1. I, Roxanne Friend, make the following declaration on personal knowledge except for those statements made on information and belief and as to those things I believe them to be true.

2. I have been told that I am asking the court to determine the validity of Scientology as a religion or the truth or falsity of Scientology's religious concepts. If the above is true, this would include the court's having to determine the validity of Scientology's teaching that human beings are impaired by things called "body thetans" and "clusters" of body thetans that are stuck together on human bodies through no volition of their own. Accordingly, Scientology teaches that these must be gotten rid of, exorcised if you will, through Scientology auditing/counseling called the "Upper Levels." Scientology also states that planet earth, millions or billions of years ago, was originally populated by beings transported here by Xenu of the Galactic Federation. These beings were tortured, frozen, clumped together and electronically forced to reside in various volcanoes.

3. Scientology's beliefs are not the essence of my suit on fraud against the defendant. Is is my contention that Scientology was presented to me as a science. It was my understanding that everything about Scientology could be proven factually in the same manner as a scientist proves a scientific fact. These points are discussed at length in many Scientology publications. The Scientologist is not exposed to the above teachings until long after he/she has been indoctrinated into the group and subjected to mind control. Thus, for me, it became impossible to see the conflict between the scientific pretenses of Scientology and the "beliefs."

4. As I stated on page 717 of my deposition, I never accepted Scientology as a religion or belief and I continued to consider myself Jewish throughout my association with Scientology. I was also told that Scientology attempted to gain its status as a religion for two purposes--one being to avoid taxation for the organization and its constituents; and two, being to avoid having to come under scrutiny for its practices of Scientology and the far-out nature of the Upper Levels while I was still a member.

5. I continually and constantly relied on the teachings of L. Ron Hubbard, the organization and the classes, auditing and publications of Defendants. This occurred during a period spanning twelve years and eight months from May 1977 to January 1990.

6. Originally, I was given a book entitled Dianetics: The Modern Science of Mental Health. I did not know it then, but this book is the basic Scientology text, referred to as Book One, and it is re-read and re-studied throughout the various levels of Scientology. In this book, Hubbard claims that all his teachings were an exact science. It was this claim that there was an exact science that could be the answer to all mankind's problem that seduced me into Scientology. Hubbard, and the Defendants, also claimed that it was a truth of science discovered by studies based on the scientific method, that unwanted emotions can be cured forever by addressing them psychosomatically with dianetics auditing.

7. Sometimes it is difficult to address the difference between how I feel now, having left the "church" of Scientology versus how I felt while I was actually going through all this. I have had two years of counseling that has helped to release me from some of the mind control techniques and indoctrination techniques that were repeatedly used on me even during times of sleep and nutrition depravation and during times of great emotional pain and distress such as deaths in my family.

8. While I was a Scientologist, at any points where I would have a thought negatively or critically about a church executive, the organization or the techniques used in Scientology, I would have to squash these thoughts since if I shared them I would be subject to expensive auditing or other disciplinary actions or projects. This is another aspect of the way Scientology controls the thoughts of its constituents. You are trained to only allow certain thoughts or it will cost you time, money and your pride since you will be punished for thinking thoughts that the organization does not want you to think. For example, you are considered and labeled a criminal if you are caught not "keeping Scientology working" and many people were continually indoctrinated into that concept (including myself) by being forced to take a "Keeping Scientology Working" course under threat of being kicked out.

9. After having read the Dianetic book on my own initially, the techniques and goals and products of Dianetics were drilled into my head on numerous occasions:

1. when I took the Basic Dianetics Book course;
2. on the Hubbard Dianetics course;
3. on the Dianetics Internship which was at the Advanced Organization of Los Angeles (AOLA), a division of Defendant Western United States;
4. on the Senior Dianetics Course;
5. on the New Era Dianetics Course which I took at the Los Angeles organization.

10. The other book that I relied on heavily that also makes repeated representations about Scientology as an empirical science and statements about improvements in health, raised IQ, better relationships and a better, happier life--i.e., that I would get all of these benefits by following Hubbard's scientific studies in his Science of Survival. I had to read Science of Survival three times. Once on my "Potential Trouble Source/Suppressive Person" course in 1977 or 1978. Then I was to redo this course between 1985 and 1989, at least once at AOLA and on another occasion when I was required to do so by Defendant FLAG.

11. To further show my reliance on the above books plus the numerous people in the organizations who reiterated the above to me, my actions and thoughts were completely attuned to what did Scientology want one to think and do. I didn't do as well as I could have at UCLA because I didn't have time to study since my days were composed of being on "course" in Scientology and getting Scientology auditing. My entire thought processes and life were completely wrapped in Scientology and I did not have a life or thoughts of my own really except what I was trained to think by Scientology and as a result of my indoctrination by classes and auditing in Scientology, thereby becoming continually reindoctrinated.

12. As I stated on pages 624-630 of my depositions, I believed that Scientology cured illnesses as this was taught to me in Scientology.

13. As I stated on pages 643 and 668, I truly believed it when I was told that Scientology was a science and not a belief system. It is only after two years of counseling that I can really even begin to face the idea that the things I was trained to practice as a science was not a science. It is very traumatic to be facing these falsehoods and the detriment the fraudulent claims have cause me.

14. During my relationship with Scientology, I was referred by Scientology to the Shaw Health Center for regular medical treatment. I was told that all of the doctors at Shaw were practicing Scientologists who used Scientology principles and techniques in their diagnosis and treatment. I was consistently dissuaded by my auditors and case supervisors from obtaining treatment from nonScientologist physicians.

15. The "Church" of Scientology forced me to participate in what they are calling religious practices that I myself did not want to participate in. For example, in the spring and summer of 1987 I was given auditing that I didn't want and was not allowed to leave Flag when I wanted to. I was made to stay there for months to undergo auditing that I did not want and even though I told them I wanted to go back to Los Angeles because my father was visiting from the east, I was not permitted to do so. During this time I went from having mono to having pneumonia and getting very ill. Still, I was made to do auditing and was not allowed to leave. I also missed being Maid of Honor at my girlfriend's wedding because the case supervisor would not let me leave to go to the wedding. The fact that being at Flag was against my will is in my deposition on page 334.

16. Then around October 1988 I was told by Flag staff member Arda Froese that I was ordered by Senior Case Supervisor International, Jeff Walker, to go down to Florida to do a special program he had written. I was then ordered to go back down and do more "Introspection Rundown". At that point I said NO.

17. In December 1989 I went back to Florida for the purpose of doing a process called the Purification Rundown but was again forced to do the Introspection Rundown auditing. I left without Case Supervisor approval which was always required prior to leaving the Flag Land Base in Florida. I left in the middle of the night and took a taxi to a hotel near Tampa airport because I did not want to be on Scientology premises or continue the Introspection Rundown. Also, I made phone calls to the Clearwater, Florida or Tampa, Florida police saying that I was being held against my will. The Scientologists had the phone in my room cut off when I did this.

18. During the period the organization had place 2-5 staff in the room next to mine who constantly watched me and intruded on my life. I had absolutely no privacy. The followed me to breakfast, lunch and dinner. If I tried to talk with police, the switchboard cut my phone off for hours on end which is mentioned in my deposition on pages 471 and 472. The "Church" of Scientology staff members. They refused to allow me even to have meals with my friends who were in Florida at the same time. Additionally, the organization did not allow me to move around freely as I wished as mentioned in my deposition on paged 476 and 477.

19. After I left Flag without permission in December 1989, I believe the organization then felt it necessary to force me into their procedures with greater force than before. This started with sending several staff members from Florida who came to my apartment in Los Angeles to try to persuade me to have auditing.

20. The staff members of the Florida Scientology organization subsequently drugged me (deposition pages 532-535) with the approval of Flag and senior officials of the "Church" of Scientology. Then they woke me up in the middle of the night (deposition page 511), took me in a recreational vehicle against my will (deposition pages 529 and 540) and subsequently held me in the RV and then in a room in Florida (deposition page 510) for a period totaling about four weeks, all against my will. I made at least two attempts to escape but I was bodily forced by the guards to return.

21. None of the above events happened with my consent. And I was kept imprisoned in Florida even after numerous written requests on my part to the staff of defendant FLAG, specifically my case Supervisor Richard Reese, stating I was being held against my will, that I wanted to leave and that I believed that what they were doing was illegal. See Exhibits 33 and 34 to Deposition of Roxanne Friend.

22. In addition to the trauma of the kidnapping and imprisonment, the Scientologists took away my privacy. In December 1989 and January 1990, I was spied upon constantly, 24 hours a day. My phone calls were monitored (when I had a phone in December); my comings and goings were reported on; and, of course, in January when I was completely imprisoned, every aspect of my life was under constant surveillance.

23. Prior to the kidnapping, I went to work, kept up with all the other regular facets of life, paid bills, and kept regular and excellent care of my horse. I had a social life, albeit one that was stifled by Scientology control. I went out regularly on Friday nights to dinner and a movie.

24. After I was released, I was unable to function at all. I could not work, I could not take care of personal business matters. I couldn't think properly or have any social intercourse whatsoever. I was so unbalanced by the experience that I was arrested for an assault and ended up under observation at U.S.C. Medical Center.

25. It is difficult to talk about and describe the feeling of being held by the Scientologists down in Florida. I felt like a hostage or a prisoner. I felt that nothing I could do could make a difference and that I better be quiet so as to protect my self. Today I am trying to pick up and arrange the fragments of my life and go forward.

Sworn to under penalty of perjury under the laws of the state of California this 6th day of December 1991.

Roxanne Friend