Attorney for ROBERT VAUGHN YOUNG

IN THE CIRCUIT.COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, LAW DIVISION

ROBERT VAUGHN YOUNG, declares as follows:

1. I am above the age of eighteen years old, am not a party to this action, and if called upon to testify in open court would testify as follows:

2. I am a resident of the State of California, City of Corona Del Mar.

3. I have reviewed a copy of the amended complaint in the above action filed on October 19, 1994. I understand that Scientology wants to take my deposition. I am providing this declaration to show that there is no basis for Scientology to depose me. I have reviewed a copy of the Amended Verified Complaint At Law filed herein on October 19, 1994, and am familiar with the allegations set forth therein. I have no information pertaining to said allegations.

4. I have never met Cynthia Kisser. I have spoken to her on the telephone, but never had any communication with her regarding the allegations in this lawsuit, or anything concerning her personal life.

5. I am not a member of the Cult Awareness Network.

6. I possess no information whether or not Ms. Kisser has ever been a "topless dancer in the Blue Note Bar in Tucson, Arizona" or any place else, as alleged in paragraph 5 of count I and paragraph 6-A of count II of said amended complaint.

7. I possess no information whether or not Ms. Kisser was ever "fired" because "she caused numerous problems with co-workers and customers" as alleged in paragraph 5 of count I and paragraph 6-A of count.11 of said amended complaint.

8. I possess no information whether or not Ms. Kisser had ever "picked up the mantle of Nazi architect of the Holocaust Reinhart Heydrich who in 1936 was ordered by Hitler to rid the Third Reich of "sects and cults" as alleged in paragraph 6 of count I of said amended complaint.

9. I possess no information whether or not Ms. Kisser, or individuals associated with the Cult Awareness Network kidnap individuals as alleged in paragraph 6-B of Count II of said amended complaint.

10. I possess no information whether or not Ms. Kisser, or individuals associated with the Cult Awareness Network provide individuals with drugs whose possession and distribution are prohibited by law as alleged in paragraph 6-C of Count II of said amended complaint.

11. I possess no information whether or not Ms. Kisser, or individuals associated with the Cult Awareness Network are associated with individuals who have been convicted of crimes involving sexual perversions as alleged in paragraph 6-D of Count II of said amended complaint.

12. I possess no information whether or not Ms. Kisser, or individuals associated with the Cult Awareness Network are Nazi- like, associated with Hitler and advocates of Holocaust type solutions to the problems of "sects and cults" and are thereby guilty of crime against humanity involving mass murder as alleged in paragraph 6-E of Count II of said amended complaint.

13. I possess no information whether or not Ms. Kisser, "had a previous career as a topless dancer at the Blue Note Lounge in Tucson, Arizona. Now defends the pedophile crowd in Nebraska" as alleged in paragraph 5 of Count IV of said amended complaint.

14. I possess no information whether or not Ms. Kisser, or individuals associated with the Cult Awareness Network have been associated with Dahmer, the Milwaukee man accused of cannibalism and dismemberment of his murder victims as alleged in paragraph 7- A of Count IV of said amended complaint.

15. I possess no information whether or not Ms. Kisser, or individuals associated with the Cult Awareness Network "took to the airwaves and newspapers to protect a pedophile ring in Omaha, Nebraska as alleged in paragraph 7-B of Count IV of said amended complaint.

16. I possess no information whether or not Ms. Kisser, or individuals associated with the Cult Awareness Network have been associated with psycho-killer Charles Manson and linked to the infamous Son of Sam murders" as alleged in paragraph 7-C of Count Iv of said amended complaint.

17. I possess no information regarding the actions of defendants in disseminating any and all of the foregoing statements.

18. I possess no information regarding the manner in which Ms. Kisser was damaged as alleged in the amended complaint.

19. I possess no information whether or not Ms. Kisser ever sought a retraction of any of the above statements as alleged in said amended complaint.

20. I am providing this declaration in order to satisfy Scientology's need to know whether or not I have any evidence related to the above case. I do not. I believe that Scientology's desire to take my deposition is part of an on-going tactic of retribution in furtherance of its Fair Game Policy because I am a former Scientologist who has taken a public stance criticizing Scientology's practices, the character of its founder L. Ron Hubbard and its present commandant, David Miscavige.

21. I have been previously deposed by Scientology on three different occasions. If Scientology can provide some reasonable basis for taking my deposition in this case, I would consider making myself available for the same. In the absence of such evidence of good faith, however, I believe that Scientology is simply attempting to harass me.

Pursuant to the laws of the State of California and under penalty of perjury, I hereby declare that the foregoing is true and correct.

Executed on October 31, 1994 at Corona del Mar, California.

Robert Vaughn Young