1. I was a member of the Church of Scientology of California from October of 1968 until February of 1980. I joined the Church in Los Angeles, California, where I was primarily based although I also took courses and/or worked at Church organizations in St. Louis, Washington, D.C., Atlanta, Georgia and Miami, Florida.
2. While in Scientology I progressed to the level of OT 3 (an advanced level) and was also audited on New Era Dianetics for OT's, which is now OT 5.
3. During the summer and fall of 1979, I worked as a volunteer for the Church's "intelligence" operation, then called the Guardian's Office (G.O.) and now called the Office of Special Affairs, or O.S.A. I performed volunteer work for the G.O. at the Cedars location in Los Angeles and at the old Bank of Clearwater location in Clearwater, Florida. It is concerning some aspects of this volunteer work for the G.O. that this declaration is written.
4. In the fall of 1979, I was approached by a young woman from the G.O. in Clearwater and given a special project involving Pinellas County Circuit Court Judge Harry Fogle. I was told that Judge Fogle was ruling on an important case involving Scientology, although I was not told any further details of the case, which would have been normal, as the G.O. operated on a need-to-know basis. My understanding was that this operation was being supervised by a G.O. agent named Milt Wolf.
5. My directions concerning Judge Fogle were as follows. I was sent with another Scientologist, pianist Mario Feninger, to attend Judge Fogle's Sunday school class at the Seminole United Methodist Church in Seminole, Florida. Mario gave a short talk on Scientology for Judge Fogle's comparative religion class. My directions were to befriend Judge Fogle after the class and get him to give me a tour of the church while engaging him in conversation. I was to try to get him alone in a room with me.
6. I was then instructed by G.O. personnel that I would be called into court where I would, under oath, make certain allegations concerning Judge Fogle: namely, that he had made sexual advances toward me, and also that he had made certain disparaging comments to me about Scientology. This was to be used to disqualify the judge from a case before him dealing with Scientology. I was coached by several different G.O. personnel who pretended to be the cross examining attorneys.
7. I was coached for my performance in court according to the Scientology policy called TR-L (for Training Routine Lie) which I was already familiar with as I had been introduced to it on one of my Scientology courses. TR-L teaches a Scientologist to lie with conviction under stressful circumstances.
8. I remember asking one of the G.O. staff members about the fact that they were teaching me to lie under oath, and I was quoted the Scientology policy called "the greatest good for the greatest number of dynamics," which simply means that whatever must be done to ensure the survival of the "third dynamic of Scientology" must be done regardless of the side effects. In other words, Scientology law is considered to be above and outside the jurisdiction of non-Scientology or "wog" law. Scientologists do not honor the Biblical oath, even though they may say that they do. This is TR-L in practice.
9. As instructed, I did meet with Judge Fogle in his Sunday school class. After the class, I did engage him in conversation, got him to give me a tour of the church, and was at one point alone in a room with him. As it happened, I never was called into the courtroom to testify against Judge Fogle, and I assumed that the situation had been taken care of in another way.
10. I was also engaged in another project at the Cedars building in Los Angeles and this project had to do with the Federal action involving the eleven Scientologists charged with burglarizing federal offices in Washington, D.C.
11. It was Standard Operating Procedure in Scientology to assign private investigators to collect information on each judge, and each lawyer and witness for the opposition in any important case. This information was then brought into the G.O. offices where a work station had been set up for each person being targeted for investigation.
12. All the information collected on one individual, for example a judge, was then laid out in chronological order in what was called a "time track." Bits and pieces of paper would be taped on a long sheet of paper. It was then the job of a writer to come in and write a narrative from this time track, and it was common knowledge that this narrative would be made available to the Scientology attorneys and it would be used for blackmail purposes when possible.
13. I was the writer assigned to complete a narrative on the U.S. Attorney's Office attorney named Raymond Banoun, which I did do. I was told to highlight with a yellow highlighter any mentions in the narrative of sexual misconduct, use of illegal substances or other crimes.
14. In another project in this same time frame, I was assigned the task of going through witness Michael Meisner's supposedly confidential preclear files and similarly tabbing any incidences of sexual irregularities, drug use, or criminal conduct to be used against him.
15. I consider myself to have been an average Scientologist in the performance of these and other duties for the G.O. In one other case, I was included in a meeting where two murders were planned by Scientology personnel, and I was at that time in agreement with everything I heard planned in the meeting.
16. It is my opinion that I was brainwashed and under hypnosis by Scientology for twelve years. If I had been ordered to commit suicide by the organization I would have, without question. I think I might have taken a life if ordered. This was the strength of the mind control that I was under in Scientology.
17. Therefore, to perjure myself under oath when so ordered by the organization was not, to me, an unreasonable task, especially if I were led to believe that the security and/or survival of the organization was at stake.
18. I believe that most any ordinary Scientologist who was trained in Training Routine Lie would, upon command, lie in court, and would lie also about having been so trained. To put it simply, nothing such a Scientologist says in court can be believed or regarded to be true, as the Scientologist believes him or herself to be above, or outside the jurisdiction of "wog law." Such a Scientologist will not honor the Biblical oath because it has no meaning to him/her.
19. I believe my opinion can be substantiated by corroboration by other ex-Scientologists, particularly those who have had experience in working for the G.O./O.S.A.
I declare under penalty of perjury, under the laws of the State of California, that the foregoing is true and correct. Executed the 23rd day of June, 1993, at Tampa, Florida.