((My comments in double parentheses - Homer))
                         STACY YOUNG AFFIDAVIT
                                CD - 20
                            13 October 1994
                     Copyright (C) 1994 Stacy Young
       Redistribution rights granted for non commercial purposes.
     I, Stacy Brooks Young, declare as follows:
     1.  I am over the age of 18 years.
     2.  I have been retained as an expert consultant and expert witness
by Dr.  Uwe Geertz's counsel in the case captioned Church of Scientology
International v.  Steven Fishman and Uwe Geertz, #CV-6426-HLH (Tx)
currently pending for purposes of hearing the accompanying motion in the
United States District Court, Central District of California.  The
statements herein are of my own personal knowledge and if called upon as
a witness, I can testify competently thereto.
     3.  This declaration is submitted in support of Defendant Dr.
Geertz's motion for costs, fees, expenses and sanctions following the
dismissal of this action with prejudice by the court on February 22,
     4.  As a result of my nearly 15 years in Scientology, I am
qualified to discuss the policies, procedures and practices of
Scientology, including the issue of "of and concerning," plaintiff CSI's
assertion that it moved to dismiss this case because of "harassment" by
Dr.  Geertz's counsel, Scientoiogy's hatred of psychology, Scientologys
practice of harassing its critics, the treatment Steven Fishman received
at the hands of this organization, and the fact that Miscavige and his
lieutenants are managing agents of CSI.  My Extensive History in the
upper Echelons of Scientology Management Qualify Me as an Expert.
     5.  I was a member of the Church of Scientology for nearly 15
years, from January 1975 until July 1989.  From October 1975 until I
left, I was a member of the Sea Organization, the most dedicated group
of Scientologists in the entire organization.  I spent most of my time
from 1978 until 1989 in a highly confidential section of Scientology
management which was known as the Guardian Office until 1982 and is
today called the Office of Special Affairs.  This section of Scientology
is responsible for dealing with all external public relations, all
matters relating to civil litigation or criminal matters, all
governmental relations such as the IRS, and all critics of Scientology.
     6.  During my tenure in Scientology I acquired extensive knowledge
of the Scientology counseling methods known as auditing, the methods of
training staff members and public Scientologists, the methods of dealing
with non-Scientologists (known as "external publics"), former
Scientologists and/or critics, known as enemies or suppressive, and the
administrative and management procedures of the organization.
     7.  My first experience with Scientology was at the Mission of
Atlanta, Georgia, where I attended a series of introductory lectures
about the mind.  I received some basic auditing and took several basic
     8.  I joined the Sea Organization ("Sea Org," or "SO") at the
Advanced Organization in Los Angeles ("AOLA") in October 1975.  To
become a Sea Org or SO member one must sign a billion-year contract to
confirm one's dedication to scientology and "clearing the planet" (see
explanation below).
     9.  All staff members involved in delivering the confidential upper
levels of Scientology auditing and all staff members involved in
Scientology management must be members of the Sea Org.  They live
communally and are under the absolute authority of the Sea Org command
lines 24 hours a day.  I was paid $24 per week - when I was paid.
     10.  The Sea Org has total authority over all Scientology and
Scientology-related organizations, including all nonprofit and for-
profit corporations.  It cuts across all corporate boundaries and can
take over any Scientology organization without notice.  Any
Scientologist who refuses to submit to Sea Org authority is declared a
"suppressive person" and expelled from Scientology.
     11.  All Scientologists consider that Scientology is the only way
for Mankind to go free.  For a Scientologist this means getting
"exterior" to the physical body ("exteriorization") and, indeed, to the
entire physical universe.  In fact, L.  Ron Hubbard created a new
category of humanity for those who go through all the levels of
Scientology processing; they transcend the state of Homo Sapiens and
become what he called Homo Novis (similar to Nietsche's Superman).
Scientologists expect that once they have attained this state they will
be free to travel throughout the galaxies, freeing others who are in the
trap of the physical universe.
     12.  The route out of the physical universe trap is called "The
Bridge to Total Freedom." Every Scientologist is at one stage or another
on this Bridge, and they are expected to get everyone else moving on
this Bridge as well.  The idea is for everyone on Earth to get exterior
to the physical universe.  The only people who aren't included are
"suppressive," meaning those who have been critical of Scientology.
     13.  The Bridge is composed of a series of auditing processes, an
auditing process being a set of specific questions and commands.  The
person who asks these questions and delivers these commands is called
the "auditor." The person who answers the questions and carries out the
commands is the "preclean," since the first major milestone on the
Bridge is called "going Clear." After one attests to the state of Clear,
one moves on to the confidential upper levels of auditing known as the
"Operating Thetan" or "OT levels" ("thetas" being Hubbard's term for the
person without his or her body).
     14.  At the level of OT 3, one is allowed access to handwritten
notes by Hubbard which detail a terrible disaster that happened in this
sector of the universe 75 million years ago.  The head of the Galactic
Federation, whose name was Xenu, solved a massive overpopulation problem
by rounding up billions upon billions of people and transporting them in
blocks of ice to several volcanoes on Earth, which was known as
Teegeeack at the time.  They were dumped near the volcanoes and
subjected to H-bomb explosions.  At the same time, they were subjected
to a series of images which were electronically driven, or "implanted,"
into their minds.  After the "implant" was completed, these disembodied
beings were transported to Hawaii and Las Palmas where they were
packaged up into "clusters." Attached hereto as Exhibit 1 is a copy of
the OT 3 materials.
     15.  According to Hubbard, the OT III implant is rigged to kill
anyone who finds out about it before they have received the lower levels
of Scientology processing.  Needless to say, it is a major revelation to
discover that one is covered from head to foot with these disembodied
beings, called "body thetans" or "BTs" in Scientology.  One has
literally millions, or even billions of these BTs, and they have to be
audited on very precise processes to get them to wake up and disengage
themselves (or "blow") from the person's body.  The idea is that once
all of these BTs have been gotten rid of, one will be able to
exteriorize from the body at will.  These BTs can cause illness and even
insanity if they become upset, so it is important to get rid of them as
quickly as possible and to make sure one has done a very thorough job of
it.  (See Exhibit 2, "What the Church of Scientology Doesn't Want You to
know," by Jeff Jacobsen and Robert P.J.  Day, and "The Total Freedom
Trip," by Jon Atack, for more information about the practices of
     16.  I was a staff member at the Advanced Organization of Los
Angeles ("AOLA") from October 1975 through December 1978.  AOLA is one
of a handful of organizations around the world where people can go to
receive the confidential upper levels of Scientology processing.  I
audited hundreds of hours on public precleans as well as staff members
to prepare them for their upper levels, or OT levels.  (When a person
begins their OT levels they no longer have an auditor.  They graduate to
what is called "solo auditing," a process in which they audit their own
BTs.) I also did many security checks on staff members.  A security
check is a method of inducing a person to confess to crimes,
particularly crimes against Scientology.
     17.  In 1977 I was posted as Interne Supervisor at AOLA.  In this
capacity I supervised auditors-in-training, known as internes, to
certify them as qualified professional auditors.  To perform this
function I had to understand auditing procedures precisely, from the
most basic processes to the advanced processes and procedures of Class 6
and Class 8, which are advanced levels of expertise, so that I could
recognize whether or not the internes were conducting themselves as
proper auditors.
     18.  As a result of my experiences at AOLA I acquired a high level
of expertise as a "tech terminal," meaning one who is knowledgeable
about the technical application of Scientology auditing and training
     19.  At the end of 1977 I transferred to the United States
Guardian's Office ("US GO") in Los Angeles.  I was a staff member in the
USGO from January 1978 through January 1982.  The Guardian's Office was
the part of Scientology that handled Public Relations, Intelligence and
Legal matters for Scientology.
     20.  Because of my technical background, I was posted as the
Organizing Officer ("Org Officer") for the Public Relations Bureau and,
later, as the Org Officer for the entire Guardian's Office.  As the Org
Officer my functions included the handling of all personnel and
organizational matters, such as correcting a staff member who made
mistakes, taking care of staff members who were sick or upset or in
trouble, recruiting new people for staff, and promoting or demoting
staff members as needed.  I was also responsible for the establishment
and proper administration of all the Guardian's Office personnel
throughout the United States.  Because the Guardian's Office oversaw
certain aspects of the administration of all other Scientology
organizations, I became very familiar with the overall structure of
Scientology and how the various organizations interact with each other
and with the outside world.
     21.  In early 1982 I was assigned to a unit known as Special
Project as a Public Relations Assistant under my husband, Robert Vaughn
Young.  In this position I became familiar with the L.  Ron Hubbard
archives material, which was the complete collection of all of Hubbard's
personal papers, including diaries, letters, and notes that he had kept
from a very early age.
     22.  Several months later Special Project became what is now Author
Services, Inc.  ("ASI"), a for-profit company whose ostensible purpose
was to be L.  Ron Hubbard's literary agency.  I was taken out of public
relations and made the Organizing Officer for ASI in April 1982.  In
this position I worked directly for David Miscavige, who was Chairman of
the Board of ASI ("COB ASI"), to carry out his orders concerning the
staff of ASI.
     23.  David Miscavige, known as DM, has been the head of Scientology
since 1981.  His loyalty to L.  Ron Hubbard and Scientology is absolute,
and he is utterly ruthless about maintaining his power.  He moved the
seat of power from ASI to the Religious Technology Center (RTC) in 1987,
because it was more defensible to run Scientology from a non-profit
corporation than from a for-profit corporation.  At that point he
appointed himself Chairman of the Board of RTC ("COB RTC"), which is his
current title.
     24.  Although ASI was established as a for-profit, non-religious
corporation, in reality while DM was COB ASI the staff of ASI ran the
entire Scientoloqy network.  ASI had complete control over the
management of all Scientology orgs and missions, all Office of Special
Affairs activities, all transfers of funds between church accounts and
LRH accounts, every aspect of the life of anyone who was a
Scientologist, whether staff or public.  These powers were moved to RTC
in 1987, as explained above.
     25.  Because of my experience in ASI I am familiar with the day-to-
day activities and procedures of the highest levels of management of
     26.  I have firsthand knowledge of the establishment of the
corporate structure of Scientology as it now exists, having worked with
the staff who were responsible for creating it.  The purpose of this
activity was to create an impenetrable, legally defensible network of
corporations such that neither the IRS nor any other legitimate agency
of government could "pierce the corporate veil" of Scientology
organizations, thereby freeing Scientology management to transfer funds
between organizations without concern for the law.
     27.  I am also familiar with the absolute authority which the
highest levels of Scientology management exercise over every aspect of
Scientology and Scientology-related organizations, whether "church" or
"secular," and the ruthlessness with which any sign of disloyalty or
disaffection is handled.
     28.  In September 1982 I was assigned to the Rehabilitation Project
Force ("RPF"), the Scientology version of a prison camp.  I was assigned
to the RPF because I was openly critical of DM's coercive and degrading
treatment of staff members.  I was on the RPF in Los Angeles for eight
     29.  As a result of this experience I am familiar with the absolute
control which the highest levels of Scientology management have over the
behavior and thought processes of every Sea Org member.  There is only
one way for a good Sea Org member to behave and think, and any deviation
from this is punished immediately and severely.  In turn, it is the
responsibility of all members of Sea Org management to bring about the
same pattern of behavior and thought in all Scientologists under their
authority, regardless of whether those under their authority are part of
the "church" or the various "secular" arms of Scientology.  This
distinction means nothing within Scientology; it was created purely to
facilitate dissemination of Scientology and to fend off Scientologys
"enemies," such as the IRS.
     30.  From May 1983, when I was allowed off the RPF, until July 1984
I was posted as Course Supervisor at the International Training
Organization (ITO) in Los Angeles.  From this position I trained
hundreds of fledgling Scientology executives from all over the world on
the administrative and management policies of L.  Ron Hubbard known as
the Organization Executive Course, or OEC.  As a result of this
experience I am very familiar with the administrative policy of
Scientology and know that Hubbard formulated it to facilitate the
establishing and organizing of his worldwide network of Scientology
     31.  In August 1984 I was transferred back to the PR Division of
the Guardian's Office, which by that time had been renamed the Office of
Special Affairs.  My primary functions were as a writer and editor for
FREEDOM Magazine, a Scientology publication created to serve as a
vehicle for attacking individuals and groups who were perceived as
threats to Scientology.  I also wrote articles for other Scientology
     32.  As a result of my experience as a writer for these different
Scientology publications, I am familiar with Scientology's practice of
changing its story for whatever public it is trying to manipulate.
Often I rewrote the same basic story for each publication, completely
changing the wording and overall thrust of the story to appeal to the
different publics that were going to read it.
     33.  As a writer in OSA I was also responsible for writing
rebuttals of negative stories about Scientology that were published in
various newspapers across the country.  I was also assigned to write
rebuttals of books that were published that were negative about Hubbard
and Scientology.  As a result of this work I became very familiar with
the policies and practices of Scientology with regard to individuals and
groups that criticize the organization.  I have personal knowledge that
the practices which were formerly called "Fair Game" continue to be
employed, although the term "Fair Game" is no longer used.  These
tactics are laid out in many of the key policies that are studied and
applied by staff of OSA.
     34.  In July 1989 my husband and I left Scientology.  We lived in
San Diego from 1989 until August 1991, at which time we moved to Newport
Beach.  We are currently living in Corona del Mar, California, which is
part of Newport Beach.
     CSI Had no Standing to File This Case.
     35.  As described above, I spent nearly 13 years at the highest
echelons of Scientology management.  My experience includes substantial
time in the Guardian's Office("GO"), its successor, the Office of
Special Affairs ("OSA"), and also at Author Services, Inc.  ("ASI").
     36.  The GO/OSA branch of Scientology is responsible for dealing
with all matters outside the confines of the cult itself, particularly
public relations, litigation, gathering of intelligence information on
critics, carrying out harassment and intimidation campaigns on critics,
etc.  The GOROSA branch is also responsible for maintaining the facade
of corporate integrity for the benefit of the courts, the Internal
Revenue Service ("IRS") and other governmental agencies.
     37.  ASI is a for-profit corporation with offices in Hollywood,
California.  ASI manages all of L.  Ron Hubbard's ("Hubbard") literary
affairs.  ASI was first created in 1982.  To this day ASI accepts only
proven members of the Sea Organization ("Sea Org"), an unincorporated
organization which, under the leadership of David Miscavige
("Miscavige"), actually runs all of Scientology.
     38.  When ASI was created, it managed the entire Scientology
empire.  Miscavige arrogated the corporate title of Chairman of the
Board of ASI ("COB ASI") to himself.
     39.  In 1987, Miscavige moved his base of operations from the ASI
facility in Hollywood to the high-security Scientology compound near
Hemet, California.  In conjunction with this move, Miscavige gave
himself the new title of Chairman of the Board of Religious TEchnology
Center ("COB RTC").  Religious Technology Center ("COB RTC").  In
reality, Miscavige's power is such that he can give himself whatever
title he wants in whatever corporation he chooses.
     40.  I know from my personal experience in GOROSA and in ASI that
the corporate structure of Scientology is purely to obtain legal and tax
advantages.  When Hubbard was still alive, the complex corporate
structure also served as a shield to protect Hubbard from litigation and
criminal charges.  The corporate integrity has certainly never been a
matter of interest to anyone outside of the GOROSA or its senior
echelons, such as RTC or ASI.  The corporate structure is not a matter
of interest or concern within the cult itself.  Most Scientologists do
not think of Scientology in corporate terms at all.  Instead of thinking
of plaintiff Church of Scientology International ("CSI") or any other
corporate entity when Scientology is mentioned, Scientologists think of
all the organizations which apply the Hubbard Technology.  Those
organizations which apply the Hubbard Technology include the
geographically located Churches of Scientoloay (e.g., Church of
Scientoloay of San Francisco, Church o' Scientology of Miami, etc.), the
geographically located missions (e.g., Church of Scientology, Mission of
Ft.  Lauderdale, etc.), the management organizations (e.g., RTC and CMO
Int), the public self-improvement organizations which apply the Hubbard
Tech (e.g., WISE, Narconon, Sterling Management, etc.), the front groups
with political action agendas (e.g., Citizens Commission for Human
Rights, etc.), and the autonomous, extra-corporate organizations for
administrative and money management (e.g., Sea Org and Flag Banking
Office, etc.)
     41.  In short, even dedicated Scientologists would not think of CSI
when they read about "Scientology" or "Scientologists," such as in the
two paragraphs of the May 1991 Time Magazine article which are the
subject of this litigation.  Additionally, even a Scientologist would
not think of CSI if he or she read something about the "church" in
material referring to Scientology.  Certainly no one outside of the
Scientology cult would think of CSI when reading about "Scientology,"
"Scientologists," or the "church," for the obvious reason that no one
outside of Scientology is likely to have heard of CSI as distinct from
Scientoloqy as a general, generic amalgam of organizations.  Indeed,
since CSI was created in late 1981 and throughout my tenure at the upper
echelons of Scientology, I found that only a small circle of
Scientologists, in OSA and the senior management such as RTC and ASI,
made reference to CSI on a regular basis.  These are the persons who
need to maintain the facade of corporate separateness to the outside
world so as to obtain various tax and litigation advantages.
     42.  For CSI to claim that the words "Scientology," "Scientologist"
and/or "the church, " as they appear in that portion of the Time
Magazine article which mentions Dr.  Geertz and Mr.  Fish man, are "of
and concerning" CSI is disingenuous in the extreme.  Based on my
education, training and experience in Scientology, the words
"Scientology," "Scientologist" and "the church" as they appear in the
Time Magazine article can only be reasonably understood to refer to
Scientology generally, generically and without particular reference to
any one of the hundreds of Scientoloqy corporations that have been
established for various purposes over the years.  The vast majority of
the corporate entities do not appear on the scientology command chart.
The fact that separate corporations exist on paper has no effect on the
daily life of Scientologists or the operation of Scientology.  The
corporate boundaries are ignored.
     43.  When I was a staff member in the GO, ASI and later OSA, it was
common knowledge that the corporate structure was a contrivance created
purely because of the tactical benefits it bestowed on Scientology for
purposes of interfacing with the "wog" world.  All Scientologists,
particularly Sea Org members, regard the Sea Org as an elite group of
superior beings whose job it is to get everyone else in the world into
Scientology.  Meanwhile, Sea Org members and Scientologists generally
refer laughingly to unenlightened non-Scientologists as "wogs."
     44.  To get along with these wogs and keep them from hindering the
forward progress of Scientology, it is necessary to create the
appearance that Scientology operates by the same rules as the rest of
society.  A large part of OSA's role is to maintain this facade through
public relations and legal actions.  In fact, Scientologists think it is
quite funny when wogs accept the facade as real.  The arrogance of
Scientology's senior management, and the contempt in which it holds any
court or other wog body which falls for the mascarade is astounding.
     45.  The contempt became apparent to me in conversations I had with
other staff, in comments made by Miscavige, Norman Starkey, Lyman
Spurlock, Steve Marlowe, and other executives during staff meetings, and
in instructions I was given about how to position certain agencies and
individuals when I wrote stories for Scientology propaganda
publications, including FREEDOM Magazine.
     46.  I was in the FREEDOM Magazine department of the public
relations division of OSA US during the trial of Wollersheim v.  Church
of Scientology of California, in 1985.  At the time, OSA US was still,
for corporate purposes, part of the Church of Scientology of California
     47.  One afternoon, I was informed, along with the other staff
members of the FREEDOM office, that our office was to be moved to
another location across the street, outside the big blue Scientology
complex which used to be Cedars of Lebanon Hospital at Sunset and
Berendo in Hollywood, California.  We were instructed to move to an
office on the second floor of B building on Catalina Street.  I was told
that the FREEDOM office and the Treasury office of OSA US were to move
out of the Scientology Complex because it looked like Lawrence
Wollersheim was going to win his suit against CSC and the corporation
had to be gutted of all its assets before the decision was handed down.
All that would be left of CSC would be a shell consisting of a Treasury
office and the FREEDOM office.  When Wollersheim tried to collect from
CSC, he would discover that there were no assets at all in CSC .
     48.  We did move our office to the building on Catalina.  The
Treasury office also moved.  I was told by the Treasury Secretary, Rhea
Smith, that all of the assets of CSC had been taken out of the CSC
accounts.  The motto of OSA US during the Wollersheim trial was "Not One
Thin Dime," meaning Scientology would never pay even a dime to Lawrence
Wollersheim.  The OSA US staff were briefed on the gutting of CSC at a
staff meeting, and all of the staff cheered because now Wollersheim
couldn't get his hands on any money even if he won his suit.
     49.  This gutting of CSC to hide assets from a litigant and then
cheering about it at a staff meeting is an example of the contempt in
which the Scientology Command holds the UPS.  justice system.  The
corporate structure of Scientology is created and recreated depending
upon the convenience of the moment, as illustrated in the above example.
     50.  The idea that the remarks attributed to Fishman and Geertz in
the Time Magazine article upon which CSI's claims are purportedly based
refer to CSI rather than to Scientology generally is absurd.  Inside the
Scientology empire no one takes the corporate structure seriously.  The
corporate structure is a contrivance to enable Scientology to interface
to its advantage with the "wog" world.  This Court should not be fooled
by the corporate sleight of hand which was attempted in this case.
"Scientology, "Scientologist" and "the church" refer to the overall,
generic empire of Scientology, not to CSI, and no one even within
Scientology would think of CSI when reading those words, much less the
general public.
     It is CSI That is Harassing.  Not the Defendants
     51.  CSI asserted that this case must be dismissed to protect
several Scientology celebrities who were noticed for brief depositions
not to exceed two hours each.  CSI claims that these celebrities were
served for the express purpose of harassment and abuse.  CSI asserted
that it feared these celebrities would be exposed to confidential upper
level materials if CSI allowed them to be deposed.  CSI further asserted
that "CSI has seen its religious tenets and scriptures assailed; it has
been compelled to produce or offer for deposition the religion's most
senior ecclesiastical leaders so they can be reviled; and it has endured
a transparent campaign to harass CSI into default."  CSI cited this as
its excuse to move to dismiss this entire case.
     52.  Nothing could be further from the truth.  The CSI manag- ing
agents and the other Scientologists who have been deposed in this case
have been interrogated only about the use and misuse of L.  Ron
Hubbard's technology ("Tech") for secular purposes.  The fact that the
same Tech is also used for so-called religious purposes does not make
inquiry about the Tech a reviling of the Scientology belief system or
its most senior members.
     53.  Even I, who spent many years helping to create this kind of
utterly hypocritical rhetoric for the Church of Scientol- ogy, am
stunned at this latest fantasy concocted by CSI.
     54.  Dr.  Geertz's attorneys have never expressed in my presence
any intention whatsoever to bring up Scientology's confidential upper
level materials during the deposition of the Scientology celebrities.  I
have been advising Graham Berry and Gordon Calhoun, Dr.  Geertz's
attorneys, as an expert consultant on Scientology Tech matters.  I would
know from the type of advice and guidance they have sought from me
whether they intended to inquire about the "religious" or
"ecclesiastical" uses of the Tech as opposed to the secular use of the
Tech.  Their inquiries have been limited to secular uses of the Tech.
Why should they ask these people about Scientology's confidential upper
level materials?  There would be no point in bringing up those
materials.  For the Scientologists to assert a concern over this is
simply another example of their assuming that others will use their own
harassing tactics.  In fact, I advised Dr.  Geertz's attorneys to depose
the Scientology celebrities about the lack of corporate boundaries in
Scientology.  Miscavige, COB RTC, insists upon treating all the
celebrities with kid gloves and personally oversees their progress in
Scientology, sending RTC, Cmo Int or Gold specialists to take care of
their needs regardless of any supposed corporate structure.
     55.  What is astonishing to me is the incredible arrogance of CSI
in accusing Dr.  Geertz and his counsel of exactly those actions in
which CSI regularly engages.  It is not the defendants Dr.  Geertz and
Mr.  Fish man who have been conducting an all-out campaign of
harassment, assault and vilification; it is CSI that has been doing so.
Indeed, the leadership of CSI has no choice but to do so.  CSI's
leadership is bound to do so by Scientology doctrine.  CSI's leadership
would be acting heretically or unorthodoxly if it did otherwise.
Founder L.  Ron Hubbard, whose edicts on these subjects are "sacred
scripture" which must be implemented without question or reservation,
gave specific instructions to harass and destroy anyone perceived as an
enemy of Scientology.  There are many, many policy statements by
Hubbard, which bind all Scientologists, that go into this.  What follows
are only a few examples.
     CSI Is Bound by Its Own scripture to Harass Its Critics
     56.  Hubbard wrote "The Scientologist: A Manual of Dissemination of
Material" (attached as Exhibit 3, see p.  157) in 1955.  He gave the
following instructions for dealing with anyone who sought to compete
with orthodox Scientology: "The purpose of the suit is to harass and
discourage rather than to win.  The law can be used very easily to
harass, and enough harassment on somebody who is simply on the thin edge
anyway, well knowing that he is not authorized, will generally be
sufficient to cause his professional decease.  If possible, of course,
ruin him utterly."
     57.  Hubbard also urged Scientologists to employ private detectives
to investigate anyone who criticized Scientology.  He added, in language
particularly apropos to this lawsuit: "...  we should be very alert to
sue for slander at the slightest chance so as to discourage the public
press from mentioning Scientology."
     58.  In 1959 Hubbard published the "Manual of Justice" for
Scientology (attached as Exhibit 4).  This document instructs
Scientologists as follows:
     "People attack Scientoloqy; I never forget it, always even the
score....  "When we need somebody haunted we investigate....  When we
investigate we do so noisily always.  And usually investigation damps
out the trouble even when we discover no really pertinent facts.
Remember that by investigation alone we can curb pushes and crush
wildcat people and unethical 'Dianetics and Scientology'
organizations....  "Of twenty-one persons found attacking Dianetics and
eighteen of them under investigation Scientology were found to be
members of the Communist Party or criminals, usually both.  The smell of
police or private detectives caused them to fly, to close down, to
confess.  Hire [private detectives] and damn the cost when you need to."
     59.  As author Jon Atack wrote in his well-researched book, A Piece
of Blue Sky: Dianetics, Scientology and L.  Ron Hubbard Exposed:  "A
mood was being created in which staff members would become 'deployable
agents,' as sociologist Roy Wallis called Hubbard's henchman in his
excellent study of Scientology.  After all, Hubbard never gave any
indication of the possibility that a complaint against him or against
Scientology could be justifiable.  The tactic of 'noisy investigation'
originated in the Manual, and came to mean harassment by defamation.
Hubbard certainly did not mind if the defamation was grossly
exaggerated, or even a total fabrication.  If you throw enough mud, some
will stick.  The Manual of Justice suggests outright blackmail." (The
section of the book which contains this passage is attached as Exhibit
5.) 60.  In 1960 Hubbard wrote another policy called "The Department of
Government Affairs" (attached as Exhibit 6), which stated, in part:
     ".  .  .  Only attacks resolve threats.  "In the face of danger
from Govts or courts there are only two errors one can make: (a) do
nothing and (b) defend.  The right things to do with any threat are to
(1) Find out if we want to play the offered game or not, (2) If not,
derail the offered game with a feint or attack upon the most vulnerable
point which can be disclosed in the enemy ranks, (3) Make enough threat
or clamor to cause the enemy to quail, (4) Don't try to get any money
out of it, (5) Make every attack by us also sell Scientology and (6)
Win.  .  "The goal of the department is to bring the government and
hostile philosophies or societies into a state of complete compliance
with the goals of Scientology.  This is done by high level ability to
control, and in its absence, by low level ability to overwhelm.
Introvert such agencies.  Control such agencies.  Scientology is the
only game on Earth where everybody wins.  There is no overt in bringing
good order."
     61.  In other words, only activities which promote tne expansion of
Scientology or which attack and injure its critics are good or ethical
by Scientology standards.  Any attack or injury to the enemies of
Scientology is justified.  The end, universal acceptance of the
Scientology belief system, justifies the means, attacking or injuring
enemies of Scientology, particularly psychiatrists, psychologists and
those who have criticized Scientology.
     62.  In another policy statement called "Attacks on Scientology
(Additional Policy Letter)" (attached as Exhibit 7) Hubbard instructed
Scientologists to: "(1) Spot who is attacking us." "(2) Start
investigating them promptly for FELONIES or worse using our own
professionals, not outside agencies.  "(3) Double curve our reply by
saying we welcome an investigation of them." "(4) Start feeding lurid
blood, sex, crime actual evidence [sic] on the attackers to the press."
     63.  Each of the documents authored by Hubbard are still part of
the Scientology doctrine today.  In fact, these documents, along with
many others, comprise the heart and soul of the activities of the Office
of Special Affairs (formerly the Guardian's Office).
     64.  In Scientology, Hubbards instructions must be followed
exactly, with no deviation.  These documents and others with similar
instructions to harass have been followed in this lawsuit and ail the
other lawsuits in which Scientology has been involved.
     65.  The Scientologists accuse defendants Dr.  Geertz and Mr.
Fishman of harassing tactics.  Yet it is the Scientologists who are
compelled by their most fundamental scriptures to harass perceived
enemies of Scientology unceasingly, including judges, defendants, their
counsel and the Scientology experts retained in this case.  66.  The
Hon.  Ronald E.  Swearinger became a target of Scientology harassment
while he was presiding over the case of Larry Wollersheim v.  Church of
Scientology of California, #C 332 027.  In the document attached as
Exhibit 8, "Linda" is Linda Hamel, who was In-Charge of the "Mission
Find the Crimes" ("MFTC I/C") in OSA, which was run directly by "Marty,"
who is Marty Rathbun, Inspector General for Ethics in RTC.
     67.  My husband Robert Vaughn Young and I have been harassed and
intimidated repeatedly since we became experts in this case.
Scientology operatives have stolen our trash.  They have slandered us to
former associates.  They have called us at all hours of the night.
High-level OSA operative Kurt Weiland sent my husband a threatening
letter.  We have been followed and surveilled on several occasions when
we were able to spot the person following or surveilling us; we have no
idea how much more surveillance we have been subjected to by operatives
skilled enough to avoid being spotted.  On one occasion we were followed
more than 100 miles from our home by a Scientology agent.  My husband
spotted the agent and stopped our car, at which point the agent pulled
in behind us and stopped his car as well.  My husband walked over and
asked him outright if he was a Scientologist, whereupon he admitted that
he was from the high- security Scientology compound in Hemet and that he
was following us under orders from Scientology Command.
     68.  These actions are embedded in the doctrine of Scientology.
Scientologists have no choice but to adhere to these policies.  CSI is
Accusing the Defendants of Its Own Criminal Activities
     69.  L.  Ron Hubbard invented a name for someone who accuses others
of crimes that he himself has committed.  In fact, Hubbard wrote a
bulletin about this, which he called "The Criminal Mind."  Ironically,
Hubbard described himself and his alter ego, the Sea Organization, when
     70.  The thinking behind CSI's motion to dismiss is best explained
by quoting Hubbard himself: "Apparently they add it up this way: 'If I
accuse him of robbing, then it would be assumed by others that I have
not robbed a bank.' By loudly voicing a condemnation of a crime, the
criminal, with a crooked think, supposes people will now suppose he is
above bank robbery and won't suspect him." (A copy of "The Criminal
Mind" is attached as Exhibit 9.)
     Scientology Doctrine Reguires That Psychiatrists and Psychologists
Must be Destroyed
     71.  There is another aspect of the Scientology doctrine which is
highly relevant to this case, because Dr.  Geertz is a psychologist.
Scientologists are taught that psychiatrists and psychologists are the
root of all evil in the world.  According to Hubbard, psychiatry and
psychology are behind a massive conspiracy to destroy Scientology and,
with it, man's only hope for salvation.  Therefore, all psychiatrists
and psychologists, including Dr.  Geertz, are Fair Game as far as
Scientologists are concerned.
     72.  Hubbard taught that the world must be protected from
psychologists and psychiatrists at all costs.  Hubbard wrote many, many
scriptures and recorded many lectures in which he vilified, ridiculed,
attacked, and blamed all the ills of the world on the mental health
     73.  The vitriol in Hubbard's attacks has three sources.  First,
much to Hubbard's surprise and chagrin, the mental health profession did
not embrace either Hubbard or Dianetics, Hubbard's "Science of Mental
Health." Second, and even more offensive to Hubbard, was the fact that
his often dangerous techniques were labeled as quackery.  Third, and
perhaps most important, Hubbard regarded the mental health profession as
a well-established and deeply entrenched competitor for monies which
might otherwise flow to him and to Scientology.
     74.  The following sampling makes clear the degree of Hubbard's
loathing and contempt for these professions, and shows that
Scientologists will stop at nothing short of total obliteration of these
     75.  In 1970 Hubbard wrote "The Psychiatrist at Work" "attached as
Exhibit 10).  he attacks psychiatry as follows: ".  .  .  psychiatry is
making insane people.  "This is why the insanity statistic is soaring
and why the crime statistic is on a wild climb....  "The psychiatrist
has masters.  His principal organization, World Federation of Mental
Health, and its members, the National Associations of Mental Health, the
'American' Psychiatric Association and the 'American' Psychological
Association, are directly connected to Russia.  .  "It goes without
saying that the savagery and fraud of psychiatry must cease and that
auditors must encourage in state and public and through all their
connections displacing psychiatric abuses with sane auditing."
     76.  Obviously, psychiatrists and psychologists were evil because
their services competed with Scientology auditing.  In a 1971 document
by Hubbard called "Confidential" (attached as Exhibit 11), he wrote:
"Policy is that we assign any case or upset in Scientology to past
damage and interference with the person by medicine or psychiatry.  They
were sent to us after medicine or psychiatry had already destroyed them.
We cannot be blamed for psychiatric or medical failures.  "By
continually repeating this, make the AMA, Nats [National Associations of
Mental Health], etc.  very wary of using our name on these psychiatric
and medical failures.  Both subjects are guilty and the statement is
demonstrably true.  Use it often.  Make it known to the enemy that this
is our policy as a restraint on their fetid imaginations: "Every time
you attack us we will disclose more records of your failures.'"
     77.  In another 1971 document of the same date, entitled "It is
time we begin to label Psychiatry for what it is, the greatest failure
of the Nineteenth Century.  Every notorious criminal and defector of the
Twentieth Century was in psychiatric hands before the crime.  Burgess,
McLean, the Texas Tower murderer, Manson and all the rest were
psychiatric failures first.  Every infamous modern assassin was a
psychiatric failure.  Psychiatric victims are endless trouble to our
society.  We are tracing social turmoil, unrest, widespread drug
addiction to psychiatry.  "We wish to issue a public warning that
psychiatry kills.  We in Scientology stand ready to help anyone, and
help Governments rid themselves of psychiatric crime.  There is urgency
in this.  In too many cases we are asked to repair persons already
maimed beyond human tolerance by psychiatric interference and brutality.
We blame psychiatric failure for the state of modern society.  We will
do all we can to help, but Nineteenth Century Psychiatry must go.  We
have never had a failure or upset that psychiatry had not first ruined."
     78.  In 1980 Hubbard wrote "Criminals and Psychiatry" (attached as
Exhibit 13).  In it Hubbard said: "Almost every modern horror crime was
committed by a known criminal who had been in and out of the hands of
psychiatrists and psychologists, often many times....  "The most
charitable look at this would be that the psychologists and
psychiatrists are simply incompetent.  But other more sinister
implications can be drawn.
     "Developed in the latter part of the nineteenth century, they
appeared on the militaristic scene of a rearming and conquest-minded
Germany.  At that time, the arch criminal Bismarck was laying the
groundwork for the slaughters of World War I and World War II.  It
fitted with the philosophy of militarism that man was an animal and that
there was neither soul nor morality standing in the way of the wholesale
murder of war.  "Up until that time the Church had some influence on the
state and possibly some power in restraining bestiality and savagely
insane conduct, but small as it might have been, it was incompatible
with the unholy ambitions of the militarists.  That man was only an
animal after all, soulless and entitled to no decency, was bound to be a
popular doctrine.  That insanity consisted of urges to harm others would
have been a very unpopular idea to government heads who had nothing else
in mind.  .  "Spawned by an insanely militaristic government, psychiatry
and psychology find avid support from oppressive and domineering
governments....  "The credence and power of psychiatry and psychology
are waning.  It hit its zenith about 1960; then it seemed their word was
law and that they could harm, injure and kill patients without
restraint.  The appearance of an actual technology of the mind--
Dianetics and Scientology--has played no small part in acting as a
restraint.  At one time they were well on their way to turning every
baby into a future robot for the manipulation of the state and every
society into a madhouse of crime and immorality.  "The world is turning,
things change.  And there may come a day when the mad dogs of the world
are not given over to the charge of mad dogs.  But that will be to the
degree that you successfully carry forward Dianetics and Scientology."
     79.  In a 1981 document called "Diabetics and Scientology Compared
to lath Century Practices" (attached as Exhibit 14), Hubbard wrote: "A
comparison between Dianetics and Scientology and psychology and
psychiatry is nonsense.  "The two lath century subjects, psychology and
psychiatry, do not achieve ANY good results.  On the contrary they are
destructive beyond belief.  They make crackpots, sexpots and vegetables
when they do not outright kill....  "The character of the Governments
themselves is established by their tolerance and use of psychology and
psychiatry.  In no human race of any civilized repute has any law
condoned broad mayhem and murder of their populations.  Yet under modern
governments psychology and psychiatry not only have carte blanche but
also get insistence on their use...  "Is this a civilized world we're
living ...  "I'm afraid it only will be when Dianetics and Scientology
can bring wisdom enough to Man to blunt his furious efforts to do
himself in."
     80.  In 1982 Hubbard wrote "The Criminal Mind and the Psychs"
(attached as Exhibit 15), which states, in part: "It has often been
noted (and routinely reported in the papers) that criminals 'treated' by
psychologists and psychiatrists go out and commit crimes.  "It could be
suspected that these 'practitioners' used pain-drug-hypnosis and other
means (under the guise of treatment) to induce the criminal to go out
and commit more crimes.  And possibly they do....  "So let us look at
psychs again -- what they call 'treatment' is a suppression (by shocks,
drugs, etc.) of the ability to think.  They are not honest enough, these
psychs, being just dramatizing psychotics themselves for the most part,
to publish the fact that all their 'treatments' (mayhem, really, when it
is not murder) make people more stupid....  "The answer to crime is
rising IQ.  But only the Scientologist can do that."
     81.  In another 1982 document called "The Cause of Crime" (attached
as Exhibit 15), Hubbard wrote: ".  .  .  So what IS the cause of crime?
The treatment, of course!  Electric shocks, behavior modification, abuse
of the soul.  These are the causes of crime.  There would be no
criminals at all if the psychs had not begun to oppress beings into
vengeance against society.  "There's only one remedy for crime--get rid
of the psychs!  They are causing it!..  "The psychs should not be let to
get away with 'treatment' which amounts to criminal acts, mayhem and
murder.  They are not above the law.  In fact, there are no laws at all
which protect them, for what sane society would sanction crime against
its citizens even as science?  They should be handled like any other
criminals.  They are at best dramatizing psychotics and dangerous, but
more dangerous to society at large than the psychotics they keep in
their offices and loony bins because they lie and are treacherous.  Why
the government funds them I do not know.  They are the last ones that
should be let loose to handle children."
     82.  In another 1982 document entitled "Pain and Sex" (attached as
Exhibit 17), Hubbard announced that psychiatrists and psychologists
(collectively called "psychs") had been behind all of our troubles for
millennia (and he also revealed his bizarre view of sexuality): "There
are two items in this universe that cause more trouble than many others
combined.  "One is PAIN.  "The other is SEX....  "Despite the false data
of Freud, psychologists, psychiatrists and other criminals, they are not
native to a being.  They are only artificial wavelengths.  They have
exact frequencies that can be manufactured....  "Destructive creatures
who do not want people big or reaching--since they are terrified of
punishment due to their crimes--invented pain and sex to shrink people
and cut their alertness, knowing Ness, power and reach....  "Pain and
sex were INVENTED tools of degradation....  "Combined, pain and sex make
up the insane Jack-the-Rippers (who killed only prostitutes) and the
whole strange body of sex murder freaks, including Hinckley who shot
President Reagan], and the devotees of late night horror movies.  Under
the false data of the psychs (who have been on the track a long time and
are the sole cause of decline in this universe) both pain and sex are
gaining ground in this society and, coupled with robbery (which is a
hooded companion of both), may very soon make the land a true jungle of
crime .  "Go into any asylum or a prison and look at the increasing
institutional population and know what you are looking at.  In the main,
these are pain and sex addicts, decadent and degraded and no longer
capable.  They were sent on that route down through the ages by the
psychs and here they are still in the psych's hands!  And do they get
well or go straight?  Oh no.  Whether in prisons or insane asylums, they
just get worse.  And the psychs in both places rub their bloodied hands
as they turn their products loose again upon the remaining population!
It's no accident.  And the stocks-in-trade of psychs are PAIN and SEX."
     83.  There are many, many more documents and tapes which comprise
Scientology doctrine about the evils of psychiatry and psychology.  As
far as the Scientologists are concerned, the world would be much better
off if all the psychiatrists and psychologists were to disappear,
leaving Scientology to move into the field of mental health and take it
over.  The Scientologists actually believe that this would be the best
thing that could happen to humankind.
     84.  Furthermore, as far as the Scientologists are concerned,
anyone who would subject himself voluntarily to years of hypnosis, as
Mr.  Fish man did, is already so far gone that there is really nothing
that can help him.  Orthodox Scientology holds that a person as damaged
by psychology as Scientologists believe Mr.  Fish man to be might as
well drop his current body, pick up another body and start over again.
     85.  So these two people, Dr.  Geertz and Mr.  Fish man, are so
degraded by choice of profession and decision to seek help from a
conventional mental health professional that each of them is infinitely
expendable in the eyes of Scientology.  See Exhibit 2 for an example of
the kind of treatment a psychiatrist who publicly criticizes Scientology
can expect from a Scientologist.  Fish man's Experience in Scientology
Drove Him to a Psychotic Break.
     86.  I have read Steven Fishman's book, The Lonesome Squirrel, and
I have reviewed his testimony up to his sentencing.  I have viewed a
1981 videotape of Fishman under hypnosis by Dr.  Uwe Geertz, and I have
viewed a 1989 videotape of Fishman being interviewed by his attorney
Mark Nurik and Dr.  Richard Ofshe in Fish man's home in Florida.  Based
on the review of these materials and my knowledge and experience in
Scientology, I do not believe there is any doubt that Steven Fishman was
driven to a psychotic break (known in Scientology as "Type 3 PTS,"' a
term which I will explain below) by Scientologists, either deliberately
or through greed and gross negligence of his welfare.
     87.  It is utterly forbidden for anyone with a serious psychiatric
background, including an extensive history of hypnosis such as Fishman
had, to be allowed to have any Scientology processing at all.  Attached
hereto as Exhibit 19 is a copy of Hubbard Commincation policy letter
entitled "Illegal Pus, Acceptance of High Crime PL." I have been advised
by Mr.  Berry that it was well known by Scientology operatives that
Fishman was not eligible for processing because of his history of
therapy with Dr.  Uwe Geertz; yet he was induced to buy more than
$100,000 worth of Scientology books, written materials, prints and E-
Meters, clearly being led to believe that he would be welcomed into the
privileged circle of dedicated Scientologists.
     88.  It is highly significant that he was induced to purchase three
E-meters (electro-psychometers), the device used in Scientology
auditing.  E-meters are not used for anything else but auditing, and
they are not supposed to be sold to anyone without proof that they are
in training as an auditor.
     89.  But in the Scientology world there is a thing called
statistics, and Fishman was an unsuspecting victim of this system.
Every single staff member in a Scientology organization has a statistic
which measures his or her production.  These statistics are reported
every Thursday to International Management in CSI and RTC.  For
Scientology staff members, their lives virtually revolve around making
sure their statistics are rising every week.  Many things depend upon
this.  If their stats are down they may not be paid that week.  They may
not be allowed to spend any time with their spouse or children.  They
may not be allowed any time off at all, and since they already work as
much as 14 to 18 hours a day or more, one day or even half a day off
becomes very important, even if it is only enough time to do laundry.
If their stats continue to go down over a period of time, they risk
being assigned to the Rehabilitation Project Force or "RPF," which is a
Scientology prison camp.  Needless to say, people can become quite
desperate under these circumstances, and they will do just about
anything to get their statistics up.
     90.  Nowhere in Scientology is the push for statistics more
frenzied than in the departments responsible for bringing money into the
organization.  Unfortunately Fishman appears to have been the unwitting
victim of a feeding frenzy which involved at least nine different
Scientology corporations.  These people discovered that Fishman had
money and that he was willing to give it to Scientology.  They took his
money even though they knew he would never be able to receive any
benefit from Scientology auditing, even though they knew he could harm
himself with the materials they were selling him, particularly because
they also sold him E-Meters.  Indeed, it is clear that Fishman was
overwhelmed by the Scientology materials he was given, to the point of
an actual psychotic break.
     91.  To understand how this could have occurred it is necessary to
explain briefly how Scientology processing works.  In essence, the
theory behind auditing is that by confronting painful incidents in the
past one can free up mental energy that has been locked up in these
painful memories.  L.  Ron Hubbard created many auditing processes which
are supposed to help an individual achieve greater sanity.  But he made
it clear that the processes must be done in a precise way with no
deviation.  There are severe penalties for anyone who deviates from the
standard procedures.  Hubbard made it clear that it can be very harmful
psychologically and even physically to deviate from these procedures.
     92.  Certain situations can cause a person to have trouble in
auditing.  The most serious thing that can hinder a person's progress up
the "Bridge to Total Freedom" (as the exact series of auditing processes
is known) is becoming a Potential Trouble Source, or PTS.  A PTS is
someone who is being suppressed in some way by another person or entity.
     93.  There are different types of PTSness.  Some of these are
listed in an October 27, 1964, policy by Hubbard known as "Policies on
Physical Healing, Insanity and Troublesome Sources." Attached hereto as
Exhibit 20 is a copy of Hubbara Communications Office Policy letter
entitled "Policies on Physical Healing, Insanity and Troublesome
Sources".  Ten types of PTSness are listed in this policy letter, each
one of which has to do with types of people who have caused Scientology
"considerable trouble." They include people who have sued the church,
newspaper reporters, family members who are hostile to Scientology, etc.
They are listed as Type A through Type J, thus the policy has been
nicknamed the "A to J policy." When someone is labelled as being any of
these types of PTS, he or she is barred from getting any Scientology
processing (auditing) or training, because people who fall into these
categories have historically caused trouble for the organization, either
by bringing legal action against it or by giving negative information to
the press.
     94.  Steve Fishman was labelled Type A, which is "persons
intimately connected with persons (such as marital or familial ties) of
known antagonism to mental or spiritual treatment or Scientology."  He
was also labelled Type C, which is "persons who have ever threatened to
sue or embarrass or attack or who have publicly attacked Scientology or
been a party to an attack and all their immediate families should never
be accepted for processing".  Fish man was labelled Type C because he
had "paid a large amount of money for a set of Hubbard's taped lectures
which he had never received, and he had threatened to sue CSI after
trying for months to get his money back.  (In Scientology one is never
supposed to step outside of the Scientology "justice system"; anyone who
does so, such as by filing a police complaint or a civil suit, is
immediately disqualified for Scientology services.)
     95.  Furthermore, because of his background of hypnosis, Fishman
could never be eligible for Scientology services.
     96.  Despite the fact that he was declared PTS A and C, and that it
was known he had an extensive history of hypnosis by a psychologist,
thereby barring him permanently from Scientology auditing and training,
Fishman was sold over S000,000 of Scientology materials, including a
huge collection of tape recorded lectures by Hubbard (which are not
supposed to be listened to until one reaches a certain level of
Scientology training), packs of material that are only supposed to be
seen by people in certain staff positions, and, what is most shocking,
three E-meters, one of which was specifically designed for use by
auditors on the confidential upper levels of auditing.  It is
specifically designed for use in solo auditing, which is auditing of
oneself.  It is clear from his videotaped interview that this is
precisely what Fishman used it for.
     97.  This created an explosive situation, one which clearly could
lead to a psychotic break in Fishman.  Even as recently as September
1993, Ray Mithoff, Senior Case Spervisor International, the most senior
Scientology technical expert in the world, supervised the auditing of a
person in England who had had a psychotic break as a result of her
experiences with Scientology.  A copy of Scientology's report on this
incident is attached hereto as Exhibit 21.  This person had a
psychiatric history, and the mixing of psychiatric techniques with those
of Scientology had caused the psychotic episode.  So it was obviously
known that Fishman risked a Type 3 psychotic break if he were allowed
training or auditing, yet he was sold thousands of dollars worth of
materials anyway, including an E-meter with a solo auditing capacity
permitting him to self audit.  Thus, either intentionally or out of
greed and negligence, Scientology created a situation in which Fishman
would almost certainly suffer a psychotic break and become a Type 3 PTS,
as explained below.
     98.  The types of PTSness described earlier, Types A through J,
relate to different types of threat a person can pose to Scientology.
There are also three types of PTSness, known as Type 1, Type 2 and Type
3, which relate to a person's own state of mind and physical health.  A
person will manifest PTSness through a range of conditions, all the way
from a minor cold to a more serious illness (all illness is a sign of
PTSness) to full-blown insanity.  All PTSness is the result of being
connected to one or more suppressive people, suppression being defined
as "a harmful intention or action against which one cannot fight back."
A copy of a Hubbard Comminications Office Bulletin entitled "Seach and
Discovery" and describing these PTS types is attached hereto as Exhibit
     99.  Type 1 PTS means that the suppressive person is actively
suppressing the person in present time.  To handle this a person is
interviewed by someone who helps them spot who is suppressing them,
whereupon the illness (a cold or whatever) is supposed to vanish.
     100.  Type 2 PTS means that the person was connected to the
suppressive person earlier, either in this lifetime or an earlier
lifetime (it might have been 150 years ago, or 76 trillion years ago -
whatever the person thinks).  Someone in present time reminds the person
of the actual suppressive person, and this is making the person sick.
Curing Type 2 PTSness requires extensive auditing, usually on the PTS
     101.  Type 3 PTS is the Scientology term for a full blown psychotic
episode.  It was my experience in Scientology that when a person has a
psychotic break they lose touch with the real world and begin to
hallucinate or imagine conversations, events, people, and whole
scenarios.  Even after they recover they are never sure what part of the
experience was real and what they imagined (Even after they recover they
are) never sure what part of the experience was real and what they
     102.  The subject of Type 3 PTS cases is one of the dark secrets of
Scientology.  No one is supposed to talk about it outside of
Scientology, and it is treated with utmost security when someone becomes
Type 3 PTS.  The reason for this is obvious: people are not supposed to
be driven insane by Scientology, so it would be a public relations
nightmare to try to explain it.  But more importantly, the treatment of
people who have psychotic breaks in Scientology is a clear abuse of the
mental health laws, and if such treatment were brought to the attention
of mental health officials there is little doubt that Scientology would
be subjected to public scrutiny for its practices in this area.
     103.  A number of things can trigger a psychotic break, or cause a
person to "go Type 3," as they say in Scientology.  In his Health, first
book, Dianetics: The Modern Science of Mental Hubbard's term for "mental
voices" was "demon circuits.  "Later he made it clear that what is
actually occurring when someone has a psychotic break or "goes Type 3"
is that all of his body thetans or BTs have become upset and are all
talking to him and through him at once.
     104.  In Fishman's case, it is unclear whether he was driven to
this state of mind purely through fraudulent irresponsibility and
negligence, or whether it was done more deliberately, as described in
the following Hubbard lectures.
     105.  In a number of taped lectures Hubbard said that a person
could be driven insane through the deliberate application of what he
called Black Diabetics.  This is his term for a method in which the
normally therapeutic methods of Dianetics and Scientology are reversed
and the person is deliberately driven mad.
     106.  In a September 17, 1951, tape called "Some Notes on Black
Dianetics," Hubbard stated: "A person can drive himself quite mad with
Dianetics without any trouble.  What you have concentrated on in your
study of Dianetics has been the process of making people well.  That is
your emphasis line.  But don't think for a moment that that is any more
than half of it.  There is as much data on how to make people insane,
uncomfortable, sick or dead as there is on how to make them well." A
copy of the transcript of this taped lecture is attached hereto as
Exhibit 23.
     107.  It is possible that such techniques were used on Fishman,
first to induce him to break the law for Scientology and then to try to
get him to commit suicide, leaving a note absolving the church of all
responsibility.  Having failed to do this, church operatives could have
deliberately driven him to the point of a psychotic break.
     108.  Hubbard explained how to do it in the following passage from
"Some Notes on Black Dianetics": "With Black Dianetics, you could tailor
make any kind of insanity you wanted to.  The person might not manifest
this the next day, maybe not the next week or maybe not for thirty days.
Maybe three months later he is walking down the street and feeling a
little bit tired when somebody honks an auto horn just right or
something of the sort, and all of a sudden he goes crazy, and there he
is - insane!"
     109.  In that same lecture Hubbard provided a blueprint for getting
someone incarcerated, just as Fishman was, without anyone ever finding
out that the person was set up: "We find that nobody can protest an
implanted engram [meaning a hypnotic command given to a person such as
was portrayed in "The Manchurian Candidate"] except the person into whom
it has been implanted.  He is the only one who can protest this.  He is
the only one who can sign out a warrant.  Even if he goes insane, nobody
can sign out a warrant.  So he could say, 'Well, it was Bill and I know
it was Bill and I saw Bill and Bill has taunted me with it since,' and
so forth, but if he has been pronounced insane...  he has lost his civil
rights and he can't issue a warrant.  In other words, this is legal
murder, legal punishment and so forth.  Because the law does not know
anything about this, no laws exist to prevent it or inhibit it."
     110.  In another tape called "The Complete Auditor, Part I,"
delivered on June 28, 1951, Hubbard said: "Any one of us could take a
human being and, with malice aforethought, drive him stark, staring
crazy with greater efficiency than even psychiatry does.  What would you
do to him?  You would just reverse all the things that you know would
help him: ...  slug him with some drugs, hit him in the face, take a
hypodermic needle to him so that you give him very painful but
unobservable somatic....  Then when he comes out of it say this had
never happened to him, feed all the content back to him again by telling
him about other people's engrams or even his own, convince him that he
does not really know what his reality is and convince him that you are
his friend.  A person can't take this; he would spin.  That would be an
efficient job, but that could be done on a person who was pretty doggone
sane!  n A copy of the transcript of this taped lecture is attached
hereto as Exhibit 24.
     111.  In still another tape, called "Outline of Therapy," Hubbard
stated: "Out of Scientology you could formulate a very fine type of
thought warfare.  Works much better than an atom bomb.  An atom bomb
just kills people, but you could take thought warfare and you could
enslave them utterly.  You could make complete slaves out of them."
copy of the transcript of this taped lecture is attached hereto as
Exhibit 25.
     112.  All of these instructions just quoted are part of the
Scientology "scriptures" Every word Hubbard ever uttered is considered
to be sacred doctrine, and Hubbard's instructions are taken quite
literally by Scientologists.  It would be entirely possible for
Scientology operatives to take these instructions from Hubbard and use
them to manipulate Fishman for their own ends.
     113.  Hubbard himself ordered that "reverse processes" (or Black
Dianetics) be run on people he felt were particularly dangerous to
Scientology.  In a 1968 issue he declared several people fair game
(meaning they could be lied to, tricked or destroyed), and instructed
that they be run on reverse processes if they ever came into an org.
Additionally, he ordered that "Any Sea Org member contacting any of them
is to use Auditing Process R2-45." This was a reference to the use of a
.45 semi-automatic pistol.  Hubbard defined R2-4s as a very fast way of
getting someone exterior to their body.  (See Exhibit 26.)  A copy of
this declare is attached hereto as Exhibit 27 (see item 7).  Hubbard ode
it clear that he did not take suicide seriously in a taped lecture
called "Create and Confront," given on January 3, 1960, as part of the
"State of Man" lecture series.  See Exhibit 28 for a transcript of
"Create and Confront," particularly pages 93 and 94.
     114.  Even if no one deliberately set out to drive Fishman
psychotic, selling him materials that would completely overwhelm him
with incomprehensible information and then putting an E-meter in h,s
hands was nothing short of criminal negligence.  There is little doubt
that Fishman used his E-meters to "audit" himself, an action that could
easily drive him into a psychotic break.
     115.  In the tape "Some Notes on Black Dianetics," Hubbard himself
described the dangers of self-auditing: "...in Dianetics you are playing
around with highly explosive material.  I would say that a person using
Dianetics in certain ways might much more happily juggle two or three
hand grenades with their pins pulled.  For instance, take some of these
people who run around self-auditing: why don't they just go get a gun?
That is much simpler and quicker."
     116.  When I was in Scientology I was assigned to keep watch over a
young girl in her early twenties who became Type 3 PTS after being
forced to sever all communication with her family, because they were
upset about her involvement in Scientology.  This incident occurred in
Hemet, California, at the high-security international headquarters of
     117.  One day this girl approached me and began to babble, making
no sense at all.  Recognizing the symptoms of someone who was going Type
3, I immediately alerted one of the security guards so that she could be
put under watch.  Sure enough, within an hour she was in a full blown
psychotic break.  She did not know who she was or where she was and she
began to get violent.  She lost touch completely with the real world and
began to hallucinate, imagining conversations, events, people, and whole
     118.  L.  Ron Hubbard wrote a series of issues detailing what to do
when someone "goes Type ..3" These issues comprise what is called the
Introspection Rundown, a rundown being a series of specific actions to
take to achieve a specific result in Scientology processing.  Hubbard
felt that the Introspection Rundown was a major breakthrough in the
handling of psychosis, and that people in mental institutions could be
cured by following these steps.  A copy of the Introspection Rundown is
attached hereto as Exhibit 29.
     119.  The first step is to isolate the person completely from
everyone except the people assigned to watch over the person.  This is
called "Isolation Watch." I was assigned to watch this girl, so I
studied the issues to ensure I would handle her correctly.  We were not
to say a word around her.  She was to have complete silence to allow her
to calm down (to allow her body thetans to go back to sleep, although
she could not be told about this, since she was not up to that level in
her processing).  This went on for many days as she was in a serious
psychotic incident.  None of the people assigned to watch her had any
formal training in dealing with psychosis.
     120.  She had no idea who she was.  One moment eke would think she
was a butterfly; the next minute she would think she was Hubbard's
daughter, Diana Hubbard.  Then she would think she was a dog, and she
would bark and growl.  We had to be very careful to watch her so that
she would not try to kill herself, and we also had to be sure she did
not get violent and hurt us or become destructive of property.
     121.  She was never referred to any mental health practitioner,
because Scientologists believe that all psychiatrists and
psychotherapists are completely evil.  Hubbard preached the evils of
psychiatry so thoroughly that no one in Scientology would ever consider
letting a mental health practitioner examine anyone, even someone who is
in the middle of a psychotic episode.  See several examples of Hubbard's
writings on psychiatry attached hereto as Exhibit 30.  This girl was not
even given anything to calm her down except a mixture of calcium and
magnesium which was supposed to relax her and let her sleep.  It did not
have that effect; this girl could hardly sleep at all and soon became
exhausted, which simply compounded the problem.
     122.  After several weeks of this, the girl finally came out of the
psychotic episode and was immediately sent back to her family to avoid a
negative public relations situation or, possibly, a lawsuit.
     123.  A more serious incident occurred when a staff member with
extremely confidential knowledge of the legal and corporate manueverings
of Scientology became Type 3 PTS.  Her name was Cat Morrow and she had
been part of a project called MCSS, for Mission Corporate Category Sort-
out that was supposed to create a corporate structure to protect Hubbard
from civil or criminal action.  Cat had information about inurement to
Hubbard and about conspiracy within the church to cover it up that would
be disastrous if it were ever leaked.  So when she had a psychotic break
it was of the utmost importance that the situation be kept quiet.
     124.  Cat was taken to the home of a wealthy Scientologist outside
of Los Angeles.  The house was surrounded with woods and there were no
other houses in sight.  There Cat- was kept under 24 hour watch, known
as "Isolation Watch" because the person is isolated from everyone except
those on the "watch." Although I was not assigned to watch her, I was
told that Cat became extremely violent on several occasions, that she
tried to jump through a plate glass window, that she repeatedly said she
wanted to kill herself, and that she had no idea who she was or what she
was doing.  This went on for several months.
     125.  I was told that when Cat came out of the psychotic break she
was audited on the Introspection Rundown.  This is a series of questions
and procedures designed to get the person to stop introspecting, based
on Hubbard's belief that this would cure the psychosis.  On someone who
is OTT, as Cat was, the Introspection Rundown is audited on the body
thetans that have gone out of control and caused the psychotic break.
The theory is that once these body thetans are disengaged from the
person's body, the person will be able to get back in control of his or
her own mind again.
     126.  Maggie Butterworth, former OSA operative David Butter worth's
wife, was usually assigned to supervise any Scientologist in Los Angeles
that had a psychotic break, and I believe that she was in charge of Cat
Morrow, in close liaison with Sandi Wilhere, a highly trained case
supervisor in CSI who used to be one of the most senior technical
experts in Scientology (Miscavige reportedly demoted her to kitchen maid
     127.  Cat Morrow's case was particularly sensitive not only because
of the information that Cat had about the church's legal affairs but
also because she was married to Jim Morrow, one of the key people
involved in dealing with the IRS.  Cat's psychosis could not be allowed
to compromise Jim's position, so her situation required the highest
security.  Normally a staff member who goes Type 3 is routed off staff
or sent to the RPF after coming out of the psychotic episode, but
because Cat had dealt with such sensitive material she was quietly
reassigned to an unimportant department where people could keep an eye
on her and make sure she remained loyal to Scientology.
     128.  A woman named Dorothy Geary was driven into a psychotic
episode under circumstances very similar to Steven Fishman's in that she
and her husband were coerced into giving Scientology a tremendous amount
of money for services they would never receive.  Her husband Robert, a
dentist in Ohio, attended a seminar given by Sterling Management
Systems, which he later discovered was a front for Scientology.  Robert
and Dorothy were both coerced into buying Scientology training and
processing after a Scientology "chaplain" orchestrated a breach between
them which threatened their marriage.  Dorothy was then coerced into
going to San Francisco for processing, while her husband flew back to
Ohio to continue his dental practice.
     129.  While Dorothy was in San Francisco she was induced to buy
nearly $100,000 worth of Scientology materials and services.  She was so
overwhelmed from the processing she received and the "hard sell" she
experienced at the hands of Scientology salesmen that after
approximately one month she had a psychotic break.  She did not know
where she was and was completely out of her mind.  Her husband helped
her to get home, but then two Scientologists came to live at the Gears'
house to try to bring Dorothy out of the psychotic episode.  However,
the only "treatment" they provided consisted of taking Dorothy for long
     130.  Finally they convinced Robert that Dorothy needed to fly back
to San Francisco.  Upon arriving in San Francisco, Dorothy was taken to
a "mountain retreat," where no one else would see what was taking place.
Dorothy was kept there for two weeks, while her husband had no idea
where she was.  Scientologists were trying to induce Robert to buy more
auditing while Dorothy was held in San Francisco.
     131.  Dorothy had been induced to buy boxes and boxes of
Scientology books and materials, all of which had been shipped to their
home in Ohio after she paid for them with credit cards.  When Robert
opened the boxes and read some of the more advanced Scientology
materials, he realized what his wife had been subjected to and called
his family doctor for advice.  His doctor gave a probable diagnosis of
an acute psychotic episode caused by trauma.
     132.  By the time the Gears' attorney helped them both to
disentangle themselves, they had given Scientology close to $180,000.
As Robert Geary described it, "This was money we obviously could not
afford to spend and without extreme undue influence there is absolutely
no way we would have ever spent such sums.  I have read a considerable
amount about mind control and now realize that my wife and I were under
mind control." A copy of the declaration of Robert Geary D.D.S.
executea September 5, 1993 is attached hereto as Exhibit 31.
     133.  There are certain people within the Church of Scientology,
particularly RTC and CSI, who have knowledge of many other cases of
Scientologists having psychotic, Type 3 PTS episodes.  These people
include the following: Ray Mithoff, whose title was Inspector General
for Technology in RTC when I left in 1989, although I have been told
that he now has the title of Senior Case Supervisor International in
CSI; Gelda Mithoff, a highly trained auditor who has dealt directly with
or supervised number of "Type 3 handling"; Greg Wilhere, whose title was
Inspector General in RTC in 1989 and who is a highly trained auditor;
Sandi Wilhere, a highly trained auditor and case supervisor in CSI who
at last report had been demoted to cook in the communal kitchen at
Hemet; and, of course, Miscavige, who supervises virtually every aspect
of Scientology, particularly anything that might threaten the public
image of the church, such as Scientologists who have Type 3 psychotic
     134.  The above-named individuals would be able to provide full
details of the symptoms and manifestations of Type 3 PTSness and would
be able to verify that Steven Fishman would never have qualified for
Scientology processing so should never have been allowed access to
Scientology materials or E-meters, certainly not a solo meter.  They can
also verify that all of the individuals who sold these materials to
Fishman did so despite the fact that Fishman had already been declared
ineligible for Scientology processing.  The only question that remains
to be answered is whether Fishman was driven to a psychotic break
deliberately, or whether it was done simply out of greed and blatant
disregard for his well-being.
     CSI's Real Motive in Filinq for Dismissal Was To Protect Its
Managing Agents
     135.  CSI claims to be concerned about allowing several Scientology
celebrities to be deposed.  CSI says it does not want these people to be
harassed by Dr.  Geertz's attorneys.  In truth, if it served CSI's
purposes to have these celebrities deposed CSI would order the deponents
to appear and not think twice about it.  This much-touted concern for
the celebrities is purely show.  What CSI is actually worried about is
that the tables have been turned on it in this case.  The Scientologists
can dish it out, but they cannot take it.  They have finally met their
match.  Dr.  Geertz's attorneys Graham Berry and Gordon Calhoun have
educated themselves, with the help of several former Scientologists,
about how this organization really operates, and they are not letting
CSI get away with its usual harassment and intimidation tactics.  This
is the real reason CSI filed for dismissal.
     136.  Dr.  Geertz's attorneys have parted the flimsy curtain of a
corporate veil honored almost always in breach to reveal the true
structure of authority in Scientology, the Sea Organization, and the
people who really run Scientology, starting with Miscavige, the managing
agent of the entire organization, and his key lieutenants, including
Norman Starkey, Greg Wilhere, Mark Yager, Marty Rathbun and Ray Mithoff.
Under Miscavige's direction, this organization has systematically
violated the civil and human rights of its members, secure in the
knowledge that because it calls Scientology a religion, it is protected
by the First Amendment.  Suddenly CSI is confronted by counsel assisted
by experts who are fully aware that the Tech is applied both secularly
and ecclesiastically.  The veil provided by the misuse of First
Amendment claims that every action by a Scientologist is religious and
beyond scrutiny by the civil justice system has been parted.  CSI's
management has been delivered a clear and compelling message.  CSI's
management knew it could not maintain its facade of respectability and
religiosity if CSI allowed this case to continue.  That is why CSI moved
to dismiss it on the eve of the trial.
     137.  Miscavige has filed a declaration in which he denies being
the managing agent of the Scientology empire.  He words his denial
carefully, using the language of the corporate shell he created to
shield his true position from the Courts.  But the truth is that he does
run it, either directly or via his key lieutenants.  This is common
knowledge within the upper echelons of the Sea Organization.
Miscavige's position of power (and the power of his lieutenants) in
Scientology is what was being protected by the filing of CSI's motion to
dismiss.  Therefore, the truth about Miscavige and the henchmen who
carry out his orders bears telling.
     Miscavige is the managing Agent of Plaintiff CSI
     138.  As stated earlier, I was a Scientologist for nearly 15 years,
from January 1975 until July 1989.  I was in the GO and its successor (a
name change only), OSA, for most of that time.  I also worked in another
part of Scientology called Author Services, Inc.  ("ASI").  I was a Sea
Organization ("Sea Org") member during my tenure on all of these costs.
     139.  All of the positions I held from 1978 until 1989 enabled me
to observe firsthand the line of command and the organizational
structure of Scientology.  There is no question whatsoever that
Miscavige now holds the same position of absolute power over
Scientology, cutting across all corporate boundaries, that Hubbard had
before he died.  Just as Hubbard was the managing agent for the original
mother church, CSC, Miscavige is the managing agent for the current
mother church, CSI, via his position as Chairman of the Board of the
Religious Technology Center ("COB RTC").
     140.  I first became aware of Miscavige in 1981, when a coup took
place within Scientology.  Until then there had been two arms of
Scientology.  The Guardian's Office was run by Mary Sue Hubbard and took
care of everything external to the organization, such as public
relations, government relations, litigation, and anything else that
might hinder the expansion of Scientology.  The other branch, the
Commodore's Messenger Organization ("COO"), ran Scientology itself under
the direct command of Hubbard (known as the Commodore).  Reality was
directly contrary to Hubbard's repeated claims that he had resigned all
management responsibility in 1966.  The CMO directed all internal
operations via an unincorporated group of highly dedicated
Scientologists known as the Sea Org.
     141.  In 1981, I was a senior executive in the United States
Guardian Office ("US GO").  One evening we were informed that the GO was
being taken over by the CMO.  From that time on Miscavige has had
complete control over all branches of Scientology.
     Miscavige Wields the Power Through a Small Circle of Lieutenants
     142.  Miscavige wields his power through a small circle of trusted
Sea Org lieutenants who obey him unquestioningly.  Until July 1989 when
I left, his most senior aides were in RTC and included Greg Wilhere, who
was the Inspector General ("IG"); Marty Rathbun, who was the Inspector
General for Ethics ("IG Ethics"); Ray Mithoff, who was the Inspector
General for Technology ("IG Tech"); and Marc Yager, who was the
Inspector General for Administration ("IG Admin").  Another top aide was
Norman Starkey, who was corporately the trustee of Hubbards estate.
     143.  Based on testimony generated in this and other cases with
which I am familiar in my capacity as a consultant and expert and
conversations with high-ranking Scientologists who have left since I
left in 1989, Miscavige has reorganized his command structure and done
away with the IG Ethics, Tech and Admin posts.  Miscavige has moved Ray
Mithoff back to his old position of Senior Case Supervisor International
("Senior C/S Int") in CSI.  He has moved Marc Yager back to his old
position as Commanding Officer of the Commodore's Messenger Organization
International ("CO CMO Int") in CSI.  From the most recent decla-
rations of Marty Rathbun and Greg Wilhere, it appears that Miscavige has
removed both of them from their posts.  They are now on the ship, the
Freewinds, probably on the Rehabilitation Project Force ("RPF"), which
is the Scientology version of a prison camp.  For some reason Miscavige
wanted both of them out of the country as this case approached trial.
This is probably because both Wilhere and Rathbun have committed acts
which may be violations of criminal and civil law on Miscavige's orders.
Many of the people designated to be trial witnesses by Dr.  Geertz's
counsel were witnesses to these unlawful transgressions.  If Miscavige's
lieutenants were to testify, they would have faced exposure to perjury
charges.  They are also aware of many wrongful acts which run afoul of
criminal and civil law of which Miscavige is directly guilty.  There is
a possibility that Miscavige's lieutenants, when faced with the prospect
of personal criminal liability for perjury for false testimony designed
to protect Miscavige, would instead abandon their mentor when placed
under oath and reveal what they know, particularly if granted immunity.
     144.  Miscavige has other top aides in CSI whom he orders either
directly or via the RTC command lines.  These CSI aides include the
Watchdog Committee ("WDC"), which is a group of Sea Org members who
manage all of the different branches of Scientology, both secular and
non-secular.  Other top CSI aides include Kurt Weiland, who is the
Commanding Officer of the Office of Special Affairs International ("CO
OSA Int"); Guillaume Lesevre, who is the Executive Director
International ("ED Int"); and Heber Jentzsch, who is a PR front man with
the title of President of the Church of Scientology International
("President CSI").  In reality, Heber has no administrative power at all
and his duties are solely to deal with media and other PR groups.
     145.  The authority of the above-named individuals comes solely
from Miscavige.  Any one of them can vanish overnight.  Any one or all
of them can be sent to the prison camp known as the RPF if Miscavige
even suspects disloyalty.  (This is undoubtedly wha.  happened to
Wilhere and Rathbun.) Miscavige's authority over RTC, CSI and (via these
two corporations) the rest of Scientology, is absolute.
     146.  Since Miscavige took over the Guardian's Office in 1981, he
has had virtually total control over the entire Scientology
organization, including all branches of Scientology management and
extending out to every single person in the world who is a
Scientologist.  No one can challenge his authority.  Miscavige can expel
anyone from Scientology literally with a snap of his finger.  In fact,
"The Sea Organization Expansion News" contains a graphic picture of
Miscavige "declaring a former Mission Holder suppressive." (See Exhibit
     147.  Miscavige derived his power directly from Hubbard, which is
why his power was and now is so absolute.  Hubbard went into hiding in
1976 to avoid the IRS.  Several government agencies around the world and
in the UPS.  and a number of former Scientologists sued Hubbard.
Miscavige gradually took over as Hubbard's eyes and ears until finally,
by 1981, Hubbard allowed him to take over entirely.
     Miscavige First Ran Scientolooy from Author services.  Inc.
     148.  In 1981 Miscavige called himself Special Project Operations
("Special Project Ops").  He set up offices in the CMO building across
the street from the big blue building in Holly- wood.  From this
position, he ran the entire Scientology operation.  He had several
people working directly with him in a unit called Special Project,
including Norman Starkey, Terri Gamboa, Lyman Spurlock, my husband
Robert Vaughn Young, myself, and others.  These people ran all the PR,
Legal and Intelligence runctions that had previously been run by the
Guardian's Office line of command.  The primary focus was the Mission
All Clear, or the MAC Unit, in the Legal Division of the Guardian
Office.  The purpose of this unit was to extricate Hubbard from all the
lawsuits that had been filed naming him as head of the church.
Miscavige was personally charged with extricating Hubbard from pending
litigation so Hubbard could come out of hiding.
     149.  Because Miscavige had the direct communication line to
Hubbard, he also had authority over all of the internal Scientology
Management personnel.  All communications from Hubbard came through
Miscavige, and all communications to Hubbard went through Miscavige.
There were only two other people more senior than Miscavige, Pat and
Annie Broker.  Their status arose because they were actually with
Hubbard.  An order from Pat or Annie had as much authority as an order
from Hubbard because they were so close to him.
     150.  But Pat and Annie were sequestered off at the Creston,
California, ranch.  Miscavige was at the center of and actually
directing Scientology activities.  He used his position of high
visibility within the Scientology command structure to run Scientology
from the moment he became Special Project Ops.
     151.  In May 1982, Miscavige and the rest of the staff of Special
Project moved to a suite of offices on Sunset Boulevard and adopted the
corporate mantle of ASI.
     152.  Miscavige appointed himself COB of ASI.  This title was for
consumption by the general public.  Miscavige continued to identify
himself as Special Project Ops in correspondence with church personnel.
Miscavige appointed Terri Gamboa Executive Director of ASI.  He gave
Norman Starkey the title Leqal Affairs Director.  Lyman Spurlock became
Corporate Affairs Director.  Miscavige gave Robert Vaughn Young the
title Public Affairs Director, and so on.  Miscavige assigned me the job
of Organizing Officer of ASI.  As such, I was responsible for making
sure the staff were doing their jobs properly.  If the staff failed in
any way, I was charged with correcting them.
     153.  During this time, and from 1981 until Hubbard died in 1986, I
observed firsthand Miscavige systematically replacing Hubbard as head of
Scientology.  Publicly, ASI was promoted as a glitzy Hollywood literary
agency dealing exclusively with the works of Hubbard.  But behind the
scenes, Miscavige was running all of Scientology from the ASI offices.
     154.  As an ASI staff member, I was instructed, and all those who
worked in ASI were also instructed, that making large amounts of money
for Hubbard was an integral part of running Scientology.  Hubbard's
written communications to ASI staff revealed that he felt nothing but
contempt for his reation, the church of Scientology.  He made it clear
that he felt perfectly justified in taking as much money out of the
church as DM and the other ASI staff could get away with.  (Hubbard
dictated all of his communications and the dictation was then
transcribed and distributed by Miscavige.  Both the dictation tapes and
the dispatches still exist, although CSI will undoubtedly deny it.)
Hubbard made it very clear that Miscavige's success or failure would be
based on how much money he could make for Hubbard, whether it came from
church coffers or other sources.
     155.  Accordingly, Miscavige made sure that as much money as
possible was taken from church accounts.  Fran Harris thought up labels,
known in Scientology as "significance," which were attached to huge lump
sums which Miscavige then ordered to be transferred from nonprofit
church accounts into ASI accounts every week.  These labels were
designed to conceal from the IRS and other governmental agencies the
true nature of the transfers.
     156.  There was never any question that the staff at the nonprofit
organizations would transfer the money as directed.  Each of these
organizations and therefore each of the staff members was junior to
Miscavige.  If Miscavige ordered it done, it had to be done.  If anyone
having responsibility over the financial accounts of the junior
organizations refused to follow orders from Miscavige he or she was
subject to immediate banishment to the RPF.  I was told by my superiors,
including Miscavige, that Miscavige was acting as Hubbard's deputy, and
that anything Miscavige ordered should be treated as an order directly
from Hubbard himself.
     157.  The only thing that ever slowed these transactions down was
making sure the significance attached to the transfer would appear
legitimate to the IRS.  Miscavige made Lyman Spurlock responsible for
working out the legal details of these transfers.  I often had to cit
down with Lyman and help him calm down after he had been ordered to
legitimize some of Fran Harris's money-making ideas.  Lyman told me that
he had had many serious disagreements with Fran about the legality of at
least some of her schemes.  In my experience, when Lyman expressed his
doubts to Miscavige, Miscavige always sided with Fran.  Miscavige's
instructions usually concluded with an order to Lyman to "make it
     158.  Miscavige also assigned Lyman the task of sorting out all of
the Scientology corporations so they would be legally defensible in the
eyes of the IRS and other governmental agencies.  It was at this point
that the huge conglomeration known as Church of Scientology of
California ("CSC"), the predecessor "mother church," was split up into
many different corporations.  Lyman worked out the whole shell,
including all the relationships between the different echelons.
     159.  Lyman arranged for the Religious Technology Center ("RTC") to
have contracts with every single corporation that uses Hubbard and
Scientology trademarks and copyrights in any way, including the
management organizations, the service organizations, the businesses that
use Hubbard's books, and so on.  The real purpose of all of these
contracts was to have a legal means by which to collect monies from
these entities, and to put anyone out of business who refused to tow the
line of Scientology orthodoxy as dictated by Hubbard or any of his
     160.  Since Hubbard's death, Miscavige has assumed the power and
authority to put out of business any Scientologist who refuses to tow
the orthodox Scientology line as he dictates it.
     161.  I worked directly with Miscavige while I was at ASI.  I was
horrified to discover that the senior-most person in Scientology, who
had daily contact with Scientologists and the public, was a ruthless,
vicious, megalomaniacal tyrant.  I had never worked with Hubbard
personally, but I learned from others who had that Hubbard was the same
way.  I was told that Hubbard was prone to the same petulant temper
tantrums that were daily occurrences with Miscavige.
     162.  Miscavige's style of management was exemplified by screaming
profanities and terrorizing the staff.  This is entirely consistent with
the Hubbard Tech which features "Ethics Presence.  n Senior managers are
taught to manage by instilling fear and terror in their subordinates.
As the most senior manager, Miscavige had to instill terror in all his
subordinates in order to be in compliance with orthodox Scientology
management techniques.
     163.  One day Miscavige gave me an insight into why he acted the
way he did.  He knew I did not approve of his cursing at the top of his
lungs.  We were having an executive meeting, and in the middle of a
sentence he suddenly turned to me, very seriously, and said, "You think
I yell loudly, but you've never heard anyone yell until you've heard LRH
[Hubbard].  I'll never be able to scream the way he does.  But Stacy,
that's the only way to get compliance." This was confirmation that he
was acting deliberately and calculatingly in accordance with the
dictates of the Hubbard Tech.  164.  I realized then that Miscavige was
trying to become as much like Hubbard as he could, and that he was
preparing to take Hubbard's place when Hubbard died.
     165.  Anyone who disagreed with Miscavige or challenged his
authority in any way was branded by Miscavige as a traitor who was out
to destroy Scientology.  This was why David Mayo was ousted, along with
most of his staff.  Many others were thrown out in l981 art 1982 arid
replaced with people Who would obey Miscavige's orders unquestioningly.
Ray Mithoff, who replaced Mayo, is today one of Miscavige's top
lieutenants.  John Nelson, head of the CMO and director of all the
Scientology organizations, was also ousted by Miscavige and replaced by
a loyal follower, Marc Yager.  Today Yager is another one of Miscavige's
top people.
     166.  Hubbard was still alive when I was at ASI in 1982, and every
staff member in ASI was required to report to Hubbard every week on the
status of his or her sector of Scientology.  week on the status of his
or her sector of scientology.  No one slept from Tuesday to Friday
because Miscavige ordered that no one could leave until he had approved
their weekly report to Hubbard.  Miscavige repeatedly rejected the
reports, insisting that they be rewritten until they were perfectly
worded to appear that Miscavige had everything fully under control.  No
one was allowed to send any communication to Hubbard that wasn't edited
by Miscavige (which meant that Hubbard effectively did not really know
what was going on from 1981 until his death).  This grueling schedule
left the entire staff in terrible shape physically, and extremely
vulnerable to Miscavige's brutal, coercive manipulation.
     167.  At that time the ASI offices were on the ninth floor of an
office building in downtown Hollywood, yet people could hear Miscavige
screaming down on the street, a block away.  It was disgusting to see
how he treated anyone he viewed as not fully "with him."
     Miscavige's Treatment of his Staff was Horrifying
     168.  Jim Isaacson, for example, was in charge of investing
Hubbard's money, and he was expected to show a profit on a weekly basis.
Anyone familiar with the investment business knows this is not a
realistic expectation, but Jim's job depended upon his showing an
increasing profit every week.  Predictably, Jim was not doing well at
all.  He was not eating or sleeping.  Miscavige was screaming
mercilessly at Jim every day.  Jim was near the breaking point.
     169.  One day Miscavige found out that Jim had lost a large amount
of money by investing incorrectly in the gold market.  Miscavige
summoned two of his top lieutenants, Norman Starkey and Terri Gamboa.
Miscavige and Starkey literally dragged Jim into the conference room.
     170.  My office was right across the hall so I heard everything
that went on.  For the next three and a half hours Miscavige screamed
profanities and wild, paranoid accusations at Jim, demanding to know who
had sent him to destroy Scientology, was he working for the IRS, was he
working for the FBI, what other enemy agents were working with him
inside Scientology, etc., etc., ad nausea.  I heard Jim repeatedly deny
the accusations, and Miscavige's response was to scream at him even
     171.  Finally Miscavige threw open the door and stormed into my
office.  He ordered me to go in and get the information out of Jim and
not let him leave until he'd confessed everything.  I'd never seen
anyone behave like Miscavige before.  (As stated above, while I was on
this post and later while I was in the RPF, I learned from others that
Miscavige's behavior mimicked Hubbard's.)
     172.  Miscavige was very frightening.  When he was worked up his
conduct was consistent with what I later learned was a psychotic
episode.  Miscavige appeared to be completely out of control.  He
screamed profanities at the top of his lungs directly in my face.
Others who went past my office kept their eyes averted and walked by as
quickly as possible.  Finally, he marched down the hall (with Norman and
Terri following) and slammed the door of his office.
     173.  When I went into the conference room I found Jim collapsed on
the table.  His eyes were glazed and he was shaking uncontrollably.
Rather than complying with Miscavige's order to continue the
interrogation, I did my best to calm Jim down, as he was clearly
terrified, and told him to go home and get some sleep.  Jim was on the
RPF within days.
     174.  Part of Jim's terror arose from the fact that Miscavige had
already sent Jim's wife, Joyce, to the RPF for refusing to go along with
his brutal treatment of staff.  I knew about this because I replaced
Joyce.  I was dispatched to the RPF shortly thereafter because I
objected to the same abuses.
     175.  No one could speak out against Miscavige's terror tactics
because there was no way to have a discussion with him on the subject.
The RPF filled up with people who tried to stand up to him.  He
surrounded himself with people who were willing to do whatever he
ordered.  I tried several times to protest and ended up in more and more
trouble as the weeks went on.  Finally Miscavige lost his temper at me
one night and threw me into my office, locked the door, and screamed at
me until finally I felt I would lose my mind if he did not stop.  I had
not slept for several days, and I snapped.
     Staff who were Critical of Miscavige Were sent to the RPF
     176.  The next day I didn't go to work, saying I was sick.  l was
afraid to tell anyone what had happened for fear that Miscavige would
separate me from my husband (another common tactic he uses, as did
Hubbard, to control people).  Unfortunately confided in someone I
thought I could trust that Miscavige was brutal, tyrannical bully.  That
person immediately reported me to Miscavige.  That night at four in the
morning there was a loud knock on my door.  It was the Scientology
security police.  They took me to the RPF.  That is how absolute
Miscavige's power is, and how immediate is the punishment for anyone who
doesn't completely submit to his authority.
     177.  Miscavige charged me with being an agent who had been sent in
to destroy Scientology.  He claimed that I was working for Michael
Flynn, an attorney who was successfully litigating against Scientology
at that time.  He ordered me to submit to what was known as a "gang-bang
sec check.  n Two very large, strong men, Andre Tabayoyon and Rick
Aznaran, locked me in a room and interrogated me for hours.  During the
interrogation, they screamed and swore at me.  They accused me of all
sorts of crimes against Scientology.  They demanded that I confess to
being an enemy agent.
     178.  Miscavige had also ordered me to do the "Running Program" as
part of the requirements for getting off the RPF.  This consisted of
running around an orange pole for 12 hours a day.  I was supposed to do
this until I had some sort of realization about what was wrong with me,
whereupon, presumably, I would stop being critical of him.
     179.  After one of the gang-bang sec check sessions, I was
extremely upset.  I was not paying sufficiently careful attention to
where I was placing my feet as I ran around the orange pole.  I ran
straight-legged into a pothole about a foot deep and smashed one of my
sacroiliac disks.  This put me flat on my back.  I was unable to walk.
I was under orders from a doctor not to move because he thought there
was a danger that I might suffer paralysis from movement before the
swelling in the disk subsided.  I paid for the doctor myself, since
Miscavige had ordered that no one give me any assistance whatsoever and,
indeed, I was not paid at all for several months on the RPF.
     180.  Despite my medical condition, diagnosed by a Scientologist
doctor, Miscavige issued orders that I be sent to Florida to get me as
far away from my husband as possible.  Miscavige said he was afraid I
would turn my husband against him.  A Commodore's Messenger burst into
my room one evening and ordered me to pack immediately so that I could
catch a flight to Clearwater that night.  I was to be transferred to the
RPF at the Flag Land Base, another Scientology compound.  I protested,
she continued to insist that I get up until I was finally able to get
her on the phone with the doctor, who told her the church would be
responsible if I ended up paralyzed.
     181.  Although Miscavige allowed me to remain in Los Angeles, I was
imprisoned, under guard, on the seventh floor of the building, so that I
could not escape and reach my husband.  We were not allowed to see each
other at all for three months, and even our letters to each other were
intercepted.  Neither of us knew what had happened to the other and it
was agonizing for both of us.  I was under threat of expulsion and I
believed that if I were expelled I would never see my husband again.  I
was deathly afraid that Miscavige would lie to my husband about me and
turn him against me.  I finally convinced Miscavige that I was not a
threat to him, and my husband and I were allowed to see each other
again.  Miscavige Rules Via the Sea Organization: There is No Corporate
     182.  Horror stories like this could be told by any Scientology
staff member who has worked in close proximity with Miscavige.  The only
people who will talk about him, however, are those who have left,
because as long as they are inside he virtually holds the power of life
and death over them.  He can separate them from the spouses, separate
them from their children, keep them from sleeping, keep them from eating
anything but rice and beans, imprison them for years in the prison camps
known as the RPF.  Miscavige's power is absolute, and it has nothing to
do with corporate boundaries.  As did Hubbard before him, he wields his
power via the Sea Organization, which is an unincorporated, fiercely
dedicated, group of Scientologists.  It is the Sea Org that actually
runs all of Scientology.
     183.  Miscavige simply uses the corporations, as Hubbard did, to
manipulate the courts, the IRS and other government agencies.  The
corporations were only created to fool the outside world, the "wog
world," as Sea Org members contemptuously call it.  Inside Scientology,
the only boundaries are the ones Miscavige chooses to create, just as it
was with Hubbard before him, and everyone knows it.  In fact, now that
Hubbard is dead, what Miscavige wants is senior even to what Hubbard
policy says.  Miscavige can violate policy and break the law whenever he
wants to and no one can stop him.  The 1982 Mission Holders' Meetinq
Illustrates the Emptiness of the Corporate shell.
     184.  Miscavige and his RTC and CSI lieutenants can walk into any
Scientology organization and order anything they want or shut it down at
whim.  Nowhere has there been a clearer illustration of the emptiness of
Scientology's corporate shell than the infamous Mission Holders' meeting
in 1982.  A transcript of this meeting is attached as Exhibit 33.
Although Miscavige's profanity and many of his and his lieutenants' less
elegantly phrased comments have been edited out, several things are
still clear.
     185.  Miscavige, who at the time was officially COB ASI, was head
of Scientology and senior to everyone else there.  The other speakers
included Lyman Spurlock, Corporate Affairs Director at ASI; Norman
Starkey, Legal Affairs Director at ASI; Ray Mithoff, Senior Case
Supervisor International in CSI; Marc Yager, CO CMO Int in CSI;
Guillaume Lesevre, ED International in CSI; Steve Marlowe, then
Inspector General of the Religious Technology Center (he was later sent
to the RPF and replaced by Vicki Aznaran, who in turn was busted and
replaced by Greg Wilhere, who has since been busted and, apparently,
replaced by Miscavige himself, holding the position of Inspector General
as well as that of COB RTC); and Wendell Reynolds, international Finance
Dictator in CSI (he was later busted and spent several years on the
     186.  Miscavige, an employee and director of ASI, and his
lieutenants, whose employment spanned RTC, ASI and CSI, were speaking
directly to a group of people who held the franchise rights to various
missions (missions being the lowest organizations on the Scientology
totem pole).  Yet there was no Scientology leaders, on Miscavige's
orders, expelled several mission holders on the spot that day for being
unhappy about what they were hearing, destroying their business with a
snap of the finger.  On Miscavige's orders the mission holders were
ordered to pay large sums of money for a promotional campaign for the
original Dianetics book, under threat of being investigated for crimes
against Scientology if they refused.  They were ordered to pay large
sums of money for many other "crimes," real or imagined, under threat of
losing their business if they refused.  The result was hundreds of
thousands of dollars paid into CSI and RTC accounts from these missions.
     187.  Hundreds of people, including many mission holders, were
expelled from the church during that time.  All people who criticized
Miscavige or refused to comply with his orders, re- gardless of status
or organizational affiliation, were subject to expulsion.  Miscavige
quickly made it clear that he could order any Scientologist, anywhere in
the world, to do anything he wanted.  See Exhibit 32 for a copy of "The
Sea Organization Expansion News," "The Sea Org Moves In!"  copyrighted
by CSI, which includes a photograph of Miscavige expelling a Mission
Holder.  There is also another photograph which shows Marc Yager,
Miscavige, Norman Starkey, Guillaume Leserve and Ray Mithoff, among
others, all identified by their Sea Org ranks even though Miscavige and
Starkey were ASI (non-church) staff at the time.  This is further
evidence that these men are managing agents of CSI, which was why Dr.
Geertz wanted them deposed in this case.
     Miscavige Personally Ordered and Oversaw the Portland Crusade
     188.  I was in the Office of Special Affairs United States (OSA US)
in Los Angeles in 1985 when a jury awarded Julie Christofferson $39
million in damages for being harmed by Scientology.  We had all expected
to win the case.  After all, Miscavige and his top aides had been up in
Portland running the whole thing directly.  How could we lose?  There
was champagne and a huge, sumptuous buffet waiting for us, as soon as we
received word on the victory.
     189.  Instead, we got word that there was a $39 million decision
against the church.  It was devastating.  Dead silence fell throughout
OSA US's offices.  For an hour, no one knew what to do.  It was the most
humiliating defeat Scientology had ever had.
     190.  And then suddenly all the OSA staff were summoned into one of
the legal offices.  Miscavige and Norman Starkey, who was Legal Affairs
Director, ASI, at that time, were on the speaker phone.  The decision
was an outrage, Miscavige told us.  He told us he would not permit it to
stand.  Every Scientologist from around the world was ordered to
Portland, immediately.  We were to spread the word by whatever means
possible, arrange transportation, raise the money, do whatever we had to
do to get the Scientologists there.  This was the beginning of what
became known as the Portland Crusade.
     191.  The staff of OSA did nothing but run various aspects of the
Portland Crusade until the judge finally declared a mistrial several
months later.  The entire operation was overseen by Miscavige and his
top staff.  Planes were chartered to fly Scientoloqists from Europe to
Portland; donations were raised to print a special edition of the church
publication, FREEDOM, about the "Religious Freedom Crusade" and
distribute it door to door to every home in Port land.  Miscavige even
ordered students to leave their Scientology courses (unheard of in
Scientology) to go to Port land.
     192.  The best time to observe how the Scientology command lines
really work is during a disaster.  The Christofferson loss of 1985 was
the biggest disaster Miscavige had ever had to deal with, and all
semblance of corporate integrity fell by the wayside in an instant.
     Miscavige Crossed All Corporations When Hubbard Died
     193.  The corporate structure was completely ignored again when
Hubbard died in January 1986.  I was ordered to ASI and briefed, along
with a roomful of others from OSA US (Church of Scientology Western
United States, or "CSWUS"), OSA Int (CSI), CMO International (CSI), Gold
(CSI) and elsewhere, by Miscavige on what had happened.  Then, although
he had no corporate authority over any of these organizations or staff,
he went around the room and gave each of us our instructions as to what
we must do in the transition to the post- Hubbard era of Scientology.
     194.  When Hubbard died, I was employed by an organization called
North Star.  This was a non-church corporation I formed to put FREEDOM
Magazine, which I edited, at arm's length from the various Churches of
Scientology for tax purposes.  I created a separate corporation based on
the advice of Scientology's lead tax attorney, Chris Cobb, Esq.
     195.  Although North Star was established as a subsidiary
corporation of CSI, in reality North Star was supposed to receive its
operating instructions from OSA US (CSWUS).  We did receive instructions
from executives at OSA, but we also received instructions directly from
ASI, including Miscavige himself.  He assigned us to do a research
project for the Hubbard biography.  At the time, we were receiving
direct orders from both OSA and ASI.
     196.  Miscavige ordered me to write the copy for a eulogy of
Hubbard.  I worked directly with Norman Starkey and Miscavige to
finalize the copy, and Miscavige gave the final approval.  Then, under
orders from Miscavige, I worked with Jonathan Epstein, a financial
banking officer who was part of CSI, to arrange for several hundred
thousand dollars to be pulled from various reserve accounts in a number
of different corporations.  These funds paid for the eulogy to be placed
in major newspapers around the country as full-page ads.
     197.  After the ads were placed, Miscavige then ordered me to
create a booklet about Hubbard to be used for promotional purposes.
Again he ordered Jono Epstein.  (CSI) to pull funds from various church
corporations to pay for a massive distribution of the booklet.  Copies
of the booklet were inserted in several major newspapers in major
cities.  Thousands of copies were mailed out.  The cost for this project
came to approximately So million and was funded by reserve accounts from
several church corporations, as ordered by Miscavige.
     Today Miscavige Has Completely Consolidated his Power
     198.  With Hubbard dead Miscavige moved quickly to consolidate his
power.  In early 1987 he removed his only remaining challengers, Pat and
Annie Broker.  He also switched his base of operations from ASI to RTC.
It was a bloody coup.  Miscavige applied the scorched-earth policy to
all who had ever had a kind word for the Brokers.  My husband, who had
worked with Pat Broeker, was sent to the RPF along with Vicki Aznaran,
Greg Ryerson, Jesse Prince, Spike Bush, and many others.  Only those who
had remained steadfastly loyal to Miscavige were allowed to keep their
     199.Today, the only people who survive are those who kowtow to
Miscavige unreservedly and completely.  He has truly become Hubbard's
successor.  He curses like him, screams like him, thinks like him, and
rules with a ruthless, iron hand and a contempt for the outside world
just the way Hubbard did when he was alive.
     200.  Just as Hubbard did, Miscavige has created many corporate
layers between him and the courts, the IRS, other governmental agencies
and the outside world in general, and he deals them like so many cards
when it is convenient.  But it is Miscavige who really holds the power,
and because he is COB RTC, RTC is the only Scientology entity with any
real power.
     201.  See Exhibit 34 for RTC Executive Directive No.  450, dated 6
September 1991, from Miscavige to all Scientologists.  The first 22
pages of this document provide a valuable glimpse of the world according
to Miscavige, bizarre paranoia and all.
     202.  On page 22, Miscavige announces a general amnesty for all
Scientologists, meaning that anyone who has gotten into trouble in the
past is forgiven and can get back on the "Bridge to Total Freedom.  This
amnesty cuts across all corporate boundaries.  The document behind it,
Inspector General Network Bulletin No.  14, is from one of Miscavige's
lieutenants, former Inspector General for Ethics RTC Marty Rathbun.
This document explains to all Scientologists how to apply the amnesty.
It also cuts across all corporate boundaries.
     203.  CSI is only a lackey corporation.  The function of the staff
members of CSI is to carry out Miscavige's orders.  If a CSI staff
member refuses to comply with Miscavige's orders he or she is removed
from post and sent to the RPF.  CSI has no more independent authority
than any other church or non-church corporation in the Scientology
network.  Its authority (indeed, its existence) is solely in the hands
of Miscavige.  If he decided to rearrange the corporate structure again
he could do away with CSI altogether and create an entirely new
corporation in its place.  This is the extent of his power over the
Scientology network, including CSI and RTC.
     204.  There is no one else who can represent Scientology.  Everyone
else is only speaking in Miscavige's place.  He is telling them what to
say and what not to say, and if they make a mistake, they will feel his
wrath.  If they make a big mistake, they will go to the RPF.  If they
ever told the courts what they really know, Miscavige would have them
expelled from scientology and labelled Fair Game, like many others
before them.
     205.  In short, the only person who is in a position to talk about
all of the inner workings of the Church of Scientology is Miscavige,
because he is the only person who will not be punished for doing so.
There is no one above him to punish him.  He alone can tell the whole
truth.  His lieutenants know the truth but can tell what they know only
if Miscavige gives them permission to do so .
     Miscavage's key lieutenants are also Managing Agents of CSI
     206.  As COB RTC Miscavige controls Scientology via several key
lieutenants who have absolute authority to carry out his orders.
Although their official positions may have changed corporately as
described above, they still wield the same degree of power.  If any of
these people have been removed from their positions recently, they can
still testify about the power they had before they were removed, and
furthermore, they can testify that it was on Miscavige's authority that
they were removed.  These lieutenants include Greg Wilhere, who held the
position of Inspector General RTC; Marty Rathbun, who held the position
of Inspector General for Ethics RTC; Ray Mithoff, who held the position
of Inspector General for Technology RTC and has apparently since been
moved to Senior Case Supervisor International in CSI; and Marc Yager,
who held the position of Inspector General for Administration and has
apparently since been moved to Commanding Officer Commodore's Messenger
Organization International in CSI.  Another top aide is Norman Starkey,
who is the trustee of Hubbard's estate and the Executive Director of
ASI.  He is also a troubleshooter for Miscavige.  Norman must be obeyed
when he is operating under Miscavige's orders.
     Ray Mithoff is a Managing Agent of CSI
     207.  Senior C/S Int Ray Mithoff is a managing agent of CSI.  He
has command lines via CSI to all churches, missions and any other
organizations that deal with the auditing and study technology of
Scientology. His primary contact points are the Senior Case Supervisors
in the various organizations. In CSI these are in CMO Int, Gold and OSA
Int.  All directives concerning the technology must be authorized by
Senior C/S Int, who in turn must get approval from Miscavige.
     Marc Yager is a Managing Agent of Cal
     208.  CO CMO Int Marc Yager is a managing agent of CSI.  He is
responsible for managing all of Scientology administratively and has
command lines via CSI to all churches, missions and other Scientology
organizations, including OSA via WDC OSA (Mike Rinder).  His primary
contact points are the executive directors of each organization, called
commanding officers in the upper management Sea Org units.  In CSI he
orders via WDC and ED Int.  All directives concerning the administration
of scientology must be authorized by CO CMO Int, who in turn must get
approval from Miscavige.
     Marty Rathbun was a Managing Agent of CSI
     209.  When Marty Rathbun was Inspector General for Ethics, he was a
managing agent of CSI.  He oversaw all ethics matters in Scientology.
Within each Scientology organization he had authority over all actions
taken by ethics officers.  He also ran the Office of Special Affairs,
which deals with all matters external to Scientology such as public
relations, litigation, intelligence actions, and so on.  OSA also has an
internal security function within the Scientology organizations, and I/G
Ethics commanded all of those functions as well.  He ran all OSA
activities via OSA Int, which is in CSI.  All directives concerning
ethics matters within Scientology organizations, and all directives
concerning OSA activities of any kind, had to be approved by I/G Ethics,
who in turn had to have the approval of Miscavige.
     Norman Starkey is a Managing Agent of CSI
     210.  Norman Starkey, Trustee of Hubbard's estate, is a managing
agent of CSI.  Starkey has been one of Miscavige's most senior
lieutenants for many years.  In 1981 Miscavige put Starkey in charge of
the Guardian's Office, running all the Scientology litigation in the
world, particularly any litigation that threatened Hubbard.  As Special
Project Legal, Starkey was one of the people most senior to the
Guardian's Office, which later became OSA Int, which is part of CSI.
     211.  In 1982 Norman Starkey became Legal Affairs Director at
Author Services, Inc.  (ASI) directly under Miscavige.  Miscavige was
COB ASI at the time and ran all of Scientology from this for-profit
corporation, a corporation which supposedly had no ties whatsoever to
the Church of Scientology.  It had no corporate ties, but in reality ASI
ran the entire church from 1982 until 1987, when Miscavige decided to
move over to RTC and become COB RTC.  This was done because it was more
defensible to run the church from a nonprofit corporation than from ASI.
     212.  When Miscavige moved over to RTC, Starkey was trustee of
Hubbard's estate.  He ran ASI and CST for Miscavige with no position
other than his initials, "IFS." He continued to send orders into the
church, but via a unit called Corporate Liaison to dilute the
     213.  In March 1985 Starkey filed a declaration in The Founding
Church of Scientoloay of Washington.  D.C..  Inc.  v.  Director.
Federal Bureau of Investigation.  et at.  in which he attempted to cover
up Hubbard's role as managing agent of Scientology (attached as Exhibit
35).  As part of his declaration he provided a white-washed version of
how Author Services, Inc.  was established, describing it as if he and
Terri Gamboa just thought of the idea one day out of the blue, as
opposed to Hubbard ordering every last detail of the company and how it
would operate.  He also attempted to distance ASI from the network of
Scientology organizations, falsely stating that ASI was not in the
business of managing the Church of Scientology, although all aspects of
Scientology management were at that time run out of Miscavige's office
at ASI.
     214.  But in paragraph 7 of his declaration Starkey made a
startling admission, namely that the Sea Organization called upon him
"from time to time" to render his services "to the propagation of this
     215.  What this means, and what is still the case, is that as the
senior officer of the Sea Org, Miscavige can order Starkey to carry out
whatever orders he deems appropriate, including but not limited to
directing the affairs of CSI and, via CSI, other Scientology
     216.  As the head of ASI, Starkey ran programs and projects that
were initiated by his juniors at ASI who were ordering church personnel
in writing, in person, and on the phone on how to conduct business
within the church to produce income for ASI (and, therefore, Hubbard).
All of this was done with the knowledge and consent, if not under the
direct orders of Miscavige.  Regular reports were made by ASI staff to
Starkey regarding the programs, projects and orders he issued that
involved CSI staff and operations.
     217.  CSI President Heber Jentzsch received orders regularly from
Miscavige and Starkey on how to conduct his office and how to conduct
public relations actions as if they were his own ideas (so as to hide
the command lines from Miscavige and Starkey).
     218.  Church staff also know that disclosure of the relationship
between Starkey and CSI or any admission that ASI was in direct command
would have been reason to remove them from their position and have them
transported to the Rehabilitation Project Force.  (People on the RPF are
kept under 24-hour guard to keep them from escaping.)  Miscavige Ordered
This Case Dismissed To Protect himself
     219.  Dr.  Geertz and Mr.  Fishman would have won this case on its
merits had it gone forward.  Instead, the Scientologists staged an
elaborate charade to avoid having the truth come out r.ot only at trial
but also in depositions or Miscavige ar,d his key lieutenants.  They
thought they would be able to win this case easily and then use it in
their 48S million suit against Time magazine.
     220.  But they have finally met their match.  Dr.  Geertz's
attorneys Graham Berry and Gordon Calhoun educated themselves, with the
help of several former high-level Scientologists, about how the
organization actually works.  They discovered what the structure of the
organization really is, that the Sea Organization runs Scientology, and
that Miscavige runs the Sea Organization.  They successfully pierced the
corporate veil, and the Scientologists saw that if they allowed this
case to go to trial, their carefully created public persona would
explode into a thousand pieces and they would be exposed for the
criminal conspirators they really are.  This is why they sought to have
this case dismissed.  It had nothing to do with any concern for the
Scientology celebrities whatsoever.
     221.  Miscavige feared that his own perjury and criminal actions
would be exposed, and he ordered the attorneys on this case to do
whatever they had to do to get rid of it before he had to testify either
in deposition or at trial.  No one but Miscavige has the authority to
have ordered the Scientology attorneys to file for dismissal.  Without
any doubt, Miscavige personally orchestrated the dismissal of this case.
See Exhibit 36, "Report of the Board of Inquiry into Scientology," by
Kevin Victor Anderson, Q.C., the lieutenant governor of the State of
Victoria, ir the Commonwealth of Australia.  It is a thoroughly
researched report on the dangers of Scientology, and includes an account
on pages 134 and 135 of a woman who was "processed into insanity." This
report led to Scientology being banned in Victoria for a number of
years.  Although the ban was later lifted, the report remains an
excellent overview of the Scientology cult.
     I declare under penalty of perjury under the laws of the United
States of America and the State of California that the foregoing is true
and correct.
     Signed - (Stacy Brooks Young)
Homer Wilson Smith           This file may be found at
homer@rahul.net              ftp.rahul.net/pub/homer/act/CD20.MEMO
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