1. I am over 18 years
of age and a resident of the State of California. I am a director of the
Church of Scientology International ('CSI" or "the Church"),
the mother church of the Scientology religion. By virtue of my position,
I am familiar with the Church's legal affairs, and I have personal knowledge
of the matters set forth in this declaration. If I were called upon to
do so, I could and would competently testify thereto.
2. In July 1994,
another Church staff member, Michael and I spent several days in Seattle,
Washington, meeting apostate Scientologists Stacy and Robert Vaughn Young.
They left the Church in 1989, and approximately four years they appeared
as witnesses for hire in litigation against Churches of Scientology, Scientologists
or businesses owned by Scientologists. Among the attorneys who hired and
paid the Youngs for their testimony was Graham E. Berry of the Lewis,
D'Amato firm, who used their purchased testimony many times in Church
of Scientology International v. Fishman and Geertz, No. 91-6426-HLH (TX)
3. The Youngs' activities
had resulted in the Church spending considerable time and energy to correct
the falsehoods they had injected into these lawsuits. So we travelled
to Seattle to meet with the Youngs in the hope that direct communication
with them might lead them to correct their false statements and cease
their campaign against the Church. We explained this purpose for our visit
when we met with the Youngs first on July 9, 1994. We told them that recently
several other litigation opponents of the Church had stated that they
had wished we had been in direct communication earlier and it may have
prevented years of litigation and disputes. We told the Youngs that we
sought to avoid that same situation from occurring with them.
4. We were direct
and forthright with explaining why we wanted to meet with them. At the
beginning of our discussion, both of the Youngs stated that they did not
enjoy manipulating the facts to attack and embarrass their former religion,
but that economic hardship had compelled them to embark upon that course.
At the end, however, it was clear that "economic hardship" was
simply a euphemism for amoral greed. Their professed guilt about the dishonest
quality of their sworn statements could not overpower their craving for
money. Thus, we resolved nothing in those talks.
5. Stacy told us
that she believed that it would be in everyone's best interest for the
conflict between the Youngs and the Church to end. It was apparent that
the reason they were talking to us was because they found it emotionally
distressing to be involved in an occupation that required them to figure
out how to manipulate and distort facts for use in litigation. Stacy said
she could not stand living a lie and wanted out, and that Vaughn also
"hated" being involved in the litigation. We explained that
we simply wanted to resolve matters, get the record set straight, and
the Church and the Youngs could get on with their respective lives. They
agreed that this was a desirable objective.
6. Stacy recounted
the story of what had happened to them and how they had come to get involved
with writing declarations in the first place. She said that neither she
nor Vaughn were good with money and that after leaving the Church in 1989,
they had run up tens of thousands of dollars in debts. She said that they
first tried to live off various family members while Vaughn attempted
to establish himself as a writer. The family eventually balked at that,
and the Youngs were on their own. She said they used up their savings
and over-extended their credit cards in an unsuccessful attempt to create
a computerized, desk-top publishing business. Stacy said that she and
Vaughn both wanted to work as writers and eventually took a series of
jobs in several small newspapers in the San Diego and Newport Beach areas.
These jobs did not pay well, and they were heavily in debt when the last
paper for which they worked went bankrupt. Their financial situation worsened
as Vaughn was unemployed and refused to take on any employment other than
as a writer. Stacy earned the only income, working for an insurance sales
firm which she said she hated.
7. Stacy told us
that their financial situation deteriorated to the point that she had
threatened Vaughn with divorce if he did not get a job. Vaughn then got
a job driving a taxi cab. He was unable to continue this however, when,
after running out of gas, he attempted to push his vehicle, lost control
of it, and injured his leg. Additionally, Stacy said she had suffered
a tubal pregnancy, necessitating an operation. Between the medical bills
and the lack of a steady income source, Stacy explained that they ended
up more than $50,000 in debt, It was in those circumstances that the Youngs
turned to trafficking in anti-Scientology allegations as a means of making
8. Stacy said that in early 1993, at the depth of their financial crisis, a British anti-Scientologist, Jon Atack, introduced them to an active anti-religionist in the Los Angeles area named Priscilla Coates. It was through Coates and her attorney, Daniel Leipold, that the Youngs connected up with Graham Berry, for whom they eventually became paid 'consultants.'
9. At one point in
our conversations, Stacy broke into tears and said that she and her husband
only began consulting with and selling declarations to Graham Berry because
she and Vaughn were so desperate for money. Stacy said she had been willing
to say under oath whatever Berry wanted her to say if it would result
in getting paid, as she could not face continuing to live under the financial
pressure she and Vaughn were suffering. Stacy said that she had made a
vow, like Scarlet O'Hara in Gone With The Wind, that no matter what it
took, she would never be poor again. Vaughn explained that it was "a
great way to utilize twenty years that I was trying to avoid on my resune,
and that he..could work one afternoon and make what would be a weekly
salary in any other job.
10. In the course
of the discussions, both Mike Sutter and I brought up how we could not
understand how they could tell so many lies in the declarations they had
filed, especially those in the Fishman case.
Neither denied that
this was what they had done, but explained that in order to be able to
survive, they provided testimony requested by the attorneys, and that
they had to write what was wanted or they would not get paid. Stacy said
it was "obvious" they would not be paid to write things that
would be helpful to the Church.
11. We challenged
them to explain how they could justify lying as a way of life, and they
told us that what they had mostly done was twist facts and used "creative
writing" and innuendo to paint a picture that was negative to the
Church. They explained that they had tried to avoid explicitly lying about
facts so they could not be accused of perjury. Vaughn especially seemed
proud of this, and said that he was a writer by profession, which is why
he was so good at preparing declarations and why he was paid so well.
He claimed that unlike the Fishman case declarations of Andre Tabayoyon,
Steve Fishman and Garry Scarff, where the lies and inconsistencies were
obvious, his declarations were worded in such a way as to make them much
more difficult to discredit. Nothing he said ever disavowed his explanation
of how he manipulated facts to create false illusions.
12. Both of the Youngs
readily agreed that they could easily set the record straight by writing
new declarations which would "clarify" the statements they had
made previously. Vaughn said that he did not want to write anything that
would be a "direct contradiction" to what he had written earlier,
but this was simply a matter of "interpreting" things differently.
He said he intended to make his career as a writer and would need "credibility"
in order to obtain future jobs, so wanted to do this "properly."
13. Stacy said that
by writing such declarations they would "burn their bridges"
with the anti Scientology camp. She went. on to say that this would not
be difficult to do as they did not want to be involved in anti-Scientology
litigation matters any longer and in fact, they were "between jobs"
at the time, so it was an opportune moment to bring this entire episode
in their lives to an end.
14. Stacy and Vaughn spoke extensively about matters they had put in earlier declarations during the course of several days of meetings. They explained their true views and talked candidly about many matters. For example, in the Fishman case, Graham Berry wanted them to execute declarations to support the contention that Steven Fishman was an experienced Scientologist. Both Youngs said that this presented a problem as the very data which Berry had given them to orient them to the "facts" of the case proved that Fishman was a fraud. Upon reading Fishman's unpublished manuscript, The Lonesome Squirrel, they told us they had the same reaction: That Fishman was psychotic and that his so-called experiences in Scientology described in his manuscript never occurred. Stacy specifically mentioned by way of example that the manuscript discusses meetings and activities allegedly done by a Church staff member, Lyman Spurlock. Stacy said that she knew that such incidents could not have occurred; that Lyman Spurlock would never have done the actions Fishman alleged and that Fishman's description simply does not match Mr. Spurlock. Further, she knew that the meetings described between Fishman and Church officials simply could not conceivably have occurred. She said the whole manuscript was ridiculous, a fabrication. Vaughn said he could not even finish the manuscript, it was so bad.
15. Similarly, they
both described watching a video of Fishman describing the operation of
a Hubbard Electrometer (E-meter). The video was supposed to demonstrate
Fishman's competence and knowledge in Scientology. The Youngs said Fishman
explained that the meter's "sensitivity knob" was used to keep
the meter's needle on its dial, and that this was such a ridiculous mistake
that they burst out laughing and knew with certainty that Fishman was
not an experienced, Scientology auditor.
16. Stacy also pointed
out that they both knew that Fishman's claims of having completed the
Saint Hill Special Briefing Course -- an advanced course in Scientology
counseling -- was a lie, that it was physically impossible for anyone
to complete the course in the six weeks Fishman claimed. In fact, after
recounting these facts, both Vaughn and Stacy stated that they knew that
Fishman and his co-defendant, Uwe Geertz, were both crazy and that their
allegations about Scientology were false.
17. Stacy said she
had to come up with a way of supporting Fishman's claims for Berry because
she needed the money. She said she knew that she could not state in a
declaration that Fishman was a long-term Scientologist as that would be,
in her words, "completely untrue." Instead, she said that she
played with words and concepts so that she could, without directly lying,
construct a picture that would create the impression that Fishman knew
what he was saying about Scientology. She said she even knew that Fishman
was ineligible for Church services due to an extensive history of psychological
treatment, and to solve that she had created a way of explaining his "involvements"
by alleging that "the Church had negligently allowed Fishman to read
church scripture," and that this "resulted in Fishman's mental
state deteriorating." She said that she knew his mental state was
not good, and that he knew some Scientology words and terms (though he
usually misused them) and therefore this was a "credible" scenario
that suited the attorney.
18. Stacy said that
her theory was used to support the contention that Fishman had been "exposed"
to upper level Church scriptures, even though he had never attained that
level in the Church and the materials are kept strictly confidential in
19. She went on to explain that her distortions had extended to allegations about brainwashing, and that here she had quoted completely out of context from the writings of L. Ron Hubbard. She gave this as a classic example of how one can distort the facts. She said that it was ironic that while she was in the Church she had compiled a pack of materials written by L. Ron Hubbard where he had alerted people to the existence and dangers of mind control techniques through the use of pain, drugs and hypnosis. She had created the pack to rebut Falsehoods presented by Bent Corydon in his case against the Church and that it showed that Mr. Hubbard was in the forefront of the condemnation of brainwashing techniques and had developed the first techniques to counteract it. For the Fishman case, however, she explained that she took this very same material and pulled selected quotes out of context to give her declaration a 180-degree reverse "spin." Her Fishman declaration then gave the false impression that Scientology techniques were mind control when, in fact, they are just the opposite.
20. One of the falsehoods
I brought up with Vaughn Young was his allegation that David Miscavige
was involved in the death of his mother-in-law, and that Vaughn had stated
that it was a murder.He said that "if you read my statements exactly
('Mr. Miscavige's behavior was overlooked in the investigation of the
death of his mother-in-law... She died... from three shots to the chest
and to the temple from a .22 rifle.') you'll see I didn't say David Miscavige
murdered his mother-in law." I told him that this was the impression
he created and he replied "Exactly." He said that he could never
have directly made the accusation as it wasn't true but he crafted his
declaration to create that impression.
22. This is what
led to him supporting Fishman's contention that he had been ordered to
commit suicide or to "do an 'end of cycle.'" Young explained
that the three words did have a meaning in Scientology, and even though
he knew that Fishman falsely claimed the term was Scientology slang for
suicide or murder, and that this in fact was further evidence that Fishman
was not a Scientologist, he had enough to go on to fashion a statement
for a declaration that would be interpreted to support Fishman's claims.
24. Vaughn had further
expanded on this theory when he stated that one cannot simply leave Scientology
-- i.e., cease being a member of the Church -- because a Church policy
states that it is better that a person "be dead" than to not
be a dedicated Scientologist. Vaughn said he knew the quote was not meant
to be taken literally, but again, it was something that as written he
could not be charged with perjury for, yet he created a completely wrong
impression. Ironically, both of them acknowledged that except for assistance
from the Church to help them retrieve their belongings after they abruptly
left the Church without notice, they had had no contact with any Scientologists
from shortly after they left the Church until they began to file declarations
against the Church, a period of more than three years.
25. Stacy also talked
about her assertions that the upper level scriptures of the Church were
in the public domain. She was challenged on this and admitted that she
knew that the Church took great care to maintain the confidentiality of
these scriptures as a matter of religious faith and actively would seek
to prevent the improper distribution and exposure of these materials.
She said she was willing to withdraw her declaration on this matter, as
she knew how important this was to Scientologists.
26. After Vaughn
and Stacy had opened up and talked a great deal about what they had been
doing in their anti-Scientology litigation, they also discussed some of
the other witnesses who had been hired by Graham Berry to attack the Church.
Their descriptions match my personal knowledge and made it obvious that
these are not credible witnesses. Stacy specifically mentioned Gerry Armstrong
and Larry Wollersheim, both of whom were also paid witnesses for Berry.
Stacy told me that Armstrong is psychotic and lives in a delusory world
in which he holds conversations with God. She said that Wollersheim is
as crazy as Armstrong is.
27. They also talked
about Andre Tabayoyon. Stacy was especially upset about him, and described
an incident in which she and others were at the offices of Berry's law
firm. Tabayoyon was upset that he had not been paid and began yelling
in a wild and uncontrolled manner and threatening to kill people. When
Stacy told him to stop shouting and to act more professionally, he began
to make threatening remarks to her. His yelling drew the attention of
employees of the law firm who came to see what was going on. When they
arrived in the conference room where Stacy and Tabayoyon were located,
Tabayoyon abruptly stormed out of the office. Stacy also told me that
Tabayoyon mistreated his wife, Mary, and that he regarded her as a slave.
Both Stacy and Vaughn found this conduct very disturbing, and they said
they would find excuses not to have to socialize with the Tabayoyons because
they were not good company and had nothing worthwhile to say.
28. The Youngs said
they would write declarations to set the record straight on points described
above along with others. However, they said that as they would no longer
have a source of income they needed help in getting on their feet. They
wanted to get into the environmental or animal rights fields. They wanted
nothing to do with litigation any longer, and even said that once they
got established they might be able to help forward the Church's environmental
campaigns and programs. We said we would try to help find them jobs and
might be able to assist them with a small loan or possibly even purchase
of the rights to future writings to help them while they embarked on a
29. We suggested
that while we made inquiries about possible jobs for them, they should
put together declarations which would rectify the falsehoods and misimpressions
thay had created. They agreed that this would be easy for them to do.
30. Mike Sutter and
I returned to Los Angeles and contacted Church staff and professionals
who had connections in the environmental and animal rights areas and lined
up several possible jobs for Vaughn and Stacy.
31. We returned to
Seattle some days later to give Vaughn and Stacy the good news about the
jobs we had found. We thought they wanted to resolve their differences
with the Church and settle down to an honest living and that this would
come as welcome news. It became clear almost immediately that they were
32. They said they
had not written draft declarations, and in fact, had been thinking about
it and had decided that they wanted the Church to pay them $540,000 --
enough money to live without having to work for five years. They claimed
that if they were to set the record straight it would end their careers
as anti-Scientology consultants and that this was a lot of future income
to give up. They made no mention of the morality of their position, and
when challenged on it, merely responded that this was just a matter of
money, not of right and wrong nor truth or fact. They would do and say
whatever would make them money.
33. In an attempt
to make their ridiculous demand sound reasonable, they stated that even
for $540,000 they were not sure that they would write the declarations
to correct the record as they had earlier agreed. They said that since
we had left they had been in communication with some people they refused
to identify, and had been given "legal advice' that if they were
to correct the declarations they had filed, the insurance company could
sue them for "breach of contract."
34. It should be
made clear here that neither of the Youngs has any claim against the Church
and both have stated such when asked this question directly in deposition.
I brought this up to the Youngs to make clear to them that they couldn't
even have a reason for thinking we owed them money. I told them that if
they wanted peace they had to voluntarily provide truthful declarations
to correct their lies and that we would not accede to their extortionate
demand. While admitting that we didn't owe them anything for what they
had done while in the Church, their answer was simple. It was not a moral
question. They earned a good living distorting facts against Scientology,
and for them to stop, we should pay up. Vaughn Young summed up their position
by claiming that the more of an asshole one is the more one is worth in
35. I told Vaughn
that I could not believe he was demanding that the Church pay him an enormous
amount of money SO he would not have to work at all. He became very indignant
at this and threatened that he would "do more" and that we would
wish that we had "paid him now rather than have to deal with what
he would do to us in the future."
36. Thus the Youngs ultimately refused to put down on paper what they had so willingly told us in person, because we would not pay them for the truth like they had been paid to lie.
37. The Youngs never
retracted their admissions that their publicly filed declarations created
false impressions and contained lies. In fact, they even said they would
now have difficulty carrying on with their "profession" as witnesses
due to what they had told us.
38. In summary, the
facts are as follows: When we met with them alone, the Youngs candidly
admitted what we have been telling the court all along, they have been
lying and intentionally distorting facts. They do it knowingly and will
readily admit to it outside the presence of an attorney or Court Reporter.
They feel comfortable in making these allegations because they know that
unfounded accusations against Scientology are given much greater deference
in the Courts than are false and degrading accusations made about others.
They saw this themselves when they were in the Church, and now they exploit
it for cash.
I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.
Executed this 27th day of October 1994 at Los Angeles, California.