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

Attorney for Plaintiff, LAWRENCE DOMINICK WOLLERSHEIM

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

LAWRENCE DOMINICK WOLLERSHEIM
Plaintiff,

vs.

CHURCH OF SCIENTOLOGY OF CALIFORNIA
Defendant

Case No.: C 332 027

DECLARATION OF JESSE PRINCE¹

I, Jesse Prince declare as follows:

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

MY PARTICIPATION IN SCIENTOLOGY

2. I am intimately familiar with the Scientology organization, movement and beliefs because I was in Scientology for 16 years (1976-92) and served in the highest ranks, including as the second in command of the Religious Technology Center (RTC). At that time, my position was “Deputy Inspector General, External” which meant being in charge of all activities outside the body of Scientology. This included being in charge of all litigation by or against any Scientology organization, intelligence (spying, covert operations) brought against perceived or imagined “enemies” (which ranged from critics to media to the courts), trademark registrations, and the licensing of trademarks to other Scientology organizations, which was how we tightly controlled all Scientology corporations while creating the false impression of “corporate integrity.”

3. From the time RTC was created in the early 80’s until the time I left RTC, RTC was the most senior, most powerful and most influential organization in all of Scientology. All RTC employees were Sea Org members.

4. In March 1983, I became the Deputy Inspector General, External, and a member of the Board of Directors RTC, as its Treasurer. (The only other board members were Warren McShane as Secretary and Vicki Aznaran as President, during this time.) At the time I was appointed a member of the Board of Directors of RTC I was forced to sign an undated letter of resignation. This is standard practice with all Scientology board members and is another means by which the Scientology corporations are controlled while giving the appearance of corporate integrity.

ACTIVITIES CONDUCTED UNDER THE GUISE OF RTC MANAGEMENT

5 . During my tenure with RTC, I have been privy to the destruction and alteration of documents to protect the group. For example, on or about April of 1983 I was present at a meeting, which took place in Los Angeles, California at a Scientology office called Author Services, Inc. (ASI). ASI presented itself as the “literary agency” for Scientology founder L. Ron Hubbard. In reality it was actually where the Scientology empire was being run from at that time. All of Scientology was being directed from ASI in 1983. ASI was where various Scientology corporations went to receive orders.

6 . Present at this particular meeting was David Miscavige, then acting under the title of chairman of the board of ASI, Vicki Aznaran then the Deputy Inspector General of Religious Technology Center, (RTC) and Lymon Spurlock, who was “Director of Client Affairs” for ASI. Mr. Miscavige expressed concern at this meeting that there might possibly be a raid on Scientology by the IRS. At that time, none of the churches of Scientology had received tax exempt status.

7 . One principle reason why tax exempt status had not been granted was the IRS’s position that Scientology founder L. Ron Hubbard (LRH) was actually the managing agent of Scientology in complete disregard of the corporate structure of Scientology. We knew this to be a fact but also knew that it violated IRS rules and thus had to be hidden.

8 . There was concern that the IRS would obtain the hundreds of daily, weekly and monthly LRH orders written by Mr. Hubbard and distributed throughout Scientology. These orders were commonly referred to in Scientology as “advices” to avoid the appearance that LRH was actually running Scientology. In fact, LRH was running Scientology. The principle concern expressed at this meeting was that the LRH orders or “advices” would be used to name L. Ron Hubbard as the managing agent of Scientology.

9 . Because of an already existing fear that an LRH “advice” might fall into the wrong hands, these orders from him were written in a way that we could deny it was from him. His name was not on them. He was never cited in the dispatch except in the third person. There was no signature and a salutation in reply was never more than “Dear Sir.” The routing at the top referred to him merely as “*,” an asterisk. However if a person (or an agency) got enough of these, there would be little doubt that we were in touch with Hubbard (via ASI) and he was telling us and each corporation what to do to make him more money.

10. David Miscavige specifically stated that ASI was “already dealing with the problem”, ridding ASI of any documents that would implicate L. Ron Hubbard as managing agent of Scientology. He stated that under his directive the LRH orders, or “advices”, were being collected and transferred by truck to a Riverside County recycling plant where the documents were to be “pulped”. This method of destruction was considered to be better than shredding. I was also given instructions that I was in charge of purging the remainder of the Scientology organization of LRH orders. This was to include Church of Scientology of California (CSC); Church of Scientology International (CSI); and, RTC.

DESTRUCTION OF WOLLERSHEIM DOCUMENTS

11. Several weeks after this first meeting, I attended second meeting at the ASI offices concerning the continuing destruction of Scientology corporate documentation. In attendance at the second meeting were David Miscavige, Lymon Spurlock, Vicki Aznaran, Norman Starkey of ASI and Marty Rathburn of ASI. At this meeting, David Miscavige for the first time, stated that Scientology had been ordered by a court to produce various documents concerning a former Scientology member named Lawrence Wollersheim who had a lawsuit pending in Los Angeles against the Church of Scientology of California. The court had ordered Scientology to produce Mr. Wollersheim’s entire ‘preclear” (PC) file.

12. A “PC” file is one of several files kept on members. The PC file is the file that includes all written records of all “confessionals” done by the member. This means that it includes not only the most self-damaging material, but it also reflects every problem the person might have had with the organization, including complaints. This PC file grows with the person’s tenure in Scientology.

13. Mr. Wollersheim’s PC file was several thousand pages in length and stood as high as a six-foot tall man. Initially at this meeting, it was decided that Mr. Wollersheim’s PC file would be redacted and culled of any evidence or documentation which might assist Mr. Wollersheim in his lawsuit against CSC. There was also concern that the materials known as Clear, OT I, OT II, OT III and NED for OTS (NOTS) would be open to public inspection if Mr.Wollersheim’s files were produced as ordered. Scientologists are taught that a person could catch pneumonia and die if that person is prematurely exposed to these ‘upper level” materials without first having taken many hours of preparatory auditing.

14. Ultimately, approximately 50 pages were produced pursuant to the court order. Mr. Wollersheim’s PC file was culled based on a direct order from David Miscavige.

15. Later, I was informed that a second court order was issued to produce Mr. Wollersheim’s entire file. Faced with the prospect of having to produce the entire file David Miscavige gave orders that the entire file simply be destroyed by being pulped.

16. Pursuant to Mr. Miscavige’s orders, I ordered Rick Aznaran to take Mr. Wollersheim’s PC files to the recycling plant in Riverside to be pulped. Several hours after I gave the order to have Mr. Wollersheim’s PC files destroyed, Mr. Aznaran returned and confirmed that the records had been pulped and even showed me a small bottle of pulped material, saying ‘Here’s what’s left.”

17. The material that David Miscavige ordered destroyed and which Rick Aznaran had pulped was the same material that the court had ordered produced in Mr. Wollersheim’s Los Angeles court case against CSC.

COMMON SCIENTOLOGY PRACTICE OF DECEPTION AND LIES IN THE WOLLERSHEIM CASE AND IN GENERAL

18. During the time I was on the Board of Directors of RTC, (1983 to 1987) I attended numerous legal strategy sessions that dealt with the Wollersheim v. Church of Scientology case. Most of these legal strategy sessions took place in the boardroom at Author’s Services, Inc. The general legal strategy of Scientology both before and after the Wollersheim judgment was rendered against the Church of Scientology of California was to make the case so complex and expensive that it would go on forever and Mr. Wollersheim would never be able to collect “One Thin Dime”.

19. This general legal strategy as pursued in the Wollersheim case is consistent with Scientology’s overall legal strategy as set forth by L. Ron Hubbard, the “source” of all of Scientology’s policies as follows:

The purpose of the suit is to harass and discourage rather than to win… the law can be used very easily to harass, and… will generally be sufficient to cause [the enemy’s] professional decease. If possible, of course ruin him utterly.

The DEFENSE of anything is UNTENABLE. The only way to defend anything is to ATTACK, and if you ever forget that, then you will lose every battle you are ever engaged in… NEVER BE INTERESTED IN CHARGES. DO, yourself, much MORE CHARGING and you will WIN.

L. Ron Hubbard, Magazine articles on Level 0 Checksheet

20. During the same period of time, I was also present at legal strategy sessions that dealt with the Christofferson case in Oregon and the David Mayo case in the USDC for the Central District of California also known as RTC, et al. v. Robin Scott 85-711-JMI (Bx). The identical legal strategy was employed in those actions.

21. The various legal strategy sessions involving the Wollersheim case were attended by the following Scientology representatives:
Lyman Spurlock of Author’s Services, Inc. (ASI);
Norman Starkey of ASI;
Marty Rathburn of ASI;
David Miscavige of AS1
Vicki Aznaran of RTC;
Warren McShane of RTC;
Marc Yeager of CSI; and,
Myself of RTC.

CORPORATE NAMES AND BOUNDARIES WERE MEANINGLESS

22. It is incumbent on this and every court, as well as the authorities, to realize the amount of deception, chicanery, lying, manipulation and outright criminality that Scientology will employ to hide the truth about their criminal activities. They will spend any amount of money to do this. I know because I was part of it for years. I received orders to break the law, and then I helped to hide these criminal activities just as they are hiding them now.

23. Scientology developed a daunting corporate structure. This structure was designed to confuse those outside of the organization. In reality, corporate names and boundaries were meaningless. Control was centralized in one person. During his lifetime until his death in 1986 that person was L. Ron Hubbard. After his death, all control of Scientology vested and remains in David Miscavige.

24. The one thing that all of us had in common is that we were all members of the Sea Organization. The Sea Organization, or ‘Sea Org” is a paramilitary type organization that virtually governs all of Scientology under guidance of David Miscavige.

25. Our corporate positions were so much window dressing. It was our Scientology positions and our membership in the Sea Organization that gave us the power to control things within Scientology, including setting legal strategy for a corporation that we were not officers or directors of, such as defendant Church of Scientology of California.

SCIENTOLOGY HAD A CORE OF LAWYERS USED FOR ALL PURPOSES

26. The attorneys present when the legal strategy for the Wollersheim case was discussed included:
Sherman Lenske;
Earl Cooley;
Chris Cobb;
John Peterson;
Lawrence Heller; and,
Joe Yanny

27. Not everyone listed above was present for every meeting. However, I am positive that at sessions at which the legal strategy to be employed in the Wollersheim case was discussed, the lawyers involved in the Wollersheim case freely discussed that case and took directions from persons who were not officers, directors or employees of the defendant Church of Scientology of California, including me.

DAVID MISCAVIGE CONTROLLED THE WOLLERSHEIM LAWYERS

28. David Miscavige routinely gave orders to attorneys representing Scientology corporations, regardless of which Scientology Corporation the attorneys ostensibly represented. This was true in every legal strategy session and in every legal case including Wollersheim.

29. I recall one legal strategy session after the judgment was rendered specifically. The attorneys representing CSC in the Wollersheim case were present. Marty Rathburn gave a general briefing on the case mentioning that the judge hated Scientology and that Scientology was not going to pay. David Miscavige said that Scientology was not going to pay even if it cost Scientology more than the thirty nillion-dollar judgment because we don’t want to open the doors to others doing this.

WARREN McSHANE DECLARATION

30. I have read the Declaration of Warren McShane dated June 11, 1999. Mr. McShane’s Declaration is false.

31. For example, Mr. McShane states that: RTC never purchased, acquired, assumed, or otherwise obtained any assets of defendant Church of Scientology of California (‘CSP) as part of any corporate reorganization of the Church of Scientology or otherwise.

In fact, RTC obtained trademarks that were registered in the name of CSC.

32. Mr. McShane’s statement that: “RTC played no role of any kind in the trial of this action” is also a fiction. Nothing could be farther from the truth. Warren McShane, Vickie Aznaran and I constituted all of the officers and members of the board of directors of RTC from 1983 through the end of 1986. Further, Lyman D. Spurlock and David Miscavige were trustees of RTC from 1983 to 1986. All of us were present during legal strategy sessions with the attorneys representing CSC during and after the trial and at those meetings we formulated the strategy that the lawyers were to employ at trial and to frustrate collection of the judgment after it was rendered.

MANAGEMENT OF WOLLERSHEIM CASE BY CSI

33. For example, at these legal strategy sessions it was determined to organize a unit within CSI known as the Wolly Unit. The Wolly Unit was to supervise and coordinate various aspects of the Wollersheim case such as intelligence gathering; public relations, including the “Not One Thin Dime For Wollersheim” Campaign; explaining to Church members Scientology’s version of the case and day to day supervision of the outside attorneys handling the CSC case.

34. Another unit was also organized within CSI. This unit was called MFTC for Mission Find The Crimes. The MFTC’s unit was literally what the title implies. MFTC members worked full time investigating any judge sitting on the Wollersheim case, the judges’ family and friends; the lawyers for Wollersheim; their family and friends; any witnesses that the Wollersheim attorneys might call at trial; and their families and friends. The job of MFTC unit was to find any crimes, unethical behavior or embarrassing information that might be used to Scientology’s advantage. Mr. Wollersheim’s attorneys, Charlie O’Rielly and Lita Schlosser were followed on an almost constant basis.

35. It was irrelevant to us if a legal strategy was pointless or had no ultimate chance for success. As long as we could argue that the legal strategy had a scintilla of colorable basis, we would demand that it be pursued with the utmost vigor. We ordered the attorneys to tie up Mr. Wollersheim’s attorneys; tie up the court; delay the case; make the pursuit of Mr. Wollersheim’s claim as difficult as conceivably possible; force the plaintiff to spend as much money as possible and make an example of Mr. Wollersheim to show that no one can ever prevail against Scientology.

MISSION CORPORATE CATEGORY SORT OUT SHAM

36. In 1981, in response to the Wollersheim case, and the IRS, Scientology created “Mission Corporate Category Sort Out” (“MCCS”). On its face, to the outside world, MCCS was designed to appear to separate corporate business functions from ecclesiastic functions. Prior to this, all of Scientology was under a hierarchy where defendant CSC was designated as the “Mother Church” and all functions of Scientology came under the umbrella of the “Mother Church.”

37. The Mission Corporate Category Sort Out was a sham. It was a smoke screen designed to put a phony corporate front on the Scientology management structure to fool the IRS and to frustrate litigants so that they would never be able to collect a judgment.

38. Scientology has no respect for the “Wog” or non-Scientology legal system. It is merely a tool we could manipulate to destroy our enemies. During the time I was an officer and director of RTC, we often destroyed evidence. I have personal knowledge that this occurred in the Wollersheim case because I participated in it. As far as Scientology was concerned, we were above the law and we were perfectly free to use any means legal or illegal, to manipulate and frustrate the legal system to our purposes.

39. Scientology always enjoyed a number of great advantages in any litigation we were involved in including the Wollersheim case. These advantages included:

a . Scientology’s opponents generally took their legal duties seriously, Scientology did not. For example, Scientology never felt obligated to produce documents it had in its possession even if a court ordered it to do so. The only way Scientology would produce documents was if the documents were worthless or damaging to Scientology’s opponent.

b. Scientology set up a maze of phony corporate structures that Scientology opponents had to negotiate. Scientology did not take these corporate structures seriously, but demanded that it’s opponents do so.

c. Scientology had virtually unlimited funds to spend on litigation and was willing to spend the money to drive any opponent into bankruptcy.

d . Scientology would “play the religious card” as often as possible screaming at the top of its lungs that any lawsuit represented a threat to all religions and was based on religious discrimination against Scientology as a misunderstood and maligned new religion.

e . If Scientology did not like what was going on in a particular court, we would just order the lawyer to file a lawsuit in another court to tie up the plaintiff and his lawyers on trumped up charges. This policy carried out L. Ron Hubbard’s admonition: “NEVER BE INTERESTED IN CHARGES. DO, yourself, much MORE CHARGING and you will WIN.” Further, these new lawsuits could be used as intelligence gathering operations to conduct discovery that the court that we did not like, would never let us conduct.

40. Both before and after the Wollersheim judgment, Scientology’s Mission Corporate Sort Out was designed to drain all the assets out of CSC and place them in other corporations where they could not be touched by anyone who had a judgment against CSC.

41. When the judgment was rendered in the Wollersheim case, I remember that a shock wave went through the Scientology organization. Although many of the assets had been drained off from CSC, there were still some attachable assets that remained within CSC and were thus reachable by Wollersheim’s lawyers. CSC was quickly reduced to one room. Even furniture was removed to other Scientology organizations. FREEDOM MAGAZINE, which had always been housed in CSC, was transferred to CSI.

42. The Essential Strategy to make it impossible for the Wollersheim judgment to be collected was formulated by CSC’s attorney Earl Cooley and CSI attorney Chris Cobb. David Miscavige and Lyman Spurlock then implanted a specific plan to carry out the lawyers’ scheme to make it impossible for Wollersheim to collect his judgment.

43. CSC was stripped of all revenue streams, which were given to other Scientology corporations and entities, including CSI. Any cash that was left in CSC was used to pay bills, debts and settlements for all the other Scientology corporations and entities. I specifically remember one meeting at which we discussed the fact that despite our efforts to strip CSC of attachable assets there was still 2.5 million dollars in cash left that might be seized. It was determined that we had to find bills or debts in other corporations that needed to be paid in order to relieve CSC of this cash. This was done. Mark Ingber of WDC (Watch Dog Committee) reserves in CSI was in charge of stripping CSC of its assets.

THE CSI AND RTC MOTION TO DISMISS

44. I have been informed that RTC and CSI have recently moved to dismiss the Wollersheim case against them on the basis of lathes. My understanding is that lathes is the legal doctrine that is applied to bar someone’s claim when they waited too long to pursue the claim. A huge part of Scientology’s legal strategy in the Wollersheim case was to hide the fact that RTC and CSI were intimately involved in the day-by-day direction of CSC’s defense and to make the case so complex, obtuse and expensive that no one would conceivably be able to get past all the phony legal issues that Scientology was raising to peal away the corporate layers and actually collect on the judgment.

45. If this case is dismissed on the basis of lathes, this cynical strategy will indeed have defeated both Mr. Wollersheim and the entire non-Scientology legal system.

46. I have not received any compensation in any form for giving this declaration. I recognize that by giving this declaration, I make myself a target for further attack by Scientology, however, I am giving this declaration because it is the truth and the right thing to do.

47. Attached hereto as Exhibit “A,” is a true and correct copy of a “Release” I entered into in 1992. The “Release” gags me from ever speaking out regarding my knowledge of the activities of Scientology. I signed Exhibit “A” under duress. I knew that neither I nor my wife would ever be allowed to leave Scientology if I did not sign this “Release.” The contents of the “Release” are simply false.

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

Executed this day of June, 1999, at Boulder, Colorado

______________
JESSE PRINCE

Notes