Declaration of Vicki J. Aznaran (August 8, 1988)

Declaration of Vicki J. Aznaran ¹

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

[…]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.

[…]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 it 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 Vanniere, 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 East 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.)

[…]

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

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

Vicki J. Aznaran

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