I, ALEXANDER TURBYNE III, make this declaration on personal knowledge except as to those matters stated on information and belief, and as to those matters I believe them to be true.

1. I received mailings from Sterling Management Systems over a number of years before I filled out a "Sterling Business Analysis" form. I do not believe any of the mailings made any mention of Scientology, and I know for sure that the questionnaire form I filled out only listed J. Chase Wilson Corp. as the owner, because I still have half of the original, and a Blank that is exactly the same.

2. In September 1990, I received a phone call from a woman at Sterling who said the questionnaire had been evaluated and that Sterling could really help me get the practice under control. The next step was to schedule my attendance at an Introductory seminar with my staff. Again no mention was made of Scientology. I initially scheduled the seminar for January 14, 1991. I received a call from Sterling in early December 1990 rescheduling to December 21, 1990, since the original date was in Portland, Oregon and not Portland, Maine. I believe I was going to cancel since the date was too close to Christmas for us, but I received a confirmation card, and I confirmed that the actual date was January 21, 1991, so we attended the seminar in Portland. There was no mention of Scientology on the confirmation card. The seminar and the personal consultaticn, during which I signed the contract, both took place at a hotel in Portland.

3. I do not recall any discussion of Scientology at the introductory seminar. The only reference to it was similar to what is in the contract. To the best of my recollection, the statement was to the effect that, "We use material developed by L Ron Hubbard, who invented Scientology, but this is different, and has nothing to do with Scientology." To this point in time I had never heard of Scientology, and certainly did not have the slightest idea of Scientology's Plan to "clear the planet," or specifically, its plans for my money.

4. The morning after the seminar, I had a private consultation with Doug Faulk who gave the seminar. He lead me to Believe that if I took the $13,500 Sterling program, the week of courses and consulting time would be IMMEDIATELY useful to a dental practice and that the "cookbook" of plans I would receive could be custom made for me, and would be very specific and easily used and tailored to MY office. I signed the contract submitted in support of my motion for summary adjudication as EXHIBIT B and paid $15,000.

5. When I arrived at Sterling's office, I was questioned by a woman about any association to the IRS or FBI. This I found a little unsettling, and I kind of wondered what Sterling had to hide and if the business was on the level. I believe at some point during the first days' meeting with my consultant, Bruce McCallister, recommended that I speak with David Oliva. He was presented as one who could help with more personal problems, and that my business gains would be tied to this. I believe a meeting was scheduled for March 18, 1991 or March 19, 1991.

6. The first book on the course was a children's book that presented L. Ron Hubbard's view on misunderstood words. Dates out in Glendale, Friday March 15, 1991 to Friday March 22, 1991. The other courses Bruce selected for me were: (1) The Ups and Downs In Life Course; (2) Ethics For Business Survival; (3) Success Through Communication; (4) How To Get Along With Others Course; (5) The Personal Integrity Course; (6) How To Increase Productivity By Managing Personnel On Statistics; and (7) Basic Organization (just started when I had to leave). As this above list shows, very little of the program was business oriented and those courses were quite general as well as clearly Scientology in nature. I did not find the courses pertinent to my business.

7. Bruce McCallister had stressed the need for the non-business courses with what OCA test showed was my depression, low self-esteem, etc. According to him, the management course would not work if I did not resolve these problems. Since I did not know what I was getting into, and wanting to maximize the returns on my money, I agreed to try personal counseling at the Hubbard Dianetics Foundation.

At some point Sunday or Monday I spoke with John (an Instructor) and told him that I felt this whole thing was a bait an switch operation. I learned that the instructors would not tolerate any serious questioning of materials being presented. Everything was placed back on me, as I were the problem if I didn't accept or like the materials. I also learned that they had no qualms about taking as much time as necessary to place themselves back in control of my indoctrination, especially since it was my quarter, and the meter was running at about $200 per hour . In other words, the counseling hours that I had paid for (for business counseling) were being used up for "counselling" me not to question the doctrines of Hubbard and Scientology.

9. The Ups And Downs course covered the Scientology war-horse concept of "ARC" (affinity, reality, and communication) plus the anti-social personality, potential trouble source, handling suppression and other related Scientology dogma. This course is particularly important for understanding how Scientology and Sterling are one and the same. To cut to the chase, Sterling's staff did, indeed, succeed in recruiting me for Scientology programs at the Church of Scientology of Orange County. And while I was there, I was required to do an Ups And Downs course: it was exactly the same as the course at Sterling!

When I inquired about this matter at Orange County, I was told by (still a member) Dave Worthen that Sterling is "just a public relations front organization for Scientology."

10. "Ethics For Business Survival" covered Scientology's "ethics Conditions" Power, Power change, affluence, Normal operation, emergency, danger, non-existence, liability, doubt, enemy, treason, confusion. All this was a very general discussion of the different levels of productivity of businesses and all other kinds of organizations. Assuming that any of it were valid, it was too general and theoretical to be useful. Furthermore, no specific aid was given as to how to turn a business that is in a condition of doubt, to one of affluence. Obviously, nothing was applicable to a dental practice and this was a complete breach of promise made to me when I signed up.

11. "Getting Along With Others" covered more on ARC triangle, tone scale, antagonism by third parties, as a cause of violence and conflict, and other Scientology philosophy. (nothing on dental practices)

12. The "Personal Integrity Course" a was on the sad state of the world and Scientology's Eight Dynamics (self, family unit, group, humankind, etc.) and HONOR CODE (totally Scientology tenets and nothing about dental management).

13. The "Management By Statistics" course was about statistics from a Scientology perspective and Scientology's "Conditions"as they were supposed to relate to business.

14. "Business Organization." I did not get very far into the course.

15. Near the end of the week I was given a very hard sell for the Speedo course, a program where a Sterling staff member comes to your office to set up the Sterling system. Given the fact that I had learned next to nothing that I could directly apply to my practice, I was concerned that my money would be totally wasted unless I purchased Speedo and I decided to purchase the plan. I was becoming very fearful that I had wasted my time and money on Sterling, and I thought if I could salvage that by spending more then I had to do it. It cost $6,709.15. The invoices shows these payments and are attached hereto as EXHIBITS G, H, I and J.

16. 1 have enclosed copies of some material from the Hubbard Dissemination course. This is a book from Sterling or Scientology and the steps outlined define just how the Sterling Sting is laid out. This is a virus spreading more viruses in a very organized and orchestrated way. I was also set up, so unsuspecting professionals, seeking self improvement, would become the milk-cows, for a Scientology organization that is seeking a new world order.

17. All these courses are, by design, indoctrinating the individuals in the dogma of Scientology by paying lip service to something which appears, to the individual, to be a common goal. When questions are raised, the fears are expertly assuaged and the subconscious climb up the gradient of indoctrination continues. Scientology gains control of substantial chunks of money, at a minimal cost to the organization and the financial security of the group is improved.

18. Had I known, by Dave Worthen's own admission, that Sterling Management was merely Scientology's Public Relations branch, and under direct control of Scientology, I would not have wasted a nickel, much less the amount I spent.

19. Prior to going to Sterling, I had expectations that I would be receiving superior quality instruction on dental practice management, that would be custom tailored to MY practices' needs. What I got, was shoddy, coloring book quality course materials, and advice on getting more patients, at a time when I had a two month back-log and didn't know how to handle that.

20. Sterling Management is good at what it does, namely, introducing people to the ideas of Scientology. The only problem is that what it does is quite different from what it says it does. If I had known this, at the introductory Seminar or through the mailings, I would have kept my money and signed up with a dental management firm and not a Scientology Recruiting Firm....

21. "When I use a word," Humpty Dumpty said, in a rather scornful tone, "it means just what I choose it to mean--neither more nor less."-- ALICE THROUGH THE LOOKING GLASS "When Lewis Carroll wrote these immortal words, he was making fun at every public speaking buffoon who has ever climbed up on a platform and tried to bamboozle the rest of us with verbal trickery and slippery syntax. What he was saying, in effect, was that we should be on the alert for serious sounding nonsense."-- BILL WILLIAMSON -- A DIFFERENT DRUMMER.

Sworn to under penalty of perjury under the laws of the state of California at Skowhegan, Maine this 3rd day of May, 1992.

Date: 5/3/92

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Alexander Turbyne III