VICKI J. AZNARAN VOLUME 9 5-9-89
IN THE UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
VICKI J. AZNARAN AND RICHARD N. AZNARAN
CHURCH OF SCIENTOLOGY OF CALIFORNIA, INC.; CHURCH OF SPIRITUAL TECHNOLOGY, INC.; SCIENTOLOGY MISSIONS INTERNATIONAL, INC.; RELIGIOUS TECHNOLOGY CENTER, INC.; AUTHOR SERVICES, INC.; CHURCH OF SCIENTOLOGY INTERNATIONAL, INC.; CHURCH OF SCIENTOLOGY OF LOS ANGELES, INC.; MISSION OFFICE WORLDWIDE; AUTHOR FAMILY TRUST; THE ESTATE OF L. RON HUBBARD; DAVID MISCAVIGE; AND NORMAN STARKEY1
NO. CV 88-1786-WDK
ORAL DEPOSITION OF VICKI J. AZNARAN
On the 9th day of May 1989, at 10:00 a.m. the oral deposition of the above-named witness was taken at the instance of the defendants before Roger W. Miller, Certified Shorthand Reporter in and for the State of Texas, at the offices of Stanley, Harris, Rice, 3100 McKinnon, Suite 1000, in the City of Dallas, County of Dallas, State of Texas, pursuant the agreement hereinafter set forth.
VICKI J. AZNARAN VOLUME 9 5-9-89
A. What money was spent or how much money was spent, which I believe was 250,000.
Q. Anything else you remember telling the FBI about that incident?
A. I told them that it was Dick Story and Dick Bass were largely the players involved.
Q. Any other details you recall telling the FBI about that?
A. No, not offhand, I don’t recall anything else.
Q. Are there any other instances involving judges that you discussed with the FBI?
A. They wanted to know about Scientology executives going to see Marianna Pfaelzer one night.
Q. Anything else? That’s what you already talked about with Mr. Cooley, is it not?
A. Yeah. I think we went into that.
Q. Any other judges?
A. Yeah. Breckenridge and the Judge on the — the original Judge on the Wollersheim case. I don’t know if “original” is the right word, but he was a judge on the case during, I believe, pretrial.
Q. What did you tell the FBI about Judge Breckenridge?
A. I told him about destroying documents that
VICKI J. AZNARAN VOLUME 9 5-9-89
Judge Breckenridge had ordered produced.
Q. What did you tell him about destroying those documents?
A. What did I tell him? I don’t remember specifically. That there were documents that he ordered his folders produced, and myself and some others went through those folders and took out and destroyed documents out of them that we did not want turned over.
Q. When you say he wanted his folders produced, who is that, judge Breckenridge?
A. Yeah. He ordered them turned over to him.
Q. His own folders?
A. Armstrong’s, Jerry Armstrong’s.
Q. And what did you tell the FBI about the first judge on the Wollersheim case?
Q. Do you recall any more —
A. I believe that’s what I told him, the drift of it, anyway.
Q. Do you recall telling him anything else about that incident?
A. Not specifically, no.
VICKI J. AZNARAN VOLUME 9 5-9-89
Q. Were you involved in that incident in any way?
A. Peripherally. No, not really. I was just there part of the time.
Q. It was not done at your instigation?
Q. You did not participate in anything involving the Judge Pfaelzer incident directly?
A. Staff members — well, no, not really.
Q. You personally, I’m not —
A. Yeah. No, not really.
Q. Now, your knowledge of the facts that you related to the FBI concerning Judge Breckenridge is firsthand, from what I understand you are saying?
A. The destruction of the documents?
Q. You participated in it?
Q. And you told that to the FBI?
A. Yes: .
Q. And what is the source of your information concerning the first Judge on the Wollersheim case?
A. I believe David Miscavige.
Q. He told you about it?
VICKI J. AZNARAN VOLUME 9 5-9-89
STATE OF TEXAS
COUNTY OF DALLAS
This is to certify that I, Roger W. Miller, Certified Shorthand Reporter in and for the State of Texas, reported in shorthand the proceedings conducted at the time and place set forth in the caption hereof and that the above and foregoing pages contain a full, true, and correct transcript of said proceedings.
Given under my hand and seal of office on this the 9th day of May, 1989.
[signed Roger W. Miller]
Roger W. Miller, Certified
Shorthand Reporter No. 328
in and for the State of Texas
My commission expires December 31, 1989.
I, Richard N. Aznaran, hereby declare and state:1
1. I am over 18 years of age and a resident of the State of Texas. I have personal knowledge of the facts set forth herein and, if called as a witness, I could and would competently testify thereto.
A. The first point is that I do not believe these are the papers which we signed when we left the cult in 1987. We were forced to sign quite a few different papers before being allowed to leave. At the time, we had asked for copies of all of the papers we had signed but were not allowed to have copies of the releases.
B. One of the conditions of being allowed to leave without being declared “fair game”1 was that we report to Mark Rathbun
1When the cult declares a person a Suppressive Person he automatically becomes Fair Game. Per the cult’s founder and existing policy when a person is Fair Game he may be lied to, cheated, stolen from and destroyed with no protection from the cults ethics codes. If the person is considered a threat in the eyes of the cult, then scientologists and their agents are encouraged or even paid to do so. This has been documented on many occasions and I am personally familiar with it.
on a regular basis. We did do this for a while and repeatedly asked for copies of these releases. We were put off with various excuses on each occasion. We never did obtain a copy of the releases. It is clear to my now that this was so that the cult’s “dirty tricks unit” could change the releases to fit their claims and then supply them as “evidence” if and when they felt they needed them. They didn’t dare supply us with doctored copies which we did not sign as they knew that this alienate us and they didn’t want to supply us with actual copies as this would preclude them from making changes later.
3. At the time that these releases were signed both my wife and myself had been receiving intensive “security checking”. This “security checking” was conducted by Ray Mithoff. Ray Mithoff was at that time (and still is to the best of my knowledge) the highest trained and most senior security checker in all of scientology. He is so senior in fact that normally all he ever does is oversee others doing it. There were two reasons why he was used. The first was obviously because of the intimidation factor he would have and the second is not so obvious.
A. Part of our security checking was so that we could be interrogated on how much we knew and so that the potential
threat of our leaving could be analyzed by David Miscavige. Miscavige trusts few people and lives in constant fear that his crimes will become public and land him in jail as it has the cult’s earlier leaders. Mithoff is the only security checker Miscavige was willing to trust. This was the second reason Mithoff was used. 2
B. In retrospect, it is easy to see that this security checking was done to soften us up and remind us of what powers the cult could bring to bear on us should we refuse to cooperate fully. Their tactics obviously worked because at the time, we were in terrible fear that we would not be allowed to leave.
4. We were not allowed to seek legal counsel at the time that we signed these releases. Two of the cults’ attorneys were brought out to further intimidate us. We were told that we could ask them questions if we had any. It was made clear that
2 Mithoff was normally used in such cases as he is trusted and considered a loyal minion by David Miscavige. David Miscavige is the senior most of the founders “messengers” and took control upon Hubbard’s demise. It was Mithoff under the alias of “George Jones” who personally oversaw Michael Meisner’s security checking after the cult had kidnapped him. Meisner was the cult’s agent who had infiltrated various government agencies and stolen documents under the direct control of Hubbard, Hubbard’s wife and the rest of the cult’s management. It was Meisner (having again escaped from the cult and sought protection from the Justice Department) whose evidence lead to the 1977 raids on the cults Los Angeles and D.C. offices by the FBI. I know of Mithoff’s involvement because he spoke to me personally about it displaying great pride in his activities.
we could definitely not seek other counsel.
5. It had been my understanding through earlier contacts with scientology’s dirty tricks unit known as the Guardian’s Office and later the Office of Special Affairs that these releases had no legal binding whatsoever. In my early years as a staff member I had seen the various policies issued by the Guardian’s Office concerning releases. Releases were to be signed by every public person and staff before and after every single service they received. The idea being that the person was to be convinced that he had no recourse for lousy service and false promises. Guardian’s Office personnel had told me repeatedly that they did not hold water and were merely a deterrent. This was later confirmed by cult attorney John Peterson.
6. To me the intention behind the releases themselves appeared unlawful. Although not trained in law, it was obvious to me that the intent included the obstruction of justice. Part of our security checking was to ensure that we had no plans to go to any government agencies to give them evidence of crimes being committed by cultists or their agents. It was stressed at the time of the signing of the releases that if we spoke to government agents about any “confidential information” we had concerning the cult that we would be in violation of our agreements and that we would be sued. Additionally we were to
withhold information and avoid testimony in any civil litigation where the truth may be harmful to the cult or aid someone else seeking justice. With the purpose of the releases including the withholding of information from lawful authorities I certainly did not feel that they could possibly be legal or binding.
7. The conditions surrounding the sale of our horse and the loan from the cult need to be made perfectly clear. Defense attorneys constantly try to twist this into some evidence of philanthropy on the cult’s part. This just isn’t the case at all.
A. David Miscavige came to visit us in our motel room a few days before we were allowed to leave. Miscavige asked us what our plans were. We told Miscavige that we didn’t have any specific plans but that since I knew some people in the area (southern California) I would probably work something out. Miscavige made it clear that he did not want us to stay in southern California but wanted us to go to Texas. He did not want us connecting up with any of our friends in southern California be they current or former scientologists. We told him that we had limited funds and would have to stay in California long enough to sell our horse and make a little money so that we could travel. Miscavige reiterated his objection to us staying in California and stated that we would have to work it out to go back to Texas.
B. The next day Mark Rathbun suggested that the cult buy the horse from us and that they loan us some money so that we could leave right away and go to Texas. Rathbun stated that this had been Miscavige’s idea.
C. This loan and purchase of the horse had nothing to do with the releases.
8. There had been a fire at one of the ranches I had worked at and all of the belongings of four people had been destroyed in the fire. I was one of them. A claim was being negotiated with the insurance company. Rather than have me wait for the insurance claim to settle I was given $1,040.90 which was the value of the goods destroyed in the fire. This is money which I understood was going to be later reimbursed by the insurance company.
9. I received the pay due to me according to their rules but this was just for the previous pay period. I never received any compensation or wages for many hundreds of hours of work I had performed and been forbidden to include on my time card during the previous thirteen months or so while I worked for the Norman Starkey, Trustee of the Estate of L. Ron Hubbard. This was not religious work and the estate was not a non-profit entity. I was supposed to be receiving minimum wage.
10. The cult purports that my wife Vicki had overall responsibility for RTC’s legal matters and litigation and such. This is only partly true. David Miscavige, the Chairman of the Board at Author’s Services, Inc.3 had final say over what did or did not occur and constantly issued streams of orders concerning everything from personnel transfers to finances. Miscavige either directly or indirectly oversaw all major decisions and even minor ones if it were his whim.
11. While it is true that Vicki (and even myself on occasion) did assign others to the Rehabilitation Project Force, it is not mentioned that there is a basic tenet in scientology’s ethics policies which state that if you fail to assign someone to the RPF and your boss feels you should have then you can be assigned to the RPF with them. In other words it is enforced from the top down. Miscavige as the senior person often assigned people for no other reason that whim. I saw him do this to others and he threatened me on several occasions. He considered such activities his “management style”.
3Author Services, Inc (ASI) was a corporation set up by Miscavige, Starkey and Lyman Spurlock. It’s purpose was to manage Hubbard’s money and oversee the cults’s finances and ensure that Hubbard was getting his “cut”. I was briefed on this by Miscavige himself when ASI was first being set up.
12. It is stated that after Vicki escaped from the desert camp where she was being held that she was able to travel freely on her own. This is not true. We were under constant surveillance by the cults’ security personnel and all of our belongings were being held to ensure our cooperation. We feigned cooperation to prevent being declared suppressive persons and opening ourselves up to “fair game”.
13. It is stated that the cult paid three hundred dollars more for our horse than I had paid for it. This is false and in fact they paid three hundred dollars less than I had paid for it.
14. While I am not a psychologist nor am I a psychiatrist, it is clear to me now that both Vicki and I had previously been brainwashed by the scientology cult. This process began in 1972, continued through 1973 when we were forced to give all of our worldly possessions to the cult leaders and has only recently ended since we were able to escape their influence. At the time we left in 1987 we were heavily under their influence and even to this day my wife has nightmares where she is still being held captive by the cult.
A. It was only once we started to become “unbrainwashed” that we began to realize the extent of suffering, misery, fear and intimidation that we were put through.
15. Claims are being made to the effect that due to the cult’s philanthropic efforts on our behalf we left as happy little cultists. Nothing could be farther from the truth. At the time of my wife’s escape from Happy Valley I was called in by Miscavige and Mithoff and interrogated until four o’clock in the morning in an attempt to get me to break up with her. When this failed I was called upon to try to get her back. I pretended to do this and even went so far as to encourage Jesse Prince and David Bush (the two men who escaped with Vicki) to go back. But during this whole time we planned to go along with whatever the cultists wanted in order to be allowed to leave without being declared “fair game”. We lived in constant apprehension and fear, not daring to believe that we could pull it off but praying against hope that we could. By the time we had successfully made it through our security interrogations we would have signed anything to be allowed to leave.
16. Scientology purports itself to be a religion. In the early 1970’s when I first became involved with scientology, the cultists were quite open about the fact that they called themselves a religion only for tax purposes. It was only later, in the mid 70’s that the Guardians Office forced the “churches” and franchises to conform to “religious image programs”. These programs covered everything from hanging up crosses to having staff “ordained” and having get togethers on Sundays and calling
them Sunday services. It would never stay in though because it was obviously bogus. Finally the threats became great enough to force it in. Hubbard himself, in earlier unedited versions of his taped lecture called “The Road to Truth” stated that there was no god but not to let the “wogs” (non-scientologists) know or they would never join. When scientology was being set up in Mexico it was decided not to make the claims of being a religion due to the fact that it would effect their ability to make money. The same thing goes for a couple of other countries. When the decision was whether to be a religion or make money, make money won out. I know of all of these points from my own personal experience.
17. I have been informed by my former attorney that although we have made discovery requests, Defendants have failed and refused to comply with even the simplest requests. During this time they have barraged us with burdensome and costly demands exceeding all reason. Additional evidence is currently in the hands of Defendants but withheld from Plaintiffs. This evidence is favorable to Plaintiffs’ opposition to Defendants Motion for Summary Judgement.
I declare under the penalties of perjury under the laws of the United States of America that the foregoing is true and correct.
Executed this 15th day of January 1989, at Dallas, TX.
Richard N. Aznaran
I, Vicki Aznaran, declare:1
1. I was involved with the Church of Scientology (“Scientology”) for approximately 15 years. I submit this Declaration on personal knowledge of the facts contained herein and if called upon as a witness I could and would competently testify thereto.
2. I was one of the highest ranking members of Scientology and was involved in upper management. From 1978 through 1987 I was a member of an organization known as the Sea Organization (“Sea Org”), an elite organization within Scientology. The Sea Org has considerable influence and control over other Scientology organizations; it sends its officers to individual organizations with unlimited power to handle ethics, tech and administration. In this regard, a Sea Org member may order a non-Sea Org member on virtually any subject, and the non-Sea Org member must obey. For example, sea Org “missions” are frequently sent to non-Sea Org organizations when those organizations are not sending enough money or public to the Sea Org organizations. These Sea Org members on “mission” can take any action they deem necessary in that non-Sea Org organization to accomplish their ends. They can control the funds of that organization and its personnel. They can remove personnel and post personnel. They can transfer funds to the Sea Org organizations or spend funds as they see fit.
3. Generally, Sea Org members hold the management posts in other organizations within Scientology. In order to be employed at a middle management level or above, one must be in the Sea
Organization. In order to be employed at the organizations that make the most money (known as the Sea Org Organizations), such as the Flag Service Org in Clearwater, the Advanced organization of Los Angeles, the Advanced Organization of the U.K., the Advanced Organization of Denmark and the Advanced Organization in Australia, one must be a Sea Org member. Additionally, in order to be employed in the organizations that control the Scientology network, such as the Religious Technology Center, one must be a Sea Org member. From 1984 through early 1987 I was president of Religious Technology Center (“RTC”). By contrast, Scientology management often designates for publicity and other reasons various officers of Scientology organizations who are figure-head officers only and possess little, if any, actual power over the organization they purportedly serve. For example, Hebert Jentzsch was at one time named the titular head of the Church of Scientology International. However, during one of Mr. Jentzsch’s depositions he was unable to answer fundamental questions concerning the management of the Church of Scientology International (“CSI”) and could not name the directors of CSI nor the other officers. During the time I was in the Religious Technology Center, from 1982 until 1987, Mr. Jentzsch had nothing to do with the running of CSI. Mr. Jentzsch was a figure head and public relations man. It was never intended that he would be involved in the administration of CSI whatsoever. There is an order from Hubbard which states that the officers of corporations should be just figure heads; the directors have more power, and then you have trustees who are over the very top corporations who can remove directors. These trustees hold the power as regards
Scientology’s money, assets, personnel, etc. The top trustees of Scientology when I was a director of RTC were David Miscavige, Lyman Spurlock and Norman Starkey. Patrick Broeker and Ann Broeker were also senior trustees over Scientology in 1982 and for some time thereafter. Miscavige convinced the Broekers to turn over their trusteeships to him in order to avoid the IRS criminal investigation that was ongoing. This left Miscavige, Spurlock and Starkey as the trustees that could control Scientology.
4. Lyman Spurlock and Norman Starkey also are both high-ranking Scientologists. At times, both within and outside my capacity as president of RTC, I have taken direct orders from Mr. Spurlock and from Mr. Starkey.
5. Both Mr. Spurlock and Mr. Starkey are members of the Sea Org. In addition, both these men hold other posts within Scientology. For example, Mr. Starkey was president of Author Services, Inc. (“ASI”), executor of the Estate of L. Ron Hubbard and Trustee of the Author’s Family Trust-B. Mr. Spurlock at various times was the Investment Officer International for the Church of Scientology, an executive of ASI, and president of Church of Spiritual Technology (“CST”). Both men have served together as officers of Galaxy Productions, Inc.
6. Mr. Spurlock controlled virtually all tax matters for the Religious Technology Center, CSI, ASI, CSC and CST. During the time I was an officer and director of RTC, I was asked to sign letters for RTC which had been drafted by Mr. Spurlock or at his request. Mr. Spurlock dealt with the tax attorneys who represented RTC. Sometimes I would be informed of actions he had taken regarding RTC tax matters after the fact, and sometimes
was never informed. Mr. Spurlock met with the Internal Revenue Service on more than one occasion to negotiate matters for RTC. He did this entirely on his own and made his own decisions regarding RTC’s tax matters and tax exempt status. Mr. Spurlock and Mr. Starkey frequently issues orders to me concerning litigation and tax matters concerning RTC, CSI, CSC and other Scientology entities. Mr. Spurlock also set up the current corporate structure of Scientology. This includes the set up of RTC, CSI and CST. Mr. Spurlock set up these structures and, along with Miscavige and Starkey, chose the directors, trustees and officers.
7. Mr. Starkey gave orders concerning litigation matters for Scientology. In 1982 Norman Starkey and David Miscavige ordered me to get Dick Story of the Guardians Office World Wide to hire a private investigator named Dick Bast to compromise Judge Krentzman, who was the judge on a case against Scientology in Florida. Judge Krentzman had been giving Scientology unfavorable rulings in the case. From 1981 up until the time I left, Starkey, Spurlock and Miscavige closely supervised all litigation brought either for or against the various Scientology corporations. The settlement initiated by Scientology for all of the cases that Michael Flynn had brought against them was ordered by Miscavige, Starkey and Spurlock with no consultation with the various corporations who were sued, such as Church of Scientology of California. In fact, this settlement was considered top secret and the officers and directors of the various corporations who were supposedly settling with Mr. Flynn did not even know the specifics of the settlement. The various officers of the
Scientology corporations know that they do not, in fact, make decisions about their respective corporations. They are told and understand that they sign what they are told to and that this is done in order to comply with the suppressive government requirements and avoid having to pay taxes to the suppressive IRS. In 1982 Mr. Spurlock ordered the then-head of international management, John Nelson, to buy into a gold mine in Canada using several million dollars worth of church funds. Mr. Nelson disagreed and said that he thought it was a bad investment. Mr Spurlock made the transaction anyway, as he controlled Scientology’s funds. Mr. Spurlock’s position at the time was Deputy Executive Director for Client Affairs at Author Services Inc., a for-profit organization which had been represented to the IRS as having no control whatsoever over tax exempt church funds. Mr. Spurlock’s gold mine venture lost a considerable sum of money for Scientology. Mr. Spurlock also ordered Scientology management, specifically Marc Yager and Wendell Reynolds, to buy into oil wells in Oklahoma. Mr. Yager expressed to me that he had reservations about this venture, but complied anyway. This venture also lost quite a bit of money for Scientology. Additionally, Starkey and Miscavige bought into the oil venture (with their personal funds) in Oklahoma and were able to get much better deal for themselves due to putting Hubbard’s and Scientology money into the venture.
8. Additional facts indicative of the management authority possessed and used by both Mr. Spurlock and Mr. Starkey over the entities involved in the Scott/Wollersheim consolidated lawsuits (i.e., Church of Scientology International (“CSI”), Church of
Scientology of California (“CSC”), Religious Technology Center (“RTC”) and Church of Spiritual Technology (“CST”) include the following:
A. Mr. Spurlock ordered that the original Scott suit be brought. He was involved in all of the major strategy meetings with attorneys concerning both the Scott and Wollersheim cases and, in fact, began planning the suit against David Mayo in 1982, shortly after Mayo opened his Church.
B. Mr. Starkey was also involved in all major meetings with attorneys concerning the Scott/Wollersheim cases. He made active decisions and ordered the attorneys as to actions they were or were not allowed to take in regards to these facts. In fact, Mr. Starkey and Mr. Spurlock accompanied an attorney for Scientology, Mr. Earle Cooley, one night on what was described by them as an attempt to visit the residence of Judge Mariana Pfaelzer Scientology after she had ruled against Scientology at a hearing. He went with Mr. Cooley in order to express their views to Judge Pfaelzer and persuade her to rule favorably for Scientology. Mr. Starkey and Mr. Spurlock stayed up all night that night working on drafting papers for the Scott/Wollersheim cases.
9. One of the reasons why Scientology elects to manage its far-flung enterprises in this manner is to try to sheild its management from legal process. Front men are designated to hold figure-head posts, while the real management power is held by others outside the corporate structure. To this end, Scientology will go to extreme lengths to conceal upper management personnel
from service of process, subpoenas and depositions. When alive L. Ron Hubbard was protected in this manner. In addition personnel have been driven around the city in covered vans to protect their identities and whereabouts. Moreover, when deemed necessary, personnel are sent out of this country in order to avoid legal process.
For example, in 1984 when the IRS was conducting criminal investigation against various Scientology entities, the personnel who had knowledge of criminal behavior as regards Scientology funds were hidden or sent away. Fran Harris, who was involved with Bridge Publications and Church and L. Ron Hubbard’s funds, was sent to Denmark for a year. Mark Ingber, WDC member for Finance, was also sent to Denmark for a year. Wendel Reynolds, who had similar knowledge, was put away on the RPF in Happy Valley. Miscavige, Starkey and Spurlock took great precautions with their travels, offices and residences so that they could not be found or served. Miscavige has been known to actually rent clandestine quarters away from any Scientology facility, paid for with Scientology funds, simply so that he could hide out from process servers.
10. Both Mr. Spurlock and Mr. Starkey have been afforded this “protection” by Scientology. It is doubtful that either will be deposed if personal service of a subpoena upon them is deemed necessary prerequisite. Scientology will take all measure necessary to keep these men cloistered from view and immunize from service.
11. On the other hand, it is clear that when Scientology wants help from Mr. Spurlock and Mr. Starkey both men stand ready
to assist. Accordingly, whenever declarations are needed by Scientology in any of their lawsuits or other legal proceedings Scientology has no difficulty in obtaining the assistance of both Mr. Starkey and Mr. Spurlock. In this regard, Miscavige took off for over two months and lived in Portland, Oregon in order to oversee and direct the attorneys for Scientology on a daily basis during the entire trial in the case of Julie Christofferson Titchbourne, which she had brought against Scientology. Mr. Spurlock also spent most of his days in Portland during the trial. During the Wollersheim trial, Miscavige, Starkey and Spurlock supervised the attorneys representing CSC on a daily basis throughout the nearly three-month trial in Los Angeles. Miscavige, Starkey and Spurlock stay briefed on a daily basis on all legal matters of any consequence involving any Scientology entity. All papers filed by the Scientology entities involved in the consolidated Scott/Wollersheim cases had to be sent via Spurlock and Miscavige for authorization before they could be filed.
12. In addition, without revealing any privileged communications, I am able to state that both Mr. Spurlock and Mr. Starkey have been involved directly in the management of CSI, CSC, RTC and CST, and have participated in meetings in which decisions affecting these consolidated Scott/Wollersheim cases have been made. We have worked together in the past and I know that no major decision affecting these entities or these cases are made without their knowledge, participation and/or consent. Based upon all the information personally available to me, I am of the
opinion that both Mr. Starkey and Mr. Spurlock are managing agents of CSI, CSC, RTC and CST.
13 . I have reason to believe that documents which would normally reflect traditional criteria of the managing agent relationship between Scientology and Messrs. Spurlock and Starkey have been either destroyed or concealed by Scientology. For example, at Mr. Starkey’s direction, I destroyed such information as it related to the involvement and control over Scientology by L. Ron Hubbard, Mr. Starkey and Mr. David Miscavige.
I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct.
Executed this 27th day of October 1988, in Dallas, Texas.
Vicki J. Aznaran
I, Vicki J. Aznaran declare as follows:1
1. I am one of the plaintiffs in the within action.
2. I was a member of the Scientology Cult from November of 1973 until April, 1987.
3. From 1975 until April 1987, I was a staff member of various organizations controlled by the Scientology Cult. Among those staff positions was the presidency of Religious Technology Center, a California corporation. In my capacity as president, I became familiar with the interlocking corporate structures of the various organizations controlled by the Scientology cult.
4. I also became familiar with the policy known as “fair game.” “Fair game” is a policy whereby those who are declared to be “suppressive” persons are subject to any form of intimidation, harassment, or oppression by any Scientologist.
5. I have seen a policy letter written by L. Ron Hubbard, the founder of Scientology, which ordered that the words “fair game” no longer be used because of negative public relations implications, but the policy letter continues to indicate that “suppressive” persons are to be treated in the same way as previously. I have witnessed the application of “fair game” over the years of my membership in the cult and in positions of responsibility within the Scientology Cult, and I know that it was still applied to “enemies” of the cult even after its public disavowal.
6. Even after leaving the Scientology Cult in April of 1987, my husband Richard and I tried very hard to avoid becoming
“fair game.” We were told that we had to maintain contact with the Scientology organizations and that Mark Rathbun would be contacting us regularly. Mr. Rathbun did contact us on a regular basis and we contacted him according to his instructions.
7. Even as late as November or December of 1987, my husband and I were contacted by Mr. Rathbun and told not to talk to reporters from the Los Angeles Times. Mr. Rathbun made it clear that we would be declared “suppressives” if we did not continue to cooperate.
8. It was not until early 1988, that I became determined to resist the efforts of the Scientology Cult to have me lie about matters which had occurred during my tenure as a member of the staff of Religious Technology Center.
9. In February 1987, I was working for the Scientology Cult at Gilman Hot Springs. In the latter part of that month, I was forced to go to the Rehabilitation Project Force at “Happy Valley.” I was rousted out of bed early in the morning after having worked late into the night before, and I was ordered to go to my office. David Miscavige was there along with Norman Starkey, Greg Wilhere, Ray Mithoff, and several other uniformed men. Mr. Miscavige ordered me to write an order assigning myself to the Rehabilitation Project Force. Mr. Miscavige told me that if I didn’t he would write it and would fill it full of libelous statements about me. He said that because of his high position within the cult, his statements would be believed, and my standing and reputation within Scientology would be destroyed.
10. I was kept up all day and late into the night, being interrogated by one person after another. Because of the
presence of several persons, I felt that any attempt to escape would be futile. I was watched at all times during the interrogation. There is an eight-foot fence topped by barbed wire surrounding the compound where I was being held, with guards posted at the gates.
11. After my interrogation, I was taken into a car with three other people who were to guard me, and I was transported to “Happy Valley.” “Happy Valley” is a piece of property owned by Scientology. It is about 10 miles from the Gilman Hot Springs Cult Headquarters. It is located just past the Soboba Indian Reservation about three miles down a dirt road into the rocky foothills. It is rocky semi-desert country and is very isolated. I felt that any attempt to escape from “Happy Valley” would be futile.
12. During my stay at the Rehabilitation Project Force at “Happy Valley,” I slept in a tin shed which had no air conditioning or heating. The shed had a bare wood floor and it was terribly cold at night and miserably hot during the day. The first night that I was there, I was forced to sleep on the floor, as there was no bunk for me. It was a small room with 12 to 14 women who slept in it.
13. During my stay at the Rehabilitation Project Force, I was required to do hard physical labor from 6:30 a.m. until 5:30 p.m. The meals consisted of either beans and rice or leftovers from the food served to other staff working at the Rehabilitation Project Force. I was not allowed to walk, but rather required to run everywhere I went in the compound.
14. I was guarded the whole time I was in the
Rehabilitation Project Force. I was not allowed to go to the restroom alone. I was not allowed to shower alone. At night I was locked in a room that had heavy bunk beds with people sleeping in them and which were pulled in front of the doors. I repeatedly requested to be able to contact my husband by phone and letter, and this was denied. During March, 1987 I asked David Miscavige that I be put in touch with my husband. Mr. Miscavige tried to make me believe that my husband did not want to communicate with me and had “written me off.” As a result of these statements, I felt isolated from my husband and a sense of despair about ever seeing him again or continuing with our relationship.
15. On March 31, 1987 two of the men in the Rehabilitation Project Force whom I knew, Jesse Prince and David Bush, escaped from the Rehabilitation Project Force. They ran out of the front gate and were pursued down the road toward the Indian reservation by guards and two others. I was later told that two men in a pickup truck drove by and slowed down. They asked Mr. Prince and Mr. Bush if they would like a ride. They climbed in the back. They were transported in the pickup truck into town to a rental car place where Mr. Prince rented a car. They then drove back to Happy Valley to get me.
16. At that time I was lying under a tree on a hill, as I was sick with a fever and had been told that I could not see a doctor until Mr. Miscavige gave his permission. I had been sick for a week. The tin building where we slept was too hot during the day to sleep in and that was why I was sent to lie down under a tree.
17. Mr. Prince and Mr. Bush opened the front gate and
drove up close to where I was under the tree. Another person at the Rehabilitation Project Force named Chris Byrnes was with me to keep me from going with them. There were at least four security guards equipped with radios and motorcycles, attempting to maneuver into a position where they could prevent us from leaving the compound. As I got up to leave, Mr. Byrnes grabbed my arm in an attempt to keep me from leaving. I pulled loose and ran to the car and got in the back seat. We then drove out the front gate, which Mr. Prince had left open when he drove into the compound.
18. When I left “Happy Valley,” I did not know where my husband was located. When one spouse leaves Scientology, it is the practice to get the other spouse to divorce them. I knew that Mr. Miscavige had been telling me that my husband “probably didn’t care about me or want to hear from me.” I knew that Mr. Miscavige would try to get Richard to leave me and would tell Richard that I was insane and that Richard needed to divorce me. Richard had been working in various Scientology locations since December, 1985. Sometimes I would know what locations he was in and sometimes I would not.
19. After leaving “Happy Valley,” Mr. Bush, Mr. Prince, and I drove around for a half hour or so and then had dinner in San Jacinto. The three of us were all concerned about our spouses, as we knew they would be told that we had “turned, and that they should make us come back or “disconnect” (a Scientology term which means to sever all relationships with a person). After we ate, Mr. Prince took me to a store to buy some clothing, as all I had was the worn out and ragged clothes that I was wearing.
20. I then got a motel room in Hemet, California. Mr.
Bush and Mr. Prince got a room in another motel down the street. Mr. Prince informed me that he was going to call Mr. Miscavige to demand that his and Mr. Bush’s wife be brought to them. I told Mr. Prince not to tell them where I was and to tell them that I would not discuss anything until I heard from my husband and that Mr. Miscavige was to let Mr. Prince know how and when I could talk to him.
21. Mr. Prince returned in a few hours relating that he had called the Scientologists and they had brought his and Mr. Bush’s wife out to see them. He told me that their wives told them they would divorce Mr. Prince and Mr. Bush if they did not return to the Rehabilitation Project Force. He said the wives then returned to Gilman Hot Springs and left Mr. Prince and Mr. Bush at the motel.
22. Mr. Prince told me the Scientologists had told him they would have my husband get in touch with me right away if I would come to the motel where Mr. Prince and Mr. Bush were staying. I moved to that motel to a room which they had reserved for me. I slept there that night and waited for my husband to arrive.
23. My husband did not arrive. So the next morning I called the two ranches where I thought he might be (San Luis Obispo and Newberry Springs). Both places informed me that Richard was not there and they did not know where he was.
24. Shortly after making that call, I looked out the window of the motel room and saw persons whom I recognized as Scientology security guards wearing civilian clothes. They were posted at various spots around the motel. Seeing this, I felt
that it was impossible for me to escape. Besides, I did not want to leave until I had made contact with my husband.
25. A little before noon on April 1, my husband arrived. He informed me that he had been up most of the night with Mr. Miscavige and others, telling him that I had gone insane and he should divorce me if he could not force me to return. We discussed our situation and agreed that we would cooperate with all their security checking and signing of documents so that we could get away without being declared fair game. From my experience as a staff member with the Scientology organizations, I knew that they would not let us leave until such time as we complied with their various requirements.
26. At this time, the Scientologists had all of our worldly possessions, including a pickup truck, a horse, and two dogs, as well as clothing and other personal effects.
27. On approximately April 2nd or 3rd, my husband took me to see Dr. Megan Shields (a doctor whom I knew to be associated with Scientology) in Los Angeles. Dr. Shields prescribed some antibiotics for my illness. We were followed by someone from Scientology when we traveled to Los Angeles and when we returned. At this time, Scientology still held our personal possessions, including the dogs and horse.
28. The process of “security checking” continued daily. It went on for several hours a day. During this time, we were submitted to intensive interrogation and required to be connected to the “E-Meter,” a device which purportedly measures a person’s truthfulness. The interrogation continued until April 8, 1987.
29. At the completion of the interrogation,
Mr. Miscavige came to the motel where we were being interrogated, along with Mr. Mithoff and Mr. Rathbun. Mr. Miscavige asked us regarding our plans and how much money we had. My husband told Mr. Miscavige that we had a couple of thousand dollars. Mr. Miscavige stated that he was concerned we might stay in California where we would be easily available to subpoenas in litigation in which Scientology was involved, or where we would be susceptible to contact by “enemies” of Scientology. Mr. Miscavige asked how much money it would take for us to move back to Texas and get started in some type of business. My husband stated he wasn’t sure since it had been 15 years since he had lived as a “normal” person, but he thought it would take about $5,000. He stated that we would manage somehow on the money we had (our main concern was getting away). Mr. Miscavige offered to loan us $20,000 if we would go back to Texas.
30. On April 9, 1987 Mr. Rathbun and Mr. Mithoff returned with a notary public and two attorneys, Mr. Larry Heller and Mr. John Peterson. We were required to sign a stack of documents. From my previous experience with Scientology, I knew they were all the usual “standard” waivers, as no one is allowed to leave the cult without signing them. Mr. Peterson and Mr. Heller informed us that we could “consult” with him if we wished to do so concerning the documents we were signing. I knew that these attorneys had represented Scientology organizations and that there was no way they would advise us regarding our best interests.
31. The last document to be signed was a loan agreement for $20,000. Once we signed that, we were given a check for
$20,000. We were then allowed to go downstairs to the parking lot where a security guard had transported our belongings. Mr. Miscavige had informed us the night before that since we had no money, he would have Scientology buy our horse for $1,500.00 so that we would be able to leave the state “right away” rather than wait around and try to sell the horse. We did not have the money to move the horse to Texas. At this point, we got our two dogs back and our belongings, and we left for Texas.
32. In 1981, when I was in the “U.S. Guardian’s Office” and had become familiar with the documents that had been seized by the F.B.I. from the Scientology Cult in 1977, I became aware that Scientology was capable of physical violence. I had heard stories of it before, but had no first-hand knowledge. Once I saw these documents (containing, among other things, evidence of operations done on Paulette Cooper, Gabe Cazares, and others), I knew that the end of “protecting Scientology” would justify any means.
33. In 1982, I witnessed David Miscavige (with a large male security guard staff member there to back him up) physically attack three people who were incarcerated at Gilman Hot Springs. Mr. Miscavige made them stand there while he hit them in the face.
Mr. Miscavige told me on more than one occasion how he had physically attacked a female who was a fellow “Commodore’s Messenger” in 1981. He said he beat her up and threw her off post. On another occasion, Mr. Miscavige called me out of his office. He had a revolver in his hand, and stated he was very angry with the “Golden Era Musicians,” as they had not handled some of the music on an album properly. He had a copy of the album cover in his hand. He spread open the album cover to show
the pictures of the musicians. He said he would like to be able to shoot the musicians, but could not. So instead he was going to put a bullet in their heads in the picture. He then proceeded to shoot the picture, of each of them in the head. On another occasion, Mr. Miscavige expressed fantasies about shooting Michael Flynn, an attorney who had claims against Scientology, with his rifle.
34. The first time Mr. Miscavige told me he was going to “blow my head off,” I had walked into his office by mistake. This was at Gilman Hot Springs, where I had just arrived to become part of the staff of Religious Technology Center. I was very shocked and did not know how to take it. The second time he told me he was going to blow my head off was when he thought I had sent up an unfavorable report on his wife and upset her. The last time he made such a statement was when he sent me to the rehabilitation Project Force. Even though he was not aiming the gun at my head when he said it, from the prior incidents that I had witnessed and the prior statements that he had made, I felt he was capable of, and indeed obsessed with, committing acts of physical violence against others.
35. In late 1981, L. Ron Hubbard sent down an order that was several pages long, setting forth how he wanted the corporate structure of Scientology re-arranged due to legal threats from criminal, civil, and IRS litigation. Prior to this time, the mother church and the corporation that held the majority of the Scientology assets was Church of Scientology of California (CSC). CSC also held the Guardian’s Office. CSC was at that time named in many civil lawsuits as the defendant. Hubbard’s strategy
was to reorganize this corporate set-up and create a new corporation to be the mother church. This corporation was created, and it was named Church of Scientology International. CSC was stripped of all assets and moved to a small office across the street from the Cedars of Lebanon complex. The majority of the cash was placed in overseas trusts in order to avoid the IRS. The people who controlled these trusts were Mr. Miscavige and Mr. Spurlock. The money was set up to flow from the various churches in the U.S. and elsewhere to these trusts. The theory for this, as I understood it from Mr. Spurlock, was that the money was being held in trust for Scientology parishioners. While I did not personally work on setting up the corporate structures or money flows, I was privy to the overall picture of the corporate reorganization of Scientology organizations in my capacity as President of Religious Technology Center and Guardian Office Missionaire.
36. In 1982, my husband Richard was sent to the Rehabilitation Project Force in Los Angeles. At that time I was working in Gilman Hot Springs. These are about 70 miles apart. During this period of time I had no time off and had to work every day, all day, and many times, all day and all night. Mr. Miscavige was my senior. He told me he did not want me going to see Richard, as he was supposed to be isolated. At that time there was another person at Gilman Hot Springs whose wife was in the Rehabilitation Project Force in Los Angeles. He was told not to see her either. He secretly went to see her one night and was caught. Because of this, he was stripped of his status as a “Commodores Messenger.” His wife was then assigned to an even
more intense level of rehabilitation until she agreed to divorce him, and he was then declared a “suppressive person.”
37. During this period I would drive to Los Angeles during the middle of the night once a week when Mr. Miscavige would be away from Gilman Hot Springs. I would return to Gilman Hot Springs in time to go to work the next morning so no one knew that I was leaving. I knew from seeing what had happened to the other person, that a similar fate awaited me if I was caught.
38. During the period from December, 1985 to April, 1987, I had only limited contact with my husband. In December, 1985 he was sent away. From that time through the middle of January, 1986 I had no contact whatsoever with him and did not know where he was.
39. For the period from mid-January, 1986 through April, 1987 I had occasional contact with my husband. Even during that time, the contact was not as frequent as we wanted. In addition to the lack of frequency, I was never sure of his location and had limited opportunities to have both physical contact with him and opportunities for intimate conversational exchanges where we could renew and sustain our relationship as husband and wife.
40. Even after we were physically reunited, on or about April 1, 1987, we were subjected to long periods of interrogation by members of the Scientology Cult. In the confined circumstances of this interrogation, I felt that we could not have the kind of closeness and intimacy that would give me the support and comfort that I needed and wanted from my husband.
41. During the period from October, 1981 to April, 1987
I worked for the cult in California. Although I may have traveled outside of California on occasion, California was my residence and the place to which I would return. During this period, I was a staff member of the Scientology Cult. I worked many hours a day, and far in excess of 40 hours per week. Although I did receive some services in exchange for my work, I was never paid a minimum wage for the work and overtime work that I performed for the cult while in California.
42. In late 1982 the “Team Member System” was created by L. Ron Hubbard in an effort to control staff of the Scientology Cult. This was a system whereby a staff member was given five laminated cards, and as the member committed various offenses, cards were arbitrarily taken away. These cards represented privileges like a place to sleep and food to eat and monetary pay. As these are taken away, a person could end up sleeping out on the ground with no food. This happened to several people while I was at Gilman Hot Springs. I personally did not end up sleeping on the ground as a result of this system.
43. If sworn as a witness, I could competently testify to the matters stated in this Declaration.
I declare under penalty of perjury that the foregoing is true and correct.
Executed this 23rd day of September, 1988 at Dallas, Texas.
VICKI J. AZNARAN
I, Vicki J. Aznaran, make the following declarations on personal knowledge except where the context indicates knowledge based upon information and belief.1
My husband Richard Aznaran and I are plaintiffs in the instant action wherein defendants (hereinafter referred to collectively as “Scientology”) have moved to strike our entire complaint and to prevent our attorneys from representing us.
2. As set forth in more detail below, my husband and I were involved with Scientology for approximately 15 years. For much of that time we were members of an organization known as the Sea Organization. This organization is an elite organization within Scientology. The Sea Organization has considerable influence and control over Scientology organizations. Generally, Sea Organization members hold the management posts within Scientology.
3. In 1978, after approximately four years as staff members, my husband and I joined the Sea Organization. From 1978 to early 1987, my husband and I worked most of our waking hours, with very few days off, at our various assignments within Scientology. I eventually became President of Religious Technology Center and, supposedly, the top “ecclesiastical” authority within Scientology. Richard was a high-level security officer. During this period my husband and I became intimately familiar with the structure and activities of various Scientology organizations. Among other things, I was briefed on and sometimes a participant in meetings involving litigation tactics and various
means used to attack and fight “enemies” of Scientology. In numerous instances I was in the chain of command or approval for such activities. The legal strategy of Scientology and the existence of numerous potential legal problems, some of which are set forth below, were known to me when I was a staff member in Scientology. Contrary to, what I understand to be claimed by defendants herein, Mr. Yanny did not reveal to me the legal strategies or secrets of Scientology. Nor did Mr. Yanny invent or open my eyes to the wrongs that I had suffered at the hands of Scientology.
4. I have become an “enemy” of Scientology. This has certain consequences that will influence what Scientology will do in this litigation. For example, it is important to understand that their value system allows dishonesty if done in the name of Scientology.
5. Enemies of Scientology are deemed to be “suppressive persons”(“SPs”). One becomes a “suppressive person” by doing a suppressive act, such as suing Scientology as a litigant or lawyer. In the jargon of Scientology, when one is “declared” this means that one has been declared a “suppressive person” and, therefore, may be, harassed, hurt, damaged or destroyed without regard to truth, honesty or legal rights. It is considered acceptable within Scientology to lie, cheat, steal and commit illegal acts in the name of dealing with a “suppressive person”.
6. This practice or policy is sometimes referred to as the policy of “fair game”. In the jargon of Scientology, a person who is “declared” is understood to be a suppressive person. This means that the person is “fair game”. The fair game policy was
issued in the 1960s. It was, never cancelled. A document was issued for public relations reasons that purportedly cancelled “fair game”; however, that document stated that it did not change the manner of handling persons declared “SP.” In reality, the purported cancellation of fair game is at most a matter of semantics. Enemies of Scientology are treated as “fair game.”
7. It is my understanding, and I have so testified in my deposition, that when my husband and I escaped from Scientology we were not immediately declared suppressive persons or subjected to the fair game policy. Among other things, we were compelled to do certain things and sign various documents to escape and avoid being subjected to fair game treatment. As we have now sued Scientology, we are “fair game”.
8. From 1984 through early 1987, I was President of Religious Technology Center (hereinafter “RTC”). As President of RTC and a Sea Organization member, I attended many meetings concerning the numerous legal actions involving Scientology organizations. During this time period, I had personal access to all legal documents having to do with RTC. I received a report every day on my computer that included a synopsis of each ongoing legal case involving Scientology. I received, or so I was told, copies of every major motion filed in cases involving Scientology. I was on the “approval lines” for legal documents dealing with RTC. During this time period, I had the option of attending legal meetings although some were mandatory. I attended many litigation meetings and became generally aware of Scientology’s dirty tricks and legal maneuvers. On specifics, I frequently deferred to in-house and outside counsel, however, at least in theory, I was
the head of RTC and had access to any business or litigation ” secrets” of Scientology.
9. As President of RTC, I was one of those responsible for retaining the services of Joseph Yanny as counsel for Scientology organizations. I supervised and worked with Mr. Yanny who served as coordinating attorney for RTC in 1985. I am not aware of any legal or corporate information concerning RTC that was available to Mr. Yanny but not available to me.
10. I am informed and believe that various Scientology organizations are contending that Mr. Yanny has somehow improperly educated me on the legal maneuvers, tactics and affairs of Scientology. Although such claims are consistent with litigation tactics of Scientology, which .are not constrained by considerations such as truth and reality, the proposition that I need Mr. Yanny to educate me on the internal affairs of Scientology is simply wrong. I was one of the highest ranking members of Scientology and was involved in upper management. Mr. Yanny was a lawyer hired by management, of which I was a part, to work for it. Further, it was the practice during the time period in question to screen the information given to outside counsel such as Mr Yanny.
11. It is the stated policy and practice of Scientology to use the legal system to abuse and harass its enemies. This crude, fundamental directive of Scientology is no secret. In any event, this information did not come to me from Mr. Yanny. The policy is to do anything and everything possible to harass the opposing litigant without regard to whether any particular motion or maneuver is appropriate or warranted by the facts or applicable law. That policy was followed in every legal case I was involved
with or learned about while a member of the Sea Organization. The management of Scientology consistently expressed and demonstrated a complete disdain for the court system viewing it as nothing more than a method to harass enemies. Some examples of this are set forth below.
12. During litigation between Gerald Armstrong and Scientology, which was before Judge Breckenridge of Superior Court for Los Angeles County, the court ordered the production of Armstrong’s pre-clear (“PC”) folders. These are files maintained by Scientology on those who submit to interrogation sessions in a process called auditing. During the course of that litigation I was ordered to go through Armstrong’s folders and destroy or conceal anything that might be damaging to Scientology or helpful to Armstrong’s case. As ordered, I went through the files and destroyed contents that might support Armstrong’s claims against Scientology. This practice is known within Scientology as “culling PC folders” and is a common litigation tactic employed by Scientology.
13. During other litigation in Los Angeles known to me as the Wollersheim case, I was told that the. judge had ordered the production of Wollersheim’s folders. As ordered, I “culled” these files. In other words, I removed contents that might have been damaging to Scientology or support Wollersheim’s claims against Scientology. For example, I removed evidence of events involving his family, the anguish this caused him, evidence of disconnection from family and evidence of fair game.
14. I was involved in numerous meetings concerning what is known to me as the Christofferson case in Portland, Oregon. This
case was tried twice. In the first case, a Scientology witness by the name of Martin Samuels was coached and drilled for hours on how to lie convincingly or avoid telling the truth. Before or during the second trial he admitted to this course of conduct. In this litigation, a Scientologist by the name of Joan Shriver produced responsive documents that may have been incriminating. This was a serious breach of policy for which she was punished. These documents were ordered produced on such short notice that apparently files were not thoroughly “culled”. In another case, Mr. Yanny was severely criticized and almost fired for failing to properly coach and feed the desired answers to Heber Jentzsch. Mr. Jentzsch was, for public relations reasons, the purported head of the Church of Scientology International. During his deposition, Mr. Jentzsch was unable to answer fundamental questions concerning the management of Church of Scientology International. This may be what certain defendants are referring to when they say that they were dissatisfied with Mr. Yanny’s services and I protected him. There were those, including McShane, who were outraged by the embarrassing testimony of Mr. Jentzsch. This was blamed on Mr. Yanny. I did not wish. to discontinue using Mr. Yanny at RTC for this perceived problem.
15. In November, 1985, I was present at a meeting whereat Earle Cooley, a Scientologist lawyer, Lyman Spurlock and Norman Starkey, all high ranking Scientologists, announced that they were going to contact Judge Mariana Pfaelzer. Earlier that day Judge Pfaelzer had denied a Scientology motion for a temporary restraining order. After losing on the application there was a meeting to determine what to do about the situation. At the
meeting Mr. Cooley had a file, that purportedly contained background and personal information on Judge Pfaelzer. During the meeting Mr. Cooley and the others announced that they were going to attempt to meet with Judge Pfaelzer that evening, at her house if necessary, concerning the litigation in which the temporary restraining order had been sought. Thereafter, Mr. Cooley and two others left with their file on Judge Pfaelzer. They returned several hours later at which time I was told that their attempts to contact Judge Pfaelzer had been unsuccessful.
16. In late 1979 and early 1980, there was a massive document destruction program undertaken to destroy any evidence showing that L. Ron Hubbard (“LRH”) controlled Scientology. I participated in this activity in Clearwater, Florida and am informed that there was also intensive document destruction at facilities in Gilman Hot Springs, California. From at least that point onward there was a continuous effort to hide or destroy any evidence of Hubbard’s control. For example, during an IRS investigation in 1984 and 1985, while in bed with pneumonia, I was ordered out of bed by Norman Starkey who told me that they had received a tip from a Los Angeles Police officer advising them of a pending IRS raid in Los Angeles. Mr. Starkey ordered me to go to a computer facility and insure that all information on the computers in Los Angeles that might show Hubbard’s involvement and control of Scientology’s money was destroyed except for one copy of each document. These copies were to be saved on computer discs which were to be hidden in secure storage places. At the time I was also instructed to destroy anything that would show the control of Mr. Starkey or Mr. Miscavige over Scientology.
17. I have been informed and believe that a an improper affidavit was filed in a case brought by L. Ron Hubbard, Jr. in Riverside, California. The circumstances were as follows: The document purported to be an affidavit of L. Ron Hubbard. The signature of Hubbard was purportedly notarized by David Miscavige. It is my understanding that this affidavit caused the case to be dismissed. Subsequently, I was told by Pat Broeker, who had been living with Hubbard at the time, and by Miscavige, that Miscavige had not seen Hubbard between 1980 and Hubbard’s death in 1986. Accordingly, the affidavit was apparently signed, notarized and dated during a time period when Hubbard was in seclusion and not seen by the person who purportedly notarized the signature of Hubbard.
18. In or about 1981, while working in a Scientology organization known as the Guardian’s Office, I had access to and observed various written and oral communications pertaining to illegitimate activities participated in by the Guardian’s Office.
The Guardian’s Office attempted to infiltrate both governmental and private agencies including the IRS, the Department of Justice, the American Medical Association and the National Institute of Mental Health. The purpose of this was to steal documents pursuant to Hubbard’s “Snow White” program. The goal of this program was to eliminate any negative reports about Hubbard and Scientology that may have been held by these various agencies.
19. While involved in Scientology I became aware of various operations directed against an author who had written a negative book about Scientology. The author, Paulette Cooper, was subjected to various forms of harassment. One operation included an
attempt to frame her. A false bomb threat was written. A Scientology agent lifted a fingerprint from Cooper’s apartment. These fingerprints were then transferred to the bomb threat letter. Ms. Cooper was subjected to an investigation and was not cleared until an FBI raid resulted in the seizure of Scientology documents that exposed the operation as a frame-up. There was at least one other operation directed against Ms. Cooper. The substance of it was to plant a boyfriend to reinforce and play upon her suicidal tendencies in the hopes that she would commit suicide.
20. In 1976 and 1977, the then Mayor of Clearwater, Florida, Gabe Cazares was involved with litigation against Scientology. Arrangements were made to have an attorney by the name of Merril [sp. Merrill] Vanniere [sp. Veneer?], a Scientologist, represent Mr. Cazares and sabotage his case. This plot was also exposed by documents obtained in an FBI raid of a .Scientology facility. Also, in response to Mr. Cazares’ litigation against Scientology, an attempt was made to implicate Mr. Cazares in a staged hit-and-run accident.
21. During the time period of my involvement with Scientology, I also learned of various. attempts to influence judges or force their removal from cases. For example, a private investigator named Dick Bast obtained a statement from a prostitute concerning involvement with a certain judge in Washington, D.C. who was sitting on a Scientology case. This was then publicized. The judge did not continue on the case. The same investigator, Dick Bast was also hired for the purpose of attempting to force the removal of a judge in Tampa, Florida. This involved what I know as the Burden case, which was civil
litigation brought by Michael Flynn. Dick Bast secured a yacht and attempted to get the judge on board for the purpose of filming him under compromising circumstances. The judge declined to go yachting and the operation was unsuccessful. Approximately $250,000.00 was spent on the operation.
22. I have been informed by Mark (Marty) Rathbun, a high ranking Scientologist, that his private investigator, Gene Ingram, “fed” a confession to Ala Tamimi when visiting him in an Italian prison. This false confession was, in substance, that Tamimi had been involved in a bad check scam involving an account of L. Ron Hubbard. This false confession implicated attorney Michael Flynn in the check scam. Michael Flynn was at the time considered a major enemy of Scientology because he represented numerous clients with claims against Scientology. This purported confession was used to slander and attack Michael Flynn. Michael Flynn has also been sued.by Scientology as part of its “strategy” for handling enemies.
23. During an IRS criminal investigation in the 1984 to 1985 time period, the IRS ordered production of various communications between Hubbard and Author Services, Inc. (ASI). The ASI staff worked literally day and night for several days reviewing documents so that unfavorable documents could be destroyed or otherwise concealed from the IRS. Lyman Spurlock and Marion M. Dendui, Scientologists involved in this operation, informed me of this operation. Also during this IRS investigation, my husband, Rick Aznaran, was ordered to remove and conceal any incriminating documents from certain locations. He was also directed to make the computer network “raid proof”. This involved creating a
system where incriminating documents could be deleted from computer storage rapidly and before the IRS could obtain control over the computers.
24. In 1985, I attended a conference on “squirrels” attended by Miscavige, Starkey, Spurlock, and McShane, members of top management, and others. In Scientology jargon, “squirrels” are people who use or practice some procedures also used by Scientology but who do not submit to the total control of the Scientology organization and, perhaps most importantly, who do not pay a percentage of their auditing or counseling fees to Scientology. At this meeting, David Miscavige ordered that public Scientologists be organized and motivated to physically attack squirrels and disrupt their operations. This was stated to be pursuant to the standard guidelines of Scientology. Pursuant to such directives, efforts were undertaken to intimidate and disrupt these persons and their organizations.
25. In 1981, operation “Juggernaut” was commenced. The purpose of this was to destroy Michael Flynn who, as stated above, was representing various plaintiffs with litigation against Scientology. This operation contemplated the use of infiltration, propaganda and attempts to persuade clients to turn against him.
26. The Guardians’ Office got into so much trouble, and worse yet got caught, that it was decided in the early 1980’s that the Guardians’ Office should be disbanded. This was purely a public relations gimmick. In short, it was decided that the Guardians’ Office and Mary Sue Hubbard, its then leader, were to take the rap for all criticism and improper conduct. This scheme was laid out in various written communications I observed in 1981
and 1982. (Of course, I was not allowed to keep or escape from Scientology with any such incriminating documents.)
27. Since the early 1970’s, Scientology has operated a forced labor camp known as the Rehabilitation Project Force (“RPF”). Staff members are incarcerated in the RPF for various real or imagined offense. People confined at this camp are forced to perform hard physical labor every day. They eat rice and beans, or left-overs, and wear rags. They are deprived of sufficient sleep. In 1987, I was confined in such a camp at Happy Valley for approximately six weeks. I worked all day and was confined in a room at night. To the best of my knowledge I was guarded 24 hours a day. They would not even let me shower alone. I had to obtain permission to use a bathroom. I was ill and not allowed to obtain medical treatment. I was not allowed to communicate with my husband nor was I allowed to obtain adequate sleep. I was told that I had gone insane and that my husband did not want to communicate with me. I was physically and psychologically abused both at Happy Valley and for numerous days thereafter in a process called “security checking”. Much oversimplified, I was grilled on a primitive lie detector called an E-Meter and made to understand that I would not be released, have my property returned, or escape fair game policy unless I eventually gave all of the “right” answers. Examples of ” right” answers were responses that I would not talk to a lawyer or consider suing Scientology. I had to give such answers before being released.
28. Recovering from the years of brainwashing, thought control and propaganda to which Scientology subjected me is a
gradual process that I do not fully understand. I am not a psychologist or psychiatrist and do not fully understand the ramifications of what I have been through although I can observe and experience many symptoms. I have many nightmares and a fear of Scientology.
29. The suit brought by Richard Aznaran and myself is based upon real events that happened to real people, namely us. Just as my husband and I do not need Mr. Yanny to educate us on any secrets of Scientology, it is simply untrue that our claims were somehow invented or manufactured by Mr. Yanny. The whimsical notion that Mr. Yanny invented this litigation through my husband and me is simply false.
30. My husband and I consider Mr. Yanny to be a friend. Further, it might be noted that Mr. Yanny was to serve as my personal counsel in a class action against Scientology and numerous individuals including myself. Recent events have changed this, however, .there was a period of time when Mr. Yanny was purportedly designated as my personal counsel with the approval of Scientology.
31. My husband and I feel quite strongly that we want Barry Van Sickle and the firm of Cummins & White to represent us in this case. Our reasons are both subjective and objective. We do not wish to list our subjective reasons, although we will do so if the Court requests it. Objectively, it might be noted that we had considerable difficulty finding counsel willing and in a position to undertake this extremely volatile, time consuming and expensive litigation. We are unable to pay hourly rates to pursue our claims and need a firm willing to work with us on a contingency
fee basis. I anticipate great difficulty, delay and prejudice if forced to find other counsel.
32. Based upon my experience within Scientology and as a litigant against it, I understand that this is not routine litigation. If I am forced to find other counsel, prospective counsel will be presented with the following situation:
(a) A complex case that must be handled on a contingency fee and cost-advanced basis;
(b) A case that requires a litigation team and substantial financial resources;
(c) A case involving an opponent who has a practice and history of suing opposing lawyers as a tactic in addition to subjecting opposing lawyers to surveillance, depositions, infiltration, bad publicity and the full ramifications of the fair game policy;
(d) A case where the opponent is not constrained by a need to be cost effective, truthful, honest or reasonable; and
(e) A case that requires extraordinary security precautions.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Executed this 9th day of August, 1988, in Dallas, Texas.
VICKI J. AZNARAN