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DECLARATION OF STACY YOUNG
I, STACY YOUNG, declare
as follows:
1. I was a member
of the Church of Scientology for fourteen (14) years, from January, 1975
until July, 1989. From October, 1979, until July, 1989, I was a member
of the Sea Organization, the most dedicated group of Scientologists in
the entire organization. During my tenure in Scientology I acquired extensive
knowledge of the counseling methods, as well as the administrative and
management practices and procedures of the organization.
2 . The facts set forth herein are of my own personal knowledge and I
could and would be competently able to testify thereto.
3 . My first experience
with Scientology was at the mission of Atlanta, Georgia, where I attended
a series of introductory lectures in January, 1975. I received my first
Scientology auditing in Atlanta called "Life Repair" and I also
took several courses.
4. I joined the Sea Organization ("Sea Org") at the Advanced
Organization in Los Angeles ("AOLA") in October, 1975, signing
a billion year contract to confirm my dedication to Scientology and "clearing
the planet."
5 . All staff members involved in tho delivery of the confidential Upper
Levels of Scientology processing ("OT Levels"), and all staff
members involved in Scientology management are members of the Sea Org,
living communally and under the authority of the Sea Org Command Lines
24 hours a day.
6 . At the end of 1977, I transferred to the United States Guardian's
Office ("USGO") in Los Angeles. I was a staff member in the
USGO from January, 1978 through January, 1982. The Guardian's Office was
the part of Scientology that handled public relations, intelligence and
legal matters for all of Scientology. The "USGO" was corporately
part of the Church of Scientology of California ((XC). The Guardian's
Office was renamed the "Office of Special Affairs" (OSA) in
or about 1983.
7 . Starting in August, 1984, I worked in the Office of Special Affairs
U.S. (OSA US). I wes assigned to handle public relations writing and to
write articles for and edit a publication known as "Freedom"
(discussed in further detail herein ). At that time the OSA US was part
of the Church of Scientology of California (CSC).
8 . The office where
I worked in 1984 was in the Scientology "complex", formerly
the Cedars of Lebanon Hospital, This "complex" covers an entire
block in Hollywood bordered by Sunset, North Berendo, Fountain Avenue,
and North Catalina.
9 . When I started working for OSA US, the OSA US offices were located
on the third and fourth floors of a building in the "complex"
known as the "American St. Hill Organization" or more commonly
the "ASHO" Building.
10. It was common knowledge within OSA US that Lawrence Wollersheim, a
former Scientologist, was suing CSC, and that Scientology and CSC had
no intention of ever paying Wollersheim "one thin dime". The
phrase "not one thin dime for Wollersheim" became a slogan for
the Wollersheim case. .
11. In early 1985 the OSA US staff was briefed at a staff meeting about
the "Wollersheim" case. The briefing was done by the Commanding
Officer of OSA US, who as I recall, was David Butterworth at the time.
The staff, including me, were told during the briefing that it looked
as though Wollersheim might win his lawsuit. This would mean that the
Court could order the corporation, CSC, to pay Wollersheim money, We all
knew that this was a joke because CSC would never pay Wollersheim a cent.
It was a matter of principal that Scientology would never pay an "enemy"
like Wollersheim.
12. At this meeting we were briefed that Scientology's plan was to gut
CSC of any and all assets. in this manner there would be nothing for Wollersheim
to seize if he won his suit.
13. To accomplish this "gutting" the OSA US Treasury office
and the Freedom Magazine office were to be moved, out of the "complex"
and into an office across the street on North Catalina. The OSA US Treasury
Office was going to be moved because that was where the financial records
for CSC would be stored. The Freedom Magazine offices were going to be
moved because it was a public office and would make it look like CSC was
a functioning Corporation. In fact, money for Freedom would be funneled
into CSC from other Scientology corporations to publish Freedom Magazine
and for other projects. This money was always spent immediately so as
to leave CSC without attachable assets.
14. The balance of the OSA US operations were to be transferred to another
corporation or entity. If I recall correctly, these other OSA US operations
became part of what is now known as the Church of ScientoLogy Western
United States.
15. To the best of
my knowledge, CSC was, for all intent and purposes "gutted"
of any and all assets. These assets were transferred from CSC to other
Scientology corporations. The asset transfers were for the express purpose
of defeating Mr. Wollersheim's chances of ever collecting any money in
this action.
16. I am aware that
on or about October 17, 1982, the Church of Scientology held a "U.S.
Missionholders Conference" in San Francisco. During the time I was
a member of Scientology, I became familiar with a multi-paged document
entitled "International Management Bulletin NBR 2 - Tools to Expand
Your Org Reference Pack." This document was directed 'to "All
Org Staff, FOLO Staff and Flag." It was copyrighted in1982 by CSI.
A true and correct copy of five pages of this document is attached to
my declaration as Exhibits "1-5". All copies have been reduced
from legal to standard size for purposes of this declaration. Exhibit
"1" represents a copy of the cover sheet of the "reference
pack" of materials which contains 162 two-sided pages. The reference
pack consists of eight "executive directives" of various dates.
Exhibit "2" is a copy of the first page of the "reference
pack" explaining the purpose for distribution of the directives.
Exhibit "3" is a true and correct copy of executive directive
SOED 2104 Int. dated 7 November 1982 and the first eight pages of the
transcript of the conference. The directive was a cover for the transcript
of the San Francisco Mission Holders Conference addressed by "Commander
David Miscavige," "Warrant officer Lyman Spurlock, Corporate
Affairs Director," and "Commander (RA) Norman Starkey,"
among others.
17, The covering directive identifies these individuals as "top officials
of the Sea Organization." The Sea Organization '("Sea Org")
is an unincorporated entity within Scientology which is the true structure
of power within the Scientology empire. It is the Sea Org which Scientologists
recognize as having power over them, not the corporate structure, which
in fact is merely a hall of mirrors used to deal with the courts and to
maintain tax exemption with the IRS. The corporate structure has nothing
to do with the true hierarchy of Scientulogy. Internally, the corporate
structure is ignored, not only in terms of authority but also regarding
the flow of monies.
18. The transcript
of the San Francisco Mission Holders Conference offers a rare window through
which can be seen how power in Scientology is actually wielded. David
Mizcavige was Chairman of the Board of ASI , a for-profit corporation
which was ostensibly created to be a literary agency for Scientology founder
L. Ron Hubbard. In reality, Miscavige was running Scientology from his
position as head of ASI when the Mission Holders Conference was held.
To the outside world, he presented himself as COB ASI, but within the
closed world of Scientology, he was Commander David Miscavige, head of
The Sea Org and thus, the head of Scientology.
19. "Warrant Officer" was Lyman Spurlock's Sea Org designation,
but he was also the Corporate Affairs Director at ASI. It was from his
position in this for-profit company that he orchestrated the corporate
restructuring of Scientology, which was then announced at the Mission
Holders Conference. "Commander (RA)" was Norman Starkey's Sea
Org designation, but he was also the Deputy Executive Director for Legal
Affairs at ASI (later to become Executive Director of ASI, directly under
Miscavige).
20. Exhibits "4" and "5" It are true and correct copies
of display charts used by Mr. Spurlock when he addressed the Conference.
These documents specifically delineate how the various entities that were
operating as the Church of Scientology of California, the "Mother
Church of Scientology" were taken over and systematically stripped
of all of its divisions, functions and assets by RTC (Religious Technology
Center) and CSI (Church of Scientology International). This is Scientology's
own version of their reorganization. Before Church of Scientology International
(CSI) was formed in late 1981, Church of Scientology of California (CSC)
was the "Mother Church". Exhibit "4" reflects the
various church entities that were included as part of CSC at that time,
including WDC (Watch Dog Committee); FSO (Flag Service Organization);
ASHO (American St. Hill Organization); Church of Scientology Los Angeles;
Church of Scientology San Francisco; USGO (U.S. Guardian Office), etc.
The FSO, Los Angeles and San Francisco, entities were major sources of
income for CSC.
21. Exhibit "5", the second chart, displays the end result of
the "reorganization" that effectively gutted the assets and
divisions of Church of Scientology California wherein CSC's divisions,
Punctions and assets were rolled over into the newly formed corporations,
Religious Technology Center (RTC) and Church of Scientology International
(CSI). As noted in Exhibit "5", after "reorganization"
CSI became the Mother Church and all the divisions, functions and assets
of CSC such as the WDC, the Flag Service Organization and the San Yrancisco
and Los Angeles Churches of Scientology were now controlled by CSI. The
reorganization also diverted all revenue flow from CSC to CSI and RTC.
22. Based upon everything
I know, and everything I observed while I was a member of Scientology,
I believe that Scientology transferred all of the assets out of CSC after
the filing of Mr. Wollershsim's lawsuit for the express purposes of preventing
Mr. Wollersheim from recovering any money as a result of the Lawsuit.
23. While in the
U.S. Guardian's Office from 1978 to 1982, I was posted as the Organizing
Officer ("Org Officer") for the Public Relations Bureau, and
later, as the Org Officer for the entire Guardian's Office. As the Org
Officer, my functions included the handling of all personnel and organizational
matters, such as correcting a staff member who made mistakes, getting
staff members into auditing or ethics handling when they were sick or
upset or in trouble, recruiting new people for staff, and promoting or
demoting staff members ae needed. I was also responsible for the establishment
and proper administration of all the Guardian's Office personnel throughout
the United States. As the Guardian's Office oversaw certain aspects of
the administration of all other Scientology organizations, I became very
familiar with the overall structure of Scientology and how the various
organizatiuns interact with each other and with the outside world.
24. In early 1982, I was posted as the Special Project PR Assistant under
my husband, Robert Vaughn Young. Several months later, Special Project
became what is now Author Services, Inc. (ASI) as described earlier, a
for-profit company whose ostensible purpose was to be L. Ron Hubbard's
literary agency. I was taken out of PR and made the Organizing Officer
for ASI in April, 1982. Miscavige appointed Terri Gamboa Executive Director
of ASI. He gave Norman Starkey the title of Legal Affairs Director of
ASI. He gave Lyman Spurlock the title Corporate Affairs Director. In my
position as organizing officer, I worked directly under David Miscavige,
who was chairman of the Board of ASI, ("COB ASI"), to carry
out his orders concerning the staff of ASI.
25. David Miscavige,
known as DM, has been the head of Scientology since 1981. He ran the Scientology
Empire from ASI until early 1987. He moved the seat of power of Scientology
from ASI to the Religious Technology Center ("RTC") in 1987,
during a period of time when the IRS wall investigating ASI's ties to
the non-profit corporations of Scientology. At that point, he appointed
himself Chairman of the Board of RTC, which is his current title. The
fact is that Miscavige runs Scientology as a dictator regardless of which
corporation he is part of. The corporate structure of Scientology is purely
a cloak used to shield Scientology from all outside control.
26, Although ASI was established as a for-profit, non- religious corporation,
in reality, while DM was COB ASI, the staff of ASI ran the entire Scientology
network. This included the Church of Scientology of California, ASI had
complete control over the management of all Scientology orgs and missions,
all Office of Special Affairs activities (the Office of Special Affairs
is the successor organization to the functions previously performed by
the Guardian's Office), all transfers of funds between Church accounts
and LRH accounts, every aspect of life of anyone who was a Scientologist,
whether staff or public, (These powers were moved to RTC in 1987, when
Miscavige appointed himself COB RTC.)
27. Because of my experience in ASI, I am familiar with the day-to-day
activities of the highest level of management of Scientology. I have first
hand knowledge of the establishment of the corporate structure of Scientology
as it now exists, having worked with the staff who are responsible for
creating it. The purpose of this activity was to create an impenetrable,
legally defensible network of corporations such that neither the IRS nor
any legitimate agency of government or any private individual engaged
in a lawsuit against Scientology could "pierce the corporate veil"
of Scientolagy organizations, thereby freeing Scientology management to
transfer funds between organizations without concern for the law.
28. I can state from
personal knowledge from my observation within Scientology that all Scientology
corporations are a sham and that David Miscavige and his key aides can
and do control every aspect of every Scientology corporation and can at
any time directly take over and seize alI practical control of any and
all Scientology corporations.
29. David Miscavige
wields such absolute authority over the entities known as Church of Scientology
International and Religious Technology Center that he should be recognized
legally as the managing agent of these two entities. It was true at the
time I left in 1989 and I believe it is still true that both CSI and RTC
have their seats of power at the secret Scientology management compound
in Gilman Hot Springs, California, where Miscavige also lives and works.
Nothing happens at the compound in Gilman Hot Springs without Miscavige's
direct approval or the approval of his circle of aides, from the daily
and weekly management of Scientology organizations and finances around
the world to the minute.details of the daily operations of the compound..
I declare under penalty of perjury under the laws of the State of Washington
that the foregoing is true and correct.
Executed this 13th
day of March, 1997, at Seattle, Washington.
______________________
Stacy Young
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