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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS

LA VENDA VAN                           )
SCHAICK, et al                         )
                                       )
                    Plaintiffs         )
                                       )       CIVIL ACTION
v.                                     )           NO. 79-2491-G
                                       )
CHURCH OF SCIENTOLOGY OF               )
CALIFORNIA, et al,                     )
                                       )
                    Defendants         )

AFFIDAVIT OF JANIE PETERSON

I, Janie Peterson, being first duly sworn, depose and say:
  1. I joined the Church of Scientology in March 1975 and was a member until July 1980, during which time I spent 2 1/2 years as a staff member.
  2. When I was introduced to "auditing" I was told that all the information revealed in auditing sessions was strictly confidential between the auditor and the "pre clear" and that this was treated the same as a parishioner giving a confession to a minister or priest.
  3. After joining staff to work in the division that delivered the auditing, I became aware of the practice of many other people having access to and going through the auditing folders. These include but are not limited to: all technical division staff, students, ethics personnel, Guardian Office personnel; if on staff - the person's seniors, other auditors, case supervisors, "word-clearing" personnel and others.
  4. While acting as "Technical Secretary" I witnessed an out-of-state person named Morris Deutsch (I am not sure of spelling) from New Mexico's auditing folders, being sent to Las Vegas, Nevada to be gone through by the Guardian Office, as he was a "suppressive" person and an "enemy" of Scientology and the Las Vegas Guardian Office, was, at that time responsible for New Mexico also.
  5. During my time in Scientology, I witnessed out-of-state "missionaires" for the Church of Scientology of California come into the Las Vegas organization and go through auditing folders of people who they were trying to recruit for the "Sea Org" and/or people they were suspicious of for any reason. This would include people who had parents, spouses, friends, etc. that did not want them in Scientology. They had complete access to all auditing files and it was firmly established that we were to cooperate with them either in person, on the telephone, telex or any other means of request for information from a person's auditing folder. This occurred on many occasions while I was in charge of the auditing and the auditing folders.
  6. Guardian's Office staff and intelligence personnel from the Guardian Office had a series of files kept on Scientologists and reports, by other Scientologists, or auditing information from auditing folders, basically anything suspicious about a person who had voiced any disagreement with Scientology or L. Ron Hubbard or executives was kept in these files. I personally saw these files and knew that auditing information was being filed in these files and this was not known to the people receiving auditing.
  7. The Church of Scientology of California completely runs Scientology at all levels. The United States Guardian Office runs every Guardian Office in the country, including Clearwater, Florida. The executive management structure is in Clearwater, Florida. Another management structure is in Los Angeles, California (FOLO) and that this is also part of the Church of Scientology of California. These run the organization throughout the U.S.
  8. The above-described actions regarding the use of auditing information, access to auditing folders, Guardian Office staff using auditing information is standard procedure and is followed throughout the U.S. at the direction of the Church of Scientology of California.
  9. While working on staff in the Guardian Office, I witnessed staff going through the auditing folders of staff members and public people. This was a regular practice. I was aware that certain information people would reveal in auditing would be sent to the Church of Scientology of California, the United States Guardian Office and Clearwater, Florida, if requested or needed.
  10. While working in the Guardian Office, I personally saw a man I believed to be sent to Las Vegas by L. Ron Hubbard actually xerox copying Mr. Ernie Hartwell's auditing reports from his auditing folder.
  11. I also saw auditing information from the auditing folder of Tonja Burden that was sent to Carol Garrity, a Guardian Office staff member, from the United States Guardian Office in California and Florida and Carol had an order from her senior in the "USGO" to get said auditing information published in the news media. Miss Burden was at that time engaged in litigation against Scientology and L. Ron Hubbard and she was considered a top enemy of Scientology.
  12. This practice of using auditing information for other purposes than were stated at the time the person received his/her auditing was standard and done routinely during all my years in Scientology.
  13. I am aware of Lavenda Van Schaick's auditing folders being gathered in Las Vegas and gone through by Guardian Office staff members at the time Mrs. Van Schaick retained the services of Attorney Michael Flynn in Boston. This was done to gain information about Mrs Van Schaick.
  14. Outer "missions" under the control of "Class 4" organizations routinely sent auditing information from persons' auditing folders who were under "ethics" actions or were in some kind of trouble regarding Scientology in the areas where the missions were. If needed, this auditing information would be sent to the Church of Scientology of California and the United States Guardian Office, which is part of the Church of Scientology of California.
  15. A Guardian Program entitled "Shake and Bake" was written by the tip management of the United States and England Guardian Office to "handle" Lavenda Van Schaick so that she would not continue with litigation against Scientology and L. Ron Hubbard. I saw this program and part of it was an "information-gathering" section on Mrs Van Schaick, including going through her auditing information.
  16. Due to all of the above actions, when I thought about leaving Scientology and pursuing my legal remedies, I was in fear that these actions would be done to me and that my personal life and the information I gave during my auditing would be used to blackmail me and be taken to the news media for publication.
  17. During auditing a person reveals his most personal thoughts, feelings, actions and those of his families, friends and anyone influencing his life.
  18. I am also aware of a Guardian's Office operation to get Michael Flynn disbarred and thereby eliminate him as a representative of individuals who have been victimized by the Church of Scientology. I observed "operations" being planned and executed to infiltrate Mr. Flynn's law office with a "plant" named William Broderick. This operation was called "Operation Oscar". The purpose of that operation and others that were being planned was to get someone inside Mr. Flynn's office for the purpose of gathering information.

Signed under the pains and penalties of perjury this 25th day of May, 1982.

Janie Peterson

SUBSCRIBED and SWORN to before me this 25th day of May, 1982.

(PHYLLIS NORQUAY) NOTARY PUBLIC