I, ROBERT VAUGHN YOUNG, declare as follows:1
PURPOSE OF THIS DECLARATION
1. I have been retained as a consulting expert by counsel for defendants Dr. Uwe Geertz in the CHURCH OF SCIENTOLOGY INTERNATIONAL VS STEVEN FISHMAN, ET AL. litigation. I make this declaration in support of Dr. Geertz’s several motions for summary judgment and in particular in response to the Declaration of Lynn Farny on issues relating to Fair Game and the Church of Scientology’s deeply imbedded adherence to the doctrine that persons such as Dr. Geertz who have been labeled “Suppressive Persons” or enemies of Scientology should and must be harassed through any means possible, particularly the judicial system, to punish them for having criticized Scientology. I will summarize the basis for the information in this Declaration. Then I will address the issues pertinent to the pending motions. Finally, I will set forth my involvement with Scientology, with is the basis for the information contained in this Declaration in detail.
50. Mr. Farny is asking the Court to believe that because there were writings prohibiting actions such as Fair Game, it is not being conducted. However, that argument was made in December 27, 1979, when “The Controller Committee” issued Guardian Order 3031 called “Scientology And The Law” under Hubbard’s name (ATTACHMENT U) in which they stressed compliance with the law. (It should also be noted this urging of compliance with the law was released only after Mary Sue Hubbard and the others signed the Stipulation of Evidence.) The issue contains many of the same platitudes that Mr. Farny quotes in his declaration. Regardless of the platitudes issued in 1979, about a year later, the hypocrisy came out when the Government revealed that the defendants confessed that Fair Game had continued up through mid-1980 and may have continued past that point.
51. In fact, Fair Game did continue. Although the Guardian’s Office was “disbanded,” a new campaign was undertaken against Gerald Armstrong in 1981, a staff member who had fled with some of Hubbard’s files. Contrary to what Mr. Farny said, there were Fair Game actions taken against Armstrong after the GO was “disbanded.” I know because I sat in on those strategy meetings and was ordered by Hubbard as well as David Miscavige to “get Armstrong.” For example, Hubbard ordered a “reward” poster that would characterize Armstrong as a criminal. (I did not comply with the order, for which I was severely berated by Miscavige.)
52. The use of Fair Game on Armstrong was confirmed in 1984 when California Superior Court Judge Paul Breckenridge, Jr., ruled against Scientology with an opinion that included a statement about the civil rights of members and Hubbard:
“In addition to violating and abusing its own members civil rights, the organization over the years with its ‘Fair Game’ doctrine has harassed and abused those persons not in the Church whom it perceives as enemies. The organization clearly is schizophrenic and paranoid, and this bizarre combination seems to be a reflection of its founder LRH. The evidence portrays a man who has been virtually a pathological liar when it comes to his history, background, and achievements. The writings and documents in evidence additionally reflect his egoism, greed, avarice, lust for power, and vindictiveness and aggressiveness against persons perceived by him to be disloyal or hostile.” (ATTACHMENT N) 21