((My comments in double parentheses - Homer))
                       ANDRE TABAYOYON AFFIDAVIT
                                CD - 13
                             19 August 1994
                   Copyright (C) 1994 Andre Tabayoyon
       Redistribution rights granted for non commercial purposes.
GRAHAM E. BERRY, State Bar No. 128503
GORDON J. CALHOUN, State Bar No. 84509
221 N. Figueroa Street, Suite 1200
Los Angeles, California 90012
Telephone: (213) 250-1800
Attorneys for Defendants
                      UNITED STATES DISTRICT COURT
CHURCH OF SCIENTOLOGY                  Case No. CV 91 6426 HLH (Tx)
non-profit religious                   DECLARATION OF ANDRE
organization,                          TABAYOYON RE: MOTION FOR
                                       Date:   APRIL 4, 1994
VS.                                    Time:    10:00 a.m.
                                       Courtroom: 7
     I, ANDRE TABAYOYON, declare as follows:
     1. I am over the age of 18 years.
     2. I have been retained as an expert consultant and expert witness
by Dr.  Geertz's counsel in the case captioned Church cf Scientology
International v. Steven Fishman and Uwe Geertz, No.  CV 91-6426-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 on 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.  Uwe
Geertz's motion for costs, attorneys' fees and sanctions.
     4. In preparation for this declaration, inter alia, read the
declarations submitted by David Miscavige ("Miscavige") , Marc Yeager,
Ray Mithoff, Guillaume LeServe and Norman Starkey in an effort to
persuade this Court that CSI has complied with the orders of the
Magistrate Judge and this Court to attend depositions.
     5. Since being designated as an expert witness herein, I have
become aware of the presence of myself being under surveillance.  On a
trip to Arizona I was followed by a van and a car.  In Mesa, Arizona I
was followed to breakfast and the person was even aware that we knew he
was watching us.  While in Newport Beach we were followed to and from
Mr. Berry's office daily.  I am currently in my home and there is a blue
late model pontiac waiting to follow me wherever I go.
     6. Before I became a Scientologist, I enlisted in the United States
Marine Corps.  I served one tour of duty in Vietnam.  I was in the
infantry and assigned as a scout to secure sites, often behind enemy
lines, from which Marine snipers would eliminate targets using specially
constructed sniper rifles.  It was also my responsibility to get the
highly trained and therefore very valuable snipers back safely to allied
lines.  Because of the high likelihood that I would be operating for
extended periods of time behind enemy lines, I received escape and
evasion training both in the Philippines and in Vietnam.  In addition to
escape and evasion training, I also received instruction on how to
resist anticipated brainwashing and coercive persuasion techniques
likely to be employed if I was captured alive.  Because of the covert
nature of the operations to which I was assigned, I was also trained how
even the most innocent utensils could be used to end my own life and
thereby prevent any captors from extracting information that might
compromise my mission or my country.  My missions required that I kill a
number of Vietnamese, including some at close range, some of whom died
in my arms.  These events left a lasting and negative impression on me.
     7. After returning from Vietnam, I was plagued by nightmares and
other disabling memories of my experiences as a front line combat
fighter.  When I returned post traumatic stress syndrome was not well
understood.  The military and veteran's hospitals provided almost no
assistance to me or a number of my companions who suffered from similar
problems.  I was determined not to descend into the depths of
degradation that followed from the abuse of narcotics and other drugs,
whether legal or illegal.
     8. While I was in this unsettled state, I was recruited into
Scientology.  The attraction was, in part, the promise that Scientology
would provide me with the means to deal with these disturbing memories
and nightmares.
     9. Various forms of coercive persuasion are used in all areas of
Scientology.  A working term in Scientology is registration ("reg")
cycle.  During a reg cycle, parishioners are coercively persuaded to do
something which a senior Scientologist believes will be good for
Scientology.  In my 21 years of membership in Scientology, I personally
observed how auditors and others identify a person's "hot button."  I
saw how auditors used many individual's hot buttons in the various types
of interviews (ethics, chaplin, registration, counseling, etc.) to
coerce the parishioner into donating money, doing the next service,
joining the Sea Org, going to the RPF and agreeing to forego spending
time with their children and families in order to devote greater time
and effort to the good of Scientology.
     10.  After joining Scientology, I became a member of the Sea
Organization ("Sea Org").  A Hubbard Communications Office policy letter
defines the Sea Org as:  "The elite religious fellowship within the
Church of scientology.  The Sea Org is not incorporated and is not part
of any corporation.  Its membership is involved in Churn management and
the delivery of the higher level services of the Church."  Finance
Series 11R.  Exhibit A.
     11.  The indoctrination I received in the Sea Organization was
extensive.  It fully acquainted me with the coercive methods that
Scientology uses on its staff and public.  My training included the
following courses which had the content as indicated below:
     (a) FLAG EXECUTIVE BRIEFING COURSE - All the policy ever written by
Hubbard about the running, debugging, and if needed, the creation of a
complete organization using thought reform ideas and practices in
conjunction with coercive persuasion on the staff and public.
     (b) ORG EXECUTIVE COURSE - All the policy ever written by Hubbard
about the running, debugging, and if needed, the creation of a complete
organization using thought reform ideas and practices in conjunction
with coercive persuasion on the staff and public.
     (c) SEA ORG OFFICER TRAINING - This course covered all of the Flag
Orders, Flag Ship Orders, Central Bureau Orders, mission school tech and
included all of the policy written by Hubbard about creating, running
and debugging a complete Scientology organization using thought reform
concepts and practices in conjunction with coercive persuasion on both
staff and public Scientologists.
the above course(s) how to use thought reform processes to make persons
amenable to persuasion.
to administer various thought, ideological and social reform procedures
to reorient now compliant subjects of thought reform- to accept
Scientology goals as articulated by Hubbard and/or Miscavige.
taught me how to recognize misapplication of thought, ideological and
social reform procedures so as to maximize the effect that coercive
persuasion had on subjects under my supervision.
taught how to use thought reform procedures to change the most
fundamental aspects of a subject's personality and exact a commitment
from the subject to further Scientology's goal of clearing planet Earth.
to use thought reform to coerce subjects into confessing their crimes
and sins against Scientology as a step towards their "rehabilitation" as
dedicated Scientologists.
     (k) ROLL BACK TRAINING - I received training on how to trace
rumors, statements of disaffection or anti-Scientology thought back to
its source so that it could be obliterated and sources of disaffection
     (l) BLACK PR RUNDOWN TRAINING - This training was to teach you how
to find out who is spreading negative information and to fully handle
him with coercive mind practices.  I learned how to ferret out negative
information about Scientology; once found out, those who are guilty
become targets for internal "Fair Game" tactics such as the RPF's RPF.
RPF or general mental abuse.
     (m) TRUTH RUNDOWN TRAINING - I learned how to use thought reform to
correct improper conduct by persons spreading rumors or black PR about
     (n) INTROSPECTION TRAINING - I learned Scientological techniques to
reach persons who had suffered psychotic breaks during the thought
reform process.  Persons in this condition were not capable of relating
to the real world.  For the most part, introspection training focused on
limiting the stimuli to which the victims were exposed with the hope
that over time they would recover.
     (o) FALSE PURPOSE RUNDOWN TRAINING - These are a whole series of
thought reform practices used to change people's way of thinking.  I
learned how to supervise auditors reforming thoughts of people, while on
the RPF.
     (p) FALSE DATA STRIPPING TRAINING - This is a technique to ferret
out and remove out tech (Non-orthodox Scientology) ideas and to replace
the out tech ideas with Hubbard's information.
     (q) EDUCATION PROCESS KTL -This is a major training ordeal where
the person is completely re indoctrinated in the basic grammar and use
of the English language to communicate Scientological principles
concisely and correctly.
     (r) TOO GRUESOME TRAINING - This training teaches a supervisor how
to instill complete terror and abject fear in subordinates so that the
subordinates will comply with the supervisor's orders without question.
I have been a member of various Churches of Scientology for 21 years
from 1971 to 1992.  During this time, I received extensive and intensive
training as a Scientologist.
     13.  I was also a member of the Sea Organization ("Sea Org") ,
which I joined in 1972.  The Sea Org is a fraternal organization of
Scientologists zealously dedicated to the protection and advancement of
Scientology and its leaders.  Sea Org members are expected to get their
assignments completed regardless of the obstacles.  The staff of CSI,
RTC and all Scientology organizations above Class IV Orgs are Sea Org
     14.  Hubbard established the Sea Org as an international solution
to periodic insolvencies which had afflicted various Scientology
organizations during the first decades of Scientology's existence.
     15.  Within Scientology, Sea Org members have unquestioned
authority over the affairs of Scientology organizations.  This authority
is exercised in a number of ways.  First, Sea Org members can be sent
into any Scientology Organization, or business owned by a Scientologist,
organization or a mission.  Historically, Guardian Office Missions and
Sea Org Missions were one and the same.  When Sea Org members are on a
mission, they have full ethics powers to take whatever steps are
necessary for the greater good of Scientology.  CMO Int Messengers
(commodores messenger organization International Messengers) are always
on Mission so they had full authority to issue whatever orders they deem
appropriate.  CMO Int Messengers had the full authority of Hubbard when
he was alive.  Hubbard was then Commodore of the Sea Org.  Now they have
the full authority of Miscavige.
     16.  The Sea Organization is to Scientology what the Communist
Party was to Soviet Russia and the Gestapo was to Nazi Germany.  Indeed,
Sea Org members were not allowed to read communist doctrines, or
magazines and books about mind control and thought reform because of the
similarity to the Sea Org life that these documents present.
     17.  I signed the standard Sea Org contract requiring me to serve
the Sea Org for one billion years.  This I would do by serving the Sea
Org in every one of my future lives with 21 year vacations at the
commencement of each life, so that the contract would not be void for
incapacity due to youthfulness or infancy.
     18.  As a Sea Org member, I received thousands of hours of training
in basic Sea Org policy.  In 1977 I was assigned to the Rehabilitation
Project Force for 18 months.  In 1980 I was assigned to the RPF for
another 2 1/2 years.  In 1987 I was again assigned to the RPF for
another 18 months.  Accordingly, I spent approx. six years in total on
the RPF.  During these six years I also spent time --19 full days-- on
the RPF's RPF.  The RPF's RPF is designed to totally destroy any
individual determinism to not want to do the RPF.  RPF is a totally
involuntary type gulag or concentration camp.  In order to get out, and
stay out, you must prove that you have altered the ideals, morals,
social and emotional and attitudinal values of another member of the RPF
of a long duration as evidenced by the physical actions and motions of
the person so altered.  One must also prepare written evidence in the
form of success stories of how wonderful and voluntary the RPF was.
During my six years in the RPF, I spent five hours a day studying and
receiving instruction in Scientological matters.  During the fifteen
years I spent with the Sea Org, when I was not on RPF, I spent two and a
half hours a day studying and receiving instruction in Scientological
matters.  Applying simple math, I estimate conservatively that I
received over 28,000 hours of Scientology study and Scientology
instruction.  My exposure to Scientology thought reform processes was
enhanced by other processes to which all Sea Org members are exposed.
These included:  (1) indoctrination at daily musters; (2) briefings; (3)
missions; (4) Scientology justice actions; (5) crusades; (6) security or
sec checking; and (7) auditing.  Auditing is the central practice of
Scientology.  It involves the E Meter which is a simple
electrogalvanometer similar to, but not the same as, a lie detector.
One holds two tin cans attached to the E meter and goes into a hypnotic
state at the command of the auditor.  These hypnotic states include
those called reverie and revivification.
     19.  I also studied and received instruction about Scientology
Policy, and Sea Org policy called Flag Orders.  Information which
appeared in green printing on white paper and is called Hubbard
Communications Office Policy Letters ("HCO PLs").  I also studied and
received instruction about Scientology Technical Policy.  This
information appeared in red printing on white paper and is called
Hubbard Communications Office Bulletins ("HCOBs.")  I also spent
hundreds of hours listening to lectures taped by Hubbard.  These tapes
included the Flag Executive Briefing Course tapes, the OEC tapes, the
Human Evaluation tapes and the Establishment Officer tapes to name a
     20.  During my 21 years as a Scientologist, I also had many
occasions to see how these Scientology policies were applied in many
different contexts.  The Hubbard Technology, often called Tech, was used
to supposedly help people.  It was also used coercively to control the
behavior of people and to punish them for real or imagined
transgressions against Scientology.
     21.  During my tenure with the Sea Org, I held many posts.  The
various posts or positions I held during my association with Scientology
     a. Commanding Officer, Master at Arms;
     b. Missionary Unit, Commanding Officer;
     C. Executive Director, Portland Crusade;
     d. D/Executive Director, Los Angeles Crusade;
     e. L. Ron Hubbard's Butler;
     f. Executive Establishment Officer;
     g. RPF Bosun WUS, Childrens RPF Bosun
     h. LRH Spaces Set Up Mission 2nd;
     i. LRH Studio Construction Mission In Charge;
     J. LRH Renovations Mission In Charge;
     k. Utilities Installation Officer;
     l. Registrar;
     M. Sea Org Recruiter;
     n. Sea Org Ethics Officer;
     0. Sea Org Officer;
     P. Missionary;
     q. Security Mission In Charge;
     r. Berthing Security Watch, Hemet (Rover);
     S. RPF Tech In Charge;
     t. RPF Case Supervisor;
     U. RPF Section Leader;
     V. RPF Member;
     W. RPF Qualifications In Charge; and
     X. Estates Project Force Mission In Charge.
     While I was on various posts at Gold, near Hemet California, I was
also responsible for the following construction projects.
     a. Constructing a full scale replica of a clipper ship complete
with sauna and jacuzzi.  This was in the desert;
     b. Construction of kitchens and dining facilities in all the office
facilities at the Hemet base;
     c. A 20 Or 48 microphone battery lecture recording room;
     d. An orchestra size music recording studio;
     e. A film studio;
     f. A complete 32 seat theater;
     g. A complete film editing facility;
     h. A complete sound editing facility;
     i. A complete sound to film facility;
     j. Two voice over studios;
     k. A complete management office facility for CMOI;
     l. A complete audio facility which had four individual recording
booths and three lecture mixing studios;
     m. A 60' x 150' file archives facility;
     n. A 65' x 165' tapes archives facility;
     o. a 150' x 350' three story manufacturing facility;
     p. A dining facility that could accommodate 1,100 people for a
minimum of three sittings per day;
     q. A 200' x 500' construction and maintenance facility which houses
the planning and buildings areas;
     r. A complete apartment complex for celebrities;
     s. A complete office facility for Miscavige;
     t. A complete lounge facility for Miscavige;
     u. A complete dressing room for Miscavige;
     v. A complete sound room for Miscavige;
     w. A complete exercise room for Miscavige;
     x. A complete security lighting system for the perimeter of the
Hemet base;
     y. A complete deep well pump which provides 800 gallons per minute
to a 16" pipe supply system for the entire Hemet base;
     z. A 1,000,000 gallon reservoir;
     aa.  A 1.8 mile exercise course;
     ab.  A nine hole golf course.
     ac.  Several miles of paved roads.
     ad.  Underground high voltage (12,500 volts) System
     ae.  An emergency generation station with 750 KW or power for
indefinite time.
     af.  A complete sewer system with 2 evaporation ponds to handle
4500 people.
     ag.  A 115 million gallon lake.
     ah.  A tennis court for Celebs and Miscavige
     ai.  Berthing facility for children at the Happy valley base.
     aj.  A large well for Happy Valley facility.
     23.  In these various Scientology posts, I observed how the inner
most parts of Scientology worked.  I observed, participated in and was
victimized by coercive and manipulative thought control processes
designed to shape the thinking of the individuals upon whom these
procedures were imposed.  These practices are particularly prevalent in
the Rehabilitation Project Force ("RPF") , a brainwashing and penal
operation very similar to what I had been trained to expect from the
Viet Cong, North Vietnamese and Red Chinese during my tour of duty in
     24.  I knew L. Ron Hubbard ("Hubbard") personally.  I worked
directly for Hubbard, the founder of the Scientology belief system.
Hubbard was Miscavige's predecessor as head of Scientology.
     25.  I worked personally with Hubbard on the ship called the
Apollo, from 1971-73.  I personally observed Hubbard running all aspects
of Scientology and Sea Org and Guardian Office ("GO") networks.  Indeed,
at the time I believed Hubbard has saved my life.  I had been
"overboarded" or thrown aboard.  Hubbard then ordered that I be pulled
out.  Thereafter I believed Hubbard had saved my life and I became very
dedicated to both him and Scientology.  I served as both steward and
butler for Hubbard.  Accordingly, I was often alone with him -- even
when he was self injecting himself in the arm with a needle and
solution.  This he did frequently.  I would also lay out the pills he
took from 10 different numbered bottles.
     26.  I know Miscavige.  I have also worked directly for him for
many years.  Miscavige is a second generation Scientologist.  He was
born into Scientology, a high school drop out and became one of
Hubbard's Commodores Messengers as a teenager.  In this capacity, I have
been informed and believe that he was responsible for many multi-million
dollar illegal international currency transfers.  He did this as an
innocent looking young courier.  Miscavige has never known of a life
outside of Scientology.  'He is as close to a 'Rondroid' (L.R.  Hubbard
droid) as it is possible to be.  He rules Scientology like David Koresh
ruled Waco and the Branch Davidians.  He endorses Hubbard's goal of
Scientology taking over the entire planet including all heads of
government and news media.  See Exhibit____.  Hubbard said "take all of
the people, put them in Scientology and have them run under the
processes of Scientology."  Hubbard's plan is for Scientology to
interface with planet earth for one person to be in charge and for the
whole planet to be under a Scientology seven Division org board.
     27.  Miscavige is now the 'ecclesiastical' head of Scientology.  He
is commander of the Scientology Sea Organization ("Sea Org").  He is
also Chairman of The Board ("COB") of the Religious Technology Center
     28.  In 1991 I had to prepare the base so that it could be defended
against the possibility of being taken over by the authorities in a time
of crisis.  There are approx. 750 people at the base.  I was in charge
of a project designing the base security system, the perimeter fence,
the ultra razor barriers, the lighting of the perimeter fence, the
electronic monitors, the concealed microphones, the ground sensors, the
motion sensors and hidden cameras which were installed and all over the
area -- even outside the base.
     29.  Church monies were used to purchase semi-automatic assault
rifles (HK 91 assault rifles capable of firing 300-350 rounds of
ammunition a minute, 45 caliber pistols, .380 automatic weapons and
twelve gauge shotguns were stockpiled.  These weapons were not
registered.  Church monies were also used to buy the ammunition.
     30.  Church monies were also used to purchase a large amount of
pounds of gunpowder for the construction of various types of explosive
devices to be used in the defense of the base.
     31.  The motorcycle guards were trained to carry loaded cocked 45
caliber pistols.  The eagle scout, mounted high above the base, was
trained to carry a high powered rifle with a telescopic scope.  There is
also a 1,000 millimeter telescope up with 'eagle'.
     32.  I developed three classifications of intruder and established
the level of deadly force to use for each.  In addition to firearms, the
guards were taught how to effectively wield little batons.  The basic
things like striking to the center of the heart, the center of the solar
plex and then to the side of the head, etc.
     33.  At church expense, I trained the security guards and other
base personnel in the use of these weapons and explosives.  I also
trained them in the close quarter use of fatal force.  We built a combat
range for training purposes and I instructed Scientologists on various
ways of shooting people.  I also trained them in night vision and ambush
techniques.  We used a ravine that was a natural round shield so the
noise would not cause any noisy inquiries.
     34.  During the more than two decades of experience I had in
Scientology, I observed on many occasions the Hubbard Tech being used as
intended to assist persons to come to grips with themselves and events,
persons and things around them.  However, I also observed the Hubbard
Tech being deliberately misused to punish Scientologists who were out of
favor with either Hubbard or Miscavige.  When the Hubbard Tech is
deliberately misused to cause harm, the practice is called Black
Dianetics or Reverse Processing.  It is my opinion that Fishman was the
victim of Black Dianetics and was only saved, by the intervention of Dr.
Geertz, from an imminent suicidal incident.  The basis of my opinion in
this regard is as follows:
     (a) Fishman was not a Scientology minister or minister in training
yet he was sold E Meters;
     (b) Fishman was an illegal p.c.  (preclear) because of his past
psychiatric counselling;
     (c) Fishman was sold Scientology materials such as the whole track
tapes, the Philadelphia tapes, the history of man book, auditing
materials and how to use the E Meter book.
     This was the application of Black Dianetics because:
     (a) Fishman was not properly trained in the use of the E meter;
     (b) My experience as an RPF case supervisor in handling cases such
as Fishman leads me to the opinion that Fishman was being encouraged to
use the tech on himself rather than under the supervision of supervisors
and auditors.  This would, in MY opinion, only lead to disastrous and/or
suicidal consequences.  Indeed, L. Ron Hubbard in 'Some Notes on Black
Dianetics' states "a person can drive himself mad on Dianetics without
any trouble" ...  "with Black Dianetics you could tailor make any kind
of insanity you want to.  The person might not manifest this the next
day, maybe not for thirty days.  Maybe three months later he is walking
down the street and feeling a little bit tired when somebody honks just
right or something of the sort, all of a sudden he goes crazy and there
he is -- insane!  It's a wonderfully smooth way of committing murder."
Emphasis added.  Exhibit.
     35.  My observations were direct and personal.  I am a highly
trained RPF auditor.  When I had responsibilities for overseeing how the
Scientology auditing technology is applied to cases of Scientologists
assigned to the RPF, I received orders directly from Miscavige, Marc
Yeager, Ray Mithoff, Sandi Wilhere and Hansuli Stalli, and others, to
misuse the Hubbard Tech to create extreme mental and emotional distress
and insanity in persons I was instructed to 'security or sec check'.  We
used the Hubbard Tech, including security checking on the E-Meter, in
conjunction with well used coercive mind control techniques of sleep
deprivation, starvation, dehydration and denial of decent
accommodations.  As an example of the appalling conditions to which
RPFers are sometimes exposed, on one occasion when I was on RPF, my
sleeping facility was a slab inside the vault of the morgue of the old
Cedars Sinai Hospital.  While on the RPF at Gold, I also occupied the
chicken coop dormitory.  This was an old chicken coop which still
smelled of chicken coop droppings.  However, it was not only RPFers who
were deprived of adequate food and sleep.  At Gold, hundreds of Sea Org
members would be deprived of adequate sleep and put on a diet of rice
and beans sometimes for six weeks at a time-and their weekly pay of
approximately S30.00 would be cut in half.  This would be punishment for
lower ethics conditions such as poor production.  However, when this
occurred, David Miscavige would still eat his bacon, eggs, sandwiches
and steak dinners.
     36.  The response of human beings to these conditions is somewhat
predictable.  I saw many people undergo psychotic breaks.  By psychotic
breaks I mean being reduced to incoherent babbling, stripping off
clothes, crawling around on the ground, banging heads, limbs and other
body parts against furniture and walls, barking, losing all sense of
one's identity and intense and persistent suicidal ideation.  This is
what Scientology calls the PTS type III phenomena.  There is a policy
which describes this.  Exh O. I have seen many PTS type III cases.  It
is my opinion that Fishman has been deliberately driven PTS type III by
Black Dianetics and/or reverse processing.
     37.  I participated in deliberately inflicting this process on
others in Scientology.  I was a Case Supervisor on the RPF.  This means
that I saw the auditing folders of all the persons assigned to the RPF
while I had this responsibility.  I saw that the Tech was regularly
misapplied for harmful purposes.  The case notes prepared by auditors
during auditing sessions were altered or deleted by senior executives.
This prevented a subsequent auditor from properly assessing and handling
the individual.  It is like flying blind without instruments.  The
potential for doing something seriously harmful is therefore greatly
     38.  I was advised by Richard Aznaran, Sinar Parman and Annie
Breeder that Hubbard was an unhandled PTS III when he died.  According
to Sinar Parman, Hubbard was a psychopathic insane person screaming
about BT's and clusters at the top of his lungs.
     39.  I was also ordered to audit a number of persons, including
Stacy Young, while they were on the RPF.  The files I was provided
relating to Stacy showed that I would be auditing a stable, well
adjusted person.  When Stacy was led into the auditing room, I was
confronted with a disheveled, irrational and incoherent person whom I
hardly recognized.  Stacy spent the first half hour or so of the session
babbling and crying hysterically.  Her folder had obviously been altered
to maximize the likelihood that further auditing would harm her.
     40.  What I know from training and experience to be Black Dianetics
and reverse processing were also inflicted on me.  I survived the
processing without experiencing a psychotic break.  I believe the
extensive survival training I received as a Marine is allowed me to
escape the extreme degradation and self-degradation I saw others
     41.  I also observed a number of individuals go crazy when exposed
to the Hubbard Tech even absent malicious intent on the part of the
persons applying the Tech.  For example, I saw John Colletto go
psychotic after he was exposed to the OT III level (Operating thetan
level III) materials.  He got a pistol.  In my presence, he shot his
wife in the head.  She died instantly.  Then John ran a short distance
before turning the pistol on himself and committing suicide.  Moreover,
John Travolta's auditor told me of two occasions on which John Travolta
went into deep depression after auditing and therefore suffered a
psychotic break.
     42.  I personally observed a number of other Scientologists go
crazy and commit suicide as a result of the auditing processes.  Bob
Shaffner and I were serving sentences on the RPF's RPF together.
Although inmates are not allowed to speak to each other while on the
RPF's RPF, Bob made it a point to tell me two or three times daily that
he was going to kill himself because of what he experienced during RPF's
RPF & OT III auditing.  One day we were working on dangerous machinery
and Bob suddenly thrust his finger into the machine which cut his finger
off.  Scientology management was fully aware of Bob's condition.  He was
placed on the risk of suicide list.  Because he was suicidal, his
berthing quarters while in the RPF were limited to first floor
facilities.  Whatever was done, if anything, to help Bob failed.  He
successfully committed suicide several years later.
     43.  I saw the Scientology thought reform procedures applied to a
large number of Scientologists who were placed on RPF or the RPF's RPF.
These procedures brought about long-lasting changes in the attitudes,
values, personalities and behaviors of the subjects.  Some of the
victims I processed were Tom Ashworth, Clarisse Brousseau, Betsy Byrne,
Al Crevello, Steve Crevello, Julie Fisher, Janadair Hockaday, Fred
Houch, Annie Logan, Jim Logan, Judy More, Toni Prybilsky, Tom Saeker,
Johnny Schleshenger, Homer Schomer, Jeff Wrothwiler, Stacy Young and
many others.
     44.  I observed, participated in and was victimized by the use of
thought reform on RPF as a means to impose the "Fair Game" law on
dissident Scientologists.  Despite claims to the contrary Fair Game has
never been, and will never be, cancelled.  The words Fair Game used in
any issue is cancelled.  However, the actions of handling suppressives
with trickery, lies, deceit and even destruction have not been cancelled
and are still being used today.
     45.  I received instructions directly from Ray Mithoff to use the
Hubbard Tech of thought reform to drive Tom Ashworth to a psychotic
break.  The express object of the exercise was to drive Tom crazy and to
commit suicide.  Tom went PTS Type III and attempted suicide.  Later,
Tom escaped from RPF and was caught, brought back against his will,
isolated with 2 guards and more thought processes were used on him to
calm him down rather than have him kill himself.
     46.  I also saw and heard the Hubbard Tech of thought reform used
to drive Gary Epstein to a PTS Type III psychotic break as punishment
for his refusal to comply with orders he received from the Wayne Marple
     47.  I saw these same techniques used on persons who had not
violated any Scientology laws or requirements.  The techniques were used
to compel persons to go up the Scientology Bridge to total freedom.
Advancing up the Bridge requires attending courses and auditing or
processing.  Both the courses and auditing becomes more expensive the
further up the Bridge a Scientologist goes.  So, these thought reform
techniques are callously employed to generate ever increasing sums of
income for Scientology.
     48.  At various times while I was stationed at the Gold base near
Hemet, I was assigned to different security functions.  Persons assigned
to the security details were in constant radio contact with other
security personnel.  We watched persons who were suspected of being
disaffected with Scientology and Miscavige closely (i.e.  Vaughn Young
and Terry Gamboa).  We were required to confirm that the suspects were
under surveillance to our seniors regularly.  We also had an armed look-
out, code-named "Eagle," who was located so that he could watch over the
entire Hemet base and keep the occupants under surveillance with a
powerful telescope.  When Miscavige wanted to give the persons working
at Hemet the impression that they were not being watched and to test out
his theories as to who was likely to blow their post, we would be
withdrawn from view and our surveillance responsibilities turned over to
     49.  We also had well established and intensively drilled
procedures to follow if anyone appeared inclined to take unauthorized
leave from the Gold base.  If disaffected members tried to leave in a
vehicle, it was security's job to get into the vehicle with the subject.
If they tried to leave on foot, we were trained to follow them while
remaining in radio contact with Gold base near Hemet.
     50.  If it was determined that a disaffected member was trying to
leave, we were instructed to call in private investigators who had been
retained by Scientology lawyers to deal with these problems.  Once the
private investigators were briefed, they took command of the situation.
The private investigators would give us instructions.  Once the private
investigators were involved, our role was limited to acting as the
private investigators' eyes and ears.  We would be sent to places where
the disaffected members were likely to go.  We would alert the private
investigators if we located the disaffected members.  Once we located
the disaffected members, the private investigators took care of the
     51.  I was personally involved in efforts to retrieve Sinar Parman,
Jeff Walker and Julie Fisher.  The efforts to retrieve Sinar Parman and
Julie Fisher were successful.  We were unsuccessful in our efforts to
return Jeff Walker to the Gold base.  As soon as he was off the base he
contacted the California Highway Patrol.  He informed the Highway Patrol
that he did not want to return to Hemet base.  To get this point across
to the Scientologists at Hemet base, Jeff returned to the Hemet base
with a Highway Patrol escort he picked up his belongings and announced
unequivocally that he wanted to leave and that he would take all
appropriate action to preserve his freedom.  He left the Hemet base
under escort from the Highway Patrol.
     52.  Over the years I was at Gold base, a significant number of
people at the base announced, or by their conduct indicated, to me that
they wanted to leave.  Julie Fisher stated repeatedly that she wanted to
leave.  She said that she did not want to remain at Gold base.  My
instructions were to keep her on the base.  Mark Fisher, who was
severely beaten by Miscavige, repeatedly told Miscavige and others that
he did not want to be at the Hemet base.  As Miscavige and others beat
Mark in my presence, Mark kept saying that his attackers could beat him
all they wanted but he still wanted to leave.  Finally, Miscavige
expressed his contempt and disgust at Mark and left the guard house
where Mark was being held.
     53.  I also saw armed guards at the "berthing" (staff) quarters at
Gilman Hot Springs.  The armed guards were stationed to prevent staffers
from leaving or "blowing" their posts during the night.
     54.  The function of the guards is not only to keep Scientologists
in but to keep "wogs" out.  Wogs are non-Scientologists.  In 1991 a
process server tried to get onto the base.  He was beaten up and
arrested by security guards who put him in handcuffs.  The Police
arrived and took the handcuffs off him saying "you guys can't do this,
Man, you guys are getting carried away.  The process server later sued
and the case was settled.  The security guard, Danny Dunnigan, was so
confused about what his senior told him to testify to that he perjured
himself about four times in the Courtroom.
     55.  I also have personal knowledge about the guarding of other
people being involuntarily detained by Gold Security, a division of CSI,
at the heavily fortified and armed Gilman Hot Springs base (Gold) and at
Happy Valley which is another Scientology base 11 miles away.
     56.  In addition, I have personal knowledge in connection with the
retrieval and return of persons who have tried to flee and leave the
Scientology organization.  This includes the involuntary detention of
Annie Broeker.  I learned that Annie blew her post when Gold Security
approached me to ask if I had seen her.  The security personnel asked me
if I had seen Annie.  They informed me that she was not at her work
assignment and not at her berthing.  Several days later, I asked what
had happened with Annie.  Russ Andress told me not to ask about Annie.
Later, I saw Annie at Happy Valley.  Persons who are believed to present
an embarrassment to Scientology are detained at Happy Valley.  The
inference that Annie was being detained was underscored by the fact that
she was not on post and was not wearing her uniform.  Furthermore, when
I saw here she was accompanied by the Director of Inspection and Reports
and the Master at Arms, who, at that time, was my son, Casavius
Tabayoyon.  From my personal experience, persons being kept under
circumstances similar to those described above are being watched and
will be detained, if they try to leave.  At a briefing, Miscavige said
that Marty Rathbun and another person from his staff had to hire a plane
to retrieve a staff member who had fled (Annie Broeker).  This briefing
was in relation to how bad we (Golden Era Crew) were doing our jobs.  It
is significant, in my opinion that the recently filed declaration of
Marty Rathbun indicated that he has been out of the U.S. jurisdiction
since late last year.
     57.  As added measure to the situation of the crew being in Doubt,
a security watch system was ordered into existence at the berthing
locations of the Hemet base.  When the crew were about to go home at
night, the guards were to be at their positions at the berthing areas.
Berthing is where the staff or crew sleep at Hemet and other Scientology
premises.  Berthing is similar to bunking on a ship.  I was put in
charge of six of the security guards.  The shore story was that these
guards were a neighborhood watch to protect the staff when they went
home, but in fact the guards were there to prevent staff members from
going to Vons or a late-night restaurant.  They were to insure that
staff members got off the bus and went directly to their berthing and.
went to bed.  Shore stories were also introduced on the Apollo.  A shore
story was a false story told to local port authorities so they would not
discover that we were Scientologists and order us to leave the port.
     58.  Another duty of the "berthing" guards was to prevent staff
from "blowing", which is the Scientology term for someone who leaves
Scientology to become a member of the real world again.  If staff
members did blow, we were to get in the vehicle with them and detain
them, and if we were stopped by the police, the "shore story" was to be
that the person was having mental difficulties and we were going to
assist them to get back home.  We were to make it look like we were
trying to help them, not hinder them.  Another duty was to call the base
when everyone was secured and a full head count was done.  As a watch
in-charge of the night berthing watch security guards, I was responsible
for roving the town of Hemet to look for staff who were not in their
berthing rooms when they were supposed to be.  The berthing guards are
CSI employees.  Miscavige personally issued the berthing guard orders.
     59.  I have personal knowledge that Miscavige issues oral and
written orders and instructions to Scientologists irrespective of either
ecclesiastical lines of authority or corporate lines of is authority or
demarcation.  Miscavige uses this omnipotent authority to exercise
personal control over any and all Scientology organizations whenever he
elects to do so.  I observed that in running the various Scientology
organizations, Miscavige constantly crosses all corporate and
ecclesiastical command lines without regard to the fact that there are
numerous Scientology related corporations of which he is neither an
employee, officer nor director.  He does not have to be to control any
Scientology organization.  He is above all Scientology organizations as
the ecclesiastical head of Scientology, COB RTC and Commander of the Sea
Org.  In this capacity, Miscavige acts as the managing agent of each
Scientology organization.
     60.  During my tenure at the Hemet base, Miscavige was always the
senior officer - over all Scientology organizations having business at
the base.  While Hubbard was alive, Miscavige's orders had the same
effect as Hubbard's.  Only Flag Orders issued by Hubbard could supersede
Miscavige's orders.  Once Hubbard died, there was no authority senior to
     61.  I personally observed Miscavige take over this position of
ultimate power over all of Scientology after Hubbard died.  I observed
Miscavige when he was COB RTC ordering into Golden Era Studios ("Gold")
, a CSI division, and ordering into the Commodore's Messenger
Organization International ("CMO Int") , another CSI division planetary
dissemination organization, etc.  Both of these Sea Org units are
corporately part of CSI.  RTC, CMO Int and Gold are all located at a
large compound outside of Hemet, California.  It is called Gold.  As I
learned, the Scientology corporate structure was only for the benefit of
the outside "wog" world.  It didn't have any bearing on how Scientology
     62.  When Hubbard was alive it was common knowledge and I also
observed it personally that he was in direct control, via Miscavige and
Pat Broeker, of CM0 Int and Gold, and the rest of Scientology.  After
Hubbard died Miscavige ousted Pat Broeker and Vicki Aznaran, who were
then in control of Scientology.  After that, it was my experience that
Miscavige had complete control over Scientology just as Hubbard had when
he was alive.  Miscavige took over Hubbard's place as managing agent of
all Scientology organizations.
     63.  The following are several examples of the power Miscavige has
over Scientology regardless of corporate boundaries:
     (a) I was on a project in 1983-84 when Hubbard was still alive and
he was planning to move to Gold properties at Hemet, so we were
renovating Hubbard's living and working quarters at the Hemet compound
so that he could live and work there.  I often spoke with Miscavige
about progress on these projects and received numerous orders on this
project directly from him.  At that time Miscavige's corporate title was
Chairman of the Board of Author Services, Inc.  ("COB ASI").  I was a
staff member of the Flag Operations Liaison Office Western United States
("FOLO WUS") , a division of CSI.  I was ordered to the Hemet compound
by Deputy Senior Messenger Janadair Swanson, who was employed by CMO Int
to work on CMO Int's project for renovating Hubbard's house.  Miscavige
ordered me to be in charge of the ceiling of the dining room in the
house.  Many living and working quarters were being renovated and
Miscavige was overall in charge as Special Projects Operations ("Special
Project OPS"), which was what he was called inside Scientology
organizations.  He would approve or reject the final product.
     (b) Later in 1985 I undertook a project as a Golden Era Productions
employee (Golden Era is part of CSI) to construct Hubbard's studio.  I
received many orders directly from Miscavige who now claims never to
have any authority with regard to CSI.  One order that is clear in my
mind concerns the main shell of the music studio.  We had just completed
the main shell, but when Miscavige inspected it he decided it would be
too small.  He ordered that it be re-engineered so it would be bigger.
This order was given to me verbally and in writing from Miscavige via
the Deputy Senior Messenger of the Household Unit.  This re-engineering
cost CSI an additional $449,000.00 which came from cash reserves of CSI
located in the main Los Angeles branch of the Sumitomo Bank.
     (c) When a Portland, Oregon, jury awarded Julie Christofferson $39
million in damages against the Church of Scientology of California,
Miscavige ordered that every available Scientologist be sent to Portland
to protest the Court's decision outside the courthouse.  This became
known as the Portland Crusade for Religious Freedom and and it involved
tens of thousands of Scientologists.  On one day I counted 12,000
people.  On another day there were 11,000 people outside the courthouse.
I was the Executive Director of the Portland Crusade.  I received direct
orders from Miscavige on what actions to take for the Crusade even
though I was employed by CSI, a non-profit corporation, and he was COB
ASI, a for-profit corporation.  Miscavige was personally involved with
the finances for the crusade submissions to Miscavige were known as
"writing it up to Department 21".  There were many other people who also
received direct orders from Miscavige, completely regardless of to what
Church of Scientology corporation they belonged.  This was battle.  This
was war.  Eventually the desired effect was achieved.  Christofferson
was bought off and gagged and the documents sealed.
     (d) Later, the judge declared a mistrial in the Christofferson
case.  The Portland Crusade was over.  Then I discovered that the
crusade had accumulated over $500,000 of debt.  Miscavige ordered a full
inspection of the financial records.  Once he had confirmed that the
records were in order, he ordered the $500,000.00 debt paid off out of
various Scientology organization accounts.
     (e) Once the Portland Crusade was over, I went back to building
Hubbard's studio.  We completed the studio.  At a special ceremony, we
received acceptance of our work by Miscavige and Hubbard.  This
established that the project was completed.
     (f) During the time of the construction of the Golden Era studio, I
read several written orders from Hubbard about the ongoing renovations
of his home and studio, as well as other aspects of the daily operations
of Gold, CMO Int and RTC.  Miscavige was directly responsible for the
implementation of these orders.
     (g) Miscavige also crosses corporate lines to berate and scream
intimidating obscenities and profanities at persons not of RTC.  Once I
did not achieve my target and Miscavige came at me, stood twelve inches
from my face, and called me a "mother fucker" and a "son of a bitch" for
about 10 minutes.  I've also been at Sea Org musters where Wendell
Reynolds shouted "You're all a bunch of treasonous sons of bitches!"
     64.  I did many construction projects at the Hemet (Gilman Hot
Springs or Gold) compound for Gold, CMO Int and RTC, and in every one of
these projects, I received at least one order directly from Miscavige on
each particular project.  On some projects, I received daily visits from
Miscavige.  During each visit, he issued several orders.
     65.  I recall meeting Steven Fishman during the L.A.  Crusade in
19-.  Miscavige also ordered this operation.  The LA Crusade was also
known as the Battle of L.A.  The purpose was to assemble so many may
Scientologists outside the LA Superior Court during the Wollershiem
trial that the judge and jury would be intimidated.  There were also
operations carried out to try and intimidate Judge Swearinger and
plaintiff's counsel Charles O'Reily.  At the LA Crusade, Fishman was
with a woman by the name of Debbie Truax.  Debbie told me that Fishman
was working on a confidential project with her and the OSA staff (Office
of Special Affairs).  My position was D/Executive Director (Deputy
Executive Director) for the L.A. crusade.  My duties included overseeing
to the productions of the crusade.  The executive director of the Battle
of L.A. was BilI Dendin.  I was not able to help Debbie, Fishman and OSA
because I had other projects for which I was responsible.  So, our
meeting was brief.  During the LA Crusade, or Battle of LA, I also saw
Fishman at the second floor of the CMO PAC building ("The Commodore's
Messenger Organization Pacific Area Command Building).  We didn't speak
to each other at that time.
     66.  About one year later, I was at a staff briefing, where Wendal
Reynolds was removed from his post for his condonement of the
Registration Cycle of Steven Fishman.  Miscavige gave the briefing about
how Steven Fishman claimed he had been defrauded because he had caught
on to the fact that there would not be any leather bound reel to reel
tape, so various Scientology organizations would now be forced to make
refunds of many tens of thousands of dollars.  This was a major upset or
flap because refunding money to people is so contrary to Scientology
principles that persons who have to refund money are severely
disciplined.  The briefing focused on the demotion of Reynolds and
others who failed to convince Mr. Fishman to leave the money with
     67.  While I was at the Hemet base, I became aware that Golden Era
Productions had sold Steven Fishman one or more E-Meters despite the
fact that Scientology records did not show that Fishman was qualified to
purchase or use the E-meter.  Records did not show that he was trained
as an auditor or as a Scientology minister.  The information I saw
indicated to me that Fishman was sold one or more E-Meters as a means to
generate money for Scientology.  These sales occurred despite the fact
that Scientology management was aware that a person like Fishman who
lacked appropriate training and who had a history of psychological
illness was highly likely to experience a PTS Type III reaction to self
auditing.  They were also aware that there was a significant possibility
that a person who induced a PTS Type III condition as the result of self
auditing would kill himself or others.
     68.  Based on my training in Scientology thought reform procedures,
I know that the nature of the materials sold to Fishman were such that
if he were to attempt to apply them to himself, the results were likely
to be extremely injurious.  Because the information available indicated
that Fishman was an illegal pre-clear, he was not eligible for the
auditing or processing that would provide him with the techniques to
deal with the mentally overwhelming consequences of what he would do to
himself.  Hubbard and other senior Scientologists had described the
practices to which Fishman was subjected as equivalent to giving a
person who had never seen a gun before a loaded gun with the safety off
and encouraging the person to play with it.  This is clearly stated in
'the article on Black Dianetics by Hubbard...  (note quotes from this
can be used here)
     69.  It is my expert opinion that Steve Fishman was a staff member
in a Scientology organization, with a position on the org board and a
senior within a division on the seven division Org board which is used
in organizations to lay out the personnel and functions of the class IV
org.  According to a letter of appointment and a letter from a staff
meeting, Fishman had a desk and a position in the Miami Organization.
The contents verify that Fishman was part of the Communication system,
was posted on the Organization board, had a desk and a letter of
appointment.  I have spent 5 years of my 21 years in Sea Org as a
personnel officer, 2 years as Organizing officer and 2 years as an
executive Establishment officer and make the above statement of opinion
from knowledge of the inner workings of the organization basic
establishment actions.
     70.  In 1989, I personally observed Miscavige ordering the entire
membership of the Gold compound near Hemit, including all of the above-
mentioned Scientology units (which are corporately part of RTC and CSI,
although the corporate distinction is not a part of the reality of daily
life at the compound), to apply the ethics condition of Confusion (see
next paragraph for an explanation of this term) as a punishment for a
mud slide which damaged Tom Cruise's private apartment at the base.  Tom
Cruise has his own personal Sea Org member assigned as a valet or
steward to clean his apartment and care for his needs when he is at the
Gold base.
     71.  In Scientology, punishment is assigned by way of what are
called "Lower Ethics Conditions."  To quote the Scientology Technical
Dictionary, "(confusion, treason, enemy, doubt, liability, non-
existence, danger, emergency, normal affluence, power change, power.)
The state or, condition of a person can be plotted on this scale of
conditions which shows the degree of success or survival of that person,
group or activity at any time."  The condition of confusion is the
lowest, most degraded ethics condition a person can be in, according to
Hubbard's writings.  When a person is in Confusion, they are only
allowed minimal sleep and food.  Persons in Confusion have to work very
hard to show that they are trying to get out of that condition before
they are allowed to be "upgraded."  I observed that Miscavige assigned
people lower conditions frequently, regardless of the specific
Scientology corporation to which they belonged.
     72.  In 1987, I observed Miscavige order Vicki Aznaran incarcerated
at a place called Happy Valley.  Happy Valley is a ranch 11 miles away
from the Gold base near Hemet.  It was then one of the Rehabilitation
Project Force ("RPF") Scientology correction and detention facilities.
Vicki had been the senior executive in RTC.  Miscavige won a power
struggle and took her off that post.  He ordered her into the RPF which
was part of Gold, a unit in CSI.
     73.  I was at the Happy Valley complex when Vicki was driven up.
She arrived in one car.  Miscavige arrived in another car right behind
her.  After Vicki and Miscavige had left the respective cars in which
they arrived, I heard Miscavige scream at Vicki, "You're going to do the
f --- ing RPF."  I did not see or hear Vicki make any response.  I saw
her go into the berthing facility.
     74.  A short time later, I spoke to Miscavige during his inspection
of the stairs and patio of a building which was under construction at
the base.  He was wearing a new captain's uniform, a rank to which he
appointed himself.  I complimented Miscavige on his new uniform.
Miscavige told me that Vicki, Jessie Prince and Spike Bush had been
consigned to RPF.  He said, "I'm almost positive they won't make it
through the RPF.  They're criminals."
     75.  Vicki spent 120 days on the RPF.  As Director of Renovations
and Construction Gold, a CSI department at the Gold base, I was in
charge of supervising the work performed by the RPF at the time.
Miscavige instructed us to keep a close watch kept on Vicki because he
feared she would try to escape.
     76.  For 12 hours every day, for the duration of her stay, except
for the few occasions when she was too ill to move, I saw her run around
a pole ("the running program").  This is one of the most severe forms of
RPF.  It is reserved for persons deemed to be in a very low ethics
status.  It is often regarded as a program to contain persons regarded
as crazy by the Scientology hierarchy.  In addition to the running
program Vicki was also working on other projects for an additional 5
hours a day.
     77.  Eventually Vicki successfully escaped from the RPF.  She is
now suing Scientology.
     78.  I also observed Miscavige promote himself to the Sea Org Rank
of Captain and assume the duties of Chairman of the Board of the
Religious Technology Center ("COB RTC") with no authorization from
Hubbard or anyone else, after Hubbard died.
     79.  When Hubbard died he left Pat and Annie Broeker in charge.
Then Annie went to the RPF and Pat Broeker went missing, and the Hubbard
order for Pat and Annie to be in charge was canceled by Miscavige, who
then made himself COB RTC.
     80.  I was at a staff briefing of all the crew at the Hemet
compound (including RTC, CMO Int, International Finance ("Int Finance"),
Hubbard Compilations Unit ("R Comps") , Translation Unit ("TU") ,
Hatting Project, Hubbard Technology, Research and Compilations Unit
("RTRC"), Household Unit ("HU"), CMO Gold and Gold) when Miscavige
announced that the ongoing strategy to handle the Cult Awareness Network
("CAN") was to send Scientologists, some of whom were totally
undercover, in to join CAN, and that we were suing CAN for
discrimination whenever they refused to allow a Scientologist to join.
He said the plan was to have so many scientologists in CAN that the
majority of CAN members would be Scientologists, and they would have no
way of knowing who was and was not a Scientologist.
     81.  I observed Miscavige approve and disapprove daily film rushes
on the films that were being produced by Golden Era Studios.  Golden Era
or Gold is part of CSI.  He also approved Renovations ("Renos")
schedules, in which all the staff at the Hemet compound were involved,
including not only RTC but also CSI Sea Org units.
     82.  I also observed Miscavige brief the CSI crow at the base on
how upset he was with the CSI crew for the way they had replied to a
survey.  CSI staff were asked where they wanted to live, and a lot of
the CSI staff answered they would like to live off the base (the Hemet
compound) for personal reasons.  Miscavige began screaming and spat at
the entire crew and said, "I spit on you" and "F--- you".  He said no
one who answered negatively was in a higher condition than Doubt
(another lower ethics condition only slightly less degraded than
Confusion).  This briefing from COB was a general order to the whole
base, including CSI, that if you didn't want to live at the base then
you were in a doubt condition.
     83.  Miscavige, at this same briefing or muster, also picked out
several particular staff members' surveys and read them to the crew so
the crew could see how terrible these people were because they wanted to
go to Vons market, or to movies or to have some time off from their post
and duties.
     84.  The next day at the canteen (a private store on the Hemet
compound) there were professionally made signs above the doors that said
Vons and a Vons grocery cart.  One staff member came in and decided it
was a ridiculous thing and decided to take the signs down.  Chris
Guider, who worked directly for Miscavige, found out about it and this
person was thrown into the lake.  This is a practice called
"overboarding."  It started on the Apollo where I participated in the
overboarding of many Scientologists who had angered Hubbard.  Indeed, I
was thrown overboard myself and only survived because of Hubbard's last
minute decision to have me plucked from the seas.  Now overboarding is
down at the lake on the base.  I have seen dozens of people thrown fully
clothed into the water (even in winter) because they did not meet their
production quotas or statistics.
     85.  I have observed Miscavige (COB RTC) do inspections of CSI's
renovation projects, the result of which was a list of additional
projects and orders for the staff.
     86.  One specific time was when I was a Gold staff member (part of
CSI) and was working in the garage at the Hemet Compound, Miscavige came
in and told me exactly how he wanted the windows handled in the planning
area.  He followed up this inspection by coming back with all his top
execs and screaming and yelling at me because all the things he had
ordered in a previous inspection were not completed.  Attached hereto as
     87.  I know Miscavige's handwriting.  Exhibit A is a copy of a 5
page document bearing Miscavige's handwriting.  Exhibit A is from Jim
Mortland, the Renos Construction Chief Gold (Part of CSI) to COB RTC
(Miscavige) via COB ASST RTC (who was Miscavige's wife Shelly).
Miscavige signed and dated the document on 12/6/90 and all of the
handwriting is his reply except the initials and date COB ASST RTC which
are those of his wife.  A translation of the handwriting is attached
hereto as Exhibit B. A copy of Exhibit A also went to D/CO Reserves CMO
Int (part of "CSI"), INT Landlord (part of "CSI") and CO IGOLD (part of
CSI). Miscavige added, above in handwriting, IG (Inspector General of
RTC) and IG Admin (Inspector General Administration of RTC) and CO CMO
INT (which is part of CSI).  Accordingly, Miscavige has added two more
of his juniors.
     88.  Exhibit - clearly demonstrates that Miscavige personally
inspected the work being done by a CSI employee, requested a report and
then directly issued further orders to the CSI employee.  Furthermore,
at the end of his handwritten reply, Miscavige requests information
regarding additional projects.
     89.  Attached hereto as Exhibit C is a document entitled Non
Existence Golden Era Productions Coordination Council.  This means the
Golden Era Production Coordinator Council was coming out of non-
existence and into existence.  Exhibit C demonstrates that at the Hemet
or Gilman Hot Springs base, there is a Coordination Council comprised of
representatives of different Scientology corporations.
     90.  In that regard, Miscavige is the ecclesiastical head of the
Church and sits atop the ecclesiastical command chart which prevails
over any corporate command lines and permeates all ecclesiastical and
corporate entities.  For example, he has total authority over the Gold
base at Hemet and the old Cedar Sinai Complex in Los Angeles even though
dozens of Scientology corporations are housed at those locations.  So
many that they created the Pacific Area Command (PAC) and Gold
Coordination Council to provide Unified control and command.  Miscavige
runs everything and even approves music scores, videos and building
     91.  Miscavige issues orders to individuals and groups including
the Coordination Council set forth in Exhibit C. The Coordination
Council itself issues orders to any part of Gold (which is part of CSI)
It cannot issue orders to Miscavige.  Nobody issues orders to Miscavige.
His authority and control is absolutely total over every aspect of
Scientology and every Scientologist's personal life.
     92.  Miscavige can order a mission of one or more people to go into
any Scientology entity, private businesses owned by Scientologists and
even Scientology families.  Indeed, he can order spouses to disconnect
from each other and/or their children.  For example, my 21 year old son
Casavius is still in Scientology.  Since my wife and I left Scientology,
he has disconnected from us.  Scientology will never let him speak to us
or see us.  There is no way for us to contact him or visit him at Hemet.
We have tried many times to do so.  When we first left Scientology we
kept a very quiet low profile, partly because of repressed memories and
partly because we didn't want to do anything to cause our son hardship
in the group.  We can stay silent no longer.  I am also aware of other
"disconnections" such as Matias Patel whose husband was head of
Scientology's finance police force in Europe.
     93.  I have also seen 15 to 20 lawyers at a time arrive for
meetings with Miscavige.  On one occasion I was working in the mini
conference room.  There were about 20 lawyers plus David Miscavige,
Michael Rinder, Heber Jentzsch, all the inspector generals and the CO
CMO INT.  Clearly this was a commingling of CSI and RTC business.
     94.  There is no doubt in my mind that Miscavige's control of
Scientology, and the Management Structures of the Church, make him the
managing agent of the Church, and a managing agent of CSI, just as
Hubbard was before him.
     95.  CSI, by its disobedience to this Court's discovery orders, has
been able to conceal the information that otherwise would have been
disclosed during the depositions of Miscavige, Jonno Epstein, Norman
Starkey, Guillaume LeSevre, Marty Rathbun, Ray Mithoff and Kurt Weiland.
     96.  Representations by CSI that these persons are not part of CSI
are simply not true.
     97.  In addition, Miscavige knows about Steven Fishman and his
extensive purchases of Scientology materials.  In the summer of 1987, &t
one of the regular weekly briefing sessions during which Miscavige
addressed all persons at the Gold base, regardless of corporate
affiliation, he informed all of those mustered that Steven Fishman, a
public Scientologist who had made large purchases of Scientology
materials, had demanded a refund because Gold had sold Fishman a large
number of leather-encased clearsound reel to reel audio tapes of Hubbard
lectures and Gold had not delivered them.  Moreover, although they had
sold Fishman the tapes, Gold was not going to deliver them and had no
intention of ever doing so.  This was the first item on Miscavige's
agenda.  Miscavige announced that Gold did not make that product, never
intended to make that product and had in fact not made the promised
product.  Because this was a major public relations flap, a mission was
established to deal with the problem.  The mission busted Wendell
Reynolds from Commanding Officer of Gold to pot washer.  Janelle
Allbach, the person who sold Fishman $80,000.00 of non-existent product,
and Fronz Schuler were also removed from their posts because of the
negative repercussions.  In addition to hearing Miscavige's explanation
of what happened at the muster, I also saw the ethics order issued on
Allbach.  It also mentioned the Fishman reg cycle and the scam that had
been perpetrated on him by unethical Scientologists.  In taking these
actions, Miscavige was operating within the Scientology commend chart
but was crossing Scientology corporate lines and issuing orders that
apply to corporations, organizations and missions where he held no
corporate post or other position.  Corporations, corporate posts and
corporate Positions are meaningless in Scientology and the Church.
     98.  Jonno Epstein is the Chief Financial Officer of CSI.  In my
experience, regardless of which Scientology organization I worked for,
whenever I needed funds to complete projects, I contacted Jonno Epstein.
So, I know that he holds the Scientology purse strings and authorizes
the writing of checks for whichever Scientology entity requires money.
This has led me to conclude that Epstein is the Chief Financial Officer
of other Scientology entities also.
     99.  In addition, I have personal knowledge of financial fraud
involving Jonno Epstein and his wife Leslie.  While on the RPF in
1987-1988, I was supervising the thought reform progress of Leslie.  She
had confessed to embezzling $24,000.00 dollars from the Church and
spending it for her own personal use.  She "handled" the situation by
writing a note to her husband Jonno to pay the owed monies from book
commission she should've received from Scientology.  Weeks later I
observed Leslie to be very happy and joyous.  I asked what had occurred
she said that, her idea to pay back the money she had embezzled was now
approved and Jonno had transferred the money to reserves.  Accordingly,
the $24,000 stolen from the Church on this occasion, for her own
personal inurement, was never repaid and was covered up with money from
another book bonus.
     100.  Guillaume LeSevre is the Executive Director International (ED
INT).  The post is the work-horse manager over Scientology International
CSI.  The ED INT receives all public mail from Scientologists who used
to write to "Ron" and now write to the ED INT.  The last Church post
that Hubbard held was that of ED INT.  He resigned from it in 1966 and
it was vacant until Miscavige appointed Bill Franks to the post in 1982.
     101.  LeSevre is the Church Official that the Church identifies as
having management knowledge.  He should have knowledge of the major
purchases of books, tapes and E-meters by Fishman.
     102.  Marty Rathbun is the Inspector General Ethics ("IG ETHICS").
Accordingly, he ran all of the Church's Offices of Special Affairs of
CSI.  This includes all legal cases, private investigations,
investigations, public relations and the execution of 'Fair Game'.
     103.  Rathbun is relevant to the inquiry as to whether Fishman was
'set up' and 'off loaded' by the Church.  OSA, and therefore Mr.
Rathbun, also received all of the data about Scientology related deaths,
suicides and financial frauds.
     104.  Norman Starkey was the trustee of the Hubbard estate
including Authors Family Trust B. It held the copyrights to all the
Scientology materials.  RTC only holds the trademarks.  All of the
Scientology books that Fishman purchased from Scientology were
copyrighted by the Hubbard trusts.  Norman had no authority in C.S.I.
Despite this, I observed Norman (who was ASI), yelling and screaming at
Arthur Hubbard (who was CSI).  Arthur told me on several occasions of
his dislike of his father (Hubbard) always trying to run his life.
Arthur got so upset with his fathers constant intervention into his life
that Arthur decided to leave the Sea Org.  He was recovered by Miscavige
and Starkey and was immediately sent to the RPF where he spent many
months.  In 1986 Arthur escaped the RPF and was again reprieved.  Norm
Starkey ordered the confinement of Arthur Hubbard at Happy Valley in
1986 after Arthur was back in the RPF he was given special thought
reform process which drove him crazy and he again left the Sea Org, this
time never to return.
     105.  Ray Mithoff is the senior-most person dealing with the
technology of Scientology which includes auditing and the handling of
Potential Trouble Source Type 3 cases ("PTS type 3").  A person who is
PTS Type 3 has suffered a psychotic break, may hear voices, may have
suicidal tendencies and will not know what is going on.  I have
personally observed numerous PTS type 3 cases in Scientology -- often in
the course of auditing.  Mr. Mithoff can verify PTS- Type 3 symptoms.
He can verify handling appropriate procedures such as the introspection
rundown and isolation watch.  He can identify and describe actual cases
and which deaths and suicides are directly attributable to Scientology
auditing.  From what Mr. Berry has told me about Fishman and his
behavior, it is my opinion, as an experienced RPF auditor and RPF case
supervisor, that he may have gone PTS-Type 3-especially if he had an
extensive psychological background and was self-auditing without
     106.  Kurt Weiland is the Commanding Officer of the Office of
Special Affairs International (CO OSA INT).  Heber Jentzsch, the
President of CSI, takes orders from, and reports to, Kurt Weiland, who
is his senior.  Kurt Weiland's job position ("Post") is within CSI.  He
directly supervises legal actions, investigations and public relations.
Kurt Weiland is senior to the Director of Investigations which is CSI's
spy section engaging in covert intelligence operations, intimidation and
harassment -- often through private investigators such as Eugene Ingram.
Kurt Weiland reports to Mike Rinder who is on the Watchdog Committee as
WDC OSA.  Rinder reports to the Chairman of the Watchdog Committee who
is Mark Yeager.  Yeager reports to Miscavige.  Thus, the President of
CSI (Rev.  Heber Jentzsch) is only a mid-level official with no
significant power of authority.  The purpose is to contain the Courts
and litigants at Heber Jentzsch's figure head level.
     107.  In 1988 I case supervised Tom Ashworth who had gone PTS type
III, slashed his wrists and later tried to escape with some upper level
materials he had somehow obtained.  I ordered a C/S 53 FIN and a LCRE.
Tom Ashworth's pre clear folder was sent up to Ray Mithoff who was then
RTC Inspector General for Tech.  I was CSI.  The folder came back with
everything regarding the psychotic break removed from the folder.
     108.  As indicated above, I have 21 years of experience with the
Scientology organization.  Throughout that time the words Scientology,
Church of Scientology, Scientologist and church were widely used.  These
words are generic in nature.  They do not refer to any particular
organization or person within the Scientology corporate hierarchy, the
Scientology Command Chart or the Scientology belief system.
     109.  I reviewed the alleged "of and concerning' language which CSI
sets forth in its complaint in this action.  There is nothing in the two
paragraphs in question that even remotely references CSI.
     110.  Within Scientology organizations, and as used by persons who
adhere to the Scientology belief system, the term Scientology refers to
a belief system based on Hubbard's Tech which is applied by
Scientologists to ecclesiastical and secular matters.  Scientology is
defined by the Tech Dictionary as:  Scientology does not refer to any
corporate entity.  The Tech Dictionary does not provide any corporate
association for the word Scientology.
     111.  Within Scientology organizations, and as used by persons who
adhere to the Scientology belief system, the term Scientologist has
always referred to an individual person who embraces the Scientology
belief system.  It does not refer to any corporate entity.  The Tech
Dictionary does not provide any corporate association for the word
     112.  The term church is used throughout Scientology organizations,
and by adherents to the Scientology belief systems, to refer to all
scientology organizations.  The term church does not imply or specify
any particular organization within the Scientology corporate hierarchy
or the Scientology Command Chart.
     113.  Accordingly, the relevant references to 'Scientology' and
'the church' are to the Church of Scientology and Scientology generally
and without reference to any of the hundreds of Scientology
     114.  I spent more than ten years stationed at the Gilman Hot
Springs Scientology base near Hemet, California.  It is known as 'Gold.'
The Gold is a fortified and armed facility operated by various
Scientology organizations.  It is under the direct control of Miscavige
who also has an expensive residence there.  These organizations include
the Church of Scientology International ("CSI") and the Religious
Technology Center ("RTC").  Gold is administered, in part, by The Gold
Coordination Council.  Exhibit ____.  While I was stationed at Gold, I
was personally involved with numerous renovations and construction
projects.  These included:
     (a) The renovation of Hubbard's personal living quarters in approx.
     (b) The renovation of Hubbard's office, which included installing
cinematography and audio sound equipment of production studio quality in
approx. 1983/84;
     (c) Constructing Hubbard's laundry facility which included
installing two large washing machines, two large dryers, a complete dry
cleaning machine and all attachments and an 18' x 12' storage closet in
approx. 1983/84.
     115.  I witnessed money from various non profit Scientology
organizations, and labor provided by various non profit Scientology
organizations being used for the personal benefit it of Miscavige, Tom
Cruise, other Scientology senior executives and other Scientology
celebrities (such as John Travolta, Chick Corea and Priscilla Presley).
     116.  I also saw monies and/or personnel from various Scientology
non profit religious organizations being used for the personal benefit
of Miscavige.  We constructed a music room for him, a lounge, a dressing
room, a personal exercise room and personnel storage rooms.  The
approximate cost of this was between $250,000, $300,000.  This does not
include the cost of labor since RPFers, or slave labor was used on these
projects for personal enurement of Miscavige.
     117.  Miscavige, other senior Scientologists and certain
celebrities would also use the movie theater we constructed on the base
to view first run movies provided to him by his acquaintances in the
movie industry.  The cost of this was easily $150,000.  This cost does
not include labor (again slave labor) or expensive film projection
     118.  During the 1980's, Miscavige befriended the actor Tom Cruise
and they spend a lot of time together on the Hemet base.  Their special
chef, Sinar Parman, would prepare them fancy meals.  Often they would
hang out alone in the space designated for L. Ron Hubbard on the Clipper
Ship we built in the desert.  This space had a small kitchen, a little
dining room, a little bar and a bed.  They also had the exclusive use of
the officers lounge.  On other occasions Miscavige and Cruise would work
out in the expensive gym we built for exclusive and restricted use.  No
one else was allowed to talk to Tom Cruise when he was on the base.  One
time one of the gardeners spoke to him and this caused a major flap on
the base.  At Gold, Miscavige is known by his initials DM and Tom Cruise
by his initials TC.  From the late 1980's until I left the Gold, Tom
Cruise was provided a personal and exclusive apartment and storage
facilities by the Scientology organization and at Scientology's expense.
Tom Cruise kept two Yamaha motorcycles, a Mercedes Benz automobile and a
large motor home at Gold.  These were stored in what used to be
Hubbard's garage and parking lot.  Obviously, Miscavige and Cruise have
developed a special relationship.  One is a young world domineering
celebrity.  The other is a young domineering cult leader who seeks to
'clear' the world and to rule it according to Scientology beliefs and
     119.  When Tom Cruise got married to Nicole Kidman, they and David
Miscavige went to a Colorado Ski Resort for the marriage ceremony.  A
Sea Org staffer (Sinar Parman) was taken along to do personal cooking
for Tom Cruise and Miscavige at the expense of Scientology not for
profit religious organizations.  This left only 3 cooks at Gold to cook
for 800 people three times a day.
     120.  I personally participated in the construction of an apartment
at the Gold base, using extensive funds from various non profit
Scientology religious organizations, for the personal and exclusive use
of Tom Cruise.  This was done on the orders of David Miscavige.  Even
though Miscavige has claimed to be Chairman of the Board of RTC, here he
is directing the expenditure of CSI money and the deployment of CSI
labor -- both paid and slave.  Other apartment cottages were built for
the use of John Travolta, Kirstie Alley, Edgar Winters, Priscilla
Presley and other Scientology celebrities who are carefully prevented
from finding out the real truth about the Scientology organization.  The
labor used to construct Tom Cruise's apartment was provided by Gold, a
division of CSI, and persons from a myriad of Scientology organizations
serving time in the RPF.  The RPF (Rehabilitation Project Force) is the
Scientology gulag or concentration camp.  Using RPFers to renovate and
reconstruct Tom Cruise's personal and exclusive apartment at the
Scientology Gold base is equivalent to the use of slave labor for Tom
Cruise's benefit.  The Tom Cruise apartment at the Gold base is located
at the golf course end of the Gold base, closest to State Street.  When
Tom Cruise visits the Gold base, and stays in his personal apartment, he
is cared for by a Sea Org steward.
     121.  We also had to renovate the Tom Cruise apartment at the Hemet
Base after it was damaged by a mud slide.  The repairs had to be
performed on an emergency basis.  Both the Gold crew and the RPFers were
placed on extended hours to restore the apartment.  Again, Tom Cruise
was benefiting from the use of what is essentially prison slave labor
being worked almost around the clock.
     122.  Tom Cruise also enjoyed use of facilities constructed on the
Gold base that were not available to any Scientology staff except the
senior most Scientologists on the base, particularly Miscavige and his
lieutenants.  For example, I saw Tom Cruise use the exercise room which
was off limits to at least 98 percent of the staff.  Tom Cruise also had
unrestricted access to the Ship which has a sauna, jacuzi and a large
Olympic sized swimming pool.  With regard to the Miscavige/Cruise gym
this was built in conjunction with the estates facility in approx. 1989.
The gym building cost approx.  $150,000 (again using slave labor) and
contains a complete lineup of the most modern weight training equipment.
It is one of the most incredible gyms imaginable and is for the
exclusive use of Tom Cruise, David Miscavige and other specially and
specifically approved by him.  It also has an incredible shower area.
     123.  To assure that Tom Cruise's stays at the Hemet base were
enjoyable, special provisions were made for him and restrictions were
imposed on the staff at the Hemet base.  Millions of Church dollars were
spent so that millionaire Tom Cruise could regularly visit the
Scientology base and be friends with Miscavige.  For example, Tom Cruise
received special meal services, special room services and the Hemet base
staff was restricted in its access to Hemet base facilities.  Indeed, a
girl by the name of Jennie Matsamura was assigned to take care of him
and his renovated cottage.  The Hemet base staff was barred from going
where Tom Cruise might be present.  Construction and renovation work
that was done on the base for Tom Cruise's benefit often had to be torn
up and redone because the coloring was slightly off or there were a few
inches of group that didn't quite match in color.  Once we had to pour a
concrete walkway so that Tom Cruise would not have to walk on the desert
soil.  Before the concrete dried it rained.  The concrete was spoiled.
Miscavige went into a fury over that.
     124.  On one occasion, prior to a Cruise/Kidman visit, Miscavige
decided to redo the meadow in beautiful flowers; Tens of thousands of
dollars were spent on the project so that Cruise and Kidman could romp
there.  However, Miscavige inspected the project and didn't like it.  So
the whole meadow was plowed up, destroyed, replowed and sown with plain
     125.  Tom Cruise also received his upper level auditing at the Gold
base.  All of his auditor training was provided under the auspices of
RTC and delivered by RTC.  Officially, RTC has no auditing service
delivery capability.  It exists solely to enforce the Scientology
trademarks.  This is yet another example of how the purported corporate
compartmentalization exists only for the "WOG" world and has no meaning
within Scientology.  At the time I left Gold, Tom Cruise had completed
Dianetics, Level O-IV, the Key to life course, the Life orientation
course and he was audited up to OT III.
     126.  OT III deals with body thetans ("bts") and clustered body
thetans ("clusters") . In essence, OT III deals with "the incident"
which Hubbard claims to have been the most engramic incident responsible
for the current state of man.  According to OT III, 75 million years
ago, the solution to overpopulation in a space confederacy (consisting
of 26 planets) was solved.  Now, each leaf on the Sea Org symbol
represents one of those planets.  Each of these planets had approx.
150-200 billion citizens each.  The overpopulation solution was to
disembody all the spirits ("mass murder") with the use of glycol
(alcohol and sugar) injected into the spinal cord causing an immediate
freezing up of the body and the unconsciousness of the being (soon to
become a bt or cluster) . The frozen bodies were then collected and
transported to earth (called Teegach by Hubbard) in space ships
resembling Boeing 707 jetliners.  The bodies were piled up, as in the
Nazi massacres, on the top of various mountain sites around the then
earth.  Inside these mountains were 17 strategically placed enormous
atomic bombs -- bigger than any built this century.  After the citizens
who had been selected to be part of the solution were placed on the
mountains, the hydrogen bombs were ignited from a remote space station
(lunar moon) by the officers of Xenu who ruled the space confederacy.
After the explosions the now disembodied thetans were electronically
trapped and transported to areas now known as Hawaii and Las Palmas
where there were pre-constructed implant stations.  Then there was a
long and arduous process of packaging the disembodied thetas (spirits)
into clusters with ideas, morals, social values, emotions, sensations,
pains and attitudes of what we now observe as human life.  The clusters
were then dispersed over planet earth through the medium of ice.  The
ice then melted and the first stage of implant command became activated.
This is known as 'Survival' in Dianetics.  The bts or clusters then seek
a human body.  When the bt or cluster occupies the body it will either
begin running or operating the body or the engramic commands earlier
received in the implants take place.  This will occur over and over
again in what is known as the life cycle -- each time resetting the
implant and restarting its effect with a death or end of cycle.'  This
technology can be used for tailor made psychosis, neurosis and general
madness.  Indeed, implant technology of this sort can be used for many
purposes.  Using implant technology, Hubbard teaches how you can cause
someone to do whatever you want them to do, starting at the prenatal
     127.  The purpose of auditing at the OT III level, such as Tom
Cruise has received, is to contact and audit the bts and clusters so
that the bts and clusters leave the body of the auditor.  The purpose of
this is to free the person from the determinism of the bts and clusters.
However, the bts and clusters that are released by the solo auditor are
now back at the beginning of their implant which they received 75
million years ago.  Survival then retriggers the basic implant which
then picks up a body, or attaches to one that is already occupied, and
re begins the whole cycle.
     128.  The ultimate goal of auditing is the return of self
determinism and abilities of the person being audited.  In other words,
to return the person to the state they were in 75 million years ago
before Xenu handled the over-population problem.
     129.  Tom Cruise also audited Kevin Catano up to grade IV.  Kevin
Catano was a member of the Sea Org security force at Gold.  Usually a
Sea Org member in the security force would be audited only by a Sea Org
member -- not a public scientologist let alone Scientology celebrity.
     130.  Tom Cruise's p.c.  (pre-clear) folder was kept in the Gold
case supervision (c/s) office which I had access to as a security
missionaire.  It contains supposedly confidential information derived
during auditing sessions.  However, the contents of such pre-clear
folders have been culled and used against people. it is my opinion,
based on my Scientology training, education and experience, that such
information is collected by the Scientology organization in order to be
able to exert control and influence over people such as Tom Cruise or
John Travolta should they ever attempt to leave the Scientology
     131.  In 1989/1990 we also constructed a tennis court at Gold for
the exclusive list of Celebrities and Miscavige.  Non profit Scientology
religious organization funds were used for this inurement project.  The
tennis court cost at least $200,000 to build.  The rubber coating alone,
on the tennis court, cost $80,000.  Then there was the landscaping and
rose garden around the tennis court.
     132.  I received money from Scientology reserves in excess of one
million dollars.  I used these monies to build a sound studio.
     133.  In 1990 Jan/Feb, I became aware of the fact that some friends
of mine came subject to severe ethics handlings.  The first was Mike
Silverman, he was assigned to the RPF's RPF for credit card scams and a
lot of other financial scams he was involved in.  It is my opinion that
Mike was the scapegoat and everyone concerned with the credit card scam
was not sent to the RPF'S RPF.  Also it is my experience that the Church
kept all the monies gotten from the scam and made the public persons
involved through coercive ethics application such as lower conditions,
pay the credit card depts and the church kept the money.  The second
friend who was subjected to severe ethics action was Joe Bueno.  Joe and
I spent months together in the RPF (Scientology's thought reform prison
camp).  I saw an ethics order on Joe Bueno which stated he was the
originator of the credit card abuse system and he arranged special
credit card loans.  Jonno Epstein, Marc Yeager claim no knowledge of
this credit card cycle.  Their' claim is just not true, as the Watch Dog
chairman Marc Yeager is briefed on the "income sources that are in
operation in Scientology.  Just as Jonno Epstein is briefed of all the
"income sources" in operation so for them to claim no knowledge is like
saying there is no sky, or there are no fish in the ocean, complete
     134.  I was also directed by L. Ron Hubbard to go to a bank in
Zurich, Switzerland, withdraw $14 million and to return with it to
Lisbon, Portugal.  Two other Sea Org members went on this mission with
me.  When we went to the bank, they brought the money out in a cart and
we sat there and counted it three times.  We then put it in a suit case,
got a taxi cab, then an air flight and handed the money over as ordered.
we were then debriefed.
     135.  Attached hereto and marked as Exhibit D is a copy of & letter
dated December 6, 1989 signed by Captain Marc Yeager concerning the
American Express credit card fraud being carried out within the church
of Scientology.
     136.  Attached hereto and marked as Exhibit E is a COPY of an
internal Church of Scientology Communication dated December 16, and
referring at paragraph "4/" to the American Express Credit Card Fraud
Scheme being conducted within the Church of Scientology.
     137.  Attached hereto and marked as Exhibit F is a copy of a Church
of Scientology document dated January 7, 1990 and being a probational
suppressive person declare regarding Jon Lundeen and stating in
paragraph 6 that for the last 15 years, he had been continuously
involved in financial irregularities ranging from forgery and fraud to
petty theft in connection with his Church of Scientology duties.
     138.  Attached hereto and marked as Exhibit G is a copy of internal
Church of Scientology Communication identifying Joe Bueno as being a
person who was "blackmailing" full time.
     139.  Attached hereto as Exhibit H is a Church of Scientology
communication dated January 20, 1990 being a copy of a non enturbulation
order regarding Joe Bueno and identifying him as being engaged in church
related financial irregularities including loan arranging, abusive
credit cards, etc.
     140.  Attached hereto and marked Exhibit I is a copy of a Church of
Scientology communication dated dated January 20, 1990 being a RPF
assignment of Mike Silverman for committing numerous, gross financial
irregularities on his Church of Scientology Post and also identifying
him to be a source of instigating the misuse of credit cards for church
     141.  Attached hereto and marked as Exhibit J is a copy of a Church
of Scientology communication dated January 31, 1990 and being a
suppressive person declare re Terry Block for committing severe
financial irregularities and identifying at least 50 instances of
illegal conduct on his behalf in connection with his Church of
Scientology duties.
     142.  Attached hereto and marked as exhibit R is a copy of a Church
of Scientology communication dated January 30, 1990 and being a
suppressive person declare re Michael Silverman and identifying him as
being involved in church related financial irregularities over the past
14 years stating that he had committed numerous gross financial
     143.  Attached hereto as Exhibit L is a copy of an internal Church
of Scientology communication dated January 31, 1990 regarding the Church
related American Express credit card fraud and the handling of that
situation by various people involved in it.
     144.  Attached hereto and marked as Exhibit M is a copy of an
internal Church of Scientology communication regarding the handling of
problems relating to Scientologist credit cards which had been the
subject of the Church related American Express credit card fraud.
     145.  Attached hereto and marked as Exhibit N is a copy of a
Scientology communication dated 29 January 1990.  Paragraph 2 states in
pertinent part, that "there has been gross criminality found on the reg
lines in all PAC Orgs."  PAC is the Pacific Area Command of the Church.
     146.  I was on the RPF with Robert Vaughn Young and others.  I was
personally charged with verifying that Young's mind control program
directed by my seniors was actually done.  This program included
application of Black Dianetics auditing procedures.  As a case
supervisor I spent between 20 and 30 hours verifying the mind control
program that was imposed on Young and then reviewing the results of the
     147.  I was also on the RPF with Stacy Young and supervised the
administration of various Black Dianetics procedures on her.  Part of
this program included a "gang bang sec check," which Rick Aznaran and I
performed at the instruction of Sr C/S Int Ray is Mithoff.
     148.  In December of 1992, Miscavige directed that we hide a large
number of sea containers of financial records relating to the Church and
himself.  The sea containers were to be hidden from the Internal Revenue
Service ("IRS" IRS investigators were scheduled to visit the Hemet base
to inspect the records of various Scientology organizations in
connection with the IRS's investigation of the various church of
Scientology entities that had applied for Section 501(c)(3) tax exempt
     (A sea container is a large transferable metal storage container,
measuring approximately 40' x 8' x 8'6".  These containers can be
transported on flat bed trucks, flat bed railroad cars and container
     149.  The procedures for concealing the information contained in
the sea container were set out in a written TRS handling program.  It
outlined the steps to be taken to secure the Hemet base and make sure
that the IRS examiners did not see any information that Miscavige did
not want the examiners to see.
     150.  There were a total of 20 sea containers involved in this
concealment.  We consolidated them down to 12 sea containers.  I was
also ordered to grade the land on which these containers had sat so that
there was no proof of them ever having been there.
     151.  One of these sea containers of documents was mistakenly
removed from the base unbeknownst to either me or Miscavige.  At the
time unused sea containers were being shipped from Gold base to their
owners.  Inexplicably, one of the sea containers containing concealed
tax information was picked up and taken from the Gold base by the
owner's employees who believed that the sea container was empty.  When
Miscavige learned that there had been a mistake in connection with the
hiding of this sea container of financial documents, he was outraged.
He flew into a tirade.  He blamed me for the error and accused me of
trying to destroy him.  It ended up on a ship at San Pedro and was off-
loaded before the ship's departure.
     My Decision to Leave Scientology
     Miscavige then told me that I was making it impossible for him to
function at the base.  By this time I had reached my limit as to the
amount of abuse I was willing to take.  I decided to flee from
Scientology.  I left ("'blew") my "post" at the Hemet base.  When I
left, I was able to locate my wife and we left together.  I was not able
to locate my 21 year old son.  He is still on staff.  We have been
unable to communicate since.  My wife and I then successfully avoided
the efforts of Scientology personnel in RTC and CSI to get us back to
the Hemet base.
     I declare under penalty of perjury under the laws of the United
States of America and of the State of California that the foregoing is
true and correct.  Executed in Los Angeles, California this 5th day of
March, 1994.
     Andre Tabayoyon
Homer Wilson Smith           This file may be found at
homer@rahul.net              ftp.rahul.net/pub/homer/act/CD13.MEMO
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