I, ROBERT VAUGHN YOUNG, declare as follows;

1. I was a member of the Church of Scientology for twenty years from 1969 to 1989. For fifteen of those twenty years, I lived communally in the Church's organization. During my twenty years with the Church, I acquired extensive information and training in the methods of Scientology. I have worked directly with every phase and aspect of Scientology from introductory levels to the highest management echelons.

2. The matters set forth herein are of my own personal knowledge and I could and would competently testify thereto. In my various capacities, I have had occasion to work directly with Scientology organizations and staff members in at least a dozen countries. Material that I produced was used in every Scientology organization at that time. I know the Scientology corporate structures and how they interlock. I am also familiar with the "secular" side of Scientology, groups that appear to be outside of the Church of Scientology but which are operated by the Scientology hierarchy. I have also completed what the Church considers to be one of its most confidential levels of personal counseling.

3. In 1968, I began studying Scientology while working in the Ph.D. program at the University of California, Davis. I even used Scientology books in the philosophy courses that I was teaching. In 1969, I left the Ph.D. program to help start the Dianetics and Scientology Mission of Davis. My functions at the Dianetics and Scientology Mission of Davis included giving introductory lectures, supervising the communications course, giving professional Dianetic auditing and handling of public relations for the Mission.

4. In early 1971, I joined the Guardian's Office of the Church of Scientology, San Francisco. This organization is presently titled the "Office of Special Affairs" or "OSA". The Guardian's Office was that part of Scientology which dealt with external matters such as media, lawsuits and goverment. The Guardian's Office was broken down into "bureaus" which handled public relations, finance, intelligence and legal matters.

5. Upon joining the Guardian's Office, I was immediately sent to Los Angeles for training in Public Relations (commonly referred to as "PR" within Scientology). During my PR training, it was required to study various official investigations into Scientology including those in the United Kingdom, Australia, New Zealand and one that was currently being conducted by the U.S. Food and Drug Administration. I also studied the press files which were extensive, with literally thousands of clippings from around the world. I was also able to read internal dispatches about these situations and problems with the media.

My PR training also included studying confidential material written by Scientology founder L.Ron Hubbard and Guardian Office (GO) personnel on how to handle public relations. This confidential material was viewed only by authorized GO personnel like myself. The material was on defining, identifying and dealing with those viewed as enemies of L.Ron Hubbard and Scientology. This material was part of my issued "hat pack" which is a folder of material that explains how to do one's job or "hat". As new material was issued, it was studied and put into the pack.

In addition, my PR training included "drills" which were exercises to teach me basic PR skills such as how to write press releases, give press conferences, how to respond to reporter's questions, how to divert a reporter, and how to avoid questions. Use of these drills continue past one's initial training for as long as one is in PR. I also drilled many others.

I underwent a "mini-hat" instruction to enable me to temporarily manage other bureaus such as the Intelligence Bureau which ran covert operations.

6. I was also trained and briefed from 1971 onwards on Scientology as a religion. At no time in nearly twenty years was the purpose of our image as a church ever designed or executed as anything but a PR, tax or legal ploy. However, there were occasions when Scientology or L. Ron Hubbard has to assume a secular mode and so I was also trained how to also make him and Scientology appear to be secular and how we could easily switch from one mode to the next, depending on the need. I was also trained on special circumstances, such as in Mexico, where we had to pretend to be Dianetics. We often practiced our responses. Thus if the audience were business people, we could promote our or Hubbard's secular side. If we were attacked, we would switch to a religious facade. This strategy came from Hubbard himself and I was privy to it. I was personally able to follow this attitude and strategy from 1971 until I left in 1989.

7. When I completed my PR training, I returned to San Francisco where I assumed the position of Assistant Guardian (AG) and ran all bureaus so the then-AG could go to Los Angeles. She was gone for perhaps four months. While serving as the AG, the San Francisco organization encountered a severe financial crisis, with the advice of the Guardian's Office U.S. in Los Angeles, I stepped in, seized the accounts and ran the entire organization until it returned to solvency. This experience taught me the financial structure of Scientology including how money was sent to various bank accounts in San Francisco, Los Angeles, and overseas.

8. As the AG, I conducted internal investigations into personnel in the organization by reviewing their ethics files, personnel files and auditing folders. I learned how to alter records in the organization to mask the trail of personnel going to the Intelligence Bureau so that they could not be traced back to Scientology. It was standard practice to destroy or alter records so that there was not trace of the persons responsible for covert acts in the event that law enforcement should try to find them.

9. As the Public Relation8 Officer (PRO), I took orders from the Guardian's Office US (Los Angeles) and the Guardian's Office World Wide (in England). I worked with all media in Northern California. Anytime a story was printed which Scientology considered unfavorable, I would act as the Scientology spokesman for Northern California to refute any such undesirable media.

10. While working for the Church of Scientology in San Francisco, I worked with other Dianetics & Scientology Missions which enabled me to learn more about how the Scientology organization operated.

11. In late 1973, I was promoted from the San Francisco office to the Guardian's Office U.S. (GOUS) located in Los Angeles where I had previously received my PR training. GOUS's function was to direct and run all Guardian's Offices in the United States as well as Mexico.

My first assignment with GOUS was to be the Public Relations Establishment Officer (PR Esto) where I was to work with all Personnel in the PR US Bureau. I also handled the budget for the bureau, called the "FP" or "Financial Planning." This was done in liaison with other bureaus. This position allowed me to learn all functions in the PR US Bureau and how the finances for the continental office worked.

12. After a few months of serving as the PR Esto, I was assigned to the position of Public Relations Liaison US (PRL US). During this time, I was in charge of the PR section of the most secret and largest program of the Guardian's Office - the "Snow White Program." The "Snow White Program" consisted of several programs written by L. Ron Hubbard and was designed to ferret out the source of international criticism of Scientology. Therewere people assigned to each bureau to carry out the Snow White program. As the PRL US, I was afforded the opportunity to become familiar with dozens of Scientology organization across the United States.

13. While working in the Snow White Program, I was directly responsible for obtaining a number of key acceptances and/or religious recognitions from federal agencies for the Church of Scientology. These came to the Church of Scientology on federal agency letterhead and were addressed to me, giving Scientology some form of acceptances, recognition or permission. These came from various agencies such as the Department of Labor and the Department of State. These letters to me were subsequently used widely by Scientology in the media, in publications and in law suits to show how Scientology had been accepted as a religion.

14. During this time, I helped form front groups that were nothing but letterhead such as the National Commission on Law Enforcement Social Justice. While working in the Snow White Program, I was able to obtain information that the International Criminal Police Organization (Interpol) had a Nazi history. Once this information was disclosed, it enabled Scientology to gain considerable media coverage for years around the world. As a result, I testified twice before Congressional Subcommittees and appeared on radio and television shows. For my success, the Church sent me to England where the Guardian's Office World Wide (GOWW)was located. At GOWW, I was given additional training in PR and learned further how the other bureaus worked, especially in other countries. I was thus given an international perspective in PR, Finance, Legal and Intelligence.

15. In July, 1977, the Federal Bureau of Investigations (FBI) raided Scientology headquarters in Los Angeles and Washington D.C. The Guardian's Office selected me as the national spokesman for Scientology and briefed me as to what to say at the press conferences. The FBI raid resulted in the conviction of L. Ron Hubbard's wife, Mary Sue as well as ten other Guardian's Office personnel.

16. Before the trial of Mary Sue Hubbard and the Guardian's Office personnel, I was given access to the documents that the government was going to use at trial. I read and reviewed thousands of highly confidential transmittals including communications with the highest executives in Scientology. In 1979, while preparing for that trial, I was sent to Washington D.C. to counter the negative publicity that Scientology was letting with propaganda that was pro-Scientology. I wrote stories which were published in Scientology publications such as "Freedom" magazine.

17. After the trial and conviction of the GO personnel, I returned to Los Angeles to head the Specialist Branch at PR US which created Scientology propaganda booklets and publications. It was there that I authored or helped on various articles and Books on Scientology.

18. About 1978, I joined the Sea Organization ("Sea Org" or "SO") in Los Angeles, where I trained as a Sea Org member. I also know how the Sea Organization, an unincorporated entity, is touted to be a mere fraternal organization, as if it has no power. It is, in truth, the actual infra structure that I and others used to direct, control and operate Scientology, whether it be "church" or "secular". I lived communally with other Sea Org staff members and therefore am intimately familiar with the Sea Org life style.

19. In 1980, I was informed that the secret hiding place of L.Ron Hubbard near Hemet, California was about to be exposed in the media. The location was also the secret international headquarters of Scientology. The Guardian's Office ordered me to take command of the base. With the permission of Mary Sue Hubbard, I converted it to look like a film and tape production studio SO that the media would not discover the true nature of the base at Gilman Hot Springs, California.

20. In 1981, I was asked to gather information from non-GO archives about L. Ron Hubbard in preparation of his biography. The archives were run by Gerry Armstrong and contained about 25 filing cabinets full of Hubbard's personal papers and memorabilia. When Gerry Armstrong disappeared from archives, I was left in charge of Hubbard's private papers and able to read them in great detail.

21. In 1982, I joined "Special Project" which was being run by David Miscavige, the current head of the Church of Scientology. Special Project later became "Author's Services, Inc." (a.k.a. "ASI"). ASI was a for-profit group ostensibly created to serve as Hubbard's literary agency. The actual functions of ASI were three-fold;

1) to run the "All-Clear Mission" which was supposed to get rid of all lawsuits against L. Ron Hubbard;

2) make money for L. Ron Hubbard; and

3) run the Church of Scientology.

To the extent that ASI ran the "All-Clear Mission", ASI was running the Guardian's Office/OSA which was responsible for handling the suits.

22. Since ASI was the senior Scientology organization, regular and numerous legal strategic meetings with the Office of Special Affairs personnel were held at ASI. I was able to sit in many of these meetings.

23. While a public relations executive with ASI, I directed the operations of Hubbard's personal international public relations network which operated in the Church of Scientology. The international head of that network reported directly to me. I held meetings with these staffs on church, as well as ASI property, and directed their training as well as their production

24. While at ASI, I was personally sent to the base at Gilman Hot Springs to handle various situations. This base contained the film and tape production unit known as Golden Era Studios as well as the international management organization that ran all of Scientology, from the church to the "secular" side such as WISE (World Institute of Scientology Enterprises.) I also gave a number of briefings to the entire base. On many this was on Hubbard's direct orders. These situations the handling of personnel to the handling of and even his family. I handled personnel and at every echelon, from musicians to members of the Watchdog Committee, which was touted as the most senior body of Scientology. I was thus privy to statistics as well as reports from around the world on the operations of Scientology.

25. Because of my position, I have also been privy to the restructuring of corporations within Scientology. was done at Hubbard's direction. The purpose was usually to mask his or our role in ASI when it came to running Scientology and yet to facilitate the takeover of any group should it run out of control.

26. Since the FBI raids in 1977 decimated the Church of Scientology's Intelligence Bureau, ASI became the focal point for "intelligence." In an effort to prevent convictions of Church personnel like those that occurred in 1977 from happening again, it was decided that the more "sensitive" work was to be assigned to attorneys and private investigators and call it "attorney work product." As a result, I am familiar with how the legal and investigative arms of Scientology came to be developed after the Guardian's Office was renamed the Office of Special Affairs.

27. When the Church of Scientology sued Gerry Armstrong (the man described above as controlling L. Ron Hubbard's archives) in 1984, I was assigned to research Hubbard's life to refute Armstrong's claims that Hubbard had lied to members of the Church of Scientology. During the Armstrong trial, the Church called me as an expert witness to testify as to what I found in my research on L. Ron Hubbard's life.

28. I held a variety of positions at ASI that ranged from public relations to writing/editing. During that time I became quite familiar with how Hubbard issued orders into church management and how we worked with him to mask this connection. I was also intimately familiar with his personal and public writings, including his fiction, and was even cited in the media as a forthcoming Hubbard biographer. When L.Ron Hubbard died in 1986, I was one of perhaps ten people selected to go that night to the site of his death to handle the situation. My task was to deal with the media and my effort appeared in a great many news stories.

29. After L. Ron Hubbard's death, a power struggle ensued between Pat Broeker and David Miscavige. David Miscavige won and consequently consolidated his position as head of Scientology. Since I was viewed as being aligned with Broeker, I ended up on the "Rehabilitation Project Force" (RPF), which was a hard labor camp operated by the Church of Scientology at Gilman Hot Springs, California. Those sent to the RPF are kept under 24 hour guard until the Church believes that the prisoner is "rehabilitated" i.e. no longer thinking things which are critical of David Miscavige, Hubbard or how Scientology is operated. After 14 months on the RPF, I was considered "rehabilitated" and was returned to ASI where I was assigned the task of producing "Ron Mags," a publication initiated by my wife and I in 1982 about L. Ron Hubbard. When I refused to follow an illegal order, I was physically assaulted and beaten. When I said I wanted to leave ASI and be assigned to the Office of Special Affairs, I was taken to the base at Gilman Hot Springs, California, for further "handling". My handler was Greg Wilhere, the Inspector General, supposedly the highest ranking position in Scientology. When I did not change my attitude and I asked Wilhere about my status, I was told I was not going to be allowed to leave. Pretending to be better, I was subsequently allowed to visit my wife in Los Angeles. on July 3, 1989, after filing a report with a church attorney about the beating at ASI, my wife and I fled Los Angeles with a few items of clothing, leaving the rest of our personal belongings behind.

30. After about two months of travel, my wife and I finally settled in San Diego, California, to begin our lives over. I subsequently began to write for a number of publications and have won awards from the Society of Professional Journalists and the San Diego Press Club.

31. As a longtime Scientologist, staff member and a highly experienced and trained public relations specialist (hereinafter "PR"), I was and am familiar with Sterling Management and the role they plan in Scientology which was not unlike the roles I handled as a PR many times.

32. Scientology could be likened to a coin with two sides: religious and secular. To the Scientologist, however, there are not two sides. There is no difference. But we (in the Guardian's Office/Office of Special Affairs and/or Author Services, Inc.) had to manufacture difference for PR or legal purposes.

33. Sterling Management has long been a source of income and new people for the Church of Scientology. Sterling Management is an excellent example of a Scientology organization that is used to disseminate Scientology into areas where the Church of Scientology could not go, namely businesses. We never rested it as anything but a means of covertly putting L. Ron Hubbard and Scientology into an area or organization.

34. To a Scientologist, the entire reason for being a Scientologist is to "move up The Bridge." This refers to a series of steps that is supposed to bring about a higher level of awareness. Like every evangelical movement, Scientologists seek to recruit others to their form of personal salvation. That is what "The Bridge" is. However, "The Bridge" can be traveled or done only at the Church of Scientology. Thus, if one is a Scientologist and supporting "The Bridge", then one is moving people ONTO it, as one might escort people to any enterprise.

35. In the overall scheme of Scientology as laid out by L. Ron Hubbard, the function of Sterling Management is quite simple:

(1) It feeds people to the Church of Scientology.

(2) It provides jobs to Scientologists who want to raise money so THEY can go up "The Bridge."

(3) It provides money to the Scientology hierarchy through licensing agreements and royalties.

These agreements are with WISE, the World Institute of Scientology Enterprises.

36. WISE promotes itself as an umbrella organization over those that use the technology of L. Ron Hubbard (LRH). However, a review of statements by WISE and the Church of Scientology will show the conflict.

37. In a statement from the Church of Scientology International (attached to IRS form 1023), WISE is called a "nonprofit religious corporation" that "was formed to accomplish several objectives with respect to expanding the religion and disseminating secular applications of the technology throughout society." (Exhibit "35", page 60.) However, in WISE's licensing agreement with Sterling Management dated 7 February 1991 (Exhibit "78"), WISE is called a "nonprofit religious fellowship. . ." It says WISE is there to unite businesses and individuals for "broad dissemination" of LRH technology. But there is no mention of "expanding the religion.'

38. This vital omission is a clear example of what we at PR faced when dealing with WISE and WISE groups such as Sterling Management and how we handled it: we simply told two different stories and hoped that no one would compare notes.

39. A closer examination of the WISE licensing agreement with Sterling Management shows that WISE uses "arbiters" to resolve disputes between WISE and any member. However, the requirements of an "arbiter" (Exhibit "2") shows the connection into the Scientology hierarchy, vis "Each arbiter shall be a member in good standing under the Scientology Scriptures, a minister of the Religion of Scientology, a member of the Sea Org, and well versed in the Scientology Scriptures, in particular those Scientology Scriptures pertaining to Scientology ethics and justice."

40. First, in my 20+ years in-Scientology, I never met a Scientologist who referred to the material of L. Ron Hubbard as "scriptures". This is part of vocabulary that we first concocted and developed in the Guardian's Office so we could appear to be a religion and get our tax exemption from the IRS. It is not a language that is used in Scientology and is even objected to by many Scientologists who resent Hubbard's writings being refered to as "scriptures." However, in public relations we had to learn to speak this language and dress the part (with turned-around collars) solely to appear as a religion. Away from the TV camera or the courtroom, we laughed at the concept for it was a complete fabrication, a show that we put on for the courts, the media and the IRS.

41. Second, the key phrase in the licensing agreement is "Sea Org", short for Sea Organization. The Sea Organization is an unincorporated entity that promotes itself as a "fraternal organization" that has no power. Any experienced Scientologist or staff member knows the truth: the Sea Org is the most powerful entity in Scientology. Being unincorporated, it escapes legal scrutiny. However, every major Scientology organization, is personnel and bank accounts are under the control of Sea Org

42. In short, WISE is no more a "fellowship" than the Sea Org because WISE is an extension of the Sea Org and it is the Sea Org that runs all of Scientology. It is the Sea Org that permeates all corporate shells and allows the orders to flow in the other direction and the personnel and money to flow in the other.

43. This is also shown in the "Command Chart of Scientology" (Exhibit ("50".) At the top is the "Watchdog Committee" (hereinafter "WDC"). This is made up of highly dedicated Sea Org personnel. It will be noted that one area is reserved for WISE. This position is called "WDC WISE." Note how there is a connection to another level of WISE beneath it, but there is no connection to the "member" at the bottom. This was done for legal reasons, to avoid showing evidence that orders are given and that money flows. However, it does not take much to see that it is useless to have an entire structure if it does not connect to the member.

44. For example, in an undated, copyrighted, 191 WISE newsletter called "WISE WINS" (Exhibit "58"), bar graphs are used to show the "Number of people routed to The Bridge by WISE members. The bar graph accompanies a story about how WISE groups are expanding and cites a number-of cases with numbers, on people going "up The Bridge." One group is cited as having "donated over $8,000,000 to The Bridge!" That means people who came to that WISE group were sent to a Church of Scientology and those people paid $8,000,000 for counseling, training, books, etc.

45. That WISE is a route into the Church of Scientology is also visually shown in WISE promotion. In a large membership Package issued in 1990 and sent to Scientologists, there is a "WISE IS. . ." photo essay. The last photo in the series shows a person being escorted into a door labeled Church of Scientology." (Exhibit "5l".)

46. It is hardly a secret in Scientology that groups such as Sterling Management route people into the Church of Scientology. In fact, if they didn't, they would be chastised. So their role is highly promoted and praised and cited with great pride. It is disputed only when there is a legal case or when the IRS might want to know about the flow of money between two desparate entities.

47. For example, in Issue 26 of the magazine "Prosperity" which is published by WISE International (Exhibit "54"), an editorial on page 1 says, in part, "The impact by WISE members this year was unprecedented. Thousands of people were gotten onto "The Bridge" by members who do management consulting in the field and by members who FSM [Field Staff Member - the acronym here is being used as a verb, basically meaning "sign up"] their own employees and business associates. People who begin to resolve seemingly unsolveable problems with LRH's Admin[istration] Tech[nology], invariably reach for more LRH Tech to handle their personal life and thus begin The Bridge to freedom by going to Scientology organizations."

48. In that same issue, Barbara Wilson of Sterling Management is pictured on page 24 with a statement she wrote. She says, "As [Sterling Management] clients get LRH's Admin[istrative] Tech[nology], they inevitably reach for other LRH Tech with many who end up on The Bridge to total freedom."

49. These references to "Scientology organizations" and "The Bridge" and "other LRH Tech" are all references to what is offered at a Church of Scientology.

50. It might be asked if people and this magazine are referring to the Church of Scientology, why don't they say the Church of Scientology? The reason is the IRS. One of my functions in PR was to teach others how to rewrite their statements so there would be no obvious connection made between the for-profit groups and the Church of Scientology, which was always fighting for its tax exempt status. So our way of doing it was to delete reference to the church as "church" and try to refer to it benignly as "The Bridge" or "other Scientology groups", etc. However, to a dedicated Scientologist, there is no question what is being said. It is only to a non-Scientologist that it might appear that they are not referring to the Church of Scientology. That was the purpose in writing it this way, so that if it were debated in court, the issue could be confused.

51. Those that send people to a Church of Scientology are called an 'FSM", a Field Staff Member. The FSM can be a person or a group. While the exact function and duties of an FSM has evolved over the years since it started in the mid-1960's, an FSM is basically a salesman who gets someone interested in buying Scientology services. When the person buys the service, the FSM gets a commission. It is as simple as that.

52. It could work in the following way: An FSM disseminates or promotes a particular course to a person. That person says they would like to do the course. The FSM fills out a slip and tells them to take it to the org. The person does and pays for the course. The FSM gets a commission on that and subsequent services the person buys.

53. Because of the high cost of Scientology services, this can be quite substantial. For example, in a newsletter issued by The Flag Service Organization in Clearwater, Florida, they list how much Sterling Management made in commissions. The newsletters are undated but each make reference to commissions made "in the past two weeks." They are during 1989-90. They are cited by volume/issue number. They offer a spot survey on Sterling Management's commissions with only one organization:

Vol. 17, Issue 4 $7,220 (Exhibit "75")
Vol. 17, Issue 6 $7,725
Vol. 17, Issue 8 $9,896
Vol. 18, Issue 1 $5,961
Vol. 18, Issue 2 $2,158 (Exhibit "76")
Vol. 18, Issue 5 $5,954 (Exhibit "77")

If the commission being paid is a minimum of 10% of what was paid to the FSO by the selectee(s), multiplying the above amount by 10 will give approximately how much money Sterling Management fed to this one organization every two weeks. Sterling is an FSB to several Scientology organizations.

54. Sterling Management takes great pride in how they are able to create new Scientologists. For example, in an undated issue of "Prosperity" (Vol. 2, Issue, 1, copyright 1985), it is said that Sterling Management "has created an enormous flow of clients onto the Bridge. In the last 12 months, Sterling Management Systems has FSMed over 1.3 million dollars into the San Francisco Mission, San Francisco Org, and Flag, from raw public individuals. Greg and Debbie Hughes and Lyn Irons owners of the company, decided the the way to expand from here is to get even closer to Source [L. Ron Hubbard]. As such, they have now decided to turn the company into a WISE Office. . ."

55. That promise was fulfilled in an undated piece of promotion that appears to be from 1987, where Sterling Management is promoting itself as WISE Glendale. The promotion said Sterling Management/WISE Glendale had "put as many as 1000 people on the road to Clear and OT." (Exhibit "59") These are levels on "The Bridge" which can be achieved only at a Church of Scientology.

56. Another piece of Sterling Management promotion from 1991 is headlined, "Want to Really Help Clear the Planet?" This is clearly directed to Scientologists for that is the objective of the Church of Scientology. The promotion goes on to say, "Sterling Management is the top FSM Group on the planet. . . . In the first half of 1991, close to 800 Sterling clients became Scientologists." (Exhibit "64") (No definition is offered but to a Scientologist this means the taking of a Scientology service at a Church of Scientology.)

57. In an undated piece of promotion for WISE, Susan Ochart of Sterling Management said, "This last quarter, the number of our clients that went Clear at Orange County Org alone totalled 109 [more than one a day.) That's what this is all about." (Exhibit "66").

58. This statistic is apparently repeated in "The Auditor: The Monthly Journal of Scientology" (Issue 253, copyright 1991) (Exhibit "70"), which is published by the Church of Scientology where it says, 'WISE field activities are very important in Scientology expansion, for example Sterling Management in the USA had 109 clients attest Clear in the last 3 months!

59. Besides providing people and funds to Churches of Scientology, Sterling Management also provides personnel to the Sea Org. Sterling Management is, in the vernacular of Scientology, a "recruitment pool."

60. A good example is shown by a "success story" by Anthony Alvarez that was used to promote the Sea Org. Mr. Alvarez said he had been working for Sterling Management when WDC WISE (Mr. Greg Hughes) came by Sterling Management and recruited Mr. Alvarez for the Sea Org. Mr. Alvarez's story is not unusual and would be expected from an organization such as Sterling Management. Knowing the Sea Org and Scientology organizations, Mr. Hughes would have been welcome at Sterling Management at any time and would have been treated as a VIP. He could have visited as an individual or as part of an event. (Sea Org recruitment tours regularly go through organizations.) Regardless, Mr. Alvarez's recruitment into the Sea Org occurs in such organizations all the time for that is one of their functions. (Exhibit "83")

61. There is a magazine ("Freewinds") issued by the ship of that name. The ship is operated exclusively by the Sea Org and sails the Caribbean. The Freewinds offers the most exclusive (and most expensive) services, including a section called "OT VIII [8]". Issue #6 has an interview with Mr. Chris Estey after he completed OT 8. (It contains some Scientology jargon that will be defined.)

"Freewinds: That's fantastic! Are you still working full time Scientology?

Mr. Estey: Yes, I'm now the Executive Director at Sterling Management. I realized that New OT IX [the next level after OT 8) would never get released if we didn't get the orgs [organizations] up to Saint Hill size fast. [Saint Hill was a large facility in the U.K. where LRH Lived and worked.] . . . I wanted to contribute to the expansion of Scientology . . . I connected up to Sterling Management because it is a major contributor to org[anization] expansion. It FSMs [the plural noun is being used as a verb] on the biggest scale I could find. They are at the top as FSMs for orgs such as Flag [in Florida], Orange County, San Francisco, Los Angeles and many others."

62. Another way that Scientology gets money from Sterling Management is via "donations" to the International Association of Scientologists (IAS). According to an application for membership, the purpose of the IAS "is to advance, protect and support Scientology religion and Scientologists so that the purpose of Scientology philosophy can be achieved and the goal of freeing mankind come true." [sic] The application requires the potential member agrees to "support dismantling of any groups and organizations which have as their purpose to prevent Scientology religion and freedom for mankind." (Exhibit "84)

63. According to the IAS magazine "Impact", Issue 35, copyright 1990 (Exhibit "85"), Gregory K. Hughes and Kevin C. Wilson are each listed as "Patron Meritorious" which means each has donated more than $250,000 to the IS "war chest"." Deborah [Mrs. Gregory) Hughes is listed as having donated $100,000, as is Barbara Wilson, wife of Sterling owner Kevin Wilson.

64. Kevin Wilson has also admitted that he contributed $3,000 a month to WISE to be a member of WISE's "CEO Circle." (Exhibit "100", pp.64-66).

65. To a dedicated Scientologist, none of this is at all unusual. In fact, it is highly commendatory that Sterling Management would put this many new people onto "The Bridge" and would, in turn, contribute this much money back to WISE. To a dedicated Scientologist, the worth of bringing people into the Church of Scientology by masking the introduction as "admin tech" is measured by Sterling Management's success in recruiting for Scientology.

66. That is how and why money and personnel move freely between these organizations, regardless of any non-Scientology regulations. To a dedicated Scientologist, it is simply a way to "go free." In short, the end justifies the means.

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

Executed this 8th Day of September, 1993 at Newport Beach, California.

Robert Vaughn Young