2. The matters set forth herein are of my own personal knowledge and if called to testify, I could and would testify competently thereto.
4. In my various capacities, I have worked directly with Scientology organizations and staff members in at least a dozen countries. Materials which I authored were used in every Scientology organization between 1969 and 1989.
5. I learned about the intricate Scientology corporate structures and how they are interrelated. I am familiar with the "secular" arms of Scientology. These are groups which do not appear on the surface to be related to the Church of Scientology but are in fact operated by the Scientology hierarchy.
6. For nearly all of my 20 years, I handled public relations (PR) for L. Ron Hubbard ("Hubbard") and/or the Church of Scientology. I have dealt with every aspect of Scientology PR, from the simplest actions to dealing with international media. I have read and been privy to every level of documentation, including Hubbard's most personal and private writings and the "upper level" materials. I have handled every type and phase of the media on behalf of Hubbard and Scientology. On many occasions I have been a national spokesman. I have generated thousands of news stories and was called to personally handle the situation of Hubbard's death. I have been called by the Church of Scientology to testify as an expert researcher. Through my direct work, I produced official recognitions of Scientology from various federal agencies with letters to me that were used by Scientology in the media and court cases around the world.
8. Mr. Farny attempts to refute the idea that "Fair Game" is a policy of Hubbard's and of Scientology. To do this, Mr. Farny (1) cites an IRS tax exemption; (2) shows that Hubbard wrote about honesty; (3) insists that Scientologists are, as a group, honest; (4) argues that Scientology justice only seeks the truth and does not punish; (5) insists that "Fair Game" meant only that one was not protected by Scientology justice; and (6) claims how the Guardian's Office was operating "totally contrary to Church policy" and thus was disbanded.
9. First, Mr. Farny says the IRS has concluded that all Scientology churches and missions "have not and do not engage in criminal or other improper conduct." This statement is demonstrably untrue. Scientology officials have been indicted and found guilty and jailed in the United States, Canada and elsewhere, starting with Hubbard's wife, Mary Sue. Many ranking officials were named as unindicted co-conspirators, including Hubbard and in-house Scientology legal counsel Kendrick "Rick" Moxon.
10. What Mr. Farny is doing is what Hubbard incorporated into Scientology: never admit to a flaw. While the records are replete with evidence of criminal behavior by Scientology officials acting in their capacity as Scientology officials, the Hubbard attitude is never to admit to any flaw. The stance always taken was, push the flaw away so that it had nothing to do with Scientology. However, as I will show, it not only had everything to do with Scientology, it had to do directly with Hubbard. That was, in fact, why he was named as an unindicted co-conspirator.
11. Second, Mr. Farny quotes extensively from Hubbard to show how Hubbard wrote about the need for honesty. But Mr. Farny did not tell all. What Mr. Farny is selecting from is Hubbard's most public writings. There was another - hidden - side of Hubbard that shows he was literally two-sided, a schizophrenic whose schizophrenia permeates all Scientology organizations as one judge noted. (To be cited later.) This other side of Hubbard is what produced the siege mentality and Fair Game, as set forth below.
12. Third, Mr. Farny's insistence that Scientologists are as a group, highly ethical is really not the issue. The worth of Scientologist as a whole is not the issue. It can be conceded they are good people without detracting from the pernicious nature of Hubbard's "Fair Game" policy or his attitudes towards his enemies, which he called enemies of Scientology.
13. Fourth, Mr. Farny argues that the Hubbard/Scientology system of ethics and justice is "based solely on getting to the truth" and has nothing to do with punishment.
14. Mr. Farny noticeably fails to say what the purpose of Scientology ethics is. According to Hubbard, "The purpose of Ethics is TO REMOVE COUNTER-INTENTIONS FROM THE ENVIRONMENT." (HCOPL 18.6.68 Ethics; caps in original) Since intentions do not exist apart from people, the question becomes, intentions counter to whom? The answer is, Hubbard's. Anyone and anything which is counter to Hubbard's intention is the target of ethics. This is crucial to understand Hubbard's ethics, the roles of the Guardian's Office aka Office of Special Affairs and "Fair Game."
15. Disagreement and the interchange of ideas is central to American society. But it is forbidden in Scientology because Scientology is a closed system. It does not allow the intrusion of new (non-Hubbardian) ideas. It is also self-defining. Happiness is according to Hubbard's definition. Survival is according to Hubbard. Sanity is according to Hubbard. If one disagrees with Hubbard's views, the fault is in the person, not Hubbard. It is up to the person to sort out his or her problem until agreement with Hubbard is achieved. (There are a variety of tools to produce this.) If the person continues to challenge a Hubbard idea, then ethics (up to the sanction of Fair Game) is used.
16. Mr. Farny says there is no punishment in the Scientology belief system. For the general public, this is true. But it is not true for staff and there are many recorded instances of which I am personally aware: people being locked in a room and screamed at by several people until they break or confess; people being locked up in chain lockers on Hubbard's boat on his orders; people being thrown overboard with hands and feet tied; people put on diets of rice and beans; people kept up for days without sleep; people being made to sleep on floors, in closets or in "pig's berthing" (the name says it); people spending years at hard labor at the notorious (and secret) gulags known as the Rehabilitation Project Force (RPF); people being physically assaulted and beaten for refusing to comply; people being made to run until they dropped in the desert sun and then being made to run some more, etc.
17. Such abuses are well known by staff members, particularly in the Sea Organization. But it is a crime against Scientology, subject to appropriate punishment, to make them known to the non-Scientology world, which might then intrude. I have personally known Mr. Farny for perhaps 10 years. I know that he knows of some of these abuses. I also know that he is a devout Scientologist who has been at one of these gulags and who was released after executives felt he had been "rehabilitated". The truth is that there is punishment in Scientology. Hubbard's original "Manual of Justice" even made that point as early as 1959 (ATTACHMENT P):
"The whole subject of Justice subdivides for a Scientologist into four phrases. These are:
"1. Intelligence Activities;
"2. Investigation of Evidence;
"3. Judgment or PUNISHMENT; and
"4. Rehabilitation (MANUAL OF JUSTICE, at p. 4. Added emphasis.)
And later:
"None of us like to judge or to PUNISH. Yet we may be the only people on Earth with a right to PUNISH - since we can undo the damage we do in most cases." (Id., at p. 7. Added emphasis.)
18. In the same manual, Hubbard also instructed how "investigation" can be used to "crush" people. This "manual" is, in fact, where one can find the philosophical origins of the practices which came to be known as "Fair Game." (There is an earlier reference that I will take up later. See paragraph ___.)
"Remember that - by investigation alone we can curb pushes and crush wildcat people and unethical "Dianetics and Scientology" organizations." (MANUAL OF JUSTICE, at p. 3.)
19. A few years later, Hubbard introduced the doctrine of using "manufactured" evidence as a threat. On August 15, 1960, the "Department of Government Affairs" was established with a policy written by Hubbard. (ATTACHMENT R) This was the forerunner of the Guardian's Office, later called the Office of Special Affairs. In the issue, Hubbard ordered:
"If attacked on some vulnerable point by anyone or anything or any organization, ALWAYS FIND OR MANUFACTURE ENOUGH THREAT AGAINST THEM TO CAUSE THEM TO SUE FOR PEACE. Peace is bought with an exchange of advantage, so make the advantage and the settle. DON'T EVER DEFEND. ALWAYS ATTACK. Don't ever do nothing. Unexpected attacks in the rear of the enemy's front ranks work best. (emphasis added.)
"The goal of the Department is to bring the government and hostile philosophies or societies into a state of complete compliance with the goals of Scientology. This is done by high level ability to control and in its absence by low level ability to overwhelm. Introvert such agencies. Control such agencies. Scientology is the only game on Earth where everybody wins. There is no overt in bringing good order."
20. An "overt" in Scientology is a transgression, a wrong. What Hubbard is saying lays the moral groundwork for Fair Game. He said, as long as one is producing compliance with Hubbard's objectives, there is no moral wrong being committed. In other words, as to the world of non-scientologists, the end justifies the means. This is how Fair Game was started and it is the current view of the dedicated GO/OSA staff member.
21. Mr. Farny makes a point of "harmful acts" but he fails to define them in Hubbard's terms and according to the policy that is binding on Scientologists. It is defined in a bulletin Hubbard wrote on October 23, 1983, called "Sec Checking: Note." (ATTACHMENT S) In it Hubbard said the true "harmful act" that Mr. Farny is citing is "something contrary to the mores of a group..." Hubbard is very emphatic on this. Scientology "technically is NOT interested in confidences or overts [harmful acts] against a group's enemies or withholds [secrets] thereof." In other words, as of 1983, actions committed against "enemies" are not of moral or ethical interest. Only those committed against Scientology. This is the ethical view that allows Fair Game to stay in place.
22. It should never be thought that Scientology attacks its critics for anything other than personal reasons. Much is made of the crusades against abuses, but in 1967 Hubbard made it clear why any attack is made by Scientology and when it will stop. The following is from HCO Bulletin 5 Nov 67 "Critics of Scientology" (ATTACHMENT T):
"We are slowly and carefully teaching the unholy a lesson. It is as follows: "We are not a law enforcement agency. BUT we will become interested in the crimes of people who seek to stop us. If you oppose Scientology we promptly look up - and will find and expose - your crimes. If you leave us alone we will leave you alone."
23. Fifth, regarding Fair Game, Mr. Farny once again has been less than candid. He has said Fair Game "meant simply that an individual so labelled was not entitled to the protection of the Scientology system of justice." He says later it is "a direct reference to what individuals who cannot have access to the Scientology justice system are likely to receive at the hands of the justice systems extant in society." Since the issue of Fair Game has been challenged and contested and argued for years, I would like to set the record straight. The following information is based upon my studying highly confidential Guardian Office files and reports and other writings and issues from Hubbard.
24. Fair Game became a subject of controversy in 1968 during governmental inquiries in the United Kingdom. By then, Hubbard had already suffered a severe setback in Australia. In 1965, the Australian Board of Inquiry into Scientology had published its final report after sitting for 160 days and hearing 151 witnesses. The opening words of the report foretold what was to come:
"There are some features of Scientology which are so ludicrous that there may be a tendency to regard Scientology as silly and its practioners as harmless cranks. To do so would be gravely to misunderstand the tenor of the Board's conclusions. This Report should be read, it is submitted, with these prefatory observations constantly in mind. Scientology is evil; it's techniques evil; its practice a serious threat to the community, medically, morally, and socially; and its adherents sadly deluded and often mentally ill."
The report also said Hubbard's sanity was "gravely doubted." In December 1965, the Australian government began to act when the state of Victoria passed the Psychological Practices Act which basically banned the practice of Scientology in that state. A few months later, on February 7, 1966, there was a call in the British House of Commons for a comparable inquiry. This is what set the stage for a flurry of retaliatory actions by Hubbard that are embedded in Scientology policy to this day.
25. On March 7, 1965, Hubbard wrote Hubbard Communications Office Policy Letter (HCOPL) of March 7, 1965, titled "Ethics: Suppressive Acts: Suppression of Scientology and Scientologists: The Fair Game Law" (ATTACHMENT A). It gave the official definition of "Fair Game." Hubbard wrote,
"By Fair Game is meant, without rights for self, possessions or position, and no Scientologist may be brought before a Committee of Evidence or punished for any action taken against a Suppressive Person or Group during the period that person or group is 'fair game'." (A revision of December 23, 1965, changed it to read, "By FAIR GAME is meant, may not be further protected by the codes and disciplines of Scientology or the rights of a Scientologist.")
26. As to what was a "suppressive person," Hubbard gave the definition:
"A SUPPRESSIVE PERSON or GROUP is one that actively seeks to suppress or damage Scientology or a Scientology by Suppressive Acts.
"Suppressive Acts are acts calculated to impede or destroy Scientology or a Scientologist and which are listed at length in this policy letter."
27. Some of the suppressive acts listed included "public disavowal of Scientology;" "public statements against Scientology;" asking for a refund of fees paid; and "writing anti-Scientology letters to the press." Even turning a Scientologist into the proper authorities can gain one the label of a suppressive. The issue also prohibits "1st degree murder, arson, disintegration of persons or belongings not guilty of suppressive acts." (emphasis added)
28. It should be noted that the policy letter in which all of the above appears is also the original which gives the "simple, five step procedure" (known to Scientologists as "A to E" that Mr. Farny quotes. Also this policy letter was published under the "Fair Game Law" title as late as 1980 in Volume 1 of "The Organization Executive Course: An Encyclopedia of Scientology Policy" by L. Ron Hubbard. The issue "Suppressive Acts: Suppression of Scientology and Scientologists: The Fair Game Law" appears on page 552 et seq, which shows that Fair Game continues. These volumes have been reprinted again to launder out certain phrases and issues of Hubbard that are giving executives legal problems. This is being done without telling church members and contrary to an issue called "The Integrity of Source" which prohibits anyone other than Hubbard from making changes in his writings. This will be addressed later.
29. Hubbard's own application of Fair Game tactics are what were later used as the model. They showed up a few months after this issue when he wrote HCO Executive letter 27 September 1965 on "Amprinistics." (ATTACHMENT B) This was what he called a "splinter" group, a group that was using Scientology methods without his control. Hubbard's three-page issue blasts the Amprinistics founders with a variety of sexual charges. (Sexual conduct, particularly homosexuality, and communism were two of Hubbard's favorite topics for accusations.) Hubbard declared the Amprinistics Fair Game. Since Hubbard is the source of Scientology policy and definitions, here is a prime example of Hubbard view of Fair Game:
"They are each fair game, can be sued or harassed [sic]. Horner can be barred out of any Commonwealth Country or England as he was the subject of a deportation order from England and his file has come alive again in the Home Secretary's Office. Harry Thompson's wives and victims are always looking for him to have him arrested. Watson is a set-up for arrest as a homosexual. Any meeting held by them should be torn up. The names of any persons attending should be collected and they should be labelled SP [suppressive person] as they have left Scientology. These people are SP because they are seeking to avoid auditing and retain their withholds. Once labeled, these persons will not then be covered by amnesty and will never be admitted to further training and processing. Persons messing themselves up with Amprinistic [techniques] should be refused any assistance. If these persons move into your area act through any agency you can to have them deported or arrested on whatever grounds. England is currently too hot for them so they may tour about. Horner's UK deportation order, Thompson's police record and Watson's homosexuality make them very vulnerable to deportation or arrest."
30. Hubbard does not stop there. He goes on to issue a five-step order that includes:
"(2) Harass these persons in any possible way...
"(4) Tear up any meeting held and get the names of those attending
and issue SP orders on them and you'll have lost a lot of rats."
31. Clearly Hubbard had another side, a side that only staff members (not the public) have seen. These are the Hubbard writings that laid the basis of "fair game," and not what Mr. Farny has tried to represent through glowing Hubbard platitudes that were written for public consumption, the media, the courts and the IRS.
32. In 1966, Hubbard began to codify those sections of Scientology that would implement Fair Game. For example, on February 17, 1966, he created the Public Investigation Section with a policy letter of that name and date. (ATTACHMENT C) As Hubbard put it,
"It will be seen that the section has all the useful functions of an intelligence and propaganda agency. It finds the data and sees that it gets actions."
In that vein, "Standard intelligence procedures are used," he wrote. The statistic of the unit included "the number of derogatory news stories appearing that week related to enemies of Scientology." He said,
"The section should note that press and the public are interested in murder, assault, destruction, violence, sex and dishonesty, in that order. Investigations which can uncover these factors in the activities of individuals of a group attacking Scientology are valuable in the degree that they contain a number of these factors."
Hubbard was also not beyond advocating the stirring of racial hatreds:
"Associating the attacking group's activities with reprehensible groups in the past by using familiar descriptive words will be found very effective. For example, if the word 'white' has been made hateful to the public by some past criminal group we use 'white' in our descriptive terminology concerning the group that is attacking us and whom we are investigating."
He later concludes, "In that way we then get rid of suppressive groups by investigation and disclosure."
33. The next day, on February 18, 1966, Hubbard wrote "Attacks on Scientology" (ATTACHMENT D) in which he again urged the use of investigations. Suppressives, he said, have crimes. "these people who attack have secrets. And hidden crimes. "These people who attack have secrets. And hidden crimes. They are afraid." He thus urged they be investigated as this, he said, would cause the attacker to withdraw.
34. A week later, on February 25, 1966, he wrote another "Attacks on Scientology" policy letter (ATTACHMENT E) in which he urged, to "Start feeding lurid, blood sex crime actual evidence on the attackers to the press."
35. On March 1, 1966, Hubbard formed the Guardian's Office which took over the intelligence function just described. (ATTACHMENT F)
36. As problems escalated for Hubbard, he wrote an issue on October 18, 1967 "Penalties for Lower Conditions" (ATTACHMENT G) whereby Fair Game was automatically issued on anyone (including staff members) who was an "enemy." They were, he said, "SP Order. [An order declaring them suppressive.] Fair game. MAY BE DEPRIVED OF PROPERTY OR INJURED BY ANY MEANS BY ANY SCIENTOLOGIST WITHOUT ANY DISCIPLINE OF THE SCIENTOLOGIST. MAY BE TRICKED, SUED OR LIED TO OR DESTROYED." (emphasis added)
37. As international problems continued for Hubbard, one of the objects of investigations was Fair Game. Issues such as the one on Amprinistics were becoming public relations problems and so on October 21, 1968, Hubbard wrote an issue ("Cancellation of Fair Game" ATTACHMENT H) that said it was a public relations problem. There was no mention of morality. The entirety of the policy letter (P/L) is as follows:
"The practice of declaring people FAIR GAME will cease. FAIR GAME may not appear on any Ethics Order. It causes bad public relations.
"The P/L does not cancel any policy on the treatment or handling of an SP. [suppressive person]
L. Ron Hubbard, Founder"
38. Since 1968, Scientology officials (including myself when I was asked the question) insisted that the practice of "Fair Game" was canceled with this issue. The Court must notice Hubbard is talking about banning the use of the words "Fair Game" from Scientology documents authorizing Scientologists to trick, sue, lie or destroy suppressive persons. And the reason is public relations. But the treatment of people does not change. Hubbard expressly states this "Policy Letter does not cancel any policy on the handling of an SP". As show above, Suppressive Persons were to be attacked, tricked, sued, lied to or destroyed. This policy did not change. In other words, Hubbard did not cancel this order that suppressives could be "tricked, sued or lied to or destroyed." That was a policy for the treatment of suppressives and this so-called "cancellation of Fair Game" clearly states that those treatments (or "handlings") were to continued unabated.
39. If the practice of Fair Game had been cancelled, then the treatment or handling of "suppressives" would have changed. However, they did not and this is proven by Hubbard and the courts as well as voluminous documents and witnesses, and Mr. Farny knows this. That will be taken up shortly.
40. On February 16, 1969, Hubbard wrote "Confidential: Targets, Defense" (ATTACHMENT I) in which he listed "vital targets on which we must invest most of our time..." The first and most important: "T1. Depopularizing the enemy to a point of total obliteration."
41. Also on February 16, 1969, he wrote "Confidential: Battle Tactics" (ATTACHMENT J) where he urged the use of military tactics and strategy in dealing with the "enemy." He wrote:
"A good general expends the maximum of enemy troops and the minimum of his own. He makes the war costly to the enemy, not to himself. One cuts off enemy communications, funds, connections. He deprives the enemy of political advantages, connections and power. He takes over enemy territory. He raids and harasses. All on a thought plane - press, public opinion, governments, etc. " (emphasis added)
He also urged the use of intelligence to get the "who when where what." (sic)
42. Hubbard wrote considerable materials on the use of intelligence and covert operations. For example, in "Confidential: Intelligence-Actions: Covert Intelligence: Data Collection" of December 2, 1969, (ATTACHMENT K) Hubbard said how these are carried out with a "Case Officer" and agents.
"Essentially a covert operation is intended to embarrass, discredit or overthrow or remove an actual or possible opponent. It is a small war carried on without its true source being disclosed."
43. By 1971, Hubbard was directing an international spy network and he felt it was paying off. On May 7, 1971, he wrote GO [Guardian Order] 070571 LRH "Secret: Notes on Smersh." (He took the word from the James Bond novels to refer to an international conspiracy that he believed was directing the attack on him.) He said,
"Penetration is always a win. We have made it in finding WHO attacks Scientology from where by doing what. This gives us an ever further penetration. We have found as well the EX intelligence officer mouth pieces [sic] in the UK that influence that government and push Nazi aims. We are getting even further penetration now into who is keeping this planet upset."
44. In 1972, he issued an order titled "CONFIDENTIAL: Black Propaganda" (GO 011272 LRH) (ATTACHMENT M) Also known as "Black PR," short for "black propaganda." Hubbard defined the topic:
"Black Propaganda is a covert communication of false info[rmation] intended to injure, impede, or destroy the activity or life of another person, group, or nation, usually issued from a false or removed source from the actual instigator.
"It is used heavily in 'psychological warfare."
In a warped sense of logic, Hubbard said,
"Our propaganda is dirty but it is not black because it is true. Black propaganda is essentially false.
"We can do this trick (as in the new operating plans wrote) by survey and attack."
45. The "operating plans" Hubbard was referring to comprised the Top Secret "Snow White" program of which I was part. The Snow White Program had basically three arms: public relations, legal and intelligence. It was the intelligence arm that was raided by the FBI in 1977. A good portion of the Snow White Program was based on the Fair Game doctrines described above, since the program was aimed at Hubbard's "enemies" and "suppressives."
46. On October 6, 1979, Hubbard's wife Mary Sue and eight other Scientology executives signed a 282-page (plus exhibits) Stipulation of Evidence that detailed the government's case. That document details the burglaries, forgeries, conspiracies, to obstruct justice and other crimes committed. But it is the Sentencing Memorandum for Jane Kember (The Guardian) and Mo Budlong (her intelligence chief) of September 16, 1980, by Assistant US Attorney Raymond Banoun that gives the most succinct view of how Fair Game was conducted after 1968. In fact, the memo discloses an admission by defendants that Fair Game continued even beyond the conviction of Mary Sue Hubbard, until mid-1980. (Banoun questions in the memo "as to whether these illegal activities were ever terminated by those defendants.")
47. The memo relates how the defendants combined intelligence and legal to defraud and abuse the courts. Portions are hereby excerpted from it.
"These crimes included: the infiltration and theft of documents from a number of prominent private, national and world organizations, law firms, newspapers and private citizens; the execution of smear campaigns and baseless law suits for the sole purpose of destroying private individuals who had attempted to exercise their First Amendment rights to freedom of expression; the framing of private citizens who had been critical of Scientology, including the forging of documents which led to the indictment of at least one innocent person; and violation of the civil rights of prominent private citizens and public officials." (page 3)
48. The memo points out how Mary Sue Hubbard had said on the witness stand that she and her codefendants "felt they could do to others whatever they perceived, however erroneously, others were doing them." (page 6)
"They presented this Court with a shabby attempt at impeaching Meisner's credibility [the Scientology intelligence agent who turned and started the investigation that led to the raid] by claiming that he stole money from the Church - the same false claim they made against another former Scientologist who had the courage to expose their crimes and thus fell victim to their fair game doctrine. Allard vs. Church of Scientology of California, 68 Cal. App. 3d 439, 129 Cal. Rptr. 797 (Ct App 1976), cert. denied, 97 S. Ct. 1101 (1977)." (page 14)
"The defendants' contention that they committed the crimes of which they stand convicted in order to protect their Church from government harassment collapses when one reviews a sample of the remaining documents seized by the FBI during the execution of the two Los Angeles search warrants. If anything, these documents establish beyond question that the defendants, their convicted co-defendants, and their unindicted co-conspirators [which included Ron Hubbard and current Scientolgoy counsel Kendrick Moxon], as well as their organization, considered themselves above the law. They believed that they have carte blanche to violate the rights of others, frame critics in order to destroy them, burglarize private and public offices and steal documents outlining the strategy of individuals and organizations that the Church had sued. These suits were filed by the Church for the sole purpose of financially bankrupting its critics and in order to create an atmosphere of fear so that critics would shy away from exercising the First Amendment rights secured them by the Constitution. (Footnote, This is precisely how Scientology's critics viewed Scientology's activities. Newsweek, November 20, 1978 at 133: "The Church of Scientology relies on suits and petty harassment to register its complaints. In August, the Scientologists slapped a $1 million suit on the Los Angeles Times after it ran a series about the Church. The Times wasn't accused of libel; rather, the Scientologists claimed that the paper conspired with the FBI and Justice Department to violate the church's civil rights by poisoning the atmosphere before a trial" of the nine convicted co-defendants. (See also discussion, infra, regarding Scientology's lawsuits against its perceived "enemy", Paulette Cooper.") The defendants and their cohorts launched vicious smear campaigns, spreading falsehoods against those they perceived to be enemies of Scientology in order to discredit them and, in some instances, to cause them to lose their employment. Their targets included, amoung others, the American Medical Association (AMA), which had branded Scientology's practice of "dianetics" as "quackery"; the Better Business Bureau (BBB), which sought to respond to private citizen's inquiries about the courses offered by Scientology; newspapers which merely sought to report the news and inform the public, law firms which represented individuals and organizations against whom Scientology initiated law suits (often for the sole purpose of harassment); private citizens who attempted to exercise their First Amendment rights to criticize an organization whose tactics they condemned; and public officials who sought to carry out the duties for which they were elected or appointed in a fair and even-handed manner. To these defendants and their associates, however, anyone who did not agree with them was considered to be an enemy against whom the so-called "fair game doctrine" could be invoked. ALLARD V. CHURCH OF SCIENTOLOGY OF CALIFORNIA, SUPRA. That doctrine provides that anyone perceived to be an enemy of Scientology or a "suppressive person," "[m]ay be deprived of property or injured by any means by any Scientologyist. [He m]ay be tricked, sued or lied to or destroyed." (Id., 58 Cal. App. 3d at 413 n. 1, 129 Cal. Rptr. at 800 n. 1.) (Footnote 2: This led the California Court of Appeals to state that "Any party whose tenets include lying and cheating in order to attack its 'enemies' deserves the results of the rick (sic) which such conduct entails." (Id., 58 Cal. App. 3d at 453, 129 Cal. Rptr. at 805.)
"Defendants, through one of their attorneys, have stated that the fair game policy continued in effect well after the indictment in this case and the conviction of the first nine co-defendants. Defendants claim that the policy was abrogated by the Church's Board of Directors in late July or early August, 1980, only after the defendants personal attack on [Federal] Judge Richey." (Transcript of September 5, 1980, at 14.) ((? no make no sense))
This policy, together with the actions of these defendants who represent the very top leadership of the Church of Scientology, bring into question their claim that their Church prohibited the commission of illegal acts." (pp 10-11)
"It is interesting to note that the Founder of their organization, unindicted co-conspirator L. Ron Hubbard, wrote in his dictionary entitled 'Modern Management Technology Defined' that "truth is what is true for you," and 'illegal' is that which is 'contrary to statistics or policy' and not pursuant to Scientology's 'approved program.' Thus with the Founder-Commodore's blessing they would could wantonly commit crimes as long as it was in the interest of Scientology."
"These defendants rewarded criminal activities that ended in success and sternly rebuked those that failed. The standards of human conduct embodied in such practices represent no less than the absolute perversion of any known ethical value system. In view of this, it defies the imagination that these defendants have the unmitigated audacity to seek to defend their actions in the name of 'religion.'" (page 33)
"It is clear from the press releases issued by Scientology following the jury's verdict, and their vicious actions against another member of this Court, that they have yet to learn the errors of their criminal ways." (page 34)
49. The other member of the Court that was being referred to was Federal District Judge Charles Richey who was the target of a sting operation conducted by a private investigator hired by Scientology that forced the judge to recuse himself from the Scientology case on which he was sitting. The judge was allegedly set up with a prostitute. The action was Fair Game. Scientology publications however called it a "BIG WIN." He would not be the last judge to be the target of Scientology Fair Game.
50. Mr. Farny is asking the Court to believe that because there were writings prohibiting actions such as Fair Game, it is not being conducted. However, that argument was made in December 27, 1979, when "The Controller Committee" issued Guardian Order 3031 called "Scientology And The Law" under Hubbard's name (ATTACHMENT U) in which they stressed compliance with the law. (It should also be noted this urging of compliance with the law was released only after Mary Sue Hubbard and the others signed the Stipulation of Evidence.) The issue contains many of the same platitudes that Mr. Farny quotes in his declaration. Regardless of the platitudes issued in 1979, about a year later, the hypocrisy came out when the Government revealed that the defendants confessed that Fair Game had continued up through mid-1980 and may have continued past that point.
51. In fact, Fair Game did continue. Although the Guardian's Office was "disbanded," a new campaign was undertaken against Gerald Armstrong in 1981, a staff member who had fled with some of Hubbard's files. Contrary to what Mr. Farny said, there were Fair Game actions taken against Armstrong after the GO was "disbanded." I know because I sat in on those strategy meetings and was ordered by Hubbard as well as David Miscavige to "get Armstrong." For example, Hubbard ordered a "reward" poster that would characterize Armstrong as a criminal. (I did not comply with the order, for which I was severely berated by Miscavige.)
52. The use of Fair Game on Armstrong was confirmed in 1984 when California Superior Court Judge Paul Breckenridge, Jr., ruled against Scientology with an opinion that included a statement about the civil rights of members and Hubbard:
"In addition to violating and abusing its own members civil rights, the organization over the years with its 'Fair Game' doctrine has harassed and abused those persons not in the Church whom it perceives as enemies. The organization clearly is schizophrenic and paranoid, and this bizarre combination seems to be a reflection of its founder LRH. The evidence portrays a man who has been virtually a pathological liar when it comes to his history, background, and achievements. The writings and documents in evidence additionally reflect his egoism, greed, avarice, lust for power, and vindictiveness and aggressiveness against persons perceived by him to be disloyal or hostile." (ATTACHMENT N)
53. Another judge who stepped down from a Scientology case was Federal District Judge James M. Ideman. But as he did so, he filed a declaration in his court on June 21, 1993, (ATTACHMENT O) which said in part:
"Plaintiff has recently begun to harass my former law clerk who assisted me on this case, even though she now lived in another city and has other legal employment. This action, in combination with other misconduct by counsel over the years has caused me to reassess my state of mind with respect to the propriety of my continuing to preside over the matter."
54. Part of the problem, he said, was seeking to have Scientology comply with discovery. They would not comply:
"This noncompliance has consisted of evasions, misrepresentations, broken promises and lies, but ultimately with refusal."
55. Judge Ideman later remarks how Scientology apparently views "litigation as war" and seeks to break the opposition through increased litigation costs. This is not news to members of the Guardian's Office, now known as the Office of Special Affairs. This tactic was laid out by Hubbard as early as 1955 in The Scientologist: A Manual on The Dissemination of Material (ATTACHMENT Q). In it Hubbard said:
"THE LAW CAN BE USED VERY EASILY TO HARASS AND ENOUGH HARASSMENT ON SOMEBODY WHO IS SIMPLY ON THE THIN EDGE ANYWAY, well knowing that he is not authorized, will generally be sufficient to cause his professional decease. If possible, of course, RUIN HIM UTTERLY." (Added emphasis)
Hubbard wrote this in 1955 but, like Fair Game, it is still followed.
56. It must be remembered that Fair Game is not the result of one policy letter from Hubbard. It was and is embedded in the organization through scores of Hubbard policies and directives. It was exposed after the raid of 1977 and again in the court of Judge Breckenridge in 1984 and in the courtroom of Judge Ideman in 1993. Time and again Scientology officials have insisted that it has ended. Now Mr. Farny is seeking to hoodwink this Court by returning to the original argument, disregarding history and facts. Ironically, that too is part of Fair Game.
57. Lastly, on the matter of Jane Kember: The Guardian was the most powerful position in Scientology after Hubbard himself and his wife Mary Sue. The Guardian was able to move any bank accounts, close and open organizations, expel people, etc. As late as 1970, Hubbard wrote, "The two most effective arms of Dianetics and Scientology are the Sea Org[anization] and the Guardian's Office." (ATTACHMENT V) Mr. Farny's statement that "Kember's removal and the disbanding of the GO were the results of the discovery by CSI's management that a few members of the GO...had undertaken actions totally contrary to Church policy" is as ridiculous as it is false. It was the FBI and Department of Justice that discovered and exposed the crimes, not CSI management. And Kember was fanatically defended until she was found guilty and went to jail. Mr. Farny know this. Nor was the GO disbanded. It was taken over. It was renamed, in the same offices, had the same personnel and operated from the same policies from Hubbard. The person who oversaw the "disbanding" was David Miscavige, who directed the Fair Game actions on Armstrong from what was called "Special Project" which was, in fact, Author Services, Inc., where I was employed.
58. The policies and directives cited in this declaration are from Hubbard. I chose to cite his words rather than the even more voluminous Fair Game materials authored by others because Hubbard's writings are considered "scripture" by Scientology and they cannot be cancelled or changed except by him. Since he died in 1986, nothing past that point can be changed. This was stated in an issue of July 7, 1982, called "The Integrity of Source" (ATTACHMENT W) which said:
"It is hereafter firm Church policy that LRH ISSUES ARE TO BE LEFT INTACT AS ISSUED."
"No one except LRH may cancel his issues."
"No one except LRH can revise his issues whereby changes are incorporated into the text and then reissued. Any valid revisions must hereafter be made in a separate issue stating the change and how the revision is to be read....
Already existing issues stand intact and valid."
60. By 1969, I left the Ph.D. program to help start the Dianetics and Scientology Mission of Davis. My functions included giving the introductory lecture, supervising the communications course, giving professional Dianetic auditing and handling public relations for the Mission. This gave me considerable experience in not only delivering basic services to new public but in how the community viewed Scientology and how Scientology interacted with the community. In my public relations capacity, I became quite familiar with the area media and other groups. I organized and presented a community anti-drug program on the UC Davis campus which brought speakers from around the state in an all-day symposium that received considerable media coverage.
61. While at the Davis Mission, I was asked by an inmate at Vacaville Medical Prison to give a talk there. I did. Then I started a Scientology group that I supervised with weekly meetings for over two years. An article in the Sacramento Union recognized me for my work.
63. Hubbard often said that the two most effective arms of Scientology were the Guardian's Office and the Sea Organization. I later became a member of the Sea Organization and became well acquainted with its' policies too. The basic difference was that the Sea Organization (SO) is an internally focused group. Its interest was in the day-by-day operation of the organizations in order to make money. The Guardian's Office (GO) was an externally focused group. It dealt primarily with perceived threats from the media, lawsuits, government agencies, and dissidents who had left Scientology. However, the GO had powers not given to the SO. As laid out in the Hubbard policy letter of 1 March 1966 that created the office of The Guardian, The Guardian was the most powerful position in Scientology, second only to Hubbard and his wife, Mary Sue. The Guardian was able to expel people, move bank accounts, close Scientology organizations if they displeased Hubbard, etc. This power extended down through a network of Deputy Guardians and Assistant Guardians and their respective bureaus: Public Relations, Finance, Intelligence and Legal. More bureaus were added later.
64. When I joined the Guardian's Office, I was sent immediately to Los Angeles for training in Public Relations ("PR"). My training lasted from 9 a.m. until 11 p.m., six days a week for over three months. It included studying the various investigations into Scientology including the (then) on-going challenge from the Food and Drug Administration and the investigations into Scientology in Australia and New Zealand. I also studied all press files which meant articles from around the world, including the United Kingdom where there had been considerable problems. I was provided and read confidential reports from Scientology Public Relations Offices around the United States to develop an understanding of how Scientologists handled PR situations. I also read similar confidential reports from international Public Relations Offices detailing how they handled public relations situations. I thus became fully familiar with the confidential PR history of Scientology up to that point, meaning the history of the Church that was not being shared with rank and file Scientologists. I was privy to the actual behind-the-scenes story of what was happening and what was being done to handle public relations problems.
65. My training also included studying material by Hubbard and Guardian Office (GO) personnel on how to handle public relations. This included tapes by Hubbard on the subject. Much of this material was "confidential" which meant it was kept locked away and was to be viewed only by authorized GO personnel. That material advised on defining, identifying and dealing with those viewed as "enemies" of Hubbard and Scientology.
66. My training also included "drills" which were exercises to teach me what Hubbard considered to be basic PR skills. These included how to write a press release and give a press conference as well as how to respond to reporter's questions, how to divert a reporter, how to stall for time, how to avoid questions, how to introvert and cave in a person and other tactics.
67. My training also included shorter instruction (called a "mini-hat") so I could temporarily manage the other bureaus, including the Intelligence Bureau which ran covert operations. During my tenure in Los Angeles I directly participated in one large cover operation targeting an area mental health group. The operation created considerable bad press for the group, severely hurt their fund-raising and was not traced to Scientology. Thus I was able to become intimately familiar with Hubbard's intelligence techniques, methods and styles.
69. At that time the power of the GO was considerable. So when several financial crises hit the San Francisco organization, I implemented Hubbard's policy. I seized the accounts and ran the finances of the entire organization until it was able to return to solvency. (I also received several daily briefings from GO US in Los Angeles to advise me.) This taught me the financial structure of Scientology including how money was sent to various bank accounts in San Francisco, Los Angeles and overseas.
70. As the AG, I also conducted internal investigations into personnel in the organization according to Hubbard's policy in order to determine staff qualifications. This was done by reviewing their ethics files, personnel files and auditing folders. I also investigated statistics throughout the organization. I also learned how to alter records in the organization to mask the trail of personnel going to the Intelligence Bureau so they could not be traced to Scientology. (This was a standard practice for operatives. It required destroying or altering records so there was no trace of the persons should law enforcement try to find them.)
71. As the Public Relations Officer (PRO), I worked on programs and orders from the Guardian's Office US and the Guardian's Office World Wide (in England). In my functions, I worked with all media in Northern California. I placed stories and dealt with media to handle stories that Scientology considered to be unfavorable. I went on several talks shows, including those with major stations, as the Scientology spokesman for Northern California.
72. I organized an Ecumenical Communications Council (ECC) which consisted of representatives from about 50 area religions or sects. The function of the ECC was to help all groups to achieve better PR, especially with the media. Behind it was my own desire to give me a stronger base for negotiating with the media. The ECC was quite successful. In fact, for my work with the community one San Francisco radio station named me "Citizen of the Week," to my surprise.
73. While working in San Francisco, I had occasion to work with other Dianetics and Scientology Missions, thus learning further how the organization worked in a large area.
74. In the latter part of 1973, I was promoted to the Guardian's Office, United States (GOUS). GOUS was located in Los Angeles, where I had received my training. The function of GOUS was to direct and run all GO offices in the United states as well as Mexico. (There was perhaps 15 at that time in major cities around the U.S. plus one in Mexico.)
75. My first assignment at GOUS was to be the PR Establishment Officer (PR Esto). My task was to work with all personnel in the PR US Bureau, to ensure that they were better trained etc. (There were about 10 people in the bureau when I arrived.) This allowed me to learn all functions in the PR US bureau and all personnel.
2. SNOW WHITE PROGRAM.
76. After a few months, however, I was assigned to the PR section of the most secret and largest program in the Guardian's Office - the Snow White Program. It consisted of several highly secret programs written by Hubbard that were designed to ferret out the source of international criticism of him and Scientology. Persons were assigned to each bureau to carry out the Snow White actions in that bureau. We had considerable authority and latitude as well as finances and the Snow White program was the "highest priority." It afforded me the opportunity to become familiar with dozens of Scientology organizations across the United States.
77. One of the objectives of the PR Snow White program was to get acceptances of Scientology from governmental agencies. I personally did that in several instances. Sometimes after many months of work including several trips to Washington, D.C., letters of recognition were written to me by several agencies including the U.S. Air Force, Department of State and Department of Labor. These letters were crucial to Scientology's legal position internationally and were widely reproduced as well as used in a variety of court cases.
3. PERSONAL ROLE IN ESTABLISHING "FRONT GROUPS".
78. During this time I helped to form "front groups" that were nothing but letterhead, such as the National Commission on Law Enforcement and Social Justice. We dreamed up the name one day so we could sound "more official". There was no such "group" other than our letterhead. But that was not unlike how Scientology front groups operate. We simply created letterhead and pretended that there was a real organization behind it. (If anyone ever challenged it, would we have been able to go out and get a few people who would claim they were active members to refute criticism.) It was from the NCLE "group" that I conducted research and found that Interpol (the International Criminal Police Organization) had a Nazi history. (Scientology's other main target in the US was the Federal Bureau of Investigations.) This enabled Scientology to gain considerable media coverage for years around the world. It also allowed me to testify twice before Congressional Subcommittees and to appear on scores of radio and TV shows, including one hour on Ton Snyder's "Tomorrow" show.
80. I also traveled through Europe and met with staff in the organizations in England, France, Netherlands, Denmark, Germany, Austria and Belgium, giving me additional insight and information into the operations of Scientology around the world.
82. The FBI took thousands of documents that the United States Attorney's Office used to convict Hubbard's wife Mary Sue and ten other GO personnel. Hubbard and a number of other Scientology executives were named as unindicted co-conspirators.
83. Before the trial, I was allowed access to the documents that the government was going to use. I read thousands of highly confidential dispatches including communications amoung the highest executives in Scientology. That was the first time I learned about the extent of the illegal activity occurring in the Intelligence Bureau. It also showed me my superiors had mislead me by misrepresenting to me the magnitude of the criminal conduct and then using me as a national spokesperson who could convincingly represent there was no wrongdoing, that the prosecution was all "harassment" by the FBI and etc. because of my actual ignorance. The extent of criminality was subsequently detailed and documented in the 284-page Stipulation of Evidence that was used as the sentencing of the executives. This publicly available document, was kept away from rank and file Scientologists. It completely refutes the position that was taken by me and by others, especially in the years to follow.
84. While preparing for that trial, I was sent with a team of people to Washington, D.C., in 1979, to try and create positive press that would offset the bad press being generated. During that time, my team worked with documents we legally gathered from government files already obtained under the Freedom of Information Act and generated several stories that went around the world. These stories were about secret chemical-biological warfare testing by the Central Intelligence Agency and the U.S. Army. These stories were also written up in FREEDOM, under my byline, "Vaughn Young." (Footnote: This, like other material I published while I was in Scientology appeared under the name Vaughn Young. I did not use my legal first name "Robert" until after fleeing from Scientology in 1989). FREEDOM was published by the Guardian's Office. I was also cited in other Scientology publications and issues as an expert in my field.
85. In 1979, my book the Interpol Connection was published by Dial Press, a non-Scientology publisher. The book is the compilation of all my research. My co-author was a non-staff member who was hired to help with the writing/composition of the book while I continued my researches. I am identified in the book as the Director of Research for the National Commission on Law Enforcement and Social Justice, which, as stated earlier, was merely a front organization.
91. The problem that OSA was facing was the inundation of lawsuits naming Hubbard as a defendant. He had gone into hiding and a unit had been set up to handle all the lawsuits. It was called the "All Clear Unit". The name gave its objective: to create an "all clear" for Hubbard so he could come out of hiding.
93. After my return to LA, I was asked to join Special Project instead. That was when I learned that Special Project was really the newly formed Author Services, Inc. (ASI). ASI was a for profit group that was ostensibly created to be Hubbard's literary agency. While ASI had that function, ASI's actual functions were: (1) to run the "All- Clear Mission" by running the GO/OSA which required constant meetings with ASI and GO/OSA staff usually chaired by Miscavige; (2) to make money for Hubbard; (3) to run the Church of Scientology to accomplish 1 and 2. This last function was carried out in secret since we were a for profit corporation and the Church of Scientology was fighting the Internal Revenue Service for its non profit status. Thus, our directing the "All Clear Unit" was also a well-kept secret. My promotion to ASI was personally approved by Hubbard in a dispatch titled "Vaughn" that defined the PR position that I was assuming. My initial Position was called Public Affairs Special Project. It was worked out with Hubbard that "Public Affairs" would be used so it could easily differentiated from "Public Relations" which would designate those in the non-profit area. When we moved to offices at 6464 Sunset Boulevard in Hollywood, my position became PA ASI (Public Affairs, Author Services, Inc.)
94. My primary function was to run Hubbard's public relations network in the Church of Scientology that extended around the world. This network was embedded mainly in what was called the "LRH Comm Network" or L. Ron Hubbard Communicator Network. LRH Comm's were supposed to be his personal representatives in each organization. To execute my functions, I ensured that a person was appointed to head the network internationally and met with her and her juniors regularly, issuing orders on what to do. One of the projects was to get "recognitions" for Hubbard, which were keys to cities, commendations, etc. These were usually collected without the issuer knowing who Hubbard was. Sometimes the "recognition" would be withdrawn when they learned who he was.
95. Since ASI was the senior Scientology organization, regular and numerous legal strategic meetings with Office of Special Affairs personnel were held at ASI. Miscavige who was the Chairman of the Board of ASI often chaired the meetings. The object of these meetings was the many lawsuits that included Hubbard as a defendant and how to deal with the suits. I sat in on many of those meetings and witnessed the orders being given to church personnel on what to file, who to depose, what to object to etc. Most of these orders came from Miscavige.
96. We also held meetings at ASI to direct other church staff on what to do. These meetings were often for the purpose of raising additional money or ordering the organizations to pay large sums of money to ASI.
97. ASI also handled Hubbard's investments in gold, oil wells, etc. To this end, additional corporations were created out of ASI. Some were intended to protect Hubbard's money, others to create a buffer between him and the non-profit Church of Scientology so that a legal link could not be made. Some of ASI's repsonsibilities were subsequently moved to some of those entities, such as the Religious Technology Center.
100. Additionally, ASI went to Gilman Hot Springs every week to prepare packages of information on the operation of Scientology that was secretly shipped to Hubbard who was in hiding. In turn, he sent us orders. This was done by him on tape which was transcribed and then sent out.
101. Also while at ASI, I ghosted material for the missing Hubbard. Some of this was read to Scientologists at large meetings as greetings from Hubbard or issued as directives from him, including policy.
102. I was also Hubbard's editor for Mission Earth, a one-million- plus word work that was delivered to ASI. I cut it into 10 books, proposed the titles, wrote introductory material and got the work ready for publication.
105. I stayed at the ranch for months. During that time, I gave interviews to or dealt with the media who called or who showed up at the ranch. I also became good friends with Pat Broeker, who had lived at the ranch with Hubbard and who was the liaison to all Scientology entities and learned more about the Hubbard and the operations of Scientology.
106. When there was concern that another secret Hubbard ranch near Barstow might be discovered, I was sent to stay there. I stayed at that location for perhaps another two months.
108. I was returned to ASI and was assigned the task of producing additional "Ron Mags," a publication that my wife and I had initiated in 1982 that were about Hubbard. When I refused to follow an illegal order, I was physically assaulted and beaten and sent back to Gilman Hot Springs for "handling." Pretending to be better, I went to Los Angeles to see my wife and told her about the situation. Before leaving Los Angeles, I wrote a report about the beating and sent it to OSA attorney Kendrick "Rick" Moxon. We put a few clothes in the car and left on July 3, 1989, leaving the rest of our belongings behind simply because it was not worth the risk to try and retrieve them.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Executed this 25 day of October 1993, at Los Angeles California.
Robert Vaughn Young