CD - 19
                            10 October 1994

                 Copyright (C) 1994 Robert Vaughn Young
       Redistribution rights granted for non commercial purposes.


     I, ROBERT VAUGHN YOUNG, declare as follows:


     1. I have been retained as a consulting expert by counsel for
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.

     2. The matters set forth herein are of my own personal knowledge
and if called to testify, I could and would testify competently thereto.


     3. I was a member of an organization calling itself the Church of
Scientology for approximately 20 years between 1969 and 1989.  For all
but the first few months of my involvement with that organization I was
an employee of the Church of Scientology.  For about fifteen of those
over twenty years, I lived communally in the organization's facilities.
I completed what Scientologists consider to be one of its most
confidential levels of personal counseling.  I acquired extensive
information and training in the techniques and methods used by people
calling themselves Scientologists.  I have worked with every phase and
aspect of Scientology from introductory levels to the highest management

     4. In my various capacities, I have worked directly with
Scientology organizations and staff members in at least a dozen
countries.  Materials which I authored were used in every Scientology
organization between 1969 and 1989.

     5. I learned about the intricate Scientology corporate structures
and how they are interrelated.  I am familiar with the "secular" arms of
Scientology.  These are groups which do not appear on the surface to be
related to the Church of Scientology but are in fact operated by the
Scientology hierarchy.

     6. For nearly all of my 20 years, I handled public relations (PR)
for L. Ron Hubbard ("Hubbard") and/or the Church of Scientology.  I have
dealt with every aspect of Scientology PR, from the simplest actions to
dealing with international media.  I have read and been privy to every
level of documentation, including Hubbard's most personal and private
writings and the "upper level" materials.  I have handled every type and
phase of the media on behalf of Hubbard and Scientology.  On many
occasions I have been a national spokesman.  I have generated thousands
of news stories and was called to personally handle the situation of
Hubbard's death.  I have been called by the Church of Scientology to
testify as an expert researcher.  Through my direct work, I produced
official recognitions of Scientology from various federal agencies with
letters to me that were used by Scientology in the media and court cases
around the world.


     7. As an expert of Scientology policies and practices, I have been
provided a copy of a declaration by Lynn R. Farny ("Mr.  Farny"), dated
October 18, 1993, in which he discusses the ethics and justice system of
Hubbard and Scientology.  I have been asked to respond.

     8. Mr. Farny attempts to refute the idea that "Fair Game" is a
policy of Hubbard's and of Scientology.  To do this, Mr. Farny (1) cites
an IRS tax exemption; (2) shows that Hubbard wrote about honesty; (3)
insists that Scientologists are, as a group, honest; (4) argues that
Scientology justice only seeks the truth and does not punish; (5)
insists that "Fair Game" meant only that one was not protected by
Scientology justice; and (6) claims how the Guardian's Office was
operating "totally contrary to Church policy" and thus was disbanded.

     9. First, Mr. Farny says the IRS has concluded that all Scientology
churches and missions "have not and do not engage in criminal or other
improper conduct."  This statement is demonstrably untrue.  Scientology
officials have been indicted and found guilty and jailed in the United
States, Canada and elsewhere, starting with Hubbard's wife, Mary Sue.
Many ranking officials were named as unindicted co-conspirators,
including Hubbard and in-house Scientology legal counsel Kendrick "Rick"

     10.  What Mr. Farny is doing is what Hubbard incorporated into
Scientology:  never admit to a flaw.  While the records are replete with
evidence of criminal behavior by Scientology officials acting in their
capacity as Scientology officials, the Hubbard attitude is never to
admit to any flaw.  The stance always taken was, push the flaw away so
that it had nothing to do with Scientology.  However, as I will show, it
not only had everything to do with Scientology, it had to do directly
with Hubbard.  That was, in fact, why he was named as an unindicted co-

     11.  Second, Mr. Farny quotes extensively from Hubbard to show how
Hubbard wrote about the need for honesty.  But Mr. Farny did not tell
all.  What Mr. Farny is selecting from is Hubbard's most public
writings.  There was another - hidden - side of Hubbard that shows he
was literally two-sided, a schizophrenic whose schizophrenia permeates
all Scientology organizations as one judge noted.  (To be cited later.)
This other side of Hubbard is what produced the siege mentality and Fair
Game, as set forth below.

     12.  Third, Mr. Farny's insistence that Scientologists are as a
group, highly ethical is really not the issue.  The worth of
Scientologist as a whole is not the issue.  It can be conceded they are
good people without detracting from the pernicious nature of Hubbard's
"Fair Game" policy or his attitudes towards his enemies, which he called
enemies of Scientology.

     13.  Fourth, Mr. Farny argues that the Hubbard/Scientology system
of ethics and justice is "based solely on getting to the truth" and has
nothing to do with punishment.

     14.  Mr. Farny noticeably fails to say what the purpose of
Scientology ethics is.  According to Hubbard, "The purpose of Ethics is
Ethics; caps in original) Since intentions do not exist apart from
people, the question becomes, intentions counter to whom?  The answer
is, Hubbard's.  Anyone and anything which is counter to Hubbard's
intention is the target of ethics.  This is crucial to understand
Hubbard's ethics, the roles of the Guardian's Office aka Office of
Special Affairs and "Fair Game."

     15.  Disagreement and the interchange of ideas is central to
American society.  But it is forbidden in Scientology because
Scientology is a closed system.  It does not allow the intrusion of new
(non-Hubbardian) ideas.  It is also self-defining.  Happiness is
according to Hubbard's definition.  Survival is according to Hubbard.
Sanity is according to Hubbard.  If one disagrees with Hubbard's views,
the fault is in the person, not Hubbard.  It is up to the person to sort
out his or her problem until agreement with Hubbard is achieved.  (There
are a variety of tools to produce this.)  If the person continues to
challenge a Hubbard idea, then ethics (up to the sanction of Fair Game)
is used.

     16.  Mr. Farny says there is no punishment in the Scientology
belief system.  For the general public, this is true.  But it is not
true for staff and there are many recorded instances of which I am
personally aware:  people being locked in a room and screamed at by
several people until they break or confess; people being locked up in
chain lockers on Hubbard's boat on his orders; people being thrown
overboard with hands and feet tied; people put on diets of rice and
beans; people kept up for days without sleep; people being made to sleep
on floors, in closets or in "pig's berthing" (the name says it); people
spending years at hard labor at the notorious (and secret) gulags known
as the Rehabilitation Project Force (RPF); people being physically
assaulted and beaten for refusing to comply; people being made to run
until they dropped in the desert sun and then being made to run some
more, etc.

     17.  Such abuses are well known by staff members, particularly in
the Sea Organization.  But it is a crime against Scientology, subject to
appropriate punishment, to make them known to the non-Scientology world,
which might then intrude.  I have personally known Mr. Farny for perhaps
10 years.  I know that he knows of some of these abuses.  I also know
that he is a devout Scientologist who has been at one of these gulags
and who was released after executives felt he had been "rehabilitated".
The truth is that there is punishment in Scientology.  Hubbard's
original "Manual of Justice" even made that point as early as 1959

     "The whole subject of Justice subdivides for a Scientologist into
four phrases.  These are:

     "1.  Intelligence Activities;
     "2.  Investigation of Evidence;
     "3.  Judgment or PUNISHMENT; and
     "4.  Rehabilitation (MANUAL OF JUSTICE, at p. 4. Added emphasis.)

     And later:

     "None of us like to judge or to PUNISH.  Yet we may be the only
people on Earth with a right to PUNISH - since we can undo the damage we
do in most cases."  (Id., at p. 7. Added emphasis.)

     18.  In the same manual, Hubbard also instructed how
"investigation" can be used to "crush" people.  This "manual" is, in
fact, where one can find the philosophical origins of the practices
which came to be known as "Fair Game."  (There is an earlier reference
that I will take up later.  See paragraph ___.)

     "Remember that - by investigation alone we can curb pushes and
crush wildcat people and unethical "Dianetics and Scientology"
organizations."  (MANUAL OF JUSTICE, at p. 3.)

     19.  A few years later, Hubbard introduced the doctrine of using
"manufactured" evidence as a threat.  On August 15, 1960, the
"Department of Government Affairs" was established with a policy written
by Hubbard.  (ATTACHMENT R) This was the forerunner of the Guardian's
Office, later called the Office of Special Affairs.  In the issue,
Hubbard ordered:

     "If attacked on some vulnerable point by anyone or anything or any
CAUSE THEM TO SUE FOR PEACE.  Peace is bought with an exchange of
advantage, so make the advantage and the settle.  DON'T EVER DEFEND.
ALWAYS ATTACK.  Don't ever do nothing.  Unexpected attacks in the rear
of the enemy's front ranks work best.  (emphasis added.)

     "The goal of the Department is to bring the government and hostile
philosophies or societies into a state of complete compliance with the
goals of Scientology.  This is done by high level ability to control and
in its absence by low level ability to overwhelm.  Introvert such
agencies.  Control such agencies.  Scientology is the only game on Earth
where everybody wins.  There is no overt in bringing good order."

     20.  An "overt" in Scientology is a transgression, a wrong.  What
Hubbard is saying lays the moral groundwork for Fair Game.  He said, as
long as one is producing compliance with Hubbard's objectives, there is
no moral wrong being committed.  In other words, as to the world of non-
scientologists, the end justifies the means.  This is how Fair Game was
started and it is the current view of the dedicated GO/OSA staff member.

     21.  Mr. Farny makes a point of "harmful acts" but he fails to
define them in Hubbard's terms and according to the policy that is
binding on Scientologists.  It is defined in a bulletin Hubbard wrote on
October 23, 1983, called "Sec Checking:  Note."  (ATTACHMENT S) In it
Hubbard said the true "harmful act" that Mr. Farny is citing is
"something contrary to the mores of a group..."  Hubbard is very
emphatic on this.  Scientology "technically is NOT interested in
confidences or overts [harmful acts] against a group's enemies or
withholds [secrets] thereof."  In other words, as of 1983, actions
committed against "enemies" are not of moral or ethical interest.  Only
those committed against Scientology.  This is the ethical view that
allows Fair Game to stay in place.

     22.  It should never be thought that Scientology attacks its
critics for anything other than personal reasons.  Much is made of the
crusades against abuses, but in 1967 Hubbard made it clear why any
attack is made by Scientology and when it will stop.  The following is
from HCO Bulletin 5 Nov 67 "Critics of Scientology" (ATTACHMENT T):

     "We are slowly and carefully teaching the unholy a lesson.  It is
as follows:  "We are not a law enforcement agency.  BUT we will become
interested in the crimes of people who seek to stop us.  If you oppose
Scientology we promptly look up - and will find and expose - your
crimes.  If you leave us alone we will leave you alone."

     23.  Fifth, regarding Fair Game, Mr. Farny once again has been less
than candid.  He has said Fair Game "meant simply that an individual so
labelled was not entitled to the protection of the Scientology system of
justice."  He says later it is "a direct reference to what individuals
who cannot have access to the Scientology justice system are likely to
receive at the hands of the justice systems extant in society."  Since
the issue of Fair Game has been challenged and contested and argued for
years, I would like to set the record straight.  The following
information is based upon my studying highly confidential Guardian
Office files and reports and other writings and issues from Hubbard.

     24.  Fair Game became a subject of controversy in 1968 during
governmental inquiries in the United Kingdom.  By then, Hubbard had
already suffered a severe setback in Australia.  In 1965, the Australian
Board of Inquiry into Scientology had published its final report after
sitting for 160 days and hearing 151 witnesses.  The opening words of
the report foretold what was to come:

     "There are some features of Scientology which are so ludicrous that
there may be a tendency to regard Scientology as silly and its
practioners as harmless cranks.  To do so would be gravely to
misunderstand the tenor of the Board's conclusions.  This Report should
be read, it is submitted, with these prefatory observations constantly
in mind.  Scientology is evil; it's techniques evil; its practice a
serious threat to the community, medically, morally, and socially; and
its adherents sadly deluded and often mentally ill."

     The report also said Hubbard's sanity was "gravely doubted."  In
December 1965, the Australian government began to act when the state of
Victoria passed the Psychological Practices Act which basically banned
the practice of Scientology in that state.  A few months later, on
February 7, 1966, there was a call in the British House of Commons for a
comparable inquiry.  This is what set the stage for a flurry of
retaliatory actions by Hubbard that are embedded in Scientology policy
to this day.

     25.  On March 7, 1965, Hubbard wrote Hubbard Communications Office
Policy Letter (HCOPL) of March 7, 1965, titled "Ethics:  Suppressive
Acts:  Suppression of Scientology and Scientologists:  The Fair Game
Law" (ATTACHMENT A).  It gave the official definition of "Fair Game."
Hubbard wrote,

     "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.")

     26.  As to what was a "suppressive person," Hubbard gave the

     "A SUPPRESSIVE PERSON or GROUP is one that actively seeks to
suppress or damage Scientology or a Scientology 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."

     27.  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)

     28.  It should be noted that the policy letter in which all of the
above appears is also the original which gives the "simple, five step
procedure" (known to Scientologists as "A to E" that Mr. Farny quotes.
Also this policy letter was published under the "Fair Game Law" title as
late as 1980 in Volume 1 of "The Organization Executive Course:  An
Encyclopedia of Scientology Policy" by L. Ron Hubbard.  The issue
"Suppressive Acts:  Suppression of Scientology and Scientologists:  The
Fair Game Law" appears on page 552 et seq, which shows that Fair Game
continues.  These volumes have been reprinted again to launder out
certain phrases and issues of Hubbard that are giving executives legal
problems.  This is being done without telling church members and
contrary to an issue called "The Integrity of Source" which prohibits
anyone other than Hubbard from making changes in his writings.  This
will be addressed later.

     29.  Hubbard's own application of Fair Game tactics are what were
later used as the model.  They showed up a few months after this issue
when he wrote HCO Executive letter 27 September 1965 on "Amprinistics."
(ATTACHMENT B) This was what he called a "splinter" group, a group that
was using Scientology methods without his control.  Hubbard's three-page
issue blasts the Amprinistics founders with a variety of sexual charges.
(Sexual conduct, particularly homosexuality, and communism were two of
Hubbard's favorite topics for accusations.)  Hubbard declared the
Amprinistics Fair Game.  Since Hubbard is the source of Scientology
policy and definitions, here is a prime example of Hubbard view of Fair

     "They are each fair game, can be sued or harassed [sic].  Horner
can be barred out of any Commonwealth Country or England as he was the
subject of a deportation order from England and his file has come alive
again in the Home Secretary's Office.  Harry Thompson's wives and
victims are always looking for him to have him arrested.  Watson is a
set-up for arrest as a homosexual.  Any meeting held by them should be
torn up.  The names of any persons attending should be collected and
they should be labelled SP [suppressive person] as they have left
Scientology.  These people are SP because they are seeking to avoid
auditing and retain their withholds.  Once labeled, these persons will
not then be covered by amnesty and will never be admitted to further
training and processing.  Persons messing themselves up with Amprinistic
[techniques] should be refused any assistance.  If these persons move
into your area act through any agency you can to have them deported or
arrested on whatever grounds.  England is currently too hot for them so
they may tour about.  Horner's UK deportation order, Thompson's police
record and Watson's homosexuality make them very vulnerable to
deportation or arrest."

     30.  Hubbard does not stop there.  He goes on to issue a five-step
order that includes:

     "(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."

     31.  Clearly Hubbard had another side, a side that only staff
members (not the public) have seen.  These are the Hubbard writings that
laid the basis of "fair game," and not what Mr. Farny has tried to
represent through glowing Hubbard platitudes that were written for
public consumption, the media, the courts and the IRS.

     32.  In 1966, Hubbard began to codify those sections of Scientology
that would implement Fair Game.  For example, on February 17, 1966, he
created the Public Investigation Section with a policy letter of that
name and date.  (ATTACHMENT C) As Hubbard put it,

     "It will be seen that the section has all the useful functions of
an intelligence and propaganda agency.  It finds the data and sees that
it gets actions."

     In that vein, "Standard intelligence procedures are used," he
wrote.  The statistic of the unit included "the number of derogatory
news stories appearing that week related to enemies of Scientology."  He

     "The section should note that press and the public are interested
in murder, assault, destruction, violence, sex and dishonesty, in that
order.  Investigations which can uncover these factors in the activities
of individuals of a group attacking Scientology are valuable in the
degree that they contain a number of these factors."

     Hubbard was also not beyond advocating the stirring of racial

     "Associating the attacking group's activities with reprehensible
groups in the past by using familiar descriptive words will be found
very effective.  For example, if the word 'white' has been made hateful
to the public by some past criminal group we use 'white' in our
descriptive terminology concerning the group that is attacking us and
whom we are investigating."

     He later concludes, "In that way we then get rid of suppressive
groups by investigation and disclosure."

     33.  The next day, on February 18, 1966, Hubbard wrote "Attacks on
Scientology" (ATTACHMENT D) in which he again urged the use of
investigations.  Suppressives, he said, have crimes.  "these people who
attack have secrets.  And hidden crimes.  "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.

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

     35.  On March 1, 1966, Hubbard formed the Guardian's Office which
took over the intelligence function just described.  (ATTACHMENT F)

     36.  As problems escalated for Hubbard, he wrote an issue on
October 18, 1967 "Penalties for Lower Conditions" (ATTACHMENT G) whereby
Fair Game was automatically issued on anyone (including staff members)
who was an "enemy."  They were, he said, "SP Order.  [An order declaring
them suppressive.] Fair game.  MAY BE DEPRIVED OF PROPERTY OR INJURED BY
(emphasis added)

     37.  As international problems continued for Hubbard, one of the
objects of investigations was Fair Game.  Issues such as the one on
Amprinistics were becoming public relations problems and so on October
21, 1968, Hubbard wrote an issue ("Cancellation of Fair Game" ATTACHMENT
H) that said it was a public relations problem.  There was no mention of
morality.  The entirety of the policy letter (P/L) is as follows:

     "The practice of declaring people FAIR GAME will cease.  FAIR GAME
may not appear on any Ethics Order.  It causes bad public relations.

     "The P/L does not cancel any policy on the treatment or handling of
an SP.  [suppressive person]

     L. Ron Hubbard, Founder"

     38.  Since 1968, Scientology officials (including myself when I was
asked the question" insisted that the practice of "Fair Game" was
canceled with this issue.  The Court must notice Hubbard is talking
about banning the use of the words "Fair Game' from Scientology
documents authorizing Scientologists to trick, sue, lie or destroy
suppressive persons.  And the reason is public relations.  But the
treatment of people does not change.  Hubbard expressly states this
"Policy Letter does not cancel any policy on the handling of an SP".  As
show above, Suppressive Persons were to be attacked, tricked, sued, lied
to or destroyed.  This policy did not change.  In other words, Hubbard
did not cancel this order that suppressives could be "tricked, sued or
lied to or destroyed."  That was a policy for the treatment of
suppressives and this so-called "cancellation of Fair Game" clearly
states that those treatments (or "handlings") were to continued

     39.  If the practice of Fair Game had been cancelled, then the
treatment or handling of "suppressives" would have changed.  However,
they did not and this is proven by Hubbard and the courts as well as
voluminous documents and witnesses, and Mr. Farny knows this.  That will
be taken up shortly.

     40.  On February 16, 1969, Hubbard wrote "Confidential:  Targets,
Defense" (ATTACHMENT I) 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."

     41.  Also on February 16, 1969, he wrote "Confidential:  Battle
Tactics" (ATTACHMENT J) where he urged the use of military tactics and
strategy in dealing with the "enemy."  He wrote:

     "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)

     He also urged the use of intelligence to get the "who when where
what."  (sic)

     42.  Hubbard wrote considerable materials on the use of
intelligence and covert operations.  For example, in "Confidential:
Intelligence-Actions:  Covert Intelligence:  Data Collection" of
December 2, 1969, (ATTACHMENT K) Hubbard said how these are carried out
with a "Case Officer" and agents.

     "Essentially a covert operation is intended to embarrass, discredit
or overthrow or remove an actual or possible opponent.  It is a small
war carried on without its true source being disclosed."

     43.  By 1971, Hubbard was directing an international spy network
and he felt it was paying off.  On May 7, 1971, he wrote GO [Guardian
Order] 070571 LRH "Secret:  Notes on Smersh."  (He took the word from
the James Bond novels to refer to an international conspiracy that he
believed was directing the attack on him.)  He said,

     "Penetration is always a win.  We have made it in finding WHO
attacks Scientology from where by doing what.  This gives us an ever
further penetration.  We have found as well the EX intelligence officer
mouth pieces [sic] in the UK that influence that government and push
Nazi aims.  We are getting even further penetration now into who is
keeping this planet upset."

     44.  In 1972, he issued an order titled "CONFIDENTIAL:  Black
Propaganda" (GO 011272 LRH) (ATTACHMENT M) Also known as "Black PR,"
short for "black propaganda."  Hubbard defined the topic:

     "Black Propaganda is a covert communication of false info[rmation]
intended to injure, impede, or destroy the activity or life of another
person, group, or nation, usually issued from a false or removed source
from the actual instigator.

     "It is used heavily in 'psychological warfare."

     In a warped sense of logic, Hubbard said,

     "Our propaganda is dirty but it is not black because it is true.
Black propaganda is essentially false.

     "We can do this trick (as in the new operating plans wrote) by
survey and attack."

     45.  The "operating plans" Hubbard was referring to comprised the
Top Secret "Snow White" program of which I was part.  The Snow White
Program had basically three arms:  public relations, legal and
intelligence.  It was the intelligence arm that was raided by the FBI in
1977.  A good portion of the Snow White Program was based on the Fair
Game doctrines described above, since the program was aimed at Hubbard's
"enemies" and "suppressives."

     46.  On October 6, 1979, Hubbard's wife Mary Sue and eight other
Scientology executives signed a 282-page (plus exhibits) Stipulation of
Evidence that detailed the government's case.  That document details the
burglaries, forgeries, conspiracies, to obstruct justice and other
crimes committed.  But it is the Sentencing Memorandum for Jane Kember
(The Guardian) and Mo Budlong (her intelligence chief) of September 16,
1980, by Assistant US Attorney Raymond Banoun that gives the most
succinct view of how Fair Game was conducted after 1968.  In fact, the
memo discloses an admission by defendants that Fair Game continued even
beyond the conviction of Mary Sue Hubbard, until mid-1980.  (Banoun
questions in the memo "as to whether these illegal activities were ever
terminated by those defendants.")

     47.  The memo relates how the defendants combined intelligence and
legal to defraud and abuse the courts.  Portions are hereby excerpted
from it.

     "These crimes included:  the infiltration and theft of documents
from a number of prominent private, national and world organizations,
law firms, newspapers and private citizens; the execution of smear
campaigns and baseless law suits for the sole purpose of destroying
private individuals who had attempted to exercise their First Amendment
rights to freedom of expression; the framing of private citizens who had
been critical of Scientology, including the forging of documents which
led to the indictment of at least one innocent person; and violation of
the civil rights of prominent private citizens and public officials."
(page 3)

     48.  The memo points out how Mary Sue Hubbard had said on the
witness stand that she and her codefendants "felt they could do to
others whatever they perceived, however erroneously, others were doing
them."  (page 6)

     "They presented this Court with a shabby attempt at impeaching
Meisner's credibility [the Scientology intelligence agent who turned and
started the investigation that led to the raid] by claiming that he
stole money from the Church - the same false claim they made against
another former Scientologist who had the courage to expose their crimes
and thus fell victim to their fair game doctrine.  Allard vs.  Church of
Scientology of California, 68 Cal.  App. 3d 439, 129 Cal.  Rptr. 797 (Ct
App 1976), cert. denied, 97 S. Ct. 1101 (1977)."  (page 14)

     "The defendants' contention that they committed the crimes of which
they stand convicted in order to protect their Church from government
harassment collapses when one reviews a sample of the remaining
documents seized by the FBI during the execution of the two Los Angeles
search warrants.  If anything, these documents establish beyond question
that the defendants, their convicted co-defendants, and their unindicted
co-conspirators [which included Ron Hubbard and current Scientolgoy
counsel Kendrick Moxon], as well as their organization, considered
themselves above the law.  They believed that they have carte blanche to
violate the rights of others, frame critics in order to destroy them,
burglarize private and public offices and steal documents outlining the
strategy of individuals and organizations that the Church had sued.
These suits were filed by the Church for the sole purpose of financially
bankrupting its critics and in order to create an atmosphere of fear so
that critics would shy away from exercising the First Amendment rights
secured them by the Constitution.  (Footnote, This is precisely how
Scientology's critics viewed Scientology's activities.  Newsweek,
November 20, 1978 at 133:  "The Church of Scientology relies on suits
and petty harassment to register its complaints.  In August, the
Scientologists slapped a $1 million suit on the Los Angeles Times after
it ran a series about the Church.  The Times wasn't accused of libel;
rather, the Scientologists claimed that the paper conspired with the FBI
and Justice Department to violate the church's civil rights by poisoning
the atmosphere before a trial" of the nine convicted co-defendants.
(See also discussion, infra, regarding Scientology's lawsuits against
its perceived "enemy", Paulette Cooper.")  The defendants and their
cohorts launched vicious smear campaigns, spreading falsehoods against
those they perceived to be enemies of Scientology in order to discredit
them and, in some instances, to cause them to lose their employment.
Their targets included, amoung others, the American Medical Association
(AMA), which had branded Scientology's practice of "dianetics" as
"quackery"; the Better Business Bureau (BBB), which sought to respond to
private citizen's inquiries about the courses offered by Scientology;
newspapers which merely sought to report the news and inform the public,
law firms which represented individuals and organizations against whom
Scientology initiated law suits (often for the sole purpose of
harassment); private citizens who attempted to exercise their First
Amendment rights to criticize an organization whose tactics they
condemned; and public officials who sought to carry out the duties for
which they were elected or appointed in a fair and even-handed manner.
To these defendants and their associates, however, anyone who did not
agree with them was considered to be an enemy against whom the so-called
"fair game doctrine" could be invoked.  ALLARD V. CHURCH OF SCIENTOLOGY
OF CALIFORNIA, SUPRA.  That doctrine provides that anyone perceived to
be an enemy of Scientology or a "suppressive person," "[m]ay be deprived
of property or injured by any means by any Scientologyist.  [He m]ay be
tricked, sued or lied to or destroyed."  (Id., 58 Cal.  App. 3d at 413
n. 1, 129 Cal.  Rptr. at 800 n. 1.)  (Footnote 2:  This led the
California Court of Appeals to state that "Any party whose tenets
include lying and cheating in order to attack its 'enemies' deserves the
results of the rick (sic) which such conduct entails."  (Id., 58 Cal.
App. 3d at 453, 129 Cal.  Rptr. at 805.)

     "Defendants, through one of their attorneys, have stated that the
fair game policy continued in effect well after the indictment in this
case and the conviction of the first nine co-defendants.  Defendants
claim that the policy was abrogated by the Church's Board of Directors
in late July or early August, 1980, only after the defendants personal
attack on [Federal] Judge Richey."  (Transcript of September 5, 1980, at

     This policy, together with the actions of these defendants who
represent the very top leadership of the Church of Scientology, bring
into question their claim that their Church prohibited the commission of
illegal acts."  (pp 10-11)

     "It is interesting to note that the Founder of their organization,
unindicted co-conspirator L. Ron Hubbard, wrote in his dictionary
entitled 'Modern Management Technology Defined' that "truth is what is
true for you," and 'illegal' is that which is 'contrary to statistics or
policy' and not pursuant to Scientology's 'approved program.'  Thus with
the Founder-Commodore's blessing they would\could wantonly commit crimes
as long as it was in the interest of Scientology."

     "These defendants rewarded criminal activities that ended in
success and sternly rebuked those that failed.  The standards of human
conduct embodied in such practices represent no less than the absolute
perversion of any known ethical value system.  In view of this, it
defies the imagination that these defendants have the unmitigated
audacity to seek to defend their actions in the name of 'religion.'"
(page 33)

     "It is clear from the press releases issued by Scientology
following the jury's verdict, and their vicious actions against another
member of this Court, that they have yet to learn the errors of their
criminal ways."  (page 34)

     49.  The other member of the Court that was being referred to was
Federal District Judge Charles Richey who was the target of a sting
operation conducted by a private investigator hired by Scientology that
forced the judge to recuse himself from the Scientology case on which he
was sitting.  The judge was allegedly set up with a prostitute.  The
action was Fair Game.  Scientology publications however called it a "BIG
WIN."  He would not be the last judge to be the target of Scientology
Fair Game.

     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

     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."

     53.  Another judge who stepped down from a Scientology case was
Federal District Judge James M. Ideman.  But as he did so, he filed a
declaration in his court on June 21, 1993, (ATTACHMENT O) which said in

     "Plaintiff has recently begun to harass my former law clerk who
assisted me on this case, even though she now lived in another city and
has other legal employment.  This action, in combination with other
misconduct by counsel over the years has caused me to reassess my state
of mind with respect to the propriety of my continuing to preside over
the matter."

     54.  Part of the problem, he said, was seeking to have Scientology
comply with discovery.  They would not comply:

     "This noncompliance has consisted of evasions, misrepresentations,
broken promises and lies, but ultimately with refusal."

     55.  Judge Ideman later remarks how Scientology apparently views
"litigation as war" and seeks to break the opposition through increased
litigation costs.  This is not news to members of the Guardian's Office,
now known as the Office of Special Affairs.  This tactic was laid out by
Hubbard as early as 1955 in The Scientologist:  A Manual on The
Dissemination of Material (ATTACHMENT Q).  In it Hubbard said:

not authorized, will generally be sufficient to cause his professional
decease.  If possible, of course, RUIN HIM UTTERLY."  (Added emphasis)

     Hubbard wrote this in 1955 but, like Fair Game, it is still

     56.  It must be remembered that Fair Game is not the result of one
policy letter from Hubbard.  It was and is embedded in the organization
through scores of Hubbard policies and directives.  It was exposed after
the raid of 1977 and again in the court of Judge Breckenridge in 1984
and in the courtroom of Judge Ideman in 1993.  Time and again
Scientology officials have insisted that it has ended.  Now Mr. Farny is
seeking to hoodwink this Court by returning to the original argument,
disregarding history and facts.  Ironically, that too is part of Fair

     57.  Lastly, on the matter of Jane Kember:  The Guardian was the
most powerful position in Scientology after Hubbard himself and his wife
Mary Sue.  The Guardian was able to move any bank accounts, close and
open organizations, expel people, etc.  As late as 1970, Hubbard wrote,
"The two most effective arms of Dianetics and Scientology are the Sea
Org[anization] and the Guardian's Office."  (ATTACHMENT V) Mr. Farny's
statement that "Kember's removal and the disbanding of the GO were the
results of the discovery by CSI's management that a few members of the
GO...had undertaken actions totally contrary to Church policy" is as
ridiculous as it is false.  It was the FBI and Department of Justice
that discovered and exposed the crimes, not CSI management.  And Kember
was fanatically defended until she was found guilty and went to jail.
Mr. Farny know this.  Nor was the GO disbanded.  It was taken over.  It
was renamed, in the same offices, had the same personnel and operated
from the same policies from Hubbard.  The person who oversaw the
"disbanding" was David Miscavige, who directed the Fair Game actions on
Armstrong from what was called "Special Project" which was, in fact,
Author Services, Inc., where I was employed.

     58.  The policies and directives cited in this declaration are from
Hubbard.  I chose to cite his words rather than the even more voluminous
Fair Game materials authored by others because Hubbard's writings are
considered "scripture" by Scientology and they cannot be cancelled or
changed except by him.  Since he died in 1986, nothing past that point
can be changed.  This was stated in an issue of July 7, 1982, called
"The Integrity of Source" (ATTACHMENT W) which said:

     "It is hereafter firm Church policy that LRH ISSUES ARE TO BE LEFT

     "No one except LRH may cancel his issues."

     "No one except LRH can revise his issues whereby changes are
incorporated into the text and then reissued.  Any valid revisions must
hereafter be made in a separate issue stating the change and how the
revision is to be read....

     Already existing issues stand intact and valid."



     59.  This long association began in 1968 when I began studying
Scientology while working in the Ph.D. program at the University of
California, Davis.  I even used Scientology books in the philosophy
courses that I was teaching.  By late 1968 my personal study of
Scientology had progressed to the point that I began to book audit.  I
acquired hundreds of hours of experience as a book auditor.

     60.  By 1969, I left the Ph.D. program to help start the Dianetics
and Scientology Mission of Davis.  My functions included giving the
introductory lecture, supervising the communications course, giving
professional Dianetic auditing and handling public relations for the
Mission.  This gave me considerable experience in not only delivering
basic services to new public but in how the community viewed Scientology
and how Scientology interacted with the community.  In my public
relations capacity, I became quite familiar with the area media and
other groups.  I organized and presented a community anti-drug program
on the UC Davis campus which brought speakers from around the state in
an all-day symposium that received considerable media coverage.

     61.  While at the Davis Mission, I was asked by an inmate at
Vacaville Medical Prison to give a talk there.  I did.  Then I started a
Scientology group that I supervised with weekly meetings for over two
years.  An article in the Sacramento Union recognized me for my work.


     62.  In early 1971, I joined the Guardian's Office (GO) of the
Church of Scientology, San Francisco.  Today the Guardian's Office is
titled the Office of Special Affairs ("OSA").  The Guardian's Office was
the most powerful arm in Scientology.

     63.  Hubbard often said that the two most effective arms of
Scientology were the Guardian's Office and the Sea Organization.  I
later became a member of the Sea Organization and became well acquainted
with its' policies too.  The basic difference was that the Sea
Organization (SO) is an internally focused group.  Its interest was in
the day-by-day operation of the organizations in order to make money.
The Guardian's Office (GO) was an externally focused group.  It dealt
primarily with perceived threats from the media, lawsuits, government
agencies, and dissidents who had left Scientology.  However, the GO had
powers not given to the SO.  As laid out in the Hubbard policy letter of
1 March 1966 that created the office of The Guardian, The Guardian was
the most powerful position in Scientology, second only to Hubbard and
his wife, Mary Sue.  The Guardian was able to expel people, move bank
accounts, close Scientology organizations if they displeased Hubbard,
etc.  This power extended down through a network of Deputy Guardians and
Assistant Guardians and their respective bureaus:  Public Relations,
Finance, Intelligence and Legal.  More bureaus were added later.

     64.  When I joined the Guardian's Office, I was sent immediately to
Los Angeles for training in Public Relations ("PR").  My training lasted
from 9 a.m. until 11 p.m., six days a week for over three months.  It
included studying the various investigations into Scientology including
the (then) on-going challenge from the Food and Drug Administration and
the investigations into Scientology in Australia and New Zealand.  I
also studied all press files which meant articles from around the world,
including the United Kingdom where there had been considerable problems.
I was provided and read confidential reports from Scientology Public
Relations Offices around the United States to develop an understanding
of how Scientologists handled PR situations.  I also read similar
confidential reports from international Public Relations Offices
detailing how they handled public relations situations.  I thus became
fully familiar with the confidential PR history of Scientology up to
that point, meaning the history of the Church that was not being shared
with rank and file Scientologists.  I was privy to the actual behind-
the-scenes story of what was happening and what was being done to handle
public relations problems.

     65.  My training also included studying material by Hubbard and
Guardian Office (GO) personnel on how to handle public relations.  This
included tapes by Hubbard on the subject.  Much of this material was
"confidential" which meant it was kept locked away and was to be viewed
only by authorized GO personnel.  That material advised on defining,
identifying and dealing with those viewed as "enemies" of Hubbard and

     66.  My training also included "drills" which were exercises to
teach me what Hubbard considered to be basic PR skills.  These included
how to write a press release and give a press conference as well as how
to respond to reporter's questions, how to divert a reporter, how to
stall for time, how to avoid questions, how to introvert and cave in a
person and other tactics.

     67.  My training also included shorter instruction (called a "mini-
hat") so I could temporarily manage the other bureaus, including the
Intelligence Bureau which ran covert operations.  During my tenure in
Los Angeles I directly participated in one large cover operation
targeting an area mental health group.  The operation created
considerable bad press for the group, severely hurt their fund-raising
and was not traced to Scientology.  Thus I was able to become intimately
familiar with Hubbard's intelligence techniques, methods and styles.


     68.  When my training was completed, I returned to San Francisco
and assumed the position of Assistant Guardian (AG) so the then-AG could
go to Los Angeles for further "enhancement."  Since the AG is over all
bureaus (PR, Finance, Intelligence, Technical and Legal) I ran all
bureaus.  (The Technical Bureau was subsequently moved to a non-GO area.
Other bureaus were also added, such as Social Coordination where major
"front groups" that generated income, such as Narconon, were run.  The
purpose of these groups were to avoid appearing to be Scientology and
thus avoid detection and criticism, thus allowing us to gain a foothold
into an area.)

     69.  At that time the power of the GO was considerable.  So when
several financial crises hit the San Francisco organization, I
implemented Hubbard's policy.  I seized the accounts and ran the
finances of the entire organization until it was able to return to
solvency.  (I also received several daily briefings from GO US in Los
Angeles to advise me.)  This taught me the financial structure of
Scientology including how money was sent to various bank accounts in San
Francisco, Los Angeles and overseas.

     70.  As the AG, I also conducted internal investigations into
personnel in the organization according to Hubbard's policy in order to
determine staff qualifications.  This was done by reviewing their ethics
files, personnel files and auditing folders.  I also investigated
statistics throughout the organization.  I also learned how to alter
records in the organization to mask the trail of personnel going to the
Intelligence Bureau so they could not be traced to Scientology.  (This
was a standard practice for operatives.  It required destroying or
altering records so there was no trace of the persons should law
enforcement try to find them.)

     71.  As the Public Relations Officer (PRO), I worked on programs
and orders from the Guardian's Office US and the Guardian's Office World
Wide (in England).  In my functions, I worked with all media in Northern
California.  I placed stories and dealt with media to handle stories
that Scientology considered to be unfavorable.  I went on several talks
shows, including those with major stations, as the Scientology spokesman
for Northern California.

     72.  I organized an Ecumenical Communications Council (ECC) which
consisted of representatives from about 50 area religions or sects.  The
function of the ECC was to help all groups to achieve better PR,
especially with the media.  Behind it was my own desire to give me a
stronger base for negotiating with the media.  The ECC was quite
successful.  In fact, for my work with the community one San Francisco
radio station named me "Citizen of the Week," to my surprise.

     73.  While working in San Francisco, I had occasion to work with
other Dianetics and Scientology Missions, thus learning further how the
organization worked in a large area.


     1. TRAINING

     74.  In the latter part of 1973, I was promoted to the Guardian's
Office, United States (GOUS).  GOUS was located in Los Angeles, where I
had received my training.  The function of GOUS was to direct and run
all GO offices in the United states as well as Mexico.  (There was
perhaps 15 at that time in major cities around the U.S. plus one in

     75.  My first assignment at GOUS was to be the PR Establishment
Officer (PR Esto).  My task was to work with all personnel in the PR US
Bureau, to ensure that they were better trained etc.  (There were about
10 people in the bureau when I arrived.)  This allowed me to learn all
functions in the PR US bureau and all personnel.


     76.  After a few months, however, I was assigned to the PR section
of the most secret and largest program in the Guardian's Office - the
Snow White Program.  It consisted of several highly secret programs
written by Hubbard that were designed to ferret out the source of
international criticism of him and Scientology.  Persons were assigned
to each bureau to carry out the Snow White actions in that bureau.  We
had considerable authority and latitude as well as finances and the Snow
White program was the "highest priority."  It afforded me the
opportunity to become familiar with dozens of Scientology organizations
across the United States.

     77.  One of the objectives of the PR Snow White program was to get
acceptances of Scientology from governmental agencies.  I personally did
that in several instances.  Sometimes after many months of work
including several trips to Washington, D.C., letters of recognition were
written to me by several agencies including the U.S.  Air Force,
Department of State and Department of Labor.  These letters were crucial
to Scientology's legal position internationally and were widely
reproduced as well as used in a variety of court cases.


     78.  During this time I helped to form "front groups" that were
nothing but letterhead, such as the National Commission on Law
Enforcement and Social Justice.  We dreamed up the name one day so we
could sound "more official".  There was no such "group" other than our
letterhead.  But that was not unlike how Scientology front groups
operate.  We simply created letterhead and pretended that there was a
real organization behind it.  (If anyone ever challenged it, would we
have been able to go out and get a few people who would claim they were
active members to refute criticism.)  It was from the NCLE "group" that
I conducted research and found that Interpol (the International Criminal
Police Organization) had a Nazi history.  (Scientology's other main
target in the US was the Federal Bureau of Investigations.)  This
enabled Scientology to gain considerable media coverage for years around
the world.  It also allowed me to testify twice before Congressional
Subcommittees and to appear on scores of radio and TV shows, including
one hour on Ton Snyder's "Tomorrow" show.


     79.  For my success, I was then sent to England where the
Guardian's Office World Wide (GOWW) was located.  I was given additional
training in PR and learned how the other bureaus operated.  I was able
to read confidential files and reports about activities around the
world.  I was thus given an international perspective in PR, Finance,
Legal and Intelligence as well as the operations of organizations.

     80.  I also traveled through Europe and met with staff in the
organizations in England, France, Netherlands, Denmark, Germany, Austria
and Belgium, giving me additional insight and information into the
operations of Scientology around the world.


     81.  In July of 1977, the Federal Bureau of Investigation raided
two Scientology locations in Los Angeles and one In Washington, D.C., in
what was then the largest raid in the FBI's history.  The target of
their raid was the Intelligence Bureau of GO US and GO DC.  Within hours
I was selected as the national spokesman and briefed as to what to say.
I held a press conference at the Los Angeles Press Club on Vermont
Avenue while the raid was in progress.  I was the spokesman for
Scientology US in the days that followed as the media continued to call.

     82.  The FBI took thousands of documents that the United States
Attorney's Office used to convict Hubbard's wife Mary Sue and ten other
GO personnel.  Hubbard and a number of other Scientology executives were
named as unindicted co-conspirators.

     83.  Before the trial, I was allowed access to the documents that
the government was going to use.  I read thousands of highly
confidential dispatches including communications amoung the highest
executives in Scientology.  That was the first time I learned about the
extent of the illegal activity occurring in the Intelligence Bureau.  It
also showed me my superiors had mislead me by misrepresenting to me the
magnitude of the criminal conduct and then using me as a national
spokesperson who could convincingly represent there was no wrongdoing,
that the prosecution was all "harassment" by the FBI and etc. because of
my actual ignorance.  The extent of criminality was subsequently
detailed and documented in the 284-page Stipulation of Evidence that was
used as the sentencing of the executives.  This publicly available
document, was kept away from rank and file Scientologists.  It
completely refutes the position that was taken by me and by others,
especially in the years to follow.

     84.  While preparing for that trial, I was sent with a team of
people to Washington, D.C., in 1979, to try and create positive press
that would offset the bad press being generated.  During that time, my
team worked with documents we legally gathered from government files
already obtained under the Freedom of Information Act and generated
several stories that went around the world.  These stories were about
secret chemical-biological warfare testing by the Central Intelligence
Agency and the U.S.  Army.  These stories were also written up in
FREEDOM, under my byline, "Vaughn Young."  (Footnote:  This, like other
material I published while I was in Scientology appeared under the name
Vaughn Young.  I did not use my legal first name "Robert" until after
fleeing from Scientology in 1989).  FREEDOM was published by the
Guardian's Office.  I was also cited in other Scientology publications
and issues as an expert in my field.

     85.  In 1979, my book the Interpol Connection was published by Dial
Press, a non-Scientology publisher.  The book is the compilation of all
my research.  My co-author was a non-staff member who was hired to help
with the writing/composition of the book while I continued my
researches.  I am identified in the book as the Director of Research for
the National Commission on Law Enforcement and Social Justice, which, as
stated earlier, was merely a front organization.


     86.  After the conviction of the Scientology executives, I returned
to Los Angeles to head the Specialist Branch at PR US which created
booklets, Freedom and other publications.  During that time I authored
additional stories for Scientology, some of which went international
such as the story about "BZ" a hallucinogenic drug that the Army was
testing.  (This was also written about in Freedom as well as in other
Scientology publications.)  Also during my tenure in the GO, I worked to
help produce several books about Scientology that were published by
Scientology and outside authors, such as Omar Garrison.


     87.  Circa 1978, I joined the Sea Organization ("Sea Org" or SO)
and subsequently trained and earned rank in the Sea Org.  SO members
live and eat communally.  SO pay was $24 a week.  We lived in a
converted single-bed hospital room in the large Scientology complex near
Sunset and Vermont Streets in Los Angeles.  Food was available in a
large dining area on the first floor.  We had no private shower but used
a communal shower down the hall.  Thus I am also intimately familiar
with the Sea Org life style.


     88.  In 1980, I was told that a secret location where Hubbard had
stayed was being exposed in the media.  The location was at Gilman Hot
Springs, near Hemet, California.  My task was to go and defuse the
situation.  The location was actually the secret international
headquarters of Scientology that also had a tape and film production
unit.  I took command of the base, converted it to look like it did
nothing but film and tape productions and presented it to the media as
Golden Era Studios, effectively defusing the situation.  It is an image
that the base still carries today, even though it is still the
international headquarters of Scientology.


     89.  In 1981, I was asked to go to a non-GO archives to gather
information about the writing of a biography on Hubbard.  The archives
was operated by Gerry Armstrong and contained about 25 filing cabinets
full of Hubbard's personal papers and memorabilia.  I worked there for
several weeks and was the last person to see Armstrong before he
disappeared.  I thereby inherited the archives by default and continued
to read Hubbard's private papers, which gave me not only an entirely
different view of the man than what we had been telling Scientologists
but a view that no one else knew (at that time) besides Armstrong.


     90.  During this time, the GO was being converted to the Office of
Special Affairs.  This was done under the direction of Vicki Aznaran who
later became Inspector General and has since left Scientology.  While it
was later touted that the GO had been "disbanded," the truth was that it
was really nothing more that a name change.  The same people were
running the group.  We had the same offices.  We had the same policies.
What did occur was the power base moved from the GO to something called
"Special Projects" which was being run by David Miscavige ("Miscavige").

     91.  The problem that OSA was facing was the inundation of lawsuits
naming Hubbard as a defendant.  He had gone into hiding and a unit had
been set up to handle all the lawsuits.  It was called the "All Clear
Unit".  The name gave its objective:  to create an "all clear" for
Hubbard so he could come out of hiding.


     92.  In early 1982, Miscavige asked me to head Hubbard's
international PR network.  I agreed.  I was taken to the international
headquarters at Golden Era Studios and introduced by Miscavige to the
then-Commanding Officer, Commodore's Messenger Organization
International (CO CMO INT), John Nelson.

     93.  After my return to LA, I was asked to join Special Project
instead.  That was when I learned that Special Project was really the
newly formed Author Services, Inc.  (ASI).  ASI was a for profit group
that was ostensibly created to be Hubbard's literary agency.  While ASI
had that function, ASI's actual functions were:  (1) to run the "All-
Clear Mission" by running the GO/OSA which required constant meetings
with ASI and GO/OSA staff usually chaired by Miscavige; (2) to make
money for Hubbard; (3) to run the Church of Scientology to accomplish 1
and 2. This last function was carried out in secret since we were a for
profit corporation and the Church of Scientology was fighting the
Internal Revenue Service for its non profit status.  Thus, our directing
the "All Clear Unit" was also a well-kept secret.  My promotion to ASI
was personally approved by Hubbard in a dispatch titled "Vaughn" that
defined the PR position that I was assuming.  My initial Position was
called Public Affairs Special Project.  It was worked out with Hubbard
that "Public Affairs" would be used so it could easily differentiated
from "Public Relations" which would designate those in the non-profit
area.  When we moved to offices at 6464 Sunset Boulevard in Hollywood,
my position became PA ASI (Public Affairs, Author Services, Inc.)

     94.  My primary function was to run Hubbard's public relations
network in the Church of Scientology that extended around the world.
This network was embedded mainly in what was called the "LRH Comm
Network" or L. Ron Hubbard Communicator Network.  LRH Comm's were
supposed to be his personal representatives in each organization.  To
execute my functions, I ensured that a person was appointed to head the
network internationally and met with her and her juniors regularly,
issuing orders on what to do.  One of the projects was to get
"recognitions" for Hubbard, which were keys to cities, commendations,
etc.  These were usually collected without the issuer knowing who
Hubbard was.  Sometimes the "recognition" would be withdrawn when they
learned who he was.

     95.  Since ASI was the senior Scientology organization, regular and
numerous legal strategic meetings with Office of Special Affairs
personnel were held at ASI.  Miscavige who was the Chairman of the Board
of ASI often chaired the meetings.  The object of these meetings was the
many lawsuits that included Hubbard as a defendant and how to deal with
the suits.  I sat in on many of those meetings and witnessed the orders
being given to church personnel on what to file, who to depose, what to
object to etc.  Most of these orders came from Miscavige.

     96.  We also held meetings at ASI to direct other church staff on
what to do.  These meetings were often for the purpose of raising
additional money or ordering the organizations to pay large sums of
money to ASI.

     97.  ASI also handled Hubbard's investments in gold, oil wells,
etc.  To this end, additional corporations were created out of ASI.
Some were intended to protect Hubbard's money, others to create a buffer
between him and the non-profit Church of Scientology so that a legal
link could not be made.  Some of ASI's repsonsibilities were
subsequently moved to some of those entities, such as the Religious
Technology Center.


     98.  ASI was also the focal point for "intelligence."  Since the
Intelligence Bureau had been decimated by the FBI raid and the
subsequent conviction of the top leadership, what was worked out to
prevent this from happening again was to assign the more sensitive work
to private investigators and to assign it to the attorneys and to call
it an "attorney work product."  However this was in name only.  Private
investigators worked directly with those of us who needed them.  I
personally directed such work and saw it being directed by others,
including Miscavige.  As it was explained to me, most of it was billed
to the Church of Scientology by the attorney who paid the private
investigator, even though he reported directly to us.  Therefore, I am
familiar how the legal and investigative arms of Scientology came to
develop after the Guardian's Office was "disbanded".


     99.  At times, Hubbard personally ordered me (via written dispatch,
transcribed from a tape) to go to Gilman Hot Springs to handle various
situations for him.  I went on assignment from Los Angeles on perhaps as
many as 70 times.  These ranged from the handling of the Golden Era
Musicians to the handling of his family.  During these many visits, I
became intimately familiar with additional duties of the international
organization, from music production on to the management of

     100.  Additionally, ASI went to Gilman Hot Springs every week to
prepare packages of information on the operation of Scientology that was
secretly shipped to Hubbard who was in hiding.  In turn, he sent us
orders.  This was done by him on tape which was transcribed and then
sent out.

     101.  Also while at ASI, I ghosted material for the missing
Hubbard.  Some of this was read to Scientologists at large meetings as
greetings from Hubbard or issued as directives from him, including

     102.  I was also Hubbard's editor for Mission Earth, a one-million-
plus word work that was delivered to ASI.  I cut it into 10 books,
proposed the titles, wrote introductory material and got the work ready
for publication.


     103.  In 1984, after Gerry Armstrong was sued by the Church of
Scientology, David Miscavige assigned me to do key research into
Hubbard's life to refute Armstrong's claims that Hubbard had lied.  With
a team of full time people working for nearly two months (compared to
Armstrong working by himself), we found additional information to
challenge some points Armstrong had made.  I was to testify as to what
had been found.


     104.  When Hubbard died in 1986, I was one of perhaps 10 people
that were selected to go to the location, which was a ranch north of San
Luis Obispo, California.  We arrived shortly after his death and well
before any authorities.  Since Scientologists had not been told the
truth of Hubbard's deteriorating condition, the task was to quickly
create a story that would be acceptable to the media as well as to
Scientologists.  My area of responsibility was the media that might call
and/or show up.

     105.  I stayed at the ranch for months.  During that time, I gave
interviews to or dealt with the media who called or who showed up at the
ranch.  I also became good friends with Pat Broeker, who had lived at
the ranch with Hubbard and who was the liaison to all Scientology
entities and learned more about the Hubbard and the operations of

     106.  When there was concern that another secret Hubbard ranch near
Barstow might be discovered, I was sent to stay there.  I stayed at that
location for perhaps another two months.


     107.  A power struggle ensued after Hubbard's death between Broeker
and Miscavige that Miscavige won.  Since I had been close to Broeker, I
was caught in the purge and sent to the "Rehabilitation Project Force"
(RPF), a Scientology gulag hidden behind an Indian reservation near
Hemet.  Those on the RPF are kept at hard labor under 24 hour guard
until they are "rehabilitated," which means no longer thinking critical
thoughts.  I escaped down a dry river bed one night but was caught in
Hemet.  I finally ended up spending 14 months on the RPF, with
deteriorating health (confirmed by medical examination.)

     108.  I was returned to ASI and was assigned the task of producing
additional "Ron Mags," a publication that my wife and I had initiated in
1982 that were about Hubbard.  When I refused to follow an illegal
order, I was physically assaulted and beaten and sent back to Gilman Hot
Springs for "handling."  Pretending to be better, I went to Los Angeles
to see my wife and told her about the situation.  Before leaving Los
Angeles, I wrote a report about the beating and sent it to OSA attorney
Kendrick "Rick" Moxon.  We put a few clothes in the car and left on July
3, 1989, leaving the rest of our belongings behind simply because it was
not worth the risk to try and retrieve them.


     In short, all Hubbard policies which created Fair Game are still in
effect, including Guardian Orders, and will remain in effect as
"scriptures" until he changes them.  This, of course is impossible
because Hubbard died in 1986.

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

     Executed this 25 day of October 1993, at Los Angeles California.

     Robert Vaughn Young