GRAHAM E. BERRY, State Bar No. 128503

GORDON J. CALHOUN, State Bar No. 84509
221 N. Figueroa Street, Suite 1200
Los Angeles, California 90012
Telephone: (213) 250-1800

Attorneys for Defendant



non-profit religious ;





Case No. CV 91 6426 HLH (TX)



Trial Date: 02/08/94
Pre-Trial Conf.: 01/31/94

Motion Cut-Off: 01/24/94
Discovery Cut-Off: 12/30/94

Hearing: January 4, 1994
Courtroom: 1001


        I am ROBERT VAUGHN YOUNG. I am over 18 years of age and a resident of Newport Beach, California.

        1. I was in Scientology for over 20 years. For nearly all of that time I was a staff member. I also trained others in Scientology techniques. I have read, studied and heard millions of words by Scientology Founder Ron Hubbard including thousands of pages of unpublished manuscripts and private papers and letters.I am thus familiar with and am an expert on Scientology.

        2. I viewed a videotape of the deposition of Heber Jentzsch, President of the Church of Scientology International. According to the dating on the tape, it took place on 12/28/93.

        3. During that deposition, Jentzsch was asked if before the deposition he had read any policies or received a "sec check" or a session. At the end of the deposition, his attorney cited this as "harassment." I would like to explain to the court why this is a complete smokescreen.

        4. First, I have known Heber Jentzsch for perhaps 25 years. He and I worked together many times. I have even drilled him in certain PR (public relations) techniques and he has reciprocated. Like him, I spent my career as a PR in Scientology and I know what we and others do in preparation for situations such as depositions, trial testimony and even major media events where we must answer questions.

        5. If a person feels uncomfortable about a forthcoming event such as a deposition, Scientology has various techniques to assist them. This can include a "session" where the person is counseled on the problem. Or a "set check" which is used to find crimes against Scientology. Or "word clearing" where material is read and the words "cleared" or defined. Or "Cramming" where the problem is found and studied.

        6. In many instances, material may be provided to the person to read. This can be very innocuous material. For example, the person is unsure of the corporate structure and feels if they are asked about it, they may not be able to respond properly. They might then be given material about this. Or it might be found that their worry is that they will be asked about an earlier deposition and so a copy of that is found so they can review it.

        7. In short, Graham Berry's questions were merely directed at the means of finding if there were any actions taken by Jentzsch that would have prompted him to read material to prepare for the deposition as these techniques are commonly used by Scientology executives before being deposed or testifying or making major public appearances.

        8. There is also drilling, where the people take the role of the attorney as well as one's counsel and (if for a trial situation) the judge. Questions are then asked and "drilled" or practiced so the person feels comfortable and knows what to expect and how to answer. Particular answers may or may not be practiced, depending on the case, the person and the importance of the answer. This was originally called "witness school." Written material on how this was to be conducted can no longer be found but the practice continues and its existence is kept a secret from the courts and opposition attorneys.

        9. I was called by the Church of Scientology to testify as an expert on The Life of L. Ron Hubbard during the trial of Church If Scientology of California v. Gerald Armstrong in 1984. My orders then were to "get Armstrong." These came from Hubbard and David Miscavige, who is now the head of the Church. I testified about Hubbard's life and archival documents that Scientology said Armstrong stole and Armstrong's work. The Judge (Breckenridge) found Armstrong and severely berated Scientology's tactics, including attempts to suppress testimony. A true and correct copy of Judge Breckenridge's decision (I am cited in it) is attached as Exhibit "A." His decision is also valuable for the notion of "privacy" and how Scientology screams yet violates the privacy of others. Breckenridge also discusses the use of Fair Game and the violation of member's civil rights. This is what executives are still trying to hide, with the same tactics they used in the Armstrong trial.

        10. "Drilling" is one of the most-used techniques in Scientology. Everything is "drilled," from how to answer a phone to how to answer questions by attorneys or reporters. Jentzsch has spent thousands of hours in drills, as I have. The idea that he did not drill for this deposition is ludicrous. That is one reason that they do not want me to attend his deposition is because I can spot the techniques. It is like watching a very skilled magician. Another magician can see the sleight-of-hand and tell you what to watch for. In this case, it would be one highly-experienced PR watching another. I also know the language and can discern when information has been held back or avoided. That is why they object. I know the arcane language, the techniques and tricks that are used.

        11. One technique that was used quite effectively in the depositions was "tagging" (also known as "black and white") where two people alternate with harrasive questions and statements to one person. The idea is to confuse, overwhelm and dominate. For example, see pp. 57-58. Plaintiffs' counsel Bowles makes a point regarding a non-appearance. Berry tries to respond. Plaintiffs' counsel Moxon interrupts and says, 'Go ahead," Bowles then says, "Go ahead." Berry tries and Moxon cuts him off and complains Berry is not asking questions of the witness. This is "tagging" where each person (Bowles and Moxon) are chopping up a person, "tagging" to the other.

        12. I might add that Jentzsch objected to being called an actor. Yet he used to rightfully brag about his film career. He has also performed in many shows and is a highly skilled performer and singer. He can no longer cite that career because seniors such as David Miscavige berated him and ridiculed him and they are the ones who can demote him back to doing manual labor again. This is one of the ways that people are controlled in Scientology.

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

Executed this 29th day of December, 1993 at Los Angeles, California.

Robert Vaughn Young