I, Zoe Woodcraft declare as follows:

1. I am 16 years of age.

2. The statements herein are of my own personal knowledge and if called upon as a witness, I can testify competently thereto.

3. In 1986, when I was two years old, my parents and 15-year-old brother joined the Sea Organization at the Flag Land Base in Clearwater, Florida. My seven-year-old sister and myself were put into the care of the Cadet Organization at this time. My family and I lived at a building on U.S. Highway 19 called the "QI" which was an acronym for Quality Inn. This building was once a Quality Inn hotel. The cadet organization was located there.

4. The room we were assigned to live in was very small, approximately 12'X 20'. It was one room and one bath; very shabby, infested with cockroaches and smelling of mold. All five of us were in this room so it was very cramped and nearly unlivable.

5. My parents were shocked when we were first shown these living quarters. When they had been recruited to come into the Sea Organization to work for Flag they had been promised a new, two bedroom apartment in the Hacienda Garden complex; that we children would go to private school and that they would get one day off every two weeks. We soon found out none of this was true.

6. After about a year we returned to England to take care of our visas. I remember being in England and playing with a cousin and not wanting to return to Florida and our horrible living conditions.

7. I also remember my father being suddenly sent away and I had no idea when he might return. This frightened me, as I feared I would never see him again. I was told he had been sent to the ship but no one could tell me when he would return. He did return after 6 months.

8. We lived in Florida for about two years and then my mother was transferred to Los Angeles.

9. In Los Angeles I was placed in the "CEO" which stood for the "cadet estates organization." This was a building located next to Celebrity Center International. This is where I lived, by myself, for the next two years. My parents and brother were placed in adult living quarters and my older sister into the Cadet Org down the street. This building housed only younger children. We did not live with our parents, but were assigned to the care of "nannies."

10. Eventually my father had to take a leave of absence from the Sea Org to further take care of visa problems. He rented an apartment at this point and our family moved in. He then began working for a company owned by a Scientologist. He was supposed to work in this company for one year in order for our family members to obtain green cards. Technically, I lived in this apartment with my parents, however because both of my parents worked such long hours I would be taken to the CEO in the early morning and then picked up by my parents late in the evening. This was my basic schedule until I was six years old.

11. When I was six I was moved to what is called the "Int Ranch." This is a compound in Happy Valley, CA. We were told that this was a secret location and I was instructed not to tell my father where it was as he and my mother were now divorced and my father was no longer in the Sea Org.

12. I was placed in a dorm that was acceptable; i.e. nice carpet, neat etc. However, neither of my parents lived on premises and there was a sixteen year-old boy named Sterling Thompson who was in charge of about twenty of us younger children, known as "pre-cadets." All together there was a staff of about six or eight adults who ran the compound and about one hundred children living there.

13. My schedule at the ranch was: wake up at 7:00 a.m., take one half hour to get dressed for the day then go to breakfast. Meals were highly regulated. We were assigned seats and each table had a "table captain" who made sure the assigned steward brought our food from the kitchen to the table. It was placed on the table and we served ourselves. Afterward we cleaned our own tables. We had half an hour to eat.

14. After breakfast we worked, dumping trash, mopping floors, sweeping etc. We were assigned cleaning stations throughout the compound. All our work was supervised by Sterling. We worked for about 20 minutes.

15. We then went to school for four hours with one fifteen minute break. Often, the school schedule was changed. Sometimes we did four hours in the morning and two at night, after working in the afternoon, and sometimes we did six hours straight.

16. Most of what I studied was Scientology materials. I remember doing the Basic Study Manual when I was six or seven years old and it was very difficult for me. This is a course geared for adults. When I did not score well on the final test, the instructor first told me to redo sections of the course and then told me to redo the entire course. I then had to start all over on this course. The only other subjects studied were reading and math.

17. After school, we had half an hour for lunch, and then we lined up and did group drills. We did "left/right/left marching, chanting of Scientology doctrines, and relay races to increase our "particle flow" so we could work faster. Then we received our work assignments for the afternoon.

18. The work consisted of such things as collecting rocks from a stream, putting them in a wheelbarrow and taking them to where a stone wall was being built; raking the football field after it had been mowed; and weeding. Most of the time we pulled weeds as the appearance of the compound was very important. We were often told how lucky we were to be allowed to live here. We worked all afternoon from lunch to dinner.

19. Before dinner, we showered. After dinner, we went to study for two more hours.

20. One thing that occurred some months after I had been there was that one afternoon we were all gathered up and directed to go to a house that was for what we called the "big boys." This was the house that Justin Miscavige lived in with several other boys. It was a very nice place, much better than the dorms. They had art paintings on the wall, whereas in our dorms we were only allowed pictures of L. Ron Hubbard or the Apollo ship. They also had different colors on the walls and the bedding, whereas the dorms were in nautical colors: navy and gold. There was no house for the big girls. Older girls just lived in the dorms with us younger children.

21. The day we were taken to the big boys house we were told to stay inside. I was told by the adult watching us that what was happening was we had too many kids at the ranch and a health inspector had come to check on us. So, we were hiding until he was gone.

22. In describing my bedroom, I again state all bedrooms were done in dark colors. Bedspreads were navy with a gold Sea Org symbol imprinted on them. The curtains were navy; the carpet was blue. We had brown dressers upon which we were not allowed to place personal items or family photos. We were not allowed to hang any personal photos or pictures; only the LRH or Apollo pictures.

23. One of the courses I had to do soon after arriving was the "make the bed" course. I had to learn how to fold the sheet corners so the bed was perfectly tucked and no wrinkles on anything. The final drill was making a perfect bed in less than five minutes.

24. At the ranch we dressed in uniforms. These consisted of khaki shorts with a red t-shirt or polo shirt with the Sea Org emblem embroidered on it. We also had sweat pants and dress pants and a vest. We could not wear our own clothes ever while on the ranch with the exception of pajamas.

25. As far as free or play time, there was none. Every aspect of our time was scheduled and controlled. Sometimes in the summer we were given twenty-five minutes to swim but that is all.

26. At the ranch there is also a form of punishment called "pigs berthing." This is levied against those who had a dirty dorm or dorm area. The punishment varies in different cadet orgs, but in this one offenders had to spend the night in what was called "The big house." The big house was an abandoned building with rotting floorboards and broken windows filled with insects, rats and bats. I clearly recall two girls about nine years old who were forced to spend the night there and in the middle on the night they ran screaming and crying from the building. One of the girls afterward told me that they had been terrified by the bats and couldn't stand it anymore.

27. This ranch was hours away from normal civilization. In the year plus that I lived there we never went into town for a field trip; never went to a movie, shopping or anything. We were totally isolated. The only time I ever left was when I was allowed once to take a leave of absence to visit my father at Christmas.

28. At the age of seven I was also made an MAA. This is a person who watches out to make sure no one is slacking in his or her work and to write reports when other children are misbehaving. For example one incident I had to write up on myself was when I had snuck into a snack shack and taken a bite of someone's candy bar. Another boy was made to stand up in front of the group and list off things he had stolen, such as a pen from a teacher. He listed about thirty such incidents of having taken or borrowed things without asking. This was extremely humiliating for him - he was about ten years old - and the next day he was kicked off the ranch.

29. Every Friday night my mother came at about 2:00 in the morning to pick me up in a car. We would return to her housing about half hour away and I would visit her until 12:00 noon the next day. This was the extent of my time with her. On alternate weeks, when I was to visit my father, my mother arranged for a friend of hers to pick me up and take me to my father's house as my father was forbidden to come to the ranch. I would stay there with my dad over night until 10:30 a.m. then I would have to return to the ranch. I often asked to stay longer, but I was always refused permission. This often upset my father and me. I felt like I had spent a lot of my life saying goodbye to my father.

30. The last few weeks I was at the ranch, I learned my mother had been sent to New York on a mission. After she was gone about three weeks, I was sent to be with her.

31. I was now in Manhattan. Here, I lived in a room with my mother. There was a bunk bed and I slept on top and she on the bottom. This room was relatively clean and nice as my mother was an "Int Missionaire" which meant she was highly ranked and the other staff members were frightened of her authority.

32. My schedule here was to hang out all day with six or seven other kids also in the building. I did no schooling during the entire time I was in New York, which turned out to be eleven months. My mother once asked me if I wanted to go to public school, but I thought public school was horrible and "the enemy" as this is what I had been taught all my life. I told her I didn't want to go and she said ok. While in New York, I turned eight.

33. At one point my mom put me in the Scientology course room to study training routines, but I didn't like it and upset the supervisor and eventually stopped. I did get to go out each day to either a comic store or to get a slice of pizza. Other than that I had no outside contact with non-scientologists. Also, there was a guy named Eugene who's job it was to watch the kids and he did take us to Central Park and to the empire state building.

34. Each Thursday night, my mother had to do the financial planning for the scientology organization and she would not come to our room in the evening. I would go to bed, but early in the morning hours I would get scared and wander around the building looking for her. I usually found her typing away in an office and I would stay with her until she came to bed.

35. Right before my ninth birthday, we returned to Los Angeles. I could not return to the ranch, as they had no more room for me. So now I went to the Apollo Training Academy.

36. The Apollo Training Academy is a training organization for scientology cadets i.e. children age seven and up. While a member of this organization I lived in the Anthony Building [AB] located on Fountain Street. The AB was a four-story heap: the pool was covered over with plywood and we were instructed not to walk on it, as it was flimsy and unsafe. Children played on it anyway as we were often unsupervised. The carpets were old and smelly and there were a lot of cockroaches. We slept in metal bunk beads with chipping paint. There was no proper bedding; not one of us had a complete sheet set, blanket and pillow. I slept without a pillow for many months.

37. All of the furniture was very old and decrepit. For light, we had bare bulbs hanging from the ceiling. The kitchens had also been ripped out to make more room for people so there were exposed pipes everywhere. These were the worst conditions I lived in during my tenure as a child of scientology.

38. This building was in an unsafe area of Los Angeles and I often heard gunshots at night. It was a very frightening place for me to live. The adult woman who was supposed to be our nanny - there were about eleven girls in my dorm - was missing most of the time. She didn't even sleep there and I remember never knowing where she was. At this time, my mother was again on a mission, this time in Mexico, so I did not see her at all. My dad, however, did begin picking me up again every two or three nights so I could stay with him.

39. The fact that I had contact with my father, who was not living within the confines of scientology, made me happy. This was a place I could go and have nice surroundings and eat whatever I wanted and he would give me spending money, as otherwise I had no money at all. I also had better clothing than the other children, who were wearing very poor clothing as their parents could not afford nice clothes and there were no uniforms here.

40. Meals at the AB were served three times a day. I don't remember what sort of food it was just that it was bad.

41. The bathrooms in the AB were also not fully functional and we often had no warm water, the tiles in the shower were moldy and we had no soap or towels.

42. In addition, the elevators in this four-story building never worked so we always had to use the steps.

43. My schooling during this year took place at the ATA building that was a five-minute bus ride away in a scientology complex. I again studied scientology principles and policies, math, reading and spelling. There were about two hundred kids in this school and we were just packed together. Kids even studied in the cafeteria where they would have to clean up their studies so we could eat. We also had no real schedule at this school. Every Monday was beach day and I did no studies on that day. We would often go to a park and spend the whole day there, also. They would also take us to a fifty-cent swimming pool, however a lot of the kids did not have the money to swim so we just sat around all day. If we asked the teacher for money, she said no and told us it was too bad for us we had no money.

44. Another activity we were assigned at the AB was what we called "chicken picking" the carpet. Since we had no vacuum cleaner, we children were instructed to get down on our hands and knees and pick dirt out of the carpet. This dirt included paint chips and we were expected to leave our section in perfect condition. This was very hard to do, especially in the small space between the carpet and the wall. There would be all sorts of small trash in there including paint and staples that hurt my fingers.

45. I lived in the Anthony Building for about two years in 1992 to early 1993 when I received a call from my mother, who I had rarely seen during this time. She asked me how would I like to come visit her in Florida for about three months. I didn't even really know where she was. I said yes, I would like to go. I didn't think I was moving permanently to Florida, because I didn't want to leave my dad. I just wanted to see my mom as I hadn't seen her in a long time.

46. So, I was flown out to Clearwater, Florida where my mom met me at the airport. She took me to her room at the Hacienda Gardens where I spent the night on her bedroom floor, which she shared with another staff member.

47. The next night, after I had been taken to a nice meal at a steak house, my mom took me to the Quality Inn (QI). She led me to a dorm room and exclaimed, "This is your room! It's nice!" and then she prepared to leave. At this point I begged her not to go and leave me. I cried and did not want to stay alone. It was one of the worst nights of my life. I was afraid at this point that I was going to be staying here permanently.

48. Later as I lay in bed, very upset and missing my father and sister in Los Angeles, I became sick and threw up my steak dinner. The next day I started on the schedule of the cadet organization.

49. Now, I had to work every day. I worked in my mom's office (Hubbard Communications Office) every afternoon filing and sorting letters. It was a similar schedule to the Int ranch schedule except instead of working outside in the afternoon I worked in an office.

50. It was at this point also that I signed a Sea Org contract. Actually, I had signed such a contract at some point earlier; this was the second one I had signed. This contract says I will work for the scientology organization for this entire life and the next one billion years. I also was told to read a policy that stated that if anyone is in scientology and does not want to be there they can just tell the captain and they will be allowed to leave. Of course, I didn't want to stay but I didn't want to upset my mother. Also, I was nine years old.

51. Schooling during this period was a bit broader than my previous experience. We studied some geography and some cultural information. We also had more diverse reading. Always, about forty percent of my schooling was scientology study. When I first got there, I only did four hours of school per day, in the morning, then worked in the afternoon, then just hung out at the QI and played at night. No one supervised our play in our rooms. After some time I started studying in the evenings also. This was called night school and it was purely scientology study.

52. Though I did see my mother in her office every day I did not spend any time with her. She was very busy and if I wandered into her room she would tell me to get back to work. The only time we spent together was Saturday mornings when I visited her at the Hacienda. This was also the only time she had to clean her room, so it was not real quality time. Occasionally, I went to her apartment the Friday night before and stayed the night. This was special to me.

53. Contact with my father during this time was very difficult. I did not know how to initiate contact and my mother was not happy with me when I sought her help. I found out later that he would call and call and finally fax angry messages demanding to speak to me. I did eventually receive these messages and permission to call him, but the deputy cadet commander always sat in the room with me when we spoke. From the time of my arrival at Flag, it was three months before my first contact with my dad, and about four months between calls thereafter.

54. After some time at the base, I was given permission to visit him twice a year. I originally visited him once in the summer and once at Christmas, however my mother and the cadet org frowned upon this as I was staying away longer than the time allowed for "leave of absence." We were only allowed three weeks leave per year and I would often extend my visits with dad because I didn't want to go back. I told my dad I didn't want to go back, but he was still a scientologist at that time and told me I had to.

55. I always got very depressed when it was time to return. I would cry through the whole flight and often upset the stewards on the plane. However, I composed myself as the flight neared Florida because I didn't want my mother to see that I was upset. She always became angry if I showed I did not like living at Flag. I also knew my mom did not like my father. She said he was "Ex-Sea Org and therefore a DB [degraded being]." There is church policy that states this as a fact that sea org members believe wholeheartedly.

56. I stayed in the cadet org for many years. At one point I moved dorms because I had been originally placed in a nice dorm, as my mom was "International management." However, when she got posted to Flag and became regular personnel, I was no longer privileged.

57. The room I was moved to was much worse. The pink carpet had brown stains on it and it had the most cockroaches I had ever had to live with. Only one other girl lived in this room. I didn't know her because I hadn't lived there long and I was shy and this girl was considered to have bad ethics. I stayed in this dorm for some months, and then I moved again. From 1994 to 2000 I lived at the QI in various dorms, some nicer than the others. I moved nine times that I can remember. Only during the final six months of 2000 did I live with my mother. By that time I was 15 years old.

58. All of this moving was very unsettling. Often, once you had become comfortable you would all of a sudden be told you had to move. Usually, this was to accommodate someone of a higher rank moving into the area. When you were told to move you had to quickly gather your belongings and go to wherever they assigned you whether you liked it or not.

59. One of my work assignments was to demolish the walls of a room. This was a strange room that had plywood attached in two layers on all the walls. We were ripping the plywood off the walls. When I asked the cadet coordinator what this room was he told me it was for "ethics particles" who had become upset or hysterical. He would place them (children) in this room and lock them in. Some of them had become so upset that they were kicking holes in the original walls as they were only drywall, so he had layered the walls with plywood so no one could kick through.

60. Life at the QI was overall depressing and dreary. The only place to play was the parking lot. We were always on a boring and strict schedule. I was never allowed to leave the QI premises and we rarely went on outings. I worked every afternoon and the entire day on Sundays. In fact, on Sundays we had "renos" (renovations) day where we worked to fix up the premises of the QI. If we did not have special permission on Saturday afternoons, after our parental visits, we also had to do renos. We were allowed to watch movies every Saturday night in the cadet room and this was our one point of fun, although we never got to select the movies; they were chosen by the governess Italia and at one point she was in love with a move called "White Knight" and we had to watch that movie over and over again for weeks. This was not a children's movie and it was unbelievably boring.

61. After one change of cadet coordinators, our reading and music selections were censored. Our rooms were searched for offensive materials and if something not approved was found it was confiscated. For example an Alanis Morrisett tape was taken away because she was "downtone" and "too much in anger." Archie Magazines were considered "too sexually oriented" and these were forbidden. Seventeen Magazine was also not allowed, nor were any fashion magazines because of the "middle class orientation" and sexual content.

62. Over the years I rose up in post. (By the way, I was considered a "missionaire" from the cadet org during the time I worked in my mom's office.) I once was the animal room I/C (in charge) of the pets. We had snakes and a tarantula and rats and a bunny. I liked this job. I then went to work as an "MAA" (Master At Arms), which deals with ethics. I had many other jobs in the HCO division and eventually became Exec Esto. On this post I carried out programs written by myself and the cadet coordinator to improve the cadet org. When I was the LC (LRH Communicator) one of my jobs was to make sure all the pictures of Ron Hubbard looked nice, so I was always cleaning cockroach feces out of the frames and the cardboard backing. I would also lead people in the chanting of scientology doctrines.

63. As the HAS and Director of Inspections and Reports I had to read the "overt write ups" of the other cadets. This would include the reports written up about masturbation and other sexual activity between the cadets. I also participated in courts of ethics and committees of evidence for children. These are disciplinary actions per church policies.

64. During some of these years I was considered a pre-cadet and at around age 11 I became a cadet. There is some pressure applied to convince children to become cadets.

65. First, it is made clear that at around the age of ten or eleven you should become a cadet and if you do not you are constantly asked why you are not a cadet.

66. Secondly, cadets receive privileges that other children do not. Cadets are paid weekly. When I first became a cadet I was paid sixteen dollars a week, but this was reduced to eight dollars some time later. There were special certificates that one could earn for extra money. These were originally worth $25.00 but were also reduced to be worth only $12.00. I did earn these certificates through good behavior and high production on my job.

67. Thirdly, cadets were given better accommodations. Non-cadets (called simply "children") and cadets had to live separately. If you were a plain "child" at the age of ten and not a "cadet" in cadet quarters you were treated differently and looked down upon.

68. Fourth, cadets were allowed more freedom of movement. They could leave the QI premises by themselves (in pairs- never alone) and if their stats were up they were allowed to go bowling. If they were "Cadet of the week" they received ice cream.

69. The drawback to becoming a cadet was that you were now, per the church policy, on the route to becoming a sea org officer. Per the policy, the definition of a cadet is "one who is training to be an officer."

70. The first time I was asked to become a cadet I said I was not sure I wanted to be in the Sea Org. I was missing my dad and thinking of returning to California. The cadet coordinator was shocked and told me I had to work this out. I told him I might want to go to college. He told me I had to do a condition of doubt. He also notified my mother.

71. I then did the condition of doubt that is designed to keep people in the Scientology organization. During this condition you have to compare the statistics of two groups you are trying to decide between. I was shown church propaganda about how wonderful the Scientology organization was, like Freedom magazine. I was then shown statistics concerning crime and children using Ritalin, as well as news stories about arsons and death. This was to prove to me that the scientology world had better statistics and was more ethical than the "Wog" (non-scientology) world. I was told about how bad psychiatrist were and all the horrible things they do to people in order to compare how scientology is a much better method of mental health. Also, I was so ashamed of being assigned this condition that I simply wanted to get out of it. The condition of doubt is a lower condition and one also loses privileges and is looked down upon when in doubt.

72. I also had a conversation with my mom about my doubt. She was angry about my not wanting to be in the Sea Org. She asked me if my father had been influencing me against scientology. She even called my sister in Los Angeles and told her to relay the message to my father to not say anything to me against scientology. She asked me where I got the idea that I might want to go to college. She thought this was completely insane.

73. At this point, I decided to stay in the Cadet org. I was eleven years old.

74. When I was twelve or thirteen I was recruited into the Cadet TTC (Technical Training Corps.) We were in training to become supervisors and word-clearers for the cadet org. I now studied the works of L. Ron Hubbard eleven hours a day, six days a week. On Sundays, I did ten hours of regular schooling. I was studying adult courses like the Student Hat course and the Hubbard Qualified Scientologist course. These are the same courses offered to adults in the orgs and missions around the world. I did this for almost a year.

75. During this time I had no free days other than Sea Org day and Christmas day and one two week trip which was very fun. We drove on a bus and went camping and visited Washington D.C. and Pennsylvania. This was an extraordinarily special trip and only a few cadets were allowed to go. In ten years there had only been four such trips all of which were arranged by Rusty Hilton and his wife.

76. I was studying the Student Hat course for seven months. It was very difficult and I hated it. Soon, I was being asked to leave the cadet org and go into the Sea Org proper. This looked attractive to me, as I hated the TTC and the Student Hat course. I decided to join the Sea Org (SO) and was routed onto what is called the "EPF" or Estates Project Force, which is the first step in training for the SO. I was fourteen years old.

77. Now, I begin the EPF. Again I am moved to a new dorm, which was quite crowded and located at the Hacienda Gardens. I studied at the staff training building near the Super Power building.

78. The general schedule was to wake at 7:30 or 8:00 to be at muster {meeting} by 9:00. We then had twenty-five minutes or less to eat breakfast. Then we had to race to quickly clean up after meal. From there I went to work doing cleaning or heavy-duty physical work. This included mopping floors, polishing and dusting banisters, vacuuming, carrying camera equipment for Gold studios, putting up plywood in the Hacienda Gardens where they were renovating, laying carpeting and shoveling gravel, intended for the Sandcastle roof, into the bed of a dump truck.

79. Specifically, for many days I worked all day in the heat of a Florida summer shoveling gravel into the bed of a truck. The truck was very tall and I had to reach and strain to toss the gravel from the heavy shovel. I became dizzy and faint while doing this work. Sometimes we were given water but not often and we were not allowed to take many breaks, as there was so much work to be done.

80. Another time we were re-carpeting the Clearwater bank building. There were a lot of teenagers working on this project. There was one hired carpet layer and a bunch of EPFers. We were tearing out carpet, putting down glue, ripping out sideboards and using a "knee pusher" to flatten out the carpet. I worked at this for a week, sleeping during the day and working during the night, all through the night. The staff was eating in this building during the day.

81. While I was doing the above a older Russian man (about 60) named Sasha had a carpet knife and accidentally slashed his arm. He was bleeding terribly and no one was doing anything to stop the bleeding. I grabbed hold of his arm and put pressure on it to stop the bleeding. We walked to a van outside, trailing blood, and drove to the hospital. There was so much blood all over that the nurse had to ask which one of us was bleeding.

82. At the hospital, the doctor was trying to communicate to Sasha but he didn't speak English. I finally told him we were with scientology and he agreed to treat him. He received stitches and I returned to work.

83. Another project we did was remove upholstery tacks from the nautical chairs in the CB and replace them with new ones. Again, we were working all night long and sleeping and studying during daylight hours. We did this for three nights in a row.

84. Mr. Dave Englehart, who was the EPF In charge, was known to have a very bad temper. One man named Vladimir from Russia had smelly feet and Mr. Englehart told him to handle it. One morning at muster he screamed, "What's that fucking smell! I thought you to get that handled!" He then pushed another EPF person (dorm captain) so the whole line of people was knocked about. He then went to Vladimir, who spoke and understood no English, and yanked up his foot and knocked Vladimir to the ground. He tore the shoe from his foot and threw it, yelling at Vladimir that he should have soaked his feet in bleach water. Vladimir was very upset and shaken by this as were we all.

85. There was another young man named Josh Greenwood who was younger than me. There was a bad storm and we all went to the Sandcastle to place sandbags. Mr. Englehart told us this was very important to protect the Sandcastle and if any of us fell in the ocean to swim to the side and for no one else to jump in to help. Josh snickered at the intensity of Mr. Englehart's speech and Mr. Englehart responded by shoving the boy and dangling him over the edge of a high stoop - about five feet high - and pretending he would drop him to the pavement below. The boy was very shaken and cowed. 86. On the EPF we had to be with our group at all times. Once I walked to the store by myself and the EPF captain ran after me and asked me where I was going as I knew I wasn't allowed to go by myself. Also, all phone calls to anyone outside of scientology were regulated. In fact I was told that frequent contact with outside family members was forbidden; once a week was too frequent. Often, he would allow no phone calls at all, always complaining about the outer contact.

87. I was on the EPF for nine months. This is an extremely long time to be on the EPF. Most people do it in weeks. I had to go back for word clearing on what I had studied on the TTC. All of this study correction and discipline for going slow and being told I wasn't smart really shook my confidence and made me think I was a dull person. Eventually, I just went back to the cadet org. This was in mid-1999.

88. Here I worked again, reposted to a new job. Of course, I was back in a new dorm, but now I could also visit my mom on Saturday mornings. On the EPF, I couldn't see her at all because those on the EPF are not allowed the Saturday morning time off.

89. It is hard for me to remember what happened next. At some point they were working to get me to return to the EPF. I kept saying no, no, no. I finally told them I was not at all sure I wanted to dedicate my entire life to the Sea Org. The moment I became honest and told them this, I was again placed in a condition of doubt.

90. In addition, I was placed on a program to "handle" my feelings aboutnot wanting to be a Sea Org member. While doing this program, my father and sister (who was by now out of the sea org herself and living a normal life with my father in Los Angeles) invited me on a vacation to Hawaii. I really wanted to go with them and I sought permission. At first, permission was denied, but I argued and argued until I was allowed to go.

91. During this trip, my dad would mildly criticize the sea org and scientology. I always immediately defended both organizations, just as I had always been taught. When we returned to LA from Hawaii, my dad really came down hard on me about the sea org. Eventually, he broke through. I admitted I really didn't want to be in the Sea Org and I did want to try going to school like a regular kid. He told me I could stay with him right then, but I felt so guilty and loyal to the church I insisted I go back and route out properly.

92. I then returned to Clearwater and upon my return my roommate Nicole Graham warned me that they were again going to try to get me to re-start the EPF, as there was some post that needed filled immediately. She was also trying to route out and that is the only reason a sea org member would tell me something like this. I was then able to mentally prepare myself for what was to come.

93. Three days after I returned, my mom came to visit the QI. This was her fist visit to the QI in years. I immediately knew what she was up to. Acting very motherly and using her affection, she and the cadet coordinator, Jim Sydjeko, asked me to take a walk. As soon as we were outside the office, they stopped and my mom started in.

94. She told me I had been working on my program and she wanted to know what I had decided. She said there was some post I was needed for and I should return to the EPF. Well, I answered her honestly, telling her I wanted to go to college and become an interior decorator. When she heard this, my mother was absolutely floored. She became visibly irritated and her "motherliness" no longer came through so well.

95. Of course, for the next hour and a half she tried to talk me intostaying and rejoining the EPF. She asked me how I was going to help the planet by going top college and a lot of other stuff I just didn't know at the age of 15. However, I had seen my mother do her work on many other people. Often, she had held me up as a shining example of a cadet, even though I was a thoroughly miserable child. I knew what was going to come out of her mouth before she said it. Thus, I was able to maintain my position. I wanted to leave.

96. Now, I was given what is called a "routing out" program. These were steps I had to take to leave the Sea Org. Most of the steps had to be worked with other people and I soon found that, as a matter of course, there was no one able to help me. After weeks of no help and no progress, I grew angry. Additionally, steps were continually being added to my program. Eventually, my mother said I should word clear the entire Student Hat, which is a huge course, and this was added to the program.

97. I became very upset when they added the Student Hat. I had been word clearing for years and all it made me do was think there was something wrong with me. When I became upset they blamed me, saying I was only angry because I still had mis-understood words. At this point, also, I was supposed to still be attending regular school, but now 90% of my studies were Scientology doctrines and policies.

98. During this time I was trying to stay in touch with Astra (my sister) and my dad. I called them every week or two. This was seriously frowned upon and the staff and my mother often scolded me for it. I was made to feel guilty and told I was doing something wrong (i.e. it was an overt to stay in contact with these "outside influences.")

99. After a couple of months, I was so filled with anger that I began arguing frequently with Jim Sydjeko, the cadet coordinator, begging for a word clearer and the other help I needed to do my program. He just yelled at me and said I was out-ethics and selfish, that they had more important things to do than work with me. When you are routing out you are no longer important and no one will help you or treat you well.

100. Sometimes, he would yell at me and advance towards me, backing me against the wall and yelling at me so hard that spit flew from his mouth into my face. I would start sobbing when he did this, and he did it several times.

101. My mother also did not like Jim and was blaming him because he had not "handled" me as a cadet to stay in the Sea Org. In the afternoons, I would see my mom when I went in to Flag to work (I still had to work every day.) She would tell me she could get me word clearing at the FH, but this happened only three or four times. At this rate, I knew it was going to take years for me to route out and I started getting feelings of dread and hopelessness.

102. After three months of trying to route out, I sort of gave up and just started working for my mom full time, not going to school at all. I returned to the QI to sleep at night. One day some cadets arrived at mom's office while I was working, carrying many of my belongings in a cardboard box and my laundry basket. I asked what was going on and they said they didn't know, Jim had just told them to bring me my stuff. Now, I really flipped out because the one place I had always lived was the QI and now I had been removed from there. I had no idea where I was supposed to go.

103. When I met my mom on break I told her what had happened. She said, oh, I thought you wanted to come live with me. This had never been discussed before and it was really upsetting to me. I did not want to live with her because I knew she was very controlling and trying to get me to stay in the Sea Org and this would only aid her. Nonetheless, I moved in with her, as I had no place else to go.

104. In my mom's small bedroom at the Hacienda Gardens, which she shared with an 80-year-old lady, I slept on the floor squeezed between a table and my mom's bed with no mattress, just a pillow and a blanket.

105. Now, I worked all day from 9:00 a.m. to 11:00 p.m. At this time, I started sneaking to the Clearwater library in the mornings just to read, as I had been forbidden to read so much for so long. I started reading magazines, newspapers, and books -- whatever I could. My mom was angry with this and told me not to do this but I continued.

106. My mom now got me back into school again at the cadet org but only on Sunday for 10 hours a day. However, all I studied was Scientology and I quit after three weeks. My schedule then became work all day seven days a week, no schooling except for my visits to the library, sleeping on my mom's floor, eating my meals in the Clearwater Building. I was no longer even working on my routing out program. I was very depressed; it was one of the worst periods of my life, because people no longer like me because I wanted to leave, I was not in uniform anymore, my friends talked to me only to convince me to stay, and all the people who had known me through the years shunned me.

107. As Christmas time approached, I started pushing again to finish my leaving staff program so I could be with my dad at Christmas. My mom would not agree or help me so I went to the Chaplain. The Chaplain talked to mom, who convinced him not to help me as I am just out-ethics. So, I spent Christmas with my mother.

108. This Christmas, my mother and my grandmother (also in the Sea Org) bought me lesser gifts and gave them seemingly begrudgingly and my mom only took the morning off to be with me.

109. Soon after Christmas, I began calling my father and sister more frequently; several times a week. I called from public phones, often from the Library, either collect or using my dad's calling card number so my mother wouldn't know. I really started complaining about not going to school and not being allowed to leave. I was becoming more and more angry.

110. In late January during one of these calls, my sister said to me, "How about you just leave? We'll come get you or buy you a ticket." At this point I was sick of feeling ashamed of myself for wanting to leave and certain they would never let me finish my leaving program. Also, I had recently been subject to re-recruitment efforts to re-start the EPF and this frightened me. Some time before, the Commanding Officer of the Commodores Messenger Organization (CMO, a specialized organization comprised mostly of young girls) had become very angry with me when I had refused to rejoin. She had ordered me to go start the EPF at once. I ran crying to my mom for help but she said she could not help and started asking, "Why don't you go on the EPF again?" I had then just gone home and refused to go to work at all for the next week.

111. So this time when Astra said just leave, I felt sudden relief. This is what I wanted to do. So we started planning. We decided I would leave at the end of February 2000. I was afraid to call a cab; I had rarely even rode in a car, so my dad agreed to fly out and rent a car and pick me up near Flag.

112. I started to sneakily pack my stuff in a cardboard box and two backpacks. The night before I was leaving I kissed my grandmother good night, feeling very sad because I wondered if I would ever see her again. Then I went to bed. The next morning was my escape day.

113. I woke up late! Nervously, I grabbed my stuff and for one of the first times in my life caught a ride with a staff member who drove a vehicle (he had a vehicle because he worked for renovations and needed it. Most staff are not allowed cars.) My cardboard box was stashed in a hidden closet in the Coachman building. I had been bringing my stuff in my backpacks every day and secretly filling the box. I was so nervous every time I spoke to anyone, thinking they would know I was going to blow.

114. When I got to work, I made up an excuse to see my mother, who was on study. Normally, it is not permitted to interrupt staff study. I gave her a kiss and said I would see her later. She was a bit annoyed by my visit. I felt so bad because I was leaving her, but on the other hand I didn't want her to know and stop me. She was like my mother and the enemy.

115. Now, I took my two tightly packed backpacks and headed for the Clearwater Library. A sea org member saw me walking and approached me. I freaked out inside, but he just made small talk and I smiled and answered, then walked on. When I got to the library, I saw my dad sitting there in a car. Now, I knew I was really leaving. I was so excited and emotional I wanted to cry but knew we really had to rush to catch our flight out.

116. I talked with him briefly then told him I had to get my cardboard box. My dad waited in the parking lot and I ran back to the coachman building to get the box from the closet. I grabbed the box, but it started falling apart and I couldn't let others see my clothes falling out. I left the box in an alley nearby, ran back to my dad and jumped in the car. We then drove over to the coachman to get the box in the alley, ducking as we passed the known surveillance cameras all over the streets of Clearwater.

117. We got to the alley and I dashed out to grab the box. Dad came to assist. My knees were shaking and I was constantly looking around to see if any Sea Org members were noticing. We managed to get the box and all the contents into the car, jump in and head for the airport.

118. I was in emotional turmoil at this time. When we got on the airplane, I began to really question what I was doing and started to cry. I was afraid I was ruining my life. However, I went through with it.

119. When we got to LA, I called Flag and left a message for my mom, telling her I had arrived in LA safely. Then, I went home with my dad. By the time we got to his apartment, there were messages from mom telling me to call her. I didn't call her even though I was an emotional mess, shaking and crying. Soon, she called back and the first thing she said to me was "Well, that wasn't very smart, was it?" Her attitude and mean spiritedness convinced me that I had done the right thing in leaving.

120. Additional incidents, which were not recounted in the above narrative, include the heavy labor children did at the QI. For example I used a jackhammer to break up concrete block and frequently used a circular saw to cut wood for bunk beds. All the children made their own, wood bunk beds.

121. When I used a jackhammer I was happy to do so as normally we were made to break up concrete with a large pick axe.

122. The QI has two floors and there are iron railings running all around. We children were made to sand the rust from them and paint them and try to make them stable with screws and nails. They were often so loose you could not lean on them and they would be tied to the roof with rope to secure them.

123. Children also painted the doors to the rooms and walls, fix holes in drywall, layed tile, cut scrap carpet and fit the pieces together to make a whole and lay on the floor. They would also use acid to wash bathroom floors that were caked with mineral deposits.

124. These are all samples of the labor done by children in keeping the building in satisfactory condition.

125. Regarding medical treatment while I was in the Sea Org, I once fractured my foot when I was about 13. My bone was fractured from my pinky bone to my ankle and I was in terrible pain. I couldn't walk at all and stayed in bed late, but still had to get up and work. The cadet coordinator checked me and told me I just had a sprain. After about a week it was not better so I went to the MLO. I waited all day and no one helped me. They finally helped me toward the end of the day. One of the MLOs took me to a nearby scientology chiropractor.

126. I was told this chiropractor would take cheap x-rays. She took them, saw the fracture and pointed it out to me and advised me to see a doctor. I was never taken to a doctor. To this day, my foot still hurts and aches when I run.

127. While I was on the EPF, I was working a lot with acid. I had no protective gloves and my skin became very dry and chapped and started peeling off. Something also happened to my feet as they became sore and red, then crusty even on top. They would crack and bleed and the bottoms were so sore I could hardly touch them. I had to continue working until I begged to go to the MLO. By this time, I could barely walk or move my fingers.

128. The MLO, who is not even a medically trained person, said it looked like some sort of fungus and would go away. I was given no treatment and sent immediately back to work. I bought my own lotion at the store and was constantly using it to take away the pain.

129. I suffered this condition up to the time I went with my father to Hawaii. When he saw my hands and feet he immediately got me some medicine and applied it frequently. By the time I returned to the Sea Org it had cleared up.

130. I want to state that the church promises you that all your medical cares will be attended to. This is not true. Medical cares are ignored unless they are extreme. You are considered to be doing something wrong if you are sick or injured.

131. Any care that costs money has to go through a long process ofapproval
that can take months. I know my grandmother paid for some of her friends surgery or medical treatment because they could not get the funds approved through the church system and were in dire need of treatment.

132. I also once cut my arm badly, where I could see white flesh, and this received no treatment other than wrapping. I have a very bad scar on my arm from this injury.

133. Another thing that happened was we children were hauled around in old, broken down school buses. These would often break down and on three occasions I and other children were directed to get out of the bus when it broke down and push it to the side of the road while the driver steered.

134. At times, the cadets received no pay at all because the base was not making enough money. One of the things we had to spend our money on was doing our laundry and buying our own hygiene items. This included laundry detergent, shampoo, tampons, soap and toothpaste. We also were responsible for certain items of clothing like underwear, socks, bras and our own hair brushes etc. This was all to come from our $8.00 to $12.00 per week pay.

135. We had to wash our clothes in the coin-operated machines provided at the QI. This would take up to half the pay I received as a cadet.

136. The other part of my pay I often spent on food because I couldn't stand what we were served at the QI. Our meals were leftovers brought from the Clearwater Bank building. One of our dinner meals was bread with cheese melted on top of it. This was served once a week. When I left in 2000 there were no desserts served ever as the base was not making enough money for these treats.

137. We also did marching drills at the QI and on the EPF. We marched together and learned formations like the number eight. We also had to run and do double and triple time and what we called the "dead run" where we had to run all-out as a group keeping in marching formation, up stairs and all over.

138. Another drill we had to do on the EPF was to run up all ten flights of stairs. In fact, no EPFers were allowed to use the elevators in the Fort Harrison hotel. When we did maid work or any work in the FH (like painting on the tenth floor) we had to run up and down the stairs all day long.

139. On the EPF we would get so hungry that we would take food from the trays left over by the "public" staying in the hotel room. When we were working, if we passed these trays in the hall or near the kitchen we would always steal any left over food. This was a regular occurrence while I was there in 1998 and 1999.

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

Executed in Clearwater, Florida this 24th day of January 2001.

Zoe Woodcraft