I, David Mayo, declare as follows:
1. I submit this Declaration in opposition to Plaintiffs' Motions for Partial Summary Judgment based upon personal knowledge of the facts contained herein and, if called upon as a witness, I could and would competently testify thereto From 1959 to 1983, I was affiliated with the Church of Scientology and, although officially designated as a "staff member," throughout the period of my affiliation I was paid typically only $10 to $22 per week for full time work for the Church. In February, 1983, I left the Church after being subjected to a six-month period of forced captivity and torture involving physical abuse and emotional distress imposed because of voicing concern about unethical and criminal activities being committed by officials of the Church
2. I have never been offered, nor have I ever requested, immunity from criminal prosecution in exchange for providing information, cooperation, or testimony with regard to criminal prosecution or legal action by the IRS or any other public agency against the Church of Scientology, the Religious Technology Center or any of their affiliates
3. I have never been charged with or convicted of any criminal offense I have never been informed that I was the subject of a criminal investigation
4. And and all testimony given by me in any legal action by federal authorities against the Church of Scientology, the Religious Technology Center, or any of thier affiliates was pursuant to subpoena by a public investigative agency
5. In October 1982, a "Committee of Evidence" was convened by plaintiff Religious Technology Center to consider a charge against me of "sexual or sexually perverted conduct." The Chairman of the Comittee of Evidence was Ray Mithoff (As the subject of the inquiry, I received a copy of the convening order, a true and correct copy of which is attached as Exhibit "A" )
6. The Committee of Evidence according to its "Findings and Recommendations", dated January 29, 1983, "met extensively, reviewing all evidence and data submitted, and conducting its own investigations where needed to determine the guilt or innocence of each interested party" regarding the charges made in the October 9, 1982, order convening the Committee It noted that I pleaded NOT GUILTY to specification No 5, "Sexual or sexually perverted conduct" and "the committee found insufficient evidence to substantiate the charge." (I received a copy of the "Committee of Evidence Findings and Recommendations," a true and accurate copy of which is attached as Exhibit "B". )
Gregory Ryerson, a staff member of the Church of Scientology International, has falsely certified Plaintiffs' Exhibit "B" as a true and correct copy of "Findinqs and Recommendations of the Comittee of Evidence" See, Declaration of Gregory Ryerson In Support Of Plaintiffs' Motion For Partial Summary Judgment Regarding Defendant David Mayo's Counterclaim For libel, signed under penalty of perjury, dated April 16, 1987 Plaintiffs' Exhibit "B" is a pastiche As such, it is not a true and correct copy of the "Findings And Recommendations Of The Committee of Evidence "
7. Vero Dantas, husband of Lecia Westerman, did not become ill because of auditing by me or anyone associated with the Church of the New Civilization at the Advanced Ability Center or elsewhere.
8. Plaintiffs stated in an Executive Directive, SO ED 2445 INT, dated February 13, 1984, "Cancellation Of All Telexes, Despatches, Cramming Orders And Verbal Tech Issued by David Mayo," p 2, # 4, that, "In 1980 Mayo tried to position himself as the source of LRH's miraculous tech breakthrough of Solo NOTs in a long lecture that he gave. He then issued the transcript of it as a Flag Information Letter and ordered people to study it, as a 'reference'" I recognize this document as an official document of the CSI issued on blue paper with blue ink and carrying the following CSI designation
CSI:AVC:RM: iw (C) 1984 CSI. All Rights Reserved (A true and correct copy is attached as Exhibit "C" )
9. The quoted matter in paragraph 8, above, refers to Flag Tnformation Letter 383, December 1980, authorized by AVC INT and approved by WDC for the Boards of Directors of the Churches of Scientology. I did not "issue" the transcript of the lecture. The Flag Information Letter itself clearly states that it was authorized and approved by and for the Boards of Directors of the Churches of Scientology. Throughout the lecture, for reasons set forth below, I gave full and complete credit to L Ron Hubbard as the source of Solo NOTs. At no point did I try to position myself as the source (A true and correct copy of Flag Information Letter 383 is attached as Exhibit "D")
10. The technology of Dianetics and Scientology is a product of the efforts of many people, including myself, and among others, Melanie Murray, Julie Mayo, Merrill Mayo, Dona Haber, Brian Livingston, and Phoebe Mauer. Moreover, I am the primary source of NOTs and SOLO NOTs
11. During my affiliation with the Church of Scientology, I only attributed discovery and authorship of the tech to L. Ron Hubbard because I was compelled to do so as an article of faith of the Church. It is the policy of the Church to require all tech to be attributed to L Ron Hubbard
12. At no time have I been in the employ of L Ron Hubbard.
13. In February 1983, I left the Church of Scientoloqy. Thereafter, the Church of Scientology, the Religious Technology Center, and their agents and affiliates began a campaign of harassment and intimidation against me and persons who associated with me.
14. On August 29, 1982, David Miscavage, and others, acting on the orders of L. Ron Hubbard, kidnapped me and subsequently kept me captive and physically and mentally abused me for six months. During this period, David Miscavage, an officer and director of RTC, told me in the presence of Vicki Aznaran, President of RTC, Mark Yaeger, Commanding Officer, CMO INT of CSI that if I ever escaped, he would personally see to it that the resources of the Church of Scientology would destroy my character and reputation internationally. During that six-month period of captivity, I was forced to run around a tree in the desert in temperatures of up to 110 degrees for 12 hours a day, 7 days a week for 3 months I was under tremendous coercion and duress. I was refused medical and dental treatment (after escaping captivity I lost six teeth and required thousands of dollars of dental work to save the rest of my teeth). I was not permitted to make or receive phone calls and all letters I wrote were read by Scientology security guards. I was often awakened during the night and interrogated (mainly by Jesse Prince). In early February 1983, I was told by Rick Aznaran, Director of Security, RTC, (husband of Vicki Aznaran, President of RTC), to get the idea of leaving out of my head because I would never leave the property alive.
15. From 1983 through to the present, Plaintiffs have engaged in a concerted campaign to destroy me in accordance with the Scientology "Fair Game Law," which allows opponents of the Church to 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."
16. As part of the campaign of harassment and intimidation against me, the Church of Scientology, the Religious Technology Center, and their affiliates and agents employed a team of private detectives who harassed parishoners and staff of the Advanced Ability Center, Santa Barbara, California, and who falsely misrepresented themselves as federal agents and conducted campaign of disinformation about me to the parishioners of the Cnurch of the New Civilization, potential parishioners of the Church of the New Civilization, the staff and the friends and relatives of the staff of the Advanced Ability Center, and among persons with whom I and the Center conducted religious services and training.
17. I was in extreme danger and under substantial duress during the six-month period of captivity and torture. The duress affected me even after my escape. I felt harassed and intimidated. When I left/was expelled in 1983, I had no job qualifications (other than related to Scientology), negligible savings, was not eligible for unemployment (nor social security) and had no job prospects. I had no friends or acquaintances who were not scientologists and all Scientologists were required to "disconnect from" (ostracize) me.
18. I have received many letters from people claiming to be Scientologists who announce that they are disconnecting from me (True and correct copies of a representative sampling of these letters are attached as Exhibits "E-L" )
19. During this time I was barely able to cope, but was at all times greatly distressed and upset. In 1984, when the Church of the New Civilization was doing exceptionally well, a new and even more concerted campaign of harassment began involving not only personal attacks on my character and reputation, but also against everyone I knew and with whom I have associated. During the summer of 1984, things became almost unbearable. My distress, feelings of helplessness and despair were overwhelming and continued to grow as each new insult was added. These troubled days continue to have a toll on my peace of mind, which was reinforced with each new act of harassment.
20. As part of the campaign of harassment and intimidation launched against me by the Church of Scientology, the Religious Technology Center, their affiliates and agents, certain publications, among which are "The Story of a Squirrel," the "Writ of Expulsion and Suppressive Person Declare," and the 'Squirrels' Executive Directive, which make false, scurrilous accusations against me have been published, circulated and distributed to Scientologists, to former Scientologists and to others who have connections with me or the Church of the New Civilization and the Advanced Ability Center.
21. In September 1983, I received the letter signed by Lecia Dantas, nee Westerman, a true and correct copy of which is annexed hereto as Exhibit "M". After receiving the letter, I telephoned her and we discussed the letter. I called her at the number I knew to be hers and I recognized her voice.
22. As documented by other Declarations concurrently filed herein, missionaires from the Religlous Technology Center and the Church of Scientology are still distributing packs containing, among other malicious documents, "The Story of a Squirrel." the "Suppressive Person Declare," the "Westerman Public Announcement," and letters and documents referring to those publications.
23. On average, for me, one-half of each working day during the active functioning of the Church of the New Civilization was consumed with responding to inquiries from parishioners and potential parishioners regarding the false and malicious charges made against me and with dealing with agents of the Church of Scientology or the Religious Technology Center sent to infiltrate and disrupt the Church. As a result of these responsive actions required on my part, I was unable to attend to my duties at the Church and Center and was unable to develop new parishioners and to attend to retention of existing parishioners.
24. As a result of the false and scurrilous accusations made against me by the Church of Scientology and the Religious Technology Center, their affiliates and agents, the parishioners of the Church of the New Civilization were lost and new parishioners were deterred from coming to the Church while it was active.
25. Because of the campaign of harassment and intimidation directed at me, at the Church of the New Civilization and Advanccd Ability Center and its staff and at parishioners, potential parishioners, and supporters of that Church, income was lost to the Church and to me, individually.
26. At no time have I sought to make my differences with the Church of Scientology a public issue Any publicity generated involving the Plaintiffs and their campaign against me has been only in response to that campaign. The only public statements made by me which could be construed as antagonistic to the Church have been made in internal publications of the Advanced Ability Center or during "Sunday talks" presented at the Advanccd Ability Center in which I responded to the Church's accusations and sought to clear my name of the false and denigrating statements made against me.
Executed on this 1st day of May, 1987, at Palo Alto, California