ROBERT VAUGHN YOUNG AFFIDAVIT

GRAHAM E. BERRY, State Bar No. 128503

GORDON J. CALHOUN, State Bar No. 84509

LEWIS, D'AMATO, BRISBOIS and BISGAARD

221 N. Figueroa Street, Suite 1200

Los Angeles, California 90012

Telephone: (213) 250-1800

Attorneys for Defendant

UWE GEERTZ, PH.D.

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

Plaintiff,

vs .

STEVEN FISHMAN AND UWE GEERTZ,

Defendants.

Case No. CV 91 6426 HLH (Tx)

DECLARATION OF ROBERT VAUGHN YOUNG IN SUPPORT OF COST BILL FOR DR. GEERTZ'S MOTION FOR AWARD OF COSTS, EXPENSES, ATTORNEY'S FEES AND SANCTIONS

Date: APRIL 4, 1994

Time: 10:00 a.m.

Courtroom: 7

[Filed and served concurrently with Dr Geertz's Bill of Costs.]

DECLARATION OF ROBERT VAUGHN YOUNG

INTRODUCTION

This declaration is submitted in support of Defendant Dr. Geertz's motion for costs, fees, expenses and sanctions following the dismissal of this action with prejudice by the court on February 22, 1994.

My credentials as an expert on Scientology includes over 20 years as a staff member in the organization. In those 20 years, I have held nearly every type of position at every echelon. I have worked at the local, the regional, the national and the international levels. I have been a Scientology representative and spokesman before governmental bodies, the media andthe courts. I have trained others on how to handle the media and governmental agencies. I have been the most senior public relations executive for Scientology world wide. I worked for years at the echelon that handles critics, "enemies," the media, judges, the courts and the government. I have been privy to documents and tactics of the most secret nature, including illegalities committed by Scientology executives and the means of cover-up. I have been called on many occasions to personally handle "hot" situations of the most sensitive nature ranging from the mysterious death of the son of Scientology Founder Ron Hubbard ("Hubbard") to the death of Hubbard himself. I have been privy to financial schemes and scams involving tens of millions of dollars. I also know how Scientology manipulates the law to avoid any revelation of the truth.

SCIENTOLOGY ADVOCATES USING THE COURTS NOT TO SEEK JUSTICE BUT TO HARASS AND RUIN PEOPLE

"The purpose of the suit is to harass and discourage rather than to win. The law can be used very easily to harass, and enough harassment on somebody who is simply on the thin edge anyway, well knowing that he is not authorized, will generally be sufficient to cause his professional decease. If possible, of course ruin him utterly." (From Hubbard's 1955 "The Scientologist: A Manual of Dissemination of Material." Emphasis added. Attached as Exhibit A) The basic reason that Scientology does not use the courts for justice is because Hubbard believed the Scientology justice system he invented was vastly superior and that his system should become the planetary standard.

DR. GEERTZ IS THE TARGET OF SCIENTOLOGY'S VOW TO DESTROY "THE PSYCHS"

PSYCHS ARE SCIENTOLOGY'S SCAPEGOATS FOR EVERYTHING INCLUDING SEX

The "psychs" are Hubbard's scapegoat for all historical ills going back not merely scores of years but hundreds, thousands and even millions of years. In Hubbard's paranoid view, everything from rock and roll to the Third Reich and even sex itself were vile inventions of 'psychs'. (See "Pain and Sex." Attached as Exhibit C.) As incredible as that may seem, Hubbard actually believed that sex was literally invented by "psychs" millions of years ago. While he doesn't come out and say it, the implications are clear: all sex - even the attraction between couples - is bad.

The intensity of Hubbard's anti-sex (and especially anti-female) attitude is not known to many Scientologists. Starting in 1981, I had full access to Hubbard's most private papers, diaries and letters. I continued to have unlimited access to it for years as part of the work to write a biography of Hubbard and was able to read letters to and from his parents, wivesm mistresses, friends and business associates. There were hundreds of thousands of pages of material - much of it originals or carbon copies in his own handwriting - that detailed his views about his life, his wives, his family and sex. Much of this was written in the 1930s and 1940s but extended into the 1970s. Some of these papers were diatribes against females and were covered with red-ink drawings of genitalia around the margins of the pages. He also graphically described what he wanted to do to women, including hurting and raping them. Suffice it to say that it was x-rated and sadistic. This was my initiation into the dark side of Hubbard's views. (These papers were subsequently locked away so no Scientologist will even know they exist, let alone allow anyone to see them.)

Hubbard's anti-female attitude appeared first, in private writings in the 1930s and 1940s. His views of "the psychs" developed after the publication of his first Scientology books in 1950 when he was courting "the psychs" for approval of his system. When he was rebuked andcriticized, he became incensed and began to blame them for his troubles with the press and his customers.

Thus Dr. Geertz is viewed as a part of the international (and intergalactic) conspiracy that must be annihilated before Hubbard and Scientology can reign on Earth.

CSI'S CASE IS PART OF THE "FAIR GAME DOCTRINE" AND "PSYCHS" ARE FAIR GAME

I will show how the Fair Game Doctrine started, how it has continued to this day and how this court has been exposed to these end- justifies-the-means methods. I will present this using the writings (now called "scriptures") of Hubbard. These are the iron-clad policies of Scientology.

"FAIR GAME": THOSE THAT HAVE NO RIGHTS; THEY AND/OR THEIR PROPERTY CAN BE DESTROYED

By FAIR GAME is meant, without rights for self, possessions or position, and no Scientologist may be brought before a Committee of Evidence or punished for any action taken against a Suppressive Person or Group during the period that person or group is 'fair game'. A revision of December 23 1965, changed it to read, "By- FAIR GAME is meant, may not be further protected by the codes and disciplines of Scientology or the rights of a Scientologist." As to what was a "suppressive person," Hubbard gave the definition:

A SUPPRESSIVE PERSON or GROUP is one that actively seeks to suppress or damage Scientology or a Scientologist by Suppressive Acts.

SUPPRESSIVE ACTS are acts calculated to impede or destroy Scientology or a Scientologist and which are listed at length in this policy letter. (Caps in original). Some of the suppressive acts listed included "public disavowal of Scientology; public statements against Scientology;" asking for a refund of fees paid; and "writing anti-Scientology letters to the press." Even turning a Scientologist into the proper authorities can gain one the label of a suppressive. The issue also prohibits "1st degree murder, arson, disintegration of persons or belongings not guilty of suppressive acts." (Emphasis added.) In other words, killing suppressive persons or destroying their property promotes Scientology and is therefore ethical within the Scientology belief system.

WHY SCIENTOLOGISTS CANNOT GIVE UNBIASED TESTIMONY

AN EXAMPLE OF HUBBARD IMPLEMENTING FAIR GAME

"(2) Harass these persons in any possible way....

"(4) Tear up any meeting held and get the names of those attending and issue SP orders on them and you'll have lost a lot of rats.

This order has never been canceled and is still "scripture" as an example how to attack "enemies." In fact, as an example of how Fair Game was being implemented against another defendant, attached as Exhibit F is a declaration from former member David Mayo who describes how he was held captive for six months and was told he would "never leave the property alive." (See pages 4-8) He describes the duress and threats as he became the target of the Fair Game Doctrine (or "Fair Game Law.")

HOW SCIENTOLOGY USES INVESTIGATION AND THE MEDIA TO ATTACK AND HARASS CRITICS

Hubbard also urged the priority of finding evidence of "murder, assault, destruction, violence, sex and dishonesty, in that order. Investigations which can uncover these factors in the activities of individuals or a group attacking Scientology are valuable in the degree that they contain a number of these factors." And note that Hubbard's use of such evidence is not for law enforcement but to the media. "In that way," he wrote, "we then Get rid of suppressive groups by investigation and disclosure." (Emphasis added.)

The next day, on February 18, 1966, Hubbard wrote "Attacks on Scientology" (Attached as Exhibit H) in which he again urged the use of investigations. Suppressives, he said, have by definition comitted criminal' acts. "These people who attack have secrets. And hidden crimes. They are afraid." He thus urged they be investigated as this, he said, would cause the attacker to withdraw.

A week later, on February 25, 1966, he wrote another "Attacks on Scientology" policy letter (Attached as Exhibit I) in which he urged, to "Start feeding lurid, blood sex crime actual evidence on the attackers to the press.

See also Hubbard's "How To Do a Noisy Investigation" of 5 September 1966 (Attached as Exhibit J). The target is "attackers of Scientology".

FAIR GAME DOCTRINE SPECIFICALLY INCLUDES THE FILING OF LAW SUITS

CANCELLATION OF FAIR GAME ONLY MEANT NOT USING THE WORDS ANY MORE BECAUSE IT CAUSED "BAD PUBLIC RELATIONS"

"The practice of declaring people FAIR GAME will cease. FAIR GAME may not appear on any Ethics Order. It causes bad Public relations. [Emphasis added.] This P/L [policy letter] does not cancel any policy on the treatment or handling of an SP. [suppressive person] L. Ron Hubbard Founder

THUS THE SO-CALLED "CANCELLATION" OF FAIR GAME DID NOT CANCEL THE USE OF FAIR GAME TACTICS.

The original directive that CSI uses to say the Fair Game Doctrine was canceled expressly establishes that the only change was to stop using the words "Fair Game.". Hubbard was quite clear that tactics were not to change. only the use of the words in public. As further evidence of Fair Game continuing, Hubbard later wrote"Confidential: Targets, Defense" on February 16, 1969, (Attached as Exhibit M) in which he listed "vital targets on which we must invest most of our time..." The first and most important: "T1. Depopularizing the enemy to a point of total obliteration."

MILITARY TACTICS ARE TO BE USED IN FAIR GAME

"A good general expends the maximum of enemy troops and the minimum of his own. He makes the war costly to the enemy, not to himself. One cuts off enemy communications, funds, connections. He deprives the enemy of political advantages, connections and power. He takes over enemy territory. He raids and harasses. All on a thought plane--press, public opinion, governments, etc. (Emphasis added.)

FAIR GAME TACTICS EXPLAIN THIS LAWSUIT

HOW SCIENTOLOGY ATTORNEYS ARE USED TO CLAIM "ATTORNEY WORK PRODUCT"

The court should note that it has been told that such practices were done by a previous Scientology administration that has been eradicated. This is not true. I am attaching the billings of a private investigator who was doing surveillance on author Omar Garrison and apostate Gerry Armstrong in 1982. (Attached as Exhibit O) These were billed to attorney John Peterson. ("Peterson") However this investigation was being directed by David Miscavige ("Miscavige") who at the time (mid-1982) was my senior in an organization called Author Services, Inc. ("ASI") ASI was a for-profit group that was purportedly a literary agency handling Hubbard's books. We did handle Hubbard's works but our real function was to serve as Hubbard's personal arm into the non-profit Church of Scientology. This investigation by Tin Goose of Omar Garrison and Gerry Armstrong was paid for by Church of Scientology funds on Miscavige's orders while Tin Goose reported directly to Miscavige. Peterson was merely the "cutout," to make it appear that it was attorney work product and to keep it away from ASI.

HOW MISCAVIGE USED A "DOUBLE-BLIND" TO GO AFTER AN ATTORNEY

With the formation of the firm of Bowles and Moxon (attorneys for plaintiff in this case), investigations were moved to them rather than attorneys like Peterson because Bowles & Moxon are Scientologists and can be manipulated and threatened. Peterson was not a Scientologist and could not be so controlled.

EXPERTS AND COUNSEL ON THIS CASE WERE KEPT UNDER SURVEILLANCE

EXAMPLE OF TARGETING A PERSON IN LITIGATION WITH SCIENTOLOGY

Those "real facts of interest" are stated in the next paragraph as to what Scientology wants on the plaintiff. The criminal background, drug history, record of arrests, former employment, perversions of Julie, fully known and documented, as needed.

The program then goes on for pages to tell how to do this. There is nothing to indicate there is anything to find, merely the Hubbard-driven assumption that anyone who sues Scientology or attacks Scientology must by definition be a criminal. The program was written on Hubbard's direction.

CSI'S REFUSAL TO COMPLY IS BECAUSE OF CSI'S COMPLETE DISDAIN FOR ANY SYSTEM OTHER THAN HUBBARD'S

ACCORDING TO THE SCIENTOLOGY BELIEF SYSTEM. THE COURTS ARE PART OF A CRIMINAL PLAN DIRECTED BY "THE PSYCHS"

THE ORDERED DEPOSITIONS SHOULD HAVE PROCEEDED

Despite Miscavige's protests, he runs all of Scientology, regardless of corporate lines. In Scientology, there is only Scientology. Corporate lines are set up as ways to deflect the courts, the IRS and the authorities. When it comes to everyday work, Miscavige is appraised of every part of Scientology, from the church to the secular. He also issues orders to all sectors and approves all major transactions. His role is as the head of Scientology is well known within Scientology. It is only when it comes to matters such as this suit that he and his lieutenants must suddenly conjure up the corporate lines and claim ignorance.

MISCAVIGE KNEW OF FISHMAN AND CROSSED CORPORATE LINES TO DEAL WITH FISHMAN'S MONEY

The others (Starkey, Yager, Mitoff et al) are Miscavige's immediate lieutenants who carry out his orders into their various sectors. They too know about the lack of corporate integrity and any role that Fishman played in Scientology. They also know about the various Hubbard directives I have quoted from.

FISHMAN WAS BEING URGED TO INVEST IN "SPECIAL PROPERTIES," WHICH IS NOTHING BUT A FINANCIAL SCAM

CSI HAS MISREPRESENTED ITS ROLE IN RELATION TO THE "CELEBRITIES"

THE DEPOSITIONS OF THE "CELEBRITIES" DID NOT INVOLVE CONFIDENTIAL MATERIAL

At no time has attorneys for Dr. Geertz asked me for any assistance in handling this material, as to what it might mean, how they might ask questions about it, how they might use it or how the material might be presented to a person in any deposition, let alone indicate in any way that they intend to use those materials with those "celebrities." Nor are attorneys for Dr. Geertz capable of doing this without expert help for the material in question is highly arcane, complex and bizarre and will make absolutely no sense to anyone outside of Scientology. Thus the idea that attorneys for Defendants will somehow expose these "celebrities" to this "upper level" material is merely a sham and an excuse. What was feared was that the other depositions would occur, namely that of Miscavige, Starkey, Yager, etc.

CSI's attempt to use their own refusal to comply with the court as the reason for dismissal is a classical Scientology through-the-looking-glass strategy.

DENIAL OF LEGAL LIABILITY WAS A TACTIC TAKEN ORIGINAL WITH HUBBARD

CSI HAS NOT REFUTED YOUNG'S STANDING AS AN EXPERT

HUBBARD'S DEATH CREATED A POWER STRUGGLE THAT MISCAVIGE WON

HUBBARD'S AND OTHER MYSTERIOUS DEATHS IN SCIENTOLOGY

Hubbard's son Quentin also died under mysterious circumstances in 1976. He had disappeared from his home in Clearwater, Florida, and was found unconscious in a car next to the Las Vegas airport. (Coroner's report is attached as Exhibit U. He died unidentified, as a "John Doe.") The engine of the car was on and a hose ran from the exhaust pipe (although it appeared to have fallen off when the authorities arrived) to the window, making it appear to be a suicide. But, like his father's death, there were a number of nagging questions. For example, Quentin was found unkempt with a beard stubble, a state that no one who knew Quentin could accept. (He was ultra-meticulous in his appearance.) Or that the license plate of the car was missing and found under a rock some distance away. Or that his wallet was gone, making identification impossible. Or that a near-empty bottle of liquor was found, as if he had been drinking, when Quentin did not. Or that there were needle marks on his arms, when he did not use drugs.

Another mysterious but key death was that of Flo Barnett, Miscavige's mother-in-law. She died in 1985 of three shots to the chest and one to the temple from a semi-automatic rifle. Two suicide notes were found. Although she was only 5'3" tall (and weighed only 114 pounds), the examiner determined she shot herself three times in the chest (with a rifle) before shooting herself through the head. (See coroner's report attached as Exhibit V.) What the authorities didn't know was that she had left Scientology and was associating with apostates, to the anger of her son-in-law Miscavige.

Defendant Uwe Geertz was prepared to present information about other mysterious deaths, murders and suicides of Scientologists and former Scientologists.

CSI DID NOT COMPLY WITH DISCOVERY

CSI has repeatedly protested how many documents and people it made available to Dr. Geertz. Being intimately familiar with Scientology files and data-gathering procedures, I can say that CSI has not turned over large volumes of requested material and personnel to Dr. Geertz that are germane to this case. For example, there are extensive files (including computerized) that would enable a person to determine the effect of adverse press. These are kept and maintained on weekly basis. I personally know of them for I have worked with and have seen these files. They have been kept by Scientology for decades. These were not provided to Dr. Geertz. Nor were other material that would have been collected on Dr. Geertz. such as reports from private investigators, credit checks, all standard actions in Scientology proceedings. Nor has CSI supplied material regarding their investigation of Fishman's role in Scientology even though CSI's corporate secretary Lynn Farny said he had seen and reviewed such material.

Nor has CSI supplied those personnel that would know most about the truth or falsity of the facts in question in the Time magazine article. Those people are Miscavige. Yager, Willhere and Mitoff, Epstein, Spurlock and Starkey would know about Fishman's financial roles and Scientology financial scams.)

IT IS ROUTINE TO ALTER SCIENTOLOGY RECORDS AND FILES TO AVOID THE AUTHORITIES

After the Federal Bureau of Investigation ("FBI") raided three Church of Scientology locations in 1977 to obtain documentation regarding violations of the law, I worked with scores of other people to quickly destroy any further evidence to keep it from falling into the hands of the authorities. We were all verbally briefed how we had to go through files and look for (1) any documents showing illegal activity and (2) any documents to show that Hubbard was running Scientology (which he was but we were trying to tell the authorities that he wasn't) and to destroy these documents. In this campaign, the amount of documents that were destroyed were in cardboard boxes stacked down halls. I do not know the page count but the stack was about four feet wide, four feet high and about 60 feet long. And this was from the location with the least amount of files. And there was no doubt that we were doing this to destroy incriminating evidence. In fact, several of us questioned this and were told to shut up and keep shredding paper.

Circa 1983 when I worked at Hubbard's "literary agency" Author Services, Inc., we were told there was a threat of an IRS raid on us and we had to move documents. These went to another floor in the building where we kept watch on them. There were about 50 bankers boxes of files that we were keeping hidden from the authorities who were also serving subpoenas to get records. Our task was to keep these other records secret. The files were kept on that other floor for a couple of months.

This last instance is cited in particular to anticipate the reply of CSI that the earlier examples were from an earlier regime that has been overthrown. This is not true. In fact, the 1983 instance at ASI was conducted by Miscavige who currently runs all of Scientology.

Thus the cleaning up of files to remove embarrassing or incriminating material was routine and the non-appearance of Fishman's name in certain groups is not indicative that he was not there.

CONTRARY TO THEIR DECLARATIONS, CSI IS STILL USING THE ORIGINAL GUARDIAN OFFICE STAFF

The precise target of the FBI raid was the Snow White Program in the Intelligence Bureau of the Guardian's Office. In 1989 the Snow White Program was still active and one of its key staff was Grace Marie Haddy. (See "Non-Existence Formula" dated 12/16/89 from Show White Pgms Chief OSA US attached as Exhibit W) Grace Marie Haddy was a key executive of the intelligence bureau and was privy to all communications detailing the illegalities that subsequently sent the 11 executives to jail.

Handling CSI's case before this court is Kendrick Moxon ("Moxon") who was named as an unindicted co-conspirator when Mary Sue and the others were indicted. Moxon was head of the Guardian Office Legal Bureau in Washington, D.C. (See the "Stipulation of Evidence" attached to the declaration of Vicki Aznaran, also filed 3/9/94 which includes a description of Moxon's role in obstructing the investigation of the Department of Justice.)

THIS CASE DOES NOT CONCERN PLAINTIFF CSI

CSI'S CASE DOES NOT HAVE MERIT FOR SEVERAL COGENT REASONS

The simple truth of this case boils down to this: the suit was brought under the "anti-psych" Fair Came doctrine by an entity without members and without standing (CSI) because it has an anti-"psych" arm whose function is to take over the field of mental health and destroy Hubbard's enemies. I know because I worked at that echelon for nearly 20 years and know it and the tactics intimately.

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

Executed in Los Angeles, California, this 9th day of March, 1994.

Robert Vaughn Young