Declaration of Stacy Brooks Young

23 November 1993


I, STACY YOUNG, declare as follows:

1. I was a member of the Church of Scientology for nearly 15 years, from January 1975 until July 1989. From October 1975 until I left, I was a member of the Sea Organization, the most dedicated group of Scientologists in the entire organization. I spent most of my time (from 1978 until 1989) in a highly confidential section of Scientology management which was known as the Guardian Office until 1982 and is today called the Office of Special Affairs.

2. During my tenure in Scientology I acquired extensive knowledge of the counseling methods known as auditing, the methods of training staff members and public Scientologists, the methods of dealing with non-Scientologists (known as "wogs") and former Scientologists, known as enemies or suppressives, and the administrative and management procedures of the organization.

3. The matters set forth herein are of my own personal knowledge and I could and would competently testify thereto.

4. My first experience with Scientology was at the Hission of Atlanta, Georgia, where I attended a series of introductory lectures about the mind. I received some basic auditing and took several basic courses.

5. I joined the Sea Organization ("Sea Org" or WSO") at the Advanced Organization in Los Angeles ("AOLA") in October of 1975. To become a Sea Org member, one must sign a billion year contract to confirm one's dedication to Scientology and "clearing the planet."

6. All staff members involved in delivering the confidential upper levels of Scientology and all the staff members involved in Scientology management must be members of the Sea Org. They live communally and are under the absolute authority of the Sea Org command lines 24 hours a day,

7. The Sea Org has total authority over all Scientology and Scientology-related organizations, including all non-profit and for-profit corporations. It cuts across all corporate boundaries and can take over any Scientology organization without notice. Any Scientologist who refuses to submit to Sea Org authority is declared a "suppressive person" and expelled from Scientology.

8. All Scientologists consider that Scientology is the only way for Mankind to go free. For a Scientologist this means getting "exterior" to the physical body and indeed, to the entire physical universe. Scientologists expect that once they have attained this state they will be free to travel throughout the galaxies, freeing others who are in the trap of the physical universe. What will happen after that is somewhat vague, but no one has attained this state as yet anyway, so it doesn't really matter.

9. The route out of the physical universe trap is called "The Bridge to Total Freedom." Every Scientologist is at one stage or another on this Bridge, and they are expected to get everyone else on this Bridge as well. The idea is for everyone on Earth to get exterior to the physical universe. The only people who aren't included are "suppressives", who don't deserve to go free.

10. The Bridge is composed of a series of auditing processes, an auditing process being a set of specific questions and commands. The person who asks these questions and delivers these commands is called the "auditor." The person who answers the questions and carries out the commands is the "preclear" since the first major milestone on the Bridge is called "going the confidential upper levels of auditing known as the "Operating Thetan" levels ("thetan" being Hubbard's term for the person without his or her body).

11. I was a staff member at AOLA from October 1975 through December 1978. I audited hundreds of hours on public preclears as well as staff members. I also did many security checks on staff members. A security check is a method of inducing a person to confess his or her crimes, particularly crimes against Scientology

12. In 1977 I was posted as Interne Supervisor at AOLA. In this capacity I supervised auditors-in training, known as internes, to certify them as qualified professional auditors. To perform this function I had to understand auditing and procedures precisely from the most basic processes to the advanced processes of Class 6 and Class 8, which are advanced levels of expertise, so that I could recognize whether or not the internes were conducting themselves as proper auditors.

13. As a result of my experiences at AOLA I acquired a high level of expertise as a "tech terminal" meaning one who is knowledgeable about the technical application of Scientology counseling and training methods.

14. At the end of 1977 I transferred to the United States Guardian's Office ("USGO") in LOS Angeles. I was a staff member at the USGO from January 1978 through January 1982. This section of Scientology, now called the Office of Special Affairs, is responsible for dealing with all external public relations, all matters relating to civil litigation or criminal matters, all governmental relations such as the IRS, and all critics of Scientology.

15. Because of my technical background I was posted as the Organizing Officer ("Org Officer") for the Public Relations Bureau and, later, as the Org Officer for the entire Guardian's Office. As the Org Officer, my functions included the handling of all personnel and organizational matters, such as correcting a staff member who made mistakes, taking care of staff members who were sick or upset or in trouble, recruiting new people for staff, and promoting or demoting staff members as needed. I was also responsible for the establishment and proper administration of all the Guardian's Office personnel throughout the United States. Because the Guardian's Office oversaw certain aspects of the administration of all other Scientology organizations, I became very familiar with the overall structure of Scientology and how the various organizations interact with each other and with the outside world.

16. In early 1982, I was transferred to a very high-level section called Special Project and was assigned as a PR Assistant under my husband, Robert Vaughn Young. In this position I became familiar with L. Ron Hubbard archives material, which was the complete collection of all of Hubbard's personal papers, including diaries, letters, and notes that he had kept from a very early age.

17. Several months later Special Project became what is now Author Services, Inc., a for-profit company whose ostensible purpose was to be L. Ron Hubbard's literary agency, I was taken out of PR and made the Organizing Officer for AS1 in April 1982. In this position I worked directly for David Miscavige, who was Chairman of the Board of ASI, to carry out his orders concerning the staff of ASI.

18. David Miscavige, known as DM, has been the head of Scientology since 1981. His loyalty to L. Ron Hubbard and Scientology is absolute and he is utterly ruthless about maintaining his power. He moved the seat of power from AS1 to the Religious Technology Center (RTC) in 1987, during a period of time when the IRS was investigating ASI's ties to the non-profit corporations of Scientology. At this point he appointed himself Chairman of the Board of RTC, which is his current title.

19. Although ASI was established as a for-profit, non-religious corporation, in reality while DM was Chairman of the Board of ASI, the staff of ASI ran the entire Scientology network. ASI had complete control over the management of all Scientology orgs and missions, all Office of Special Affairs activities, all Scientology litigation, all transfers of funds between church accounts and LRH accounts, every aspect of the life of anyone who was a Scientologist, whether staff or public. These powers were moved to RTC in 1987, as explained above.

20. Because of my experience in ASI I am familiar with the day-to-day activities and procedures of the highest levels of management of Scientology.

21. I have firsthand knowledge of the establishment of the corporate structure of Scientology as it now exists, having worked with the staff who were responsible for creating it. The purpose of this activity was to create an impenetrable, legally defensible network of corporations such that neither the IRS nor any other legitimate agency of government could "pierce the corporate veil" of Scientology organizations, thereby freeing Scientology management to transfer funds between organizations without concern for the law.

22. In September 1982 I was assigned to the Rehabilitation Project Force ("RPF"), the Scientology version of a prison camp. I was assigned to the RPF because I was openly critical of DM's coercive and degrading treatment of staff members. I was on the RPF in Los Angeles for eight months.

23. As a result of this experience I am familiar with the absolute control which the highest levels of Scientology nanagement have over the behavior and thought processes of every sea Org member.

24. There is only one way for a good Sea Org member to behave and think and any deviation from this is punished immediately and severely. In turn, it is the responsibility of sll members of Sea Org management to bring about the same pattern of behavior and thought in all Scientologists under their authority, regardless of whether those under their authority are part of the "church" or the various "secular" arms of Scientology. This distinction means nothing within Scientology. It was created purely to facilitate dissemination of Scientology and to fend off Scientology's "enemies" such as the IRS.

25. From May 1983, when I was allowed off the RPF, until 3 July 1984 I was posted as Course Supervisor at the International Training Organization (ITO) in Los Angeles. From this position I trained hundreds of fledgling Scientology executives from all over the world on the administrative and management policies of L. Ron Hubbard known as the Organization Executive Course, or OEC. AS a result of this experience I am very familiar with the administrative policy of Scientology and know that Hubbard formulated it purely to facilitate the establishing and organizing of his worldwide network of Scientology organizations.

26. In August 1984 I was transferred back to the PR Division of the Guardian's Office, which by that time had been renamed the Office of Special Affairs. My primary functions were as a writer and editor for FREEDOM Magazine, a Scientology publication created to serve as a vehicle for attacking individuals and groups who were perceived as threats to Scientology.

27. In 1985 I personally created a nonprofit, non-tax-exempt corporation called North Star Publishing for the purpose of moving FREEDOM Magazine away from the Church of Scientology. I did this so that FREEDOM would have more credibility and not be seen as a mouthpiece of Scientology. This corporation was active until 1987, and during the time I ran North Star I gained experience in interfacing with the business world while running a purely Scientology organization. I am familiar with the legal, financial and public relations sleight of hand required by Scientology corporations that must deal with the non-Scientology business world.

28. In 1987 North Star Publishing was disbanded and the staff were reassigned to OSA. My primary functions were again writing and editing. I wrote for FREEDOM Magazine, Scientology Today, and the Crusader.

29. In Scientology every aspect of PR is directed toward a particular "public." FREEDOM Magazine was directed toward government officials, legislators, heads of businesses, and other key "publics" who needed to be brought into agreement with Scientology's views of the key attackers of Scientology, such as the IRS, psychiatrists, etc. Scientology Today was directed all Scientologists and was intended to promote OSA as a powerful and successful arm of Scientology that was winning the war against the enemies of Scientology. The Crusader was a publication directed toward religious leaders and ministers of other religions and was intended to create allies for Scientology in the religious community.

30. As a writer and editor in the PR Division of OSA my primary responsibility was to "communicate the correct message to the correct public."

31. As a result of my experience as a writer for these different Scientology publications, I am familiar with Scientology's practice of changing its story for whatever public it is trying to reach. Often I rewrote the same basic story for each publication, completely changing the wording and overall thrust of the story to appeal to the different publics that were going to read it.

32. AS a writer in OSA I was also responsible for writing rebuttals of negative stores about Scientology that were published in various newspapers across the country. I was also assigned to write rebuttals of books that were published that were negative about Hubbard and Scientology. As a result of this work I became very familiar with the policies and practices of Scientology with regard to individuals and groups that criticize the organization. I have personal knowledge that the practices which were formerly called "fair game" continue to be employed although the term "fair game" is no longer used. These tactics are laid out in many of the key policies that are studied and applied by staff of OSA.

33. In July, 1989 my husband and I left Scientology. We lived in San Diego from 1989 until August, 1991, at which time we moved to Newport Beach. We are currently living in Corona del Mar, California.

34. As a result of my experiences in Scientology, I am qualified to discuss the policies, procedures and practices of this organization, including its relationship to Sterling Management with is important in this case.

35. Few people are qualified to act as experts on the subject of Scientology. Unfortunately, it is not a subject that one can learn by taking a course at the local university. It can only be understood by experiencing it, as I did for 15 years.

36. I believe it is crucial for outsiders to begin to understand what Scientology really is, what motivates its members, how the leadership views non-Scientologists and critics of Scientology, how Scientologists manipulate the courts for their own ends, and the role played by Scientology front groups in their overall plan to take over the world. I have agreed to act as an expert witness because I think it is important for people to begin to understand the true nature of this organization. But by telling the truth about Scientology, I am making myself a target of their Fair Game doctrine, which endangers not only me but my family as well.

37. I have information which the leaders of the Church of Scientology will do anything to keep me from discussing publicly. I know this to be true because I have firsthand knowledge of fair game being practiced on Scientology critics, including former Scientologists like myself and people who have never been in Scientology. I have firsthand knowledge of incredibly harassive and destructive actions being taken against people to silence their criticism of the Church. Scientology representatives claim that they do not practice fair game any more, but that is a lie.

38. My husband, Robert Vaughn Young, is also a target of their fair game practices because he is speaking out about the abuses he observed and experienced himself during his 20 years in Scientology.

39. Scientology operatives have begun to contact people from our past for the purpose of harassing and intimidating us into being silent about what we know.

40. I know they have gone through our trash as recently as Friday, September 10. Both my husband and I are personally aware, from our own experience in the organization, that stealing trash is part of the Church of Scientology's intelligence tactics against critics.

41. Based on my own experience, I know that they are looking for envelopes, letters, bills, notes or anything else with names, addresses and/or phone numbers they can use to harass .s . I have personal knowledge that they take names from trash and call them to get information and to spread rumors about their critics. I know they are looking for any other documents they can use to harmor harass or intimidate us.

42. The Office of Special Affairs (OSA), formerly the guardian's Office, is the section of Scientology under the immediate direction of the Religious Technology Center (RTC), that is responsible for silencing critics of Scientology. Within ISA there is an intelligence section, called the Information Division or Info, which is responsible for gathering derogatory nformation about critics which can then be used against them. The FBI raided this section of Scientology in 1977, confiscating thousands of documents which implicated the highest levels, including Hubbard and his wife, in criminal activities and , resulted in criminal convictions against 11 Sceintology operatives, including Hubbard's wife.) This information Jathering is done either by intelligence staff or by private investigators hired by the law firm of Bowles and Moxon, which is part of OSA. Private investigators are used when the actions are particularly dirty, so that if they are caught, the church leadership can deny all knowledge of it and also so that everything they do can be protected as attorney work product.

43. Scientology leaders repeatedly insist that the people who used to intimidate and harass critics have all been kicked off staff and that these kinds of dirty tricks are no longer practiced by Scientology against its perceived enemies, but this is not true.

44. An example of these tactics has already been filed as an exhibit in the case of Sterling v. CAN. It is a 1987 letter sent from Joan Heller, the Legal Officer (an OSA position) of Sterling Management Systems, to her senior at WISE [World Institute of Scientology Enterprises) International for approval before sending it out to a dissatisfied Sterling client who had requested a refund. (Anyone who asks for a refund is immediately labeled a suppressive person, or enemy of the Church.) In the letter, Ms. Heller makes it clear that if this person criticizes Sterling (a Scientology front group) any further, she will expose that he has been cheating on his income taxes:

"A cursory review of your folder . . . shows that you actually make moremoney than you report to the IRS and that you are skimming around $25,000.00 off the top prior to reports.

"This information is only what we have found so far. If this matter went public, of course, we would have to pursue what's behind this attack and expose any other crimes found. It is our experience that those who attack us, after all the things we try to do for them, have something to hide. We are more than willing to review this publicly if you continue your slanderous and defamatory accusations."

45. My husband and I have also begun to receive an inordinate number of phone calls , particularly very late at night, in which the caller simply hangs up without saying anything. This is another form of harassment and intimidation by church operatives which has been experienced by many critics of Scientology.

46. Former IRS Commissioner Donald Alexander mentioned this in an October 24, 1993 article. In it he was quoted as saying, "I hope the IRS did not give in to intimidation. By intimidation I mean 2 o'clock in the morning telephone calls."

47. We have received calls as late as 4:00 in the morning in which when the phone is answered, the caller simply hangs up. Apparently a church operative has been ordered to call us at 10:00 p.m., 1:00 a.m., and 4:00 a.m. as this is when the calls occur.

48. The Scientologists claim they no longer treat people as fair game, but this categorically untrue.

49. Fair game was defined by Scientology founder L. Ron Hubbard in 1965 as "without rights for self, possessions or position, and no Scientologist may be . . . punished for any action taken against a Suppressive person or Group during the period that person or group is 'fair game'."

50. Hubbard defined "suppressive person or group" as "one that actively seeks to suppress or damage Scientology or a Scientologist by Suppressive Acts. . . A truly Suppressive Person or Group has no rights of any kind and actions taken against them are not punishable."

51. In Scientology, one is labeled "suppressive" for exercising basic rights which other US citizens take for granted. Scientologist give up their rights to freedom of speech, freedom of the press, and freedom of association. A Scientologist is declared "suppressive" and becomes a target of fair game if he or she is publicly critical of Scientology in any way, if he or she writes anything critical or in any way negative about Scientology in a newspaper or magazine, or if he or she communicates in any way - much less meets with - someone else who has been publicly critical of Scientology.

52. In a later version of the policy letter that defined the above terms, Hubbard left out any mention of fair game and simply said that anyone declared suppressive would not have any rights as a Scientologist. What must be understood, however, is that in the world of Scientology, if one has no rights as a Scientologist, then one has no rights at all.

53. In the late 1960's Hubbard realized that some of his public statements were not good for Scientology's public relations, and he began to speak more euphemistically. This is how the cancellation of fair game came about. But Hubbard made it clear in the cancellation itself that he was doing it purely for public relations purposes:

"The practice of declaring people FAIR GAME will cease. FAIRGAME 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."

All he did was to order his followers to stop publishing anything with the words FAIR GAME on it. He specifically told them to continue to apply of his policies on the "treatment and handling of an SP." It was purely a matter of semantics. He felt that only the initiated could understand why Scientology's enemies must be tracked down and eliminated; therefore, he simply stopped talking about it with the uninitiated. Certainly the cancellation of fair game did not alter Scientology doctrine one iota. But the experience taught Hubbard a lesson; he became more careful about his and Scientology's public image.

54. Indeed, Hubbard was a master of the "acceptable truth." As he wrote in a 1970 PR policy:

"Handling truth is a touchy business . . . You don't have to tell everything you know --that would jam the comm[unication] line too. Tell an acceptable truth."

"Agreement with one's message is what PR is trying to achieve. Thus the message must compare to the personal experience of the audience.

"So PR becomes the technique of communicating an acceptable truth - and which will attain the desirable result."

55. He was also a master at getting others to do his dirty work. This is how it came about that 11 of his key henchmen (including his own wife) went to jail for crimes he ordered them to commit, but there was not enough evidence to indict Hubbard himself. Of course there wasn't. He was far too clever to get caught.

56. One of the tricks Hubbard used was to issue his sensitive orders as if he were explaining the tactics of Scientology's "enemies."

In a 1969 policy letter entitled "Targets, Defense," one of the errors he pointed out that had nearly put Scientology out of business was "not learning enemy tactics and using and bettering them."

With hints like this, he was then free to couch his written or verbal instructions in reverse terms. For example, in 1969 he gave explicit instructions on how to conduct covert intelligence data collection but wrote it as an explanation of how the enemies of Scientology carried out covert operations against the church.

57. He made it clear that he was not to be implicated in the covert actions his intelligence arm carried out:

"In using such data or documents as are furnished, there is a danger of exposing the . source of them or the agent so one usually falsifies the source and takes other measures to obscure both that one is dealing with Intelligence and that the agent or case officer had any connection with it."

Further in the same written briefing, Hubbard mapped out what he wanted from his covert operations section:

"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…."

"It follows all the rules of war but uses propaganda psychological effect surprise shock [sic], etc. to achieve its ends."

Finally, Hubbard outlined what he wanted done to his enemies:

"We remove his agents and vanquish his troops and we directly attack his central group. That's sound tactics. . .

"Our direct assault will come when they start to arrest his principals and troops (already begun)."

"Our total victory will come when we run his organizations, perform his functions and obtain his financing and appropriations."

58. After the FBI raided the church in July 1977, every Guardian's Office staff member, including myself, was ordered to participate in massive shredding parties. Every single piece of paper that incriminated Hubbard in any way was either shredded completely or the incriminating bits were sliced out with a razor blade.

59. Hubbard always had a very small number of lieutenants who were utterly, unquestionably loyal to him. He counted on his lieutenants for two things: to carry out his orders to the letter, and to maintain his image as a humanitarian.

60. This idea of Hubbard as a humanitarian would be ludicrous if it were not so dangerous. It is dangerous because people are lured into Scientology believing they are becoming part of a charitable organization founded by a humanitarian genius. In fact, the Scientology empire is a mirror image of a man who was evil, manipulative, megalomaniac, vindictive, cunning and psychopathic.

61. I know this to be true because I am one of only a handful of people who have read Hubbard's personal archives in its entirety. My husband was assigned to take care of these archival materials after Gerald Armstrong left the church at the end of 1981, and I was assigned as my husband's assistant. Because Gerald had left after reporting that some of the documents would expose Hubbard as a liar and a charlatan, our task was to become thoroughly familiar with all of the materials so that we could make sure Hubbard's image remained intact.

Many of the documents I found in Hubbard's personal archives made me physically ill, because they showed him to be so different from everything I had been led to believe about him.

62. Gerald Armstrong turned over thousands of these documents to his attorney, Michael Flynn, after he left the church in 1981. The church sued Armstrong to force him to return the material, but after hearing testimony from a number of former members and reviewing the materials, Los Angeles Superior Court Judge Paul G. Breckenridge refused to order the documents returned. In his decision, Judge Breckenridge provided one of the most accurate analyses of Hubbard and Scientology ever recorded:

"The organization clearly is schizophrenic and paranoid, and this bizarre combination seems to be a reflection of its founder. 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."

63. Shortly after the Breckenridge decision was issued, a judge in the High Court in London described Scientology as "immoral, socially obnoxious, corrupt, sinister, and dangerous" and called the behavior of Hubbard and his inner circle "grimly reminiscent of the ranting and bullying of Hitler and his henchmen."

64. Yet Hubbard was a master showman who knew how to charm his audience. In hundreds of taped lectures and thousands of published documents, he portrayed himself as a man who wanted nothing more than to help man free himself of all misery and insanity. He portrayed the Scientology organization as the only group that could save the world from the evil forces that were seeking to enslave it and he presented himself as the only person in the world who could safely lead humanity out of this terrible trap. That he was able to pull off this hoax so successfully --and that even though he is dead the fraud is actually continuing - is a testimony to Hubbard's astonishing talents of manipulation land deceit.

65. The people who are running Scientology now are Hubbard's most fanatical followers, his inner circle. He carefully gathered around him in his inner circle only his most loyal and dedicated followers , people who believed in him completely and would literally do anything he told them to. He made it a fundamental part of the Scientology philosophy that anyone who criticized him or his organization, and especially any member of the inner circle who betrayed them, was a criminal who was out to destroy him or the group because they were afraid Scientology would find out about their crimes. He instilled in his hand-picked lieutenants his Own rabid paranoia and ruthless vindictiveness.

66. When he died in 1986 the responsibility for continuing this bizarre crusade fell to David Miscavige, who has spent millions of dollars to promote the Church of Scientology as simply an "applied religious philosophy."

In fact, these people fully intend to take over the world, as Hubbard directed them to do in "Targets. Defense":

"The vital targets on which we must invest most of our time are:


Tl. Depopularizing the enemy to the point of total obliteration.

T2. Taking over the control or allegiance of the heads or proprietors of all news media.

T3. Taking over the control or allegiance of key political figures.

T4. Taking over the control or allegiance of those who monitor international finance and shifting them to a less precarious finance standard. .

"Our only justification for doing these things is that Scientology is the only game where everyone wins."

67. This is not the language of a religious leader. Indeed, Hubbard patterned his Sea Organization on a military model and made it clear that Scientology was at war. In policy after policy he repeated this, such as a 1969 policy entitled "Battle Tactics":

"If you uniformly apply the tactics and strategy of battle to the rows we get into, press or legal or public confrontation, you will win . . .

"If we and they are considered as two hostile and opposing nations at war, then a huge array of tactics and strategy become visible. . .

In this case it is not safe to hope for any halfway win. We must ourselves fight on a basis of total attrition of the enemy. So never get reasonable about him. Just go all the way in and obliterate him."

68. What is particularly frightening to me is that I see the Scientologists running roughshod over the judicial system of this country. I see them getting better and better at their sleight of hand, blithely holding up their masks of religiosity while laughing amongst themselves at the gullibility of the Court.

69. In fact, the current leaders of Scientology hold the justice system of the United States in utter contempt, as Mark C. Rathbun, one of the highest-placed executives in Scientology, in a declaration he filed on January 29, 1992:

"A reference to a person being 'fair game' 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. Compared to Scientology ethics and justice procedures, lay justice procedures are, in fact, barbaric."

If Scientology leaders view the courts as "barbaric", clearly their motive in filing so many lawsuits is purely to harass. If the court system has any value at all, it is to the degree that it can be manipulated to further Scientology's own purposes.

70. The most spectacular record of Sceintology's contempt for "lay justice procedures" can be found in the 284-page Stipulation of Evidence in the 1979 case of United States of America v. Mary Sue Hubbard, et al. This case was the result of the FBI's 1977 raids on several locations of the Guardian's Office, the intelligence arm of Scientology run by Hubbard's wife, Mary Sue. This document and the Sentencing Memorandum in the companion case of U.S. v. Jane Kember and Morris Budlong clearly illustrates Scientologists' contempt for the law and arrogant belief in their right to deceive the United States government and the courts.

According to these documents, the crimes revealed in the documents seized by the FBI included "the execution of smear campaigns and baseless lawsuits 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 atleast one innocent person; and the violation of the civil rights or prominent private citizens and public officials….

It is clear to the government that the church has filed lawsuits "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 their First Amendment rights secured them by the Constitution. The defendants and their cohorts launched vicious smear campaigns, speading falsehoods against those they perceive to be enemies of Scientology in order to discredit them and, in some instances, to cause then to lose their employement… To these defendents and their associates … anyone who did not agree with them was considered to be an enemy against whom the so-called 'fair game doctrine' could be invoked…"

71. This contempt for the law and arrogance continues unabated to this day, although the current leadership under the direction of David Miscavige, and many of his henchmen such as Mark Rathbun, would have the courts - and the IRS - believe otherwise.

This arrogance stems, in part, from the fact that the Scientology leaders are in the habit of saying whatever they want to the courts, believing they can get away with it because there is no one who can refute them.

72. In an article in the October 24, 1993 St. Petersburg Times, the following information was quoted from documents submitted by Scientology to the IRS:

"The Guardian's Office, set up to harass the government, has been shut down, the Church of Scientology says. 'Any individuals who were found at that time to be on staff were dismissed and informed never to apply for re-employment,' the Scientology lawyers wrote. New hires are checked against a list of former Guardian's Office criminals' the lawyers wrote."

This claim, which was apparently instrumental in gaining Scientology's recent tax-exempt status, is astonishing in light of the ease with which it can be proven false by anyone familiar IS with the histories of many current high-level Scientology management staff members. The truth is that only the name of the Guardian Office was changed; it was never shut down. The same organization, run on the same policies and staffed by many of the same people, is now called the Office of Special Affairs. I was there when David Miscavige's group of "Commodore's Messengers" arrived in the Guardian's Office and announced that they were taking over. I was there when they announced that all staff members of the Guardian's Office would henceforth be required to be members of the Sea Organization, and I was also there when the name of the Guardian's Office was changed to the Office of Special Affairs.

73. Some staff members left because they did not want to join the Sea Organization and have their lives controlled 24 hours a day by Miscavige and his "Commodore's Messangers." A few staff members, like Fred Hare and Jimmy Mulligan, who had been involved in the illegal activities but had not been caught were ordered off staff so they could not be an embarrassment to Scientology in the future. But for the most part, Guardian Office staff members continued their activities with out interuption.

74. Start with Heber Jentzsch, a well known Guardian Office staff member for at least a decade, who is now President of the Church of Scientology International and a staff member of the Office of Special Affairs International.

75. Kurt Weiland, a long-time Guardian Office staff member is now the Commanding Officer of the Office of Special Affairs International, the highest position in that organization.

76. Many other Guardian Office staff members became Office of Special Affairs staff, including Linda Hamel, Allen Hubbert, Gail Armstrong, John Carmichael, Jeff Quiros, and others. David Butterworth and Debbie Hubbert Rossouw, both of whom became OSA staff, were actually senior to the GO as Mary Sue Hubbard's personal GO liaisons before David Miscavige took over.

77. Responsibilities that were formerly held by Mary Sue Hubbard and the most senior Guardian Office executives are now carried out by the Religious Technology Center (RTC), which directs all Office of Special Affairs activities. Some Guardian Office staff were promoted to RTC after the current leadership came to power.

78. Warren McShane, for example, was a Guardian Office leadership, including David Miscavige, Marty Rathbun and Lynn Farney, are aware of the Guardian Office background of every single one of these personnel.

81. There is one other former Guardian Office staff member who deserves special attention.

Kendrick (Rick) Moxon, currently an attorney with the firm of Bowles and Moxon, (a law office which is actually part of the Office of Special Affairs), was named as an unindicted co-conspirator in the U.S. v. Marv Sue Hubbard case and is cited in the Stipulation of Evidence for his role in covering up the illegal activities which led to the indictments.

The record shows that in 1976, Moxon was the Assistant Guardian for Legal Bureau in Washington, D.C. He was served with a subpoena for handwriting samples of another Guardian Office staff member, Michael Meisner, suspected of breaking and entering several government offices and on whom a warrant had been issued. A week later Moxon submitted an affidavit with nine pages of handwritten material, stating that the nine pages were Meisner's handwriting. According to the record, it was later revealed that "Mr. Moxon had been directed to supply the government with faked handwriting samples in lieu of Mr. Meisner's true handwriting exemplars."

Moxon was simply doing what any loyal Scientologist would do. Moxon was lying under oath to protect Scientology.

82. Today, Kendrick Moxon is directing most, if not all, of the lawsuits that have been brought by the church against its critics. It was Moxon who interrogated both my husband and myself in deposition on October 23, although he is not even an attorney of record in the case for which we were deposed. It doesn't matter. That case was irrelevant to Moxon's actual objectives anyway. He was only there to conduct a fishing expedition, which he did despite repeated objections of counsel that his questions were utterly irrelevant to the case at hand. He was there to get us to make statements that could then be quoted and used to discredit us (which he immediately tried to do in a totally unrelated case). He was there to get information out of us that could be used to harass and intimidate us, which is exactly what began to happen immediately thereafter.

83. Moxon has been manipulating the courts since the 1970's and he is now doing so as an attorney licensed by the State of California. He is one of David Miscavige's key henchmen. He hires many of the private investigators who are directed to "find the crimes" of Scientology's critics.

84. The Scientologists consider themselves to be above the law; only the codes of Scientology are valid. They use their religious status as a shield which protects them from the normal restraints and inhibitions all other US citizens are expected to adhere to. Thus, staff members are routinely forced to go without sleep for days at a time, without decent food, there are instances of physical abuse against staff members, parents are not allowed to see their children, spouses are separated from each other for months at a time.

85. It is extremely difficult to document these accusations, because no current member will admit that these conditions exist (if they did, they would be assigned to the RPF or declared immediately) and before any outsider is allowed to intimidation of critics with their devout belief that they are the only chance man has, that anyone who criticizes Scientology is part of the overall conspiracy to destroy Scientology, and that all enemies must be obliterated at all costs for the sake of the future of mankind.

86. The people in charge of Scientology are merciless in their treatment of those that who don't measure up to the Scientology code of conduct, whether the individual is inside or outside of the organization. Many of these Scientologists executives have never known any other life except within the narrow confines of the Scientology world. Many, like the most senior Scientologists, David Miscavige, have little or no formal education and have never heard or read of any other reality than that one created by Hubbard.

87. Yet, wrapping themselves in the cloak of freedom of religion, they are utterly free to treat the staff as abusively as they choose, secure in the knowledge that no one will punish them because no one can touch them legally. Furthermore, as long as a staff member remains as Scientologist he or she is expressly forbidden to report abuses to the authorities. It is only by leaving Scientology that one is free to talk about the abuses that go on. Unfortunately, Scientology keeps the police and the courts at bay with its increasingly slick public image and its cloak of religiosity, and it keeps former Scientologists and others quiet by making it clear that anyone who speaks out publicly must be ready for their relentless harassment and intimidation.

88. Scientologists justify their harrassment and intimidation of critics with their devout belief that they are the only chance man has, that anyone who critizes Scientology is part of the overall conspiracy to destroy Scientology, and that all enemies must be obliterated at all costs for the sake of the future of mankind.

89. The contempt with which Hubbard and his followers view non-Scientologists was made clear in a 1967 policy by Hubbard entitled "Critics of Scientology" in which he declared:

"We are slowly and carefully teaching the unholy a lesson. It is as follows: We are not a law enforcement agent. 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."

90. One of the primary methods of intimidation the Scientologists employ is the threat of public exposure of information divulged during security checks, publicly called "confessional" for the benefit of the courts and the IRS. This procedure is used extensively as a control method on staff members and is an extremely effective way of silencing criticism.

91. Anyone who leaves Scientology is extremely reluctant to speak out against the organization, being acutely aware that all of their security checks will be thoroughly culled for information that can be used against them, whether they are violations of the law or simply aspects of their personal life that will be embarrassing.

92. Scientologists routinely compile such information and either turn it over to the authorities for prosecution or, if (as usually occurs) there is nothing in which the authorities would be interested, they create a pamphlet or pack of materials and pass this information out to the target's neighbors, friends, family members, and business associates. The purpose, as Hubbard has stated repeatedly, is to destroy the person. Ideally, the person will be sent to jail; short of that, his or her reputation can be ruined and the person left penniless through loss of business.

93. It was in 1960 that Hubbard first began to institutionalize the destruction of his critics, a practice he would later refer to as the Fair Game doctrine. In a policy called "Department of Government Affairs" he established the forerunner of the Guardian's Office, later to be renamed the Office of Special Affairs:

"In the face of danger from Govts or courts there are only two errors one can make: (a) do nothing and (b) defend. . . . 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 then 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. . . ."

"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 agesncies. Scientology is the only game on Earth where everyone wins. There is no overt in bringing good order."

94. It has been my personal experience that the current Scientology leaders will stop at nothing to protect Scientology from anyone they perceive as a threat. In this they are no different than the earlier Scientology leaders who went to jail, except that they have learned from the mistakes of their predecessors. The real crime of the Guardian Office leadership was that they got caught. The current Scientology leadership does not intend to let that happen again. They have developed more sophisticated methods of dealing with outsiders, (including the courts and the IRS) to mask their true motives and activities. But they are utterly unscrupulous in their determination to obliterate all obstacles that stand in the way of a "cleared planet"

95. I am still recovering from my experience in Scientology. I am still learning about how groups like Scientology use coercive methods to control people like myself, my husband, and many other individuals who are still under its spell. I believe that all Scientologists, even the current leadership, are the victims of Hubbard's version of mind control, just as I was. These people, including the Scientology attorneys and paralegals who deal with the courts, have no idea how much they are under the coercive influence of Scientology and its leaders. They are utterly fanatical about their dedication, and determined to protect Scientology from "enemies" like my husband and me.

96. There have been a number of people before me who have publicly told the truth about Scientology and every one of them has been threatened, frightened, coerced or bought off into silence. I have to assume that packs of materials are already being assembled to discredit my husband and me; I am sure plans have already been drawn up which include every possible avenue of harassment and intimidation they can think of to silence us.

97. If the truth is ever going to come out about Scientology, I believe the court is going to have to recognize the danger inherent in becoming an expert witness on Scientology and offer every possible protection to such experts from the fanatical vindictiveness of this organization. I respectfully request that the court offer this protection to me in this case.

I declare, under penalty of perjury, that the foregoing is true and correct.

Executed this 23rd of November, 1993 at Orange California.

Stacy Young

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