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

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“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

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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

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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

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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.

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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

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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,

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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

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$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

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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

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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

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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

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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.

[signed]
VICKI J. AZNARAN
Declarant

Notes