Kennan Dandar Dandar & Dandar
1009 North O'Brien Street
Tampa, FL
Tele: (813) 289-3858


ESTATE OF LISA McPHERSON, by and through the Personal Representative, DELL LIEBREICH,





Case No.: 97-01235


I, ROBERT VAUGHN YOUNG, declare and say:

1. I am over eighteen years of age and am a resident of the State of Washington. This declaration is of my own personal knowledge and if called upon to testify to the facts herein, I could and would competently testify thereto.

2. I have read the affidavit of Jesse Prince recently filed in this case and am qualified to address its validity and relevance. I was in the Scientology organization for nearly twenty-one years and am familiar with the organizational structure he describes and its procedures. For that reason, I have been retained by counsel for the plaintiff as an expert consultant. I also happen to have known Mr. Prince while in the organization.

3. At issue in this case is the command structure of Scientology and the issue of who might have known what or issued orders regarding the incarceration of Lisa McPherson. The organization is seeking to keep the controversy isolated to the Clearwater organizations, but this is not how Scientology has ever operated. I will explain how it operates and how a corporate "shell game" is employed to baffle and thwart the courts and the authorities.

4. The current corporate structure of the Scientology organization was created (starting in 1981) to prevent the intrusion of the courts and the authorities, by throwing up what appeared to be distinct corporations. This structure came about after the FBI raid of Scientology in 1977, which produced considerable evidence that the organization had been burglarizing federal (and other) offices as well as conducting other illegal activities. For these activities Mary Sue Hubbard, the wife of Scientology founder L. Ron Hubbard and ten of her executive staff were jailed. Hubbard, himself, was named as an unindicted co-conspirator.

5. At that time, the Scientology corporate structure had been pretty much an afterthought, created merely to do business. The actual structure had evolved over the years and was fairly simple and was never effected by the incorporation of various entities over the years. No one paid any attention to the corporate structure. At the top of the actual structure was Hubbard with his aides. His wife, Mary Sue, headed Scientology's Department 20 which concerned itself with external matters, such as the media, government licenses or inquiries, the courts and perceived or imagined critics or "enemies." This section was known as the "Guardian's Office" (GO).

6. I was asked to join the Guardian's Office in 1971, because of my PR (public relations) and media experience. (I had been working for over two years at a Scientology franchise.) I joined the San Francisco GO as an "Assistant Guardian for Public Relations" and was trained at the US (national) GO in Los Angeles. My training was not only in PR but the entire structure of the GO and how it interfaced to the rest of the organization. When I was done about five months later, I returned to the San Francisco GO, which was responsible for all external matters in Northern California. I held that position until I was promoted to the PR Bureau in the USGO in 1973, where I remained until early 1982.

7. The GO was headed by "The Guardian" who was headquartered in the United Kingdom. The GO initially had four bureaus, each headed by a "Deputy Guardian" for that bureau: PR, Legal, Finance and Intelligence. PR took care of media and public officials. Legal took care of all legal matters, including court cases. Finance oversaw the income of the organization. The Intelligence Bureau dealt with internal security (not only within the GO, but for all Scientology organizations) as well as gaining information about any external "threats." This meant surveillance via spies, plants and agents.

8. A "Tech" (technical) and "Social Coordination" bureau were later added in the early 1970's. The Tech Bureau oversaw "auditing" (Scientology's counseling and confessional method) and the Social Coordination Bureau coordinated the various front groups where Hubbard was seeking to have his material accepted on non-religious fronts, such as drug rehabilitation and study methods. These groups represented themselves as not being affiliated with the Church of Scientology but were being controlled by the GO to make sure they made inroads and money.

9. Every continent had a "Deputy Guardian" ("DG") for that continent, with a replication of the same bureaus. Thus the US had a DG for PR, Legal, Finance, Tech, Social Coordination and Intelligence. Every major organization replicated the structure again with an "Assistant Guardian" ("AG"). Thus in the US there would be an AG San Francisco, Los Angeles, Washington, DC, Miami, Detroit, etc. In fact, the presence of an AG's office was what designated an organization as a "Class IV organization" (org) vs. the franchises.

10. Prior to the 1981 re organization, the GO had more power than the Sea Org. The GO (from the actual Guardian and down through to the AG's) had the power to confiscate the bank accounts and to take control of the local organization. This was given to the GO by Hubbard and was to be exercised if the organization was failing or threatened, perhaps by a lawsuit.

11. Complementing the Guardian's Office (GO) was the Sea Organization ("Sea Org" or SO). The SO directed the day-by-day internal affairs of the organization while the GO took care of external affairs. In fact, Hubbard even wrote how "the two most effective arms of Scientology" were the GO and the SO. He ran the SO and his wife ran the GO. This was done from the ship "Apollo" where Hubbard had been forced to take refuge, in the Mediterranean. He assigned himself the SO rank of "Commodore." The Apollo was known as the "Flagship" or "Flag."

12. Between Hubbard and his immediate aides on the Apollo were FOLOs (Flag Operations Liaison Office) which were fully staffed by Sea Org personnel. Each continent had a FOLO, just as it had a Deputy Guardian's office. The FOLO took orders from "Flag" and replicated Hubbard's aide's structure there, as each GO replicated it's higher command echelon. The purpose of the FOLO was to relay orders from Flag and to send reports and information (to Flag). They were the "middle management" echelon. These units were all set up without regard to corporate structure, which was there just to make things look legal. The paradigm that Hubbard was using was the military structure, which was why there were ranks and echelons and command channels. If one is to understand how the organization is actually structured and operates, the military model is the one to use.

13. Hubbard was enamored of the military lifestyle. The Scientology structure, the language, the types of directives and the manner of command follow a military (in his case, naval) model. Ranks were assigned along with uniforms and military procedure. Many of his directives employ military language. He wrote often how one should plan with military thinking and strategy and peppered his directives with military language. In that vein, there was military discipline.

14. On the ship, Hubbard had "aides" who operated as his personal council. They were known as "Commodore's Staff." Mary Sue was "Commodore's Staff Guardian" or CS-G. While she (and all the others) held Sea Org ranks, the GO itself (off the ship, in various countries) were not Sea Org. The reason was to keep the GO away from the SO command channels, because of the nature of the GO's work, especially the Intelligence Bureau. It was also to keep the GO at "arm's length" from Hubbard, should anything go wrong, which is exactly what happened with the FBI raid of 1977, which will be discussed later.

15. The GO (as well as other organizations) all reported up the command channels in a similar fashion. Each section of each bureau made its reports as to activities for the week. This was compiled by the AG and forwarded to the DG (the continental bureau) which collected the reports for that area (and possibly recompiled them) and forwarded them to The Guardian who did the same with her area and then forwarded them to CS-G (Hubbard's wife) who reported to Hubbard himself. This was also done for individual orders that may have been issued by Mary Sue Hubbard or any junior. When the order was done, a "compliance report" was sent back up the command channel.

16. Reports were also made on threatening situations, as soon as they happened, e.g., a lawsuit, a bad news story, a death, or anything that posed either a legal problem or an embarrassment. These reports were made immediately along with a plan for "handling" the "situation," as they were called. The situations and ongoing handlings were then reported on weekly or whenever there was some change or development. If it involved other bureaus (such as a lawsuit that produced media) then there was coordination between the bureaus. A "program" (a series of steps to "handle" the "situation" was often written and proposed for approval or issued and had to be followed with "compliance reports" as to each step. (This reporting method was kept in place despite reorganizational changes.)

17. In 1977, the FBI conducted what was then the largest raid in the history of the bureau. Their target was the Intelligence Bureaus in DC and the US headquarters in Los Angeles. An Intelligence Bureau agent (Michael Meisner) who had participated in burglaries and wiretapes of federal offices had defected and talked. With that information, the FBI conducted its raid and walked out with hundreds of thousands of documents detailing how Intelligence Bureau agents had infiltrated the government (as well as private companies) and been stealing files. (There was a considerably more that they were doing, illegally.)

18. On the day of the raid, I was at the Los Angeles headquarters and was named the "national spokesman" to respond to the charges then and in the months to follow. The GO tried to denounce Meisner, just as the leadership is eager today to denounce Jesse Prince and me and anyone who speaks out. But their problem was that the FBI had the incriminating documents to show that the GO Intelligence Bureau was operating on a Hubbard-written program (code named "Snow White," which was cited in the search warrant) and were writing compliance reports to him and Mary Sue Hubbard. Weekly and "situation" reports were also going to them. It was only by the narrowest of margins that Hubbard himself was not indicted but he was named as an unindicted co-conspirator, along with dozens of others.

19. The raid and the subsequent legal threats tore the GO to shreds. One of its primary functions had been to keep Hubbard at "arm's length" and away from any legal threats and now the floodgates had opened. One lawsuit after another named him because he was not only implicated with his Snow White program but it was clear that the entire organization was operating on his tactical and strategic policies.

20. With the raid, Hubbard went hiding to avoid being served. Meanwhile, despite the screams and protestations about "religious persecution" that the GO was issuing, Mary Sue Hubbard and the 10 named aides signed a "Stipulation of Evidence" and accepted the charges and went to jail. With her and The Guardian and other key executives jailed and Hubbard in hiding, elements of the Sea Org moved in to take command. A "corporate sortout" project had already been underway to restructure the organization to allow Hubbard to return and take command and to give him new protection. This was augmented by a "Special Project" headed by David Miscavige that went to Los Angeles in 1981 to take command. Amongst their tasks, was the secret creation of several corporations, including Author Services, Inc. (ASI) and Religious Technology Center (RTC).

21. In early 1982, I was invited by Miscavige to join "Special Project" to head up the PR section. The idea was forwarded to Hubbard who approved of my appointment in mid-February. I was then informed that "Special Project" (and Miscavige was "Special Project i/c" or "in-charge") was in reality ASI but we could not admit to it yet.

22. ASI was formed as a for-profit corporation on the guise that it was Hubbard's "literary agency." While we had that function, our actual function was to be Hubbard's contact point back into the Scientology organization. (He was long gone from the ship and had no viable command channels because he was in hiding.) We at ASI reported to him and he issued orders to us (how this was done will be taken up later) which we then issued down into the organization, thus making ASI the most senior entity in the Scientology hierarchy. This did not come easy for Hubbard was prevented from saying that ASI was his replacement for "Flag" because that would have defeated the entire purpose and linked him back to the non-profit churches. So there was considerable arm-twisting and threats and demotions as Miscavige and ASI consolidated its power over the very Sea Org units that had been in control. (ASI was, by the way, staffed only by Sea Org personnel. I had joined the Sea Org earlier.)

23. In mid-1982, ASI established itself in private offices at 6464 Sunset Boulevard with about 15 staff. Any visitor would get the impression that we were merely Hubbard's "literary agency" since we did have that function. While even the most prolific authors might have one agent in a firm, Hubbard had (for starters) 15 who worked for him and when we were asked why such an imbalance, we said it was because he was "so prolific." The truth was that the "literary agency" part took little time. So many were needed because ASI was running the Scientology empire, along with his book sales and personal finances.

24. Because ASI was at the top of the Scientology empire, it was often the site of meetings with various officers from different Scientology organizations. They had come to learn that we (at ASI) were now Hubbard's personal representatives and spoke for him so the ASI boardroom became the site of clandestine meetings of various corporations so Hubbard's orders could be issued. Of course, this was all quite illegal since ASI was a for-profit corporation and we were issuing orders to non-profit entities. We had simply replaced the earlier structure and disregarded corporate lines as we had always disregarded corporate lines. The difference was that the power was no longer distributed between the GO and the SO but held in one place: Miscavige and the ASI that he controlled.

25. ASI was the site of meetings (often chaired by Miscavige) that directed legal strategies, telling different corporations and their attorneys what to do or what to sell and how much money should come to ASI, which was then funneled into Hubbard's personal accounts. If anyone disagreed, they were simply removed and replaced with someone who complied.

26. Throughout this period, Hubbard issued his orders as "advices," rather than "orders," and attempts were made to make him a "consultant" while he was busy doing "writing and research." In truth, he was fully in command as much as he had been when he was on the ship Apollo. David Miscavige was in charge of ASI and he had assumed the title of "Chairman of the Board" (COB) of ASI so he (and we, if necessary) could claim that he was not the Executive Director or an officer of ASI. This was done to give him an "arm's length" protection, just like Hubbard, to avoid any litigation. But titles aside, there was never any question in the minds of the Scientology hierarchy who was in charge: David Miscavige.

27. This became known to the field in 1982 when Miscavige organized a "Mission Holder's Conference" in San Francisco. (The franchises had been renamed "missions" to give them a better religious image, for the purpose of a sought-after tax exemption.) With all of the shakeups and Hubbard being unable to appear, the "field" (meaning the franchises) was threatening to revolt. Mission holders (those who owned the franchises) were protesting new demands for more money and more control being exerted over them. Gathering staff from ASI (and one from another Sea organization), Miscavige and his crew donned Sea Org uniforms and took over and terrorized the Mission Holder's Conference, even expelling some of the franchise holders on the spot and threatening to do the same to others who protested. It was a show of brute Sea Org strength and it was even touted in the "Sea Org Expansion News[letter]" that was sent to all Scientologists, showing that Miscavige and the Sea Org were now fully in control. A true and correct copy of the Sea Org Expansion News entitled "The Sea Org Moves In" is attached hereto as Exhibit "A." The guise, of course, was that they were "protecting the Tech" or getting people "on source" (meaning following Hubbard's directives) when really it was nothing more than a consolidation of power. It worked. The dissenters were shut up. I did not attend the meeting but I listened to the "war stories" of Miscavige and some others from ASI who went with him (Norman Starkey and Lyman Spurlock) when they returned to ASI, laughing and boasting how they are terrorized this or that person and how successful their "raid" was.

28. In 1983, we were told that, according to some of our intelligence sources, the IRS was considering a raid on ASI and possible some other Scientology organizations. There was no doubt in our minds what they would find if they got our documents, as the FBI had done in 1977. Such documents would have shown Hubbard running the Scientology empire via ASI and our bleeding it for millions of dollars, most of it under the guise of "licensing agreements" drawn up by Spurlock, all of the money going into ASI's and then Hubbard's personal accounts. Some moneys were converted to precious metals or jewels that were couriered directly to Hubbard. Some were couriered to overseas banks (usually in Luxembourg or Liechtenstein) that had secret accounts in his and ASI's names. (This allowed him to tap into them directly, should he need the funds.) Since ASI was incorporated as a for-profit organization, we knew that ordering non-profits to come up with incredible sums sometimes in a matter of hours (a $25,000 "licensing fee" from just one organization was not unusual) was all in violation of IRS laws and it could put Hubbard and ASI at risk. So we implemented Miscavige's orders to hide the evidence.

29. We were ordered to go through our files and to pull all correspondence with Hubbard that involved his or our connection to the various Churches of Scientology. Since that had been mostly what we had been doing for years, it was most of our files. These documents were then gathered and moved down to an office that had been quickly rented on the fourth floor. (We were on the ninth floor.) When we were done, there were perhaps 20 four-drawer filing cabinets filled with documents connecting Hubbard, ASI and the various Scientology organizations. The room had a 24-hour guard that rotated amongst ASI staff (about every two weeks), including myself. We had to do our work there and then at night, we slept on a cot. We were connected to the main ASI office by telephone and radio, as well as TV surveillance cameras, with orders that should anyone demand entry (such as the IRS with a search warrant) to sound the alarm while refusing entry. We also had the home phone numbers of our attorneys should the raid occur after hours, refusing entry until they arrived and took action. This secret office was maintained for a couple of months, until we were finally told that the crisis had passed and we could return to some degree of normalcy.

30. At the same time that we were briefed to take action to hide our connection to Hubbard and the Scientology "nonprofits," Other Scientology executives were called to the ASI boardroom and given the same briefing and told how to implement actions at their end.

31. After this "near call," it was decided to beef up the Religious Technology Center (RTC) to take some of the functions from ASI, thus reducing the threats. Until then, RTC had been junior to ASI only because the most senior organization was where Miscavige was working. (He also had an office at Golden Era Studios at Gilman Hot Springs, California. That was where Hubbard's orders physically arrived, via a courier, and compliances and monies were sent to him. Pat Broeker was the courier. He was Hubbard's closest aide and companion at the ranch where Hubbard was hiding. No one, not even Miscavige, knew where that was. As it turned out, if was a few hours away.) Miscavige began to spend more time at RTC, which was taking on the function of running Dept. 20, which was renamed as the "Office of Special Affairs." RTC could thus be the "enforcement" section so ASI personnel didn't have to implement another "Mission Holder's Conference" and put Miscavige in the limelight.

32. In 1985, an adverse court ruling in Portland, Oregon, prompted Miscavige to show his command. He called in key Scientology executives to the ASI offices and ordered that 100,000 Scientologists flood into Portland to protest. He ordered organizations to charter airplanes, empty their course rooms, send their staff and do anything to meet that quota. (The actual number turned out to be more like 5,000, which was still impressive.) I was sent from ASI to take command of the PR aspects of the massive protest. (Except for a meeting with the editorial board of the local newspaper and then giving some quotes to the New York Times and the St. Petersburg Press, I kept a low profile, using my staff to coordinate and implement actions.) We all represented ourselves as "individual Scientologists" when really the entire event was strongly coordinated and directed by Sea Org personnel reporting directly to Miscavige, who came several times to see how it was going.

33. When Hubbard died in 1986, I was one of a ten-person contingent (it included attorneys and was headed by Miscavige) who were rushed to the ranch that night. (My task was merely to take PR control of the area, should it be needed.) It was there that the story how Hubbard had "moved on to his next level of research" was concocted for the announcement to Scientologists in Los Angeles. I stayed on at the ranch and got to know Pat Broeker. When a power struggle ensued between Broeker and Miscavige and Miscavige won, and I was sent to a Scientology "rehabilitation" camp for 16 months as part of the purge of people loyal to Broeker. Miscavige declared (using his Sea Org rank) that a "final message" from Hubbard that put Broeker in command was a forgery. (No other "final message" was ever produced, which would have been quite unlike Hubbard to not leave one.) Miscavige was now in full control. I "graduated" from the camp as "rehabilitated" and returned to ASI in 1988. By that time, Miscavige had moved fully to RTC which was now in control of ASI and every other Scientology organization, because Miscavige was running RTC. I fled in 1989.

34. In my nearly 21 years in various Scientology organizations and echelon, from when Hubbard was in charge to after he was dead, the basic structure and operation of the organization never really changed all that much. The manner in which orders were issued or situations reported remained on a military model. Whether the orders came from Hubbard or Miscavige, the manner that they were issued and enforced never changed even when the organization name (the GO or RTC or ASI) changed. Nor was compliance and reporting ever changed. Corporate entities were merely ways of giving the impression that there was a different structure when there wasn't one. We didn't pay attention to corporate structure before the 1977 raid and we didn't pay attention to it after the reorganization of 1980-81. The only difference was the power of the Sea Org and the Guardian's Office was consolidated. The task of executives remained the same: forward orders from "command" while ensuring that the senior not implicated if anything goes wrong. If this meant hiding or destroying documents or shifting personnel or even lying, it was done. That is an unchanging pattern that the organization developed with Hubbard and then Miscavige. Just as an army protects its general or command central, so does Scientology (working on the military model) protect those who are in command.

35. I have seen the protests of the higher level organization that they knew nothing of Lisa McPherson, from the time of her initial automobile accident to her isolation to her death. To the uninitiated, this seems plausible. To those who know how the organization works, this is ludicrous. That excuse has been conjured up by the organization for every flap to protect the hierarchy. Sea Org members (as it was true for GO members) deem it their duty to "take responsibility" and let the buck end with them when "senior command" is threatened. For example, when the 11 Guardian Office executives were indicted after the 1977 raid, not one of them cooperated with the authorities, even for a reduced sentence. They would rather go to jail than to implicate Hubbard or even Mary Sue, regardless of the documented evidence. Only people of that mind are allowed at that echelon and that is what is being presented to this court. Only the most fanatically loyal who are willing to sacrifice themselves to protect the courts or the authorities from reaching "command" are brought forward. Those who say otherwise (such as myself or Jesse Prince) are denounced as viciously as we denounced Michael Meisner in 1977, trying to convince the courts and the media that he was a low-level, lying clerk who was in it for personal gain. That is the reaction of any group who seeks to hide the facts and protect its leadership. Like Mafia leaders, suddenly they are just little, innocent businessmen with families being persecuted by bigoted law enforcement agencies. Those who claim to have inside knowledge are denounced as frauds. But those of us who do speak out have more than our own experiences to show the courts and the authorities. We have the long, unchanging pattern of behavior of this organization not only in the US but in other countries where it has been documented that the organization will lie and cheat and defraud the government and the courts to protect itself.

36. Thus based on my nearly 21 years experience in doing just that (my task was to manipulate the media and the membership), I fully concur with Jesse Prince's conclusion that there is no way that the highest echelon of this organization did not know about Lisa McPherson. From the time that she took off her clothes in the street, she presented herself as at least a PR danger, if not a legal one. Those reports are instantly sent to the top of the command channel with recommended handlings and the lowest echelon knows that it cannot admit to it because it would involve "command." They must "make it their own" (to quote a Scientology communications drill called TR1) even if it wasn't theirs to begin with. Every staff member learns this very early on. "Make it your own" means that it is yours, even if it isn't. Thus the staff member who gets an order from Miscavige must "make it their own" which means that if asked whose idea it is, the staff member is capable of saying in all honestly, "It was my idea," even if it wasn't. That is TR-1, one of the most basic instincts drilled into every staff member for years.

37. Jesse Prince also knows how this organization operates, despite their protests or attacks on him. I knew him when he held his positions and what he described in his declaration is either true by my personal knowledge or fully consistent with what I know about this organization and its policies and its history. I can find nothing in his declaration that contravenes that experience. I also know that for telling the authorities what he has that he will be subjected to intense attacks. It is in the nature of the organization. It can do nothing else but deny and attack. These are Hubbard's policies (collectively known as "Fair Game") and they do not change, which is why the organization does not change. It cannot.

38. Like Mr. Prince, I too have seen records kept on Lisa McPherson and I concur that she was held against her will with the knowledge and consent and direct orders of Scientology executives that would come directly from the Religious Technology Center (RTC.) RTC would have been the first to be told and be kept updated, as Mr. Prince states. The saddest part is that the organization demands such information not for the benefit of the person involved or hurt but to protect the image of the organization. The Scientology maxim is, "The greatest good for the greatest number." When it comes to protecting the organization itself, that determines the morality of the act. It is "the end justifies the means." That is why she was isolated and that is why there are records missing. The organization and its "command" must be protected at all costs. That is why Lisa McPherson died.

39. In conclusion, let me say that any attempt to say that these various Scientology organizations are distinct and separate is like saying the kidneys and lungs are separate organs of the body. They are but they are connected and controlled by a blood, endocrine and nervous system and in Scientology that nexus is the Sea Org. It connects and commands the entire Scientology empire and has since Miscavige took control in 1982.

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



[signed 10/6/99 - filed 10/7/99]