DECLARATION OF STACY YOUNG

I, STACY YOUNG, declare as follows:

1. I was a member of the Church of Scientology for 14 years, from January, 1975 until July, 1989. From October, 1975 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 administrative and management practices and procedures of the organization.

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

3. I have reviewed Exhibits 1, 2, 6, 18-25, 29,30, 32-35, 41, 42, 44-80 and 82-87 of this motion and relied on them in forming the opinions set forth in this declaration.

4. 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.

5. 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" (see explanation below).

6. All staff members involved in the 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. The Sea Org has complete authority over all Scientology and Scientology-related organizations, including all nonprofit and for-profit corporations. It cuts across all corporate boundaries and can take over any Scientology organization without notice. Any Scientologist who refuses to submit to Sea Org authority is declared a "suppressive person" and expelled from Scientology.

7. For a Scientologist, it is crucial to move up "The Bridge to Total Freedom", and get everyone else on Earth up "The Bridge" as well. The Bridge is composed of a series of specific processes developed by L. Ron Hubbard in which a counselor, called an "auditor", asks certain questions of a person, called a "preclear." The two people are normally alone in a room during this procedure, which is known as "auditing." The auditor's questions are designed to get the preclear to look at various incidents that have happened in the person's life. By doing this in a certain way, the person frees up mental energy that has been locked away by these incidents.

8. The idea is that the person frees up more and more mental energy by moving up The Bridge, regaining sanity and acquiring more control over life. The first major milestone on The Bridge is known as "going Clear." At this point, the person no longer has his or her own "reactive mind", (also called the "bank" or "case") which is the part of the mind that stores all the negative energy that keeps a person from realizing his or her full potential. After one achieves the state of Clear, one moves on to the confidential levels known as "Operating Thetan" "thetan" being Hubbard's term for the life force which is the person himself). These states are numbered, such as OT 1, OT2, OT3, etc. Currently, the highest level that can be achieved is OT 8.

9. Scientology's goal is to "clear the planet", by which is meant getting everyone on Earth up the Bridge to Clear and beyond.

10. I was a staff member at AOLA from October, 1975 through December, 1978. Once I had completed my training and had attained the "case level" of OT 3, I became an "AO Auditor" and audited hundreds of hours on public preclears as well as staff nembers. I audited many of the "tough cases" at AOLA because of any ability to "get the pc through" whatever was stopping him or her from continuing "up the Bridge." I also did many security checks on staff members. A security check is a technique whereby a person is supposed to confess to his or her crimes, particularly crimes against Scientology.

11. In 1977 I was posted as Interne Supervisor at AOLA. In this capacity I supervised auditors in-training, known as internes, to certify them as qualified professional auditors. To perform this function I had to understand auditing procedures precisely, from the most basic processes to the advanced processes and procedures of Class 6 and Class 8, which are advanced levels of expertise, so that I could recognize whether or not the internes were conducting themselves as proper auditors.

12. As a result of my experiences at AOLA I acquired a high level of expertise as a "tech terminal," meaning one who is knowledgeable about the technical application of Scientology counseling and training methods.

13. 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 Scientology.

14. Because of my technical background, 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 as needed. I was also responsible for the establishment and proper administration of all the Guardian's Office personnel throughout the United States. Because 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 organizations interact with each other and with the outside world.

15. In early 1982, I was posted in Special Project as PR Assistant under my husband, Robert Vaughn Young. In this position I became familiar with the L. Ron Hubbard archives materials, which was the complete collection of all of Hubbard's personal papers, including diaries, letters and notes that he had kept from a very early age.

16. Several months later Special Project became what is now Author Services, Inc., 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. On this position 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.

17. David Miscavige, known as DM, has been the head of Scientology since 1981. His loyalty to L. Ron Hubbard and his adherence to Scientology procedures is absolute, and he is utterly ruthless about maintaining his power. He moved the seat of power from ASI to the Religious Technology Center in 1987, during a period of time when the IRS was investigating ASI's ties to the nonprofit corporations of Scientology. At that point he appointed himself Chairman of the Board of RTC, which is his current title.

18. 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. ASI had complete control over the management of all Scientology orgs and missions, all Office of Special Affairs activities, all transfers of funds between church accounts and LRH accounts, every aspect of the life of anyone who was a Scientologist, whether staff or public. These powers were moved to RTC in 1987, as explained above.

19. Because of my experience in ASI I am familiar with the day-to-day activities of the highest levels of management of Scientology. I have firsthand knowledge of the establishment of the corporate structure of Scientology as it now exists, having worked with the staff who were 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 other legitimate agency of government could "pierce the corporate veil" of Scientology organizations, thereby freeing Scientology management to transfer funds between organizations without concern for the law.

20. I am also familiar with the absolute authority which the highest levels of Scientology management exercise over every aspect of Scientology and Scientology-related organizations, whether "church" or "secular."

21. In September of 1982, I was assigned to the Rehabilitation Project Force ("RPF"), the Scientology version of a prison camp. I was on the RPF in Los Angeles for eight months. As a result of this experience, I am familiar with the absolute control which the highest levels of Scientology management have over the behavior and thought processes of every Sea Org member. There is only one way for a good Sea Org member to behave and think, and any deviation from this is punished immediately and severely. In turn, it is the responsibility of all members of Sea Org management to bring about the same pattern of behavior and thought in all Scientologists under their authority, regardless of whether those under their authority are part of the "church" or the various "secular" arms of Scientology. This distinction means nothing within Scientology; it was created purely to facilitate dissemination of Scientology and to fend off Scientology's "enemies" such as the IRS.

22. From May, 1983, when I was allowed off the RPF, until July, 1984 I was posted as Course Supervisor at the International training Organization ("ITO") in Los Angeles. From this position I trained hundreds of fledgling Scientology executives from all over the world on the administrative and management policies of L. Ron Hubbard known as the Organization Executive Course, or OEC. As a result of this experience, I am very familiar with the Administrative policy of Scientology and know that Hubbard formulated it to facilitate the establishing and organizing of his worldwide network of Scientology organizations.

23. In August, 1984 I was transferred back to the PR Division of the Guardian's Office, which by that time had been renamed the Office of Special Affairs. My primary functions were as a writer and editor for FREEDOM Magazine, the Scientology publication which was originally created as a vehicle for attacking individuals and groups who were perceived as threats to Scientology.

24. In 1985 I personally created a nonprofit, non-tax-exempt corporation called North Star Publishing for the purpose of moving FREEDOM Magazine away from the Church of Scientology. I did this so that FREEDOM would have more credibility and not be seen as a mouthpiece of Scientology. This corporation was active until 1987, and during the time I ran North Star, I gained experience in interfacing with the business world while running a purely Scientology organization. I am familiar with the legal, financial and public relations sleights of hand required by Scientology corporations that must deal with the non-Scientology business world,

25. In 1987, North Star Publishing was reintegrated as part of OSA again. My primary functions were again writing and editing. I wrote for FREEDOM Magazine, Scientology Today, and the Crusader. In Scientology, every aspect of PR is directed toward a particular "public." FREEDOM Magazine was directed toward government officials, legislators, heads of businesses, and other key "publics" who needed to be brought into agreement with Scientology's views of the key attackers of Scientology, such as the IRS, psychiatrists, etc. Scientology Today was directed toward all Scientologists and was intended to promote OSA as a powerful and successful arm of Scientology that was winning the war against the enemies of Scientology. The Crusader was a publication directed toward religious leaders and ministers of other religions and was intended to create allies for Scientology in the religious community.

26. As a writer and editor in the PR Division of OSA, my primary responsibility was to "communicate the correct message to the correct public." When I wrote for Scientology Today, a publication intended for Scientologists, the viewpoint to be communicated was that Scientology was everywhere, that Scientology always wins, and that no matter who we are or what we are doing, we are all Scientologists working for the same purpose: to clear the planet.

27. When I wrote for FREEDOM Magazine, which is for non-Scientologists, specifically media, government officials, legislators and major business leaders, I was not to emphasize Scientology at all, but rather, I was to present a strictly factual, professional view of whatever subject I was writing on. These subjects were "exposes" of the crimes of enemies of Scientology, particularly the IRS, psychiatry and any other government agency or individual that was attacking Scientology.

28. The editors of FREEDOM Magazine, including two others and myself, created a front group called "The Coalition of IRS whistleblowers" so that when we wrote stories attacking the IRS we could quote someone else rather than having to attribute it to Scientology. To do this we ran ads in several papers asking for current and former employees of the IRS to come forward and tell their stories of abuse within the agency." In this way, we acquired several disgruntled former IRS agents, one disgruntled former congressman, and several "abuse cases" (citizens who felt they had been treated unjustly by the IRS) who were all willing to speak out publicly against the IRS. We staged several press conferences at which former IRS agent PaulDesFosses, former Congressman George Hansen, and others made public statements about how abusive the IRS was. We then reported on these events in FREEDOM, thereby putting us at arm's length from the statements being made. The group was funded, organized and managed by Scientology, but this was never mentioned.

29. The Crusader was a front publication created during the "Religious Freedom Crusade," a PR event staged for the Wollersheim case, as a means of "allying" ministers and other religious leaders and to create goodwill for Scientology. There was no mention of Scientology in the copyright or masthead of the publication, and no one outside of OSA was to know that the Crusader was published by Scientology. In each issue there might be one or two stories on a Scientology-related issue, but most of the stories were about other religions and other topics concerning religious freedom. No one in OSA or on the OSA command lines cared about these other issues. It was simply a way to mask the true purpose of the publication and to get religious leaders to view Scientology as a religion that they should defend along with their own faith.

30. When Hubbard died in 1986 I was ordered to write the copy for the "In Memoriam" full-page eulogy that ran in several major papers across the country. I was then assigned the task of creating the "LRH booklet," a longer eulogy of Hubbard in which his achievements in various areas were catalogued. These areas included Explorer, Philosopher, Drug Rehabilitation, Educator, Administrator, Artist, Author of Fiction, and Humanitarian.

31. Two different versions of the booklet were created. For Scientologists and other religious "publics," the subhead on the cover of the booklet read "Best-selling Author, Founder of Scientology, Friend to Millions." For businesses and educators, the subhead read "Best-selling Author, Humanitarian, Friend to Millions." Certain passages in the text of the booklet were also revised for the "secular" version of the booklet, because WISE (World Institute of Scientology Enterprises) and ABLE (Association for Better Living and Education) would not be able to use the booklet with their potential markets if it showed Hubbard as the founder of Scientology. He could be the author of the writings that had later been adopted by the Church of Scientology, but if the WISE and ABLE publics found out that they were being promoted by a leg of the Church of Scientology, they would be turned off. So two different versions were published and carefully separated so that the secular version went to WISE and ABLE and the "religious" version went to Scientologists and other religions.

32. As a result of my experience as a writer for these different Scientology publications, I am familiar with Scientology's practice of changing its story for whatever public it is trying to reach. Often I rewrote the same basic story for each publication, completely changing the wording and overall thrust of the story to appeal to the different publics that were going to read it.

33. As a writer in OSA I was also responsible for writing rebuttals of negative stores about Scientology that were published in various newspapers across the country. I was also assigned to write rebuttals of books that were published that were negative about Hubbard and Scientology. As a result of this work I became very familiar with the polices and practices of Scientology with regard to individuals and groups that criticize the organization. I have personal knowledge that the practices which were formerly called "fair game" continue to be employed although the term "fair game" is no longer used. These tactics are laid out in many of the key policies that are studied and applied by staff of OSA.

34. In July, 1989 my husband and I left Scientology. We lived in San Diego from 1989 until August, 1991, at which time we moved to Newport Beach. We are currently living in Corona del Mar, California.

35. As a result of my experiences in Scientology, I am qualified to discuss the policies, procedures and practices of this organization, including its relationship to Sterling Management.

36. Within Scientology there is no question that Sterling is a dissemination arm of Scientology, and that its main purpose is to feed new people into the "church." Certainly no one in Scientology is actually concerned about helping dentists or veterinarians to increase their business. There is no policy by L. Ron Hubbard that encourages Scientologists to help dentists and veterinarians increase their business, so there is no interest in it. The only reason that Scientologists engage in any kind of activity is that it is covered in a policy written by L. Ron Hubbard.

37. Sterling Management is allowed to exist for two reasons: (1) it acts as a feeder of new preclears into Scientology and therefore, (2) it is an excellent source of income for Scientology. Income is always of great interest to Scientology management.

38. I have read a number of declarations by dentists and others who have been taken in by Sterling (including declarations by Alexander Turbyne, John Finucane, Glaydon R. Kern, D.D.S., Michael E. Rolfing, D.D.S., Julia A. Holmes, D.D.S., Connie Hyler-Both, Frances S. Miller and Peter S. Miller.) These people are all bewildered by the fact that no one in Sterling is trained as a consultant in their field of expertise. What these people do not understand is that for a Scientologist, the only valid field of expertise is Scientology. Everything else is only valuable to the degree that it will forward Scientology and speed the spread of Scientology throughout the world. For a Sterling "consultant", the best possible result for one of their "clients" would be that he or she (1) gives all their money to Scientology, ind (2) closes the business altogether and joins staff at Sterling (or some other branch of Scientology). If the person is actually in a powerful position of some sort in the business world, the idea would be to turn them into a Scientologist and get them disseminating Scientology to everyone they do business with. In that case, it would be better not to recruit them onto staff since they would be able to disseminate more effectively by remaining in place in society.

39. This is simply the way it is, and it is an attitude which is voiced with pride within Scientology. It is only for those who are not yet in Scientology that this charade of helping them expand their business is played out.

40. This charade is part of the public persona of Scientology, which is held up for all non Scientologists to see. This image of Scientology is carefully orchestrated so that different parts of society are shown a "Scientology" that will be most appealing to them. The entire purpose of this elaborate public relations activity is to hook a person into becoming a Scientologist by getting him or her to accept one little piece of it that is acceptable, and then to draw them in further by gradually introducing them to more and more of the "technology" until before they know it, they are on "The Bridge to Total Freedom."

41. Hubbard discusses this quite openly in a number Of policies. For example, in a policy called PR Series 2, the Missing Ingredient (HCO PL 13 Aug 70 II), Hubbard begins by stating emphatically that one should "NEVER USE LIES IN PR." But then he qualifies his statement, as follows:

42. He says more on the same subject in PR Series 3, Wrong Publics (HCO PL 13 Aug 70 III):

43. It is all a matter of publics, and how to go about getting them into Scientology in the fastest, most economical way. This is clear in ads for Sterling Management in Scientology publications such as Prosperity and Source, because when they are communicating to their Scientology public, they drop the charade. Barbara Wilson's success story in Issue 74 of Source is a perfect example of how a Sterling staff member would characterize what they are actually doing. She would, of course, never communicate this way to a potential client. (See Exhibit "32")

44. The guise of the helpful, professional consulting business drops immediately if a client shows any sign of exposing Sterling's charade. One can catch a glimpse of the true face of Scientology in a letter dated October 8, 1987, signed by Joan Heller, Legal Officer. (See Exhibit "35") The routing on the letter is from Sterling Management Systems to WISE International, which is Sterling's senior within the Sea Org. Apparently Joan was sending this letter to her senior for approval before sending it out.

45. The name of the doctor to whom this letter was to be sent has been deleted, but from the content it is clear that he had asked for his money back and had been speaking out publicly in some negative way about Sterling. Within Scientology, publicly criticizing Scientology is a suppressive act, and the person committing such an act is known as a suppressive person. This means the person is an enemy of Scientology, and there are many policies covering what to do to silence such a person. It used to be known as the "fair game" policy. As stated earlier, although it is no longer called fair game, the practice is still in force.

46. In this particular letter, the Legal Officer tells him that a review of his file "shows that you actually make more money than you report to the IRS and that you are skimming around $25,000 off the top prior to reports. This information is only what we have found so far. If this matter went public, of course, we would have to pursue what's behind this attack and expose any other crimes found. It is our experience that those who attack us, after all the things we try to do for them, have something to hide. We are more than willing to review this publicly if you continue your slanderous and defamatory accusations." In the real world, this is a clear example of blackmail. Within Scientology, it is simply standard procedure for protecting Scientology from its enemies.

47. The particular lawsuit against the Cult Awareness Network for which this declaration has been prepared, is a classic example of the kind of tactics employed by Scientology to silence its critics. CAN has been a thorn in Scientology's side for many years, and as far as Scientology is concerned, the two groups are involved in a fight to the death. Certainly Scientology's aim is to put CAN out of business permanently. This was its aim when I was personally involved in attacks against CAN, and I have no reason to believe this aim has changed. As stated earlier, Scientologists do exactly what they are instructed to do in L. Ron Hubbard policies and nothing else. Policy on the handling of critics of Scientology has not changed. Therefore, until CAN stops speaking out against Scientology, the group will continue to be attacked, harassed and sued by Scientology.

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

Executed this 9th day of September, 1993 at Corona del Mar, California.

__________________

Stacy Young