Declaration of Vicki J. Aznaran (Sell-out No. 2) (May 19, 1994)

I, VICKI J. AZNARAN, hereby declare as follows:1

1. I am over 18 years of age and a resident of the State of Texas. I have personal knowledge of the matters set forth herein and, if called upon to do so, could and would competently testify thereto.

2. From 1972 until 1987, I was a member of various Church of Scientology (“Church”) entities. During that time I held a number of important positions in the corporate and ecclesiastical hierarchy of the Church. I was also a devout believer in the religion of Scientology. In March of 1987, my husband Richard Aznaran and I left our positions with the Church and returned home to Texas from California. At the time we left, Richard and I voluntarily executed certain releases and waivers in full settlement of any and all disputes we had with the Church. In April of 1988, notwithstanding our execution of those releases and waivers, Richard and I filed a lawsuit against several Church entities and individuals in the United States District Court for the Central District of California.

3. During the time I was a senior Church executive, I gained first hand knowledge of the manner in which some apostate former Church members had pursued civil claims against the Church, and obtained successful verdicts or judgments or favorable settlements notwithstanding the merits. The courts consistently allowed the Church’s adversaries leeway to introduce allegations without regard to the normal rules of procedure and evidence. At the time, this was a source of great concern to me, both as a Scientologist and a Church executive, particularly

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since my staff duties included responsibilities regarding certain areas of litigation.

4. Thus, having participated in Scientology litigation both as a Church executive and as a litigant against the Church, I bring two distinct, but related, perspectives to this declaration from my personal knowledge and observation. First, at the time my husband and I brought our own suit I understood that the legal system could be used to pursue my position. Later, upon having sued various Scientology churches and having allied myself with other litigants and their counsel suing Scientology churches, I observed first hand the ways in which the legal system is successfully used by litigants and counsel opposing the Church.

5. The fundamental premise upon which the Church’s adversaries and their lawyers operate is the likelihood that courts and juries are willing to believe any allegation made against the Church by a former member, without regard to plausibility, contrary evidence or the true facts. That concept was most succinctly expressed, on videotape, by anti-Scientology litigant, Gerald Armstrong, when he stated that a lack of documents or evidence was no impediment to litigating against the Church when the litigant can “just allege it.” The active pursuit of that litigation approach has now led to the formation of a small group of disaffected Scientologists who are now employed by an even smaller number of attorneys who are making a practice of litigating against the Church. This stable of witnesses can be relied upon to furnish “corroboration” for any allegation which an attorney wishes to make against the Church in

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pleadings at deposition, in affidavits, and ultimately in trial testimony.

6. The process of “just alleging it” begins with the complaint. For example, in the complaint which was filed on our behalf against the Church, there were numerous allegations which were either false or which we could not substantiate. When I was initially deposed in our case, I conceded that numerous portions of the complaint should not have been drafted by counsel in the fashion they were. Thus, for example, in deposition in June, 1988, I testified that the allegation in paragraph 7 of our complaint, that the “[Church] organizations were created solely for the purpose of making money from the sale of copyrights of the book Dianetics…” was not true. I testified that I did not create corporate structures within the Church and that I do not know where this allegation in paragraph 16 of our complaint came from.

7. There were several other improper or incorrect allegations which should not have appeared in the complaint that I had to acknowledge in deposition. As another example, the complaint alleged in paragraph 16 that I worked for Author Services, Inc., in managing the sales of copyright of the book Dianetics. In deposition I testified that I never worked for Author Services, Inc. and was not aware of any such sale of copyrights.

8. Paragraph 16 of the complaint included the allegation that I had been employed as a “missionaire” to remove assets of Defendant Church of Scientology of California to overseas trusts where they could not be accessed. This allegation was false, and

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it was not an allegation that either my husband or I requested be included in the complaint. I was definitely not employed for that reason, and I have never claimed that I was.

9. It was also alleged in paragraph 16 of the complaint that I was employed as a “missionaire” to “set up sham corporate structures to evade prosecution generally.” This allegation is also false. I was never employed for that purpose. I had never even heard of that allegation until I read it in the filed complaint. I did not make that allegation, and I do not know where it came from.

10. Paragraph 12 of the complaint contains the false allegation that my husband and I were forced to “involuntarily abandon [our] identities, spouses, and loyalties…” My depostion testimony established that this was not the case. For example, my husband used to engage in his hobby of target shooting during his years in the Church. We had pets, including a German shepherd which my husband trained in his spare time. I took riding lessons. I also trained in karate, because I was interested in learning that discipline. These were all ways in which my husband and I expressed our individuality while on staff and demonstrate no abandonment, forced or otherwise, of our individual interests.

11. My husband and I both testified to numerous separate, factual errors in the complaint. Our attorney firm, Cummins & White, and later our subsequent counsel, Ford Greene, were aware of these errors to which we testified. Even though we asked them to, no attempt to file a corrected or amended complaint was ever made, nor did any such correction ever occur.

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12. The abusive device most consistently utilized by litigants and counsel adverse to the Church occurs in connection with the filing of declarations or affidavits. It is common knowledge among the stable of disaffected ex-Scientologists who supply such sworn statements that the attorneys dictate the desired content of such testimony with the primary, often sole, purpose of presenting inflammatory accusations that prejudice the Church in the eyes of the court. In such declarations or affidavits, context, the truth, and relevance to the issues in the case are disregarded altogether. As time has passed and this technique has evolved, anti-Church litigants and their counsel have become more and more emboldened in making such declarations and affidavits because the tactic has proven to be so effective in poisoning courts and juries against the Church.

13. The most common and probably the most devastating manifestation of this tactic is the use of allegations concerning the so-called “Fair Game” policy of the Church. The term “Fair Game” has been misrepresented and repeatedly used by the Church’s litigation adversaries as a means to create prejudice against the Church. To accomplish that end, counsel fashions a declaration in which the witness identifies an ugly event — real, imagined, or just plain invented — and then alleges that it was a deliberate act which was committed by the Church. The idea is to create the false impression that the Church is committing acts of retribution in pursuit of “Fair Game.”

14. A central element of exploiting the “Fair Game” tactic is to make certain that the allegations are crafted so they cannot be objectively disproved. In other words, the declarant

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makes an allegation of a bad or harmful or harassing act that cannot be documented in a tangible form and then alleges that it was done by the Church pursuant to the Fair Game “policy”. By so doing, the declarant has put the Church in the impossible position of trying to prove a negative and trying to prove it without documentation. It becomes a matter of the declarant’s word against that of the Church, and by making the act alleged sufficiently despicable, the result is prejudice against the Church.

15. The Fair Game policy was a policy to forward Scientology’s belief that any attacks on Scientology by those seeking to destroy it were to be vigorously defended by legal means and never ignored. It was not a policy condoning or encouraging illegal or criminal activities. The policy was misinterpreted by others and was thus canceled. It has since been used by litigants over the years as a vehicle to give credibility to allegations to try to prejudice courts against Scientology. An event happens such as someone’s wife dies in a car accident, and the allegation is made that this is a murder committed by the Church pursuant to “Fair Game” policy. This technique is known to those who attack the Church and so they continue to use this term to try to prejudice the courts. These people feel comfortable making scandalous allegations, knowing that the Church does not have such a policy. I am unaware of any allegations of “Fair Game” being made by persons who have simply left the Church. Rather, the charges of Fair Game are invariably made by parties who have subsequently become involved in litigation with the Church and who have started working with

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other anti-Scientology litigants familiar with this tactic.

16. It has been my experience that these litigants and lawyers become emboldened because the history of Scientology litigation demonstrates that virtually any charge leveled against the Church in litigation by an avowed enemy, no matter how outrageous or unfounded, will be accepted and believed. Based on my experience it is a matter of common knowledge that efforts by the Church to refute such prejudicial allegations have commonly not been believed in the courts.

17. Thus, it has become a routine practice of litigants to make accusations against the Church, including even false allegations of threats of murder, which would be summarily thrown out of court as unsupported and scandalous in other litigation. They do it because it works, and they do it by deliberately mischaracterizing the term “Fair Game”. They do it as an intentional means to destroy the reputation of the Church in the context of litigation so that they can win money or force the Church to settle.

18. The term “fair game” has become a catch phrase for those who attack the Church. When I was in the Church I never heard it referred to as a policy to be used, the only time it was discussed was in reference to litigation in which it was being alleged by Church adversaries. When I was in the Church, I knew that litigants opposing the Church were constantly making fair game allegations against us and that those allegations were nonsense. I also know the frustration those allegations caused because of the willingness of courts and juries to embrace them. From my experience in litigating against the Church, I can see

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that nothing has changed in this regard. I also know from my experiences in suing the Church and from my association with other litigation adversaries of the Church that they know that “Fair Game” as they portray it is not Church policy. “Fair Game” exists only as a litigation tactic employed against the Church.

19. There are other things I have seen and experienced in anti-Scientology litigation that seem very unusual to me. There is a group or “team” of anti-Scientology witnesses who are being paid for their testimony, and based on my experience, this testimony is being altered and falsified, either by the witnesses themselves or the attorneys. For example, Graham Berry, counsel of record for a defendant in the case of CSI v. Fishman, filed numerous declarations from ex-Scientologists after the lawsuit was dismissed which had been purchased for many thousands of dollars. Mr. Berry told me that these payments were made possible because his client had insurance coverage.

20. In February of 1994, Mr. Berry called my husband and me and offered to hire us at the rate of $125 per hour for us to study materials in the Fishman case and to write declarations supporting issues Mr. Berry wished us to support in the Fishman case. Mr. Berry gave us an advance of $2,500, which we were expected to bill against services rendered. He told us that because his client in the Fishman case had insurance coverage, the insurance money enabled him to do this. He said he was able to get the insurance company to pay our salaries by naming us as “experts”, which also enabled the use our declarations without regard to whether we were actually witnesses to the events at issue in the Fishman case, which we were not.

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21. Mr. Berry told us he had assembled a team of former Scientologists for use in litigation, all of whom were employed by him in the Fishman case as so-called experts. Although we were not eager to get involved in Fishman’s litigation, we agreed to do because the $2,500 advance by Mr. Berry was attractive. Mr. Berry sent us some documents from the court record in the Fishman case, which I read, since I was being paid $125 per hour to do so.

22. I know from subsequent conversations I have had that Andre Tabayoyon is similarly employed, as are Vaughn and Stacy Young and others, each paid to create declarations for Mr. Berry when he needs them. On the basis of my knowledge of the Church and the declarants, I can state that these individuals are not “experts’ in any recognized sense of the word as I understand it. They are nothing more than witnesses who are being paid to make sworn statements against the Church. More than just being paid, they are actually employed by Mr. Berry as a source of signed declarations of testimony or as a “source” of allegations, the need for such is decided by him.

23. Later in February 1994, Mr. Berry called us again. He said that the Church had dismissed the Fishman case and he needed declarations from us on an immediate basis for use in his motion to recover attorneys fees and costs. I thought this was odd, since it seemed to me that one would support such a motion with receipts, bills, invoices, and such. Even though it seemed senseless to provide declarations after the case was dismissed, I told him I would provide a declaration because he had already paid and I would rather have done this than return the money he

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had paid us. He then told us what areas of testimony he wanted us to cover in the declarations. Accordingly, I transmitted to Mr. Berry’s firm a eight-page declaration which I had prepared on my word processor and signed on the last page bearing the date of February 24, 1994.

24. I recently learned that Mr. Berry actually filed a nineteen-page declaration purportedly signed by me. Mr. Berry attached my signature to a declaration which I never saw or authorized.

25. Passages inserted without my knowledge or authorization in the version of my declaration filed by Mr. Berry include statements that are untrue and/or about which I have no personal knowledge. Not only did I not make these statements, I never heard of them before. The following are some examples of these falsities:

a) In my declaration there are statements concerning “Project Quaker” which are false. In fact I have never heard of “Project Quaker,” and the statement in the version of my declaration Mr. Berry filed (paragraph 7) was not in the declaration I sent to Mr. Berry. It could not have been as I have never heard of “Project Quaker”;

b) The statements in the filed declaration concerning the death of Michelle Miscavige’s mother were added to without authorization by me. This included mention of the death of Heber Jentzsch’s wife which is not something I had ever spoken to Mr. Berry about, and I have no knowledge and never heard anything

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that indicated there was anything unusual about Mr. Jentzsch’s wife death. She died of natural causes. The statement concerning Flo Barnett’s death were not put in context and were not meant to imply that there was any wrongdoing surrounding her death. In approximately September 1985, when I was the Deputy Inspector General of Religious Technology Center (“RTC”), I learned that Mary Florence Barnett, Mrs. Miscavige’s mother, had committed suicide. She had been involved with a group of disaffected former Scientologists who practiced altered versions of Scientology. I only know that after hearing about her death both David and Shelly Miscavige were very upset over the fact that Flo Barnett had killed herself. I also wish to make known that I have seen mention in an affidavit by Vaughn Young that David Miscavige ordered the matter “hushed up.” This was stated in the context of indicating wrongdoing on Mr. Miscavige’s part and insinuating he had some participation in the matter. A careful and literal reading of the statment shows that Mr. Young never actually says he knows Mr. Miscavige was involved in this suicide, or that there was any evidence of such, but by innuendo his statement still leaves this impression. To my knowledge there was never any order by David Miscavige or anyone else to keep the matter quiet. If any such order existed it would most likely have been given to me. And since I took actions to make the matter quite well known and

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never heard anybody, let alone David Miscavige, ask for the matter to be hushed up, I know this statement and the innuendo to be false;

c) the entirety of paragraph 16 on page 10 of the declaration filed by Mr. Berry concerning L. Ron Hubbard and the IRS was written by someone other than me and was inserted into my declaration without my knowledge or authorization. This entire paragraph makes unfounded and outrageous allegations intended to create the impression that David Miscavige or any other Scientologist would want Mr. Hubbard to die in order to avoid supposed IRS problems. This is unthinkable to any Scientologist, and I never heard this or any similar statement made by anyone in the Church.

d) Paragraph 15 of the declaration claims that “Earle Cooley Esq. and others convinced the San Luis Obispo coroner not to do any autopsy on Hubbard’s body” implying there was something hidden or covered up about Mr. Hubbard’s death. This is false. It was not written by me and I know of no such thing. I was in a position to have knowledge of this matter and I know that Mr. Hubbard died of natural causes and the statement attributed to me is a complete fabrication.

e) There is also a statement made in paragraph 18 that Mike Rinder’s child received “Hubbard’s baby care technology.” The implication is that the child’s death had something to do with Scientology which I never believed to be the case. I did not make this statement and have no

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information that this was the case.

f) In fact, paragraphs 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35A and 35B were not in the version of the declaration that I sent to Mr. Berry to be filed. He added them after the fact, and I never saw them before this declaration was filed and I never gave authorization for Mr. Berry to add any of these things to my declaration.

g) The statements concerning the Church of Scientology International (“CSI”) and whether the Time article concerned CSI, and the corporate structure of the Church (paragraph 20) were also not in the version I signed and sent to Mr. Berry. And again, I know the statement to be entirely false.

h) One other point I wish to clarify concerning the use of “End of Cycle.” There is nothing in Scientology writings which relates the term “End of Cycle” to connote murder or suicide. To my knowledge, this characterization of the term “End of Cycle” was invented by Steven Fishman. I have never heard this term used by the Church to mean “suicide” or “murder” and even though I am a disaffected ex-Scientologist, I know it to be a false allegation. Its only use is to smear the Church for litigation purposes as detailed earlier. I earlier verbally told Mr. Berry this when he first contacted me for this exact information.

26. I gave no authorization for my declaration to be changed after I sent the signed copy of it to Mr. Berry and the changes made to my declaration were made without my knowledge or

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consent. Mr. Berry never contacted me after he filed the manufactured 19 page version of my declaration. Had I not later obtained a copy of the declaration filed by Mr. Berry from another source, I never would have found out about any of these alterations.

I declare under the penalty of perjury under the laws of the United States of America, and under the laws of each individual state thereof, including the laws of the states of California and Texas, that the foregoing is true and correct.

Executed this 19th day of May, 1994 in Dallas, Texas.

[signed]
VICKI J. AZNARAN

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Notes

Affidavit of Vicki J. Aznaran (January 27, 1992)

I, Vicki J. Aznaran, of Mesquite, Texas, U.S. Citizen, Passport No. 03197042, do herewith depose and swear:1

1. That from the approximate dates of 1984 until 1987 I held the positions of President and Chairman of the Board of Directors in the Scientology organization called the Religious Technology Center, INC, (RTC) which is now the senior governing entity of the International Church of Scientology, the Church of Scientology of California, and all affiliated organizations within the U.S., as well as senior governing entity for all foreign Scientology organizations and the civil associations of Scientology such as those called Dianetica or Narconon in Spain.

2. That despite efforts to cloak the fact, the true role of the Religious Technology Center, Inc. is that role explained above, and it holds this managerial position within the matrix of all of the interrelated organizations of Scientology: The Church of Scientology International, Inc., The Church of Scientology of California, Inc., The Church of Spiritual Technology, Inc., Authors Services, Inc., Missions International de Scientology, Inc., Religious Technology Center, Inc., Authors Family Trust, Asociacion Civil de Dianetica, Asociacion Civil de Narconon.

3. That these various organizations exist in this manner to provide an ” arm’s length” appearance in order to protect the current board of directors from actual legal culpability for any illegal acts committed by or through the churches of Scientology or any of their other affiliated organizations, as well as to confuse any issues, investigations or litigation which might expose the illicit actions of any individual Scientology orqanization or member thereof.

4. That as a former senior executive of this body, from 1984 until 1987, I have observed and have certain knowledge of the activities of RTC and of its finances as well as its manner of incorporation and related documents.

5. That during the period of my employment by the RTC I reported to David Miscavige, who was at that time Trustee of the corporation. Miscavige maintains absolute control over all officers and board members of this corporation, controlling these other members of the board of directors by fact of his possessing undated, signed resignations of each member, the holding of which gave and gives him complete control over each member of the board.

6. That also, to my certain knowledge, David Miscavige conceived, planned and ordered the implementation of the basic strategic and tactical actions of the church against those whom he considered to be causing legal or public relations conflicts against any church or against his personal and absolute control of Scientology. He also ordered the allocation of and made available funding for the financing of these actions, which included the declaring of those whom he considered to be his “enemies’ as Suppressive Persons, the implementation of the policies known as “Fair Game” against these persons once so declared, the infiltration of private and governmental environments which he deemed hostile to his absolute control over Scientology, the organization of vigilante groups within the organizations of Scientology to be used against those individuals whom he deemed to be his enemies.

7. That following Miscaviges’ orders, I transferred monies to Spain, and witnessed briefings by Miscavige to Heber Jentszch, who was in fact the “puppet” president of the church, but who actually is a .camouflage for Miscavige, concerning covert operations taking place in Spain against former Scientologists and concerninq false testimony and concerning the attempt to offset a rumored investigation by the spanish authorltles lnto the activities of Scientology in Spain, the very investigation which resulted in the surprise arrest of Jentszch himself in November of 1988. These operations included orders for investigations by the private detectives employed by the Scientology organizations to obtain information by any means possible to incarcerate the leaders of a reform movement who had not been silenced previously by Miscavige’s policies and declarations, with the express intent of obtaining their incarceration.

8. That during this same period and as part of these same operations, a plan was formulated to destroy the reform movement in europe by completely eliminating the leaders of this reform movement, William Robertson, John Caban and others, by any means possible. This included the infiltration of the reform group in Spain by covert agents of RTC, Kurt Weiland and William Knight, continued investigation and harassment by detectives employed by the scientology organizations in Spain and by recruiting others who would help to splinter the reform movement and to render it ineffective.

9. That additional orders were given to institute any action necessary including false denunciations, assaults by covert agents apparently in bad standing with the church, to infiltrate, offset and attack those leaders of the reform movement who were thought. to be responsible for reporting Scientology activities to the spanish authorities and undermining Miscaviqes intentions.

10. That the policies known as “Fair Game” are, as described in the writings of L. Ron Hubbard, ethics policies, and other organizational policies are in fact continued as originally written by Hubbard, and that it is the purpose of the RTC to see that all of his policies are followed exactly as intended. It was common knowledge that the “Cancellation of Fair Game” referred only to the use of the term, since it had obtained bad public relations for Scientology, and that the same tactics and actions which referred to those so-called Suppressive Persons were and are continued in effect.

11. That the organization known as the Guardian’s Office, while apparently abandoned, in fact was moved from the position as a separate organization or network, and incorporated within the organizational structure of Scientology, and all of the purposes and most of the Guardian personnel have remained the same. Again, the purpose of these changes were to obtain complete control by Miscavige over all Scientology organizations, and to obtain a more favorable image after Hubbard’s wife was found guilty of crimes as head of the Guardian’s Office.

12. Since my departure from the church my husband and I have been repeatedly threatened and harassed by members of Scientology, and we are now in fear for our safety.

Many of the statements made above contain information which has been testified. to by others and/or are matters of publlc record within other areas of litigation within the United States.

I swear under penalty of perjury under the laws of the state of Texas that the contents of this affidavit are true to the best of my knowledge and recollection.

Date 1 – 27 -92 Vicki J. Aznaran (signature)

1-27-92
signature
Notary Public
Dallas County, Texas
USA

Notes

  1. Document source: Document source: http://www.whyaretheydead.net/krasel/aff_va92.html

Declaration of Vicki Aznaran (October 27, 1988)

I, Vicki Aznaran, declare:1

1. I was involved with the Church of Scientology (“Scientology”) for approximately 15 years. I submit this Declaration on personal knowledge of the facts contained herein and if called upon as a witness I could and would competently testify thereto.

2. I was one of the highest ranking members of Scientology and was involved in upper management. From 1978 through 1987 I was a member of an organization known as the Sea Organization (“Sea Org”), an elite organization within Scientology. The Sea Org has considerable influence and control over other Scientology organizations; it sends its officers to individual organizations with unlimited power to handle ethics, tech and administration. In this regard, a Sea Org member may order a non-Sea Org member on virtually any subject, and the non-Sea Org member must obey. For example, sea Org “missions” are frequently sent to non-Sea Org organizations when those organizations are not sending enough money or public to the Sea Org organizations. These Sea Org members on “mission” can take any action they deem necessary in that non-Sea Org organization to accomplish their ends. They can control the funds of that organization and its personnel. They can remove personnel and post personnel. They can transfer funds to the Sea Org organizations or spend funds as they see fit.

3. Generally, Sea Org members hold the management posts in other organizations within Scientology. In order to be employed at a middle management level or above, one must be in the Sea

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Organization. In order to be employed at the organizations that make the most money (known as the Sea Org Organizations), such as the Flag Service Org in Clearwater, the Advanced organization of Los Angeles, the Advanced Organization of the U.K., the Advanced Organization of Denmark and the Advanced Organization in Australia, one must be a Sea Org member. Additionally, in order to be employed in the organizations that control the Scientology network, such as the Religious Technology Center, one must be a Sea Org member. From 1984 through early 1987 I was president of Religious Technology Center (“RTC”). By contrast, Scientology management often designates for publicity and other reasons various officers of Scientology organizations who are figure-head officers only and possess little, if any, actual power over the organization they purportedly serve. For example, Hebert Jentzsch was at one time named the titular head of the Church of Scientology International. However, during one of Mr. Jentzsch’s depositions he was unable to answer fundamental questions concerning the management of the Church of Scientology International (“CSI”) and could not name the directors of CSI nor the other officers. During the time I was in the Religious Technology Center, from 1982 until 1987, Mr. Jentzsch had nothing to do with the running of CSI. Mr. Jentzsch was a figure head and public relations man. It was never intended that he would be involved in the administration of CSI whatsoever. There is an order from Hubbard which states that the officers of corporations should be just figure heads; the directors have more power, and then you have trustees who are over the very top corporations who can remove directors. These trustees hold the power as regards

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Scientology’s money, assets, personnel, etc. The top trustees of Scientology when I was a director of RTC were David Miscavige, Lyman Spurlock and Norman Starkey. Patrick Broeker and Ann Broeker were also senior trustees over Scientology in 1982 and for some time thereafter. Miscavige convinced the Broekers to turn over their trusteeships to him in order to avoid the IRS criminal investigation that was ongoing. This left Miscavige, Spurlock and Starkey as the trustees that could control Scientology.

4. Lyman Spurlock and Norman Starkey also are both high-ranking Scientologists. At times, both within and outside my capacity as president of RTC, I have taken direct orders from Mr. Spurlock and from Mr. Starkey.

5. Both Mr. Spurlock and Mr. Starkey are members of the Sea Org. In addition, both these men hold other posts within Scientology. For example, Mr. Starkey was president of Author Services, Inc. (“ASI”), executor of the Estate of L. Ron Hubbard and Trustee of the Author’s Family Trust-B. Mr. Spurlock at various times was the Investment Officer International for the Church of Scientology, an executive of ASI, and president of Church of Spiritual Technology (“CST”). Both men have served together as officers of Galaxy Productions, Inc.

6. Mr. Spurlock controlled virtually all tax matters for the Religious Technology Center, CSI, ASI, CSC and CST. During the time I was an officer and director of RTC, I was asked to sign letters for RTC which had been drafted by Mr. Spurlock or at his request. Mr. Spurlock dealt with the tax attorneys who represented RTC. Sometimes I would be informed of actions he had taken regarding RTC tax matters after the fact, and sometimes

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was never informed. Mr. Spurlock met with the Internal Revenue Service on more than one occasion to negotiate matters for RTC. He did this entirely on his own and made his own decisions regarding RTC’s tax matters and tax exempt status. Mr. Spurlock and Mr. Starkey frequently issues orders to me concerning litigation and tax matters concerning RTC, CSI, CSC and other Scientology entities. Mr. Spurlock also set up the current corporate structure of Scientology. This includes the set up of RTC, CSI and CST. Mr. Spurlock set up these structures and, along with Miscavige and Starkey, chose the directors, trustees and officers.

7. Mr. Starkey gave orders concerning litigation matters for Scientology. In 1982 Norman Starkey and David Miscavige ordered me to get Dick Story of the Guardians Office World Wide to hire a private investigator named Dick Bast to compromise Judge Krentzman, who was the judge on a case against Scientology in Florida. Judge Krentzman had been giving Scientology unfavorable rulings in the case. From 1981 up until the time I left, Starkey, Spurlock and Miscavige closely supervised all litigation brought either for or against the various Scientology corporations. The settlement initiated by Scientology for all of the cases that Michael Flynn had brought against them was ordered by Miscavige, Starkey and Spurlock with no consultation with the various corporations who were sued, such as Church of Scientology of California. In fact, this settlement was considered top secret and the officers and directors of the various corporations who were supposedly settling with Mr. Flynn did not even know the specifics of the settlement. The various officers of the

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Scientology corporations know that they do not, in fact, make decisions about their respective corporations. They are told and understand that they sign what they are told to and that this is done in order to comply with the suppressive government requirements and avoid having to pay taxes to the suppressive IRS. In 1982 Mr. Spurlock ordered the then-head of international management, John Nelson, to buy into a gold mine in Canada using several million dollars worth of church funds. Mr. Nelson disagreed and said that he thought it was a bad investment. Mr Spurlock made the transaction anyway, as he controlled Scientology’s funds. Mr. Spurlock’s position at the time was Deputy Executive Director for Client Affairs at Author Services Inc., a for-profit organization which had been represented to the IRS as having no control whatsoever over tax exempt church funds. Mr. Spurlock’s gold mine venture lost a considerable sum of money for Scientology. Mr. Spurlock also ordered Scientology management, specifically Marc Yager and Wendell Reynolds, to buy into oil wells in Oklahoma. Mr. Yager expressed to me that he had reservations about this venture, but complied anyway. This venture also lost quite a bit of money for Scientology. Additionally, Starkey and Miscavige bought into the oil venture (with their personal funds) in Oklahoma and were able to get much better deal for themselves due to putting Hubbard’s and Scientology money into the venture.

8. Additional facts indicative of the management authority possessed and used by both Mr. Spurlock and Mr. Starkey over the entities involved in the Scott/Wollersheim consolidated lawsuits (i.e., Church of Scientology International (“CSI”), Church of

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Scientology of California (“CSC”), Religious Technology Center (“RTC”) and Church of Spiritual Technology (“CST”) include the following:

A. Mr. Spurlock ordered that the original Scott suit be brought. He was involved in all of the major strategy meetings with attorneys concerning both the Scott and Wollersheim cases and, in fact, began planning the suit against David Mayo in 1982, shortly after Mayo opened his Church.

B. Mr. Starkey was also involved in all major meetings with attorneys concerning the Scott/Wollersheim cases. He made active decisions and ordered the attorneys as to actions they were or were not allowed to take in regards to these facts. In fact, Mr. Starkey and Mr. Spurlock accompanied an attorney for Scientology, Mr. Earle Cooley, one night on what was described by them as an attempt to visit the residence of Judge Mariana Pfaelzer Scientology after she had ruled against Scientology at a hearing. He went with Mr. Cooley in order to express their views to Judge Pfaelzer and persuade her to rule favorably for Scientology. Mr. Starkey and Mr. Spurlock stayed up all night that night working on drafting papers for the Scott/Wollersheim cases.

9. One of the reasons why Scientology elects to manage its far-flung enterprises in this manner is to try to sheild its management from legal process. Front men are designated to hold figure-head posts, while the real management power is held by others outside the corporate structure. To this end, Scientology will go to extreme lengths to conceal upper management personnel

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from service of process, subpoenas and depositions. When alive L. Ron Hubbard was protected in this manner. In addition personnel have been driven around the city in covered vans to protect their identities and whereabouts. Moreover, when deemed necessary, personnel are sent out of this country in order to avoid legal process.

For example, in 1984 when the IRS was conducting criminal investigation against various Scientology entities, the personnel who had knowledge of criminal behavior as regards Scientology funds were hidden or sent away. Fran Harris, who was involved with Bridge Publications and Church and L. Ron Hubbard’s funds, was sent to Denmark for a year. Mark Ingber, WDC member for Finance, was also sent to Denmark for a year. Wendel Reynolds, who had similar knowledge, was put away on the RPF in Happy Valley. Miscavige, Starkey and Spurlock took great precautions with their travels, offices and residences so that they could not be found or served. Miscavige has been known to actually rent clandestine quarters away from any Scientology facility, paid for with Scientology funds, simply so that he could hide out from process servers.

10. Both Mr. Spurlock and Mr. Starkey have been afforded this “protection” by Scientology. It is doubtful that either will be deposed if personal service of a subpoena upon them is deemed necessary prerequisite. Scientology will take all measure necessary to keep these men cloistered from view and immunize from service.

11. On the other hand, it is clear that when Scientology wants help from Mr. Spurlock and Mr. Starkey both men stand ready

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to assist. Accordingly, whenever declarations are needed by Scientology in any of their lawsuits or other legal proceedings Scientology has no difficulty in obtaining the assistance of both Mr. Starkey and Mr. Spurlock. In this regard, Miscavige took off for over two months and lived in Portland, Oregon in order to oversee and direct the attorneys for Scientology on a daily basis during the entire trial in the case of Julie Christofferson Titchbourne, which she had brought against Scientology. Mr. Spurlock also spent most of his days in Portland during the trial. During the Wollersheim trial, Miscavige, Starkey and Spurlock supervised the attorneys representing CSC on a daily basis throughout the nearly three-month trial in Los Angeles. Miscavige, Starkey and Spurlock stay briefed on a daily basis on all legal matters of any consequence involving any Scientology entity. All papers filed by the Scientology entities involved in the consolidated Scott/Wollersheim cases had to be sent via Spurlock and Miscavige for authorization before they could be filed.

12. In addition, without revealing any privileged communications, I am able to state that both Mr. Spurlock and Mr. Starkey have been involved directly in the management of CSI, CSC, RTC and CST, and have participated in meetings in which decisions affecting these consolidated Scott/Wollersheim cases have been made. We have worked together in the past and I know that no major decision affecting these entities or these cases are made without their knowledge, participation and/or consent. Based upon all the information personally available to me, I am of the

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opinion that both Mr. Starkey and Mr. Spurlock are managing agents of CSI, CSC, RTC and CST.

13 . I have reason to believe that documents which would normally reflect traditional criteria of the managing agent relationship between Scientology and Messrs. Spurlock and Starkey have been either destroyed or concealed by Scientology. For example, at Mr. Starkey’s direction, I destroyed such information as it related to the involvement and control over Scientology by L. Ron Hubbard, Mr. Starkey and Mr. David Miscavige.

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

Executed this 27th day of October 1988, in Dallas, Texas.

[signed]
Vicki J. Aznaran

Notes

  1. Signature page in image format.

Declaration of Vicki J. Aznaran (August 9, 1988)

I, Vicki J. Aznaran, make the following declarations on personal knowledge except where the context indicates knowledge based upon information and belief.1

My husband Richard Aznaran and I are plaintiffs in the instant action wherein defendants (hereinafter referred to collectively as “Scientology”) have moved to strike our entire complaint and to prevent our attorneys from representing us.

2. As set forth in more detail below, my husband and I were involved with Scientology for approximately 15 years. For much of that time we were members of an organization known as the Sea Organization. This organization is an elite organization within Scientology. The Sea Organization has considerable influence and control over Scientology organizations. Generally, Sea Organization members hold the management posts within Scientology.

3. In 1978, after approximately four years as staff members, my husband and I joined the Sea Organization. From 1978 to early 1987, my husband and I worked most of our waking hours, with very few days off, at our various assignments within Scientology. I eventually became President of Religious Technology Center and, supposedly, the top “ecclesiastical” authority within Scientology. Richard was a high-level security officer. During this period my husband and I became intimately familiar with the structure and activities of various Scientology organizations. Among other things, I was briefed on and sometimes a participant in meetings involving litigation tactics and various

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means used to attack and fight “enemies” of Scientology. In numerous instances I was in the chain of command or approval for such activities. The legal strategy of Scientology and the existence of numerous potential legal problems, some of which are set forth below, were known to me when I was a staff member in Scientology. Contrary to, what I understand to be claimed by defendants herein, Mr. Yanny did not reveal to me the legal strategies or secrets of Scientology. Nor did Mr. Yanny invent or open my eyes to the wrongs that I had suffered at the hands of Scientology.

4. I have become an “enemy” of Scientology. This has certain consequences that will influence what Scientology will do in this litigation. For example, it is important to understand that their value system allows dishonesty if done in the name of Scientology.

5. Enemies of Scientology are deemed to be “suppressive persons”(“SPs”). One becomes a “suppressive person” by doing a suppressive act, such as suing Scientology as a litigant or lawyer. In the jargon of Scientology, when one is “declared” this means that one has been declared a “suppressive person” and, therefore, may be, harassed, hurt, damaged or destroyed without regard to truth, honesty or legal rights. It is considered acceptable within Scientology to lie, cheat, steal and commit illegal acts in the name of dealing with a “suppressive person”.

6. This practice or policy is sometimes referred to as the policy of “fair game”. In the jargon of Scientology, a person who is “declared” is understood to be a suppressive person. This means that the person is “fair game”. The fair game policy was

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issued in the 1960s. It was, never cancelled. A document was issued for public relations reasons that purportedly cancelled “fair game”; however, that document stated that it did not change the manner of handling persons declared “SP.” In reality, the purported cancellation of fair game is at most a matter of semantics. Enemies of Scientology are treated as “fair game.”

7. It is my understanding, and I have so testified in my deposition, that when my husband and I escaped from Scientology we were not immediately declared suppressive persons or subjected to the fair game policy. Among other things, we were compelled to do certain things and sign various documents to escape and avoid being subjected to fair game treatment. As we have now sued Scientology, we are “fair game”.

8. From 1984 through early 1987, I was President of Religious Technology Center (hereinafter “RTC”). As President of RTC and a Sea Organization member, I attended many meetings concerning the numerous legal actions involving Scientology organizations. During this time period, I had personal access to all legal documents having to do with RTC. I received a report every day on my computer that included a synopsis of each ongoing legal case involving Scientology. I received, or so I was told, copies of every major motion filed in cases involving Scientology. I was on the “approval lines” for legal documents dealing with RTC. During this time period, I had the option of attending legal meetings although some were mandatory. I attended many litigation meetings and became generally aware of Scientology’s dirty tricks and legal maneuvers. On specifics, I frequently deferred to in-house and outside counsel, however, at least in theory, I was

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the head of RTC and had access to any business or litigation ” secrets” of Scientology.

9. As President of RTC, I was one of those responsible for retaining the services of Joseph Yanny as counsel for Scientology organizations. I supervised and worked with Mr. Yanny who served as coordinating attorney for RTC in 1985. I am not aware of any legal or corporate information concerning RTC that was available to Mr. Yanny but not available to me.

10. I am informed and believe that various Scientology organizations are contending that Mr. Yanny has somehow improperly educated me on the legal maneuvers, tactics and affairs of Scientology. Although such claims are consistent with litigation tactics of Scientology, which .are not constrained by considerations such as truth and reality, the proposition that I need Mr. Yanny to educate me on the internal affairs of Scientology is simply wrong. I was one of the highest ranking members of Scientology and was involved in upper management. Mr. Yanny was a lawyer hired by management, of which I was a part, to work for it. Further, it was the practice during the time period in question to screen the information given to outside counsel such as Mr Yanny.

11. It is the stated policy and practice of Scientology to use the legal system to abuse and harass its enemies. This crude, fundamental directive of Scientology is no secret. In any event, this information did not come to me from Mr. Yanny. The policy is to do anything and everything possible to harass the opposing litigant without regard to whether any particular motion or maneuver is appropriate or warranted by the facts or applicable law. That policy was followed in every legal case I was involved

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with or learned about while a member of the Sea Organization. The management of Scientology consistently expressed and demonstrated a complete disdain for the court system viewing it as nothing more than a method to harass enemies. Some examples of this are set forth below.

12. During litigation between Gerald Armstrong and Scientology, which was before Judge Breckenridge of Superior Court for Los Angeles County, the court ordered the production of Armstrong’s pre-clear (“PC”) folders. These are files maintained by Scientology on those who submit to interrogation sessions in a process called auditing. During the course of that litigation I was ordered to go through Armstrong’s folders and destroy or conceal anything that might be damaging to Scientology or helpful to Armstrong’s case. As ordered, I went through the files and destroyed contents that might support Armstrong’s claims against Scientology. This practice is known within Scientology as “culling PC folders” and is a common litigation tactic employed by Scientology.

13. During other litigation in Los Angeles known to me as the Wollersheim case, I was told that the. judge had ordered the production of Wollersheim’s folders. As ordered, I “culled” these files. In other words, I removed contents that might have been damaging to Scientology or support Wollersheim’s claims against Scientology. For example, I removed evidence of events involving his family, the anguish this caused him, evidence of disconnection from family and evidence of fair game.

14. I was involved in numerous meetings concerning what is known to me as the Christofferson case in Portland, Oregon. This

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case was tried twice. In the first case, a Scientology witness by the name of Martin Samuels was coached and drilled for hours on how to lie convincingly or avoid telling the truth. Before or during the second trial he admitted to this course of conduct. In this litigation, a Scientologist by the name of Joan Shriver produced responsive documents that may have been incriminating. This was a serious breach of policy for which she was punished. These documents were ordered produced on such short notice that apparently files were not thoroughly “culled”. In another case, Mr. Yanny was severely criticized and almost fired for failing to properly coach and feed the desired answers to Heber Jentzsch. Mr. Jentzsch was, for public relations reasons, the purported head of the Church of Scientology International. During his deposition, Mr. Jentzsch was unable to answer fundamental questions concerning the management of Church of Scientology International. This may be what certain defendants are referring to when they say that they were dissatisfied with Mr. Yanny’s services and I protected him. There were those, including McShane, who were outraged by the embarrassing testimony of Mr. Jentzsch. This was blamed on Mr. Yanny. I did not wish. to discontinue using Mr. Yanny at RTC for this perceived problem.

15. In November, 1985, I was present at a meeting whereat Earle Cooley, a Scientologist lawyer, Lyman Spurlock and Norman Starkey, all high ranking Scientologists, announced that they were going to contact Judge Mariana Pfaelzer. Earlier that day Judge Pfaelzer had denied a Scientology motion for a temporary restraining order. After losing on the application there was a meeting to determine what to do about the situation. At the

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meeting Mr. Cooley had a file, that purportedly contained background and personal information on Judge Pfaelzer. During the meeting Mr. Cooley and the others announced that they were going to attempt to meet with Judge Pfaelzer that evening, at her house if necessary, concerning the litigation in which the temporary restraining order had been sought. Thereafter, Mr. Cooley and two others left with their file on Judge Pfaelzer. They returned several hours later at which time I was told that their attempts to contact Judge Pfaelzer had been unsuccessful.

16. In late 1979 and early 1980, there was a massive document destruction program undertaken to destroy any evidence showing that L. Ron Hubbard (“LRH”) controlled Scientology. I participated in this activity in Clearwater, Florida and am informed that there was also intensive document destruction at facilities in Gilman Hot Springs, California. From at least that point onward there was a continuous effort to hide or destroy any evidence of Hubbard’s control. For example, during an IRS investigation in 1984 and 1985, while in bed with pneumonia, I was ordered out of bed by Norman Starkey who told me that they had received a tip from a Los Angeles Police officer advising them of a pending IRS raid in Los Angeles. Mr. Starkey ordered me to go to a computer facility and insure that all information on the computers in Los Angeles that might show Hubbard’s involvement and control of Scientology’s money was destroyed except for one copy of each document. These copies were to be saved on computer discs which were to be hidden in secure storage places. At the time I was also instructed to destroy anything that would show the control of Mr. Starkey or Mr. Miscavige over Scientology.

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17. I have been informed and believe that a an improper affidavit was filed in a case brought by L. Ron Hubbard, Jr. in Riverside, California. The circumstances were as follows: The document purported to be an affidavit of L. Ron Hubbard. The signature of Hubbard was purportedly notarized by David Miscavige. It is my understanding that this affidavit caused the case to be dismissed. Subsequently, I was told by Pat Broeker, who had been living with Hubbard at the time, and by Miscavige, that Miscavige had not seen Hubbard between 1980 and Hubbard’s death in 1986. Accordingly, the affidavit was apparently signed, notarized and dated during a time period when Hubbard was in seclusion and not seen by the person who purportedly notarized the signature of Hubbard.

18. In or about 1981, while working in a Scientology organization known as the Guardian’s Office, I had access to and observed various written and oral communications pertaining to illegitimate activities participated in by the Guardian’s Office.

The Guardian’s Office attempted to infiltrate both governmental and private agencies including the IRS, the Department of Justice, the American Medical Association and the National Institute of Mental Health. The purpose of this was to steal documents pursuant to Hubbard’s “Snow White” program. The goal of this program was to eliminate any negative reports about Hubbard and Scientology that may have been held by these various agencies.

19. While involved in Scientology I became aware of various operations directed against an author who had written a negative book about Scientology. The author, Paulette Cooper, was subjected to various forms of harassment. One operation included an

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attempt to frame her. A false bomb threat was written. A Scientology agent lifted a fingerprint from Cooper’s apartment. These fingerprints were then transferred to the bomb threat letter. Ms. Cooper was subjected to an investigation and was not cleared until an FBI raid resulted in the seizure of Scientology documents that exposed the operation as a frame-up. There was at least one other operation directed against Ms. Cooper. The substance of it was to plant a boyfriend to reinforce and play upon her suicidal tendencies in the hopes that she would commit suicide.

20. In 1976 and 1977, the then Mayor of Clearwater, Florida, Gabe Cazares was involved with litigation against Scientology. Arrangements were made to have an attorney by the name of Merril [sp. Merrill] Vanniere [sp. Veneer?], a Scientologist, represent Mr. Cazares and sabotage his case. This plot was also exposed by documents obtained in an FBI raid of a .Scientology facility. Also, in response to Mr. Cazares’ litigation against Scientology, an attempt was made to implicate Mr. Cazares in a staged hit-and-run accident.

21. During the time period of my involvement with Scientology, I also learned of various. attempts to influence judges or force their removal from cases. For example, a private investigator named Dick Bast obtained a statement from a prostitute concerning involvement with a certain judge in Washington, D.C. who was sitting on a Scientology case. This was then publicized. The judge did not continue on the case. The same investigator, Dick Bast was also hired for the purpose of attempting to force the removal of a judge in Tampa, Florida. This involved what I know as the Burden case, which was civil

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litigation brought by Michael Flynn. Dick Bast secured a yacht and attempted to get the judge on board for the purpose of filming him under compromising circumstances. The judge declined to go yachting and the operation was unsuccessful. Approximately $250,000.00 was spent on the operation.

22. I have been informed by Mark (Marty) Rathbun, a high ranking Scientologist, that his private investigator, Gene Ingram, “fed” a confession to Ala Tamimi when visiting him in an Italian prison. This false confession was, in substance, that Tamimi had been involved in a bad check scam involving an account of L. Ron Hubbard. This false confession implicated attorney Michael Flynn in the check scam. Michael Flynn was at the time considered a major enemy of Scientology because he represented numerous clients with claims against Scientology. This purported confession was used to slander and attack Michael Flynn. Michael Flynn has also been sued.by Scientology as part of its “strategy” for handling enemies.

23. During an IRS criminal investigation in the 1984 to 1985 time period, the IRS ordered production of various communications between Hubbard and Author Services, Inc. (ASI). The ASI staff worked literally day and night for several days reviewing documents so that unfavorable documents could be destroyed or otherwise concealed from the IRS. Lyman Spurlock and Marion M. Dendui, Scientologists involved in this operation, informed me of this operation. Also during this IRS investigation, my husband, Rick Aznaran, was ordered to remove and conceal any incriminating documents from certain locations. He was also directed to make the computer network “raid proof”. This involved creating a

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system where incriminating documents could be deleted from computer storage rapidly and before the IRS could obtain control over the computers.

24. In 1985, I attended a conference on “squirrels” attended by Miscavige, Starkey, Spurlock, and McShane, members of top management, and others. In Scientology jargon, “squirrels” are people who use or practice some procedures also used by Scientology but who do not submit to the total control of the Scientology organization and, perhaps most importantly, who do not pay a percentage of their auditing or counseling fees to Scientology. At this meeting, David Miscavige ordered that public Scientologists be organized and motivated to physically attack squirrels and disrupt their operations. This was stated to be pursuant to the standard guidelines of Scientology. Pursuant to such directives, efforts were undertaken to intimidate and disrupt these persons and their organizations.

25. In 1981, operation “Juggernaut” was commenced. The purpose of this was to destroy Michael Flynn who, as stated above, was representing various plaintiffs with litigation against Scientology. This operation contemplated the use of infiltration, propaganda and attempts to persuade clients to turn against him.

26. The Guardians’ Office got into so much trouble, and worse yet got caught, that it was decided in the early 1980’s that the Guardians’ Office should be disbanded. This was purely a public relations gimmick. In short, it was decided that the Guardians’ Office and Mary Sue Hubbard, its then leader, were to take the rap for all criticism and improper conduct. This scheme was laid out in various written communications I observed in 1981

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and 1982. (Of course, I was not allowed to keep or escape from Scientology with any such incriminating documents.)

27. Since the early 1970’s, Scientology has operated a forced labor camp known as the Rehabilitation Project Force (“RPF”). Staff members are incarcerated in the RPF for various real or imagined offense. People confined at this camp are forced to perform hard physical labor every day. They eat rice and beans, or left-overs, and wear rags. They are deprived of sufficient sleep. In 1987, I was confined in such a camp at Happy Valley for approximately six weeks. I worked all day and was confined in a room at night. To the best of my knowledge I was guarded 24 hours a day. They would not even let me shower alone. I had to obtain permission to use a bathroom. I was ill and not allowed to obtain medical treatment. I was not allowed to communicate with my husband nor was I allowed to obtain adequate sleep. I was told that I had gone insane and that my husband did not want to communicate with me. I was physically and psychologically abused both at Happy Valley and for numerous days thereafter in a process called “security checking”. Much oversimplified, I was grilled on a primitive lie detector called an E-Meter and made to understand that I would not be released, have my property returned, or escape fair game policy unless I eventually gave all of the “right” answers. Examples of ” right” answers were responses that I would not talk to a lawyer or consider suing Scientology. I had to give such answers before being released.

28. Recovering from the years of brainwashing, thought control and propaganda to which Scientology subjected me is a

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gradual process that I do not fully understand. I am not a psychologist or psychiatrist and do not fully understand the ramifications of what I have been through although I can observe and experience many symptoms. I have many nightmares and a fear of Scientology.

29. The suit brought by Richard Aznaran and myself is based upon real events that happened to real people, namely us. Just as my husband and I do not need Mr. Yanny to educate us on any secrets of Scientology, it is simply untrue that our claims were somehow invented or manufactured by Mr. Yanny. The whimsical notion that Mr. Yanny invented this litigation through my husband and me is simply false.

30. My husband and I consider Mr. Yanny to be a friend. Further, it might be noted that Mr. Yanny was to serve as my personal counsel in a class action against Scientology and numerous individuals including myself. Recent events have changed this, however, .there was a period of time when Mr. Yanny was purportedly designated as my personal counsel with the approval of Scientology.

31. My husband and I feel quite strongly that we want Barry Van Sickle and the firm of Cummins & White to represent us in this case. Our reasons are both subjective and objective. We do not wish to list our subjective reasons, although we will do so if the Court requests it. Objectively, it might be noted that we had considerable difficulty finding counsel willing and in a position to undertake this extremely volatile, time consuming and expensive litigation. We are unable to pay hourly rates to pursue our claims and need a firm willing to work with us on a contingency

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fee basis. I anticipate great difficulty, delay and prejudice if forced to find other counsel.

32. Based upon my experience within Scientology and as a litigant against it, I understand that this is not routine litigation. If I am forced to find other counsel, prospective counsel will be presented with the following situation:

(a) A complex case that must be handled on a contingency fee and cost-advanced basis;

(b) A case that requires a litigation team and substantial financial resources;

(c) A case involving an opponent who has a practice and history of suing opposing lawyers as a tactic in addition to subjecting opposing lawyers to surveillance, depositions, infiltration, bad publicity and the full ramifications of the fair game policy;

(d) A case where the opponent is not constrained by a need to be cost effective, truthful, honest or reasonable; and

(e) A case that requires extraordinary security precautions.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Executed this 9th day of August, 1988, in Dallas, Texas.

[signed]
VICKI J. AZNARAN

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Notes

  1. This document in PDF format.