((My comments in double parentheses - Homer))
                                CD - 21
                            13 October 1994
                 Copyright (C) 1994 Stacy Brooks Young
       Redistribution rights granted for non commercial purposes.
non-profit religious
Case No. CV 91 6426 HLH (Tx)
SEPTEMBER 22, 1993; (2)
U.S.C. ' 1927, ETC.
Date: April 4, 1994
Time: 10:00 AM.
Courtroom: 7
     I, Stacy Brooks Young, declare as follows:
     1.  I am over the age of 18 years.
     2.  I have been retained as an expert consultant and expert witness
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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 California.  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 competently thereto.
     3.  This declaration is submitted in support of Defendant Dr.
Geertz's Opposition to CSI's Motion for Continuation of Confidentiality
Order Entered September 22, 1993, Opposition to CSI's Motion to Seal Re-
Created Versions of Plaintiff's Confidential Upper Level Scriptures, and
Opposition to CSI's Motion for Attorney's Fees, Costs and Sanctions
Under 29 U.S.C.  S 1927, Etc.
     4.  I was a Scientologist for nearly 15 years, from January 1975
until July 1989.  I was in the Guardian Office ("GO") and its successor
(a name change only), the Office of Special Affairs ("OSA"), for most of
that time.  I also worked in another part of Scientology called Author
Services, Inc.  ("ASI").
     5.  It is incredible that plaintiff CSI is still concerned about
maintaining any degree of confidentiality of Scientology's so-called
"upper level materials." The information contained in these documents
has been available any large public or university library for many
years.  attached as Exhibit 1 is a sampling of the many books and
newspaper and magazine articles in which these materials have been
published.  The fact is that these materials are no longer confidential.
They are already broadly publicly available.  For the Court to continue
to maintain their confidentiality" is somewhat like closing the barn
door after the cows have already escaped.
     6.  CSI's counsel accuses Mr.  Berry of being harrasive in his
defense of his client.  This is ludicrous.  I have personal knowledge
that Mr.  Berry has not intended to be harassive nor has he acted in a
harassive manner.  I have been advising him in this case as an expert on
Scientology practices, policies and language.  CSI cites Mr.  Berry's
use of certain Scientology words and phrases as an example of his
harassive tactics.  In fact, I advised Mr.  Berry that he would be much
more successful in communicating with Scientologists if he learned the
Scientology language and spoke it as much as possible when dealing with
Scientologists.  In addition, that he learned the Scientology definition
of words that are in common English usage but are defined differently by
L.  Ron Hubbard.  In the past, communications between Scientology and
opposing counsel would have been like two ships passing in the night.
How can it be harassive when someone goes to the trouble to learn an
extremely complex language just so that he can better communicate?  Or
has Scientology now decided that non- -Scientologists are not allowed to
use Scientology words?
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     7.  CSI cites two words used by Mr.  Berry in a letter as examples
of his abuse of the Scientology religion.  Yet the two words he used are
strictly administrative terms having nothing to do with religious
beliefs whatsoever.  "Dev-T" is a word that means "Developed Traffic,"
an administrative term for unnecessary or duplicative work.  "CSWP"
stands for "Completed Staff Work, please" This term is simply a request
for a full proposal.  There is nothing religious in either of these
     8.  Mr.  Lubell, an attorney for CSI, stated in his original motion
to strike or seal my expert declarations in this case that "If there
were such a thing as an 'expert' on Scientology scripture, such a
designation could only be made by the Church"; yet the truth is just the
opposite.  It is only someone who has been directly involved with
Scientology management and then leaves the cult, as I did, who can be
trusted to provide the Court with straightforward information about the
inner workings and practices of Scientology.  It is utterly impossible
for anyone who is still a Scientologist (and who therefore still
believes that their entire future depends upon remaining a
Scientologist) to tell the truth about Scientology.  The organization
would immediately punish anyone who did so.  In short, one can only tell
the truth after having made the decision no longer to adhere to the
policies of Scientology, which include protecting it at all costs and
never uttering a word of criticism or adverse testimony.
     9.  Contrary to the representations that have been made about my
motives in numerous declarations and motions filed in this litigation, I
agreed to assist Mr.  Berry in his defense of Dr.  Geertz because I
think it is crucial for outsiders to begin to understand what
Scientology really is, what motivates its members, how the leadership
views non- Scientologists and critics of Scientology (particularly
psychiatrists and psychologists such as Defendant Dr.  Uwe Geertz), how
Scientologists manipulate the courts for their own ends, and the cold-
bloodedness with which people like Steven Fishman are coerced into
parting with huge sums of money.
     10.  The Scientology attorneys claim that I am putting the
"religious beliefs" of Scientology on trial.  That is nonsense.  This is
the United States of America; people have the right to believe whatever
they want to and I have no desire to convince anyone to stop believing
in the Scientology philosophy.  It is the practices of this organization
that concern me, not the belief system.  Violations of civil and human
rights, to say nothing of common decency, are so rampant in this
organization that it is extremely difficult for an outsider to
comprehend why anyone would remain in such a group.
     11.  Indeed, this is precisely why the Scienntologists continue to
get away with such abuse.  Former members have such bizarre, outrageous
tales to tell that outsiders find their stories very difficult to
believe, and the Scientologists do everything they can to discredit the
former members as mercenaries, liars, thieves, lunatics and worse (as
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evidenced by the language that has been used by Scientoloqy leaders and
their attorneys to describe me during the course of this litigation).
The result is that while declaration after declaration has been filed
detailing horror stories of sleep deprivation, starvation, involuntary
incarceration, loss of consortium, child abuse, suicide, financial
crimes and more, Scientology has successfully convinced many courts that
the authors of such statements were nothing more than "embittered
apostates," as they have now described me.
     12.  The truth is much simpler: I am no longer under the influence
of the coercive and manipulative methods of Scientology and I can now
see how abusive the practices of this group are.  There are many people
who are still its psychological and emotional captives, and these people
are not only being victimized by the Scientology Sea Organization
command structure but are also perpetrating abuse on others, Including
children who cannot speak for themselves.  People are being held under
guard; people are being interrogated on the E-Meter for the slightest
infraction.  or the slightest hint of disaffection, women are being
coerced into aborting their unborn children; parents are being kept from
their children for weeks and even months at a time.  Scientology
registrars are coercing people to part with their life savings; they are
convincing people to turn over their credit cards; Sclentology leaders
are pouring money into the Sea Org coffers while staff in the local
organizations live in abject poverty.
     13.  In his declaration of February 28, 1994, Heber Jentzsch
objected to my reference to the dangerous methods of Black Dianetics;
yet methods of "reverse processing" are employed as control tactics
against Scientology staff members on a regular basis.  I have no doubt
that he himself has been the target of such methods.  Such methods
include brutal interrogations in which two or more people gang up on
someone (who has usually been deprived of sleep for days) in locked room
and scream abuses until the person confesses to anything they want him
or her to confess to; "overt/withhold" writeups in which the person is
forced to continue writing up "crimes," whether real or imagined, until
someone decides he or she has "come clean" and is allowed to stop;
"ethics conditions" in which one is not "upgraded" to the next condition
until one has satisfied the ethics officer or senior that one has "fully
confronted" one's criminality; group "musters" at which staff members
are publicly condemned for their "crimes" (this is reportedly a favorite
pastime of Miscavige at the high- security Hemet compound), denounced to
their peers and ordered to jump into a freezing lake as punishment.
     14.  Mr.  Jentzsch stated that both my husband and I have been on
the Rehabilitation Project Force, or RPF.  This is very true, and it is
where the most horrifying of the abuses takes place, out of sight of
anyone else, where staff members are stunned to discover that they
themselves are Fair Game for whatever punishment or coercive tactics
those in control of Scientology think should be meted out to them.
There is no recourse short of leaving Scientology; there is no way off
the RPF except to finish the program, and the product of the program is
a person who will be utterly, uncritically compliant with his or her
seniors without question.  Until that is achieved the person is not a
product" and must remain on the RPF.  I know that this is true.  I
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experienced it, and so did my husband.  So have many other people who
have already spoken out about this.  I note that there are many things I
stated in my declarations which have not been challenged by Mr.  Moxon,
Mr.  Jentzsch, Mr.  Miscavige, Mr.  Starkey or any of the other
Scientology leaders in their declarations.  This is because what I have
said is true, and they would be perjuring themselves to state otherwise.
They malign my character; they call me many names; but they do not
dispute the facts contained in my declarations.  I am "vile" and
"scurrilous" not because I am lying, but because I am telling the truth
to people outside of Scientology.
     15.  I note that there are many things I stated in my declarations
which have not been challenged by Mr.  Moxon, Mr.  Jentzsch, Mr.
Miscavige, Mr.  Starkey or any of the other Scientology leaders in their
declarations.  This is because what I have said is true, and they would
be perjuring themselves to state otherwise.  They malign my character;
they call me many names; but they do not dispute the facts contained in
my declarations.  I am "vile" and "scurrilous" not because I am lying,
but because I am telling the truth to people outside of Scientology.
     16.  Reference is made to the declarations filed by Mr.  Moxon, Mr.
Jentzsch, Mr.  Miscavige, Mr.  Starkey and the other Scientology
leaders.  They are telling what L.  Ron Hubbard called "acceptable
truths," and Mr.  Jentzsch and Mr.  Moxon are both veterans of this
tactic.  So am I; I used to write much of the material that was used to
discredit people.  Accordingly, I am very familiar with the process by
which these declarations were written.  These people would have been
intently searching through my declarations, looking for statements that
could easily be discredited.  Obviously they were not able to find very
many, based on what they have written.
     17.  Mr.  Jentzsch provides a good example of a Scientology tactic,
which is to divert attention off the actual point.  I stated in my
January 4 declaration that what found most shocking about Steven
Fishman's treatment by Scientology was that he was sold E-Meters even
though he could never qualify for auditing.  Mr.  Jentzsch never
explains why someone who would never be eligible for training or
processing would have been sold E-Meters.  Instead, he skirts the issue,
saying that "the various uses of E-meters by Scientology ministers is
hardly relevant to this Court"; yet in fact the uses of the E-Meter are
extremely relevant.  I repeat what I stated in my earlier declaration:
only people who are eligible for auditor training or solo auditing
(indeed, only people who are ministers or ministers-in-training) are
supposed to be sold E-Meters.  Fishman was eligible for neither; he
should never have been sold an E-Meter.
     18.  Mr.  Jentzsch then mischaracterizes what I wrote ln paragraph
62 of my January 4 declaration.  I never said, as he claims, that
Fishman was driven mad by reading Scientology materials.  On the
contrary, I stated, "There is little doubt that Fishman used his E-
Meters to 'audit' himself, an action that could easily drive him into a
psychotic break." Self auditing is known in Scientology as the sign of a
borderline psychotic.  To sell someone with a known history of
hypnotherapy an E-Meter so that they can self-audit is tantamount to
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driving them into a psychotic break.  Any technically trained
Scientologist can confirm this (although no one who is still inside
would be allowed to do so).
     19.  Mr.  Jentzsch states that the plaintiff "can produce 1,500
staff members of plaintiff [CSI] who are more competent than the Youngs
and could testify that they are wrong...." Of course all 1,500 staff
members of CSI will testify that I am wrong.  If they are ordered to do
so, they have no choice It doesn't matter what they personally believe;
if they do otherwise than denounce me for what I am revealing about
Scientology, they will be declared Suppressive and expelled, or sent to
the RPF to be made more compliant.  Indeed, it has been my experience
that the current Scientology leaders will stop at nothing to protect
Scientology from anyone they perceive as a threat.
     20.  I am still recovering from my experience in Scientology.  I am
still learning about how groups like Scientology use coercive methods to
control people like myself, my husband and many other individuals who
are still under its spell.  I believe that all Scientologists, even the
current leadership, are the victims of Hubbard's version of mind
control, just as I was.  These people, including the Scientology
attorneys and paralegals who deal with the courts, have no idea how much
they are under the coercive influence of Scientology and its leaders.
They are utterly fanatical about their dedication, and determined to
protect Scientology from "enemies" like my husband and me.
     21.  I have no wish to turn this litigation into a personal "war"
with Scientology, as Mr.  Jentzsch suggested in his declaration.  It is
Scientology, by its refusal to admit the truth of its actions, that
invariably turns any litigation into a war.
     22.  There have been a number of people before me who have pulicaly
told the truth about Scientology.  and nearly every one of them has been
threatened, frightened, coerced or bought off into silence.  I have
spoken to many of these people, and many others who are too frightened
to come forward publicly, and I can assure you that the information I
have been providing to this Court can, be corroborated by many other
former Scientologists.  These people are not "embittered apostates."
They are decent human beings who regret having wasted years of their
lives in an organization which they now realize was coercive and
destructive of thelr civil and human rights.  They have friends who are
still captive, as do I.  They want to do whatever they can to help those
who are still in this group, as do I.  I feel it is my duty to provide
the truth to the Court as long as the Court finds it relevant.
     23.  I also feel it is imperative upon the Court not to seal what I
and other Scientology experts like me have to say.  There are citizens
of the United States, right now, whose civil rights are being trampled
upon and who have no recourse to the laws of this country.  This is
happening right in Los Angeles and many other cities.  There is a
compound (called "the base" or "Int") near Hemet, California, in
Riverside County, where security guards keep watch on the staff members
to make sure they do not leave the compound.  If these people violate
the Scientology rules they risk being refused food and shelter.  Others
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are being involuntarily imprisoned.  The women at this compound are not
allowed to get pregnant and if they do, they are coerced into getting
abortions at the Riverside Planned Parenthood Clinic.  Church funds are
being spent to build exercise rooms and sports fields for the exclusive
use of celebrities like Tom Cruise and Nicole Kidman, using slave labor
from the RPF at $5.00 a week.  These laborers are kept up for days at a
time at the whim of Scientology leaders like David Miscavige.  Children
are being kept at camps, away from their parents for weeks at a time.
Parents who ask to see their children more than this are frowned upon;
children are considered "distractions" to production.  Mr.  Jentzsch
knows this: he and his wife Karen were coerced by David Miscavige into
being divorced because Karen wanted Heber to spend more time with their
son, Alexander.  Miscavige viewed Alexander as a distraction to Heber's
     24.  My expert declarations have nothing to do with religious
beliefs.  They have to do with serious violations of civil rights of
U.S.  citizens.  This is not the view of an "embittered apostate; this
is the view of a citizen of this country who feels that all Americans
have the right to life, liberty and the pursuit of happiness, no matter
what their religious beliefs.  If the Court were to silence voices like
mine, as the Scientologists would like the Court to do, there would be
no one to speak for the people who are being victimized and destroyed by
this group, people like Fishman and Dr.Geertz whose only crime has been
to tell the truth to the best of their knowledge.
     I declare under penalty of perjury under the laws of the United
States of America and the State of California that the foregoing is true
and correct.  Executed in Los Angeles, California, this day of March,
(Signed -Signature) Stacy Brooks Young