Mike Sutter


Declaration of Michael Rinder (December 3, 2013)

DECLARATION OF MICHAEL RINDER1

My name is Michael Rinder, I am over the age of 21, and I have personal knowledge of the facts stated herein, which I declare are true and correct subject to the penalty for perjury.

1.  I was raised in a Scientology family from the age of six. I joined church staff in April 1973 at the age of eighteen and remained a full time employee until June 2007.

2.  For most of the time between 1982 and 2007 I was a senior official in the Church of Scientology International (CSI), the so-called mother church of Scientology.  I was on the Board of Directors of CSI from its inception in 1982 until I left in 2007.

3.  During the majority of the time between 1982 and 2007 I was the most senior official within CSI responsible for “external affairs”, meaning government and media relations, investigations and intelligence operations, as well as all litigation and contract matters. This function is performed by the Office of Special Affairs (“OSA”) and I was the head of OSA for most of this time.

4.  I have read Defendant Church of Scientology International’s “Anti-SLAPP Motion to Dismiss Plaintiff’s First Amended Petition” and attached affidavits of Allan Cartwright, David Lubow, John Allender, Richard Hirst, Monty Drake and Steven Sloat and I have also read Defendants Miscavige and RTC Special Appearances and requests for dismissal alleging this court does not have jurisdiction. I have relevant information concerning both of these efforts to dismiss this case. Miscavige and RTC Special Appearances and requests for dismissal alleging this court does not have jurisdiction. I have relevant information concerning both of these efforts to dismiss this case.

Miscavige and Me

5.  Though a CSI employee, I answered directly to David Miscavige (the self-titled Chairman of the Board of Religious Technology Center or “COB RTC” or nowadays simply “COB”) and Religious Technology Center, either directly to Miscavige or through his representatives, primarily Mark (“Marty”) Rathbun and to a lesser extent Warren McShane and Mike Sutter. Even when there was someone who was administratively senior to me in CSI, they were senior in title only. RTC still directed my activities and I reported to one of the four named individuals above.

6.  I have more than two decades of personal experience working for David Miscavige dealing with the most pressing “external affairs” matters — from negotiations with the IRS to dealing with “attackers” and responding to media and numerous lawsuits. Miscavige has always maintained personal and direct control over situations he felt threatened his position of authority and power within the church or would harm his image. To facilitate this without subjecting himself to liability, an elaborate corporate structure was put in place to shield his involvement in direct actions, particularly those that are unsavory or could generate damaging PR or could drag him into litigation.

7.  I was selected by David Miscavige and brought to Los Angeles from Florida in April 1981 to participate in the purge of the “Guardian’s Office” which had been the arm of the church that had been responsible for “external affairs” but had been caught and prosecuted by the US Government for illegal acts. This in turn had engendered civil litigation which at the time was moving towards judgments against the church and threatened to drag Scientology founder L. Ron Hubbard into civil and potentially criminal liability. Marty Rathbun was also part of this small group of people hand selected by Miscavige. OSA is heir to the role of the Guardian’s Office.

8.  At Miscavige’s direction, extensive and elaborate methods were employed to shield Hubbard from liability. After Hubbard died in 1986 and Miscavige took over, similar methods were employed by Miscavige to shield himself from liability.

9.  Miscavige is acutely aware of personal liability and carefully uses subterfuge to make it appear he has no connection to unsavory or potentially tortious or criminal activities. He talks on the phone or in person with no record to his trusted “lieutenants” about “sensitive matters” (such as anything relating to the “handling” of “attackers”, defined as anyone who threatens his position or the church through exposure in the media, on the internet or in. the legal arena). If written communication is required it is not signed by him and gives no indication who it was written by. At times Miscavige even writes about himself in the third person (e.g. “this would impact COB” rather than “this would impact me.”) This is a pattern developed by Hubbard. Other times Miscavige instructs his lieutenants to issue orders in their name. This happened hundreds if not thousands of times where I would relay Miscavige orders to underlings in various Churches of Scientology around the world in my name.

10.  Miscavige compartmentalizes information — those who did not “need to know” were excluded from conversations or written orders. The majority of the time 1. worked under Miscavige, “sensitive” subjects, which included matters related to litigation, ongoing investigations or high level defectors were discussed ONLY with his most trusted juniors. On numerous occasions that meant only Marty Rathbun and me. He would tell others to leave the room, or he would step outside with us before discussing these matters. This was particularly the case when he wanted to discuss ongoing “investigations.”

11.  The “Case Officers” (usually Neal O’Riley, Ben Shaw and Linda Hamel, all former Guardian Office members) who directed Pi’s and other operatives reported only to me, and I forwarded it to Miscavige, Rathbun, McShane and Sutter. The information they collected and activities they directed were kept segregated from even others in OSA. This is pursuant to the written policy of the church on how to conduct covert investigations and operations. (Some operations were so sensitive that Rathbun or McShane went directly to the Case Officers and I was not informed about what they were doing)

12.  Miscavige received a daily report concerning every legal case, every media action and every investigation ongoing in the world. I prepared this briefing each day, entitled the “OSA DR” (Office of Special Affairs Daily Report) and it was sent to Marty Rathbun and David Miscavige via an encrypted email program. The report had no indication on it who it was written by or who it was addressed to. There was a separate “Investigations Report” that I compiled with very limited distribution including David Miscavige and Marty Rathbun. The “Invest Report” contained specifics of all ongoing activities of Private Investigators and intelligence operations working for the church against “attackers”. This was delivered in an unmarked, sealed envelope with no indication who it was from or who it was to and is labeled “Secret — Eyes Only.” On hundreds of occasions David Miscavige specifically commented upon, issued orders concerning, and even micro-managed the format of the OSA Daily Reports. When I was in a different location from Miscavige, he would call me on the phone every single day first thing to direct what was to be done about matters raised in the OSA Daily Report (it was the first thing he looked at before even getting dressed when he woke up in the morning) and he would call me again at the end of the day to ask if there was any other “significant news”. Some days, if there was an investigation or legal case or media matter that he was especially interested in, he would call me several times during the day. All staff in OSA knew that phone calls “from COB” were highest priority and any meetings or other matters were to be interrupted to take a “call from COB.” Staff in OSA Int saw me receive literally thousands of phone calls from “COB.” When we were in the same location, I would be summoned to his office several times each day.

13.  Each and every OSA Daily Report and Intel or Invest Daily Report that was produced daily from 1981 to the present is filed both in electronic and hard copy form at OSA. It is long-standing, firm, unalterable Scientology policy that every report generated by OSA is faithfully and securely kept on file for eternity. The files are considered to be the mind of the organization.

Corporate Lines of Control — The Sea Organization

14.  In addition to the compartmented information and sensitive matters not being put in writing, an elaborate corporate structure is in place on paper intended to insulate Miscavige and RTC from any civil or criminal liability. I helped establish this structure starting in 1981, creating the different corporations of Scientology including CST and RTC. This structure served three purposes: making a legally defensible structure that the IRS could ultimately grant tax exempt status to, creating an impenetrable corporate shield to limit liability to Hubbard (and subsequently Miscavige) and protecting assets from judgments by litigants by locating them in different corporate entities than those that were in direct contact with the public.

15.  In fact, there is no corporate separation in the Scientology hierarchy because the entire structure of Scientology corporations is completely subservient to the Sea Organization (“Sea Org” or “SO”). And that is under the unquestioned authority of its supreme commander, Captain David Miscavige.

16.  The Sea Org is a fraternity of the most dedicated members of Scientology. They pledge themselves to eternal service, signing a billion year “contract.” Sea Org members live in church facilities and have no life outside the church. The name derives from the late 1960’s when L. Ron Hubbard took his most dedicated and trusted followers to sea on a fleet of ships. Hubbard assumed the naval rank of Commodore and the naval traditions of rank and command structures became part and parcel of the leadership of Scientology.

17.  Everyone in CSI and RTC and all other senior organizations of Scientology are members of the Sea Organization. I was a member of the Sea Organization from 1973 until 2007 and as all Sea Org members are required to do, I signed a billion year “contract”, committing myself to an eternity in service of Scientology and dedicating myself without question to the Sea Org strict and unquestioned code of conduct.

18.  The real control of Scientology lays within the Sea Organization hierarachy. Every person in any position of authority in the international structure of Scientology is a Sea Org member. Every one of them is answerable to Miscavige. He uses a contrived title that makes him sound like a Board Chairman of a normal corporation. This is a deliberate ruse. He is really the most senior official of the Sea Org and as such has complete and unquestioned authority over every Sea Org member regardless of their “corporate position.”

19.  When Hubbard died in 1986 and Miscavige took over to “follow in his footsteps” — Hubbard’s rank of Commodore was retired. Miscavige assumed the most senior rank of “Captain.” This bestows upon him ultimate “seniority of command” and authority over everyone else in the Sea Org (meaning every person in any position of authority in Scientology no matter their corporate position). Internally in Scientology, even members who are not in the Sea Org refer to him as “Captain Miscavige” and he is identified in church publications accordingly.

20.  When this true “line of command and control” was brought up in litigation in the 1990’s by former Sea Org members, Miscavige went to extraordinary lengths to camouflage his control by appointing a number of other people to the rank of “Captain (brevet).” “Brevet” means “temporary.” In that way he was able to submit a declaration to the court claiming that because there were “other Captains” he was not in fact able to exercise sole control of the Sea Organization. That conclusion was false, though his assertion that there were “other Captains” was literally true but the other “Captains” were temporary and each understood Miscavige could take away their “rank” as quickly as he had bestowed it. And. he did so. After that declaration was filed he subsequently demoted every person he mentioned, not a single one of them retained the rank of Captain (brevet).

21.  In Scientology, Corporate Boards are window-dressing. The members of the Board of CSI had no idea what their duties and responsibilities were. As the head of OSA and thus responsible for maintaining “corporate regularity” I would direct board minutes he put together and sent to the various board members of CSI and many different corporations for the “Directors” to sign. Many did not even read them. They understood they were merely a formality required for maintaining “corporate regularity” but it had nothing to do with their actual operations. Every member of every corporate board and all officers (including CSI and RTC) had signed undated resignations that could be activated by Miscavige at any time. So too have many of the corporate directors (myself included) signed false declarations asserting these corporations are real because as dedicated Sea Org members it is considered far more important to protect L. Ron Hubbard or David Miscavige than comply with “wog” (the Scientology term for non-Scientologists) laws which are considered worthy only of contempt.

22.  I was directed by Miscavige personally on many, many different situations from lawsuits that he felt were important, to meeting with key media, to visiting with government officials, to directly running private investigators and intelligence operations. In each instance the level of micromanaging Miscavige engaged in is hard to believe.

Miscavige Connection to Texas

23.  Out of literally dozens, if not hundreds of examples, I recount what happened with the Aznarans in 1994, primarily because they were Texas residents and the events took place in Dallas. Vicki Aznaran, like Mark Rathbun, was previously the “Inspector General” of Religious Technology Center. She was ousted by Miscavige and left the church and she and her husband filed suit against a number of church entities in 1988. Miscavige considered her a threat due to her knowledge of the power struggle he had been engaged in after the death of L. Ron Hubbard in 1986. Aznaran had taken sides against Miscavige and therefore she and her husband had become “enemies.”

24.  In 1994 the Aznaran’s called the church and said they wanted to engage in settlement discussions to resolve their lawsuit.

25.  Miscavige called me, told me in detail what he wanted done and sent me to meet with Richard Aznaran at Dallas-Fort Worth airport. I was instructed by Miscavige to secretly record the entire meeting so Miscavige could hear every word that was said. I covertly recorded my meeting with Mr. Aznaran as Miscavige had ordered.

26.  When I returned to Los Angeles, Miscavige listened to the recording and then directed that I set up a settlement meeting with the Aznarans in Dallas. He gave me very explicit instructions. I was sent back to Dallas with Miscavige lieutenant, and RTC staff member, Mike Sutter and met with Richard and Vicki Aznaran in a suite in the Adolphus hotel in Dallas. Richard and Vicki were “represented” by Vicki’s sister as they were dissatisfied with the lawyer who had been representing them (Barry Van Sickle) and they wanted to be paid directly without Van Sickle getting anything.

27.  I negotiated a settlement with the Aznaran’s over two days in Dallas. T was called by Miscavige at least every hour and bad to give detailed descriptions of everything that had transpired and then receive more detailed. direction from him on what was to be done. As has now become standard practice in all Scientology settlements, we were required to get the Aznarans to sign declarations that could be used to counter statements they had earlier made in the course of their lawsuit.

28.  Sutter and I returned to Los Angeles. We worked in Miscavige’s office on the 11th floor of the Hollywood Guarantee Building (HGB) 1710 Ivar Ave. (which also carries the CSI address of 6331 Hollywood Blvd) in Hollywood putting declarations — favorable to Miscavige himself that Miscavige had dictated — into final form. We typed them up and submitted them to Miscavige for his approval. Miscavige then despatched me and Sutter back to Dallas to get these signed and to tell the Aznarans that if they wouldn’t shut them there was no deal and they would get no money.

28 [1].  The Aznaran’s balked at signing the documents. Some modifications were made to things the Aznarans considered were too blatantly and provably false. Every change required approval from Miscavige via telephone. If he disagreed with the wording they wanted Miscavige dictated a different version to go back to them.

29.  Miscavige was also directly and personally involved in other matters I am aware of related to Texas. Private Investigator Monty Drake was used to gather information on Dell Liebriech in Dallas Texas. Dell Liebriech was the plaintiff in a civil lawsuit filed in Florida on behalf of Lisa McPherson who had died under church care. Miscavige had been personally involved in the administration of Scientology counseling (auditing) to Ms. McPherson and was extremely concerned that he would be implicated in the case. He, Marty Rathbun and I essentially relocated to Florida from 1998 through 2002 to work almost exclusively on the case. Miscavige controlled every single aspect of it, primarily through Rathbun and me — from meeting with lawyers and experts to responding to protestors and making statements to the press. Not a single thing relating to the McPherson case was done that was not ordered by him. Not a single thing happened relating to that case that he was not immediately apprised of. Not a single utterance was made to the hundreds of media who repeatedly inquired of the church about the case without Miscavige either dictating the words to be spoken or authorizing them. All intelligence operations against the McPherson family and their lawyers were conducted only at the direction of or with prior approval of Miscavige.

“The Hole”

30.  From January 2004 off and on through 2007, I was incarcerated by direct order of David Miscavige in what he called “The Hole.” This was formerly the building on the church “international headquarters” property in Hemet known as the “Int Trailer” as it consisted of two double-wide trailers connected by a conference room. Myself and in excess of one hundred other Sea Org members were confined to this building for months on end by order of Miscavige. This included all the other former “Captains” of the Sea Org, including those from CST and IAS, entities the church alleges are NOT under the control of Miscavige and RTC but ARE manned by Sea Org members and thus do in fact answer to his ultimate authority.

31.  We slept on the floor and ate all our meals within that building. It was literally turned into a prison, with. bars on the doors and windows and a 24 hour-a-day security officer guarding the only entrance. Warren McShane was assigned by Miscavige as the “Warden” of the “The Hole” and he reported directly to Miscavige about the personnel and activities in The Hole. The only person anyone incarcerated in the Hole could communicate with outside the Hole was “Mr. McShane.”

32.  Virtually the only thing that happened in The Hole was efforts to extract “confessions” from people about their misdeeds and “evil intentions” towards Miscavige. This was done by “group pressure” — dozens of people screaming at you for hours on end, sometimes physical assaults, even torture, lack of sleep and food. I think everyone who was in the Hole eventually wrote self-incriminating “confessions” in an effort to prove to Miscavige that they no longer needed to be held prisoner. If the “confession” was not sufficiently contrite or dramatic, it would be rejected and the mental and physical torture would resume.

33.  During some periods between 2004 and early 2006 The Hole and its occupants were temporarily reprieved for no apparent reason. But after a while, Miscavige changed his mind again and The Hole would be put back into operation. In early 2006 it became a permanent operation until I left it in March 2007.

34.  Select people that Miscavige needed would be allowed OUT of The Hole to conduct specific activities for Captain Miscavige. On, a number of occasions I was released from The Hole to deal with the media. Angie Blankenship and Laurance Stumbke were allowed out of The Hole to work on specific building purchase and design matters for Miscavige. Once several people in The Hole were despatched to retrieve (a virtual kidnapping) Clark Morton who had escaped and fled to Las Vegas. Another time I and several others were temporarily reprieved by Miscavige and sent by him personally to “pick up” the IAS (International Association of Scientologists) executives including “Captain” Janet McLaughlin, and bring them to “The Hole.” Though Miscavige and the church claim the IAS is a completely separate and independent organization, it is manned exclusively by Sea Org members, all of whom must answer to Miscavige.

35.  My last reprieve from The Hole was in late 2006 when I was personally ordered by Miscavige to assist Tommy Davis. Davis had been taken out of Celebrity Centre International (a church in Los Angeles) to work directly and only for Miscavige. He had become one of the “Miscavige henchmen” he always maintained to carry out his express wishes. No mind was paid to their corporate positions or functions, they all knew they were answerable to Miscavige and did his bidding. For many years, I had been in that position. Because Miscavige had put me and the President of CSI, Heber Jentzsch in The Hole, he had turned to Tommy Davis to deal with inquiries by BBC Panorama in pursuit of a story. But Tommy Davis was inexperienced with the media. Miscavige told me I was to work for Tommy as his “servant” and that I was to “lick his asshole.” But soon Miscavige was calling and texting me to report on what Tommy was doing. It was a standard pattern of Miscavige: for every “go-to guy” he had as part of his personal team of henchmen there was someone else who would report on the person directly to Miscavige. In earlier times I had done this with Mark Rathbun and he had done so with me.

36.  Davis reported to Miscavige hourly, and sometimes more often, concerning the BBC. If it was not a phone call it was Blackberry text messages. Many times the messages from Miscavige were in the name of his “Communicator” (Laurisse “Lou” Stuckenbrock nee Henley-Smith his personal secretary who was with him every waking minute) — she would even speak to Davis and me on the phone saying the words that Miscavige was telling her to say (he could be heard saying it to her and then she would relay it).

My Escape and Subsequent Harassment

37.  After finally having enough of Miscavige’s physical and mental abuse, and participating in the lies he was perpetrating on the world, I escaped in June 2007. As a result of this all my family was ordered to disown me and “disconnect” from me. My wife divorced me, my children, brother, sister and mother (my father is deceased) all shunned me and do so to this day.

38.  After I spoke to the media in 2009 to confirm information they had been told by Marty Rathbun, I was stalked and surveiled by private investigators and representatives sent to my then-home town of Denver, Colorado. Miscavige’s personal attorney Monique Yingling and another attorney (Bill Walsh) from Washington DC, along with Tommy Davis and Jessica Feshbach were sent by Miscavige to attempt to ‘settle’ with me so that I would withdraw the corroboration I had provided for Mr. Rathbun’s interview with the St. Petersburg Times. They attempted to use the threat of me never seeing or hearing again front my mother, wife, siblings, and children to force me to cooperate with their demands not to talk to the media. When I refused to be intimidated or paid for silence about crimes I had myself witnessed, I became a public enemy of Miscavige and the church of Scientology in the same fashion as Marty Rathbun. I have been mentioned by defendants in this case on a number of occasions, usually characterized as Mark Rathbun’s associate or co-conspirator. My wife (Christie Collbran) and I have been subjected to a similar campaign of harassment to the Rathbuns as detailed below. Neither me nor my wife have ever sought to counsel anyone since leaving the church.

39.  What I have done is respond to requests for information from the media, starting with speaking to reporters from the St. Petersburg Times (now Tampa Bay Times). I felt it was my obligation to make the truth about what goes on inside the church known. I have also been a witness for the FBI and other law enforcement officers who reached out to me and asked for my assistance in their investigations. As a result, the church has conducted a campaign of intimidation, spying, stalking and harassment against me and my wife and those I have worked with very similar to that conducted against the Rathbun. Clearly its purpose has only been to attempt to intimidate me into silence as David Miscavige and his church did not like what I disclosed about their methods and activities. Unlike Mr. Rathbun, I never attempted to nor purported to counsel former members or apply Scientology to them in any fashion since my departure. What Mr. Rathbun and I hold in common is that we spoke out about what we witnessed. As a result, the same tactics applied against Mr. Rathbun have been applied against me and my wife by RTC and CSI following their longstanding practice of attempting to silence and destroy “critics.”

40.  Since 2009 me (and my wife) have been:

• Repeatedly followed and filmed by Private Investigators (including David Lubow),
• Harassed by “Squirrelbusters” (including Ed Bryan who was arrested while engaged in one of his efforts to harass me on a business trip to Miami),
• Had my garbage taken by church Pi’s,
• Had surveillance cameras trained on my house from neighboring homes and from a specially constructed “bird house” in a neighboring property,
• Had friends, people I have worked with and for and neighbors “noisily investigated,” by Private Investigators working for the church,
• Spies have been sent to try and inveigle themselves into our lives,
• A house within sight of our home became the headquarters for Private Investigators watching us 24 hours a day
• I have been “tailed” by up to 6 vehicles at a time driven by Private Investigators wearing masks when I was in Los Angeles to see the FBI,
• I was followed by at least 2 cars the entire trip when I drove from Tampa. Florida to Houston Texas,
• We have been met and hassled at airports after the church illegally accessed my travel plans,
• I have been followed to other cities by PI’s filming me including to Australia, England and Ireland as well as across the United States, My phone records have been illegally accessed resulting a letter from T-Mobile that they were conducting an internal investigation,
• Had phony postings about “Estate Sales” at my home put on Craigslist resulting in dozens of people knocking on my door starting at 6am on Saturday,
• My car was “keyed,”
• My wife and children have been followed to the supermarket, to the doctor and to the park,
• Numerous websites and publications containing false and defamatory statements about me and my wife have been distributed by the church.

41.  This is all in accordance with the pattern and practice of the Church of Scientology. Attached hereto are two of the key issues that are the “operations manual” of the church and David Miscavige in dealing with anyone perceived as an “attacker.” The most important sections are excerpted from each but the complete writings are revelatory and are ironbound and unbending policy of the church. The first details the operating principle of finding out what the person is seeking to protect and threatening that in order to “restrain” the “attacker.” This is often, as noted, the person’s job, but also includes family, particularly immediate family that the person feels a need to protect. The second gives some examples about how one can create scenarios that will cost someone their job by manufacturing false evidence against them.

1. These persons can always lose their jobs. These jobs, permitting them power to destroy, are valuable to them. This is A POINT OF VULNERABILITY.

2 if the person’s job is also not valuable to him or if he cannot be made to cost his job, something can be found which he is seeking to protect and it can be threatened.

A. COUNTER ATTACK TO OBTAIN THE REMOVAL OF THE PERSON with a product of DISMISSED ATTACKER.

B. If on test, A is not feasible, SURVEY TO FIND WHAT THE PERSON CONSIDERS VALUABLE AND USE IT FOR RESTRAINT

Exhibit A 28 March 1972 COUNTER ATTACK TACTICS

Example: Gosh Porge is located as an antagonistic source in the Bureau of Mines.Study Bu of Mines. They frown on corrupt and bankrupt employees, it is carefully worked out by survey. Gosh Forge receives a check for 250 pounds from the Aluminium Company of America at his office for ‘Yip off and patents sent” and “his wife” runs up fur coat bills at Harrods who sue and “a man in Soho” wants his 1800 pounds gambling debt and “a mistress” calls his boss and demands the return of her diamonds “Gosh borrowed” and as it keeps up, even Gosh Porge’s best denials won’t prevent his being sacked.

And “Legal areas” like lawyers are a point of hit also.

Without consulting Legal Bu Bish Srnish is suing C of S for truckloads. Survey his attorneys covertly. One finds they detest “people from the City”, very prejudiced against money clauses. So City blokes start appearing on their lines for Bish Smish – will he win the suit? Broker wants to know can Bish Smish cover his margins? City bowler hat beats up lawyer with an umbrella because Bish Smish said he was going to get the lawyer to sue him over the “blocks of stock” Bish Smish swindled. Keep it up.
Soon he wont have any lawyer!

Exhibit B 28 March 1972 INTELLIGENCE PRINCIPLES

Miscavige “Enemy” Handlings

42.  Anything that happens relating to “major attacks” on Scientology is micro-managed by Miscavige. Nobody else has the authority to call any shots on anything that could threaten his position. Thus, for example, in 2005 when the Los Angeles Times planned to do a story on Scientology, Miscavige directed every action, cleared all written correspondence (and wrote much of it even though it was sent out in my name), listened to recordings of the meetings I conducted with the reporters and spoke to me on the phone immediately before any meeting I had with them, dining the meeting and immediately after. I would routinely excuse myself from meetings with the media to debrief to Miscavige. Between 1997 and 2004 often if I was recording a media interview Marty Rathbun would be sent along so he could be on the phone reporting in to Miscavige while I was being interviewed. This happened dozens of times. The last thing I did in the church in 2007 was deal with BBC Panorama and Miscavige literally micro-managed minute-by-minute with text messages, phone calls and numerous encrypted emails.

43.  The same pattern occurred with investigations into what were labeled “anti-Scientologists” like Bob Minton — who for a time was the single biggest thorn in Miscavige’s side. Minton is perhaps the closest recent example of someone Miscavige considered a similar sort of threat to his position and reputation as Marty Rathbun, though Minton was not of the same stature as he had never been an “inside?’ who worked directly with Miscavige for years. In. fact, he had never met Miscavige.

44.  Nevertheless, because Minton publicly asserted Miscavige was involved in Lisa McPherson’s death and that he had physically abused his underlings, Miscavige micro-managed the activities of the church to put an end to Minton’s efforts. At various times Miscavige called me numerous times a day for updates on Minton. Otherwise it was daily for several years. For someone like Minton, or now Rathbun, Miscavige required detailed proposals from his underlings (myself, Rathbun, McShane or Sutter back then — whoever is filling our roles today) on the handlings to be taken. He in turn issued detailed orders and responses. All of this correspondence is maintained in a special department that maintains a complete, exact record, both electronically and hard copy of everything that is sent to or emanated from “COB.” These are considered to be the most important documents in the church and they are painstakingly filed and maintained. When I last saw them in 2007 there were literally hundreds or perhaps thousands of 3″ ring binders filled with “COB (written) Orders” and transcripts of his verbal orders, briefings, conferences, discussions and phone calls.

45.  In 1999, Miscavige dispatched Marty Rathbun and me to both Boston and Los Angeles to meet with Minton. On both occasions he gave us special surreptitious recording devices so we could record the entire meeting and forward it to him.

46.  When Minton began picketing the Church in Clearwater over the death of Lisa McPherson, Miscavige ordered pickets to be sent to his home in New Hampshire and also outside businesses he was engaged in. He also ordered pickets outside of Minton’s “Lisa McPherson Trust” office in Clearwater and at the homes of Minton associates including Mark Bunker. In my experience, the exclusive source of this sort of confrontation has been Miscavige. He ordered me personally to arrange a picket and march around the Clearwater Police Department and the St Petersburg Times in 1997 and was on the phone with me the entire two hours of the picket.

47.  The “Squirrelbusters” attack that has been used to harass the Rathbuns in Texas was conceived and instituted by Miscavige in 1984 when be ordered “confrontations” by the original “Squirrelbusters” at David Mayo’s facility in Santa Barbara. This was the beginning of the hostile “confrontations” that continue to this day.

48.  I was charged with the responsibility of locating people who would be willing to carry out such confrontations and harassment and brought in a man named Dennis Clark from Hawaii and a local Scientologist Jim Jackson, They in turn recruited others to join them. h reported on their activities daily, in person, to Vicki Aznaran in RTC who relayed the information to Miscavige. Clark and Jackson were instructed that if they were approached and questioned by anyone concerning their activities, including media or law enforcement officials, they were to claim that they were merely “parishioners” of Scientology who had “decid<xl on their own initiative” to protest Mr. Mayo’s activities.

49.  In addition to the “confrontations” Miscavige personally ordered a full time investigation of Minton that would “find his buttons” and get him to stop complaining about Miscavige’s abuses and “stirring up trouble.” The investigator I assigned to this was David Lubow. I met with Lubow in Clearwater and briefed him (relaying specifically what Miscavige told me the investigator was to do). This included extensive surveillance of Minton and his family, investigating all neighbors and business contacts and being “in his face” at all times. Lubow’s  reports were relayed by me to Miscavige as “Eyes Only” reports or when I was in the same location as him I verbally relayed them to his face.

2010 Texas Experience

50.  In April 2010 I flew to Corpus Christi, Texas where I was met inside the terminal by 5 individuals dispatched by Captain Miscavige to attempt to intimidate me and prevent me from meeting an old friend, John Brousseau (“JB”). JB had recently escaped Miscavige’s guarded compound near Hemet, California and made his way to Mark and Monique Rathbun’s home near Corpus Christi. Like Rathbun,18 was an extremely high priority problem for Miscavige as he had worked closely with Miscavige and Tom Cruise. Miscavige spared no expense to try to prevent JB from connecting with Rathbun and me.

51.  I had traveled to Corpus Christi with the express approval of the FBI (who paid my airfare) to determine whether JB was legitimate and to ask him to speak with the FBI.

52.  I soon learned that there were many more than those 5 people despatched by private jet to Corpus Christi that day. In addition to those 5 Church spokesman Tommy Davis and three other church executives who at the time worked exclusively for Miscavige (Angie Blankenship, Laurance Stumbke and Bob Wright), Tom Cruise’s former assistant Michael Doven, Scientology actors Michael Roberts and Michael Duff, as well as several others from Miscavige’s personal entourage at the Hemet church high security base where he lives.

53.  Nobody other than Miscavige has authority to order staff from different churches as well as public Scientologists, to get on a private plane and fly to Corpus Christi to try and prevent JB from meeting with Marty Rathbun and me. The Corpus Christi Airport Police and local FBI agents ultimately arrived on the scene to ensure I had safe passage to leave to meet with Marty Rathbun and JP, and subsequently accompany JB to meet with the FBI in San Antonio 3 days later.

54.  Over the course of more than 20 years I knew the level of situation that Miscavige insisted he call the shots on: Any international media. Any legal case that might directly implicate or involve him. Any significant negotiations with major governments (US, UK, Spain) concerning tax exemption. Potential criminal prosecution in the United States. Anyone exposing his dirty laundry and threatening his PR or position. Marty Rathbun fits into virtually all of these categories. He has been interviewed by major international media. He has been a witness for legal cases and provided declarations. He was one of the key witnesses/informants for the FBI investigation. And he has more direct personal knowledge of the activities of David Miscavige than perhaps anyone else on earth. Thus, there is not a chance that any action would be taken concerning Marty Rathbun (or his wife) that was not either ordered by David Miscavige or sanctioned by him in response to a detailed proposal of action requested by him. Of that there is no doubt.

My name is Michael John Rinder. My date of birth is April 10th, 1955. My address is 808 Bentwood Ct, Palm Harbor, Florida.

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

Executed in Pinellas County, State of Florida, on the 3rd day of December 2013.

Michael Rinder

Notes

  1. Document in PDF format.

Be Glad You Lost, Julie (November 9, 2003)

By Dan Garvin
9 November 2003

Source: http://groups.google.com/group/alt.religion.scientology/msg/71f514f4e97f24231


In the summer of 1985, I had been in OSA Int for less than a year. I was in charge of external computerization for OSA, which meant I got to go all over the place setting up and taking care of anything that had a CPU and wasn’t inside OSA Int. Up in Portland, Oregon, the “Christo Trial” was getting going. There was already a Trial Unit of OSA Int, OSA US, local DSA and other staff and some volunteers. Some attorneys were also in Portland Earle Cooley was the main one I dealt with. Miscavige was there, as were Marty Rathbun, Mike Sutter, Lynn Farny, Ken Long, Karen Hollander, and many other names you’d recognize. Many famous SPs were there too. Somebody got a nice picture once of Gerry Armstrong flipping the bird at the camera as he was leaving the courtroom.

The Christo Trial was a damages suit by Julie Christofferson against the Church in Portland for, IIRC, fraud and emotional distress and a number of related torts. By that time she was Julie Titchbourne, but we still called the case Christo in OSA. After a while, I was called up from LA. There were two or three condominiums in the same building in downtown Portland, near the courthouse. One was Earle Cooley’s; one was the work and research area for the OSA Int execs and senior Legal personnel; I think there was a third one for the ASI/RTC personnel (at that time, Miscavige was still calling himself ED ASI, although he was just as much the boss of everything as he is now, at least as far as OSA was concerned). These condos were fairly luxurious. The lesser beings worked in the Trial Unit at the Celebrity Centre. I got to work in the OSA Int Condo, although I slept in a hotel some distance away.

The reason I was brought up is that they wanted transcripts of the proceedings loaded into computers on a daily basis so they could be searched by Cooley, Farny, Long, et al. At first, so I was told by one of the attorneys (probably Tim Bowles), we were not even supposed to have been given the transcripts. Only the attorneys were allowed to have them, for some reason. So our attorneys of course violated this order and gave the transcripts to me and to other personnel. But I got pretty crappy copies. I had miniature duplicates of the INCOMM computers set up in the condo. They were made by a company called WICAT, and they had a Unix-like proprietary operating system. We had one or two OCR – optical character recognition – machines set up. In those days, OCRing was pretty primitive (or prohibitively expensive), and these could only handle certain fonts, which had to be in very good condition. So the crappy and illicit copies we were getting had to be mostly typed in by hand, and for that there were about a half dozen personnel who had been doing that type of thing in LA.

Later they got permission to let us have copies of the transcripts, and the quality improved vastly. The other typists were sent home and I was pretty much running the whole computer show. I could OCR and correct everything by myself. We had huge rack-mount tape drives with twelve- or fourteen-inch reels, each holding 10 MB of data. I used these for backups and to transfer the data up to the computer in Earle Cooley’s condo. The information was loaded into a database that INCOMM called FAST, which was like SIR, or Source Information Retrieval, which is all the LRH issues (of all kinds, and advices too for those authorized) in a searchable database. FAST was the same system exactly, but for non-LRH material. OSA was inputting all the documents in all legal cases, and later added just about everything else as well. When a case was going on, everybody would rush to get it into FAST as soon as possible so the legal vultures could pick it over for anything they could use to win points the next day in court.

The Christofferson case is a fascinating story, but one I don’t know very well. What’s relevant to this post is, we lost. The jury awarded Julie Titchbourne something like $30 million. Nothing like this had ever happened before (so I was told and believed). The loss would set a precedent and all the other “frivolous” deep-pocket lawsuits against Scientology churches would fall like dominoes in favor of the enemy. We were crushed. I had not been in the courtroom once the whole time I was there, but I came down to hear the decision – and share in the victory. When I heard the award against us, I literally did not know what to do. I thought it was the end of the world, or pretty close. It was impossible and unthinkable. Our religion could be shut down by ambulance-chasing attorneys and professional victims. I wandered out of the courtroom in a daze. I went down to a park in town and just walked around. Everything seemed surreal. But I realized we would not just cave in. We would appeal. We would fight with every ounce of our strength, and when that was gone, we would still fight on. I started to feel a little better. All the same, it was unbelievable. After all, RTC and ASI were running things directly, and if anybody would make sure LRH legal tech was standardly applied, they would and still we lost. Man, there must be some heavy-duty corruption going on behind the scenes, to create such a miscarriage of justice! Well, we’d find that, too, and somehow we’d win. We had to. The survival of the world depended on it.

So I got tired of moping and headed back to the condo. The execs and OSA guys were there; I don’t remember which ones but probably most of the ones who normally worked or attended conferences there. Nobody was saying much; it looked like everybody else hadn’t finished moping yet. So I took a hint and resumed moping. Every once in a while somebody would wonder what the hell we were going to do, or what went wrong, and speculate about how bad it was going to be. After a while, the CO OSA Int, Mike Sutter, spoke up. He said  (paraphrasing), “I don’t care if she thinks she won. That bitch is never going to see one single cent. I’ll kill her first. I don’t care if I get the chair it’s worth it. It’s just one lifetime.

I froze. I wasn’t moving much to begin with, but I froze solid. I didn’t want to breathe. I forgot all about our immediate problems. My CO had just said he was going to murder Julie Titchbourne. He was absolutely serious. I was in shock. Sure, she deserved to die all SPs did. But you can’t actually do that that sort of thing. My thoughts raced. Please, I thought, please, somebody say something that will make this stop. I was trying to think what I could say. If I said the wrong thing, or said it the wrong way, I’d be out of there that night and getting sec checked the next day. But this was madness!

There was not a sound in the room. It seemed like ten minutes but was probably only one. Finally Miscavige spoke up. Here’s what he didn’t say: He didn’t say, “Sutter, you’re fucking crazy, we don’t kill people!” He didn’t say, “You’re joking, right?” He didn’t explain that Julie’s estate would still get the money or that killing a plaintiff would be a hundred times worse for the Church than paying her even the whole $30 million. He just said, “No, this is what we’re going to do.” And then launched what within a day or two became the Portland Crusade.

The Crusade, along with a lot of flanking actions and, according to Cooley, his own research in the database I’d put together for him, worked, and the Judge, Londer, eventually threw out the decision. Julie would have had to start from scratch, with much tighter restrictions on what was admissible as evidence. I guess they just gave up.

Julie deserved that money, or at least some compensation for being screwed over by Scientology. I’m sorry for my part in stopping her from getting paid. But, then again, if the Crusade and everything had failed and she had won in the end, I wonder if Sutter would ultimately have made good on his promise to murder her. Even if the estate still collected Julie’s money, it sure would have made other plaintiffs think twice about their own cases. It may be that Julie’s loss is the only reason she is alive today.

One thing I am absolutely certain of: When Mike Sutter said he would kill her, he meant it, absolutely and literally. He certainly was not reprimanded or corrected at the time by anyone for suggesting this, and if any action was taken against him later, it was nothing I ever heard about – nor did anybody ever pull me aside and say, “You know we would never actually do that, right?” or some such. In fact, a few months later he was promoted to RTC. He was still in RTC as late as 1995 or so. I don’t know if he has been seen in the last few years. That could mean a number of things. He could just have a post that never requires him to leave the Gold Base, or he could have gone to the RPF, or he could have been transferred somewhere else on some secret post or mission. Or, for all I know, he could have gone off to do the Hit Man Full Hat and Apprenticeship.

Hubbard’s Code of Honor says, near as I can recall, “Your honor and integrity are more important than your physical body.” Also, the third and fourth dynamics (the group Scientology, and all mankind) are more important than anyone’s first dynamic (self an SP’s life or the life of whatever hero murdered the SP). To the average Scientologist and perhaps the average SO member, this interpretation of those ideals may sound extreme, even beyond extreme. As one nears the top of the ladder, though, I think they’re pretty typical. What may not be typical is the willingness to actually go through with it, mainly because the repercussions on Scientology would be far worse than the consequences of not committing the murder.

Lurkers, those of you still in the COS this is a glimpse at a side of RTC that you don’t hear about at the International Events. Next time you’re watching David Miscavige spewing his glib, formulaic PR at you, try remembering that this is a man to whom murdering a plaintiff was apparently just another option, one that he ultimately rejected in favor of a better one, but one he seemed to have no fundamental objections to.

Dan Garvin

Notes

Testimony of Jesse Prince (Volume 4) (July 9, 2002)

0467

IN THE CIRCUIT COURT FOR PINELLAS COUNTY, FLORIDA
CASE NO. 00-5682-CI-11

DELL LIEBREICH, as Personal Representative of the ESTATE OF LISA McPHERSON,
Plaintiff,

vs.

CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, JANIS JOHNSON, ALAIN KARTUZINSKI and DAVID HOUGHTON, D.D.S.,
Defendants.
_______________________________________/

PROCEEDINGS: Defendants’ Omnibus Motion for Terminating Sanctions and Other Relief.

Testimony of Jesse Prince.

VOLUME 4

DATE: July 9, 2002.

PLACE: Courtroom B, Judicial Buiding
St. Petersburg, Florida.

BEFORE: Hon. Susan F. Schaeffer, Circuit Judge.

REPORTED BY: Donna M. Kanabay RMR, CRR, Notary Public, State of Florida at large.

0468

APPEARANCES:

MR. KENNAN G. DANDAR
DANDAR & DANDAR
5340 West Kennedy Blvd., Suite 201
Tampa, FL 33602
Attorney for Plaintiff.

MR. LUKE CHARLES LIROT
LUKE CHARLES LIROT, PA
112 N East Street, Street, Suite B
Tampa, FL 33602-4108
Attorney for Plaintiff.

MR. KENDRICK MOXON
MOXON & KOBRIN
1100 Cleveland Street, Suite 900
Clearwater, FL 33755
Attorney for Church of Scientology Flag Service Organization.

MR. LEE FUGATE and MR. MORRIS WEINBERG, JR. and ZUCKERMAN, SPAEDER
101 E. Kennedy Blvd, Suite 1200
Tampa, FL 33602-5147
Attorneys for Church of Scientology Flag Service Organization.

MR. ERIC M. LIEBERMAN
RABINOWITZ, BOUDIN, STANDARD
740 Broadway at Astor Place
New York, NY 10003-9518
Attorney for Church of Scientology Flag Service Organization.

MR. STEPHEN WEIN
BATTAGLIA ROSS DICUS & WEIN
980 Tyrone Blvd.
St. Petersburg, FL 33743
Attorney for Mr. Minton.

0469

INDEX TO PROCEEDINGS AND EXHIBITS
                                                       PAGE  LINE
Recess                                                    535   10
Recess                                                    580   3
Reporter’s Certificate                          581  1

0470

(The proceedings resumed at 10:05 a.m.)

[… Other court business.]

THE COURT: Okay. I’m ready for Mr. Prince.

MR. DANDAR: All right. Thank you.

THE COURT: He’s still under oath. Same oath he’s taken. You only have to take it once.

You may continue, Mr. Dandar.

MR. DANDAR: Thank you.

THE COURT: Mr. Wein, you’re going to hear some unusual evidentiary rulings here, because we’re dealing with things like, perhaps, state of mind of your client. However, you don’t have — you’re  just — your client is nothing but a witness in this hearing. Therefore, as I told Mr. Battaglia yesterday —

MR. WEIN: I understand I can listen but I  shouldn’t be standing up and objecting.

THE COURT: That’s correct.

And you might think, “What in the world kind of

0499

rulings is she making? She doesn’t understand anything about the rules of evidence.” This is an unusual hearing with unusual rules, and we’ve got some objections that have been made and will be preserved, that have been made, First Amendment objections, expert objections, stuff like that, that are preserved. So you might hear triple hearsay come in in this hearing. It’s just an unusual hearing. So —

MR. WEINBERG: So it’s both the lawyers that aren’t objecting —

THE COURT: Yeah. When you hear that —

MR. WEINBERG: (Inaudible.)

THE COURT: When the lawyers don’t object —

MR. WEINBERG: (Inaudible, simultaneous speakers.)

THE COURT: — just understand that we’re involved in somewhat of an unusual hearing, and I’ve made some somewhat unusual evidentiary rulings already. So we’re —

MR. WEIN: Yes, your Honor.

THE COURT: — taking it from there.

Continue.
__________________________________________
25
0500

BY MR. DANDAR:

Q  Mr. Prince, I’m not sure I asked you this question yesterday or not, but are you aware that Mr. Minton received from me any information concerning any of the mediations in this wrongful death case?

A  No, I am not.

Q  Did Mr. Minton ever talk to you and say, “Oh, Ken Dandar told me this about the mediation and what was said at the mediation”?

A  No, he did not.

Q  Now, before you left the Church of Scientology, how many years did you know — personally know David Miscavige?

A  I’d say about 12 years.

Q  And yesterday you said you were a friend of David Miscavige?

A  I said we’d been friends; we had been friends, close friends, at a point in time.

Q  Okay. When did that friendship end, if at all?

A  Well, it’s been quite a while since we’ve talked to each other. Probably — you know, if we talked to each other — I don’t know — maybe we could still find some friendship there. But we haven’t talked for quite a while.

Q  Well, give us a year. When did you last talk to him?

0501

A  ’92.

Q  And is ’92 the year that you were no longer a Sea Org member?

A  ’92 is the year that I left.

Q  Okay. And prior to leaving, did you still consider him to be your friend?

A  Yes, I did.

Q  Okay. And did he work with you in RTC when you were deputy inspector general?

A  Yes, he did. And as a matter of fact, more often than not I would report to him.

Q  Rather than Vicki Aznaran?

A  Together with Vicki Aznaran or without Vicki Aznaran.

Q  Can you describe to the court his management style?

A  Well, same management style that’s pretty much taught throughout the management series of Scientology, wherein an executive is expected to know about or be in control of all areas underneath the executive.

Normally when you have a person that’s high in the organizational chart in Scientology, you’ll have a seven-division org board. The person that is over that activity has to know the details of what’s going on in all of those seven divisions. Each division may be having three

0502

separate departments, as many as three separate departments, and different units within the department. So there could be a lot of people there. There is provisions for inspecting, getting information, and on and on and on, with that. But it’s very much expected to know everything.

But it certainly gets carried to an extreme, or certainly was carried on to an extreme during my tenure there, in that certain sections or areas would be micromanaged to the point where the staff in that area could only act on orders and comply with orders, comply with command intention, comply with programs. There was not a lot of original thought process going on in some areas by staff.

Q  How far down the org board did you personally observe Mr. Miscavige micromanaging during your tenure?

A  All the way down to the janitor.

Q Really.

A  Yeah.

Q  Would he manage that way with RTC or would he go outside of RTC?

A  Would go outside of RTC. There’s plenty of examples of that.

Q  Can you give us a few?

A  Well —

MR. WEINBERG: Could we just date this? I was

0503

under the impression that when Mr. Prince was at RTC, Mr. Miscavige wasn’t. So can we put a date when he’s talking about?

THE WITNESS: I certainly will.

THE COURT: And what was that?

THE WITNESS: Well, I haven’t spoken of any instance yet, but the instance that I’m about to talk about right now happened in 1985 — and I do believe I’ve done a declaration about this before — whereby myself, David Miscavige, Vicki Aznaran, Mark Yeager, Mark Ingber, Ray Mithoff, the usual crew, came to the FSO.

BY MR. DANDAR:

Q  Flag?

A  Flag Service Organization.

Q  In Clearwater?

A  In Clearwater, Florida.

Went through the entire organization, started declaring suppressive persons of staff and public on the spot; people that we didn’t want or felt were inappropriate to be in the Flag Service Organization.

I’ve given a declaration about that before.

THE COURT: Have I seen that declaration?

MR. DANDAR: I don’t — I don’t think —

Was it — it wasn’t in this case, was it?

0504

THE WITNESS: No. I believe it was in another case.

I will certainly find it, when —

THE COURT: That’s all right. I just didn’t know — I didn’t remember —

MR. DANDAR: No, it wasn’t.

THE COURT: — reading it.

MR. WEINBERG: Does he know what cases?

Was it the Wollersheim case?

THE WITNESS: I believe it may have been.

A  There’s another instance that was produced and written about by KSW News or Scientology News, where again the usual crew — myself, Miscavige, Lyman Spurlock, Ray Mithoff, Mark Ingber, Mark Yeager, several Scientology attorneys — went to San Francisco to have a mission holders’ conference with the current mission holders.

THE COURT: Go to the mission —

THE WITNESS: Mission holders. Mission holders would be like franchise holders, organization — The Scientology organization is one thing.

Then you can have a franchise of that which is called a mission. And the mission holder would be the owner of the mission.

THE COURT: I see.

A  Anyway, we went up to San Francisco to have a

0505

mission holders’ conference. And prior to actually having the conference, we stopped in a local Scientology organization, the San Francisco organization, went through the entire organization, spoke to everyone in the
organization, and removed the executive from the organization, removed other people, and left.

BY MR. DANDAR:

Q  What gave you the power —

MR. WEINBERG: Could you please date that one too, please?

BY MR. DANDAR:

Q  What year was that?

A  That one was 1982 — late ’82 or very early ’83, as I recall.

Q  And what gave Mr. Miscavige and your group the power to go into a separate corporation, the San Francisco organization, and remove officers of the corporation?

A  This is the subject of something I’ve also given extensive testimony and declaration about, because it goes to alter-ego within Scientology.

But there’s a thing called mission tech, where Sea Org members can get together on orders based on Sea Org programs, and go into any organization and take it over completely and remove its executives, alter, change its policy, change its board of directors, change whatever it

0506

wants to. And once it deems that the activity is performing to the expected standard, then the mission will pull out.

Normally these missions last for two, three weeks.

Q  So it has to do —

THE COURT: Mission —

I’m sorry, Mr. Dandar. We must be driving you crazy.

The mission lasts for two or three weeks, meaning the mission church or the mission of these folks that are going in to take a look?

THE WITNESS: The mission of these folks going in to take a look —

THE COURT: Okay.

THE WITNESS: — your Honor.

BY MR. DANDAR:

Q  And the officers of the corporation are removed because they’re doing —

I mean, what’s the reason for that? Let’s talk about the San Francisco organization.

THE COURT: Why is that relevant?

MR. DANDAR: It’s the power of the Sea Org, which is one of the issues raised at this hearing.

MR. WEINBERG: But it’s not an issue at this hearing. It may be an issue he’s trying to raise, but the issue at this hearing is whether or not, A,

0507

there was misconduct by Mr. Dandar and others; and B, whether or not there was a basis to allege that David Miscavige had ordered the killing, death of Lisa McPherson. Not Sea Org, none of that.

THE COURT: Well, part of the allegation was he was the head of the Sea Org, which was by — That is an issue.

MR. WEINBERG: But it’s — it — Mr. Miscavige, as we know, is not a party, because he didn’t pursue — that was the way they got him to be a party, by saying he was outside of the contract —

THE COURT: I —

MR. WEINBERG: — and —

THE COURT: — understand that, Counsel. But the allegation in the complaint that you are trying to get a summary judgment on and — and have dismissed as false is that David Miscavige did these certain things. And that still is part of the complaint, whether he’s a party or not.

MR. WEINBERG: There’s a lot of accusations in the complaint that I guess Mr. Dandar could have this hearing go for the next three months about, but that isn’t a central — I’ve said my piece.

THE COURT: Thank you.

0508

BY MR. DANDAR:

Q  So Mr. Prince, you and your party, which included Mr. Miscavige, ousting the corporate officers of the San Francisco corporation, what — what gave them the power to do that?

A  Again, it was just Sea Org — it’s called Sea Org mission tech, where a person in the Sea Org, called a mission op, or operator — mission ops, it’s called — will put together a set of, like, project order to get done in the organization.

They may call for removing the executives; it may call for investigating and then removing upon determination; it may call for training; it may call for correction.

Q  And back in late ’82, early ’83, when you and Miscavige and the others went to San Francisco, who was the head of the Sea Org?

A  David Miscavige.

Q  And when you left in ’92 —

THE COURT: Mr. Hubbard was still alive then?

THE WITNESS: In 1992, yes.

MR. DANDAR: No, ’82.

THE COURT: ’82.

THE WITNESS: Oh. ’82. Yes. I’m sorry.

THE COURT: And he was not the head of the Sea Org?

0509

THE WITNESS: Yes, he was. He was the commodore.

But you know, we were going through this whole song and dance to try to get tax-exempt status for the various organizations of Scientology, and the problem came up where I guess it was determined that L. Ron Hubbard — it was found that L. Ron Hubbard was the managing agent of Scientology and the Sea Org. And so Mr. Hubbard, by that time, had really separated himself for the purposes of allowing this church entity — these Scientology entities to get tax-exempt status. He had kind of separated himself totally from Scientology activity.

THE COURT: Okay.

BY MR. DANDAR:

Q  So when he separated himself, who took over as the head of the Sea Org?

A  Miscavige. David Miscavige.

Q  And when you left in ’92, who was the head of the Sea Org?

A  David Miscavige.

Q  Was there anyone in the Sea Org that had equal or greater rank than David Miscavige from ’82 to ’92 when you left?

A  At the time before I left, David Miscavige — this

0510

whole thing with brevet rank and being a captain and stuff — this is something that happened, I believe, later, after I was done there.

Mr. Miscavige derives his authority from being the chairman of the board of nearly every — all of the major corporations. He’s on the board of directors somehow, where he derives —

And then also, as far as Sea Org is concerned, Miscavige — I mean, basically, L. Ron Hubbard passed the torch to Miscavige. He didn’t pass it to Miscavige; he passed it on to Pat and Annie Broeker. Miscavige got rid of Pat and Annie Broeker, so effectively took control of Scientology.

Q  And did he take control of Scientology as the chairman of the board of some corporation or through the Sea Org?

A  He took control of Scientology through — by corporate means. And he was able to — You see — you see, this may be a little confusing, so I think this is worth — takes a moment to explain.

The Sea Org operates on not only these green policy letters and these red bulletins that we’ve seen, but the Sea Org has its own issues and issue types that it operates on. And they’re called Flag orders. Flag

0511

orders — you know, they supersede corporate boundaries; supersede posts or positions or whatever.

A  So Flag orders — L. Ron — the last Flag order that he wrote, he turned over Scientology to Pat and Annie Broeker. He called them loyal officers. Loyal officers is a term that comes up from reading Scientology’s, quote/unquote, advance materials. That was — loyal officers were supposed to be the highest rank in Scientology.

Miscavige — after L. Ron Hubbard passed, Miscavige cancelled that issue, did not let Pat and Annie —

THE COURT: We don’t really need to go there, do we?

MR. DANDAR: Well, I’m leading up to one question.

THE COURT: Okay.

A  Anyway, he effectively took it over.

BY MR. DANDAR:

Q  All right. Now, why is it that paragraph 34 — based on your affidavit, why is it that it alleges that David Miscavige, outside of anyone else, would be the person who would have given this order to end cycle?

A  Well, I think what my affidavit actually says is — is David Miscavige would have sat there with Ray Mithoff, with Marty Rathbun, the people that meet, to — to

0512

make sure that the flaps within Scientology that are a threat are dealt with. I think what I said there was that those three people would have gotten together and decided —

THE COURT: Ray Mithoff and who else?

THE WITNESS: Marty Rathbun.

MR. DANDAR: R-a-t-h-b-u-n.

THE WITNESS: Would have sat there with full knowledge and information of what was going on with Lisa McPherson. And instead of letting her be taken to a hospital, would have told these people to just let her stay there, and let’s see what happens here.

Let’s continue. See if we can, you know, finish the introspection rundown. Don’t put her on any line where she can tell a story about what’s happening to her.

In other words, let her die. If she dies, that’s what happens.

BY MR. DANDAR:

Q  Now, what if the — based upon your tenure and your experience of working with Mr. Miscavige, Mr. Rathbun, Mr. — I’ve forgotten the third name.

A  Mithoff.

Q  Mithoff.

If Mr. Mithoff and Mr. Rathbun said, “No, no, no. We have these reports, that she needs to — she’s not

0513

doing — she’s getting worse. She needs to go to the hospital. Send her to the hospital,” and Mr. Miscavige says, “No. We’re not going to do that,” out of those three, who prevails?

MR. WEINBERG: Objection. This is just rank speculation.

THE COURT: It would appear to be so, except I believe he indicated, back when he was at RTC, these same people were there?

MR. WEINBERG: No. Mr. Mithoff was in CSI.

Mr. Rathbun was not in RTC.

I — I mean, he —

BY MR. DANDAR:

Q  Mr. Prince —

MR. WEINBERG: — at the time —

THE COURT: I’m going to allow it, because I know what the answer is. I mean —

BY MR. DANDAR:

Q  Mr. Prince, who was in RTC when you were in RTC, at these meetings?

MR. WEINBERG: No —

A  The only people that were in RTC were myself and Vicki Aznaran. David Miscavige was the chairman of the board of Author Services, a for-profit corporation that was L. Ron Hubbard’s publishing company. However, that meant

0514

nothing in relationship to who were the principals of Scientology, who were directing — directing the actions of Scientology as a whole. And the people that were doing that were David Miscavige, myself, Vicki Aznaran, Mark Yeager, Mark Ingber, Lyman Spurlock.

THE COURT: Was there a majority vote taken?

THE WITNESS: There’s no such thing as a vote in the Sea Org, unless you’re deciding on a quality of food, in Scientology.

THE COURT: If you disagree on a decision, who made the final call?

THE WITNESS: If you disagreed on a decision — if you disagreed with someone that was above you, you would be sent for correction to straighten out your —

THE COURT: Look, if you folks are sitting around trying to decide something — you and all these people, you said, were kind of a — there — and you disagreed; you know, you said, “I think this should happen,” Ms. Aznaran said, “I think this should happen,” David Miscavige said, “I think this should happen,” who made the call?

THE WITNESS: Ultimately the person who would have the authority and everyone would have to follow would be Mr. Miscavige.

0515

THE COURT: So he — he made the final call.

THE WITNESS: Yes, he would say, “Okay. Yeah.

This is how you do it.”

BY MR. DANDAR:

Q  Would he get input from the others for —

A  Yes. I mean, that happened. But the purpose — I mean, you know — and I just want to clear this picture — make this picture a little bit more clearer as to how it actually works.

Mr. — Mr. Mithoff, based on how it worked when I was there — I’m just going to explain this. Mr. Mithoff would have brought this situation to the attention of Mr. Rathbun. Mr. Rathbun would have looked over this — okay. And again, in my mind, I’m not going with the theory that she was crazy when they took her to the hospital; I’m not going with the theory that she just lay there and wanted to be there; I’m going with the theory that, just like she said, she wanted to leave. She was trying to leave. They incarcerated her, falsely incarcerated her, wouldn’t let her leave.

So Mr. Mithoff would have brought it to Mr. Rathbun’s attention. Because you have a threat. You have a person that is now escalated. They want to get out. And now they’re sick. It’s going bad — worse to bad. Mr. Mithoff would have taken and put an exact

0516

instructions in her folder, went over it with Mr. Rathbun.

And at the meeting they would have sat down with Mr. Miscavige and said, “This is the situation. This is the flap. This is the handling.” If their handling included not taking her to the hospital and keeping her there  and doing Scientology on her, Mr. Miscavige would have said, “Fine.” If their handling would have been, “Look, I think we better take this risk even though she is antagonistic, and we got to send her to the hospital,” it is my opinion that his answer would have been, “No. You leave her right there.”

Q  And why is that? What do you base that opinion on?

A  I base that opinion on the fact that protecting Scientology is the ultimate goal of any Scientologist, irrespective of friend, family, business. Scientology comes first. Because the idea in Scientology is that Scientology’s going to save the world. And if you lose Scientology, you lose the world. So it’s the greatest good to protect Scientology than it would be to be concerned about an individual, or a group, for that matter.

Q  Now, are you familiar with the term and policy letter called “bypass”?

A  Yes, I am.

Q  All right. Can you tell the court what that is?

0517

A  Bypass is a situation — I guess I can just do a real example here using the court reporter. If this court reporter here were typing transcripts and she were making too many errors, someone else would have to come in here and take over her job and — while she goes and gets fixed or gets corrected, and takes over her actual job, and does the job until she’s able to perform it again.

Q  Do you have an opinion whether or not, in Lisa McPherson’s case, bypass would have come into play?

THE COURT: I don’t understand that. I’m sorry. Maybe I just didn’t understand the example.

Maybe —

THE WITNESS: Okay. I’ll try to do another example, your Honor.

THE COURT: Bypass, to me, means you jump over somebody or you go around someone.

THE WITNESS: Well, you actually displace that person and assume their position.

THE COURT: Oh, I see. Okay.

THE WITNESS: Until they can do the job correctly.

THE COURT: Okay.

BY MR. DANDAR:

Q  Let me show you —

THE COURT: I don’t think he answered your

0518

question. I interrupted him. So if you want an answer, do you —

MR. DANDAR: Well, I’m going —

THE COURT: In the Lisa McPherson case —

MR. DANDAR: No —

THE COURT: — did bypass occur?

MR. DANDAR: I’m going to ask a question first.

THE COURT: Okay.

MR. DANDAR: I’m going to interrupt myself.

THE COURT: All right.

BY MR. DANDAR:

Q  Let me show you what I have marked as Plaintiff’s Exhibit 127, see if you can identify this.

A  Okay.

Q  Can you identify this?

A  Yes, I can. This is what’s commonly referred to as a CBO, central bureau order. It’s another issue type that Scientology puts out, you know, like a bulletin or a policy letter. And this particular issue talks about senior management bypassing into lower areas or lower units within the Scientology infrastructure.

Q  Under what circumstances would that happen?

A  This would happen at any point where the senior officer or senior body felt that there was a situation going on in a lower area that wasn’t being dealt with to par.

0519

Q  Now, do you have an opinion, based upon your experience in Scientology, whether or not, after your review of the Lisa McPherson matter, the policy bypass would have come into play?

MR. WEINBERG: Objection to competence. I don’t even know what this is. I mean, this is not written by L. Ron Hubbard, apparently. It’s not in the green volumes or the red volumes. There’s been no — there’s been no —

And Mr. Prince said he knew what bypass was. Well — but — and now he’s going to apply it to some hypothetical situation that he doesn’t have any personal knowledge of?

THE WITNESS: I think the issue speaks for —

THE COURT: I —

THE WITNESS: — itself.

THE COURT: I think for this purpose of this hearing, I just want to hear everything he has to say.

MR. WEINBERG: I understand. I just —

THE COURT: So I’m going to allow it.

MR. WEINBERG: Every now and then, I just need to get up to renew —

THE COURT: All right.

MR. WEINBERG: — my —

0520

Just so Mr. Wein —

Is it Wein —

MR. WEIN: Yeah.

MR. WEINBERG: Mr. — I’m “wine,” and he’s “ween.”

THE COURT: I want to hear everything —

MR. WEINBERG: Okay.

THE COURT: — because I want to find out all the things that Mr. Prince may have, as Mr. Dandar’s consultant —

MR. WEINBERG: I understand.

THE COURT: — told him about, so that I can have some understanding of the complaint and the allegations you’ve made. And so I’m going to allow it.

BY MR. DANDAR:

Q  Have you seen this document before today, Mr. Prince?

A  Yes, I have.

Q  And under what circumstances have you seen that?

A  I have seen this during messenger training.

I had to, myself — when I went to Gilman Hot Springs in 1982, I became what’s called a commodore messenger. And I’ve explained that endlessly too. It’s a person — it’s an emissary of L. Ron Hubbard who has the

0521

same authority as L. Ron Hubbard. When they come with an order to an area, it’s like L. Ron Hubbard giving an order to an area. So you know, this has the highest level of priority, as far as compliance’s concerned.

I became a commodore’s messenger. And as part of being a commodore’s messenger, this was the first time in my study pack on the duties of commodore’s messenger that I read this particular issue.

Q  Okay. And do you have an opinion whether or not this bypass would come into play in any part of the matter concerning Lisa McPherson?

A  I think it would have certainly come into play, given the fact that Mrs. McPherson was not being cooperative or — and actually intended to leave Scientology. And this was consistent in what she was saying. So that’s like a breach of technology. There’s no such thing as Scientology not working, as far as the written materials are concerned. If Scientology doesn’t work, then something is wrong with the individual. Somebody has done something wrong or somebody has misapplied it.

So if you have a person in the extreme situation like Lisa was, that continued, that would be reason for bypass; to come in and, you know, deal with it specifically.

Q  Who gets involved when bypass happens?

A  For the FSO?

0522

Q  Yes.

A  Normally Ray Mithoff.

Q  In what position?

A  He’s the senior technical person internationally for Scientology. The Flag Service Organization is the senior mecca of technical perfection as far as Scientology is concerned, so the — the Flag Service organization is certainly one of the major providences of the senior CS  international.

Q  Now, a while back, you know, in my office, you pulled out an OW of Lisa McPherson —

THE COURT: OW?

MR. DANDAR: Overt withhold, abbreviated OW.

BY MR. DANDAR:

Q  — that she wrote in the fall of ’95, concerning February of ’95, where she mentioned management had to get involved? Do you recall that?

A  Yes. This was a — right around the first time I believe that Lisa started experiencing severe difficulty with Scientology, as far as her relationship to it. And she mentioned that whatever was going on with her was — you know, technically it resulted in a bypass by senior management; a bypass of the Flag Service Organization, to specifically help her and deal with her situation.

Q  Now, we already have in evidence and marked as

0523

Exhibit 96 —

And this is an extra copy.

MR. DANDAR: And Judge, I’ll show it to you if you need to see it again.

BY MR. DANDAR:

Q  But it’s the Heide Negro (sic) isolation watch report. Did you see that before?

A  Yes, I did.

Q  And on the second page it talks about —

THE COURT: That’s in evidence?

MR. DANDAR: Yes. 96.

THE COURT: Oh, okay. It’s been a long time.

THE WITNESS: I think she needs —

MR. DANDAR: It is a long time.

THE COURT: Thank you.

BY MR. DANDAR:

Q  On the second page, first paragraph of the last sentence —

MR. WEINBERG: Well, hold on. Mr. — I object to his competence — he has no personal knowledge of any of this.

THE COURT: I don’t even know what the question is going to be, so —

MR. WEINBERG: He’s now going into

0524

somebody’s —

THE COURT: Well, you don’t know what he’s going to go into because you haven’t heard the question. So let’s hear it and I’ll —

MR. WEINBERG: If I could —

THE COURT: Go on ahead with your question.

BY MR. DANDAR:

Q  Okay. The first paragraph, it says that this data came originally from FSO CS, Alain Kartuzinski, who was in charge of John Taylor’s correction. Who —

THE COURT: See, I don’t even know where you’re reading from.

MR. DANDAR: I’m sorry. First paragraph on page 2.

THE COURT: Oh. Page 2.

MR. DANDAR: Yes. I’m sorry.

THE COURT: Okay. Go ahead.

BY MR. DANDAR:

Q  “This was later corrected by a telex from Mr. Ray Mithoff, who indicated that the RD –” I guess that’s rundown —

A  Right.

Q  “– in fact could be delivered, at which point delivery commenced.”

0525

Now, what does that mean in plain English?

A  There was a question of whether or not this person could be given the introspection rundown. Alain Kartuzinski apparently thought that no one was qualified at this particular location, which is their advanced organization in the United Kingdom. This person was — apparently had similar symptoms to what Lisa and other people were having that have that problem. And Mr. Mithoff — this, again — at management, was alerted.

And Mr. Mithoff indicated that the rundown could be given, because Mr. Mithoff is the senior-most technical person within the Scientology infrastructure. Senior FSO CS Alain Kartuzinski — any auditor or case supervisor located here in Clearwater, Florida, operating in the Ft. Harrison Hotel and the Sandcastle, are considered to be the cream of the crop as far as auditors and technically trained people are concerned.

Q  Okay. Well, are you aware of evidence that you’ve seen where David Miscavige has become personally involved in the matters concerning Lisa McPherson?

A  One thing that I saw where he actually comes out himself was a letter that was written to Mr. Bernie McCabe concerning dismissing the criminal case that was brought against Scientology for Lisa McPherson’s death.

MR. WEINBERG: Your Honor, Mr. Dandar’s not

0526

taking the position that this justifies his accusation that David Miscavige murdered Lisa McPherson, whatever he’s got to show you, that happened in the criminal investigation.

THE COURT: No. I think what he’s about to show me, based on his question, is something that indicates that David Miscavige knew about the Lisa McPherson case. I don’t think —

MR. WEINBERG: Well, I think —

THE COURT: — that that —

MR. WEINBERG: — the whole world knew about the Lisa McPherson case once there were people — once the church was indicted and people were walking around with picket signs.

THE COURT: We have to read it, ’cause I don’t know what it is.

BY MR. DANDAR:

Q  Plaintiff’s 128. Is that the letter you’re referring to, Mr. Prince?

A  Yes, it is.

MR. WEINBERG: Well, could I have a copy, please?

MR. DANDAR: Oh.

A  Yeah.

0527

BY MR. DANDAR:

Q  Based upon your experience as a Scientology executive in RTC, why would RTC have anything to do or be  involved with the Lisa McPherson matter?

A  I think if you just look at the second paragraph on page 7 of this letter, the last sentence, I think that pretty much says it all. It says, “Therefore, if rapid, responsible and meaningful resolution of this case is to be achieved –”

THE COURT: Just a second. I can’t find out where you are. Page 7, what?

THE WITNESS: Second paragraph. Last sentence in the second paragraph.

THE COURT: All right.

THE WITNESS: Where it says, “Therefore, if rapid, responsible and meaningful resolution of this case is to be achieved, you and I are the persons to do it.”

BY MR. DANDAR:

Q  You, meaning Mr. McCabe, and I, meaning Mr. —

A  Miscavige.

Q  — Miscavige?

A  Correct.

Q  Why would — again, why would Mr. Miscavige then be personally involved in the Lisa McPherson matter?

0528

MR. WEINBERG: Again —

A  Again, bypass —

MR. WEINBERG: — isn’t this pure speculation on his part?

THE COURT: Well, I think that — that — I would read this that this was after the charge was brought.

MR. DANDAR: Yes.

THE COURT: And that Mr. Miscavige, as the ecclesiastical head of the church against whom a charge was brought, was saying, “If this is going to be resolved, Mr. McCabe, as the state attorney, and I, as the head of this church, need to sit down and try to resolve it.”

MR. WEINBERG: And of course, he was not successful at that point, because the case continued for another year. And we all know how it —

THE COURT: However, we perhaps need to hear from Mr. Prince how he believes that statement shows that Mr. Miscavige was involved before Lisa McPherson died. Which is what your point of the question —

MR. DANDAR: That’s where I’m heading, yes.

THE COURT: Okay.

0529

BY MR. DANDAR:

Q  How does that — how can you explain that as reference to, as the judge just said —

A  I think the letter, you know, indicates Mr. Miscavige’s broad knowledge of every step of the criminal case, you know. And there’s no obvious evidence that he’s had involvement in this case, but it would certainly be my opinion that he has. Because again, this is a flap. It’s a bypass.

THE COURT: Well, Mr. Prince, let me just ask you what would seemingly be a logical question to me:

You could certainly have a situation — I’m not saying this is true or not true. But you could have — certainly have a situation where somebody didn’t know about somebody being ill, but when criminal charges were filed, because that person died, if they’re the head, they’d become involved and take over from that point.

THE WITNESS: Yes, your Honor. That is a rational line of thinking for, you know, regular world activities. But in Scientology, these — you know, Scientology —

THE COURT: I’m not saying that —

THE WITNESS: — is extremely —

0530

THE COURT: — Mr. Miscavige didn’t know.

THE WITNESS: Right.

THE COURT: I am saying that another explanation — I mean, this is about a criminal charge —

THE WITNESS: Right.

THE COURT: — right?

THE WITNESS: Right.

THE COURT: And so you could certainly have —

THE WITNESS: Against the Flag Service Organization.

THE COURT: Yeah. You could have a situation where the ecclesiastical head, after criminal charges are filed, says, “Let’s you and I sit down and see if we can resolve this criminal case.”

THE WITNESS: Right.

Well, you know, where are the letters from the corporate heads of the Flag Service Organization, doing the same thing with Mr. McCabe?

THE COURT: I’m sorry. Where are the what?

THE WITNESS: The corporate officers of the Flag Service Organization. Where’s Mr. Ben Shaw’s letter to Mr. McCabe to sort this out? Why does this necessitate Mr. Miscavige? This is against the

0531

Flag Service Organization.

THE COURT: Well, because as I understand it, Mr. Miscavige is the ecclesiastical head of the Church of Scientology.

THE WITNESS: Every one of them.

THE COURT: Every one of them.

THE WITNESS: Right.

THE COURT: Yeah. There’s no disagreement.

So as I said, I can — I’m not saying that Mr. Miscavige did or did not know about Lisa McPherson’s situation when she was at the Ft. Harrison Hotel. Because quite frankly, that’s one of the issues.

But this letter just simply says that, “I as the head of this church, all of them, want to sit down with you and resolve this case.”

THE WITNESS: Right.

THE COURT: So how do you jump from that —

THE WITNESS: Well —

THE COURT: In other words, there’s lots of people who have testified that David Miscavige, as chairman of the board of RTC, knew about Lisa McPherson. There’s just no question in their mind.

THE WITNESS: Right.

THE COURT: He would have known. He would have

0532

known because that’s the way business is done.

THE WITNESS: Correct.

THE COURT: Sort of.

THE WITNESS: Correct.

THE COURT: Okay. I’ve heard all that testimony. I presume you would testify the same.

But what does this letter add to this?

THE WITNESS: I — you know, your Honor, I think the only purpose of this letter is — is just to show what we were talking about earlier, when we were talking about the bypass and — and how, you know, it’s a pattern of conduct; how the organization does business. I think that’s the purpose of why this is in here.

THE COURT: Well, if this letter has relevance — if this letter has relevance, it has relevance to the, I suspect, agreed-to evidence in this case, which is that David Miscavige is the ecclesiastical head of the Church of Scientology, including — including Flag.

MR. DANDAR: Right.

THE COURT: Including all of the organizations.

MR. WEINBERG: The letter isn’t relevant to this proceeding.

THE COURT: No. It is not relevant to this

0533

proceeding, as I said, except that it might be relevant to that issue, which I assume is an agreed-upon issue.

MR. WEINBERG: The first church in the United States within 200 years is indicted, it’s not surprising that Mr. Miscavige —

THE COURT: No, it’s not.

MR. WEINBERG: — would want to try to find a resolution to it.

THE COURT: That is true, and that’s what I said. I don’t think it has any relevance to this proceeding unless it is to establish that indeed Mr. Miscavige is the ecclesiastical head of the church, including — including Flag.

MR. WEINBERG: He’s the ecclesiastical — he’s the ecclesiastical leader of the churches of Scientology.

THE COURT: Right.

MR. WEINBERG: The religious leader of the Church of Scientology.

THE COURT: Well, ecclesiastical leader and religious leader are the same thing.

MR. WEINBERG: Right. Same thing. He happens to be the chairman of the board of an organization called RTC, but he’s the ecclesiastical or religious

0534

leader of Scientology.

THE COURT: Right.

BY MR. DANDAR:

Q  Mr. Prince, is Mr. Miscavige the leader of all of the Scientology churches as — because he’s the COB of RTC or because he’s the captain of the Sea Org?

A  Because he’s the captain of the Sea Org.

Q  When Mr. Miscavige was the captain of the Sea Org and the COB, of the for-profit corporation Office Services, Inc., ASI, was he the head of all of the churches of Scientology as well?

A  Well, again, as your Honor correctly pointed out, Mr. Hubbard was alive at that time.

Q  Oh, okay.

A  Shortly after Mr. Hubbard passed, that was certainly the situation for a moment.

But immediately upon the death of Mr. Hubbard and the ousting of Pat and Annie Broeker, Mr. Miscavige assumed control of Religious Technology Center.

Q  All right. And did he do that because he was the chairman of the board of ASI or the captain of the Sea Org?

A  Because he was the captain of the Sea Org. You know, everything is done in the Sea Org with missions.

MR. WEINBERG: Your Honor, could he just answer —

0535

THE COURT: Yes. He’s answered the question.

MR. DANDAR: Judge, I have a document — actually, it’s a notice of filing. I’m going to have to have the clerk mark this notebook. And —

(A discussion was held off the record.)

THE COURT: All right. We’ll go ahead and take our morning break since it’s very close to that time. We’ll be in recess till 11:30.

(A recess was taken at 11:17 a.m.)

(The proceedings resumed at 11:37 a.m.)

THE COURT: You may continue.

MR. DANDAR: What I had marked and what I was about to hand the witness and the court, and not have to make an extra copy for Mr. Weinberg — which I didn’t because, quite frankly, he has all this, but I understand what he’s saying. He should have the same thing I’m handing — and that’s fine.

We’ll get that done over the lunch break — is Exhibit 130. It’s a compilation of documents, statements and depositions of staff.

But I’m only going to ask this witness about J, which is the narrative investigation of Detective Carrasquillo, April 15th, 1997.

MR. WEINBERG: I object to the use of this

0536

document. It’s just — it’s a — it’s not a sworn statement; it’s not a sworn statement of a witness. It’s just her — it’s a hearsay account of what she claims — I guess summarizes what somebody would have told her. That’s not evidence.

THE COURT: Well —

MR. WEINBERG: It’s not — certainly not for — I think where he’s going is that he’s offering it for the truth of the matter asserted. And it’s pure hearsay.

THE COURT: Well, it would be true hearsay if he’s offering it for the truth of the matter asserted, but I don’t know what he’s going to ask this witness. So let’s hear it.

MR. WEINBERG: All right.

BY MR. DANDAR:

Q  Mr. Prince — of course, we obtained this document, you know, a year after your affidavit of August of ’99 —

A  Mm-hmm.

Q  — when this was made a public record —

But in paragraph 3, the interview summary of Mr. and Mrs. Ortner, O-r-t-n-e-r, indicates that Mr. Miscavige was staying at the Ft. Harrison Hotel —

MR. WEINBERG: That’s what I’m talking about,

0537

your Honor.

BY MR. DANDAR:

Q  — while they were there, around November 20th of 1995.

Do you — here’s my question: Do you know of circumstances or other occasions when Mr. Miscavige would stay at the Ft. Harrison Hotel?

A  Yes, I do. Again, I’ll refer to the — to the video that was played the first day of my testimony where we were having a New Year’s Eve event. He would be there for that. He would be there for March 13th, which is  L. Ron Hubbard’s birthday. They normally have an event at the —

MR. WEINBERG: Are you talking about a specific year?

A  — and —

THE WITNESS: Excuse me?

MR. WEINBERG: About a specific year?

THE WITNESS: No. I’m talking — he asked me a question of when normally he would be there. I’m talking about —

MR. WEINBERG: All right. My objection is the question was whether he stayed there, not whether he was there. Big difference. And in this case there is no — I mean, if this is being offered that Mr. Miscavige was in Clearwater in November or

0538

December of 1995, it’s pure hearsay. And he wasn’t. And if he was —

THE COURT: I didn’t hear —

MR. WEINBERG: — he would have obviously — the state attorney would have done some investigation on it if that were the case. And it’s not the case.

But the question was whether he — whether Mr. Miscavige ever stayed at the Ft. Harrison Hotel, and Mr. Prince is talking about whether Mr. Miscavige was ever at the Ft. Harrison Hotel, which is completely different.

BY MR. DANDAR:

Q  How did you understand the question, Mr. Prince?

A  I understood the question as to at what times would Mr. Miscavige likely be at the Ft. Harrison.

Q  Okay. All right. Well, let’s —

THE COURT: I think that has some relevance, if it was anytime around — in and around the time of Lisa McPherson’s stay at the Ft. Harrison.

BY MR. DANDAR:

Q  So what events would he normally routinely come to in the Ft. Harrison?

A  There would be auditor’s date —

Q  Which is —

0539

A  — which is sometime in September; there would be IAS —

Q  What’s IAS?

A  Excuse me. International Association of Scientologists. They have an event in the summertime, I think, that’s around June or something like that, they have an IAS event. The New Year’s event. L. Ron Hubbard birthday event.

Q  Which is March?

A  March 13th.

Some of the more common times that I can think of that he would be there.

Q  What about non-Scientology holidays such as Thanksgiving?

A  Not likely —

Q  Okay.

A  — in my experience.

Q  Okay.

THE COURT: And the reason he would be at the Ft. Harrison Hotel as opposed to someplace else is because it’s the mecca of all —

THE WITNESS: Yes, your Honor.

The Ft. Harrison is a very beautiful hotel.

THE COURT: Is that — mecca of all technology — mecca of all technology?

0540

THE WITNESS: Yes, your Honor.

BY MR. DANDAR:

Q  Was —

THE COURT: Now, on a New Year’s event, I thought he was out in California on the tape that I saw.

THE WITNESS: No, your Honor. That was right in the Ft. Harrison.

THE COURT: Oh, it was?

MR. WEINBERG: You’re talking about two different tapes. The tape that you saw was California. The tape that Mr. Prince was in, was —

THE COURT: In Clearwater.

MR. WEINBERG: — in the Ft. Harrison.

THE COURT: Okay.

MR. WEINBERG: That was — Mr. Prince was 20 years ago; your — I don’t know when it was. 2000.

THE COURT: Okay.

MR. DANDAR: It was less than 20 years ago.

BY MR. DANDAR:

Q  But anyway, do you — do you have any recollection of Mr. Miscavige staying at the Ft. Harrison Hotel rather than just showing up for an event?

A  Well, when I testified earlier about Mr. Miscavige and myself, Vicki Aznaran, you know, the regular crew coming

0541

into the Flag Service Organization and rearranging and declaring some people, we stayed there at that time.

I mean, you know, whenever Mr. Miscavige would come to the Clearwater area, as well as myself, we always stayed at the Ft. Harrison Hotel.

THE COURT: What were the dates that Lisa McPherson was at the Ft. Harrison?

MR. DANDAR: November the 18th of ’95 through December the 5th of ’95.

THE COURT: Do you have any information that would say that David Miscavige was or was not at the Ft. Harrison Hotel on those dates?

THE WITNESS: Your Honor, beyond what Mr. Dandar is presenting here today, I do not.

THE COURT: So regardless, if it weren’t for that hearsay document, you have no firsthand knowledge or other way of knowing whether he was there or not.

THE WITNESS: Correct.

THE COURT: Okay.

BY MR. DANDAR:

Q  Mr. Prince, one thing I wanted to ask you about that’s out of sequence, and that is after you left the Church of Scientology in 1992, did you have occasion after that time to consult with Scientology attorneys?

0542

A  Yes, I did. I was contacted by Mr. Mike Sutter, who worked in the Scientology — worked in the Religious Technology Center. He told me that he wanted me to meet with Mr. Earle Cooley concerning ongoing church litigation.

Q  And who is Mr. Cooley?

A  Mr. Earle Cooley was lead counsel for Scientology during the early ’80s.

Q  And what date or what month and year was this that Mr. Sutter asked you to meet with Mr. Cooley?

A  You know, to the best of my knowledge, I do believe it was 1994.

We met in Boston.

Q  What was the purpose of that meeting?

A  Well, I thought I was going to go there to speak about current legal cases, because that’s what they told me they wanted me to speak about. But in fact, when I got there, it became quite a different show. They wanted me to reaffirm for them the fact that — you know, the — under the — reaffirm the conditions under which I left Scientology, the documents and things that I was — felt obligated to sign to leave. They wanted to update all of that again.

So they recorded me and — And I — and I guess I also found out that they were having trouble in the Wollersheim 4 case, in that —

0543

and they wanted to know if persons such as Vicki Aznaran, Lawrence Wollersheim, any attorneys, had contacted me to give testimony concerning Scientology.

Q  And as of that time, had anyone contacted you?

A  No.

Q  And did they pay you for your time?

A  Yes.

Q  How much?

A  I think it was 28- — 27-, $2,800.

Q  Was that the last time you were consulted by any representative of the Church of Scientology on matters such as that?

A  I believe so.

Q  Okay. Now, Mr. Prince, you —

MR. DANDAR: And I am going to be jumping around here.

THE COURT: You said this was 1994?

THE WITNESS: Yes, your Honor.

BY MR. DANDAR:

Q  All right. Let me show you Plaintiff’s Exhibit 131. And I have highlighted certain portions of it. I’m going to direct your attention to certain areas.  First of all, can you identify this document?

A  Yes. This is another Scientology issue type.

It’s called an executive directive. And this is an

0544

executive directive concerning senior HCO Int. And it concerns security situations and threat handlings.

Q  Now at the top it has references, and it has a bunch of HCO policy documents. Is that what — am I reading that correctly?

A  Yes. There’s four HCO policy letters. The FO — there’s one Flag order; there’s one SPD, which is a Scientology policy directives; two more HCO PLs, another SOED, that’s a Sea Org executive directive; and a couple of more policy letters.

Q  Okay. And the references for like the Sea Org executive director 4234 international, it says, “Coordination on security and investigation matters, suppressive acts.” Do you see that?

A  Yes, I do.

Q  Did I read — maybe I didn’t read that right.

A  Well, suppressive acts is the HCO PO, 23 December, ’65.

THE COURT: What does HCO stand for?

THE WITNESS: Hubbard Communications Office.

BY MR. DANDAR:

Q  And the last HCO policy of October 27th, 1964 talks — or concerns physical healing, insanity and sources of trouble. Do you see that?

A  Yes, I do.

0545

Q  All right. What does this document, mentioning insanity and healing and sources of trouble, have to do with security?

A  Well, when you have a — an insane person or a source of trouble, potential trouble source within a Scientology organization, according to its policies, this is a source of great potential trouble for an organization, be it a Sea Organization or regular Scientology organization, and these gives — it gives the steps of prevention and handling.

Q  Is “handling” a word that is used in the policies?

A  Yes.

Q  And in this particular checklist, it talks about — the second paragraph, where I’ve highlighted, uses, “Make sure the situations are actually handled.”

A  Right.

Q  Now, turn to page 2, letter G.

A  Okay.

Q  First of all, this list is below a paragraph that says the types of security situations, am I reading this correctly, where it says, G,”Attempted suicide cases or PTS Type IIIs and any external or antagonistic connections to these –” are these security issues?

A  Absolutely.

Q  Do you have an opinion whether or not this

0546

particular checklist would come into play in reference to the Lisa McPherson matter, in November and December of ’95?

A  This — the date of this issue is the 11th of May, 1991, and it’s basically instructing the divisions within Scientology organizations to coordinate with OSA — Office of Special Affairs — to deal with the  situations listed A through O, Type III — PTS Type IIIs being one of them, PTS Type III being the Scientology term for a psychotic.

Q  Mr. Prince, this is, as you said, dated May, 1991.

Does it surprise you that it references policy letters that are written in 1959 and 1964 and 1968, et cetera?

A  No. The words of L. Ron Hubbard are eternal to Scientology.

MR. DANDAR: I’d like to move Exhibit 131 in evidence.

THE COURT: Any objection?

MR. WEINBERG: No objection. I don’t know what the relevance is, in light of the fact that there isn’t anything about RTC in this document.

THE COURT: It’ll be received.

BY MR. DANDAR:

Q  All right. And Mr. Prince, let me show you Exhibit 129. I don’t have an extra copy here, for some reason. Oh, I do. Okay.

0547

Remember yesterday we talked about in order to get the injectable Valium prescriptions and the chloral hydrate prescriptions from drugstores, you talk about staff — somebody filling out what’s called a CSW, completed staff  work?

A  Yes.

Q  All right. This document, Plaintiff’s Exhibit 129, do you know where this comes from?

A  Yes. This comes from the Hubbard Administrative Dictionary, which is a dictionary that defines administrative terms used in Scientology organization.

Q  Okay. And the definition of completed staff work, does that fit within your understanding of what you testified to yesterday?

A  Yes, it does.

MR. DANDAR: Like to move 129 into evidence.

THE COURT: It’ll be received.

BY MR. DANDAR:

Q  Also Mr. Prince, you mentioned several times today that — when I was asking you about bypass and Mr. Miscavige’s role, you mentioned you had prior declarations. Let me show you Plaintiff’s Exhibit 132.

First of all, what is 132?

A  This is a supplemental declaration that was submitted in the Los Angeles courtrooms on behalf of

0548

plaintiff Lawrence Wollersheim.

Q  And this is your declaration?

A  Yes, it is.

Q  It’s dated December 22nd, 1999?

A  Yes.

Q  Is this one of the declarations you were referring to when you said you — in your testimony today, that you had previously filed declarations on the matters that we talked about?

A  No.

Let me just scan it here real quick.

Q  All right.

A  Well, yeah. I think right — starting on page 2, under the subtitle Sea Organization, I talk about Scientology missions, meaning, you know, a group of people going into an organization, taking it over. I talk about that.

Q  And on page number 40, you talk about —

MR. WEINBERG: Your Honor, I object to this. Why are we doing this? Mr. Dandar can ask him questions, but this is just a hearsay — I mean, this is an affidavit. He’s on the stand. I mean, if there’s something he wants

to ask him about, he can ask him, instead of saying, “On paragraph such and such it says such and such.”

0549

THE COURT: Well, I would normally tend to agree with you, except we have affidavits, prior declarations of so many people in this case, I don’t know why I would keep the prior declaration of Mr. Prince’s out.

BY MR. DANDAR:

Q  But Mr. Prince, the command channels and structure of the hierarchy of the Church of Scientology in this declaration, Plaintiff’s Exhibit Number 132, is it any different than your testimony than you’ve given in

this case today?

A  No, it is not.

Q  Is it any different than your — and the reason why you reached the opinions you reached in August of 1999 concerning David Miscavige’s role in Lisa McPherson’s death?

A  No, it is not.

MR. DANDAR: I’d like to move 132 into evidence as Plaintiff’s Exhibit 132.

THE COURT: I’m going to receive it over objection, just as a prior affidavit that —

MR. WEINBERG: Right. I mean, I — the objection would be, normally, just buttressing his testimony.

THE COURT: That is true. In other words, that would be exactly right. And that would be proper

0550

objection, not hearsay or —

However, I’m going to let it in.

BY MR. DANDAR:

Q  All right. Now, Mr. Prince, have you worked with Mr. Michael Rinder in your tenure in Scientology?

A  Yes, I have.

Q  And what did — how did — under what circumstances?

A  Mr. Rinder was a member of the watchdog committee during my tenure at RTC. He was a member of the watchdog committee, a commodore’s messenger, and he worked for the corporation the Church of Scientology International.

Q  What is the watchdog committee?

A  The watchdog committee are the principals of the Church of Scientology International. The principals of each sector and section of Scientology — if you look at a Scientology org board, you will — you will see it’s broken down into certain sections and sectors. One — one sector of Scientology is Scientology International. That means all of the organizations that are not Sea Org organizations and are not missions.

So you would have a WDC member, a watchdog committee member, for the Scientology organizations. Then you’d have a WDC member or a watchdog committee member for the Sea Organization. You would have a watchdog committee

0551

member for SMI, S-M-I, Scientology Missions International, et cetera, et cetera.

Q  And who is the head of that watchdog committee?

A  The chairman of the watchdog committee, during the time — my tenure in Religious Technology Center, was Mark Yeager.

Q  And did Mr. Miscavige serve on that board as well?

A  No, he did not.

Q  Okay.

A  That board reported to Mr. Miscavige.

Q  So Mr. Miscavige was above that board?

A  Correct.

Q  Now, Mr. Prince, based upon your experience and expertise in Scientology, do you have an opinion as to why Michael Rinder was meeting with Bob Minton to try to get the McPherson case dismissed, as early as 1998?

MR. WEINBERG: Objection to the — I mean, this is pure speculation. It is — it’s — I think it’s improper opinion testimony. He says that he has some expertise — which we have challenged, you know, for a number of
reasons — with regard to the religious technology.

Now he’s going to be speculating as to why someone would have been meeting with Mr. Minton? Mr. Minton’s testified regarding that; Ms. Brooks

0552

has testified in regard to that meeting at length.

THE COURT: I — I understand. We’ve had some opinions in — I don’t know why we wouldn’t listen to his, too. I mean —

MR. WEINBERG: I — it’s more frustration than anything.

That’s my objection. I understand that you’re overruling it, and I just wanted to —

THE COURT: All right.

MR. WEINBERG: Thank you.

A  Sorry. I don’t remember the question.

BY MR. DANDAR:

Q  Why would Mr. Rinder —

First of all, is Mr. Rinder part of the Flag Service Organization?

A  To my knowledge, he is not.

Q  Do you have an opinion as to why Mr. Rinder would be meeting with Mr. Minton, as early as 1988, and of course in 2002, to get the Lisa McPherson case dismissed?

A  Certainly I have an opinion, based on experience. Because like the Wollersheim case that happened here, and the Mayo case, any major case that’s being litigated in the United States, irrespective of the corporation, the decisions, the planning and the execution of legal is done with OSA — Office of Special Affairs, David Miscavige,

0553

Marty Rathbun.

Q  All right.

A  Lyman Spurlock if it — if it involves corporate. Lyman Spurlock was an expert on corporate entities.

THE COURT: Who is Mr. Rathbun? What is his capacity?

THE WITNESS: Mr. Rathbun has had many capacities. Prior to coming into the Religious Technology Center, he was what was called a client affairs; legal client affairs. And he handled the legal affairs for the publishing aspect for Mr. Hubbard in Author Services. When he moved to Religious Technology Center, he became the inspector general for ethics. Ethics —

THE COURT: Is that what he is now?

THE WITNESS: I’m not sure what he is now —

THE COURT: Okay.

THE WITNESS: — your Honor.

But that position handles all legal PR and intelligence as part of its duties for Scientology organizations.

THE COURT: And do I recall correctly — I know we’ve had a vacation, and frankly some of this has escaped me —

Is Mr. Rinder the head of OSA?

0554

MR. DANDAR: Well, Mr. — at one time, Mr. Shaw, who is the head of OSA here, was — testified that he reported — his senior was Mr. Rinder. What his title was to be Mr. Shaw’s senior, I don’t know.

THE COURT: Well, OSA would have a —

Okay. I believe there’s testimony about that in this hearing that he is the head of the Office of Special Affairs. I think. Maybe not.

MR. DANDAR: All right.

THE COURT: Which includes legal.

THE WITNESS: Yes.

MR. DANDAR: Right.

BY MR. DANDAR:

Q  Now, Mr. Prince, let me show you what’s already in evidence as Plaintiff’s Exhibit 110, known as KSW News. And if you could, I’m going to —

THE COURT: I don’t know — I allowed the answer, but I don’t know what the answer was. I mean, the answer —

MR. WEINBERG: Mr. Shaw can explain it to you.

THE COURT: No. What — what I think — he went off to tell us about Mr. Rathbun. I think the question was why would it have been — why would Mr. Rinder have been called to this meeting. And

0555

is — what is your answer?

THE WITNESS: Right. Because Mr. Rinder would have been in that position, the senior person within the OSA network. And OSA operates on a statistic, just like other departments and sections within the Scientology organization operate on. And a statistic for the OSA would be a threat handled; a threat being a lawsuit or a person that was perceived to be an adversary against Scientology or taken an adversarial position against Scientology.

So getting rid of a lawsuit would be something that would improve conditions, you know, a statistic going up. That would be a good thing for them.

So — and that’s what they focus and concentrate on, handling legal situations.

BY MR. DANDAR:

Q  OSA.

A  Yes.

Q  All right. The KSW News, if you open up to the little — I believe it should be in the middle — there is a list of matters that need to be reported up lines to RTC.

A  Yes.

Q  Do you see that?

A  Yes, I do.

Q  And there’s an arrow that I drew —

0556

THE COURT: You all are too loud back there. Go ahead.

BY MR. DANDAR:

Q  — next to PTS Type III?

A  “Any person who acts PTS Type III, potential trouble source.”

Q  Okay.

A  And that is of concern.

Q  Does PTS Type III include people who are psychotic as well as people who want to leave? A  Correct.

Q  Now, this publication, when was it published?

A  1994 —

Q  And —

— is when the copyright notice is on it, RTC copyright notice.

Q  All right. So it certainly wasn’t published after Lisa McPherson died in ’95.

A  No, it was not.

Q  Now, this reporting up lines of PTS Type III to RTC, was that in effect when you were an active Scientologist?

A  Yes, it was.

MR. WEINBERG: Well, excuse me. What does that mean, an active Scientologist? When he was —

0557

BY MR. DANDAR:

Q  Prior to ’92. Prior to you actually leaving —

MR. WEINBERG: When you were at the RTC?

THE WITNESS: Yes. Yes, it was.

BY MR. DANDAR:

Q  Now, these meetings that you had with David Miscavige and Rathbun and Mithoff, Aznaran and others, you said there was a certain agenda?

A  Correct.

Q  And that the top of that agenda for each of these meetings was what?

A  Flaps.

Q All right. What was —

A  And what the handlings were.

Q  — the next —

How they were handling the flaps?

A  Yes.

Q  What was the — give us a list of — in priority of each meeting.

A  Flaps and handlings. Then statistics, go over the statistics of the departments, the divisions. Then you talk about — the next thing is talk about wins.

Q  Wins.

A  Wins. You know, successes. Scientology successes. Successes on the job, successes within the

0558

organization.

Q  And how often would these meetings occur?

A  Once a week.

Q  And this is just a meeting of people who were at RTC?

A  No. This is a pattern that is continued throughout the majority — all of Sea Org organizations.

Q  That includes Flag?

A  Yes.

Q  And back in —

MR. WEINBERG: Your Honor, could I — the question was about Mr. Miscavige, and the answer obviously was way broader. You’re not — I don’t think Mr. Prince was saying Mr. Miscavige was having meetings on a weekly basis at all the Scientology organizations.

THE WITNESS: No, no. That’s not —

THE COURT: He’s saying, when he was a member and he would meet with these people, what was their agenda? That’s all —

MR. WEINBERG: Right. No — but then the next question was — then what he said was, “And this is done in all Scientology organizations,” which means — I think what he meant was there’s meetings every week in Scientology organizations with people

0559

in the org. That’s what —

THE WITNESS: The pattern of flaps and handlings, statistics and wins, is a pattern that every Sea Org organization has in their meetings, their weekly meetings. Miscavige isn’t at those meetings. I —

BY MR. DANDAR:

Q  But at the meetings that you had and you participated in with Mr. Miscavige, were these meetings — when you say flaps, were they just — my question was, did they just concern RTC or was it flaps —

A  No.

Q  — of what —

A  When RTC has a meeting about flaps and handlings, it could include any aspect of the Scientology empire. It could include the FSO; it could include the organization in Australia if there was a threat in Australia of some org getting ready to be closed down, or if one of the Scientology organizations were raided in Greece or whatever.

You know, it could be anyplace.

Q  All right.

A  Because the problems were existing — in the lower organizations, their flaps —

THE COURT: You need to get to the point.

In your opinion, as somebody who was with — in

0560

RTC, at the time you were there, would the Lisa McPherson situation have been discussed at one of those meetings.

THE WITNESS: Yes, your Honor.

THE COURT: All right.

BY MR. DANDAR:

Q  Is there any doubt about that?

A  No. And as I was getting ready to say is, the reason being is the lower organizations have to report to the higher organizations. The higher organizations have to approve the handlings for the flaps; have to verify the statistics. Then it goes to the next organization, who’ll do the same thing. And by the time it gets to RTC, it’s pretty much confirmed what the lower organization is saying.

And maybe the handlings may be modified, but you know, they’re pretty much all on the same page.

Q  Is there any doubt in your mind — as you sit here today, do you question your opinions that you reached in your August, ’99 declaration concerning the involvement of Mr. Miscavige in the Lisa McPherson as a PR flap?

A  No. I haven’t changed my opinion one bit.

Q  And is that opinion solely your opinion or are you being influenced by anyone to make that opinion?

A  I base my opinions on my personal experience, what I’ve observed, the written word of L. Ron Hubbard.

0561

Q  All right. Now, let’s jump now to 2002. The — we left off with your meeting — I believe you said you had this rather un- — not unpleasant, but bad — heated words were exchanged at that hotel, the Radisson on Clearwater Beach, when you met with Mr. Minton and Ms. Brooks. Do you recall that?

A  Yes, I do.

Q  And Ms. Brooks walked out to the parking lot with you?

A  Yes.

Q  All right. I want to pick up from there.

When is the next time you recall having further conversation with Ms. Brooks or Mr. Minton?

THE COURT: What — do we have the date on that?

MR. DANDAR: April the 14th.

THE COURT: Okay.

A  The last —

MR. WEINBERG: I don’t think he said that —

MR. DANDAR: Yeah. April the 14th.

THE COURT: Well, he said the dates were as they were in his affidavit, ’cause he sat down with a calendar.

MR. DANDAR: Right.

A  The next time that I talked to them, I think, was

0562

maybe a week or some days later, when they were staying at another hotel — oh, wow. Windham, the Hyatt Windham Hotel. I called and spoke to Bob and asked if he wanted to come by to the — ’cause I was having a barbecue.

MR. DANDAR: All right. And Judge, just for the record, I am looking at his April, 2002 Jesse Prince affidavit.

THE COURT: All right.

MR. DANDAR: His handwritten note is April 14th, that’s attached, 2002.

BY MR. DANDAR:

Q  Mr. Prince, the handwritten note, did you write that when you met with me and Mr. Lirot?

A  Yes, I did.

Q  Okay. And after that is when —

Maybe I’m confused. Let’s hold on.

After that is when you had the dinner with Mr. Minton?

A  After I wrote this handwritten note is the Sunday that I met with them at the Radisson.

Q  Is that when you had that heated conversation —

A  Yes.

Q  — at dinner?

A  Yes.

Q  Was that — were you supposed to meet Mr. Rinder

0563

that day?

A  Correct.

Q  And who told you that?

A  Mr. Minton, Mrs. Brooks.

Q  And did you meet with Mr. Rinder on April 14th, 2002?

A  No, I did not.

Q  Why not?

A  Because it was deemed by Mr. Minton that I was not ready, because I was not willing to perjure myself.

Q  And who told you that?

A  Mr. Minton.

Q  How did he want you to perjure yourself?

A  He wanted — he wanted me to come in and say that you influenced me to write the August, ’99 declaration that I did; that you put words in my mouth. And he wanted me to say that some meeting occurred where Mr.  Minton was at, where you talked about adding David Miscavige on as a party.

And he kept using this term of, like, “You have to walk with us on this because we’re going to show you what to do. You know, we’re the A team. We got to be together on this. There can’t be any breaks. This is what we’re doing. This is what I’m saying. This is what you need to do to back it up.”

Q  How did you respond?

0564

A  “I absolutely will not do it.”

Q  Did Mr. Minton ever indicate to you that he knew that he was lying?

THE COURT: Could I ask —

Just one more minute.

What you’re saying — which affidavit is it that they — they, meaning Mr. Minton — wanted you to say Mr. Dandar influenced you to write?

THE WITNESS: The one where I wrote that Miscavige had knowledge and culpability in Lisa McPherson’s death.

THE COURT: The one that dealt with the change — or the amendment of the complaint. Is that the one he’s talking about?

MR. DANDAR: Yes. That’s the one he’s talking about.

THE COURT: That would have been the first affidavit he filed maybe in this case? Well, it doesn’t matter.

MR. DANDAR: No. The first one, I think, was the PC folders.

THE COURT: I know which one you’re talking about.

THE WITNESS: It was the second one.

MR. DANDAR: It’s the August, 1999 affidavit.

0565

THE WITNESS: Right.

THE COURT: And he also wanted you to state —

THE WITNESS: That Mr. Dandar had had a meeting with myself, Mrs. Brooks, Dr. Garko, Mr. Minton, to discuss adding Mr. Miscavige on as a party.

THE COURT: Right.

THE WITNESS: And apparently Bob was saying, you know, and we have to say that Mr. Dandar said that the meeting never happened, and you know, we were adding on Miscavige basically to try to force Scientology into a settlement position.

BY MR. DANDAR:

Q  Was any of that true?

A  No.

THE COURT: Could we find out, since that does seem to be an issue here, what he remembers about whatever meeting there was to discuss adding Mr. Miscavige as a party? Or are you not ready for that, or are you not going to go there, or —

MR. DANDAR: Well, I’m trying to not invade my work product as much as possible. But it is an issue, and so I didn’t — We can ask him that question.

THE COURT: All right.

MR. DANDAR: I just don’t know how far I want

0566

to invade my work product.

BY MR. DANDAR:

Q  But Mr. Prince, do you recall having any meeting with me, Dr. Garko and Stacy Brooks about adding on David Miscavige —

THE COURT: I’m not going to let them get into the extent of the discussion necessarily, other than what we’ve done thus far in this hearing, which is who was there —

MR. DANDAR: Okay.

THE COURT: — and was there a discussion about adding Mr. Miscavige, and who was in favor of it and who wasn’t? That’s pretty much all that’s been discussed.

MR. DANDAR: All right.

THE COURT: And it’s been discussed by a lot of witnesses —

MR. DANDAR: Yes.

THE COURT: — Stacy Brooks, Mr. Minton, Mr. Garko, you.

MR. DANDAR: All right. So — That’s fine.

BY MR. DANDAR:

Q  So was there such a meeting?

A  There was a meeting between you, myself,

0567

Mrs. Brooks, Dr. Garko, where we discussed — and I mean, my recollection is there’s been more than one time that we  discussed this — about adding Mr. Miscavige on as a party.

Q  Was Mr. Minton ever at any of those meetings?

A  No, he was not.

Q  Do you have any idea why Mr. Minton would tell you, when you met with him in April, why he wanted to say he was at a meeting to add on David Miscavige?

A  Because the idea was —

MR. WEINBERG: Objection. If it’s something Mr. Minton told him, fine. But otherwise it would just be pure conjecture.

THE COURT: That’s true. If it’s something Mr. Minton told him, then he can discuss it.

Go ahead.

A  Okay. The idea that Mr. Minton told me is Scientology had several things that they wanted Mr. Minton to do. These were in conjunction and coordination with things that could be done to get the case dismissed. Specifically, going after you. Specifically, you were to be made the target of whatever stack of papers that Scientology provided to Mr. Minton. There was five or six things that they wanted him to do in relationship to you only. And you were the obvious target —

0568

BY MR. DANDAR:

Q  Why?

A  — to —

Because they wanted to get you kicked off the case. Because they figured if they got you kicked off the case, then no other attorney would pick it up and the suit would simply go away.

Q  And Mr. Minton told you this.

A  Yes.

Q  And how many times did he tell you that?

A  Several.

Q  Did Mr. Minton ever indicate to you that he knew that what he was saying about me was not true?

A  Mr. Minton was in — in the — in the very beginning, Mr. Minton was in anguish over the — the prospect of — of lying on behalf of Scientology for — against you. Mrs. Brooks was in a panic and desperate frame of mind to do whatever it took to extricate Mr. Minton from just the assault that Scientology was enacting upon Mr. Minton. And she thought that it would be a good idea for Mr. Minton to cooperate with Mr. Rinder, with Mr. Rosen,  whatever they wanted, to get him extricated from the Scientology assault.

Q  Did Mr. Minton or Ms. Brooks tell you that —

Well, you said they — let me go back.

0569

You said something about Scientology gave Mr. Minton a stack of papers about what he needed to say against me?

A  Yes.

Q  What —

A  Or possible things to go into. And that’s the stuff that came from the Adams Mark Hotel, after we had the meeting, after I went to see him again, after he lied the first time on the stand.

MR. WEINBERG: Well, objection.

A  And —

MR. WEINBERG: If this is —

THE COURT: Wait a minute.

MR. WEINBERG: If this is the same stack that Mr. Prince testified yesterday that he never looked at —

THE COURT: Right.

MR. WEINBERG: — so how’s he going to answer questions about what was in the stack?

THE COURT: He’s not answering questions about what was in the stack. He’s talking about what  Mr. Minton told him. That’s all he’s supposed to  testify about.

MR. DANDAR: That’s what he’s doing.

MR. WEINBERG: Well —

0570

BY MR. DANDAR:

Q  You didn’t look at the stack of papers, right?

A  No, I did not.

Q  So how do you know what was in the stack of papers?

A  ‘Cause he told me. There were five to six things in there that Scientology wanted him to do against you, and you specifically, and you only.

Q  Okay.

A  And two of them were the check. You know, somehow saying that you caused him to perjure himself concerning the check. And then the meeting. These were two very important issues to —

You know, I can’t say that I fully understood it because I’m not a lawyer, but this was very important that they executed in that way.

Q  Okay. And let’s talk about the check, all right?

A  Okay.

Q  Did Mr. Minton ever tell you that — after he met with Scientology, did he ever tell you that the check was from him; that May, $2,000 (sic) check for $500,000?

A  At that time he did.

Q  All right. Did you have any conversation with him as to why he told you something different on the roof of the parking lot across from the Lisa McPherson Trust office?

0571

MR. WEINBERG: Objection. Asked and answered. He talked about that yesterday.

THE COURT: I think he did.

MR. DANDAR: Did he?

THE COURT: Yeah, I believe he did.

MR. DANDAR: All right. Okay.

THE COURT: Do you remember — sometimes one day bleeds into the next. I do know he talked about being on the roof of the parking lot, and I do know he talked about Mr. Minton telling him something different. Did he — Did you discuss yesterday with us why Mr. Minton said he was telling a different story now? I don’t remember.

THE WITNESS: Well, yes, your Honor. Your recall is actually quite correct. Because you yourself asked me, “Well, what did they say,” when I  brought up the fact that we had been on the roof. And he had told us this whole different story. And you asked me, “Well, what did they say,” and I said that, “They just looked at me stupidly.” But of course —

THE COURT: So is the answer then he really didn’t say anything about this difference —

THE WITNESS: Right.

0572

THE COURT: — that you’re telling that —

MR. WEINBERG: Changed the subject.

THE COURT: Changed the subject.

THE WITNESS: Right.

THE COURT: Okay.

BY MR. DANDAR:

Q  Did you ever talk to him again about the check, or was that the last time?

A  I think that is the last time I spoke to him about the check.

Q  Okay. Did you have any other conversations with Mr. Minton or Ms. Brooks about trying to get you to lie and go down the road with him, as you say?

A  Well, I had continuing conversations with them after negotiate — after they had the negotiations in New York and then began the negotiations — continued the negotiations in Clearwater.

MR. WEINBERG: Well, my objection, your Honor, is he went over all this yesterday.

MR. DANDAR: Right.

MR. WEINBERG: I mean, now we’re going back and we’re going to go repeat what happened yesterday.

THE COURT: That’s true. I think we really were, yesterday, up to the point of this forward meeting.

0573

MR. DANDAR: That’s right.

THE COURT: Although frankly, you never did discuss the meeting where there was a discussion to have Mr. Miscavige added. And I think he’s done that now.

MR. DANDAR: Yes, he has.

THE COURT: Right. And — and that was the second thing. And I — I think now you’ve explained that. So you can go — I shouldn’t say you — Mr. Prince can explain what.

THE WITNESS: There was something I left off about Mr. Miscavige — adding Miscavige as well, in the discussions that I had with Mrs. Brooks and Mr. —

THE COURT: Oh, yeah. I don’t believe he’s ever discussed with us what his discussions with Mr. Minton were about that.

THE WITNESS: Right.

THE COURT: So you might want to.

MR. DANDAR: Oh.

THE WITNESS: Right.

MR. DANDAR: Okay. Go ahead.

THE WITNESS: As you well know, and certainly Mr. Weinberg well knows, we all sat before Judge Moody forever on this issue of adding David

0574

Miscavige as a party. We discussed this back and forth.

MR. WEINBERG: “We” being —

THE WITNESS: The judge said a key question to be asked was, is was that anything I wanted to have happen? The answer is no. I was not in favor of  adding David Miscavige. I thought it would drag  down the lawsuit and just be cumbersome.

THE COURT: That’s you. You were not in favor of adding him.

THE WITNESS: Right.

But in discussions about this, it was decided to do it anyway, and it was decided because this is  what Ms. Liebreich wanted to do. But we discussed this. And my — my thing with Mr. Minton as we were  talking about this when they were trying to get me to do this, is when the record is so obvious why and how that happened, why are you now trying to say it’s just all Ken’s fault, when Mrs. Brooks was the one that was really wanting this to happen; wanting to add Miscavige? So we talked about that.

BY MR. DANDAR:

Q  Okay.

0575

THE COURT: And what did he say?

MR. WEINBERG: Excuse me. Talked about it when, then?

So now it’s Ms. Brooks or Ms. Liebreich that wanted this to happen. I mean, I —

THE COURT: No. No. I understand this. Wait till you get the transcript.

MR. WEINBERG: I’m sorry.

THE COURT: It’ll be very clear to you. Don’t  get all flustered.

MR. WEINBERG: I’m not flustered.

THE COURT: Yes, you are.

MR. WEINBERG: I’m hungry.

THE COURT: I’m hungry too. We’re going to stop at 12:30. Did you say you were hungry?

MR. DANDAR: That’s what he said.

MR. WEINBERG: That’s what I said.

MR. DANDAR: That’s a new objection.

THE COURT: Just so we see if the testimony’s consistent —

At this meeting, Jesse Prince was not in favor of adding Mr. Miscavige; Stacy Brooks really wanted to add David Miscavige. What about Dr. Garko?

THE WITNESS: Dr. Garko was hesitant about it.

And —

0576

THE COURT: Okay.

THE WITNESS: And Mr. Minton didn’t care one way or the other. I mean —

THE COURT: I thought Mr. Minton wasn’t there.

THE WITNESS: You know, later, when we discussed it, when, you know, Stacy — we went to the office. And Stacy says, “Well, I think, we’re  going to do this,” and he’s, like, “Yeah, okay. So what?” Because Mr. Minton always — you know, he was concerned about what he was doing. Mr. Minton  wasn’t concerned with what Mr. Dandar was doing  or — or what Mr. Prince was doing or Mr. Brooks  (sic). He had his own agenda. When he came down  to — here in Florida, he would be more concerned  about what he was doing.

BY MR. DANDAR:

Q  Well, was there a meeting with Mr. Minton?

A  No.

Q  Well, what are you talking about when you said Minton — Mr. Minton didn’t care?

A  I recall Stacy Brooks and myself having a conversation with Mr. Minton, mentioning the fact that we were doing this.

Q  Oh, okay. Was I there, or Dr. Garko?

A  No.

0577

Q  All right.

A  No. And he’s like, “Okay. Where do you guys want to eat,” type of thing. You know, he just didn’t care.

“Okay.” You know, that’s — “Ken –” “Whatever.”

Q  Did Mr. Minton ever tell you he had an agenda?

MR. WEINBERG: Excuse me, your Honor, could we date that meeting?

MR. DANDAR: Yeah. Let’s date the meeting.

MR. WEINBERG: And where it was?

MR. DANDAR: Yeah.

THE WITNESS: When Stacy and I discussed it, I think it was probably — some — maybe a week or sometime prior to the fifth amended complaint actually being filed —

BY MR. DANDAR:

Q  Well —

A  — we discussed it.

Q  — there were several times that the fifth amended complaint —

MR. WEINBERG: Well, your Honor —

A  Well, okay. To answer the question, no, I don’t know when it was. I just know —

THE COURT: No. I think —

MR. WEINBERG: My objection was Mr. Dandar prompting him.

0578

THE COURT: No, he wasn’t prompting him.

There were several fifth amended complaints. I would like to know.

Was it the fifth amended complaint where Mashburn (sic) and — Rathbun — all those other people were added or was it the fifth amended  complaint that’s now the complaint?

THE WITNESS: Your Honor — I don’t —

THE COURT: Or do you know?

THE WITNESS: I don’t have a clear recollection of which —

THE COURT: Was this a discussion where it was decided to add Mr. Miscavige as, I guess, chairman of the board of RTC — I don’t know how — I’ve never seen that complaint — or was it before the discussion to add Mr.

Miscavige as head of the Sea Org?

THE WITNESS: I think it was after the discussion to add — after it had been resolved that Mr. Miscavige could be added as head of the Sea Org.

You know —

THE COURT: After it was resolved by whom? By Judge Moody?

THE WITNESS: Yes. By Judge Moody.

THE COURT: Then you had a discussion with

0579

Mr. Minton about this?

THE WITNESS: Yeah. I believe he, Stacy and I were in the car, traveling, and we talked about it.

THE COURT: Okay.

BY MR. DANDAR:

Q  So it was after the hearing we had, you said took forever, with Judge Moody?

A  I know that it became a serious possibility after we exhausted, in front of Judge Moody, every way of whether or not it would be correct or appropriate or even allowed to do it; coming in as head of the Sea Org, when Judge Moody said that it could — that he could be added as head of the Sea Org, not as COB because of that agreement.

Q  Right.

A  Which, you know, I didn’t even know about until after the fact.

MR. DANDAR: All right. Okay. Probably a good time to break for lunch, unless you have a question, Judge.

THE COURT: I think it’s a good time to break for lunch. We’ll be in recess — you know, an hour just isn’t enough. I need to make some phone calls and sign some things. We’re going to break until quarter till 2.
Court’s in recess.

MR. WEINBERG: And the same instructions to

0580

Mr. Prince.

THE COURT: Same instruction.

(A recess was taken at 12:29 p.m.)

0581

REPORTER’S CERTIFICATE

STATE OF FLORIDA  )
COUNTY OF PINELLAS )

I, Donna M. Kanabay, RMR, CRR, certify that I was authorized to and did stenographically report the proceedings herein, and that the transcript is a true and complete record of my stenographic notes.

I further certify that I am not a relative, employee, attorney or counsel of any of the parties, nor am I a relative or employee of any of the parties’ attorney or counsel connected with the action, nor am I financially interested in the action.

WITNESS my hand and official seal this 9th day of July, 2002.

______________________________
DONNA M. KANABAY, RMR, CRR

Notes

Declaration of Jesse Prince (December, 1999)

Daniel A. Leipold, State Bar No. 77159
LEIPOLD, DONOHUE & SHIPE, LLP
960-A West Seventeenth Street
Santa Ana, CA 92706
Telephone: (714) 796-1555
Facsimile: (714) 796-1550

Craig J. Stein, State Bar No. 98041
GARTENBERG JAFFE GELFAND & STEIN LLP
11755 Wilshire Boulevard, Ste. 1230
Los Angeles, CA 90025-1518
Telephone: (310) 479-0044

Ford Greene, State Bar No. 107601
HUB LAW OFFICES
711 Sir Francis Drake Blvd.
San Anselmo, CA 94960
Telephone: (415) 258-0360

Attorney for Plaintiff,
LAWRENCE DOMINICK WOLLERSHEIM

SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES

LAWRENCE DOMINICK WOLLERSHEIM

Plaintiff,
vs.
CHURCH OF SCIENTOLOGY OF CALIFORNIA
Defendant
Case No.: C 332 027

Honorable Charles W. McCoy
Department 24

SUPPLEMENTAL DECLARATION OF JESSE PRINCE1

I, Jesse Prince declare as follows:

1. I am over 18 years of age and currently reside in the State of Illinois, County of Cook. This declaration is of my own personal knowledge and if called upon to testify to the facts herein I could and would be competently able to testify thereto.

MY PARTICIPATION IN SCIENTOLOGY
THE SEA ORGANIZATION

2. I joined the Sea Organization, commonly referred to as the Sea Org, in September of 1976. The Sea Org is a para-military organization that manages and controls all of the Scientology Organizations and related entities that exist in the world. I was also required to sign a billion year contract at the time I was recruited. Within a week, I entered the first Sea Org indoctrination program named the Estates Project Force. The Estates Project Force consists of several levels of indoctrination named “Product Levels.” On these “Product Levels,” I was indoctrinated in Scientology ethics and justice procedures and the history of the Sea Organization. I was invasively interrogated (called confessional in Scientology) and took a mission school-training course, among other indoctrination courses. Flag Order 3155RC, entitled “The Basic Sea Org Training Program,” details the training required for persons newly recruited to the Sea Org. A true and correct copy of this document is attached hereto as Exhibit “HHH-99.” From the very beginning, through indoctrination from these courses, I learned that the Sea Org managed all Scientology Organizations and related entities such as Scientology Missions International (SMI), World Institute of Scientology Enterprise (WISE) and Narconon, to name a few. The length and breadth of the doctrine of the Sea Org is detailed and codified in issues named “Flag Orders.” The primary business of the Sea Org is missions. One definition of “mission” in Sea Org terms describes an activity whereby two or more Sea Org members go to a remote Scientology organization or enterprise and take over the activity for the purpose of getting the activity to make more money which, in turn, benefits the Sea Org financially. The governing policy of the type of mission referred to above, is to cause the activity (Organization) to make money, then make more money, then make other people produce so as to make money. See HCO Policy Letter 9 March 1972 “Income Flows and Pools,” a true and correct copy of which is attached hereto as Exhibit “QQ-99.” These same missions are authorized by the Sea Org to use Scientology ethics and justice procedures. This authority gives these types of missions total authority to remove and demote personnel, including corporate officers and executives in any Scientology Organization, corporation or Scientology-related entity as it sees fit. See Exhibits: “M-99,” “Y-99” and “FF-99,” which are true copies of the original documents. See also, Sea Organization Central Bureaux Order 621 29 November 1979 “By Pass of Management Sector Handling of,” a true copy of which is attached hereto as Exhibit “RR-99.”

3. The success of the Sea Org is primarily measured by its income. Sea Org income is defined as “the amount of money received by the corporation (Sea Org) after the allocation to Sea Org and Scientology Organizations” [translated, this means each and every Sea Org organization as well as each and every Scientology organization world wide sends to the Sea Org all monies remaining after the basic necessities (bills and payroll for staff) of the individual organization are paid and before management expenses are taken out; this is the classic double bite which normally reduced the Sea Org and Scientology Organization staff payroll allocation]. This is according to Hubbard policy letter of 9 March 1972, called “Income Flows and Pools, Principles of money management,” a true copy of which is attached as Exhibit “QQ-99.” This “policy” was written by L Ron Hubbard. During my tenure in the Sea Org, I executed many of these missions within the United States and other countries of the world.

COMMAND STRUCTURE AND HIERARCHY OF THE COMMODORE’S MESSENGER ORGANIZATION AND THE SEA ORGANIZATION

4. Until his death in 1986, L. Ron Hubbard was the unchallenged dictator of the entire Scientology enterprise. L. Ron Hubbard designated himself “Commodore”. In the hierarchy of the Sea Org, “Commodore” is the highest rank. L. Ron Hubbard created a “statistic system” for every function and activity of Sea Org and Scientology organizations and micro-managed this created “statistic system.” According to his many written policies, the best thing a Sea Org member or Scientologist could do was to always have “statistics” going up. Hubbard authored, or had others author, many thousands of detailed instructions and directives intended to teach his flock how to keep the “statistics” going up. He wrote or had written Polices, Flag Orders, Bulletins and Executive Directives concerning every aspect of the operation of the Sea Org and Scientology organizations. Sea Org members and Scientologists are required to follow these instructions and orders of Hubbard to the letter. This is documented and made very clear in a policy letter written by Hubbard, entitled “Keeping Scientology Working.” This policy letter declares that it is a “criminal offense” not to follow any L. Ron Hubbard instruction to the letter. These crimes are punishable through Scientology ethics and justice procedures.

5. Next in authority in the Sea Org hierarchy are the “Commodore’s Messengers.” L. Ron Hubbard authored Flag Order 3729, also known as Executive Directive 106 Commodore’s Messenger Organization (CMO), entitled “Commodore’s Messengers.” This issue is one of many directives and instructions on how to be a “good” Commodore’s Messenger. In the above issue, Hubbard shares his total authority over his Sea Org and Scientology Empire with others who have been trained to think and act in the same way as Hubbard himself. He designated his “messengers” as emissaries of himself. This same issue was issued to all Sea Org members with the instruction that all were to recognize his messengers as an extension of himself. All were instructed to show his messengers the same respect and courtesy as his flock of Sea Org members and Scientologists were required to show Hubbard, the single highest authority of the Sea Org and Scientology empire he created. Messengers had complete authority to go within any Sea Org, Scientology, or Scientology-related entity. A true and correct copy of Flag Order 3729 is attached hereto as Exhibit “UU-99.” As a note, only Sea Org members are ever eligible to become Commodore’s Messengers.

6. There is a hierarchy within the Commodore’s Messengers Organization. The top messenger, also known as the “Commanding Officer,” commands and orders all other messengers within the organization of messengers. The top Commodore’s Messenger in Scientology is David Miscavige. There are also subordinate “In Charge” positions within the messenger organization. An In Charge would have the authority to command and order lesser messengers, Sea Org Members and any Scientologist if it meant complying with an order from a higher messenger or L. Ron Hubbard himself. Two issues written or ordered by L. Ron Hubbard, entitled CMO Command Channels, issued 15 June 1976 and issue CMO Regulations, issued 11 Jan 1976 are among the many directives that define the authority of the Commodore’s Messenger Organization. A true and correct copy of CMO Command Channels is attached hereto as Exhibit “TT-99;” a true and correct copy of CMO Regulations is attached hereto as Exhibit “SS-99.”

7. There is also a hierarchy among the different messenger organizations. The most senior messenger organization in all of the different messenger organizations is “The Religious Technology Center” (RTC). This is documented in the many different “Command Channels” booklets issued and authored, and/or authorized by RTC since the early 80s. See Exhibit “X-99.”

8. The next command level below RTC is called “The International Watchdog Committee.” The Watchdog Committee was created with the purpose of overseeing the activities of the Guardian’s Office and Scientology management bodies in order to “keep Scientology working.” It is a senior management committee that manages all sectors of Scientology, i.e., all Sea Organizations, all Scientology Organizations International, and related Scientology entities such as Scientology Missions International (SMI), and World Institute of Scientology Enterprise, International (WISE). See HCO PL 22 December 1981, “International Watchdog Committee,” a true and correct copy of which is attached hereto as Exhibit “VV-99.”

9. The next level of hierarchical authority within the messenger organizations and Scientology Enterprise is the “Commodore’s Messengers Organization International” (COMINT). This body executes the orders and commands of the Watchdog Committee, and manages and supervises the many other Commodore’s Messenger Organizations within the United States and abroad. (See Exhibit “VV-99.”)

10. Next in the chain of hierarchy is the Office of the Executive Director International (EDINT). The Executive Director International orders and commands the senior-most Sea Org executives over all the different management sections of the Sea Org, Scientology Organizations International, and every other Scientology related entity. These executives in turn order and command all areas of the Scientology empire. This office is not a Commodore’s Messenger Organization, but it is a Sea Org organization.

11. There are descending levels of the hierarchical chain of command from this point, as described in Scientology’s Command Channel booklets. From early 1983 until January 1987, I was the second in command of the Religious Technology Center. I was identified by RTC attorney Samuel Rosen as such in Federal Court in Denver on August 20, 1998. See Exhibit “C-99,” attached hereto.

A CLASSIC EXMAPLE OF THE APPLICATION OF “MISSION TECH” TO BYPASS CORPORATE LINES OF AUTHORTIY

12. In October of 1982, I was part of a Sea Org Mission that was sent to San Francisco to “handle” the Mission Holders of the Church of Scientology. The Mission Holders were Franchisees of Scientology who offered introductory
courses in Scientology to the public.

13. L. Ron Hubbard was upset with the Mission Holders because he felt that the Mission Holders in general were withholding tithes owed to Sea Org International Management. L. Ron Hubbard had also sent down orders stating that several Sea Org members in high leadership positions within the Commodor’s Messenger Organization International (“CMO Int.”) and the Office of the Executive Director International (“ED Int.”) were dissatisfied with Scientology management and were siding with the Mission Holders. L.Ron Hubbard’s orders went to David Miscavige and they were clear: Handle this insurrection and crush anyone who protested.

14. The missionaire in charge of the San Francisco Mission Holder’s Mission was David Miscavige. Mr. Miscavige is flat out attempting to deceive this court in his declaration when he characterizes his presence at this conference as that of an “invited” master of ceremonies. Mr. Miscavige was the Missionaire I/C (In Charge) and was running the entire operation. Further, his “invitation” certainly did not come from the Mission Holders, it came in the form of Mission orders from the Commodore himself, L. Ron Hubbard. Lest there be any doubt whatsoever about the truth of what I am saying, I invite the court to examine Exhibit “L-99,” a true and correct copy of which is attached hereto.

15. Exhibit “L-99,” paints a far different picture of the San Francisco Mission Holder’s Conference than the “Shore Story” Scientology is telling. Exhibit “L-99,” THE SEA ORG MOVES IN, is a newsletter that shows clearly how Miscavige and the Sea Org characterized the San Francisco Mission Holder’s conference for the purpose of letting the staff and paying public of Scientology know who had won the power struggle between the Sea Org and the Mission Holders. It gives a far truer picture of what was going on at this conference than even the published “transcript” of the conference, because the transcript was heavily edited before Miscavige approved it for publication.

16. I was part of the mission headed up by David Miscavige that was ordered to handle the San Francisco Mission Holder’s Conference. The first thing the mission did upon its arrival in San Francisco was to visit the local Scientology Organization. Missionaire I/C, David Miscavige immediately bypassed all corporate lines of authority and started an inspection of the organization. He decided that the Executive Director of the organization was incompetent and he viciously interrogated him with an e-meter, (a form of lie detector), physically abused him, and removed him from his position on the spot.

17. From the local Org, we proceeded to the Mission Holder’s Conference. By this time, David Miscavige had really worked himself into a lather, and he declared two Mission Holders “Suppressive Persons” and expelled them on the spot. This is brazenly bragged about in the issue “The Sea Org Moves In.” The doors to the conference room were locked and guarded. Miscavige then lined up approximately 20 other Mission Holders, most of whom were crying and terrified, and told them to get their checkbooks ready as they had been “ripping off” Scientology Organizations of their “rightful income” for too long. In reality, Miscavige and several others just took whatever amount of money they wanted out of the Mission Holder’s corporate accounts.

18. Miscavige introduced Larry Heller, attorney for Scientology who was personally hired by Miscavige, who informed the Mission Holders that the “New Tough Management” intended to prosecute and jail anyone who did not comply with the orders and directions of the new management.

19. Lyman Spurlock, a senior Sea Org executive who was one of Miscavige’s inner circle, threatened the Mission Holders with prosecution and explained that the Sea Org now had the power to do this to the Mission Holders because of all the new corporate changes that were designed to exert more control over the Mission Holders.

20. The “new management” is pictured in their Sea Org uniforms at the speaker’s table in Exhibit “L-99.” These are the same people who manage Scientology today, and they do it in the same manner, through their positions of power in the Sea Org.

21. When all of the speakers were done, each and every Mission Holder was viciously interrogated by multiple missionaires using the e-meter. Then each mission holder was required to have a mug shot taken, one from the front and one from the side, in the same way police commonly do. After the mug shots were taken, the Mission Holders were required to write checks from their corporate accounts for the maximum amount of money possible.

22. When all the Sea Org Missionaires returned to Gilman Hot Springs, which is the true home of Scientology’s International Management, the results of the mission were sent directly to L. Ron Hubbard. The Commodore was very pleased with the report he got from David Miscavige and decided to make it a policy to run this mission in European countries where Scientology existed. I was sent on this mission along with others to do the same activity to Mission Holders in Copenhagen, Denmark.

23. This activity continued in other locations, executed by the International Finance Police under the direction of the International Finance Dictator located in the Commodore’s Messenger Organization International. All of this was under the dictatorship of Miscavige.

ATTACK THE ATTACKER

24. Attached hereto as Exhibit “A-99,” is a true and correct copy of a Scientology directive titled “Attacks on Scientology, Additional Policy Letter,” which states, in part: “This is the correct procedure:

“(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 on the attackers to the press.

“Don’t ever tamely submit to an investigation of us. Make it rough, rough on attackers all the way…

“Never talk about us – only them. Use their blood, sex, crime to get headlines. Don’t use us…

“Shift the spotlight to them. No matter how. Do it!”

25. Attached as Exhibit “AAA-99,” is A true and correct copy of the Committee of Evidence and “Declare” statement of Alex Sibersky, and attached as Exhibit “BBB-99,” is a true and correct copy of the Committee of Evidence and “Declare” statement of David Mayo.

26. I was a member of the committees of evidence documented in Exhibits “AAA-99” and “BBB-99.” There was no fairness involved in these supposed “justice” actions. Hubbard considered that these people were “disaffected with management,” and disloyalty (meaning questioning anything at all) is the worst crime a Sea Org member can commit. What was going to happen to these people was already pre-determined by Hubbard and executed by Miscavige. We were required to sign our names to a document that had already been prepared. I have personal knowledge that such actions are
based on long-standing policies.

27. Attached hereto, as Exhibit LL-99 is a true and correct copy of Flag conditions Order 7068, 27 December 1982, SURPPRESSIVE PERSONS DECLARE pertaining to eight separate individuals.

28. With regard to my former position as a high-ranking executive in the Sea Org, even Scientology attorney Samuel Rosen told the judge in the FACTNet hearing in Denver that I had been second in command of all of Scientology (See Exhibit “C-99”). I was an expert witness on the subject of Scientology on behalf of RTC in the Robin Scott/David Mayo litigation. In addition, on December 31, 1986, Miscavige himself introduced me as “Deputy Inspector General” at a New Year’s Eve event at the Flag Land Base in Clearwater, Florida. I gave a briefing at that event about how RTC was going about crushing people who tried to apply any part of Scientology technology without paying for it, an issue which was part of the Scott/Wollersheim II litigation. (A true and correct copy of a audio tape of the Scientology New Years Event of 86/87 is contained on Exhibit “XX-99,” attached to this motion.)

29. I did give two taped interviews, which contradict my statements in this declaration concerning Miscavige’s control of Scientology. The first interview occurred shortly before Halloween in 1992. With my wife, I was trying to get permission to leave the secret compound in Gilman Hot Springs, and they would not allow us to leave unless I agreed to state on audiotape that I was leaving on my own free will, that I was happy and pleased with being incarcerated against my will on the Rehabilitation Project Force, that I had committed many crimes in Scientology and Scientology had helped me overcome these criminal tendencies, that Miscavige was not the dictator of Scientology, and that I had never witnessed any illegal activities being committed within Scientology. I was also required to make self-denigrating statements on this tape which were not true. I was threatened by Marty Rathbun and Mike Sutter that if I did not agree to make this taped statement, I would become the target of Fair Game. The giving of “interviews” such as I went through are part of the policy of Scientology and anyone leaving the Sea Org is required to “route out” pursuant to policy or be declared.

30. The second interview happened in Boston in 1994. Mike Sutter called me and said that he wanted to see me to find out how I was doing. He made it sound like a friendly chat that we were going to have. At that time I was still afraid of the imagined power these people had over me. I agreed to meet with Mike Sutter and Scientology attorney Earl Cooley at Cooley’s office in Boston. Instead of a friendly chat, it turned into an interrogation in which they told me they were doing poorly in some of their legal cases and demanded to know if I was assisting “the enemy.” Before I was allowed to go, they drilled me on what to say and then put it all on tape. They took information from my auditing folders and kept “reminding” me of things I had said in sessions.

31. These taped statements are Scientology’s way of attempting to destroy the credibility of a former Scientologist who has knowledge that can harm the organization in case that individual later decides to come forward to expose the truth.

32. Until the reorganization of 1982, in which RTC was formed, it had been CSC that registered the trademarks for Scientology. RTC was specifically created to take over that function from CSC. As far as I know, ASI took over the function of overseeing the copyrights.

I declare under penalty of perjury that the foregoing is true and correct under the laws of the State of California executed this __ day of December 1999, at Tampa, Florida

_____________________________
JESSE PRINCE

Notes

Declaration of Stacy Brooks Young (December 14, 1994)

CT 7437

I, Stacy Brooks Young, declare as follows:1

1. I am over 18 years of age and a resident of Seattle, Washington.

2. I was a Scientologist for nearly 15 years, from January 1975 until I escaped with my husband, Robert Vaughn Young, in July 1989. From October 1975 until I left I was a member of the elite inner circle of Scientology, an unincorporated organization known as the Sea Organization (“Sea Org”) which rules the Scientology empire. Unbeknownst to the outside world, even to lower level Scientologists, the head of the Sea Org and of Scientology, David Miscavige, subjects Sea Org members to extremely abusive and degrading treatment, sometimes carried out directly by him but often carried out by his key aides.

3. Such abuses include sleep deprivation, an enforced diet of nothing but rice and beans for weeks or even months at a time, incarceration in Scientology prison camps known as the Rehabilitation Project Force (“RPF”) for months and sometimes years; sexual harassment and discrimination, requiring women to undergo abortions with the threat of losing their jobs if they refuse, enforced separation of parents and children, enforced separation of husbands and wives, and denial of proper medical care for people driven into psychotic episodes as a result of such abuse as described above.

4. A year and a half ago, in July 1993, my husband and I were asked by several attorneys to document the abuses we experienced and witnessed while in the inner circle of Scientology. These attorneys were defending people who were being sued by Scientology. Until that time we had kept totally quiet about our experiences because we were aware of how Scientology intimidates and harasses anyone who speaks out publicly about the abuses in this organization. We knew that if we began

1

CT 7438

to talk about what we knew our lives would no longer be our own, that Scientology would apply their “Fair Game” doctrine against us. The Fair Came doctrine directs Scientologists to lie, cheat and destroy anyone perceived as an “enemy.” They claim that Fair Game was canceled long ago, but they are lying. Because we had seen it done to others, we knew that they would send private investigators to talk to our family, friends and neighbors, that they would dredge up everything they could about our private lives, in short, that we would be subjected to a campaign of character assassination just as any other fascist political movement like Scientology would conduct against its critics. However, we made the decision that it was too important to make the truth known, no matter what the cost to our own privacy.

5. The Scientologists have lived up to our worst expectations and beyond. They have stolen our trash, kept us under constant surveillance, sent out libelous information, slandered us to friends and family, and done everything possible to make us “shudder into silence,” as Scientology creator L. Ron Hubbard directed them to do with critics. Our home has also been burglarized twice, and while we cannot prove that Scientology was responsible, we pointed out to police investigators that only our in-home office computers and disks were stolen, while other valuables in the house were left untouched.

6. In July 1994, just this past summer, two high level Scientologists approached my husband and me and offered to pay us money if we would perjure ourselves by stating under oath that the information we have provided in sworn declarations is false, which it is not, and agree never to speak or write another critical word about Scientology again. These two Scientologists warned us that if we refused to agree to their terms they would increase the intimidation and harassment of us, break us financially, and ruin our reputations. We still refused to give in to their threats.

7. True to their promise, they have stepped up their campaign against us in the last several months. It is continuing as recently as Monday, December 12, when a

2

CT 7439

private investigator called my mother and, under the guise that he was doing an investigation of my husband, attempted to turn my mother against me with lurid tales about my sex life. His attempt backfired, however, when my mother made it clear to him that she does not care about my sex life and that his attempt at character assassination made her sick. She demanded to know his name and phone number, and when he refused to give it to her she hung up on him. What they don’t realize is that people outside of Scientology don’t adhere to their Draconian morality, which especially in the Sea Org is so intrusive that people are sent to the prison camp for their sexual practices (the only exception being Miscavige’s hand-picked aides, for whom these same laws do not apply). This same private investigator has already called one of my sisters and my other sisters are now expecting calls from him as well. Our family and friends are aware that this campaign is being waged against us and that it is being done because Scientology has not been able to silence us any other way.

8. I have been shown an extract of a motion made by Church of Scientology International in the case of Church of Scientology International v. Fishman and Geertz, No. 91-6426-HLH (Tx) (C.D.Cal.) in which CSI falsely alleges that my husband and I committed perjury in certain declarations we have submitted for this case. The extract is entitled Two Other Defense Witnesses Signed False Declarations. XXX[initial SBY] XXX[initial SBY] The phrase “two other defense witnesses” refers to my husband and me. It is false.

9. The extract is based on a certain “Rinder Declaration,” submitted October 27, 1994, which is a wildly distorted, false representation of a series of meetings which occurred over an eight-day period in July 1994.

10. In June 1994, two high-level Scientology operatives, Mike Rinder and Mike Sutter, began to call me and my husband begging us to meet with them to “settle our differences.” These two people called one or the other of us nearly every day for approximately a month, insisting that we meet with them and assuring us that they

3

CT 7440

would make it very worth our while to do so, clearly implying that they wanted to pay us money to stop doing the legal consulting work that we have done for Mr. Graham Berry and other attorneys whose clients have been sued by Scientology.

11. My husband Vaughn had no interest in meeting with them at all and told them so in no uncertain terms. Rinder and Sutter continued to call him and even arrived uninvited at our house in Corona del Mar, California, (where Vaughn was finishing up some work in preparation for moving to Seattle,) to try to get him to agree to a meeting. When it became obvious that Vaughn would not agree, they began calling me at our house in Seattle.

12. Mike Sutter called me every day, telling me how important it was that we meet with him and Rinder. Both Mike Sutter and Mike Rinder were superior to me and had a tremendous amount of power over me when I was a member of the cult. Sutter in particular had been assigned to “handle” me after Vaughn and I had tried to leave the cult and had been persuaded to return. Because of this past relationship which I now understand was based on mind control, I was still afraid of Sutter even five years after leaving Scientology. I allowed him to engage me in conversation, and by intimidating me he succeeded in convincing me that Vaughn and I should hear them out. I then talked Vaughn into meeting with them.

13. My state of mind at the time was that I did not want to have anything to do with Scientology any more. Although I did not realize it at the time, I was still under the influence of the cult to the degree that they could still intimidate me, frighten me, and “trigger” strong emotional reactions in me. Scientology was particularly upset about the work my husband and I had done for attorney Graham Berry, advising him about the destructive practices of the upper echelons of Scientology and submitting a number of declarations relevant to CSI v. Geertz. As I explained earlier in this declaration, because of our work for Mr. Berry and other attorneys, Scientology considered us “enemies” and we became the targets of Scientology’s

4

CT 7441

Fair Game doctrine, meaning that we had been harassed and intimidated relentlessly by Scientology operatives. Although they attacked my husband much more viciously than me, it upset me very deeply and frightened me. I did not want to have my private life exposed and I did not want to see my husband’s private life being distorted and exposed and held up to ridicule the way Scientology had been doing.

14. Because of their relentless harassment and intimidation, I had made a decision not to do any more work to expose the truth about the Scientology cult and, indeed, had not done so for several months prior to the meetings with Rinder and Sutter. I was also strongly pressuring my husband to stop so that we could regain our privacy and peace of mind. I wanted Scientotogy to leave us alone.

15. It was in this frightened state of mind that I began to receive the daily phone calls from Mike Sutter. Sutter assured me that the harassment would stop and made it clear that Scientology would pay us a large amount of money if we would settle with them. Sutter also made it clear that if we did not agree to settle with Scientology, we would be subjected to even greater harassment than we had already experienced, although he said that he was “sorry” and that “it doesn’t have to be that way,” if we would only agree to talk to them. I felt extremely intimidated by his phone calls and strongly pressured Vaughn to agree to talk to them. Although Vaughn did not feel that they were being above-board about their intentions, he agreed to it because he knew that I was very afraid of them and he did not feel he should force me to continue in a situation that was extremely frightening to me.

16. Mike Rinder and Mike Sutter arrived in Seattle on Friday, July 8, 1994. Vaughn also flew to Seattle on that day. Vaughn and I met with them nearly every day for the next eight days. I was extremely gracious and cordial to both of these Scientologists throughout the meetings, inviting them to our home and doing everything possible to create an atmosphere of trust and honor. After reading Rinder’s declaration I feel betrayed and outraged that he has now perverted and

5

CT 7441

twisted things that my husband and I talked to them about during those meetings. I do not fault these two individuals. I know that they are under the influence of Scientology mind control and that the vicious lies Rinder has sworn to in his declaration are part of the campaign of character assassination that he is under orders to conduct against my husband and me.

17. However, I wish to correct the many lies and perversions of the truth that he has told about us. I also want to make it clear that I went along with much of what Rinder and Sutter said to us because I knew it would do no good to argue with them about much of what they were saying. Someone under the influence of Scientology mind control cannot change his mind about certain attitudes and beliefs, and I was aware that because these two people were still under the control of Scientology it would do no good to try to argue with them. Therefore, Rinder seems to have come away from the meetings thinking that I agreed with what he said simply because I did not refute it. The fact is that I did not bother to refute many things he and Sutter said because I knew it would be a waste of time. Furthermore, my husband and I had agreed to go along with them so that we could find out whatever it was they had to say to us that was so important that they had begged us to meet with them for over a month. The reason the meetings went on for so many days was that we kept waiting for them to get to the point and weren’t able to find out what it was until the eighth day. (When we did finally get them to get to the point, we walked out.)

18. First and most importantly, at the very outset of these meetings we made it clear that we would not perjure ourselves by recanting any statements made in our previous declarations, that what we had stated was true and we would not now lie by saying that what we had written was not true. Much to their dismay, we also made it clear immediately that we would not in any way denigrate Mr. Graham Berry. They tried to change our minds about Mr. Berry by suggesting that he had put us up to writing our declarations, but we were emphatic in stating that he never did any such

6

CT 7443

thing and we would not say that he did. At the end of the series of meetings we discovered that, indeed, one of their main purposes was to get us to discredit Mr. Berry, who has been extremely successful in litigating against Scientology. A key theme in the declarations they drafted for us to sign was that Mr. Berry had orchestrated every aspect of our “attack” against Scientology. We refused to go along with their character assassination of Mr. Berry.

19. Throughout the meetings they repeatedly suggested that we write declarations but were vague about what they wanted the declarations to say. When they would bring up the subject of these declarations we would repeat that we could not write anything that would in any way suggest that we had lied, since we had not. At one point Sutter asked me what I felt I would be able to say, and I replied that I would be able to say I had written declarations as an expert witness for the defense of Uwe Geertz and Steven Fishman and that I had written them in a way that would be helpful to their defense. lt is utterly false that “when the Youngs — especially Stacy Young — spoke frankly about what occurred here, they revealed that their declarations, too, had been falsified.” We repeatedly emphasized to both Rinder and Sutter that nothing whatsoever in our declarations was false.

20. Many of the statements in the Rinder declaration are entirely false, while others are treacherously misleading in the way statements we made are misinterpreted and deliberately twisted to make me or my husband appear to be dishonorable or unscrupulous.

21. It is completely and utterly untrue that “At the beginning of our discussion, both of the Youngs stated that they did not enjoy manipulating the facts to attack and embarrass their former religion, but that economic hardship had compelled them to embark upon that course.” Neither my husband nor I have ever believed that Scientology is a religion and would never refer to it as such. Furthermore, neither of us feel that we have manipulated facts. On the contrary, we have told the truth about

7

CT 7444

many destructive practices that are part of the Scientology empire in the hopes that exposure of these conditions will lead to their being changed.

22. Rinder’s opinion that “it was apparent that the reason they were talking to us was because they found it emotionally distressing to be involved in an occupation that required them to figure out how to manipulate and distort facts for use in litigation” is contrived and utterly false. Moreover, I never said that I “could not stand living a lie and wanted out.” As I have explained in a previous paragraph, what I found emotionally distressing was the campaign of harassment, intimidation and character assassination Scientology has been waging against us ever since we began to speak out about the abuses inside the cult.

23. Rinder’s statement that I said we “tried to live off various family members while Vaughn attempted to establish himself as a writer” is utterly untrue and a fabrication out of thin air, as is the comment that “the family eventually balked at that, and the Youngs were on their own.” We never “tried to live off” any of our family members and have been “on our own” all along.

24. Vaughn and I did have financial difficulties when we first left Scientology, as do many long-term members of Scientology’s inner circle (and any other totalitarian cult, for that matter) if they are fortunate enough to free themselves from the cult’s psychological, emotional and physical subjugation. Vaughn had been a Scientology staff member for 20 years and I had been one for 15 years. We had no résumé that we felt would make any sense to the “outside” world, nor did we have any references. We were considered “enemies ” by Scientology, so we knew that people still inside the cult would not say anything favorable about us. Since we had had virtually no professional contact with anyone outside the cult for many years, we had no references. It was literally as if we had just landed from outer space.

25. I am sorry that I told these two Scientologists about the hardships Vaughn and I experienced as we were struggling to come out of the cult experience. I should have

8

have realized that they would utilize these details of our personal life in their campaign to discredit us. Rinder has now taken this information and twisted it to support his false argument that we are exposing the truth about Scientology to make money. The Court should know that there are many, many other ways we could make a living that would be much more enjoyable and more lucrative. But we feel a moral obligation to do what we can to expose the civil and human rights violations and serious abuses which this cult is perpetrating on its subjugated mind control victims.

26. Rinder falsely states that “At one point in our conversation, Stacy broke into tears and said that she and her husband only began consulting with and selling declarations to Graham Berry because she and Vaughn were so desperate for money. Stacy said she had been willing to say under oath whatever Berry wanted her to say if it would result in getting paid, as she could not face continuing to live under the financial pressure she and Vaughn were suffering. There was one point during the meetings with Rinder and Sutter when I did, indeed, break into tears. It was certainly not, however, for the reason Rinder states. I began to cry at one point as Mike Sutter was attempting to address my concerns about staff conditions and certain specific abuses I suffered while I was in the cult. Something he said triggered some extremely painful memories for me, memories of being forcibly separated from my husband, having our mail intercepted, being kept under guard to keep me from escaping to find my husband, being deprived of sleep for days on end, being locked in a room and interrogated for days at a time, being screamed at and terrorized by Miscavige and his top aides.

27. For many former cult members, certain things someone might say or do can trigger painful memories from their cult experience and they may find themselves becoming very emotional at unexpected times. I found that simply being in the same room with two members of Scientology’s inner circle, two people who used to have

9

CT 7446

enormous power over me, stirred deep-seated emotions that I had not felt since I escaped from the cult. Of course, I did not explain this to these two Scientologists because I knew they would not understand. But certainly I was not upset for the reason Rinder has stated. He is trying to paint my relationship with Graham Berry in a scurrilous light but his accusations are utterly groundless and false. Mr. Berry never told me what to say in my declarations and certainly never drafted a declaration for me to sign the way Rinder and Sutter did for my husband and me. In fact it is the Scientologists who will say whatever will further their own agenda, regardless of whether it is true or not, just as Rinder has done in his declaration. They assume that people outside of Scientology have the same contempt for the legal system as they do, and that others are guilty of the same illegalities, such as perjury, which they commit themselves as a matter of course.

28. Rinder states that “both Mike Sutter and I brought up how we could not understand how they could tell so many lies in the declarations they had filed, especially those in the Fishman case. Neither denied that this was what they had done…” and repeats his character assassination of us as liars in the next paragraph where he states, “We challenged them to explain how they could justify lying as a way of life…” As I have stated earlier in my declaration, in fact my husband and I both repeatedly told them that we had not lied in our declarations, although throughout the meetings Rinder and Sutter did continue to characterize our sworn testimony as “lying.” The truth is that if either of these people ever admitted to themselves that our testimony is true it would break the spell that Scientology has over them. But Scientology has a self-policing mechanism built into its mind control techniques which makes it almost impossible for someone under its influence to break through. Rinder and Sutter both know that our testimony is true. They are both acutely aware of the abuses we have described. But they are loyal Party Members and are sworn to protect the Party at all costs.

10

CT 7447

29. Clearly the main intent of Rinder’s declaration is to discredit the declarations my husband and I have filed in CSI v. Fishman and Geertz. He seems most concerned with a declaration submitted by me on January 3, 1994, in which I detail how Scientology’s fraudulent negligence in selling Steven Fishman nearly $200,000 of Scientology materials and devices could have driven him into a psychotic episode. Rinder goes on for several pages, carefully reconstructing our conversations to make it appear that I somehow admitted to him that what I wrote was untrue. The subject of my January 3 declaration is extremely sensitive for Scientology and this is why Rinder has spent so much time trying to discredit it. But what I wrote in the declaration is true, and I attached many Scientology documents to prove it.

30. In fact, many people have been driven into psychotic episodes by Hubbard’s techniques, as Rinder well knows. Far from being “pure nonsense,” what I wrote about is one of Scientology’s darkest secrets. I have personal knowledge of many people who have been driven into psychotic episodes by Scientology’s techniques. Hubbard wrote precise directions about how to “handle” these people, including the “Isolation Watch.” Rinder is well aware of these occurrences but cannot admit to it because it would violate Scientology policy for him to tell the truth about this subject publicly. It would threaten his good standing as a Scientologist and might get him sent to the prison camp, known as the Rehabilitation Project Force, where he would be separated from his wife and children, kept under guard and forced to do hard labor for 12 or more hours a day. Scientologists will do just about anything to avoid being sent to the RPF.

31. Rinder falsely states that I admitted to creating a false impression in the January 3 declaration about Scientology creator L. Ron Hubbard’s use of mind control techniques. In fact, it is my firm conviction that Hubbard developed extremely sophisticated mind control techniques, that he did so quite deliberately, and that Scientology practices can be very psychologically damaging because of this. I

11

CT 7448

did not pull quotes out of context for the declaration as Rinder asserts. I would be happy to provide more quotes from Hubbard in which he goes into even more detail about how Scientology can be used destructively.

32. Rinder also distorted a conversation I had with him concerning Scientology’s “upper level” materials. I do know that Hubbard wanted these materials kept secret, but I do not agree that they should be. People have the right to know that Hubbard’s science fiction story about the cosmos is what they can expect after they have been sold many thousands of dollars of Scientology services. I do not consider a science fiction story to be a religious scripture, nor do I believe (as Scientologists claim) that there is any danger that anyone will get sick by reading these materials “before they are ready.” This story has been published in many, many publications over a period of many years, and I have yet to hear of one person who has gotten sick from reading it. I think the only reason the Scientologists are so worried about keeping these materials secret is that they are afraid of losing money if people learn the truth. Certainly it has absolutely nothing to do with religion.

33. Rinder attempts to use me to further his own agenda in discrediting other former Scientologists. He falsely states that I think Gerry Armstrong and Larry Wollersheim are both psychotic. To set the record straight, I do not think either of these individuals is psychotic. Indeed, I think both are doing very well at recovering from their lengthy experience with Scientology mind control. However, I do know that Rinder and Sutter both think Gerry Armstrong and Larry Wollersheim are psychotic. I also know that they think my husband and I are psychotic, along with many other people who have come to their senses and left Scientology. This is because Hubbard said so. He repeatedly stated that anyone who leaves Scientology is psychotic. When I was still in Scientology and working for the Office of Special Affairs, it was accepted as a basic truth that anyone who left Scientology was crazy, especially anyone who left and then sued Scientology, which both Armstrong and Wollersheim

12

CT 7449

have done. The truth is that I consider Gerry Armstrong and Lawrence Wollersheim to be good friends and very courageous individuals.

34. Rinder also attempts to use me to discredit the testimony of another former Scientologist, Andre Tabayoyon. Rinder’s version of my relationship with Andre and his wife Mary is wildly distorted and is clearly an effort on his part to create bad feelings between us. This is a technique called “Third Party” in Scientology, in which someone deliberately tells lies about a person to turn friends against friends. I did discuss an incident involving Andre, but I did so in the context of voicing concern about a friend. I now regret ever having said a word and realize I should have known he would use it to try to destroy my friendship with Andre and his wife, Mary. The conversation was carried on at Rinder’s urging, of course, and I was naive not to see what he was doing. In fact, I value my friendship with Andre and Mary and think they are both extremely courageous to have testified about the outrageous abuses they were both subjected to while in Scientology. I hope they are progressing well in their recovery from Scientology.

35. My husband and I never agreed to “write declarations to set the record straight on points described above along with others.” In fact we never did write any declarations or even portions of declarations but rather waited until Rinder and Sutter presented us with their own declarations, drafted by Scientology, for us to sign. When we read them we discovered that they had drafted declarations which did exactly what we had told them repeatedly we would not do. The declarations they wanted us to sign were utterly perjurious, stating that we had lied about virtually everything we have ever stated in declarations submitted in CSI v. Fishman and other cases. Additionally they wanted us to sign a gag order which would have destroyed our freedom of speech as well as our freedom of association by forbidding us ever to speak about our experiences in Scientology or even to meet with anyone else who was speaking about their experiences in Scientology.

13

CT 7449.1

36. The motion which is based on Rinder’s declaration makes the wildly ridiculous claim that we were in “serious emotional turmoil over what [we] had done” and that we “agreed to execute new declarations undoing the false impressions they had created for Mr. Berry.” In fact, as I have already stated, we never did execute any declarations for them at all, and the declarations they drafted for us to sign were completely outrageous.

37. The truth is that when they showed us the declarations they wanted us to sign I told them they were completely wrong to think we regretted any aspect of the work we had done for Mr. Berry. Indeed, I told them in no uncertain terms that I am very proud of the work I have done for Mr. Berry, because I feel it is extremely important for the truth to come out about Scientology.

38. Finally, the motion claims that we “demanded” to be paid an outrageous sum of money but that “the Church was and is unwilling to pay the Youngs to tell the truth.” In fact, they offered to pay us nearly $200,000 to sign their false and perjurious declarations, but we refused. We told them that we would never sign their declarations no matter how much money they gave us, because we would never perjure ourselves nor would we become pawns in Scientology’s vendetta against Graham Berry.

39. Vaughn and I walked out of the meetings at that point, although they begged us to stay. They continued to call us repeatedly over the next several days, imploring us to meet with them again, assuring us that they would give us a “substantial financial settlement,” but I finally made it clear to them that there was no point in continuing the meetings. Vaughn and I have made our decision to continue to expose the truth about Scientology no matter the cost, and that is what we intend to do. Rinder’s blatantly false declaration is simply another part of their campaign to destroy our reputations and our credibility, which is what they warned us they would do if we did not give in to their demands.

14

CT 7450

40. During the course of our meetings Rinder commented that he couldn’t think of anything he wouldn’t do to silence an enemy of Scientology, that as far as he was concerned, the end would justify the means. Sutter and Rinder both made veiled threats during the course of the meetings, making it clear that if we did not settle with them Scientology would ruin our reputations, break us financially, and generally make our lives miserable. True to their threats, Scientology is now doing everything possible, including submitting perjured testimony to this court, to discredit me and my husband. But all of the testimony I have submitted to this court has been true, and it is extremely important that the information which has been submitted remain on the public record.

I swear under the laws of the State of Washington and the United States that the foregoing is true and correct.

Executed in Seattle, Washington, this 14th day of December, 1994.

[signed] Stacy Brooks Young
Stacy Brooks Young

Notes

Declaration of Michael Rinder (October 27, 1994)

[CT 7417]

I, MICHAEL RINDER, declare as follows:1

1. I am over 18 years of age and a resident of the State of California. I am a director of the Church of Scientology International (‘CSI” or “the Church”), the mother church of the Scientology religion. By virtue of my position, I am familiar with the Church’s legal affairs, and I have personal knowledge of the matters set forth in this declaration. If I were called upon to do so, I could and would competently testify thereto.

2. In July 1994, another Church staff member, Michael and I spent several days in Seattle, Washington, meeting with apostate Scientologists Stacy and Robert Vaughn Young. The Youngs left the Church in 1989, and approximately four years later, in 1993, they appeared as witnesses for hire in litigation against Churches of Scientology, Scientologists or businesses owned by Scientologists. Among the attorneys who hired and paid the Youngs for their testimony was Graham E. Berry of the Lewis, D’Amato firm, who used their purchased testimony many times in Church of Scientology International v. Fishman and Geertz, No. 91-6426-HLH (TX) (C.D.Cal.).

3. The Youngs’ activities had resulted in the Church spending considerable time and energy to correct the falsehoods they had injected into these lawsuits. So we travelled to Seattle to meet with the Youngs in the hope that direct communication with them might lead them to correct their false statements and cease their campaign against the Church. We explained this purpose for our visit when we met with the Youngs first on July 9, 1994. We told them that recently several other

1

[CT 7418]

litigation opponents of the Church had stated that they had wished we had been in direct communication earlier and it may have prevented years of litigation and disputes. We told the Youngs that we sought to avoid that same situation from occurring with them.

4. We were direct and forthright with explaining why we wanted to meet with them. At the beginning of our discussion, both of the Youngs stated that they did not enjoy manipulating the facts to attack and embarrass their former religion, but that economic hardship had compelled them to embark upon that course. At the end, however, it was clear that “economic hardship” was simply a euphemism for amoral greed. Their professed guilt about the dishonest quality of their sworn statements could not overpower their craving for money. Thus, we resolved nothing in those talks.

5. Stacy told us that she believed that it would be in everyone’s best interest for the conflict between the Youngs and the Church to end. It was apparent that the reason they were talking to us was because they found it emotionally distressing to be involved in an occupation that required them to figure out how to manipulate and distort facts for use in litigation. Stacy said she could not stand living a lie and wanted out, and that Vaughn also “hated” being involved in the litigation. We explained that we simply wanted to resolve matters, get the record set straight, and the Church and the Youngs could get on with their respective lives. They agreed that this was a desirable objective.

6. Stacy recounted the story of what had happened to them

2

[CT 7419]

and how they had come to get involved with writing declarations in the first place. She said that neither she nor Vaughn were good with money and that after leaving the Church in 1989, they had run up tens of thousands of dollars in debts. She said that they first tried to live off various family members while Vaughn attempted to establish himself as a writer. The family eventually balked at that, and the Youngs were on their own. She said they used up their savings and over-extended their credit cards in an unsuccessful attempt to create a computerized, desk-top publishing business. Stacy said that she and Vaughn both wanted to work as writers and eventually took a series of jobs in several small newspapers in the San Diego and Newport Beach areas. These jobs did not pay well, and they were heavily in debt when the last paper for which they worked went bankrupt. Their financial situation worsened as Vaughn was unemployed and refused to take on any employment other than as a writer. Stacy earned the only income, working for an insurance sales firm which she said she hated.

7. Stacy told us that their financial situation deteriorated to the point that she had threatened Vaughn with divorce if he did not get a job. Vaughn then got a job driving a taxi cab. He was unable to continue this however, when, after running out of gas, he attempted to push his vehicle, lost control of it, and injured his leg. Additionally, Stacy said she had suffered a tubal pregnancy, necessitating an operation. Between the medical bills and the lack of a steady income source, Stacy explained that they ended up more than $50,000 in debt, It was in those circumstances that the Youngs turned to trafficking in

3

[CT 7420]

anti-Scientology allegations as a means of making money.

8. Stacy said that in early 1993, at the depth of their financial crisis, a British anti-Scientologist, Jon Atack, introduced them to an active anti-religionist in the Los Angeles area named Priscilla Coates. It was through Coates and her attorney, Daniel Leipold, that the Youngs connected up with Graham Berry, for whom they eventually became paid “consultants.”

9. At one point in our conversations, Stacy broke into tears and said that she and her husband only began consulting with and selling declarations to Graham Berry because she and Vaughn were so desperate for money. Stacy said she had been willing to say under oath whatever Berry wanted her to say if it would result in getting paid, as she could not face continuing to live under the financial pressure she and Vaughn were suffering. Stacy said that she had made a vow, like Scarlet O’Hara in Gone With The Wind, that no matter what it took, she would never be poor again. Vaughn explained that it was “a great way to utilize twenty years that I was trying to avoid on my resume,” and that he could work one afternoon and make what would be a weekly salary in any other job.

10. In the course of the discussions, both Mike Sutter and I brought up how we could not understand how they could tell so many lies in the declarations they had filed, especially those in the Fishman case. Neither denied that this was what they had done, but explained that in order to be able to survive, they provided testimony requested by the attorneys, and that they had to write what was wanted or they would not get paid. Stacy said it was “obvious” they would not be paid to write things that

4

[CT 7421]

would be helpful to the Church.

11. We challenged them to explain how they could justify lying as a way of life, and they told us that what they had mostly done was twist facts and used “creative writing” and innuendo to paint a picture that was negative to the Church. They explained that they had tried to avoid explicitly lying about facts so they could not be accused of perjury. Vaughn especially seemed proud of this, and said that he was a writer by profession, which is why he was so good at preparing declarations and why he was paid so well. He claimed that unlike the Fishman case declarations of Andre Tabayoyon, Steve Fishman and Garry Scarff, where the lies and inconsistencies were obvious, his declarations were worded in such a way as to make them much more difficult to discredit. Nothing he said ever disavowed his explanation of how he manipulated facts to create false illusions.

12. Both of the Youngs readily agreed that they could easily set the record straight by writing new declarations which would “clarify” the statements they had made previously. Vaughn said that he did not want to write anything that would be a “direct contradiction” to what he had written earlier, but this was simply a matter of “interpreting” things differently. He said he intended to make his career as a writer and would need “credibility” in order to obtain future jobs, so wanted to do this “properly.”

13. Stacy said that by writing such declarations they would “burn their bridges” with the anti Scientology camp. She went on to say that this would not be difficult to do as they did not

5

[CT 7422]

want to be involved in anti-Scientology litigation matters any longer and in fact, they were “between jobs” at the time, so it was an opportune moment to bring this entire episode in their lives to an end.

14. Stacy and Vaughn spoke extensively about matters they had put in earlier declarations during the course of several days of meetings. They explained their true views and talked candidly about many matters. For example, in the Fishman case, Graham Berry wanted them to execute declarations to support the contention that Steven Fishman was an experienced Scientologist. Both Youngs said that this presented a problem as the very data which Berry had given them to orient them to the “facts” of the case proved that Fishman was a fraud. Upon reading Fishman’s unpublished manuscript, The Lonesome Squirrel, they told us they had the same reaction: That Fishman was psychotic and that his so-called experiences in Scientology described in his manuscript never occurred. Stacy specifically mentioned by way of example that the manuscript discusses meetings and activities allegedly done by a Church staff member, Lyman Spurlock. Stacy said that she knew that such incidents could not have occurred; that Lyman Spurlock would never have done the actions Fishman alleged and that Fishman’s description simply does not match Mr. Spurlock. Further, she knew that the meetings described between Fishman and Church officials simply could not conceivably have occurred. She said the whole manuscript was ridiculous, a fabrication. Vaughn said he could not even finish the manuscript, it was so bad.

15. Similarly, they both described watching a video of Fishman describing the operation of a Hubbard Electrometer

6

[CT 7423]

(E-meter). The video was supposed to demonstrate Fishman’s competence and knowledge in Scientology. The Youngs said Fishman explained that the meter’s “sensitivity knob” was used to keep the meter’s needle on its dial, and that this was such a ridiculous mistake that they burst out laughing and knew with certainty that Fishman was not an experienced, Scientology auditor.

16. Stacy also pointed out that they both knew that Fishman’s claims of having completed the Saint Hill Special Briefing Course — an advanced course in Scientology counseling — was a lie, that it was physically impossible for anyone to complete the course in the six weeks Fishman claimed. In fact, after recounting these facts, both Vaughn and Stacy stated that they knew that Fishman and his co-defendant, Uwe Geertz, were both crazy and that their allegations about Scientology were false.

17. Stacy said she had to come up with a way of supporting Fishman’s claims for Berry because she needed the money. She said she knew that she could not state in a declaration that Fishman was a long-term Scientologist as that would be, in her words, “completely untrue.” Instead, she said that she played with words and concepts so that she could, without directly lying, construct a picture that would create the impression that Fishman knew what he was saying about Scientology. She said she even knew that Fishman was ineligible for Church services due to an extensive history of psychological treatment, and to solve that she had created a way of explaining his “involvement” by alleging that “the Church had negligently allowed Fishman to read

7

[CT 7424]

church scripture,” and that this “resulted in Fishman’s mental state deteriorating.” She said that she knew his mental state was not good, and that he knew some Scientology words and terms (though he usually misused them) and therefore this was a “credible” scenario that suited the attorney.

18. Stacy said that her theory was used to support the contention that Fishman had been “exposed” to upper level Church scriptures, even though he had never attained that level in the Church and the materials are kept strictly confidential in the Church.

19. She went on to explain that her distortions had extended to allegations about brainwashing, and that here she had quoted completely out of context from the writings of L. Ron Hubbard. She gave this as a classic example of how one can distort the facts. She said that it was ironic that while she was in the Church she had compiled a pack of materials written by L. Ron Hubbard where he had alerted people to the existence and dangers of mind control techniques through the use of pain, drugs and hypnosis. She had created the pack to rebut falsehoods presented by Bent Corydon in his case against the Church and that it showed that Mr. Hubbard was in the forefront of the condemnation of brainwashing techniques and had developed the first techniques to counteract it. For the Fishman case, however, she explained that she took this very same material and pulled selected quotes out of context to give her declaration a 180-degree reverse “spin.” Her Fishman declaration then gave the false impression that Scientology techniques were mind control when, in fact, they are just the opposite.

8

[CT 7425]

20. One of the falsehoods I brought up with Vaughn Young was his allegation that David Miscavige was involved in the death of his mother-in-law, and that Vaughn had stated that it was a murder.He said that “if you read my statements exactly (‘Mr. Miscavige’s behavior was overlooked in the investigation of the death of his mother-in-law… She died… from three shots to the chest and to the temple from a .22 rifle.’) you’ll see I didn’t say David Miscavige murdered his mother-in law.” I told him that this was the impression he created and he replied “Exactly.” He said that he could never have directly made the accusation as it wasn’t true but he crafted his declaration to create that impression.

21. Young said he had done the same thing when he attempted to create the impression that the Church was involved in the death of Steven Fishman’s wife, even though he knew this was simply incredible. However, he explained that they needed statements that would support the defense’s position, so he worked with the material he had.

22. This is what led to him supporting Fishman’s contention that he had been ordered to commit suicide or to “do an ‘end of cycle.'” Young explained that the three words did have a meaning in Scientology, and even though he knew that Fishman falsely claimed the term was Scientology slang for suicide or murder, and that this in fact was further evidence that Fishman was not a Scientologist, he had enough to go on to fashion a statement for a declaration that would be interpreted to support Fishman’s claims.

23. Vaughn also said that the Church could be poisoned by

9

[CT 7426]

throwing around numerous allegations about the Church ordering people to commit suicide or murder. This was especially difficult to respond to when the events were so old they could not be objectively verified, and where no allegation of wrongdoing had been made at the time, so it would be too time consuming to attempt to correct them all.

24. Vaughn had further expanded on this theory when he stated that one cannot simply leave Scientology — i.e., cease being a member of the Church — because a Church policy states that it is better that a person “be dead” than to not be a dedicated Scientologist. Vaughn said he knew the quote was not meant to be taken literally, but again, it was something that as written he could not be charged with perjury for, yet he created a completely wrong impression. Ironically, both of them acknowledged that except for assistance from the Church to help them retrieve their belongings after they abruptly left the Church without notice, they had had no contact with any Scientologists from shortly after they left the Church until they began to file declarations against the Church, a period of more than three years.

25. Stacy also talked about her assertions that the upper level scriptures of the Church were in the public domain. She was challenged on this and admitted that she knew that the Church took great care to maintain the confidentiality of these scriptures as a matter of religious faith and actively would seek to prevent the improper distribution and exposure of these materials. She said she was willing to withdraw her declaration on this matter, as she knew how important this was to

10

[CT 7427]

Scientologists.

26. After Vaughn and Stacy had opened up and talked a great deal about what they had been doing in their anti-Scientology litigation, they also discussed some of the other witnesses who had been hired by Graham Berry to attack the Church. Their descriptions match my personal knowledge and made it obvious that these are not credible witnesses. Stacy specifically mentioned Gerry Armstrong and Larry Wollersheim, both of whom were also paid witnesses for Berry. Stacy told me that Armstrong is psychotic and lives in a delusory world in which he holds conversations with God. She said that Wollersheim is as crazy as Armstrong is.

27. They also talked about Andre Tabayoyon. Stacy was especially upset about him, and described an incident in which she and others were at the offices of Berry’s law firm. Tabayoyon was upset that he had not been paid and began yelling in a wild and uncontrolled manner and threatening to kill people. When Stacy told him to stop shouting and to act more professionally, he began to make threatening remarks to her. His yelling drew the attention of employees of the law firm who came to see what was going on. When they arrived in the conference room where Stacy and Tabayoyon were located, Tabayoyon abruptly stormed out of the office. Stacy also told me that Tabayoyon continually mistreated his wife, Mary, and that he regarded her as a slave. Both Stacy and Vaughn found this conduct very disturbing, and they said they would find excuses not to have to socialize with the Tabayoyons because they were not good company and had nothing worthwhile to say.

11

[CT 7428]

28. The Youngs said they would write declarations to set the record straight on points described above along with others. However, they said that as they would no longer have a source of income they needed help in getting on their feet. They wanted to get into the environmental or animal rights fields. They wanted nothing to do with litigation any longer, and even said that once they got established they might be able to help forward the Church’s environmental campaigns and programs. We said we would try to help find them jobs and might be able to assist them with a small loan or possibly even purchase of the rights to future writings to help them while they embarked on a new career.

29. We suggested that while we made inquiries about possible jobs for them, they should put together declarations which would rectify the falsehoods and misimpressions thay had created. They agreed that this would be easy for them to do.

30. Mike Sutter and I returned to Los Angeles and contacted Church staff and professionals who had connections in the environmental and animal rights areas and lined up several possible jobs for Vaughn and Stacy.

31. We returned to Seattle some days later to give Vaughn and Stacy the good news about the jobs we had found. We thought they wanted to resolve their differences with the Church and settle down to an honest living and that this would come as welcome news. It became clear almost immediately that they were not interested.

32. They said they had not written draft declarations, and in fact, had been thinking about it and had decided that they wanted the Church to pay them $540,000 — enough money to live

12

[CT 7429]

without having to work for five years. They claimed that if they were to set the record straight it would end their careers as anti-Scientology consultants and that this was a lot of future income to give up. They made no mention of the morality of their position, and when challenged on it, merely responded that this was just a matter of money, not of right and wrong nor truth or fact. They would do and say whatever would make them money.

33. In an attempt to make their ridiculous demand sound reasonable, they stated that even for $540,000 they were not sure that they would write the declarations to correct the record as they had earlier agreed. They said that since we had left they had been in communication with some people they refused to identify, and had been given “legal advice’ that if they were to correct the declarations they had filed, the insurance company could sue them for “breach of contract.”

34. It should be made clear here that neither of the Youngs has any claim against the Church and both have stated such when asked this question directly in deposition. I brought this up to the Youngs to make clear to them that they couldn’t even have a reason for thinking we owed them money. I told them that if they wanted peace they had to voluntarily provide truthful declarations to correct their lies and that we would not accede to their extortionate demand. While admitting that we didn’t owe them anything for what they had done while in the Church, their answer was simple. It was not a moral question. They earned a good living distorting facts against Scientology, and for them to stop, we should pay up. Vaughn Young summed up their position by claiming that the more of an asshole one is the more one is

13

[CT 7430]

worth in this game.

35. I told Vaughn that I could not believe he was demanding that the Church pay him an enormous amount of money so he would not have to work at all. He became very indignant at this and threatened that he would “do more” and that we would wish that we had “paid him now rather than have to deal with what he would do to us in the future.”

36. Thus the Youngs ultimately refused to put down on paper what they had so willingly told us in person, because we would not pay them for the truth like they had been paid to lie.

37. The Youngs never retracted their admissions that their publicly filed declarations created false impressions and contained lies. In fact, they even said they would now have difficulty carrying on with their “profession” as witnesses due to what they had told us.

38. In summary, the facts are as follows: When we met with them alone, the Youngs candidly admitted what we have been telling the court all along, they have been lying and intentionally distorting facts. They do it knowingly and will readily admit to it outside the presence of an attorney or Court Reporter. They feel comfortable in making these allegations because they know that unfounded accusations against Scientology are given much greater deference in the Courts than are false and degrading accusations made about others. They saw this themselves when they were in the Church, and now they exploit it for cash.

39. No doubt they will now try to deny the facts laid out in this declaration, but when they do so, their motivation should be

14

[CT 7431]

remembered. They still have their jobs as anti-Scientology witnesses to protect.

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

Executed this 27th day of October 1994 at Los Angeles, California.

[signed]
Michael Rinder
MICHAEL RINDER

Notes

Video: GA signs Scientology’s “Settlement Agreement” (December 6, 1986)

1

Notes

OSA INT ED 19 “Squirrels” (September 20, 1984)

E X E C U T I V E    D I R E C T I V E

OSA INT ED 191

ALL SCIENTOLOGISTS
PUBLIC NOTICE BOARD
STAFF NOTICE BOARD

20 September 1984

SQUIRRELS
___________

The following people have demonstrated that they cannot be trusted with the religion of Scientology or Scientologists. Their actions are destructive and aimed at the enslavement rather than the freedom of man.

Dede Voegeding
Kima Douglas
Gerry Armstrong
John Nelson
Laurel Sullivan
David Mayo

The above named squirrels have attempted to taint government with their false reports.

They have deliberately held policy up to scorn and altered such policies to suit their own destructive end.

Some of these squirrels have offered false testimony to the IRS in order to protect their overts against mankind and their only road out of this universe.

Several of them have misrepresented Scientology practices to the FBI or Justice Department in a futile attempt to taint the minds of the government and the courts against the Church of Scientology.

They have supported psychiatric aims and principles over Scientology principles in their misrepresentations to Department of Justice representatives as well as Boston lawyer Michael Flynn.

They have turned from ethical and moral Scientology principles by demanding no ethics be applied to them or by them.

Several of them have spoken out against Scientologists in good standing to the IRS in a hope that they might escape from their own destructive acts and shift attention from themselves and their crimes.

They have altered and assisted in the alteration of Tech in an attempt to seal off the bridge to those who have fallen prey to their destructive intentions.

Their continual harmful acts to themselves and their continued desire to drag others to the level of beasts and animals devoid of spiritual qualities places them in the psychiatric camp of those who manufacture madness for profit.

Therefore, be it known that these acts of spiritual destruction and cries for no ethics, no morals, and no policy, have separated them from the body of the ethical and practicing Scientologists of this planet.

-2-

Dedicated Scientologists need not support them until they have fully recanted and fully fulfilled all of the requirements of the Ethics and Justice PLs dealing with suppressives and suppressive acts.

This ED is written that those who are not informed as to the acts of those named above may now be so informed.

It is written so that those who are not Scientologists may be warned that these individuals do not represent the Church or the religion of Scientology in any capacity.

Their only terminal is the International Justice Chief.

CO OSA INT2

Authorized by
AVC INT

for the
CHURCH OF SCIENTOLOGY
INTERNATIONAL
CSI:AVCI:COOSAI:ts
(c) 1984 CSI
All Right Reserved3

Notes

  1. This document in PDF format.
  2. Probably Mike Sutter.
  3. See also:  Armstrong Comments on OSA ED INT 19 SQUIRRELS