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HUB LAW OFFICES
Ford Greene, Esquire
California Bar No. 107601
711 Sir Francis Drake Boulevard
San Anselmo, California 94960-1940

Attorney for Plaintiffs
VICKI J.AZNARAN and
RICHARD N. AZNARAN

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

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FORD GREENE declares:

    1. I am an attorney licensed to practice law in the Courts

of the State of California, am admitted to the Bar of this Court,

and am the attorney of record for Vicki J. Aznaran and Richard N.

Aznaran, plaintiffs herein.

    2. Defendants, and their counsel, have recently submitted an

increasingly shrill litany of degrading aspersions regarding the

nature of my alleged affiliation with defendants' former lawyer,

Joseph A. Yanny. The purpose of this declaration is respond

Page 1.            DECLARATION OF FORD GREENE REGARDING ALLEGED "TAINT" OF J.A. YANNY ESQUIRE

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thereto in a general manner because a point by point refutation is

not worth the time, effort and trouble required to articulate.

    3. The suggestion, much less the claim, that I am somehow

the puppet of Yanny is ludicrous. In short, my response to the

allegations of defendants regarding the Yanny taint and the extent

to which it has been alleged to be spread on me is as follows:

My writing in this case has thus far been stylistically and

substantially consistent. As the court will note from my

opposition to Scientology's initial summary judgment motion (with

the exception of the injudicious use of the term "Cult") in this

case to my most recent oppositions, I have a particular style of

legal expression that is my own. The content and approach thereof

is relatively consistent. The hand that so writes is mine, not Mr.

Yanny's.

    4. I was responsible for articulating the theory which the

California Supreme Court in Molko v. Holy Spirit Association (1988)

46 Ca1.3d 1096 found persuasive. That theory primarily deals with

the interrelationship between deceit and coercion as those

ingredients impact upon an individual's ability to reason and

capacity to exercise an informed consent to organizational

affiliation. I am convinced that "brainwashing" is the intentional

and deliberate application of specific and identifiable techniques

designed to undermine an individual's ability to reason and

severely impair his capacity to exercise an informed consent so as

,to replace those volitional ingredients with an indiscriminate and

unconditional obedience to the commands of the leadership. I

understand the manner in which brainwashing attacks an individual's

sense of identity and achieves dominance of such individual. I am

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convinced that a coercive, closed group or "cult" is a group of

people, often masquerading in the guise of a religion, the members

of which are unconditionally and indiscriminately obedient to the

commands of a single leader who claims to have a direct

relationship with God, or some greater-than-human source of

authority.

    5. In varying ways, and from different points of reference,

my participation in the case at bar has involved the application,

within the confines of the law, of the specialized knowledge I

possess having to do the deceit and undue influence practiced

by the Scientology organization. I believe my analysis in this

regard, as it has been expressed in writing in this case, is

ascertainable and has been consistent during the pendency of the

case at bar. Joseph Yanny never has had anything to do with the

way I think and the manner in which I apply and/or express the

knowledge I possess.

    6. I have met with John Koresko on a Saturday and Sunday in

early August. In assisting Mr. Yanny accomplish the transition of

the case back to my office, he delivered to me papers that had been

filed in this matter during the period that Yanny was attorney of

record (including papers, filed by defendants, which falsely stated

that I had been in a rehabilitation facility for substance abuse).

Mr. Koresko offered his assistance in helping me get up to speed.

I provided Mr. Koresko with copies of Scientology's table of

authorities extracted from each of its six pending motions and sent

him to the Marin County Law Library with instructions to make

photocopies of each of the cases that was not a California case (I

have a full-service California law library). I received no

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litigation instructions of any sort from Koresko, Yanny originated

or otherwise.

    7. I am grateful for the on-going assistance that I have

received from Gerry Armstrong. While I have worked - at times

around the clock - he has assembled the products of my labors and

ensured that they were prepared for filing and service. I have

received no Yanny originated suggestions regarding how to litigate

against Scientology from Armstrong and the suggestion that he is

Yanny's shill and that I am the dupe of both is laughable.

    8. I am informed and believe and allege thereon that

defendants have in the past, and will continue in the future, to

exploit their fallen relationship with their former attorney as a

manner of attempting to obfuscate the real issues in the case at

bar. It is more expedient for Scientology to cry wolf and attempt

to engender sympathy than to meet the issues head on and fight

clean.

    9. During my participation in the instant litigation, my

office, my home, the home of girlfriend and her person have been

the subjects of repeated and on-going surveillance. In spring

1989, Scientology operatives rented an apartment unit across the

street from my office in order to maintain around-the-clock

surveillance of me, my clients and friends. During the last month

the street in front of my office and the parking lots across the

street have been crawling with Scientology investigators with their

cameras, video-cameras, binoculars, cellular telephones and yellow

legal pads. My neighbors have expressed fear to me regarding the

meaning of such activities. Scientology, through its chief

"investigator" Eugene Ingram, has managed to generate

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investigations of me by the F.B.I., Los Angeles County District

Attorney's Office and State Bar for allegedly committing perjury in

what I am informed and believe has been an effort to obtain my

"disqualification" from representing the Aznarans, or subject me to

retribution for being so bold as to stand in opposition to the

Scientology organization. I am informed and believe that the

reason that Eric Lieberman telephoned me in February or March 1991

in order to seek a stipulated continuance of the April 9 trial date

in the case at bar was so that Ingram would have enough time to

generate a criminal prosecution against me. I am informed and

believe that no such prosecutions will be forthcoming. I am

informed and believe that in the spring of 1989 Scientology

operatives searched through my office garbage, in order to find the

names of cases, clients, and opposing counsel whom then were

contacted in an attempt to stir up trouble for me; I have been

contacted by such people who have reported such activities to me.

    10. I am losing patience with the tactics of my adversaries.

I assure the court that the moral conviction required to endure

such extra-judicial harassment, and work around the clock

responding to the pounds of motions filed by Scientology, would

never exist were I another man's puppet.

    11. I am my own man and do not consult with Joseph Yanny

concerning litigation strategies in this case.

    Under penalty of perjury pursuant to the laws of the United

States I hereby declare that the foregoing is true and correct

according to my first-hand knowledge, except those matters stated

to be on information and belief, and as to those matters, I believe

them to be true.

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    Executed on September 4, 1991, at San Anselmo, California.

[signed]
FORD GREENE

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PROOF OF SERVICE

    I am employed in the County of Marin, State of California. I

am over the age of eighteen years and am not a party to the above

entitled action. My business address is 711 Sir Francis Drake

Boulevard, San Anselmo, California. I served the following

on the following persons) on the date set forth below, by placing

a true copy thereof enclosed in a sealed envelope with postage

thereon fully prepaid to be placed in the United States Mail at San

Anselmo, California:    SEE ATTACHED SERVICE LIST

DATED: September 4, 1991

[signed]
FORD GREENE

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AZNARAN vs. SCIENTOLOGY

Service List

JOHN C. ELSTEAD
Clifton, Polson & Elstead
6140 Stoneridge Road
Suite 500
Pleasanton, California 94588

EARLE C. COOLEY
Cooley, Manion, Moore & Jones, P.C.
21 Custom House Street
Boston, Massachusetts 02110

ERIC LIEBERMAN
Rabinowitz, Boudin, Standard,
Krinsky & Lieberman, P.C.
740 Broadway at Astor Place
New York, New York 10003-9518

WILLIAM T. DRESCHER
23679 Calabasas Road, Suite 338
Calabasas, California 91302

MICHAEL L. HERTZBERG
740 Broadway at Astor Place
New York, New York 10003-9518

LAURIE J. BARTILSON
Bowles & Moxon
6255 Sunset Boulevard, Suite 2000
Hollywood, California 90028

JAMES H. BERRY, JR.
2049 Century Park East
Suite 2750
Los Angeles, California 90067

JOHN J. QUINN
Quinn, Kully & Morrow
520 South Grand Avenue
8th Floor
Los Angeles, California 90071

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