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DECLARATION OF ROBERT VAUGHN YOUNG ROBERT VAUGHN YOUNG,
declare as follows; 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. 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 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;
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 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":
45. On using the law to harass (from the same text):
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.":
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:
48. In the same "scripture" he said:
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:
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:
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.
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."
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."
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:
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 |