GRAHAM E. BERRY, State Bar No. 128503
GORDON J. CALHOUN, State Bar No. 84509
LEWIS, D'AMATO, BRISBOIS and BISGAARD
221 N. Figueroa Street, Suite 1200
Los Angeles, California 90012
Telephone: (213) 250-1800
I, Robert Vaughn Young, declare that I am over
18 years of age and am a resident of Newport Beach, California.
I have been retained as an expert consultant
and expert witness by Dr. Uwe Geertz's counsel in the case captioned Church of
Scientology International v. Steven Fishman and Uwe Geertz. *CV-6426-HLH (Tx)
currently pending in the United States District Court, Central District of
The statements herein are of my own personal knowledge or reasonably based upon
information and belief, and if called upon as a witness, I can testify
This declaration is submitted in support of
Defendant Dr. Geertz's motion for costs, fees, expenses and sanctions following
the dismissal of this action with prejudice by the court on February 22, 1994.
My credentials as an expert on Scientology
over 20 years as a staff member in the organization. In those 20 years, I have
held nearly every type of position at every echelon. I have worked at the local,
the regional, the national and the international levels. I have been a
representative and spokesman before governmental bodies, the media andthe
I have trained others on how to handle the media and governmental agencies. I
have been the most senior public relations executive for Scientology world wide.
I worked for years at the echelon that handles critics, "enemies," the
media, judges, the courts and the government. I have been privy to documents and
tactics of the most secret nature, including illegalities committed by
executives and the means of cover-up. I have been called on many occasions to
personally handle "hot" situations of the most sensitive nature
from the mysterious death of the son of Scientology Founder Ron Hubbard ("
to the death of Hubbard himself. I have been privy to financial schemes and
involving tens of millions of dollars. I also know how Scientology manipulates
the law to avoid any revelation of the truth.
SCIENTOLOGY ADVOCATES USING THE COURTS NOT TO SEEK JUSTICE BUT TO HARASS
AND RUIN PEOPLE
Plaintiff Church of Scientology
("CSI") request that this case be dismissed is in keeping with one of
their most senior scriptures," to use to courts to harass and ruin people
rather than win. It has been a primary tactic since Hubbard gave the edict in
1955 when he wrote the purpose of bringing a lawsuit:
"The purpose of the suit is to harass and discourage rather than to
The law can be used very easily to harass, and enough harassment on somebody who
is simply on the thin edge anyway, well knowing that he is not authorized, will
generally be sufficient to cause his professional decease. If possible, of
ruin him utterly." (From Hubbard's 1955 "The Scientologist: A Manual
of Dissemination of Material." Emphasis added. Attached as Exhibit A)
The basic reason that Scientology does not use the courts for justice is
Hubbard believed the Scientology justice system he invented was vastly superior
and that his system should become the planetary standard.
DR. GEERTZ IS THE TARGET OF SCIENTOLOGY'S VOW TO DESTROY "THE
The key to understanding the mystery of the
current lawsuit and its tortuous route will be found in the above Hubbard
plus one further element: Defendant Dr. Uwe Geertz is a psychologist.
has vowed to destroy and take over the field of mental health. Thus Dr. Geertz
is the target of Scientology's equivalent of "The Final Solution,"
a profession has become a universal scapegoat.
PSYCHS ARE SCIENTOLOGY'S SCAPEGOATS FOR EVERYTHING INCLUDING SEX
It is drilled into every Scientologist's head
that all troubles and problems - Hubbard's, Scientology's, America's, the world,
this corner of the galaxy and literally the entire universe - are due to
and psychologists, known collectively as "the psychs." In fact,
said the ONLY cause of crime is the "psychs." He even goes so far as
to say "there are no laws at all which protect them." from being
(See Hubbard's "The Cause of Crime," Attached as Exhibit B. See also
declaration of Stacy Young also filed this date.)
The "psychs" are Hubbard's scapegoat
for all historical ills going back not merely scores of years but hundreds,
and even millions of years. In Hubbard's paranoid view, everything from rock and
roll to the Third Reich and even sex itself were vile inventions of 'psychs'.
(See "Pain and Sex." Attached as Exhibit C.) As incredible as that may
seem, Hubbard actually believed that sex was literally invented by "
millions of years ago. While he doesn't come out and say it, the implications
are clear: all sex - even the attraction between couples - is bad.
The intensity of Hubbard's anti-sex (and
anti-female) attitude is not known to many Scientologists. Starting in 1981, I
had full access to Hubbard's most private papers, diaries and letters. I
to have unlimited access to it for years as part of the work to write a
of Hubbard and was able to read letters to and from his parents, wives,
friends and business associates. There were hundreds of thousands of pages of
material - much of it originals or carbon copies in his own handwriting - that
detailed his views about his life, his wives, his family and sex. Much of this
was written in the 1930s and 1940s but extended into the 1970s. Some of these
papers were diatribes against females and were covered with red-ink drawings of
genitalia around the margins of the pages. He also graphically described what
he wanted to do to women, including hurting and raping them. Suffice it to say
that it was x-rated and sadistic. This was my initiation into the dark side of
Hubbard's views. (These papers were subsequently locked away so no Scientologist
will even know they exist, let alone allow anyone to see them.)
Hubbard's anti-female attitude appeared first,
in private writings in the 1930s and 1940s. His views of "the psychs"
developed after the publication of his first Scientology books in 1950 when he
was courting "the psychs" for approval of his system. When he was
andcriticized, he became incensed and began to blame them for his troubles with
the press and his customers.
Thus Dr. Geertz is viewed as a part of the
(and intergalactic) conspiracy that must be annihilated before Hubbard and
can reign on Earth.
CSI'S CASE IS PART OF THE "FAIR GAME DOCTRINE" AND "
ARE FAIR GAME
CSI has a Fair Game Doctrine where any "
can be "destroyed." This doctrine is practiced against apostates,
the press and has even been used against courts. It has been practiced against
Dr. Geertz (starting with this lawsuit that put him into bankruptcy) and his
in this case (ranging from an investigation that this court ordered stopped to
vandalism of Mr. Graham Berry's property.
I will show how the Fair Game Doctrine
how it has continued to this day and how this court has been exposed to these
end- justifies-the-means methods. I will present this using the writings (now
called "scriptures") of Hubbard. These are the iron-clad policies of
"FAIR GAME": THOSE THAT HAVE NO RIGHTS; THEY AND/OR THEIR
CAN BE DESTROYED
The doctrine of Fair Game was codified on
7, 1965, when Hubbard issued titled "Suppressive Acts: Suppression of
and Scientologists: The Fair Game Law" (Attached as Exhibit D) Hubbard
"By FAIR GAME is meant, without rights for self, possessions or
and no Scientologist may be brought before a Committee of Evidence or punished
for any action taken against a Suppressive Person or Group during the period
person or group is 'fair game'. "
A revision of December 23 1965, changed it to
"By- FAIR GAME is meant, may not be further protected by the codes and
disciplines of Scientology or the rights of a Scientologist."
As to what was a "suppressive person,
Hubbard gave the definition:
A SUPPRESSIVE PERSON or GROUP is one that actively seeks to suppress or
Scientology or a Scientologist by Suppressive Acts.
SUPPRESSIVE ACTS are acts calculated to impede or destroy Scientology or a
Scientologist and which are listed at length in this policy letter. (Caps in
Some of the suppressive acts listed included
"public disavowal of Scientology; public statements against Scientology;
asking for a refund of fees paid; and "writing anti-Scientology letters to
the press." Even turning a Scientologist into the proper authorities can
gain one the label of a suppressive. The issue also prohibits "1st degree
murder, arson, disintegration of persons or belongings not guilty of suppressive
acts." (Emphasis added.) In other words, killing suppressive persons or
their property promotes Scientology and is therefore ethical within the
WHY SCIENTOLOGISTS CANNOT GIVE UNBIASED TESTIMONY
The material just quoted also shows why
cannot give unbiased testimony. If the testimony is viewed as critical of
or a Scientology executive, it would be a "public disavowal" and a
statement against Scientology" and would be a suppressive act. The person
could then be kicked out of Scientology and be made Fair Game and sued. Since
Scientologists don't want this to happen to them, they will not make any
remarks or remarks that may be deemed critical. This is why Scientology
have insisted that only active Scientologists can be experts" - because
will be biased to Scientology rather than responding fully and honestly to the
AN EXAMPLE OF HUBBARD IMPLEMENTING FAIR GAME
Scientologists like to find instances where
Hubbard applied a doctrine so they can imitate it. Hubbard gave an example of
how Fair Game should be applied shortly after he created the doctrine. Hubbard
gave specific orders on how to apply the Fair Game doctrine in HCO Executive
27 September 1965 or. "Amprinistics " (attached as Exhibit E) This was
what he called a "splinter" group, a group that was using Scientology
"technical" methods without his control. Hubbard's three-page issue
blasts the Amprinistics leaders with a variety of sexual charges (one of his
topics for accusations) and says what should be done: "They are each fair
game, can be sued or harassed. Hornercan be barred out of any Commonwealth
or England as he was the subject of a deportation order from England and his
has come alive again in the Home Secretary's Office. Harry Thompson's wives and
victims are always looking for him to have him arrested. Watson is a set-up for
arrest as a homosexual. Any meeting held by them should be torn up. The names
of any persons attending should be collected and they should be labeled SP
person] as they have left Scientology. These people are SP because they are
to avoid auditing and retain their withholds. Once labeled, these persons will
not then be covered by amnesty and will never be admitted to further training
and processing. Persons messing themselves up with Amprinistic [techniques]
be refused any assistance. If these persons move into your area act through any
agency you can to have them deported or arrested on whatever grounds. England
is currently too hot for them so they may tour about. Horner's UK deportation
order, Thompson's police record and Watson's homosexuality make them very
to deportation or arrest. Hubbard does not stop there. He goes on to issue a
order that includes:
"(2) Harass these persons in any possible way....
"(4) Tear up any meeting held and get the names of those attending and
issue SP orders on them and you'll have lost a lot of rats.
This order has never been canceled and is still
"scripture" as an example how to attack "enemies." In fact,
as an example of how Fair Game was being implemented against another defendant,
attached as Exhibit F is a declaration from former member David Mayo who
how he was held captive for six months and was told he would "never leave
the property alive." (See pages 4-8) He describes the duress and threats
as he became the target of the Fair Game Doctrine (or "Fair Game
HOW SCIENTOLOGY USES INVESTIGATION AND THE MEDIA TO ATTACK AND HARASS
In 1966, Hubbard began to codify those
of Scientology that would implement Fair Game. For example, on February 17,
he created the Public Investigation Section with a policy letter of that name
and date. (Attached as Exhibit G) He said it would serve "the useful
ofan intelligence and propaganda agency. It finds the data and sees that it gets
action." The statistic of the unit included "the number of derogatory
news stories appearing that week related to enemies of Scientology."
Hubbard also urged the priority of finding
of "murder, assault, destruction, violence, sex and dishonesty, in that
Investigations which can uncover these factors in the activities of individuals
or a group attacking Scientology are valuable in the degree that they contain
a number of these factors." And note that Hubbard's use of such evidence
is not for law enforcement but to the media. "In that way," he wrote,
"we then Get rid of suppressive groups by investigation and
The next day, on February 18, 1966, Hubbard
"Attacks on Scientology" (Attached as Exhibit H) in which he again
the use of investigations. Suppressives, he said, have by definition comitted
criminal' acts. "These people who attack have secrets. And hidden crimes.
They are afraid." He thus urged they be investigated as this, he said,
cause the attacker to withdraw.
A week later, on February 25, 1966, he wrote
another "Attacks on Scientology" policy letter (Attached as Exhibit
I) in which he urged, to "Start feeding lurid, blood sex crime actual
on the attackers to the press.
See also Hubbard's "How To Do a Noisy
of 5 September 1966 (Attached as Exhibit J). The target is "attackers of
FAIR GAME DOCTRINE SPECIFICALLY INCLUDES THE FILING OF LAW SUITS
On October 18, 1967, he issued "Penalties
for Lower Conditions" (Attached as Exhibit K) whereby Fair Game was
issued on anyone (including staff members) who was an "enemy." Such
people were, he said, "Fair game. They may be deprived of property or
by any MEANS by any Scientologist without any discipline of the Scientologist.
May be tricked, sued or lied to or destroyed." (Emphasis added.)
CANCELLATION OF FAIR GAME ONLY MEANT NOT USING THE WORDS ANY MORE BECAUSE
IT CAUSED "BAD PUBLIC RELATIONS"
In the late 1960s, Hubbard was having growing
public relations problems. One problem was Fair Game. To deal with it, Hubbard
wrote an issue that is often cited by CSI as evidence that Fair Game was
But a careful reading will show that nothing has changed but semantics. The
is "Cancellation of Fair Game" dated 21 October 1968. (Attached as
L) The entire text of the policy letter (P/L) is as follows:
"The practice of declaring people FAIR GAME will cease. FAIR GAME may
not appear on any Ethics Order. It causes bad Public relations. [Emphasis
This P/L [policy letter] does not cancel any policy on the treatment or handling
of an SP. [suppressive person] L. Ron Hubbard Founder
THUS THE SO-CALLED "CANCELLATION" OF FAIR GAME DID NOT CANCEL
THE USE OF FAIR GAME TACTICS.
The original directive that CSI uses to say the
Fair Game Doctrine was canceled expressly establishes that the only change was
to stop using the words "Fair Game." Hubbard was quite clear that
were not to change. only the use of the words in public. As further evidence of
Fair Game continuing, Hubbard later wrote"Confidential: Targets,
on February 16, 1969, (Attached as Exhibit M) in which he listed
"vital targets on which we must invest most of our time... The first and
most important: "T1. Depopularizing the enemy to a point of total
MILITARY TACTICS ARE TO BE USED IN FAIR GAME
On the same day, February 16, 1969, he wrote
"Confidential: Battle Tactics" (Attached as Exhibit N) where he urged
the use of military tactics and strategy in dealing with the "enemy."
"A good general expends the maximum of enemy troops and the minimum of
his own. He makes the war costly to the enemy, not to himself. One cuts off
communications, funds, connections. He deprives the enemy of political
connections and power. He takes over enemy territory. He raids and harasses. All
on a thought plane--press, public opinion, governments, etc. (Emphasis added.)
FAIR GAME TACTICS EXPLAIN THIS LAWSUIT
When the Fair Game Doctrine and Scientology's
"Final Solution" attitude towards "psychs" (psychologists
and psychiatrists) are understood, this lawsuit can be understood. It will also
be seen that what was at issue was not the deposition of the "
but those of the executives who were in non-compliance with this Court's Order.
The reason was simple: they are the ones who directed this entire campaign.
HOW SCIENTOLOGY ATTORNEYS ARE USED TO CLAIM "ATTORNEY WORK
Surveillance is one of the standard tactics
used by Scientology and CSI. It is often done by staff from the Office of
Affairs ("OSA"). Tougher or more important assignments are given to
private investigators who are paid by attorneys so the investigation can be
"attorney work product." This practice was because the 1977 FBI raid
shattered Scientology's intelligence network.
The court should note that it has been told
that such practices were done by a previous Scientology administration that has
been eradicated. This is not true. I am attaching the billings of a private
who was doing surveillance on author Omar Garrison and apostate Gerry Armstrong
in 1982. (Attached as Exhibit O) These were billed to attorney John Peterson.
("Peterson") However this investigation was being directed by David
Miscavige ("Miscavige") who at the time (mid-1982) was my senior in
an organization called Author Services, Inc. ("ASI") ASI was a for-
group that was purportedly a literary agency handling Hubbard's books. We did
handle Hubbard's works but our real function was to serve as Hubbard's personal
arm into the non-profit Church of Scientology. This investigation by Tin Goose
of Omar Garrison and Gerry Armstrong was paid for by Church of Scientology funds
on Miscavige's orders while Tin Goose reported directly to Miscavige. Peterson
was merely the "cutout," to make it appear that it was attorney work
product and to keep it away from ASI.
HOW MISCAVIGE USED A "DOUBLE-BLIND" TO GO AFTER AN ATTORNEY
In 1982 a "double-blind" system was
initiated by Miscavige when he was directing the campaign against Boston
Michael Flynn. ("Flynn") Flynn had been representing plaintiffs in
against Scientology and Hubbard, and Miscavige was demanding that Flynn be
(This is the Fair Game Doctrine although the words were never used, per
orders.) Peterson was told to hire another attorney who had no connection or any
knowledge of Scientology. That fresh attorney was to hire the private
to undertake certain harassing actions on Flynn. Thepurpose of the double-blind
was if the investigator was caught and traced to an attorney, it would not be
one hired by a Scientology group and any illegalities could be protected twice
as attorney work product.
With the formation of the firm of Bowles and
Moxon (attorneys for plaintiff in this case), investigations were moved to them
rather than attorneys like Peterson because Bowles & Moxon are
and can be manipulated and threatened. Peterson was not a Scientologist and
not be so controlled.
EXPERTS AND COUNSEL ON THIS CASE WERE KEPT UNDER SURVEILLANCE
The court was advised of the investigation of
counsel Graham Berry and ordered that it be stopped. (It was not because CSI
stop. Such investigations are required by Hubbard's "scriptures.") A
similar investigation and surveillance was done of other experts on this case
including myself and my wife. This went on for months. We have been tailed on
the freeways, in shopping malls and even while a hundred miles from home on a
day off. (In one instance, a tail I accosted confessed that he was tailing me
and that he was Scientology staff.) Our trash has also been pilfered and former
employers and associates interviewed. All of this is in keeping with the Fair
Game Doctrine, hoping that they will find something to intimidate the person
(If that doesn't happen, then something is concocted. They are now doing that
with me, asserting that I assaulted a Scientologist in the city of Hemet. Their
insistence that I be charged is being led - appropriately enough - by one of
key public relations people, Ken Hoden, who gets his orders from David Miscavige
("Miscavige") who is the head of the Scientology empire. At this
nothing has come of their baseless allegations.)
EXAMPLE OF TARGETING A PERSON IN LITIGATION WITH SCIENTOLOGY
Attached as Exhibit P is a Scientology program
("Julie's Background") designed to deal with a court problem in 1979.
Julie Christofferson. She had sued the church and this program was written to
document that the people involved in the Christofferson case are criminals with
criminal backgrounds and criminal records and that they engage in a criminal
to defraud the organization under the guise of "home and mother."
appears to be pure as the driven snow, so considerable background data
euphemism for covertly obtained data] on her is needed to give usdirection in
locating the real facts of interest about her.
Those "real facts of interest" are
stated in the next paragraph as to what Scientology wants on the plaintiff. The
criminal background, drug history, record of arrests, former employment,
of Julie, fully known and documented, as needed.
The program then goes on for pages to tell how
to do this. There is nothing to indicate there is anything to find, merely the
Hubbard-driven assumption that anyone who sues Scientology or attacks
must by definition be a criminal. The program was written on Hubbard's
CSI'S REFUSAL TO COMPLY IS BECAUSE OF CSI'S COMPLETE DISDAIN FOR ANY
OTHER THAN HUBBARD'S
CSI's general non-compliance with the orders
of this Court was because of the disdain that Hubbard and the current leadership
have for this and any court as well as the law. Time and again Hubbard wrote how
his system of "justice" was superior to any system. Additionally
and Scientology were constantly being challenged by the courts. In Hubbard's
neither he nor Scientology should have to answer to anyone.
ACCORDING TO THE SCIENTOLOGY BELIEF SYSTEM. THE COURTS ARE PART OF A
PLAN DIRECTED BY "THE PSYCHS"
Another reason Hubbard and Scientology hold
the courts in such disdain is Hubbard's view that the purpose of the justice
is to support psychologists and psychiatrists. This is done by "
creating criminals who keep the courts alive who feed them back as a self-
system, funded entirely by the government. Hubbard wants to have the criminals
fed to Scientology and to replace the legal system of justice with Hubbard's
thus collecting the money that he felt is going to the psychiatrists and
(See attached as Exhibit Q "The Criminal Mind and The Psychs,"
as Exhibit R "The Cause of Crime," attached as Exhibit S "
and Psychiatry," and attached as Exhibit C "Pain and Sex.")
THE ORDERED DEPOSITIONS SHOULD HAVE PROCEEDED
The Court ordered David Miscavige, Norman
Mark Yager, Ray Mitoff, Lyman Spurlock, Marty Rathbun, Greg Wilhere and Jonathan
Epstein to deposition. Most have, in turn, filed declarations to explain why
know nothing that is germane to this case. To the contrary, these are the
who know more about this case than any other people.
Despite Miscavige's protests, he runs all of
Scientology, regardless of corporate lines. In Scientology, there is only
Corporate lines are set up as ways to deflect the courts, the IRS and the
When it comes to everyday work, Miscavige is appraised of every part of
from the church to the secular. He also issues orders to all sectors and
all major transactions. His role is as the head of Scientology is well known
Scientology. It is only when it comes to matters such as this suit that he and
his lieutenants must suddenly conjure up the corporate lines and claim
MISCAVIGE KNEW OF FISHMAN AND CROSSED CORPORATE LINES TO DEAL WITH
Additionally, Miscavige knows about Defendant
Steve Fishman ("Fishman") and the amounts of money that Fishman
to Scientology. Miscavige had people removed from their positions because of the
Fishman's money and now Miscavige claims he knows nothing. But Miscavige knew
of the massive amounts of money the Fishman had contributed. Miscavige gave a
briefing at Golden Era Studios near Hemet, California, in 1987 to hundreds of
staff (that included staff from non-CSI corporations) about Fishman's
of about $80,000 for a library of "leather-bound" tapes. In that
Miscavige screamed and cursed at the head of Golden Era Studios (Wendall
because there were no such tapes to be sold. Miscavige (who is Chairman of the
Board of the Religious Technology Center, a non-CSI entity) removed Reynolds
his position on the spot and assigned Reynolds to the gulag known as the
Project Force where he worked at hard labor for over two years. (I was sentenced
to the same gulag for 14 months. Reynolds was there when I arrived.) Thus
not only knows of Fishman but has admitted it to hundreds of others. His claim
he knows nothing is false testimony, as many can testify.
The others (Starkey, Yager, Mitoff et al) are
Miscavige's immediate lieutenants who carry out his orders into their various
sectors. They too know about the lack of corporate integrity and any role that
Fishman played in Scientology. They also know about the various Hubbard
I have quoted from.
FISHMAN WAS BEING URGED TO INVEST IN "SPECIAL PROPERTIES,"
IS NOTHING BUT A FINANCIAL SCAM
The idea of "leather-bound tapes"
is part of a line of "special properties" that was created by
in 1982 when he was Chairman of the Board at Author Services, Inc. ("
I joined ASI in February, 1982, and left it in 1989. One of ASI's functions was
to make millions of dollars for Hubbard. One way was by investments of Hubbard's
fortune, which Miscavige directed, even though Miscavige had no investment
Miscavige poured millions of dollars into oil speculation and lost it without
telling Hubbard. (At one point the estimate was that Miscavige had lost about
$50 million of Hubbard's.) "Special Properties" was Miscavige's idea
on how to recoup the millions before Hubbard (and the IRS) found out. The idea
was to create "leather-bound special editions" and other items that
could be sold at outrageous prices as an "investment". Those who
books at thousands or even tens of thousands of dollars were then told a few
later how their "investment" had increased. Meanwhile, on the open
the books were worth perhaps a hundred dollars, which was why Miscavige
the open sale of these "Special Properties." (ASI now denies that
ever was a line of properties for investment.") This was how Fishman came
to spend an astounding $80,000 for a set of "leather-bound" tapes,
didn't even exist, and why Miscavige knew.
CSI HAS MISREPRESENTED ITS ROLE IN RELATION TO THE "CELEBRITIES"
CSI's claim that it didn't want to put its
through a hardship is patently ridiculous. In my 20+ years in Scientology (which
included working with many of them), I never once heard anything like this. To
the contrary, it was just the reverse: "celebrities" would complain
how they were being used, how they were being ordered to promote Scientology and
being made to make media appearances when there was a legal problem or a problem
in the media. The fact that these "celebrities" did not appear for
ordered depositions shows the control that CSI has over them. Now CSI turns it
upside down again, claiming their welfare is why they want to drop a three-year
old suit that has cost millions of dollars.
THE DEPOSITIONS OF THE "CELEBRITIES" DID NOT INVOLVE
CSI has made it a point that several "
will be exposed to "confidential" material if forced into deposition.
I know what material CSI was referring to and those materials had nothing to do
with the ordered depositions. The "confidential" material is what is
called "upper level" material in Scientology. This material is
for certain steps in Scientology "counseling," and had nothing to do
with the ordered depositions of "celebrities," none of whom are even
familiar with them.
At no time has attorneys for Dr. Geertz asked
me for any assistance in handling this material, as to what it might mean, how
they might ask questions about it, how they might use it or how the material
be presented to a person in any deposition, let alone indicate in any way that
they intend to use those materials with those "celebrities." Nor are
attorneys for Dr. Geertz capable of doing this without expert help for the
in question is highly arcane, complex and bizarre and will make absolutely no
sense to anyone outside of Scientology. Thus the idea that attorneys for
will somehow expose these "celebrities" to this "upper
material is merely a sham and an excuse. What was feared was that the other
would occur, namely that of Miscavige, Starkey, Yager, etc.
CSI's attempt to use their own refusal to
with the court as the reason for dismissal is a classical Scientology through-
DENIAL OF LEGAL LIABILITY WAS A TACTIC TAKEN ORIGINAL WITH HUBBARD
It was a long a well-known fact to Scientology
executives that Hubbard ran Scientology, even though he had made public claims
he was not. That was why there were programs to make it appear that Hubbard had
no legal connection to the church. That tactic is what is now being used for
who has taken over Hubbard's position at the top of Scientology, even though
runs it just as Hubbard did. (See Exhibit T for "Operation Bulldozer
a program designed to create that impression.)
CSI HAS NOT REFUTED YOUNG'S STANDING AS AN EXPERT
In the declarations filed to claim discovery
is complete, CSI has tried to refute my standing as an expert, even going to far
as to twist the facts. For example, Miscavige tries to refute my claim that I
arrived on the scene of Hubbard's before the authorities by saying that I
with some gardeners and cooks. This is not only not true but ridiculous since
I arrived in the same entourage as Miscavige himself, two private investigators
and attorney Earl Cooley who handled the disposition of Hubbard's body.
knows that I was a top Hubbard aide who was privy to considerable material and
so do many others. He (Miscavige) can no more tell the truth about my role than
he can about his, that he runs all of Scientology. I stand by my declarations
and the documents supplied with them and am confident that the Court can winnow
the wheat from the chaff.
HUBBARD'S DEATH CREATED A POWER STRUGGLE THAT MISCAVIGE WON
Hubbard died in hiding in January, 1986. He
had been in hiding for several years. Even though we were in weekly written
with him at Author Services, Inc., it was our task to pretend we were not, to
keep the authorities from knowing how to reach him. During this time, Hubbard's
closest confidant was Pat Broeker who was living with him as his aide. When
died, a power struggle erupted between Broeker and Miscavige as to who would run
Scientology. Miscavige won. Those on Broeker's side were purged. That included
me. I was sent to a desert gulag for 14 months. Broeker's wife Annie gave in and
arrived while I was there. She later escaped once and was captured and returned
and kept under 24- hour guard. Pat disappeared and no one has heard of him
It is not known if he is alive.
HUBBARD'S AND OTHER MYSTERIOUS DEATHS IN SCIENTOLOGY
When it comes to the issue of deaths in
there are some important ones to use as a measure, starting with that of its
Hubbard, who died in January, 1986. I arrived at his secret ranch near San Luis
Obispo, California, within hours of his death, well before the authorities. I
went with Miscavige, attorney Earl Cooley, two private investigators and a few
other key, selected staff. It was our collective task to take command of the
The greatest fear was that there would be a panic in the Church of Scientology
if the circumstances of Hubbard's death were known. For example, while Hubbard's
condition deteriorated in the final weeks, his personal physician (Dr. Gene
was sent to Reno to gamble, leaving Hubbard with no medical attention. Or that
Hubbard's primary source of Scientology help was a person who had taken LSD over
1000 times. Or that the story that Hubbard decided to "leave the body"
(Scientology's way of saying "died") was dreamt up at the next morning
to calm Scientologists. Or that the body was quickly disposed of to avoid any
autopsy that would reveal "medicines" that he had been taking. Thus
the actual truth of Hubbard's death has yet to be told.
Hubbard's son Quentin also died under
circumstances in 1976. He had disappeared from his home in Clearwater, Florida,
and was found unconscious in a car next to the Las Vegas airport. (Coroner's
is attached as Exhibit U. He died unidentified, as a "John Doe.") The
engine of the car was on and a hose ran from the exhaust pipe (although it
to have fallen off when the authorities arrived) to the window, making it appear
to be a suicide. But, like his father's death, there were a number of nagging
questions. For example, Quentin was found unkempt with a beard stubble, a state
that no one who knew Quentin could accept. (He was ultra-meticulous in his
Or that the license plate of the car was missing and found under a rock some
away. Or that his wallet was gone, making identification impossible. Or that a
near-empty bottle of liquor was found, as if he had been drinking, when Quentin
did not. Or that there were needle marks on his arms, when he did not use drugs.
Another mysterious but key death was that of
Flo Barnett, Miscavige's mother-in-law. She died in 1985 of three shots to the
chest and one to the temple from a semi-automatic rifle. Two suicide notes were
found. Although she was only 5'3" tall (and weighed only 114 pounds), the
examiner determined she shot herself three times in the chest (with a rifle)
shooting herself through the head. (See coroner's report attached as Exhibit V.)
What the authorities didn't know was that she had left Scientology and was
with apostates, to the anger of her son-in-law Miscavige.
Defendant Uwe Geertz was prepared to present
information about other mysterious deaths, murders and suicides of
and former Scientologists.
CSI DID NOT COMPLY WITH DISCOVERY
One unfamiliar with Scientology systems might
think there would be no other information to be provided but as a 20-year
and one intimately familiar with the unchanging system, I can attest there is
considerable information that was not provided although requested by Dr. Geertz.
CSI has repeatedly protested how many
and people it made available to Dr. Geertz. Being intimately familiar with
files and data-gathering procedures, I can say that CSI has not turned over
volumes of requested material and personnel to Dr. Geertz that are germane to
this case. For example, there are extensive files (including computerized) that
would enable a person to determine the effect of adverse press. These are kept
and maintained on weekly basis. I personally know of them for I have worked with
and have seen these files. They have been kept by Scientology for decades. These
were not provided to Dr. Geertz. Nor were other material that would have been
collected on Dr. Geertz. such as reports from private investigators, credit
all standard actions in Scientology proceedings. Nor has CSI supplied material
regarding their investigation of Fishman's role in Scientology even though CSI's
corporate secretary Lynn Farny said he had seen and reviewed such material.
Nor has CSI supplied those personnel that would
know most about the truth or falsity of the facts in question in the Time
article. Those people are Miscavige. Yager, Willhere and Mitoff, Epstein,
and Starkey would know about Fishman's financial roles and Scientology financial
IT IS ROUTINE TO ALTER SCIENTOLOGY RECORDS AND FILES TO AVOID THE
As early as 1971, I was introduced to the
of altering Scientology records and files to thwart the authorities. This
when I worked as the Temporary Assistant Guardian in San Francisco. Under me was
the Intelligence Bureau which was where Scientology was running its spies and
agents. One day I received an order from the Guardian's Office United States (in
Los Angeles) and was told to do a "clean-up" on any reference to
Williams because she was going to become staff of the Intelligence Bureau in Los
Angeles and possibly become an agent. What a "clean-up" meant was that
I was to find and remove any reference to her anywhere in the San Francisco
where she had served, so there would be no record of her in the organization.
This was to thwart any investigation of her or any trace on her by any
I removed her name from various records and files and sent the material to Los
Angeles. I later saw her in Los Angeles, as Intelligence staff, when I joined
the US Guardian's Office.
After the Federal Bureau of Investigation
raided three Church of Scientology locations in 1977 to obtain documentation
violations of the law, I worked with scores of other people to quickly destroy
any further evidence to keep it from falling into the hands of the authorities.
We were all verbally briefed how we had to go through files and look for (1) any
documents showing illegal activity and (2) any documents to show that Hubbard
was running Scientology (which he was but we were trying to tell the authorities
that he wasn't) and to destroy these documents. In this campaign, the amount of
documents that were destroyed were in cardboard boxes stacked down halls. I do
not know the page count but the stack was about four feet wide, four feet high
and about 60 feet long. And this was from the location with the least amount of
files. And there was no doubt that we were doing this to destroy incriminating
evidence. In fact, several of us questioned this and were told to shut up and
keep shredding paper.
Circa 1983 when I worked at Hubbard's "
agency" Author Services, Inc., we were told there was a threat of an IRS
raid on us and we had to move documents. These went to another floor in the
where we kept watch on them. There were about 50 bankers boxes of files that we
were keeping hidden from the authorities who were also serving subpoenas to get
records. Our task was to keep these other records secret. The files were kept
on that other floor for a couple of months.
This last instance is cited in particular to
anticipate the reply of CSI that the earlier examples were from an earlier
that has been overthrown. This is not true. In fact, the 1983 instance at ASI
was conducted by Miscavige who currently runs all of Scientology.
Thus the cleaning up of files to remove
or incriminating material was routine and the non-appearance of Fishman's name
in certain groups is not indicative that he was not there.
CONTRARY TO THEIR DECLARATIONS, CSI IS STILL USING THE ORIGINAL GUARDIAN
On a number of occasions, CSI has tried to
itself from the Guardian's Office that was raided by the FBI in 1977 and the
Office staff that went to jail, including Hubbard's wife, Mary Sue. It has been
CSI's contention that those associated with the crimes were purged. This is not
The precise target of the FBI raid was the
White Program in the Intelligence Bureau of the Guardian's Office. In 1989 the
Snow White Program was still active and one of its key staff was Grace Marie
(See "Non-Existence Formula" dated 12/16/89 from Show White Pgms Chief
OSA US attached as Exhibit W) Grace Marie Haddy was a key executive of the
bureau and was privy to all communications detailing the illegalities that
sent the 11 executives to jail.
Handling CSI's case before this court is
Moxon ("Moxon") who was named as an unindicted co-conspirator when
Sue and the others were indicted. Moxon was head of the Guardian Office Legal
Bureau in Washington, D.C. (See the "Stipulation of Evidence" attached
to the declaration of Vicki Aznaran, also filed 3/9/94 which includes a
of Moxon's role in obstructing the investigation of the Department of Justice.)
THIS CASE DOES NOT CONCERN PLAINTIFF CSI
With over 20 years as a staff member in
Scientology entities, both inside the Church of Scientology and in secular
groups, I can say with confidence that after reading the article in Time
and the section for which Fishman and Dr. Geertz are being sued, I did not think
of CSI. Although I was well aware that CSI existed, it would have been one of
the last entities that would have come to mind. The article and the sections in
question are about Scientology as a subject and practice, including the secular
side of Scientology. (The secular side of Scientology is a multi-million dollar
activity that has been kept hidden from the court. This side promotes that
writings - the same ones used in this case as scriptures" are non-religious
and "secular" and can be used in commercial enterprises to help the
business or a client. This is the Jekyll & Hyde syndrome of Scientology, how
they pretend to be a religion or a business, according to the potential customer
CSI'S CASE DOES NOT HAVE MERIT FOR SEVERAL COGENT REASONS
Besides the fact that the Time article is not
about CSI, there are additional reasons why CSI's case has no merit. Some of
have already been covered. (1) CSI refused to comply with discovery. (2) CSI
intended to complete discovery because the suit was brought solely for malicious
reasons (to punish a member of a group Scientology has promised to destroy,
to the Fair Game Doctrine.) (3) CSI is not the true plaintiff. Being familiar
with the ecclesiastical and corporate structures of Scientology, I know by
the passages at issue that Dr. Geertz was not speaking of Plaintiff Church of
Scientology International ("CSI"). However that is one of the roles
that CSI has, to intervene, because it has the manpower to wage lawsuits and to
carry out the Fair Game Doctrine via the Office of Special Affairs. (4) There
is a likelihood that what Dr. Geertz said is true, that Fishman was told to
cycle" and to kill Dr. Geertz. CSI's refusal to provide information and
has prevented an adequate defense. But based on my 20 years in Scientology and
seeing the level of criminality that was able to permeate the organization -
kept from the view of all but a select few - I cannot discount his allegations.
(5) Even if Defendants statements are false, CSI was not hurt. By their own
CSI has no members that can be wronged. Additionally by Scientology's own
no press ever hurts them, especially anything in Time magazine. To the contrary,
they have claimed that they grow in the face of such adverse publicity. Thus CSI
must either admit that they were not harmed or admit that their Hubbard's claims
of Scientology's infallibility are false.
The simple truth of this case boils down to
this: the suit was brought under the "anti-psych" Fair Came doctrine
by an entity without members and without standing (CSI) because it has an anti-
arm whose function is to take over the field of mental health and destroy
enemies. I know because I worked at that echelon for nearly 20 years and know
it and the tactics intimately.
I declare under penalty of perjury under the
laws of the United States of America and the State of California that the
is true and correct.
Executed in Los Angeles, California, this 9th
day of March, 1994.
Robert Vaughn Young