I, Vicki Aznaran, hereby declare and state:

1. I am over 18 years of age and a resident of the State of Texas. I have personal knowledge of the facts set forth herein and, if called as a witness, I could and would competently testify thereto.

2. There are many factors surrounding the releases attached as Exhibits A and B to defendants' Motion for Summary Judgement which the defendants neglect to mention. Firstly these "releases" appear to be much longer than the one I signed. My husband and I had asked for copies of what we signed at the time and were told that we would get copies later. We never got these. After we filed suit, the releases attached to defendants motion for summary judgement were brought forth by the Scientologists. The releases which were signed (which do not appear to be these) were signed under extreme duress. I had been incarcerated in the desert for the last 6 weeks, under guard, locked up, and not allowed adequate sleep and eating inadequate food. I was physically ill.

A. I was not represented by counsel. Contrary to the affidavit submitted by defendants I was not availed of any counsel of my own. The only counsel present were the cult's attorneys both of whom I knew were strictly looking after the interests of the Scientology cult which they are paid very well to do.

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B. Shortly after my escape from Happy Valley I had called my sister in Texas because I was afraid of what the Scientologists might do to me and/or my husband. I had wanted her to know that I was planning to come home and that if she didn't hear from me to please call the law enforcement authorities. There were no releases in question at that time and the matter of legal counsel had not even come up.

3. There is the matter of "Fair Game" which is known to anyone who has been in Scientology for any length of time. If you do not conform to the power hierarchy in Scientology you can and will be considered to be Fair Game which per Scientology policy means that you can be lied to, cheated, stolen from, sued, harassed and anything else they deem necessary to get you to conform to their wishes. My husband and I had no desire to be declared Fair Game. Had we demanded our own counsel or not signed what we were told to sign or refused to undergo the extensive security checking they demanded we would have been declared "suppressive persons and thus become fair game". We decided that we would co-operate with whatever was asked of us so that we could get away without being declared "fair game".

C. Since I left Scientology I have been monitored and harassed. This became increasingly intense when I was asked to testify for Joe Yanny I received threatening phone calls from cult

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attorneys and cult members came to my home and place of business to intimidate me and attempt to coerce me not to testify for Joe Yanny. Since the filing of my lawsuit I have been declared suppressive and thus fair game. Private investigators follow and harass me and my family. My sister has been sued as well as myself and my husband. The cult has interfered with our business in an attempt to cause us to lose business. They have run phoney credit checks on us through a Ford dealership in Sacramento California. They have told the postal authorities that we were under investigation for drugs.

4. Additionally, I was told by Mr. John Peterson, one of the Scientology Cult's attorneys for many years, that the releases that the Scientologists had people sign were not worth the paper they were written upon. He said that one could never sign away their right to sue nor could they refuse to testify against Scientology should they be subpoenaed before a court of law. Mr. Peterson said the value of the releases was that once someone had signed them, that person would think that he could not bring suit or testify against Scientology and that would act as a deterrent. One of the major purposes of these releases is to prevent anyone from testifying hostilely against Scientology to the U.S. government. Scientologists are trained to believe that the U.S. government is involved in a conspiracy to wipe them out. They also have a legitimate fear of being prosecuted for their criminal activity such as tax fraud, tax evasion, and obstruction

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of justice.

5. The Scientologists also neglect to mention that they held all of my personal belongings and did not release them to me until I had signed the release. I know of others who did not sign releases and their pets were given away and their belongings destroyed. I did not wish for that to happen to me. It was not much but it was all I had to show for the fifteen years of exploitation by the cult.

6. I believe that there are other cases brought against the Scientology cult in which releases such as these were held to be invalid. We have not had adequate discovery into this matter to learn all the facts and need some more time in order to do that. Defendants have continuously refused to comply with my prior attorneys discovery requests although we have cooperated in their extensive, lengthy discovery with many days of depositions including depositions of our families.

7. These releases were not negotiated at all nor were they mutual in that we received nothing in return. In regard to defendants' Exhibit H, a loan to be paid back with interest is not recompense. We did not request any loan and were told that we were getting it to keep us "out of enemy hands". In regard to defendant's Exhibit C they paid for personal belongings which were destroyed in a fire caused by the negligence of management,

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overcrowded conditions and a lack of adherence to fire codes is merely putting back what was already there. This vas being repaid by the insurance company regardless of any releases. The fact of Richard's $387.37 in wages that were owed would have been paid as his wages. These were not in question and nothing about them was negotiated. The reason the cult wished to indemnify me in any lawsuit I might be named in or subpoenaed in was to keep me from testifying hostilely in any of the litigation against them or to government agencies. The horse was purchased for less than we had put into her. We made no profit from that and did not even wish to sell the horse but the Scientologists wanted us out of California quickly so we would not be served with any subpoenas in the cases that were going on against them at that time. That was why they offered to purchase the horse.

8. I was forced to assign myself to the RPF. I was told that if I did not write an issue assigning myself that David Miscavige would write it and it would be far far worse than anything I could ever imagine. In other words he would write anything he wished to and make it broadly known. One example of this is a case where a girl refused to conform as ordered to and the Scientologists wrote an issue stating that the girl was a lesbian and published it to all of her friends. She escaped them and sued for libel and slander. It turned out that it was completely false and the Scientologists paid her to drop her suit and be quiet. This was in the San Francisco area in 1982. I was informed of this by the

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cult member in the Office of Special Affairs who handled the lawsuit.

9. I did not decide on March 31, 1987 that I should leave the RPF. I had attempted to escape two weeks before that but had been caught by guards. I had expressed my desire to get away to several people on different occasions.

10. During the time I was in a motel in Hemet California, after leaving the RPF and up until any releases were signed, my husband and I were being security checked daily (an intense and lengthy form of interrogation) and we were being watched by guards. We had hardly any money, less than fifty dollars and we were extremely afraid of being declared fair game if we did not co-operate. I was in a very bad physical and mental state and would have signed anything in order to get away. The only thing I was grateful for was getting away.

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

Executed this 15th day of January, 1989, at Dallas, Texas.

[Signed]
Vicki J. Aznaran

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