Declaration of Vicki Aznaran

Aznaran Litigation

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I, Vicki Aznaran, declare:

1. 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.

2. I was one of the highest ranking members of Scientology and was involved in upper management. From 1978 through 1987 I was a member of an organization known as the Sea Organization ("Sea Org"), an elite organization within Scientology. The Sea Org has considerable influence and control over other Scientology organizations; it sends its officers to individual organizations with unlimited power to handle ethics, tech and administration. In this regard, a Sea Org member may order a non-Sea Org member on virtually any subject, and the non-Sea Org member must obey. For example, sea Org "missions" are frequently sent to non-Sea Org organizations when those organizations are not sending enough money or public to the Sea Org organizations. These Sea Org members on "mission" can take any action they deem necessary in that non-Sea Org organization to accomplish their ends. They can control the funds of that organization and its personnel. They can remove personnel and post personnel. They can transfer funds to the Sea Org organizations or spend funds as they see fit.

3. Generally, Sea Org members hold the management posts in other organizations within Scientology. In order to be employed at a middle management level or above, one must be in the Sea


Organization. In order to be employed at the organizations that make the most money (known as the Sea Org Organizations), such as the Flag Service Org in Clearwater, the Advanced organization of Los Angeles, the Advanced Organization of the U.K., the Advanced Organization of Denmark and the Advanced Organization in Australia, one must be a Sea Org member. Additionally, in order to be employed in the organizations that control the Scientology network, such as the Religious Technology Center, one must be a Sea Org member. From 1984 through early 1987 I was president of Religious Technology Center ("RTC"). By contrast, Scientology management often designates for publicity and other reasons various officers of Scientology organizations who are figure-head officers only and possess little, if any, actual power over the organization they purportedly serve. For example, Hebert Jentzsch was at one time named the titular head of the Church of Scientology International. However, during one of Mr. Jentzsch's depositions he was unable to answer fundamental questions concerning the management of the Church of Scientology International ("CSI") and could not name the directors of CSI nor the other officers. During the time I was in the Religious Technology Center, from 1982 until 1987, Mr. Jentzsch had nothing to do with the running of CSI. Mr. Jentzsch was a figure head and public relations man. It was never intended that he would be involved in the administration of CSI whatsoever. There is an order from Hubbard which states that the officers of corporations should be just figure heads; the directors have more power, and then you have trustees who are over the very top corporations who can remove directors. These trustees hold the power as regards


Scientology's money, assets, personnel, etc. The top trustees of Scientology when I was a director of RTC were David Miscavige, Lyman Spurlock and Norman Starkey. Patrick Broeker and Ann Broeker were also senior trustees over Scientology in 1982 and for some time thereafter. Miscavige convinced the Broekers to turn over their trusteeships to him in order to avoid the IRS criminal investigation that was ongoing. This left Miscavige, Spurlock and Starkey as the trustees that could control Scientology.

4. Lyman Spurlock and Norman Starkey also are both high-ranking Scientologists. At times, both within and outside my capacity as president of RTC, I have taken direct orders from Mr. Spurlock and from Mr. Starkey.

5. Both Mr. Spurlock and Mr. Starkey are members of the Sea Org. In addition, both these men hold other posts within Scientology. For example, Mr. Starkey was president of Author Services, Inc. ("ASI"), executor of the Estate of L. Ron Hubbard and Trustee of the Author's Family Trust-B. Mr. Spurlock at various times was the Investment Officer International for the Church of Scientology, an executive of ASI, and president of Church of Spiritual Technology ("CST"). Both men have served together as officers of Galaxy Productions, Inc.

6. Mr. Spurlock controlled virtually all tax matters for the Religious Technology Center, CSI, ASI, CSC and CST. During the time I was an officer and director of RTC, I was asked to sign letters for RTC which had been drafted by Mr. Spurlock or at his request. Mr. Spurlock dealt with the tax attorneys who represented RTC. Sometimes I would be informed of actions he had taken regarding RTC tax matters after the fact, and sometimes


was never informed. Mr. Spurlock met with the Internal Revenue Service on more than one occasion to negotiate matters for RTC. He did this entirely on his own and made his own decisions regarding RTC's tax matters and tax exempt status. Mr. Spurlock and Mr. Starkey frequently issues orders to me concerning litigation and tax matters concerning RTC, CSI, CSC and other Scientology entities. Mr. Spurlock also set up the current corporate structure of Scientology. This includes the set up of RTC, CSI and CST. Mr. Spurlock set up these structures and, along with Miscavige and Starkey, chose the directors, trustees and officers.

7. Mr. Starkey gave orders concerning litigation matters for Scientology. In 1982 Norman Starkey and David Miscavige ordered me to get Dick Story of the Guardians Office World Wide to hire a private investigator named Dick Bast to compromise Judge Krentzman, who was the judge on a case against Scientology in Florida. Judge Krentzman had been giving Scientology unfavorable rulings in the case. From 1981 up until the time I left, Starkey, Spurlock and Miscavige closely supervised all litigation brought either for or against the various Scientology corporations. The settlement initiated by Scientology for all of the cases that Michael Flynn had brought against them was ordered by Miscavige, Starkey and Spurlock with no consultation with the various corporations who were sued, such as Church of Scientology of California. In fact, this settlement was considered top secret and the officers and directors of the various corporations who were supposedly settling with Mr. Flynn did not even know the specifics of the settlement. The various officers of the


Scientology corporations know that they do not, in fact, make decisions about their respective corporations. They are told and understand that they sign what they are told to and that this is done in order to comply with the suppressive government requirements and avoid having to pay taxes to the suppressive IRS. In 1982 Mr. Spurlock ordered the then-head of international management, John Nelson, to buy into a gold mine in Canada using several million dollars worth of church funds. Mr. Nelson disagreed and said that he thought it was a bad investment. Mr Spurlock made the transaction anyway, as he controlled Scientology's funds. Mr. Spurlock's position at the time was Deputy Executive Director for Client Affairs at Author Services Inc., a for-profit organization which had been represented to the IRS as having no control whatsoever over tax exempt church funds. Mr. Spurlock's gold mine venture lost a considerable sum of money for Scientology. Mr. Spurlock also ordered Scientology management, specifically Marc Yager and Wendell Reynolds, to buy into oil wells in Oklahoma. Mr. Yager expressed to me that he had reservations about this venture, but complied anyway. This venture also lost quite a bit of money for Scientology. Additionally, Starkey and Miscavige bought into the oil venture (with their personal funds) in Oklahoma and were able to get much better deal for themselves due to putting Hubbard's and Scientology money into the venture.

8. Additional facts indicative of the management authority possessed and used by both Mr. Spurlock and Mr. Starkey over the entities involved in the Scott/Wollersheim consolidated lawsuits (i.e., Church of Scientology International ("CSI"), Church of


Scientology of California ("CSC"), Religious Technology Center ("RTC") and Church of Spiritual Technology ("CST") include the following:

A. Mr. Spurlock ordered that the original Scott suit be brought. He was involved in all of the major strategy meetings with attorneys concerning both the Scott and Wollersheim cases and, in fact, began planning the suit against David Mayo in 1982, shortly after Mayo opened his Church.

B. Mr. Starkey was also involved in all major meetings with attorneys concerning the Scott/Wollersheim cases. He made active decisions and ordered the attorneys as to actions they were or were not allowed to take in regards to these facts. In fact, Mr. Starkey and Mr. Spurlock accompanied an attorney for Scientology, Mr. Earle Cooley, one night on what was described by them as an attempt to visit the residence of Judge Mariana Pfaelzer Scientology after she had ruled against Scientology at a hearing. He went with Mr. Cooley in order to express their views to Judge Pfaelzer and persuade her to rule favorably for Scientology. Mr. Starkey and Mr. Spurlock stayed up all night that night working on drafting papers for the Scott/Wollersheim cases.

9. One of the reasons why Scientology elects to manage its far-flung enterprises in this manner is to try to sheild its management from legal process. Front men are designated to hold figure-head posts, while the real management power is held by others outside the corporate structure. To this end, Scientology will go to extreme lengths to conceal upper management personnel


from service of process, subpoenas and depositions. When alive L. Ron Hubbard was protected in this manner. In addition personnel have been driven around the city in covered vans to protect their identities and whereabouts. Moreover, when deemed necessary, personnel are sent out of this country in order to avoid legal process.

For example, in 1984 when the IRS was conducting criminal investigation against various Scientology entities, the personnel who had knowledge of criminal behavior as regards Scientology funds were hidden or sent away. Fran Harris, who was involved with Bridge Publications and Church and L. Ron Hubbard's funds, was sent to Denmark for a year. Mark Ingber, WDC member for Finance, was also sent to Denmark for a year. Wendel Reynolds, who had similar knowledge, was put away on the RPF in Happy Valley. Miscavige, Starkey and Spurlock took great precautions with their travels, offices and residences so that they could not be found or served. Miscavige has been known to actually rent clandestine quarters away from any Scientology facility, paid for with Scientology funds, simply so that he could hide out from process servers.

10. Both Mr. Spurlock and Mr. Starkey have been afforded this "protection" by Scientology. It is doubtful that either will be deposed if personal service of a subpoena upon them is deemed necessary prerequisite. Scientology will take all measure necessary to keep these men cloistered from view and immunize from service.

11. On the other hand, it is clear that when Scientology wants help from Mr. Spurlock and Mr. Starkey both men stand ready


to assist. Accordingly, whenever declarations are needed by Scientology in any of their lawsuits or other legal proceedings Scientology has no difficulty in obtaining the assistance of both Mr. Starkey and Mr. Spurlock. In this regard, Miscavige took off for over two months and lived in Portland, Oregon in order to oversee and direct the attorneys for Scientology on a daily basis during the entire trial in the case of Julie Christofferson Titchbourne, which she had brought against Scientology. Mr. Spurlock also spent most of his days in Portland during the trial. During the Wollersheim trial, Miscavige, Starkey and Spurlock supervised the attorneys representing CSC on a daily basis throughout the nearly three-month trial in Los Angeles. Miscavige, Starkey and Spurlock stay briefed on a daily basis on all legal matters of any consequence involving any Scientology entity. All papers filed by the Scientology entities involved in the consolidated Scott/Wollersheim cases had to be sent via Spurlock and Miscavige for authorization before they could be filed.

12. In addition, without revealing any privileged communications, I am able to state that both Mr. Spurlock and Mr. Starkey have been involved directly in the management of CSI, CSC, RTC and CST, and have participated in meetings in which decisions affecting these consolidated Scott/Wollersheim cases have been made. We have worked together in the past and I know that no major decision affecting these entities or these cases are made without their knowledge, participation and/or consent. Based upon all the information personally available to me, I am of the


opinion that both Mr. Starkey and Mr. Spurlock are managing agents of CSI, CSC, RTC and CST.

13 . I have reason to believe that documents which would normally reflect traditional criteria of the managing agent relationship between Scientology and Messrs. Spurlock and Starkey have been either destroyed or concealed by Scientology. For example, at Mr. Starkey's direction, I destroyed such information as it related to the involvement and control over Scientology by L. Ron Hubbard, Mr. Starkey and Mr. David Miscavige.

I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct.

Executed this 27th day of October 1988, in Dallas, Texas.

Vicki J. Aznaran