church" in these two
have also been advised by Graham E. Berry, Esq., that the Church of
Scientology International alleges that the words "Scientology" and
Church" were "of and concerning" Church of Scientology International
("CSI"). This allegation is absurd and false. CSI is a management
church only. It has no members. In essence, it is a trademark/copyright
licensing vehicle and a financial conduit. Moreover, the corporations
of Scientology are a carefully contrived sham and shell structure
intended to confuse and divert litigants, the courts and the I.R.S.
Indeed, Mission Corporate category sort out ("MCCS"), of which
the MCCS tapes were a part, (see the Zolin case) was part of the
creation of this corporate shell game.
21. Accordingly, it is absurd to allege that the words
"Scientology" and "the church", as used in the relevant
sections of the
Time Magazine article, refer to anything other than Scientology or
the Church generally and/or generically. Certainly, they are not of
and concerning CSI.
SUPPRESSIVE PERSONS AND FAIR GAME
22. 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
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,
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."
23. This practice or policy is sometimes referred to as the
policy of "fair game." In the jargon of Scientology, a person who
declared is understood to be a suppressive person ("SP") . This
means that the person is "fair game." The fair game policy was
issued in the 1960s. It was never canceled. A document was issued
for public relations reasons that purportedly canceled "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.
came across my desk I know that throughout my presidency of RTC,
fair game actions against enemies were commonplace. In addition to the
litigation tactics described below, fair game activities included burglaries,
assaults, disruptions 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.
FRIVOLOUS SCIENTOLOGY LITIGATION
25. 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 0 Checksheet" American Saint
Hill Organization 1968.)
26. 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 on-going legal case involving
Scientology. I received, or so I was told, copies of every major motion
filed in cases involving Scientology 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.
27. It is the stated policy and practice of Scientology to
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 of 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.
SCIENTOLOGY DESTROYS EVIDENCE AND REWRITES HISTORY
28. 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 preclear (" 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 claim against
Scientology. This practice is known within Scientology as "culling PC
folders" and is a common litigation tactic employed by Scientology.
29. 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
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.
30. 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 a
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 International.
31. 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 on her stationery. 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.
32. 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 Merrit
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.
33. 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.
SCIENTOLOGY INFILTRATES THE U.S. GOVERNMENT
34. 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,
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
FISHMAN ALLEGATIONS ARE CREDIBLE
35. I have examined certain documents regarding
Steven Fishman's experience with Scientology, have had
conversations with Mr. Fishman's counsel, in his criminal
prosecution and I have reviewed the 1151-page autobiographical
account of Mr. Fishman's Scientology experience entitled "The
Lonesome Squirrel." Based on my 15 years of experience in
Scientology and my review of the Fishman materials, I offer the
following opinions and conclusions.
A. I believe Mr. Fishman's assertions that he was
a member since 1979 and that he was 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 apparently 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
B. 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 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
whatever 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 is consistent
with their modus operandi.
I declare under penalty of perjury under the laws of the
United States of America that the foregoing is true and correct.
Executed this 7th day of March, 1994 at Dallas, Tx.