A. Leipold, State Bar No. 77159
LEIPOLD, DONOHUE & SHIPE, LLP
960-A West Seventeenth Street
Santa Ana, CA 92706
Telephone: (714) 796-1555
facsimile: (714) 796-1550
Craig J. Stein, State
Bar No. 98041
ZARTENBERG JAFFE GELFAND & STEIN LLP
11755 Wilshire Boulevard, Ste. 1230
Los Angeles, CA 90025-1518
Telephone: (310) 479-0044
Ford Greene, State
Bar No. 107601
HUB LAW OFFICES
711 Sir Francis Drake Blvd.
San Anselmo, CA 94960
Telephone: (415) 258-0360
Attorney for Plaintiff,
LAWRENCE DOMINICK WOLLERSHEIM
COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
CHURCH OF SCIENTOLOGY
Case No.: C
DECLARATION OF JESSE PRINCE
I, Jesse Prince declare
1 . I am over 18
years of age and currently reside in the State of Illinois, County of
Cook. This declaration is of my own personal knowledge and if called upon
to testify to the facts herein I could and would be competently able to
IN SCIENTOLOGY THE SEA ORGANIZATION
2 . I joined the
Sea Organization, commonly referred to as the Sea Org, in September of
1976. The Sea Org is a paramilitary organization that manages and controls
all of the Scientology Organizations and related entities that exist in
the world. I was also required to sign a billion year contract at the
time I was recruited. Within a week, I entered the first Sea Org indoctrination
program named the Estates Project Force. The Estates Project Force consists
of several levels of indoctrination named "Product Levels."
On these "Product Levels, l' I was indoctrinated in Scientology ethics
and justice procedures and the history of the Sea Organization. I was
invasively interrogated (called confessional in Scientology) and took
a mission school-training course, among other indoctrination courses.
Flag Order 3155RC, entitled "The Basic Sea Org Training Program,"
details the training required for persons newly recruited to the Sea Org.
A true and correct copy of this document is attached hereto as Exhibit
"HHH-99." From the very beginning, through indoctrination from
these courses, I learned that the Sea Org managed all Scientology Organizations
and related entities such as Scientology Missions International (SMI),
World Institute of Scientology Enterprise (WISE) and Narconon, to name
a few. The length and breadth of the doctrine of the Sea Org is detailed
and codified in issues named "Flag Orders." The primary business
of the Sea Org is missions. One definition of "mission" in Sea
Org terms describes an activity whereby two or more Sea Org members go
to a remote Scientology organization or enterprise and take over the activity
for the purpose of getting the activity to make more money which, in turn,
benefits the Sea Org financially. The governing policy of the type of
mission referred to above, is to cause the activity (Organization) to
make money, then make more money, then make other people produce so as
to make money. See HCO Policy Letter 9 March 1972 "Income Flows and
Pools," a true and correct copy of which is attached hereto as Exhibit
"QQ-99." These same missions are authorized by the Sea Org to
use Scientology ethics and justice procedures. This authority gives these
types of missions total authority to remove and demote personnel, including
corporate officers and executives in any Scientology Organization, corporation
or Scientology-related entity as it sees fit. See Exhibits: "M 99,
It "Y-99" and "FF-99," which are true copies of the
original documents. See also, Sea Organization Central Bureaux Order 621
29 November 1979 "By Pass of Management Sector Handling of,"
a true copy of which is attached hereto as Exhibit 'RR-99. "
3 . The success of the Sea Org is primarily measured by its income. Sea
Org income is defined as "the amount of money received by the corporation
(Sea Org) after the allocation to Sea Org and Scientology Organizations"
[translated, this means each and every Sea Org organization as well as
each and every Scientology organization world wide sends to the Sea Org
all monies remaining after the basic necessities (bills and payroll for
staff) of the individual organization are paid and before management expenses
are taken out; this is the classic double bite which normally reduced
the Sea Org and Scientology Organization staff payroll allocation]. This
is according to Hubbard policy letter of 9 March 1972, called "Income
Flows and Pools, Principles of money management," a true copy of
which is attached as Exhibit "QQ-99." This "policy"
was written by L Ron Hubbard. During my tenure in the Sea Org, I executed
many of these missions within the United States and other countries of
AND HIERARCHY OF THE COMMODORE'S MESSENGER ORGANIZATION AND THE SEA ORGANIZATION
4 . Until his death
in 1986, L. Ron Hubbard was the unchallenged dictator of the entire Scientology
enterprise. L. Ron Hubbard designated himself "Commodore". In
the hierarchy of the Sea Org, "Commodore" is the highest rank.
L. Ron Hubbard created a "statistic system" for every function
and activity of Sea Org and Scientology organizations and micro-managed
this created "statistic system." According to his many written
policies, the best thing a Sea Org member or Scientologist could do was
to always have "statistics" going up. Hubbard authored, or had
others author, many thousands of detailed instructions and directives
intended to teach his flock how to keep the "statistics" going
up. He wrote or had written Polices, Flag Orders, Bulletins and Executive
Directives concerning every aspect of the operation of the Sea Org and
Scientology organizations. Sea Org members and Scientologists are required
to follow these instructions and orders of Hubbard to the letter. This
is documented and made very clear in a policy letter written by Hubbard,
entitled "Keeping Scientology Working." This policy letter declares
that it is a "criminal offense" not to follow any L. Ron Hubbard
instruction to the letter. These crimes are punishable through Scientology
ethics and justice procedures.
5 . Next in authority in the Sea Org hierarchy are the "Commodore's
Messengers." L. Ron Hubbard authored Flag Order 3729, also known
as Executive Directive 106 Commodore's Messenger Organization (CMO), entitled
"Commodore's Messengers." This issue is one of many directives
and instructions on how to be a "good" Commodore's Messenger.
In the above issue, Hubbard shares his total authority over his Sea Org
and Scientology Empire with others who have been trained to think and
act in the same way as Hubbard himself. He designated his "messengers"
as emissaries of himself. This same issue was issued to all Sea Org members
with the instruction that all were to recognize his messengers as an extension
of himself. All were instructed to show his messengers the same respect
and courtesy as his flock of Sea Org members and Scientologists were required
to show Hubbard, the single highest authority of the Sea Org and Scientology
empire he created. Messengers had complete authority to go within any
Sea Org, Scientology, or Scientology-related entity. A true and correct
copy of Flag Order 3729 is attached hereto as Exhibit "UU-99."
As a note, only Sea Org members are ever eligible to become Commodore's
6 . There is a hierarchy
within the Commodore's Messengers Organization. The top messenger, also
known as the "Commanding Officer," commands and orders all other
messengers within the organization of messengers. The top Commodore's
Messenger in Scientology is David Miscavige. There are also subordinate
"In Charge" positions within the messenger organization. An
In Charge would have the authority to command and order lesser messengers,
Sea Org Members and any Scientologist if it meant complying with an order
from a higher messenger or L. Ron Hubbard himself. Two issues written
or ordered by L. Ron Hubbard, entitled CM0 Command Channels, issued 15
June 1976 and issue CM0 Regulations, issued 11 Jan 1976 are among the
many directives that define the authority of the Commodore's Messenger
Organization. A true and correct copy of CM0 Command Channels is attached
hereto as Exhibit "TT-99;" a true and correct copy of CM0 Regulations
is attached hereto as Exhibit "SS-99."
7 . There is also a hierarchy among the different messenger organizations.
The most senior messenger organization in all of the different messenger
organizations is "The Religious Technology Center" (RTC) . This
is documented in the many different "Command Channels" booklets
issued and authored, and/or authorized by RTC since the early 80s. See
8. The next command
level below RTC is called "The International Watchdog Committee."
The Watchdog Committee was created with the purpose of overseeing the
activities of the Guardian's Office and Scientology management bodies
in order to "keep Scientology working." It is a senior management
committee that manages all sectors of Scientology, i.e., all Sea Organizations,
all Scientology Organizations International, and related Scientology entities
such as Scientology Missions International (SMI), and World Institute
of Scientology Enterprise, International (WISE). See HCO PL 22 December
1981, "International Watchdog Committee," a true and correct
copy of which is attached hereto as Exhibit "W-99."
9 . The next level of hierarchical authority within the messenger organizations
and Scientology Enterprise is the "Commodore's Messengers Organization
International" (COMINT) . This body executes the orders and commands
of the Watchdog Committee, and manages and supervises the many other Commodore's
Messenger Organizations within the United States and abroad. (See Exhibit
10. Next in the chain of hierarchy is the Office of the Executive Director
International (EDINT) . The Executive Director International orders and
commands the senior-most Sea Org executives over all the different management
sections of the Sea Org, Scientology Organizations International, and
every other Scientology related entity. These executives in turn order
and command all areas of the Scientology empire. This office is not a
Commodore's Messenger Organization, but it is a Sea Org organization.
11. There are descending levels of the hierarchical chain of command from
this point, as described in Scientology's Command Channel booklets. From
early 1983 until January 1987, I was the second in command of the Religious
Technology Center. I was identified by RTC attorney Samuel Rosen as such
in Federal Court in Denver on August 20, 1998. See Exhibit 'C-99,"
A CLASSIC EXAMPLE OF THE APPLICATION OF "MISSION TECH"
TO BYPASS CORPORATE LINES OF AUTHORTIY
12. In October of
1982, I was part of a Sea Org Mission that was sent to San Francisco to
"handle" the Mission Holders of the Church of Scientology. The
Mission Holders were franchisees of Scientology who offered introductory
courses in Scientology to the public.
13. L. Ron Hubbard was upset with the Mission Holders because he felt
that the Mission Holders in general were withholding tithes owed to Sea
Org International Management. L. Ron Hubbard had also sent down orders
stating that several Sea Org members in high leadership positions within
the Commodor's Messenger Organization International ("CMO Int.")
and the Office of the Executive Director International ("ED Int.")
were dissatisfied with Scientology management and were siding with the
Mission Holders. L.Ron Hubbard's orders went to David Miscavige and they
were clear: Handle this insurrection and crush anyone who protested.
14. The missionaire in charge of the San Francisco Mission Holder's Mission
was David Miscavige. Mr. Miscavige is flat out attempting to deceive this
court in his declaration when he characterizes his presence at this conference
as that of an "invited" master of ceremonies. Mr. Miscavige
was the Missionaire I/C (In Charge) and was running the entire operation.
Further, his "invitation" certainly did not come from the Mission
Holders, it came in the form of Mission orders from the Commodore himself,
L. Ron Hubbard. Lest there be any doubt whatsoever about the truth of
what I am saying, I invite the court to examine Exhibit "L-99,"
a true and correct copy of which is attached hereto.
15. Exhibit "L-99," paints a far different picture of the San
Francisco Mission Holder's Conference than the "Shore Story"
Scientology is telling. Exhibit "L-99," THE SEA ORG MOVES IN,
is a newsletter that shows clearly how Miscavige and the Sea Org characterized
the San Francisco Mission Holder's conference for the purpose of letting
the staff and paying public of Scientology know who had won the power
struggle between the Sea Org and the Mission Holders. It gives a far truer
picture of what was going on at this conference than even the published
"transcript" of the conference, because the transcript was heavily
edited before Miscavige approved it for publication.
16. I was part of the mission headed up by David Miscavige that was ordered
to handle the San Francisco Mission Holder's Conference. The first thing
the mission did upon its arrival in San Francisco was to visit the local
Scientology Organization. Missionaire I/C, David Miscavige immediately
bypassed all corporate lines of authority and started an inspection of
the organization. He decided that the Executive Director of the organization
was incompetent and he viciously interrogated him with an e-meter, (a
form of lie detector), physically abused him, and removed him from his
position on the spot.
17. From the local Org, we proceeded to the Mission Holder's Conference.
By this time, David Miscavige had really worked himself into a lather,
and he declared two Mission Holders "Suppressive Persons" and
expelled them on the spot. This is brazenly bragged about in the issue
"The Sea Org Moves In." The doors to the conference room were
locked and guarded. Miscavige then lined up approximately 20 other Mission
Holders, most of whom were crying and terrified, and told them to get
their checkbooks ready as they had been "ripping off" Scientology
Organizations of their 'rightful income" for too long. In reality,
Miscavige and several others just took whatever amount of money they wanted
out of the Mission Holder's corporate accounts.
18. Miscavige introduced Larry Heller, attorney for Scientology who was
personally hired by Miscavige, who informed the Mission Holders that the
"New Tough Management" intended to prosecute and jail anyone
who did not comply with the orders and directions of the new management.
19. Lyman Spurlock, a senior Sea Org executive who was one of Miscavige's
inner circle, threatened the Mission Holders with prosecution and explained
that the Sea Org now had the power to do this to the Mission Holders because
of all the new corporate changes that were designed to exert more control
over the Mission Holders.
20. The "new management" is pictured in their Sea Org uniforms
at the speaker's table in Exhibit "L 99." These are the same
people who manage Scientology today, and they do it in the same manner,
through their positions of power in the Sea Org.
21. When all of the speakers were done, each and every Mission Holder
was viciously interrogated by multiple missionaires using the e-meter.
Then each mission holder was required to have a mug shot taken, one from
the front and one from the side, in the same way police commonly do. After
the mug shots were taken, the Mission Holders were required to write checks
from their corporate accounts for the maximum amount of money possible.
22. When all the Sea Org Missionaires returned to Gilman Hot Springs,
which is the true home of Scientology's International Management, the
results of the mission were sent directly to L. Ron Hubbard. The Commodore
was very pleased with the report he got from David Miscavige and decided
to make it a policy to run this mission in European countries where Scientology
existed. I was sent on this mission along with others to do the same activity
to Mission Holders in Copenhagen, Denmark.
23. This activity continued in other locations, executed by the International
Finance Police under the direction of the International Finance Dictator
located in the Commodore's Messenger Organization International. All of
this was under the dictatorship of Miscavige.
ATTACK THE ATTACKER
24. Attached hereto
as Exhibit "A-99," is a true and correct copy of a Scientology
directive titled "Attacks on Scientology, Additional Policy Letter,"
which states, in part:
is the correct procedure:
Spot who is attacking us.
Start investigating them promptly for FELONIES or worse using
our own professionals, not outside agencies.
Double curve our reply by saying we welcome an investigation
Start feeding lurid, blood, sex, crime actual evidence on
the attackers to the press
ever tamely submit to an investigation of us. Make it rough, rough
on attackers all the way...
talk about us - only them. Use their blood, sex, crime to get headlines.
Don't use us...
the spotlight to them. No matter how. Do it!"
25. Attached as Exhibit
"AAA-99," is a true and correct copy of the Committee of Evidence
and "Declare" statement of Alex Sibersky, and attached as Exhibit
"BBB-99," is a true and correct copy of the Committee of Evidence
and '"Declare" statement of David Mayo.
26. I was a member of the committees of evidence documented in Exhibits
"AAA-99" and "BBB 99." There was no fairness involved
in these supposed "justice" actions. Hubbard considered that
these people were "disaffected with management," and disloyalty
(meaning questioning anything at all) is the worst crime a Sea Org member
can commit. What was going to happen to these people was already pre-determined
by Hubbard and executed by Miscavige. We were required to sign our names
to a document that had already been prepared. I have personal knowledge
that such actions are based on longstanding policies.
27. Attached hereto, as Exhibit LL-99 is a true and correct copy of Flag
conditions Order 7068, 27 December 1982, SUPPRESSIVE PERSONS DECLARE pertaining
to eight separate individuals.
28. With regard to my former position as a high-ranking executive in the
Sea Org, even Scientology attorney Samuel Rosen told the judge in the
FACTNet hearing in Denver that I had been second in command of all of
Scientology (See Exhibit 'C-99") . I was an expert witness on the
subject of Scientology on behalf of RTC in the Robin Scott/David Mayo
litigation. In addition, on December 31, 1986, Miscavige himself introduced
me as "Deputy Inspector General" at a New Year's Eve event at
the Flag Land Base in Clearwater, Florida. I gave a briefing at that event
about how RTC was going about crushing people who tried to apply any part
of Scientology technology without paying for it, an issue which was part
of the Scott/Wollersheim II litigation. (A true and correct copy of a
audio tape of the Scientology New Years Event of 86/87 is contained on
Exhibit 'Xx-99," attached to this motion.)
29. I did give two taped interviews, which contradict my statements in
this declaration concerning Miscavige's control of Scientology. The first
interview occurred shortly before Halloween in 1992. With my wife, I was
trying to get permission to leave the secret compound in Gilman Hot Springs,
and they would not allow us to leave unless I agreed to state on audiotape
that I was leaving on my own free will, that I was happy and pleased with
being incarcerated against my will on the Rehabilitation Project Force,
that I had committed many crimes in Scientology and Scientology had helped
me overcome these criminal tendencies, that Miscavige was not the dictator
of Scientology, and that I had never witnessed any illegal activities
being committed within Scientology. I was also required to make self-denigrating
statements on this tape which were not true. I was threatened by Marty
Rathbun and Mike Sutter that if I did not agree to make this taped statement,
I would become the target of Fair Game. The giving of "interviews"
such as I went through are part of the policy of Scientology and anyone
leaving the Sea Org is required to "route out" pursuant to policy
or be declared.
30. The second interview happened in Boston in 1994. Mike Sutter called
me and said that he wanted to see me to find out how I was doing. He made
it sound like a friendly chat that we were going to have. At that time
I was still afraid of the imagined power these people had over me. I agreed
to meet with Mike Sutter and Scientology attorney Earl Cooley at Cooley's
office in Boston. Instead of a friendly chat, it turned into an interrogation
in which they told me they were doing poorly in some of their legal cases
and demanded to know if I was assisting "the enemy." Before
I was allowed to go, they drilled me on what to say and then put it all
on tape. They took information from my auditing folders and kept "reminding"
me of things I had said in sessions.
31. These taped statements
are Scientology's way of attempting to destroy the credibility of a former
Scientologist who has knowledge that can harm the organization in case
that individual later decides to come forward to expose the truth.
32. Until the reorganization of 1982, in which RTC was formed, it had
been CSC that registered the trademarks for Scientology. RTC was specifically
created to take over that function from CSC. As far as I know, AS1 took
over the function of overseeing the copyrights.
I declare under penalty of perjury that the foregoing is true and correct
under the laws of the State of California executed this ___day of December
1999, at Tampa, Florida