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 one 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 government.

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, I was required to study various official investigations into Scientology. I also studied the press files which were extensive. 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.

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. 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 had 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.

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. She was gone for perhaps four months. While I was 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.

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 Relations 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.

10. 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.

11. 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. There were people assigned to each bureau to carry out the Snow White program. As the PRL US, I was afforded the opportunity to
come familiar with dozens of Scientology organization across the United States.

12. While working in the Snow White Program, I was directly responsible for obtaining a number of key acceptances and/or religious recognition 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.

13. 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 Scientology PR, Finance, Legal and Intelligence.

14. In July, 1977, the Federal Bureau of Investigation (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.

15. 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 getting with propaganda that was pro-Scientology, I wrote stories which were published in Scientology publications such as 'Freedom"magazine.

16. 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.

17. 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.

18. 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.

19. 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.

20. 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.

21. 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.

22. 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.

23. 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 occasions, this was on Hubbard's direct orders. I handled personnel and situations at every echelon, from musicians to members of the Watchdog Committee, which was touted as the most senior body in the Church of Scientology. I was thus privy to statistics as well as reports from around the world on the operations of Scientology.

24. Because of my position, I have also been privy to the creation and restructuring of corporations within Scientology much of this 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.

25. 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.

26. 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.

27. When L. Ron Hubbard died in hiding 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.

28. 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 reassigned to ASI by David Miscavige 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 several months later, I was physically assaulted and beaten by Norman Sharkey, Trustee. 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" by 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 church attorney Kendrick Moxon 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.

29. 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 play in Scientology which was not unlike the roles I handled as a PR many times.

30. After my wife and I fled Scientology, we wanted to simply put it behind us. We wanted no contact with anyone. All we wanted to do was to reconstruct our lives, without the fear that we would be locked in a room and interrogated for days and even beaten to force compliance or - if one will not comply - be dragged off to a gulag and be kept under guard while working at hard labor until we were "rehabilitated." That is the fear that Scientology imposes on its staff and that was the nightmare we wanted to never see again.

31. When obtaining writing jobs, I kept my Scientology background hidden because I needed time to recover. I also knew that Scientology executives would monitor us to see how we felt. This is done with private detectives who rummage through your trash, interview neighbors,etc., to see if we were planning to make any publicly critical remarks about Scientology. If they found that I was discussing Scientology with anyone (and this I could be for professional, religious or medical reasons), they would institute Fair Game, doctrine I will discuss shortly.

32. After more than three years of this existence, three years of trying to hide my past, I began to come to grips with what happened. I began to read texts that were forbidden to Scientologists. (Scientologist cannot exercise their basic constitutional rights and read what they wish, say what they wish and associate with whom they wish.) The first book was Jon Atack's A Piece of Blue Sky. I had never spoken to or met Atack. All I did was read the book. As I did, I realized that I had lived in an artificial world in Scientology and had created another since leaving. I also realized that I had friends back in the organization who were also suffering and that as long as
people such as David Miscavige and Norman Starkey and Marty Rathbun and the others were allowed to terrorize and intimidate and harass and then dress in tuxedos like Mafia dons and pretend there was no blood on their hands, the abuse would only grow.

33. I also realized that there had never been a person like me to have left Scientology, nor a couple like my wife and me. Between us we had 35 years in the highest echelons. I knew virtually every phase and level of activity. I knew the policies and directives and orders that told us how to lie, deceive, bully, harass and destroy people.

34. I knew without a doubt that if we spoke out, they would seek to destroy my wife and me. This is not said lightly. I spent 20 years in those sections of Scientology where the lives of "enemies" - from apostates to journalists to judges - were made targets of destruction. I knew how Miscavige was ready to spend millions to destroy anyone. I have sat in on those conferences as one of his top aides. I heard the screaming profanities as people were ordered to "get" a person at all costs. I also knew that the smiling, cordial attitude given to the courts and the media was a facade that we practiced and how we laughed later how a judge or journalist was fooled. I knew all those schemes and which Hubbard "scriptures" told us to destroy anyone in Scientology's path. That is why I have undertaken additional security measures including briefing local law enforcement as to our situation.

35. One of the first results of my decision was a feature article that I wrote for Quill, the publication of the Society of Professional Journalists, titled, "Scientology: From Inside Out," (Exhibit "A") My credentials for being published in a professional journal that has included Pulitzer Prize winners is stated in the article. I wrote it to try to educate the media on how Scientology abuses and misleads them and what they can do about it. I wrote it after reading a piece in Quill published two years earlier by Los Angeles Times writer Robert Welkos who told how he had been the target of Fair Game when writing about Scientology. (Exhibit "B") After reading it, I realized that it was not right that such abuse continue in the media as well as the courts and that it was time to speak out.

36. This was not an easy decision. By speaking out, exercising my constitutional right, by being willing to present sworn testimony, I am an "enemy" to Scientology. No Scientologist questions this because Hubbard is senior to the Constitution and to the law. They are willing to abrogate their rights' and even their lives to his will. I am no longer willing to do so. I wish to present my sworn statements as to the truth of the organization.

37. I have already served as a Scientology expert consultant to attorneys involved with a Scientology case in Michigan (Dickerson v. Sally Jesse Raphael, et al.; Washtenaw County Case Number NG-WA-92-007117 NZ). I am also serving as a Scientology expert in a case where Scientology is suing over a 1991 article in Time magazine. (Church of Scientology v. Steven Fishman and Uwe Geertz in US District Court, Central District of California, Case No. 910642HLH J (TX).)

38. I have been asked to serve as a Scientology expert consultant in the case in which this declaration is filed, Sterling Management v. Cult Awareness Network and have already filed a declaration. My declaration explained why, although the Church of Scientology and Sterling Management are two corporate entities, they are not truly separate. What Scientology presents to the courts and to any legal entity is entirely different from the actual practice conducted each day within Scientology.

39. Scientology executives don't want me to testify to a truth that is known and accepted and even applauded within Scientology. The reason is the same as if it were the Mafia: I am telling people outside the secret circle, For that, a person becomes "Fair Game."

40. Hubbard's Fair Game doctrine has already come into play in this case. It is directed at me and my family for my willingness to expose it. The following is a documented account of what Fair Game is and how it works.

41. Scientology seeks and tries to crush and destroy what it feels are its "enemies." It tries to use the courts to do this. The target can be an apostate, a potential witness, an attorney or even a judge.

42. This end-justifies-the-means method of retaliation is called Fair Game, a doctrine that Scientology officials have insisted was cancelled in 1968. This is not true. I was in the movement for over 20 years, from 1968-1989, much of that in echelons that dealt with "enemies" of Scientology and so I know intimately that the practice never stopped and cannot stop. The reason is that it is in the writings of Scientology Founder Lafayette Ronald Hubbard which are now deemed "scripture." Since, according to Scientology policy, no one but Hubbard can cancel or revise his writings ("scriptures"), and since Hubbard died in 1986, his existent writings stand. I will draw from those writings.

43. Fair Game is basically the Hubbard doctrine that "enemies" of Scientology can and should be destroyed. It is the product of a man that grew so paranoid that he lived in hiding, under an assumed name and disguise, pretending this lifestyle was part of his "research."

44. In 1955, Hubbard laid the groundwork for Fair Game in "The Scientologist: A Manual on the Dissemination of Material." In it he offers two instances when a Scientologist must attack: if arrested and if sued. Hubbard's orders what to do are clear. The following are excerpts from that "scripture":

"Cause blue flame to dance on the courthouse roof until everybody has apologized profusely . . .

The DEFENSE of anything is UNTENABLE. The only way to defend anything is to ATTACK . . . NEVER BE INTERESTED IN CHARGES. DO, yourself, much MORE CHARGING, and you will WIN."

45. On using the law to harass (from the same text):

"The purpose or the suit is to harass and discourage rather than to win. The law can be used very easily to harass and enough harassment on somebody who is simply on the thin edge anyway, sell knowing that he is not authorized, will generally be sufficient to cause his professional decrease. If possible, of course, ruin him utterly."

46. There is also "investigation", Hubbard said in the same document. This is used when you want "somebody haunted." The purpose, he said, was to "crush" the people with what is called a "noisy investigation.":

"When we investigate, we do so noisily always. And usually mere investigation stamps out the trouble even when we discover no really pertinent facts. Remember that - by investigation alone we can curb pushes and crush wildcat people and unethical 'Dianetics and Scientology' organizations."

In short, Hubbard (who died in hiding) felt that everyone should be as terrified of an investigation as he was.

47. A few years later, Hubbard introduced the notion of manufacturing evidence against an enemy. In "Department of Government Affairs"(August 15, 1960) Hubbard wrote:

"If we are attacked on some vulnerable point by anyone or anything or any organization, always find or manufacture enough threat against them to cause them to sue for peace. Peace is bought with an exchange of advantage, so make the advantage and then settle. Don't ever defend. Always attack."

48. In the same "scripture" he said:

"The goal . . , is to bring the government and hostile philosophies or societies into a state of complete compliance with the goals of Scientology. This is done by high level ability to control and in its absence by low level ability to overwhelm. Introvert such agencies, control such agencies. Scientology is the only game on Earth where everybody wins. There is no overt in bringing good order."

49. An "overt" in Scientology is a transgression, a wrong, In unethical act. What Hubbard is saying is that no crime can committed as long as one's actions are "bringing good order." This is what permits Fair Game in Scientology, that the non- Hubbard laws can be broken when pursuing "enemies."

50. The doctrine of "Fair Game" was modified on March 7, 1965, when Hubbard issued "Suppressive Acts: Suppression of Scientology and Scientologists: The Fair Game Law". Hubbard wrote: "By FAIR GAME is meant, without rights for self, possessions or position, and no Scientologist may be brought before a Committee of Evidence or punished for any action taken against a Suppressive Person or Group during the period that person or group is 'fair game'." (A revision of December 23, 1965 changed it to read, "By FAIR GAME is meant, may not be further protected by the codes and disciplines of Scientology or the rights of a Scientologist.")

As to what was a "suppressive person" Hubbard gave the definition: "A SUPPRESSIVE PERSON or GROUP is one that actively seeks to suppress or damage Scientology or a Scientologist by Suppressive Acts."

"SUPPRESSIVE ACTS are calculated to impede or destroy Scientology or a Scientologist and which are listed at length in this policy letter." Some of the suppressive acts listed included "public disavowal of Scientology"; "public statements against Scientology"; asking for a refund of fees paid; and "writing anti-Scientology letters to the press." Even turning a Scientologist into the proper authorities can gain one the label of a suppressive. The issue also prohibits "1st degree murder, arson, disintegration of persons or belongings not guilty of suppressive acts." (emphasis added)

51. A few months later, Hubbard gave specific orders on how to apply the Fair Game doctrine in HCO Executive letter 27 September 1965 on "Amprinistics". This was what he called a "splinter"group, a group that was using Scientology methods without his control. Hubbard's three-page issue blasts the Amprinistics leaders with a variety of sexual charges (one of his favorite topics for accusations) and says what should be done:

"They are each fair game, can be sued or harassed [sic]. Corner can be barred out of any Commonwealth Country or England as he was the subject of a deportation order from England and his file has come alive again in the Home Secretary's Office. Harry Thompson's wives and victims are always looking for him to have him arrested. Watson is a set up for arrest as a homosexual. Any meeting held by them should be torn up. The names of any persons attended should be collected and they should be labeled SP [suppressive person] as they have left Scientology. . . . If these persons move into your area act through any agency you can to have them deported or arrested on whatever grounds. . . . Horner's UK deportation order, Thompson's police record and Watson's homosexuality make them very vulnerable to deportation or arrest. Hubbard does not stop there. He goes on to issue a five step-order that includes: (2) Harass these persons in any possible way. . . (4) Tear up any meeting held and get the names of those attending and issue SP orders on them and you'll have lost a lot of rats."

This order is one of the clearest examples of Hubbard's Fair Game doctrine. What he wrote has never been cancelled and thus is still "scripture."

52. In 1966, Hubbard began to codify those sections of Scientology that would implement Fair Game. For example, on February 17, 1966, he created the Public Investigation Section with a policy letter of that name and date. He said it would serve "the useful functions of an intelligence and propaganda agency. It finds the data and sees that it gets action." The statistic of the unit included "the number of derogatory news stories appearing that week related to enemies of Scientology."

53. Hubbard also urged the priority of finding evidence of "murder, assault, destruction, violence, sex and dishonesty, in that order. Investigations which can uncover these factors in the activities of individuals or a group attacking Scientology are valuable in the degree that they contain a number of these factors." And note that Hubbard's use of such evidence is not for law enforcement but to the media. "In that way," he wrote, "we then get rid of suppressive groups by investigation and disclosure."

54. On February 25, 1966, Hubbard wrote an "Attacks on Scientology" policy letter, in which he said to "Start feeding lurid, blood sex crime actual evidence on the attackers to the press."

55. On October 18, 1967, he issued "Penalties for Lower Conditions", whereby Fair Game was automatically issued on anyone (including staff members) who was an "enemy." They were, he said Fair game. May be deprived of property or injured by any means by any Scientologist without any discipline of the Scientologist. "May be tricked, sued or lied to or destroyed." (Emphasis added)

56. In the late 1960's, Hubbard was having growing public relations problems. One problem was Fair Game. To deal with it, Hubbard wrote an issue that is often cited by the church as evidence that Fair Game was cancelled. But a careful reading will show that nothing has changed but semantics. The issue is "Cancellation of Fair Game" dated 21 October 1968. The entirety of the policy letter (P/L) is as follows: "The practice of declaring people FAIR GAME will cease. FAIR GAME will not appear on any Ethics Order. It causes bad public relations. This P/L does not cancel any policy on the treatment or handling of an SP. (suppressive person)"

Notice that Hubbard did not cancel his "scripture" that suppressives could be "tricked, sued or lied to or destroyed." This so-called "cancellation of Fair Game" clearly states that those treatments (or "handlings") were to continue unabated. All that changed was the appearance of two words on a piece of paper.

57. As further evidence of Fair Game continuing, four months later Hubbard wrote "Confidential: Targets, Defense" on February 16, 1969, in which he listed "vital targets on which we must invest most of our time . . The first and most important: "T1. Depopularizing the enemy to a point of total obliteration."

58. On the same day, February 16, 1969, he wrote "Confidential: Battle Tactics", where he urged' the use of military tactics and strategy in dealing with the "enemy" He wrote:

"A good general expends the maximum of enemy troops and the minimum of his own. He makes the war costly to the enemy, not to himself. One cuts off enemy communications, funds, connections. He deprives the enemy of political advantages, connections and power. He takes over enemy territory. He raids and harasses. All on a thought plane - press, public opinion, governments, etc."

59. Hubbard wrote about how to "embarrass, discredit or or remove an actual or possible opponent" through "covert operations" in "Confidential: Intelligence-Actions: Covert Intelligence: Data Collection: of December 2, 1969.

60. In 1977, Hubbard's spy world exploded when the FBI conducted raids on the Intelligence Bureaus of the Guardian Offices in Los Angeles and Washington, D.C. From evidence collected in that raid, 11 top Scientologists went to jail, including Hubbard's wife, Mary Sue. (I was Scientology's National spokesman on the day of the raid and the months that followed.)

61. On October 6, 1979, Hubbard's wife Mary Sue and eight other Scientology executives signed a 282 page (plus exhibits) Stipulation of Evidence that stated the government's case. That document details the burglaries, forgeries, conspiracies to obstruct justice and other crimes committed. However, it is the Sentencing Memorandum for Jane Kember (The Guardian) and Mo Budlong (her intelligence chief) of September 16, 1980, by Assistant US Attorney Raymond Banoun that gives the most succinct view of how--Fair Game was conducted after 1968. In fact, the memo discloses an admission by defendants that Fair Game continued even beyond the conviction of Mary Sue Hubbard, until mid-1980. (Banoun speculates in the memo "as to whether these illegal activities were ever terminated by defendants.")

62. The memo relates how the defendants combined intelligence and legal to defraud and abuse the courts. Portions are hereby excerpted from it.

"These crimes included: the infiltration and theft of documents from a number of prominent private, national and world organizations, law firms, newspapers and private citizens; the execution of smear campaigns and baseless lawsuits for the sole purpose of destroying private individuals who had attempted to exercise their First Amendment rights to freedom of expression; the framing of private citizens who had been critical of Scientology, including the forging of documents which led to the indictment of at least one innocent person; and violation of the civil rights of prominent private citizens and public officials."

The memo points out how Mary Sue Hubbard had said on the witness stand that she and her codefendants "felt they could do to others whatever they perceived, however erroneously, others were doing to them."

"They presented this Court with a shabby attempt at impeaching Meisner's credibility [the Scientology intelligence agent who turned and started the investigation that led to the raid] by claiming that he stole money from the Church - the same false claim they made against another former Scientologist who had the courage to expose their crimes and thus fell victim to their fair game doctrine." Allard v. Church of Scientology of California, 68 Cal.App.3d 439, 129 Cal.Rptr 797 (Ct. App. 1976), cert:denied, 97 S.&t 1101 (1977) - page 14.

"The defendants' contentions that they committed the crimes of which they stand convicted in order to protect their Church from Government harassment collapses when one reviews a sample of the remaining documents seized by the FBI during the execution of the two Los Angeles search warrants. If anything, these documents establish beyond question that the defendants, their convicted co-defendants, and their unindicted co-conspirators [which included Ron Hubbard and current Scientology counsel, Kendrick Moxon], as well as their organization, considered themselves above the law. They believed that they had carte blanche to violate the rights of others, frame critics in order to destroy them, burglarize private and public offices and steal documents outlining the strategy of individuals and organizations that the Church had sued. These suits were filed by the Church for the sole purpose of financially bankrupting its critics and in order to create an atmosphere of fear so that critics would shy away from exercising the First Amendment rights secured them by the Constitution.

FOOTNOTE: The defendants and their cohorts launched vicious smear campaigns, spreading falsehoods against those they perceived to be enemies of Scientology in order to discredit them and, in some instances, to cause them to lose their employment. Their targets included, among others, the American Medical Association ((AMA) which had branded Scientology's practice of "Dianetics" as "quackery"; the Better Business Bureau (BBB), which sough to respond to private citizens' inquiries about the courses offered by Scientology; newspapers which merely sought to report the news and inform the public, law firms which represented individuals and organizations against whom Scientology initiated lawsuits (often for the sole purpose of harassment): private citizens who attempted to exercise their First Amendment rights to criticize an organization whose tactics they condemned; and public officials who sought to carry out the duties for which they were elected or appointed in a fair and even-handed manner. To these defendants and their associates, however, anyone who did not agree with them was considered to be an enemy against whom the so-called "fair game doctrine" could be invoked. Allard v. Church of Scientology, supra. That doctrine provides that anyone. Perceived to be an enemy of Scientology or a "suppressive person" "[m]ay be deprived of property or injured by any means by any Scientologist without any discipline of the Scientology. [He m]ay be tricked, sued or lied to or destroyed." Id., 58 Cal.App.3d at 413 n.1, 129 Cal.Rptr at 800 n.1.3 This policy, together with the actions of these defendants who represent the very top leadership of the Church of Scientology, bring into question their claim that their Church prohibited the commission of illegal acts."

"It is interesting to note that the Founder of their organization, unindicted co- conspirator L. Ron Hubbard, wrote in his dictionary entitled 'Modern Management Technology Defined' that 'truth is what is true for you,' and 'illegal' is that which is 'contrary to statistics or policy' and not pursuant to Scientology's 'approved program.' Thus, with the Founder-Commodore's blessing they would wantonly commit crimes as long as it was in the interest of Scientology."

"These defendants rewarded criminal activities that ended in success and rebuked those that failed. The standards of human conduct embodied in such practices represent no less than the absolute perversion of any known ethical value system. In view of this, it defies the imagination that these
defendants have the unmitigated audacity to seek to defend their actions in the name of religion."

"It is clear from the press releases issued by Scientology following the jury's verdict, and their vicious actions against another member of this Court, that they have yet to learn the errors of their criminal ways."

63. The other member of the Court that was being referred was Federal District Judge Charles Richey who as the target of a sting operation conducted by a private investigator hired by Scientology that forced the judge to recuse himself from the Scientology case he was sitting on. The judge was allegedly set up with a prostitute. The action was clearly Fair Game. Scientology publications however called it a "BIG WIN." He would lot be the last judge to be the target of Scientology Fair Game,

64. In 1981, a new campaign was undertaken against Gerald Armstrong, a staff member who had fled with some of Hubbard's files. Contrary to what Scientology executives have said, there were Fair Game actions taken against Armstrong after the GO was "disbanded." I know because I sat in on those strategy meetings and was ordered by Hubbard as well as David Miscavige to "get Armstrong." For example, Hubbard created a "reward" poster that would characterize Armstrong as a criminal. I did not comply with the order, for which I was severely berated by Miscavige.)

The use of Fair Game on Armstrong was confirmed in 1984 when California Superior Court Judge Paul Breckenridge, Jr., ruled against Scientology with a opinion that included a statement about the civil rights of members and Hubbard: "In addition to violating and abusing its own members' civil rights, the organization over the years with its 'Fair Game' doctrine has harassed and abused those persons not in the Church whom it perceives as enemies. The organization clearly is schizophrenic and paranoid, and this bizarre combination seems to be a reflection of its founder LRH. The evidence portrays a man who has been virtually a pathological liar when it comes to his history, background and achievements. The writings and documents in evidence additionally reflect his egoism, greed, avarice, lust for power and vindictiveness and aggressiveness against persons perceived by him to be disloyal or hostile."

65. Another judge who stepped down from a Scientology case was Federal District Judge James M. Ideman. But as he did so, he filed a declaration in his court on June 21, 1993 which said, in part: "Plaintiff has recently begun to harass my former law clerk who assisted me on this case, even though she now lives in another city and has other legal employment. This action, in combination with other misconduct by counsel over the years has caused me to reassess my state of mind with respect to the propriety of my continuing to preside over the matter." Part of the problem, he said, was seeking to have Scientology comply with discovery. They would not comply, he said. Judge Ideman later remarks how Scientology apparently views "litigation as war" and seeks to break the opposition through increased litigations costs. This is not news to members of the Guardian's Office, now known as the Office of Special Affairs. This is part of Fair Game.

66. The reason that Fair Game does not stop is because the doctrine stems from policies and directives by Hubbard and they cannot be cancelled or exchanged except by him. Since he died in 1986, nothing past that point can be changed. This is also stated in an issue of July 7, 1982, called "The Integrity of Source which said: "It is hereafter firm Church policy that LRH issues are to be left intact as issued."

"No one except LRH may cancel his issues."

"No one except LRH can revise his issues whereby changes are incorporated into the text and then reissued. Any valid revisions must hereafter be made in a separate issue stating the change and how the revision is to be read. . . "

"Already existing issues stand intact and valid."

67. On Saturday, October 23, 1993, from 9:00 a.m. until 3:30 p.m., my deposition was taken by Kendrick "Rick" Moxon, in Dickerson v. Sally Jesse Raphael, et al. I have known Moxon since about 1973 when he was in the Legal Bureau of the Guardian Office in Washington, D.C. After the 1977 FBI raid, Moxon was named as an unindicted co-conspirator by the Federal Grand Jury that indicted Mary Sue Hubbard and ten others. Moxon is thus a key example of how Scientology executives have lied when they say that anyone involved in the Guardian Office was removed and none remain. Moxon remained in the Guardian Office, even when it underwent the name change to the Office of Special Affairs (OSA). Moxon is still OSA staff and is now the lead in-house attorney for OSA, church of Scientology International. His law firm (Bowles & Moxon) pretends to be an independent law firm when, as it is well-known in OSA and all other senior ranks of Scientology, he and the firm are controlled and operated by OSA and then by OSA's senior, the Religious, Technology Center (RTC).

68. The stated purpose of the deposition that Moxon took was that I might be called to testify as an expert.

69. But not until the last 30 minutes or so of my deposition did Moxon even start to address my position in relation to the case at hand. The time was spent trying to find the names of those I have worked for or associated with since I left Scientology in 1989. I knew the purpose: to initiate the "Fair Game." In 24 hours, I received calls from two former employers who said Eugene Ingram, who was thrown off the Los Angeles Police Department for his association with drugs and prostitutes and turned to being a private detective for Scientology, had been trying to find information about me.

70. They are also harassing a woman who I had never met face-to-face. She has nothing to do with Scientology or any case. We had corresponded via a BBS (bulletin board system, a form of E-Mail) perhaps six months earlier and she had asked me to look at material she had written. I agreed and she mailed it to me. I did not respond and instead discarded the material. That Ingram had the material meant that he or someone had taken it from my trash. This is a standard "noisy investigation" technique.)

My interest in BBSs was generated by research I had conducted for an article in the May issue of Oranae Coast magazine (Exhibit "C").

71. As a result of their "fishing" tactics, one week after Moxon took my deposition in Dickerson v. Sally Jesse Raphael, his partner, Timothy Bowles used a portion of the unedited transcript to try to quickly exclude me as an expert witness in an unrelated case (Church Of Scientology v. Steven Fishman and Uwe Geertz) with a motion served on Fishman.

72. I left Scientology after I was mentally and physically abused to the point of breaking. I had been locked in rooms and assaulted until, like a prisoner of war, I had "confessed" to pre-ordained crimes and ordered to put them into my own handwriting. (The parallel of Scientology interrogation techniques to those of the Communists in obtaining "confessions" is staggering. Like many Communists, the Scientologist may even come to believe that he or she committed the fictional crime. The purposes of these "confessions" - particularly in their own handwriting - is to have material that can be used to blackmail or coerce the person later and thus to keep them in the organization, keep them compliant and to keep them from talking about the crimes being conducted in the name "religion".)

73. My wife was abused and was nearly crippled for life. We were physically separated on several occasions for months at a time to try and break our marriage. I had to literally sneak out from my captors to visit her and then sneak back before my absence was known.

74. I was physically assaulted by Hubbard Trustee Norman Starkey. I reported the felony in writing to Moxon as a church attorney but he disregarded it. That and other incidents leave no doubt in my mind that the people who still run this organization are capable of continued abuse, harassment and physical assault upon myself and my family. Their use now of a person who war thrown off the LAPD for association with prostitutes and drugs also concerns me.

75. The conduct of Moxon in my last deposition, harrassing me for hours, left no doubt what they intend: to use the courts for Fair Game as they have in the past.

76. Although I wish to exercise my basic constitutional rights of freedom of speech, freedom of association and freedom of religion, my desire to do SO makes me a target of retribution. I am "Fair Game" for merely wanting to walk away. No one walks away from Scientology. In Hubbard's words, he would "rather see you dead."

77. Because I know how abusive Scientology executives can become (especially via attorneys and private detectives who are used as cut-outs), I have taken additional security measures to protect myself, my family and my home. This includes briefing neighbors, family friends and law enforcement of our situation and possible tactics and methods and by whom.

78. I am not only willing but desirous to testify about the policies, practices and doctrines of Scientology as well as its link to Sterling Management and how Scientology abuses the courts and the law, But to do this fully, I require:

1. A non-Scientology related location. I am fearful for my personal safety: I was physically assaulted twice in Scientology organization by Scientology executives. I have seen others physically assaulted. I have also been locked up, kept under 24 hour guard, and interrogated for days on end until I broke. I cannot give free testimony at a Scientology location such as at the in-house attorney firm of Bowles & Moxon, nor any group affiliated with the World Institute of Scientology Enterprises.

2. No deposition recordings not authorized by the court. Surreptitious records (video as well as audio) are standard Scientology intelligence methods, They were done against federal agencies, federal judges and even private citizens. I have seen these recordings and heard the audio tapes that were secretly made. It is part of "Fair game"

3. No one in the room or nearby but attorneys and officers of Sterling and/or Cult Awareness Network. Scientology attorneys like to bring in others who have known the deponent plus a private investigator (who was thrown off the Los Angeles Police Department for his link to prostitutes and drugs.) The purpose for bringing them in is intimidation while the attorney conducts the third degree. I am willing to respond to an attorney, not a gallery. Nor do I want any others on the premises, lurking in the halls or a nearby restroom where I can be kidnapped, harassed or beaten as Scientology executives have done and ordered done.

4. No harassment. Their cop-turned-criminal has already undertaken the "noisy investigation" on me, per Hubbard's "scriptures." This has included contacting former employers and harassing those they think might know me, sometimes misrepresenting himself as with the LAPD. My trash is also occasionally stolen. And the middle-of-the-night phone calls have started. (This is where the invention of the answering service is appreciated.) I want my family, my friends and my home safe from their Fair Game harassment. They have a right to investigate but not to conduct what Hubbard called "Black Propaganda" where discreditable information is provided people under the guise of an investigation.

5. No information from my confidential Scientology files. Scientology touts how various files are "confidential" and "priest/penitent." But under Fair Game, they violate their fiduciary relationships and cull the folders for what might be embarrassing or harassing. Some of this is "laundered" by giving the information to other people who then testify about it. I know how this is done because I saw these tactics used time and again. I also know that Scientology executives deny it is done. This is a lie and they know it. It is simply Fair Game.

6. No penetration of attorney work product in unrelated cases. In my last deposition, they sought to learn the names of other Scientology-related cases and attorneys I have been in contact with. They also tried to trick me into lifting the confidentiality of other cases so they could gain information. They also were listing the names of attorneys and cases to see if I had worked for any of them. All of this is Fair Game where they have complete disdain for the legal process.

79. I have a right to be an ex- Scientologist and to express my expert opinion and to give sworn testimony without being attacked, harmed, harassed or intimidated by thugs, executives, attorneys or anyone in their hire. And my family and friends have the right, to be free from Hubbard's Fair Game Doctrine.

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

Executed this 23 nd day of November, 1993 at Orange, California


Robert Vaughn Young