((My comments in double parentheses - Homer))
                          DAVID MAYO AFFIDAVIT
                                CD - 23
                            14 October 1994
                     Copyright (C) 1994 David Mayo
       Redistribution rights granted for non commercial purposes.
     I, David Mayo, declare as follows
     1.  I submit this Declaration in opposition to Plaintiffs' Motions
for Partial Summary Judgment based upon personal knowledge of the facts
contained herein and, if called upon as a witness, I could and would
competently testify thereto From 1959 to 1983, I was affiliated with the
Church of Scientology and, although officially designated as a "staff
member," throughout the period of my affiliation I was paid typically
only $10 to $22 per week for full time work for the Church.  In
February, 1983, I left the Church after being subjected to a six-month
period of forced captivity and torture involving physical abuse and
emotional distress imposed because of voicing concern about unethical
and criminal activities being committed by officials of the Church
     2.  I have never been offered, nor have I ever requested, immunity
from criminal prosecution in exchange for providing information,
cooperation, or testimony with regard to criminal prosecution or legal
action by the IRS or any other public agency against the Church of
Scientology, the Religious Technology Center or any of their affiliates
     3.  I have never been charged with or convicted of any criminal
offense I have never been informed that I was the subject of a criminal
     4.  And and all testimony given by me in any legal action by
federal authorities against the Church of Scientology, the Religious
Technology Center, or any of thier affiliates was pursuant to subpoena
by a public investigative agency
     5.  In October 1982, a "Committee of Evidence" was convened by
plaintiff Religious Technology Center to consider a charge against me of
"sexual or sexually perverted conduct." The Chairman of the Comittee of
Evidence was Ray Mithoff (As the subject of the inquiry, I received a
copy of the convening order, a true and correct copy of which is
attached as Exhibit "A" )
     6.  The Committee of Evidence according to its "Findings and
Recommendations", dated January 29, 1983, "met extensively, reviewing
all evidence and data submitted, and conducting its own investigations
where needed to determine the guilt or innocence of each interested
party" regarding the charges made in the October 9, 1982, order
convening the Committee It noted that I pleaded NOT GUILTY to
specification No 5, "Sexual or sexually perverted conduct" and "the
                                                                  PAGE 2
committee found insufficient evidence to substantiate the charge." (I
received a copy of the "Committee of Evidence Findings and
Recommendations," a true and accurate copy of which is attached as
Exhibit "B".  )
     Gregory Ryerson, a staff member of the Church of Scientology
International, has falsely certified Plaintiffs' Exhibit "B" as a true
and correct copy of "Findinqs and Recommendations of the Comittee of
Evidence" See, Declaration of Gregory Ryerson In Support Of Plaintiffs'
Motion For Partial Summary Judgment Regarding Defendant David Mayo's
Counterclaim For libel, signed under penalty of perjury, dated April 16,
1987 Plaintiffs' Exhibit "B" is a pastiche As such, it is not a true and
correct copy of the "Findings And Recommendations Of The Committee of
Evidence "
     7.  Vero Dantas, husband of Lecia Westerman, did not become ill
because of auditing by me or anyone associated with the Church of the
New Civilization at the Advanced Ability Center or elsewhere.
     8.  Plaintiffs stated in an Executive Directive, SO ED 2445 INT,
dated February 13, 1984, "Cancellation Of All Telexes, Despatches,
Cramming Orders And Verbal Tech Issued by David Mayo," p 2, # 4, that,
"In 1980 Mayo tried to position himself as the source of LRH's
miraculous tech breakthrough of Solo NOTs in a long lecture that he
gave.  He then issued the transcript of it as a Flag Information Letter
and ordered people to study it, as a 'reference'" I recognize this
document as an official document of the CSI issued on blue paper with
blue ink and carrying the following CSI designation
     CSI:AVC:RM: iw
     (C) 1984 CSI.
     All Rights Reserved
     (A true and correct copy is attached as Exhibit "C" )
     9.  The quoted matter in paragraph 8, above, refers to Flag
Tnformation Letter 383, December 1980, authorized by AVC INT and
approved by WDC for the Boards of Directors of the Churches of
Scientology.  I did not "issue" the transcript of the lecture.  The Flag
Information Letter itself clearly states that it was authorized and
approved by and for the Boards of Directors of the Churches of
Scientology.  Throughout the lecture, for reasons set forth below, I
gave full and complete credit to L Ron Hubbard as the source of Solo
NOTs.  At no point did I try to position myself as the source (A true
and correct copy of Flag Information Letter 383 is attached as Exhibit
     10.  The technology of Dianetics and Scientology is a product of
the efforts of many people, including myself, and among others, Melanie
Murray, Julie Mayo, Merrill Mayo, Dona Haber, Brian Livingston, and
Phoebe Mauer.  Moreover, I am the primary source of NOTs and SOLO NOTs
     11.  During my affiliation with the Church of Scientology, I only
attributed discovery and authorship of the tech to L.  Ron Hubbard
because I was compelled to do so as an article of faith of the Church.
                                                                  PAGE 3
It is the policy of the Church to require all tech to be attributed to L
Ron Hubbard
     12.  At no time have I been in the employ of L Ron Hubbard.
     13.  In February 1983, I left the Church of Scientoloqy.
Thereafter, the Church of Scientology, the Religious Technology Center,
and their agents and affiliates began a campaign of harassment and
intimidation against me and persons who associated with me.
     14.  On August 29, 1982, David Miscavage, and others, acting on the
orders of L.  Ron Hubbard, kidnapped me and subsequently kept me captive
and physically and mentally abused me for six months During this period,
David Miscavage, an officer and director of RTC, told me in the presence
of Vicki Aznaran, President of RTC, Mark Yaeger, Commanding Officer, CMO
INT of CSI that if I ever escaped, he would personally see to it that
the resources of the Church of Scientology would destroy my character
and reputation internationally.  During that six-month period of
captivity, I was forced to run around a tree in the desert in
temperatures of up to 110 degrees for 12 hours a day, 7 days a week for
3 months I was under tremendous coercion and duress I was refused
medical and dental treatment (after escaping captivity I lost six teeth
and required thousands of dollars of dental work to save the rest of my
teeth) I was not permitted to make or receive phone calls and all
letters I wrote were read by Scientology security guards I was often
awakened during the night and interrogated (mainly by Jesse Prince) In
early February 1983, I was told by Rick Aznaran, Director of Security,
RTC, (husband of Vicki Aznaran, President of RTC), to get the idea of
leaving out of my head because I would never leave the property alive.
     15.  From 1983 through to the present, Plaintiffs have engaged in a
concerted campaign to destroy me in accordance with the Scientology
"Fair Game Law," which allows opponents of the Church to be "deprived of
property or injured by any means by any Scientologist without any
discipline of the Scientologist.  May be tricked, sued or lied to or
destroyed ."
     16.  As part of the campaign of harassment and intimidation against
me, the Church of Scientology, the Religious Technology Center, and
their affiliates and agents employed a team of private detectives who
harassed parishoners and staff of the Advanced Ability Center, Santa
Barbara, California, and who falsely misrepresented themselves as
federal agents and conducted campaign of disinformation about me to the
parishioners of the Cnurch of the New Civilization, potential
parishioners of the Church of the New Civilization, the staff and the
friends and relatives of the staff of the Advanced Ability Center, and
among persons with whom I and the Center conducted religious services
and training.
     17.  I was in extreme danger and under substantial duress during
the six-month period of captivity and torture.  The duress affected me
even after my escape.  I felt harassed and intimidated.  When I left/was
expelled in 1983, I had no job qualifications (other than related to
Scientology), negligible savings, was not eligible for unemployment (nor
                                                                  PAGE 4
social security) and had no job prospects.  I had no friends or
acquaintances who were not scientologists and all Scientologists were
required to "disconnect from" (ostracize) me.
     18.  I have received many letters from people claiming to be
Scientologists who announce that they are disconnecting from me (True
and correct copies of a representative sampling of these letters are
attached as Exhibits "E-L" )
     19.  During this time I was barely able to cope, but was at all
times greatly distressed and upset.  In 1984, when the Church of the New
Civilization was doing exceptionally well, a new and even more concerted
campaign of harassment began Involving not only personal attacks on my
character and reputation, but also against everyone I knew and with whom
I have associated.  Durinq the summer of 1984, things became almost
unbearable.  My distress, feelings of helplessness and despair were
overwhelming and continued to grow as each new insult was added.  These
troubled days continue to have a toll on my peace of mind, which was
reinforced with each new act of harassment.
     20.  As part of the campaign of harassment and intimidation
launched against me by the Church of Scientology, the Religious
Technology Center, their affiliates and agents, certain publications,
among which are "The Story of a Squirrel," the "Writ of Expulsion and
Suppressive Person Declare," and the 'Squirrels' Executive Directive,
which make false, scurrilous accusations against me have been published,
circulated and distributed to Scientologists, to former Scientologists
and to others who have connections with me or the Church of the New
Civilization and the Advanced Ability Center.
     21.  In September 1983, I received the letter signed by Lecia
Dantas, nee Westerman, a true and correct copy of which is annexed
hereto as Exhibit "M".  After receiving the letter, I telephoned her and
we discussed the letter.  I called her at the number I knew to be hers
and I recognized her voice.
     22.  As documented by other Declarations concurrently filed herein,
missionaires from the Religlous Technology Center and the Church of
Scientology are still distributing packs containing, among other
malicious documents, "The Story of a Squirrel." the "Suppressive Person
Declare," the "Westerman Public Announcement," and letters and documents
referring to those publications.
     23.  On average, for me, one-half of each working day during the
active functioning of the Church of the New Civilization was consumed
with responding to inquiries from parishioners and potential
parishioners regarding the false and malicious charges made against me
and with dealing with agents of the Church of Scientology or the
Religious Technology Center sent to infiltrate and disrupt the Church.
As a result of these responsive actions required on my part, I was
unable to attend to my duties at the Church and Center and was unable to
develop new parishioners and to attend to retention of existing
                                                                  PAGE 5
     24.  As a result of the false and scurrilous accusations made
against me by the Church of Scientology and the Religious Technology
Center, their affiliates and agents, the parishioners of the Church of
the New Civilization were lost and new parishioners were deterred from
coming to the Church while it was active.
     25.  Because of the campaign of harassment and intimidation
directed at me, at the Church of the New Civilization and Advanccd
Ability Center and its staff and at parishioners, potential
parishioners, and supporters of that Church, income was lost to the
Church and to me, individually.
     26.  At no time have I sought to make my differences with the
Church of Scientology a public issue Any publicity generated involving
the Plaintiffs and their campaign against me has been only in response
to that campaign.  The only public=20 statements made by me which could
be construed as antagonistic to the Church have been made in internal
publications of the Advanced Ability Center or during "Sunday talks"
presented at the Advanccd Ability Center in which I responded to the
Church's accusations and sought to clear my name of the false and
denigrating statements made against me.
     Executed on this 1st day of May, 1987, at Palo Alto, California
53474-001 LP04247-A40
Homer Wilson Smith           This file may be found at
homer@rahul.net              ftp.rahul.net/pub/homer/act/CD23.MEMO
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