Graham E. Berry, State Bar No. 128503
Gordon J. Calhoun, State Bar No. 84509
Lewis, D'Amato, Brisbois & Bisgaard
221 N. Figuero Street, Suite 1200
Los Angeles, California 90012
Telephone: (213) 250-1800

Attorneys for Defendants




   CHURCH OF SCIENTOLOGY          )        No. CV 91-6426 HLH (Tx)
   INTERNATIONAL                  )
                                  )      REVISED DECLARATION OF HANA
   Plaintiff,                     )      WHITFIELD RE MOTION FOR COSTS
   vs.                            )      Date: APRIL 4, 1994
   STEVEN FISHMAN and UWE GEERTZ  ) Time: 10:00 a.m.
                                  ) Courtroom: 7
   Defendants                     )


I, Hana Whitfield, declare as follows:

1. I am over the age of 18 years. I am a resident of the State of California and I have personal knowledge of the matters set forth herein. If called upon as a witness herein I could testify competently as to the matters set forth herein.

2. Having been retained and designated as an expert witness in the Church of Scientology International vs Steven Fishman and Uwe Geertz law suit, I am responding to several declarations submitted by Messrs. Lubell, Moxon, Bowles, Miscavige, Starkey, Mithoff, and others on February 17, 1994 along with the Church of Scientology International's ("CSI") Memorandum of Points and Authorities in Support of Motion to Dismiss, dated February 16, 1994.

3. It is significant to note the hateful and vengeful emotions the aforementioned Scientologists entertain toward their critics such as Dr. Uwe Geertz, Steven Fishman ("Fishman"), their attorneys, Vaughn and Stacy Young and others. These emotions and their ensuing acts, have been dominant toward CSI critics for decades. They originate in the very policies and bulletins written by L. Ron Hubbard ("Hubbard") included herein.

4. It is apparent that the CSI vs Steven Fishman and Uwe Geertz law suit was designed exactly according to Hubbard's policies so as to do the very acts to Dr. Geertz and Fishman that CSI and the Religious Technology Center ("RTC") and Author Services, Incorporated ("ASI") claim is being done to them.


5. I was a Scientologist for twenty years. I became an adherent after reading Hubbard's book, Dianetics The Modern Science of Mental Health ("DMSMH") in 1965 in South Africa. I started auditor training in Johannesburg, then went to Saint Hill, England, and received advanced auditor training through Level 7, the highest auditor and case supervisor training level available at that time. I also completed Hubbard's Organization Executive Course, a multi-volume course covering all Hubbard's organizing, business management, finance, establishment, promotional and public relations policies and procedures, during which I learned how to run a Scientology Organization.

6. I received auditing up through the state called "Clear." Hubbard's Technical Dictionary contains thirteen definitions for the state, attached hereto as Exhibit 1, some of which are: "A Clear, in an absolute sense, would be someone who could confront anything and everything in the past, present and future." (Taken in part from Ability Minor Magazine Number 256); "A Clear has no vicious reaction mind and operates at total mental capacity just like the first book (Dianetics The Modern Science of Mental Health) said. In fact every early definition of Clear is found to be correct." (Taken in part from Hubbard Bulletin 2 April 1965, "The Road to Clear"); "To clear: to release all the physical pain and painful emotion from the life of an individual." (Taken from Hubbard's book, DMSMH.)

7. I served one year as contracted staff at the Los Angeles Organization in 1966 and 1967 after which, by special invitation, I joined Hubbard's Sea Project in Las Palmas, Canary Islands. Hubbard assumed the title of Commodore in 1966 or 1967. The Sea Project grew into the Sea Organization ("Sea Org") which was looked upon as Scientology's 'elite.' Even though we were Scientologists and ordained ministers, Hubbard had us wear naval type uniforms and insignia, and sign billion year contracts. For the next eight years through 1975, I served on two of Hubbard's ships, on the "Avon River," later renamed the "Athena," and the "Royal Scotman," later renamed the "Apollo." I held positions including those of Ship's Captain, Deputy Captain, Commodore's Staff Aide, Deputy Commodore for the United States and others, and was immediately subordinate to Hubbard for most of this time.

8. Hubbard once spoke about his strategies for "handling" his enemies. The best way was to, literally, drive them crazy, to use all one's resources to find their weaknesses and hit them hardest where it hurt the most. He said there were few men in history who mastered the techniques to do so successfully. He intimated he was one.

9. By 1975, Hubbard's auditing techniques were already affecting me negatively. I had almost constant migraine headaches and was scared that Hubbard's techniques no longer worked on me.

10. In October 1975, Hubbard moved his organization ashore to Clearwater, Florida. From then on to the early 1980s, I got worse. I couldn't get medication strong enough to stop the never ending pain. By early 1976, I developed suicidal ideation because I couldn't conceive any other way to stop the pain. It continued unabated until well after I left the Sea Org in March 1982.

11. In 1984, I experienced a disaster with a CSI front group, Sterling Management Systems, ("SMS"). SMS promoted Hubbard's business management policies to doctors, dentists and chiropractors as a way to way to expand their business and double their income. SMS claimed no connection to CSI though its consultants, including myself, knew otherwise. The despicable treatment I saw meted out to two decent dentists in a San Bernadino clinic, and to me and my superior, by Sterling staff and by Scientologists, shocked me so deeply that I left CSI. Both dentists paid for expensive SMS consultants to introduce Hubbard's management techniques into their practice, train their employees and double their income by year's end.

12. The dentists were pushed to buy a CSI auditing package for nearly $1,000 an hour, with a minimum of 25 hours, for each dentist. They saw their budget overextend and put a stop on the check. On the same day the dentists heard one of their SMS consultants, who touted no connection between SMS and CSI, talk about the transgressions they had divulged to their auditors in confidential priest-penitent auditing sessions. The same day, one dentist's wife also bought home a pack of critical CSI news articles from the public library.

13. SMS and CSI went into overdrive and the screaming and duress began. The dentists were threatened: to make the check good one dentist was blackmailed and the other was told he would reincarnate as a rock in his next life. My superior and I were fired two weeks later, and I left Scientology forever.

14. I then began a long recovery, searching for answers as to why I joined Scientology and gave it twenty years of my life only to end up suicidal and in chronic ill health.


15. In order to understand how Hubbard directed Scientology throughout its myriad corporations almost up to his death in 1986 and how the authority he created has continued thereafter, one has to understand his foundational policies. Hubbard's policies established all lines of authority, corporate structures and job descriptions in CSI. His policies had seniority over those of others without exception, regardless of corporate or organization positions. His policies were permanently valid unless canceled by Hubbard himself.

16. Hubbard Policy of 13 March 1966, "Orders, Precedence of Personnel, Titles Of," attached hereto as Exhibit 2, states, "The following table gives the precedence ... of orders or directions in Scientology. This table shows what order to follow first and if one below is contrary to one above, follow the upper one." (emphasis added). The first three entries are Board Resolution, Policy signed by Hubbard, Bulletin signed by Hubbard, and so on down the chart. Orders originated and signed by others come after these four. The policy continues, "No order lower on the scale may cancel or set aside an order above it on the scale ... Any written or published order may be canceled by a published order senior to it on the above chart except that, traditionally, board minutes cannot cancel policy letters or bulletins, these being originated or modified by the Executive Director whose powers only are ratified by the board."

17. On 13 August 1967, during the early days of the Sea Project, Hubbard wrote Flag Order #5, "Staff Conduct," attached hereto as Exhibit 3. It states, "The order of importance of ... orders is: (a) Commodore's (Hubbard's) concerns first, (b) others second. Do both. Both are important." This Flag Order was never canceled by Hubbard.

18. In 1978 Hubbard wrote, "The Code of a Sea Org Member," attached hereto as Exhibit 4. It states, "I promise to uphold, forward and carry out Command Intention." This Code was never canceled by Hubbard.

19. Another Hubbard policy of 24 September 1970, "Issues-Types Of," attached hereto as Exhibit 5, clarified the value of various major types of issues: "HCOPL - Hubbard Communications Office Policy Letter. Written by LRH only. This is a permanently valid issue of all third dynamic (group), org and administrative technology ... HCOBs - Hubbard Communications Office Bulletins. Written by LRH only. These are the technical issue line. They are valid from first issue unless specifically canceled ... The above are the ... main lines of issue of valid data. They have first priority on mimeo and in distribution." This policy was never canceled by Hubbard.

20. A later CSI Policy Directive #19 of 7 July 1982, "The Integrity of Source," attached hereto as Exhibit 6, stated, "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 ..." It was written and issued by the Watchdog Committee, a division of CSI.

21. These Hubbard policies laid an automatic response into Sea Org members and Scientologists - that their first loyalty was to Hubbard as head of the Sea Org and Scientology, not to the Commanding Officer of their own organization and even less so to their direct organization superior. This loyalty remains so into the present. Current and former Scientologists would all say that they would follow Hubbard's orders or a Commodore's Messenger's orders rather than that of their Commanding Officer, attached hereto as Exhibit 7.


Misrepresentation That Criminal Acts Done in the Past Were Aberrational Acts By The Discredited And Defunct Guardian Office Rather Than Mandated By Hubbard's Policy.

22. David Miscavige ("Miscavige"), in his February 17, 1994 declaration filed herein, misdirects the attention of this Court by misrepresenting that criminal acts done in the past were aberrational acts by the discredited and defunct Guardian Office ("GO") and concealing that such criminal acts were, and still are, mandated by Hubbard's policy. (Miscavige declaration, pages 19 and 26). He also said (page 39), "... the only reason that the Youngs feel safe enough to make their outrageously false allegations of bad conduct and harassment against the Church and me is because they know there will be no "Fair Game" retaliation, thanks to my kicking out the GO and putting a permanent end to their abuses." (Miscavige declaration, page 39).

23. Miscavige's claims are false. The defunct GO is the wrong direction to look for blame and the wrong source to focus it on.

24. To look in the right direction and at the right source, one must go to Hubbard's own policies.

25. In a taped lecture in June 1952, "The Journal of Scientology, Issue 18-G," attached hereto as Exhibit 8, pages 1 and 2, Hubbard said, "The only way you can control people is to lie to them ... When you find an individual is lying to you, you know that the individual is trying to control you. That is the mechanism of control.....Not "is going to", but "is lying to you." This taped lecture was never canceled by Hubbard.

26. A Hubbard bulletin of 5 November 1967, "Critics of Scientology", attached hereto as Exhibit 9, states, "Now, get this as a technical fact, not a hopeful idea. Every time we have investigated the background of a critic of Scientology, we have found crimes for which that person or group could be imprisoned under existing law. We do not find critics of Scientology who do not have criminal pasts. Over and over we prove this." Hubbard continued on page 2, "Two things operate here. Criminals hate anything that helps anyone, instinctively. And just as instinctively a criminal fights anything that may disclose his past ... If you, the criticized, are savage enough and insistent enough in your demand for the crime, you'll get the text, meter or no meter. Never discuss Scientology with the critic. Just discuss his or her crimes, known and unknown. And act completely confident that those crimes exist. Because they do." This is a key Hubbard bulletin which lays the foundation for the beliefs and the actions of Scientologists. Other Hubbard writings amplify it. This bulletin was never canceled by Hubbard.

27. In mid-March 1955, Hubbard wrote the "Dissemination of Material," attached hereto as Exhibit 10, which states: "The purpose of the suit is to harass and discourage rather than to win. The law can be used very easily to harass, and enough harassment on somebody who is simply on the thin edge anyway ... will generally be sufficient to cause his professional decease. If possible, of course, ruin him utterly." This article was never canceled by Hubbard.

28. Hubbard's policy of 15 August 1960, "Dept of Govt Affairs," attached hereto as Exhibit 11, states: (3) Make enough threat or clamor to cause the enemy to quail ... (6) If attacked on some vulnerable point by anyone or ... any organization, always find or manufacture enough threat against them [emphasis added] to cause them to sue for peace. Don't ever defend. Always attack. Don't ever do nothing. Unexpected attacks in the rear of the enemy's front ranks works best." This policy was never canceled by Hubbard.

29. Hubbard policy of 25 February 1966, "Attacks on Scientology," attached hereto as Exhibit 12, states, Scientology must respond to attacks by "... attacking the attackers only. NEVER agree to an investigation of Scientology. ONLY agree to an investigation of the attackers. This is the correct procedure: (1) Spot who is attacking us. (2) Start investigating them promptly for FELONIES or worse using our own professionals, not outside agencies ... (4) Start feeding lurid, blood, sex, crime, actual evidence on the attackers to the press. Don't ever tamely submit to an investigation of us. Make it tough, rough on attackers all the way.... There has never yet been an attacker who was not reeking with crime. All we had to do was look for it and murder would come out." This policy was never canceled by Hubbard.


30. Miscavige brought up Hubbard's policy on the "FAIR GAME LAW" in his February 17, 1994 declaration attached hereto, page 39, saying there would be no "Fair Game" retaliation on Vaughn and Stacy Young who, like my husband and me, are speaking out about CSI. This is false.

31. The first Hubbard policy on "Fair Game" was printed 1st March 1965, "JUSTICE SUPPRESSIVE ACTS SUPPRESSION OF SCIENTOLOGY AND SCIENTOLOGISTS THE FAIR GAME LAW," attached herein as Exhibit 13. It states: "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 ... Such Suppressive Acts include ... Ist degree murder, arson, disintegration of persons or belongings not guilty of suppressive acts (emphasis added)..." Hubbard thus gave Scientologists carte blanche to commit criminal acts against anyone declared a suppressive person. Despite Scientologists' protestations that the policy does not exist or never existed, I was a student at Saint Hill Manor, England in late 1965 when I was required to study it.

32. These Hubbard policies are not philosophical. They are functional; they are the guide to how CSI and RTC operate, how the GO operated, and how its successor, Office of Special Affairs ("OSA"), a division of CSI, operates.

33. After the policy's distribution, there was so much media and public outcry against it, that Hubbard revised it and deleted the underlined phrase above. The most recent revision, Hubbard Policy of 23 December 1965 revised 8 January 1991, "SUPPRESSIVE ACTS SUPPRESSION OF SCIENTOLOGY AND SCIENTOLOGISTS," attached hereto as Exhibit 14, bears little similarity to the earliest 1 March 1965 edition.

34. A further Hubbard policy ordered upper level OT graduates to commit criminal acts on suppressive persons. It is, "O.T. REGULATIONS," of 30 September 1966, attached hereto as Exhibit 15. It states, "No Operating Thetan may engage in a suppressive action against any person, state or country in the absence of an ... Ethics Order labeling the person, state or country suppressive. Such orders must be obtained beforehand." This policy was never canceled by Hubbard.

35. A later Hubbard policy of 18 October 1967, "PENALTIES FOR LOWER CONDITIONS," attached hereto as Exhibit 16, states: "SP Order. 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." This policy was never canceled by Hubbard.

36. The action of declaring people suppressive persons still continues in all Scientology Organizations.


37. Scientologists argue interminably that Hubbard's "Fair Game" policy was canceled in 1968 and again later, that it never existed, that because it doesn't appear in the 1991 policy manuals it doesn't exist, and more. A review of "Fair Game" cancellations shows this is false.

38. Hubbard policy of 21 October 1968, "CANCELLATION OF FAIR GAME," attached hereto as Exhibit 17, a key policy quoted by Scientologists as purportedly canceling "FAIR GAME," in fact upholds the "Fair Game" treatment of suppressive persons with criminal acts. It states, "The practice of declaring people FAIR GAME will cease. FAIR GAME may not appear on any Ethics Order. It causes bad public relations. This P/L does not cancel any policy on the treatment or handling of an SP" (emphasis added). This meant that a declared suppressive person or SP was still subject to the practice and acts ordered by "Fair Game." He just was not labeled "Fair Game" anymore.

39. An affidavit written by Hubbard on March 1976, attached hereto as Exhibit 18, though claimed by Scientologists to cancel "FAIR GAME," fails to do so.

40. An 8 June 1979, order titled, "DECLARE," attached hereto as Exhibit 19, quotes Hubbard's "Fair Game" policy of 23 December 1965 and the words "THE FAIR GAME LAW." This was well after any Hubbard "cancellations."

41. In a 16 December 1980 "Sentencing Memorandum of the United States of America," attached hereto as Exhibit 20, US Attorney Ruff and US Assistant Attorneys Banoun, Hetherton and Winfree wrote 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 Judge Richey." (Sentencing Memorandum, page 16 footnote)

42. Several Courts found that CSI continued applying the "Fair Game" doctrine beyond any time the Church said it was canceled, such as Judge Breckenridge in his decision of June 22, 1984, in Church of Scientology of California vs Gerald Armstrong, specifically pages 8, 11 and 13, attached hereto as Exhibit 21. 43. A further purported "Fair Game" cancellation of 22 July 1980, "ETHICS CANCELLATION OF FAIR GAME, MORE ABOUT," attached hereto as Exhibit 22, also did not conceal the practice. It wasn't even written by Hubbard but by "The Boards of Directors of the Churches of Scientology," so, by Hubbard's own rules quoted in paragraphs 16 to 21, this "cancellation" did not have the authority to cancel Hubbard's "Fair Game" policy.

44. That "Fair Game," including criminal action and massive financial fraud continue and which implicates Miscavige himself, occurred in San Francisco, on 17 October 1982.

44a. Seven top Scientologists held a conference of United States Mission Holders in the San Francisco Hilton Hotel. They were Miscavige, Norman Starkey ("Starkey"), Marc Yager ("Yager"), Lyman Spurlock ("Spurlock"), Ray Mithoff ("Mithoff"), Guillaume Lesevre ("Lesevre") and Steve Marlowe ("Marlowe"), attached hereto in Exhibits 23 and 24.

44b. Exhibit 23 shows the seven men at a table with Starkey talking at the microphone. Miscavige is behind the microphone, looking up at Starkey. They are all in Sea Org Officer uniform, with lanyards and service ribbons. Miscavige was a Commander, Starkey a Commander, Yager a Captain, Spurlock a Warrant Officer, Lesevre a Captain. Mithoff and Marlowe, who worked in the non-profit RTC, were both Commanders.

44c. The United States Mission Holders, with whom they were interacting, were licensed by a separate entity, Scientology Missions Int.("SMI"), operating within the non-profit CSI's corporate structure.

44d. The announced conference purpose was to make the Mission Holders unquestioningly compliant. Miscavige personally declared at least one Mission Holder a suppressive person, attached hereto as Exhibit 25, and said criminal charges were filed against him. This constituted the practice of "Fair Game." The conference resulted in massive intimidation and belittling of Mission Holders.

44e. What Exhibits 23, 24 and 25 do not show, but what occurred in fact was an utter abandon of corporate integrity. The majority of these Officers held full time positions in the for profit AUTHOR SERVICE, INC. organization, yet represented themselves as non profit CHURCH OF SCIENTOLOGY INTERNATIONAL members and SEA ORG OFFICERS as well. (1) All seven men worked in tandem during this conference; (2) All seven men wore full Sea Org uniform and were introduced by their Sea Org ranks; (3) Miscavige and Starkey held full time positions in the for profit ASI; Miscavige as ASI Chairman of the Board since March 1982 and Starkey as ASI Chief Executive; (4) Spurlock held a full time position in the for profit ASI as Corporate Affairs Director. (5) ASI supposedly acted as agent for Hubbard's fictional works, but in reality it was running the non-profit CSI and RTC, attached hereto as Exhibit 26, in trial testimony of Homer Schomer in JULIE CHRISTOFFERSON TITCHBOURNE vs. CHURCH OF SCIENTOLOGY, et al., pages 3598, 3605, 3607-8. (7) Marlowe, Lesevre and Mithoff were the only three who wore Sea Org Officer uniforms validly - they were Inspector General RTC, Executive Director Int. CSI, and Senior Case Supervisor Int. CSI respectively at the time, both RTC and CSI being non-profit corporations.

44f. What is also not seen in Exhibits 23, 24 and 25, is that the Mission Holder Conference was held in order to perpetrate an enormous financial fraud and scam on CSI and individual Mission Holders, and was done with the full knowledge and participation of Miscavige, others present as well as Hubbard as follows: (1) Through massive intimidation and coercion ("Fair Game"), the wealthy and independent Mission Holders were forced to pay huge sums of money through CSI to ASI; (2) ASI funneled the money through a Liberian shell corporation, Religious Research Foundation, and through Canada, into Hubbard's private bank accounts in Luxembourg and Lichtenstein; (3) During only part of 1982, over forty million dollars from the non-profit CSI was funneled through the for profit ASI into Hubbard's personal bank accounts, attached hereto as Exhibit 26, according to trial testimony of Homer Schomer in JULIE CHRISTOFFERSON TITCHBOURNE vs. CHURCH OF SCIENTOLOGY, et al., pages 3609, 3611, 3614-3620, 3629-3630.

44g. This is only the tip of the iceberg concerning corporate integrity violations, which were standard operating procedure with Hubbard and which he passed on to his followers. Scientology management cannot succeed without such violations ... Hubbard's policies and procedures, only some of which mandate the authority and independence of Boards and Executive Directors, do not, in the main, tolerate this in practice.

44h. Miscavige's attempts to portray himself, CSI, RTC and ASI as having clean hands since the "demise" of the GO in 1981 are thus blatantly false, attached hereto as Exhibits 23, 24, 25, and 26, according to trial testimony of Homer Schomer in JULIE CHRISTOFFERSON TITCHBOURNE vs. CHURCH OF SCIENTOLOGY, et al., pages 3652 and 3659.

45. Hubbard was Miscavige's role model. Hubbard purportedly signed an "Agreement" on September 15, 1966, regarding his resignation, "from all directorships of Church of Scientology effective September 1, 1966." I purportedly witnessed the agreement and signed it, "Hana Eltringham," my former name, attached hereto as Exhibit 27. The Agreement is false. In September 1966, I was a student auditor at Saint Hill, England, completing Class 7 auditor interne requirements in order to join my husband, Guy Eltringham, in Los Angeles. I was a nobody. Up to that time, I never met or spoke with Hubbard. I signed the Agreement either on board the "Avon River" or the "Royal Scotman" between August 1967 up to March 1969, when I was still a rising star in Hubbard's personal entourage.

46. "In 1983 and 1992, CSI printed and distributed two publications, each containing hundreds of Scientology and Sea Org members names who were declared suppressive persons. They are SO ED 2192 INT (Sea Org Executive Directive 2192 International) of 27 January 1983, "LIST OF DECLARED SUPPRESSIVE PERSONS" containing approximately 570 names, attached hereto as Exhibit 28. And FLAG ED 2830RB (Flag Executive Directive 2830RB) of 25 July 1992 containing approximately 415 groups and 2,230 individuals, attached hereto as Exhibit 29. Both my husband's and my name appear on these lists.

47. Arguing whether "Fair Game" is canceled or not is the wrong issue. Scientologists continuously deny that Hubbard meant what he wrote in his first policy on "Fair Game." Hubbard does the same in his March 1975 Affidavit, attached herein as Exhibit 18. If so, why do Scientologists continue to practice "Fair Game?"

48. The record clearly shows that "Fair Game" continues. It is replete with harassment after harassment of current day critics, per paragraphs 64 through 93. It, and the other Hubbard policies, are the criminal legacy Hubbard passed onto his blindly loyal followers.

49. Further, if Hubbard's "Fair Game" policy was really canceled and remains canceled in the present, why weren't all the other Hubbard "fair game type" policies stricken out of the record long ago? Why are they reprinted in the 1991 Policy and Bulletin manuals?

50. It must be noted that this Court is not immune to the "Fair Game" treatment meted out by Scientologists to courts in the recent past. Some of these abuses are documented in the 1980 article, "Scientology's War Against Judges" attached hereto as Exhibit 30, and the 1993 article, "Churches Litany of Lawsuits," attached hereto as Exhibit 31. CSI's personal attack on Judge Ritchie is attached hereto in Exhibit 20, page 16 footnote. Another example is that of Judge Ideman as outlined in his declaration of 17 June 1993, attached hereto as Exhibit 32.

51. All Hubbard's works, including "Fair Game," constitute CSI's sacred scripture, attached hereto as Exhibit 33, page 24, "Scriptures: In the Scientology religion, the scriptures are all the spoken and written words of L. Ron Hubbard. The scriptures include millions of written words contained in books, films, various forms of issues, and writings and several thousand tape recorded lectures."

52. This is the Hubbardian mindset which directed the criminal acts of the now-defunct GO, and which continues to direct the acts of all Hubbard's corporations today, both profit and non-profit.

53. I experienced this in 1968, when both the "Avon River," the ship I captained at the time, and the "Royal Scotman," Hubbard's Flag ship, were in Bizerte, Tunis, in North Africa. Two Sea Org Officers and I spoke on the dock one evening. They were both flying out the next day to Los Angeles, on a Hubbard assignment. They told me that Hubbard ordered them to shoot up Jack Horner, who lived in Los Angeles, a suppressive person whom Hubbard had personally declared some years earlier. Both men had hand guns and would travel with them. They left ... and then returned some weeks later. After their debrief they told me that Horner had indeed been shot at multiple times, while he and his family were in their home one evening. Fortunately, no one had been hurt.


54. Scientologists, knowing their vulnerability to a motion for costs, attorneys' fees and sanctions based on bad faith litigation tactics and use of litigation for improper purposes, are attempting to rewrite Hubbard's criminal policies. One documented example is Hubbard's 1955 Article, "The Dissemination of Material." It states, "The purpose of the suit is to harass and discourage rather than to win. The law can be used very easily to harass, and enough harassment on somebody ... will generally be sufficient to cause his professional decease. If possible, of course, ruin him utterly." It appears in the Technical Bulletin Volumes printed in 1976, attached hereto as Exhibit 10.

55. Despite policy which forbids Hubbard's writings being changed except by himself, the same article appeared without the quote in a 1986 Impact Magazine, after Hubbard's death, attached hereto as Exhibit 34. In the 1991 edition of the Technical Bulletin Volumes, the article also appears without the quote, attached hereto as Exhibit 35.

56. That Scientologists and the general public only see the watered down version since 1986, does not negate or minimize the validity of the original Hubbard order.

57. Nor does it prevent CSI from continuing to silence its critics by the misuse of the litigation process. OSA, a division of CSI, attached hereto as Exhibit 36, is the entity which took over from the infamous GO, as stated in an 18 May 1986 letter from OSA staff member, Lela, to Mike Meyers, attached herein as Exhibit 37. It states, "Dear Mike: Seven years ago you had some interest in USGO (the United States Guardian Office.) This group is now called Office of Special Affairs ..."

58. OSA is the entity responsible for carrying out "Fair Game" on critics and suppressive persons, and injuring, tricking, suing, lying or destroying them. It gathers overt and covert data on critics and enemies and runs overt/covert operations against them. It directs all litigation activities.

59. In his Memorandum of Points and Authorities filed on February 16, 1994, filed herein, Jonathon Lubell tries to portray the injustice of five CSI entertainers, Charles Durning, Kelly Preston, Maxine Nightingale, Juliette Lewis and Isaac Hayes, all non-parties to the litigation, being served with subpoenas, (J. Lubell Memorandum of Points and Authorities, page 1 & 30), that discovery has been extensive, abusive and is a harass-to-default strategy (J. Lubell Memorandum of Points, pages 4 & 5), that deposition questions were abusive, irrelevant and harassing (J. Lubell Memorandum of Points, page 10), and that the deponents have no relevance to the case (J. Lubell Memorandum of Points, page 14).

60. Kendrick Moxon, CSI attorney, in his Declaration of February 14, 1994 filed herein, accuses Geertz's counsel of improper and abusive discovery tactics and seeking to provoke disputes and incite hostility (K. Moxon declaration pages 2 & 18).

61. Miscavige, in his Declaration of February 17, 1994, filed herein, protests he is accused of evading service (D. Miscavige declaration page 2), that he never received a subpoena (see D. Miscavige declaration page 8), and, that by attending the Corydon vs. CSI deposition, he was rewarded by being served with subpoenas in disrelated matters (Miscavige declaration page 9).

62. The truth is these tactics are common litigation practice by CSI attorneys and related personnel. They are sourced in Hubbard's policies and bulletins, attached hereto as Exhibits 8 to 16, as they were in the heyday of the defunct GO. Their compliance in the present is unquestioningly demanded just as it was then.


63. My husband and I became well acquainted with "Fair Game" tactics over the past seven years. We work with families who have a loved one in CSI, and at their request, conduct voluntary interventions during which the loved one can obtain information to make a more informed choice about his affiliations. Because of this, Mr. Moxon and other CSI lawyers and hordes of their P.I.s and agents have repeatedly tried to prove; (1) we are kidnappers, (2) we are deprogrammers, and forcibly, physically and mentally assault and harm and injure Scientologists, (3) we are agents of cult awareness groups; (4) we kickback to such groups, (5) and much more. Despite all their posturing, neither CSI, RTC or any other Scientology organization has presented one bit of evidence to back their allegations. Why? Because we do not do the actions of which they accuse us.

64. In 1986, P.I. Al Bei of Ingram Detective Agency, called upon Jerry's elderly father in New Mexico, falsely representing himself as a Federal Investigator, saying that Jerry's father could answer questions about Jerry then and there or else be subpoenaed to answer the questions in a California court. Al Bei also divulged personal information about Jerry to his father which could only have come from Jerry's confidential priest-penitent CSI preclear folder. Attached hereto as Exhibit 38. Jerry's sister also wrote a report on the incident, attached hereto as Exhibit 39.

65. In 1989, a CSI front group in Glendale, SMS, found a bomb threat note in their men's washroom, attached hereto as Exhibit 40. My husband's name was one of ten top suspects. Don Yaeger, an Investigator for the Glendale Fire Department, and Dan Becker, a P.I. assisting Yaeger, were in possession of a sample of my husband's printing - the bomb threat was hand printed. It did not, though, match my husband's printing. We took the opportunity to educate both men on CSI's "Fair Game" tactics and harassment operations, such as the false bomb threat manufactured by Scientologists against New York freelance writer, Paulette Cooper, who was a very vocal Scientology critic in the 1970s and the years of unmitigated harassment they dealt her, attached here to as Exhibit 41, (transcript of Cooper's testimony in the 1984 Clearwater, Florida, hearings into CSI).

Over five years, CSI (at least) has compiled dossiers of spurious information on my husband and me. They are evolving documents, sometimes distributed as a dossier on each of us, sometimes as one on both of us. The latest edition is attached herein as Exhibit 42.

Since 1991, innumerable copies have been handed in person or mailed to our friends, colleagues, associates, and even people we do not know in the USA, England and Australia.

In November 1993, my husband and I attended a Cult Awareness Conference in Minneapolis. I found dossiers about me in the ladies washroom. Dossiers about my husband were found in the men's washroom. Scientologists handed copies of the packs to conference attendees.

69. In 1991, someone impersonating my husband called American Express and obtained three months worth of our statements. In 1992 someone called inquiring into other credit cards. In 1993 the same occurred.

70. Repeated attempts were made for more than five years to obtain our phone account information, and failing that, to determine what calls we make to certain area codes at certain times. (Someone was trying to find out which phone numbers we called long distance, and therefore which families we were working with.)

71. Between 1991 and 1993, at least fifty of our family members, friends, acquaintances and associates, including people we did not know up to that point, were phoned or visited by CSI hired Private Investigator John J. Gaw, and at times other P.I.s, asking questions about us, our backgrounds, families, education, work and clients and making false and/or derogatory innuendos. The P.I.s used many "fronts," such as: (1) they needed a deprogrammer to get their Scientology child out of the group; (2) we owed an East Coast client a lot of money and refused to pay him or take his calls; did the person know whether we had other disgruntled clients? (3) they needed a deprogrammer and were the Whitfields any good; (4) and many more.

72. During 1991, in England, we worked with a family whose son was a Scientologist. Someone impersonating my husband's elderly father called an English friend begging and pleading for our phone number in England, saying it was a matter of great urgency. Our friend finally gave the number, thinking the caller was genuine. Within hours, our Bed & Breakfast was surrounded by at least five cars driven by Scientologists. We were under heavy P.I. surveillance from then on. The P.I.s photographed us from their cars as well as their second floor stake-out room in the Bed & Breakfast across the road. The P.I.s room contained expensive surveillance equipment aimed at our Bed & Breakfast twenty four hours a day. The surveillance continued around the clock for a week. Our landlady was followed when she went shopping. The head of OSA, a division of CSI, in England, Ms. Barbara Bradley, told the police that my husband and I had kidnapped and were holding two people against their will in our Bed & Breakfast. The police investigated. They found the report false.

73. In August 1991, my husband was subpoenaed in, Friend vs. Church of Scientology International. Even though my husband never met or spoke with Roxanne Friend and provided a declaration to that effect, he was the first person to be subpoenaed, attached hereto as Exhibit 43.

74. In late 1991, someone called a friend of ours in England, long distance. The person, identifying himself only as an interviewer from a New York TV station, said he was calling urgently for Hana Whitfield and needed to know my phone number and location in England. No one in a New York or other American TV station knew I was in England. (Someone was trying to locate us and find out which family we were working with.)

75. We receive many phone calls from families requesting information on Scientology and assistance. We learned rapidly to determine which calls were genuine and which were not.

76. We were under surveillance for months on and off. In 1993 I had three to five cars, as well as two people on motor bikes, monitoring me all at the same time. We were photographed and video taped innumerable times and also covertly tape recorded many times.

77. P.I. John Gaw filed a complaint with the Board of Behavioral Science Examiners in Sacramento, attached hereto as Exhibit 44, that we practice counseling or interventions without a license. We don't counsel, now have we ever called ourselves counselors. Nothing came of the report.

78. The Zoning Commission said our neighbors were complaining because there were too many people visiting our home. We have very few visitors, a friend now and then, and are on extremely good terms with our neighbors. So we knew the complaint was false.

79. Scientologists falsely defamed my husband as a child beater, a wife beater, a drug dealer, addict and thief. They falsely accused him of "stealing" Narconon, a CSI front group and drug treatment center, attached in Exhibit 42, page 1.

80. Scientologists accuse me of potential violence because I took Prozac. However, what it did was help resolve the chronic, debilitating depression and mental "fragmentation" brought on by Hubbard's dangerous auditing techniques and CSI's intense high demands, duress and manipulations.

81. We were repeatedly called kidnappers and deprogrammers and accused of "brutally ripping peoples' beliefs from their minds," in CSI publications and on TV and radio programs.

82. In 1992 we were sued for "false imprisonment," attached hereto as Exhibit 45, by Scientologist Casillas ("Casillas"), who ran surveillance on my husband and me for days. An LAPD Officer stopped Casillas for driving without a license plate and cuffed him while he checked Casillas and the car. Casillas was then released, attached hereto as Exhibit 46. The result? We were sued.

83. On March 14, 1993, the CSI law firm Bowles & Moxon, flew a young man, Curtis Harmon, from Seattle, Washington State, to Los Angeles to depose him. (Earlier, my husband, I and Mr. Harmon, arranged an intervention after which Curtis left CSI.) Eugene Ingram, a CSI P.I., told Curtis that unless Curtis agreed to be deposed, he would lose his relationship with his Scientology mother. So Curtis went through ten hours of video deposition in which he was asked the same questions repeatedly. Afterwards, he was given an affidavit, attached hereto as Exhibit 47, which drafted and typed for Curtis' signature. It contained statements contrary to those he said in the deposition, but, because he was exhausted and afraid of losing his mother, he signed. On the 23rd March, Curtis wrote a second affidavit in Seattle to correct the first, attached hereto as Exhibit 48, stating, "... I was asked the same question over and over in many different ways until I agreed to one small part of what they were talking about, but then it would be twisted to fit what they wanted to hear. Even when I would say I didn't really remember or didn't really know for sure, it would end up in the Affidavit anyway." (C. Harmon affidavit of March 23, 1993, page 1).

84. On April 13, 1993, my husband and I were served with two subpoenas each in the CSI vs. IRS case, and the Kevin Harness vs. Cult Awareness Network, et al.,In Re: CAN Coordinated Cases, attached herein as Exhibit 49. The two subpoenas were handed to each of us three times that day by three different people, once in Logan Airport, Boston, by an OSA staff member, Jane Parker, a second time by a man as we waited to board our plane, and the third time by Scientologist Andrew Bagley and another man after we arrived at LAX airport. My husband and I were non parties.

85. Sometime in May 1993, I was served with a subpoena in the (Scientologist) Philip Hart vs. Cult Awareness Network case. On May 4, 1992, our attorney filed a protective order, attached herein as Exhibit 50, Protective Order of 4 May 1992, pages 4 to 9.

86. Miscavige claims in his February 17, 1994 declaration that he was "rewarded (after deposition in Corydon vs. CSI) by having plaintiff's counsel serve me with various subpoenas in other disrelated matters." CSI did the same to my husband and me. In June 1993, we were deposed by CSI lawyer K. Moxon in a CSI vs. IRS case. We were non parties. The questions were irrelevant, harassing and went into irrelevant issues. Moxon then served us with subpoenas in another unrelated case.

87. On June 25, 1993, I was deposed in a second CSI vs. IRS case - I don't know title or number. I was a non party.

88. On June 30, 1993, my husband and I were deposed in the Harness vs. Cult Awareness Network combined case as non-parties. Neither my husband nor I know Mr. Harness.

89. During the latter half of 1993, I and my husband were served with subpoenas in the Emery Wilson Corporation DBA Sterling Management Systems vs. Cult Awareness Network Et Al as non-parties. Due to harassment my husband experienced in his deposition, our attorney filed a Protective Order for me, attached herein as Exhibit 51, because my husband was subjected to extensive harassment regarding not only our intervention activities but also our confidential financial affairs and associations, even though the court ordered all allegations about deprogramming and exit counseling to be stricken. None of the questioning was discoverable as a matter of right. It was clear we were being sought for an improper purpose.

90. In September 1993, I learned of further "Fair Game" and harassing tactics initiated by CSI and RTC against me because I am a Scientology critic. John Richardson ("Richardson") of Premiere Magazine, wrote that Marty Rathbun, RTC Inspector General for Ethics, and Heber Jentzsch, CSI President, claimed I was an accomplice in the tragic murder of my father 30 years ago, attached hereto as Exhibit 52 of September 1993, page 91. This is blatantly and completely false.

91. In early November 1993, my husband and I attended a Cult Awareness Convention in Minneapolis. Three Scientologists, Carly Swirtz, Jane Parker (OSA staff) and Jennie Walker, handed out earlier versions of the spurious dossier on my husband and me, attached hereto as Exhibit 42.

92. In 1993, groups of people, among them Scientologists, demonstrated outside our home in Silverlake, Los Angeles, waving placards stating "Hate Mongerers [sic] get out of Silverlake" and "Stop religious bigotry." They handed leaflets, attached hereto as Exhibit 53, to neighbors and passers by, which say, "WHICH HUSBAND AND WIFE TEAM BREAKS UP FAMILIES FOR $1,5000 A DAY?" and then give our names. They falsely state that we are violent kidnappers, our actions are terroristic, that I tried to kill my father with a gun then changed my name and fled South Africa.

93. These actions are the practices of "Fair Game." They show that Hubbard's "Fair Game" doctrine is alive despite supposed cancellations, and is practiced by CSI and RTC.

94. CSI lawyer, Jonathon Lubell, says in his February 16, 1994 Memorandum of Points and Authorities, attached herein, that CSI religious tenets and scriptures have been assailed (page 2), that certain religious writings called upper level materials are held to be strictly confidential as a matter of religious precept (page 12), that there is a precise path to spiritual freedom that one walks one step at a time (page 13), non-party entertainers who have not achieved this level will be at risk (page 14).

95. CSI lawyer, Tim Bowles, states in his February 16, 1994 declaration that the insertion of altered or recreated versions of CSI's upper level scriptures into the court record would violate the religion's deep belief that such are confidential (page 5).

96. Both the above statements are invalid and attempt to cloud the Courts perception of these upper level scriptures or materials. The upper levels start at Operating Thetan One, or OT 1, and advance up through OT 8. They are strictly confidential within CSI. A Scientologist can only get onto a higher OT level by satisfactorily completing the earlier one and paying for the next one.

97. OT 1, in summary, consists of walking around and observing one's surroundings in different ways so as to familiarize oneself, as a new "Clear," to one's environment.

98. OT 2, attached hereto in part as Exhibit 54, consists of running out or deleting past life "implants."

99. OT 3, attached hereto in part as Exhibit 55, of all the OT levels, attracts the most criticism. It consists of telepathically locating "body thetans," also called BTs, which are stuck to one's body. Each BT is then individually audited on techniques to erase the implants it forcibly received 75 million years ago from a despotic ruler named Xemu (sometimes spelt Xenu). Hubbard called OT 3 the "Wall of Fire, attached hereto as Exhibit 56, pg 2. The BT then leaves and goes on its way or reincarnates into its next life as a human being. The next BT is then located and audited until it leaves ... and so on. Each person has hundreds of thousands of BTs on his body and inside it. Ridding oneself of concentrated quantities of BTs is akin to performing a religious practice of exorcism on oneself.

100. OT 4 through OT 7 consist of exorcising more lawyers of BTs, though each new OT level utilizes different techniques.

98. Having seen CSI's OT levels printed in publications like the Los Angeles Times, the Washington Post and books, I can verify that they are Hubbard's exact upper level materials as written by him and which I audited from 1968 onward.

101. A significant reversal, a manipulation, occurs in Hubbard's cosmology between the state of Clear and the OT 3 level. As a Scientologist gets to Clear, he learns and believes that all his physical and psychosomatic ills will be eradicated forever. He learns from Hubbard's article, "The State of Clear," that, "A clear can be tested for any and all psychoses, neuroses, compulsions and repressions (all aberrations) and can be examined for any autogenetic (self-generated) diseases referred to as psychosomatic ills. These tests confirm the clear to be entirely without such ills or aberrations. Additional tests of his intelligence indicate it to be high above the current norm," attached hereto as Exhibit 57.

102. He learns from Hubbard's bulletin, "TECHNICAL BULLETIN OF 22 JULY 1956," attached hereto as Exhibit 58, that "We are now capable of solving cases to the extreme level of clear ... We have created the permanent stable clear."

103. He learns from Hubbard's 1958 "The Freedoms of Clear," attached hereto as Exhibit 59, that "In clearing people we achieve four freedoms, and I'll enumerate them for you ... The first one is illness ... Next we have freedom from pain ... The next ... is freedom from ignorance ... a thetan knows everything ... The last part of these freedoms is the most controversial of them all: death (emphasis added)."

104. He also learns from Hubbard's 2 April 1965 bulletin, "The Road to Clear," attached hereto as Exhibit 60, that, "I have just made a breakthrough in finding what a clear really is ... A clear has no vicious reactive mind and operates at total mental capacity like the first book said. In fact every early definition of CLEAR is found to be correct ... But at its end, MAGIC ... There's the state of clear we've sought for all these years. It fits all definitions ever given for clear."

105. He learns from Hubbard's bulletin of 23 August 1966, "CLEAR TEST," that the first Clear, John McMaster, achieved Clear, attached hereto as Exhibit 61, and that, "no doubt exists that he has erased his bank completely and its gone."

106. He learns from a "GO CLEAR" advertisement, attached hereto as Exhibit 62, that "A Clear is a being who can be at cause knowingly and at will over mental matter, energy, space and time as regards the First dynamic ... It is a stable state ... A Clear has over 135 I.Q., a vibrant personality, glowing health, good memory, amazing vitality, self-control, happiness and more." There are many more Hubbard claims about Clear.

107. However, despite the claims, all Dianetic and Scientology auditing results are temporary, though emotionally fulfilling while they last. Clear is not a permanent state.

108. Clears find, to their chagrin, that they hurt again with similar hurts, upsets and problems they had before and they hope that OT 3 will fix them. When they are told that they are at risk until they do OT 3, attached hereto as Exhibit 63, they don't realize that OT 3 is Hubbard's excuse for his false claims about Clear.

109. It is only after the Clear completes OT 1 and 2 and pays for OT 3 that he can learn what OT 3 is.

110. When he reaches OT 3, he finds, usually to his shock and incredulity, that all his physical and psychosomatic problems are caused by BTs and not by engrams in his reactive mind, that every negative thought, problem and upset he has find their origins in the minds of BTs, not in his mind.

111. This is Hubbard's most insidious bait and switch. All the way to Clear, the person believes the cause of his upsets and problems was his reactive mind and engrams, and that he will be Clear forever. On OT 3, he suddenly learns that he paid $6,000 and $7,000 to find out he is infested with hundreds of thousands of BTs who are the cause of all his ills, and that he must learn to be an exorcist and talk telepathically to demons in order to reach OT 8. Attached hereto as Exhibit 64.

112. Throughout Hubbard's 1950 book, DMSMH, and later writings, Hubbard repeats that dianetic techniques are not hypnotic. Yet his dianetic auditing procedure from DMSMH clearly shows the technique is hypnotic. Attached per Exhibit 65, pages 42 and 43, from the "HUBBARD DIANETICS SEMINAR" training pack "based on the works of L. Ron Hubbard."

113. Hubbard then wrote in his 1952 article, "Danger, Black Dianetics!" that, "Hypnotism is a rather old and untrustworthy method of influencing or enslaving others. However, hypnotism is very unreliable ... The mechanisms of hypnotism ... are circumscribed in Black Dianetics ... Processing ... can undo Black Dianetics unless, of course, the victim has been driven into suicide or past the point of no return - a feat which is not difficult, but a condition which is not desirable where the operator seeks real advantage ... Several people are dead because of Black Dianetics ... Thousands may die because of Black Dianetics ..." Attached hereto as Exhibit 66, pages 519 & 520.

112. Scientologists can't grasp these contradictions because their normal reality checks are 'disengaged.' This occurs in the constant application of repetitive and hypnotic techniques in Hubbard's auditing and business management techniques, and the resultant onset of trance states, the wide awake, intensely focused state in mental and physical creativity. Scientologists have to deny these contradictions in the face of incontrovertible evidence they are correct, because their existence revolves around the one person they trust completely, their authority figure, Hubbard.

114. The Scientology "Bridge" is also a massive form of financial fraud. Even though the 'services,' the auditing and training, have been promoted for years as being "100% standard tech," the same auditing action costs less at a subordinate organization and more at each successively higher level organization. The rationalization used for the price increase is that the higher level organization has better trained auditors, thus less flubs and faster delivery. Scientologists do not see the two sides of that coin .. and that it can't be both ways.

115. In my experience, which is not based on psychological expertise I claim but what I learned from mental health experts and from CSI, it is the bait and switch and the false claims about the techniques, including those on the OT levels, that cause so many upper level Scientologists physical and mental illness and even death.

116. That Hubbard ordered the OT materials to be kept strictly confidential under threat of immense punishment, becomes apparent when one reads them. The OT levels are confidential for the survival of Scientology, not for that of its parishioners. They are confidential because newer and less indoctrinated Scientologists would not believe them. If a Scientologist knew up front that on OT 3 he would, at great cost, enter a science fiction world and telepathically exorcise good and bad BTs for years, he might seek less costly and more conventional help elsewhere.

117. Scientologists argue that premature exposure to the OT level materials will cause anyone, including their parishioners, great physical harm and possibly death. What would really happen is that Scientologists would see Hubbard's doctrine for what it is - patently science fiction and not scientifically valid nor containing observable facts.

118. The OT materials have been in the public domain since the late 1970s. I have never heard or seen reports of large numbers of deaths occurring coincident with the general public reading these materials in publications.

119. Hubbard spoon fed Scientologists level by level. There are books and materials on past lives, on out of body and mystical experiences and more, available but these are "teasers" and "mysteries" to keep Scientologists moving along. The big mysteries are the state of Clear and the OT levels.

120. In his "Professional Auditor's Bulletin" Number 66 of 25 November 1955, attached hereto as Exhibit 67, page 2, Hubbard said, "The principle of Mystery is, of course, this: The only way anybody gets stuck to anything is by a mystery sandwich."

121. I also heard Hubbard say that, to keep a person on the Scientology path, feed him a mystery sandwich.

122. The Scientologists are entitled to any beliefs they wish. It is actually not their beliefs that is the issue. What is the issue is how they act.

123. It is CSI's practices, not their beliefs, that were the issue in the past and are still the issue now. For example, in this case it is CSI's practice of telling parishioners and staff members to end their lives, as in paragraph 257, so as to promote the greatest good for the greatest number of dynamics, telling parishioners to kill suppressive persons for the same reason according to "Fair Game," and orchestrating large financial frauds for the same reason and not religious beliefs that are the issue.

124. Hubbard's OT 3 materials are skimpy and bring up many questions. Some which I've tried to help OT 3 students resolve are: how do BTs stick to a person lifetime by lifetime if he has a different body each life? how can an electronic ribbon "catch" a body thetan? how are BTs packed into boxes and flown around in airplanes? how come BTs were implanted 75 million years ago on Hawaii and the Canary Islands when these islands did not exist at that time? I audited hundreds of Scientologists through such confusions to complete their indoctrination and accept the materials as valid.

125. I talked with many former Scientologists in the last eight years. The majority said they left CSI after getting onto OT 3 and reading the materials, or after getting onto higher OT levels and realizing they contained more BT exorcism techniques. I also talked with many former Scientologists who claim their physical and/or psychological problems started or worsened after getting onto OT 3.


126. Miscavige writes in his 17 February 1994 declaration (attached herein) that "[Vaughn] Young has taken a personal tragedy in my family's life, the suicide of my mother-in-law, and attempted to make this an issue in this lawsuit by twisting it to imply non-existent wrongdoing in my past."

127. This is the criminal mind talking. Hubbard's bulletin of 15 September 1981, "CRIMINAL MIND," attached hereto as Exhibit 68, states, "There is a datum of value in detecting overts and withholds in criminal individuals: THE CRIMINAL ACCUSES OTHERS OF THINGS WHICH HE HIMSELF IS DOING ... THE CRIMINAL ONLY SEES OTHERS AS HE HIMSELF IS."

128. My husband and I have also experienced similar abuses by Miscavige and CSI, including multiple accusations of murder and other crimes which are not based on facts and of which we are not guilty.

129. Miscavige took a thirty year old personal tragedy in my family's life and twisted it to imply non-existent and criminal wrong doing on my part, as follows:

130. In early 1992, Miscavige, as RTC Chairman of the Board announced to a group of 700 Sea Org members that I murdered my father. He said this at a full staff meeting of the CSI International Headquarters in Gilman Hot Springs, Southern California. Three former high level Scientologists who recently defected, witnessed this. All three defectors told me that Miscavige said I was caught with my hand in the cookie jar and was, at that time, in prison in South Africa serving time for the crime. This is a complete falsehood and fabrication. Not one part of Miscavige's statement is true, except that my father was tragically murdered in 1964 in East London, South Africa, thirty years ago. My older brother, after a life time of incest perpetrated by my father on the children, confessed to the crime and was tried, convicted, sentenced, and served time. I was in Johannesburg at the time of my father's death and had nothing to do with it. Miscavige knows that.

131. CSI agents and P.I.s, including my former husband, Guy Eltringham (a Scientologist living in Los Angeles), attempted to get the South African Police ("SAP") to re-open my father's murder investigation on the basis that I did it or was an accessory. My elderly and ailing invalid mother, and my brother and his family in Johannesburg, were terribly harassed, to the point of my mother shouting in fear at the 'investigators,' and my niece also screaming in fear at the strange men who came to her father's house late at night with invasive and harassing questions about her father's past. My husband and I had to retain a Johannesburg attorney to defend my family and myself from CSI's and RTC's horrendous "Fair Game" acts and spurious charges. Our Johannesburg lawyer concluded the Scientologists spent well over a year and a fortune on their investigation. However, the SAP recently said the matter is closed as there is no evidence of my complicity. I am awaiting formal notification to this end from them.

132. This has not stopped CSI from continuing with its "Fair Game" activities against us. Several days ago, Marcy McShane ("McShane"), the wife of OSA member Warren McShane, who worked for the GO, visited our home unannounced, asking to see Hana, myself. My husband answered the door. McShane proceeded to accuse us of deprogramming and hiding like criminals. She scolded my husband, saying that he had promised to stop giving radio interviews if, as McShane said, "We stopped the murder investigation on Hana in South Africa and stopped demonstrating outside your home." McShane was misinformed. My husband had never made such a promise to anyone at anytime, ever.

133. On 7 March 1994, an updated "dead agent" dossier reached my husband and me from CSI. It contains additional information about my brother's court case and trial, testimony of witnesses and includes an affidavit reportedly written by a family member which recounts explicit sexual acts ... the document is pornographic. Furthermore, it has nothing to do with me. Additional information is also included about my husband.

134. The CSI's actions stem from Hubbard's policies and procedures which order the death of suppressive persons, their unending harassment with "manufactured" evidence if needed, and more.

135. Due to the years of unmitigating and shocking "Fair Game" harassment by CSI and RTC of my husband, myself and my family, I experienced overwhelming shock, emotional and physical distress which has caused frequent illness and inability to function and work.

136. The following excerpt of Hubbard's taped lecture, "Clearing Methodology" of 13 May 1959, reprinted in 1993 by the Church of Scientology Flag Service Organization in Clearwater, attached hereto as Exhibit 69, page 2, applies. It states, "I won't call it privacy because that dignifies it. You have to be willing to invade privacy, very definitely ... when you realize that the highest point of aberration on the third dynamic was the first time you decided not to invade somebody's privacy ... you will see at once where this connects on 8-Cing somebody into a service zone."

137. It is shocking that Miscavige and Jentzsch, who are protesting the fruits of their own law suit, the particulars which have come to light during its proceedings and their court ordered depositions, would protest their innocence while being guilty of acts to blacken critics' names such as those of Dr. Uwe Geertz, Fishman, Vaughn and Stacy Young and my husband and me.


138. Raymond Mithoff ("Mithoff"), Senior Case Supervisor Int., writes in his February 16, 1994 declaration attached herein, "I can ... state that there is no special terminology in Scientology Church scripture for suicide. Suicide is regarded, in church scripture, as an aberration, and any person who has suicidal tendencies is a person who needs help." Mithoff doesn't specify what help is given to Scientologists with suicidal tendencies and who are PTS Type III. Due to my auditor training and experience, I was privy to information about suicides and PTS Type 3s, as was Mithoff, that most Scientologists aren't, so I understand his reluctance in elaborating on these points.

139. Hubbard redefined or repositioned mental health terms, including words like "suicide" in his own language and to his own ends. One example of the repositioning of "suicide" is contained in Hubbard's taped lecture of 3 January 1960 titled, "CREATE AND CONFRONT," attached hereto as Exhibit 70, pages 93 and 94. Hubbard said the Markab Confederation, a civilization that existed between 19,000 and 40,000 years ago, was so medically advanced that death was eliminated. People received body part replacements instead, ad infinitum. The one sure way to die was to do it oneself, massively, on a speedway or racetrack, which existed for that purpose. Hubbard said, "And so before I used the track for the purpose it was intended, which was knocking off a mock-up, why, I'd get in there and ...." Another example is 'PTS Type 3' or 'PTS Type III', in Hubbard bulletin of 24 November 1965, "Search and Discovery," attached hereto as Exhibit 71, pages 701, 703 & 704. Hubbard said, "Type III is beyond the facilities of organizations not equipped with hospitals as these are entirely psychotic ... Type 3 PTS is mostly in institutions or would be. In this case the apparent SP is spread all over the world ... for the person sometimes has ghosts about him or demons and they are just more apparent SPs but imaginary as beings as well. All institutional cases are PTSes. The whole of insanity is wrapped up on this one fact ..." Hubbard's remedy - a safe environment, quiet, rest, no treatment of a mental nature at all, intravenous feeding if required, soporifics (narcotics, sedatives or tranquilizers).

140. According to Hubbard, psychosis, insanity and PTS Type 3 are one and the same.

141. Based on my Scientology experience and what I have learnt from psychology experts, Hubbard's aim in auditing was to push the preclear into his past, make him believe what he found, then push him into his youth ... then his birth experience ... and then ... past lives ... all the while believing that what he sees in his mind is as real as what he sees with his eyes in the material world. In so doing, Hubbard successfully collapsed the factual boundaries between objective and subjective reality.

142. Scientologists will adamantly deny this and as adamantly declare that contacting and auditing their past lives and believing what they find, is voluntary. But Hubbard's books, tapes and all Scientology and Dianetic techniques and literature are replete with past lives and mystical experiences.

143. The OT levels are the ultimate past life. One audits not just one's own past lives but those of hundreds of thousands of BTs as well. One runs into mass kidnappings, betrayals, exploding volcanoes, decimation of civilizations, mass implanting of body thetans, evil rulers, electronic mountain traps, heroes, earlier universes, parallel universes, between lives implants, the beginning of the cosmos, and more.

144. Many Scientologists have difficulty determining whether their past lives are real or imaginary. Hubbard's 24 November 1965 bulletin, "Search and Discovery" attached hereto as Exhibit 71, states that the ghosts and demons seen by institutionalized persons are imaginary. But his OT 5 materials state that BTs (who Hubbard said are real) can take on the identity of a ghost or a demon. Attached hereto as Exhibit 72, Bulletin of 17 September 1978, NED for OT Series 6, page 3, "A BT or cluster can go into the valence of a person ... BTs and clusters thinking they are the person ... This is discussed under the heading of "Ghosts" ... Nearly everybody has a ghost if he looks ... " In answer, therefore, to how one will know whether past lives and BTs and clusters are real or not, Hubbard's sole answer is that one will know. As Hubbard is the absolute authority figure, Scientologists' answers are that they will know.

145. One question arises - what happens to people who live in a fantasy world which becomes more real to them than the physical or material universe? In which objective reality has become subjective reality, and vice versa? This could be said to happen to people in institutions. This is what happens with every practicing and dedicated Scientologist who starts into auditing and continues on with it.

146. A fundamental Hubbard doctrine is the "overt motivator sequence." It meant that I, and I alone, was responsible for my upsets and problems. It wasn't Hubbard, or the organization, or his techniques ... and never could be. A Scientologist's acceptance of this and other Hubbard's doctrines and policies, assisted the Scientologist in accepting the validity of his subjective reality almost over that of his objective reality.

147. An example of this occurred in the early 1980s at the HQ in Clearwater, Florida. A painter from New York was at the HQ getting auditing. While he was in session one day, his small child, under the supervision of a nanny, fell into the pool in the garden and drowned. The painter was told about the tragedy after his session. He was shattered. Instead of an investigation being held into how and why the young child fell into the pool and why it was left there long enough to drown, the only action that was taken with any of the people involved, was to put the father back into an auditing session immediately. He was then audited on what sins or transgressions he had done that caused his young child to drown.

148. Based on my Scientology experience and what I learned from mental health experts, most Scientologists undergo vast personality changes. They are completely unaware of it, and will deny it and argue with great conviction against it. But the longer and stronger their adherence, and the more they are steeped in Hubbard's teachings, the deeper and more lasting the changes. Their normal thought patterns, reality checks, logical thought processes, responses and family values they were raised with, are all modified by Hubbard's teachings. They eventually become Hubbard's alter-ego, to the point of chain smoking (Hubbard had bad teeth, nicotine stained dark brown), screaming at subordinates as a routine ... and manufacturing evidence against SPs, inducing parishioners into insanity, holding people against their will, denying people professional treatment, ordering parishioners to kill SPs and themselves, and orchestrating large financial frauds.

149. Considering the numbers of Scientologists who were ill despite repeated 'PTS handlings,' those on whom the techniques did not work, those who had interminable case problems and who required extra auditing or the best auditors, and the tens of thousands who never took their next step, Hubbard's grandiose claims about Scientology are patently false.

150. The techniques, particularly the OT levels, and the drastic personality changes, are dangerous and harmful to the Scientology majority who apply them over long periods of time. They induce mental illness of many kinds, such as dissociative states, hallucinations, paranoias, suicidal ideation, all of which are considered normal within CSI ... and death. I have seen many Scientologists suffer, and live in pain, because of Hubbard's beliefs, but now their own, that auditing would 'handle' their physical or emotional or mental condition.

151. In forty four years, Scientology has produced only 50,000 Clears and 1,200 OT 8s, attached hereto as Exhibit 73. Yet CSI claims an active international membership of six to thirteen million. What happened to the rest?

152. CSI auditors are unlicensed practitioners who have no professional or academic credentials about the human mind.

153. The wanton waste of human life in CSI is horrifying.


154. I had a devastating experience in CSI. I did well at first. But had great difficulty accepting the "BT" story on OT 3 and applying the techniques. I began "hearing voices" soon afterward, at first faintly and then increasingly.

155. From 1974 onward, I suffered from intense, continuous migraines - ironically brought on in auditing which was designed to remedy forever the occurrence of headaches. I ended up in pain twenty four hours a day, seven days a week, four weeks a month and twelve months a year thereafter.

156. Periodically the "voices" got worse. I felt split into hundreds of "me's", each arguing with the other. I got physically and emotionally very debilitated. Because of Hubbard's doctrine, I felt I must have done something terrible in a past life to be in so much pain in the present. At times I thought I was going crazy.

157. But according to Hubbard's doctrine of the "overt motivator sequence," I, and I alone, was responsible for my pain. I was responsible for everything that happened to me. A burning question was ... if the doctrine was correct and applied to every Scientologist, how come the same doctrine didn't apply to Hubbard and Scientology? Because Hubbard and Scientology were experiencing increasing quantities of problems internationally, year by year?

158. In my auditing sessions over the next seven years, I almost went crazy trying to find the cause of the pain - to no avail. Until early 1976, I received thousands of hours of daily auditing, with Hubbard as my case supervisor - to no effect.

159. I was often unable to work for two to three days each week due to the pain. I could not lie down because the pressure of the pillow or mattress on my head made the pain unbearable. It was all known to my auditors, case supervisors and Hubbard.

160. I finally realized that my only solution to stopping the pain was to end my life. I mentioned this in my auditing sessions repeatedly. In late 1977 in Clearwater, Florida, I was sent to a doctor for physical tests - with no result. This depressed me more. I searched for help in Hubbard's writings; I asked a few Class 12 auditors for any Hubbard bulletins, books or tape references that would help me. Paulette Cohen referred me to Hubbard's Expanded Dianetic taped lectures. I listened to all of them. The material referred to evil purposes, evil intentions and other things. But it didn't address my problems. I ended up more confused. I continued getting regular sessions though Hubbard no longer did the case supervision. Sometimes my sessions went badly for weeks. A big square piece of red paper, a "red tag," was frequently pinned to the front cover of my pc folder. It denotes a failed session in which the preclear did not improve. Every time I saw the "red tag." I felt more guilty that I wasn't respond to Hubbard's techniques. This redoubled my efforts to find what was wrong. I was reduced to terrible, continual fear for my life and sanity.

161. I was also fearful that by REMAINING at the CSI HQ in Clearwater, my presence would harm Hubbard, his family and his goals. The only solution I could see was to leave, or die. I came very close to committing suicide several times. What held me back was the hope, always the hope, that the next session would bring relief. Sometimes I took up to 15 aspirin a day to alleviate the pain - it never did. I always told my auditors what I was thinking about, including how many times I nearly jumped from the top floor of the Clearwater building but refrained because it cause disrepute to Hubbard and CSI, how many times I almost broke into the Medical Officer's room to find relief for the pain, how I planned to run away and burn my ID (to prevent ill repute to Hubbard and Scientology) and kill myself. The only things that prevented me from leaving Scientology earlier or killing myself, were my dedication to Hubbard and complete belief in him and my adamant unwillingness to bring ill repute to his name and his organization. This continued until I left the Clearwater HQ in March 1982 of my own accord.

162. I was never given licensed medical or mental health assistance, only that provided by Hubbard's Scientology techniques which was inadequate for the task.


163. During my twenty years in Scientology, I delivered thousands of hours of auditing to others, among them preclears with similar experience to mine and worse, and some who committed suicide.

164. In mid-1985 a high level Scientologist, Mary Florence Barnett, called Flo, phoned me. She was Miscavige's mother-in-law. I had left CSI the previous year. Flo cried on and off during the call. She complained of severe, constant pain in her head which nothing helped. According to her doctor, a recent head operation to repair an aneurysm wasn't the cause, but he did not know what the cause was. Flo was very scared of the pain, and kept saying she wanted to kill herself to stop the suppressive BTs from taking over her mind. Both the Advanced Organization in Los Angeles ("AOLA") and the Clearwater HQ refused to audit her because she had no money to pay. Flo had been to the Advanced Ability Center ("AAC") once, a break-away former CSI group in Santa Barbara, and had good auditing there, but had no money to return.

165. Flo was very depressed after her daughter Shelley, Miscavige's wife, came to visit and ended up screaming at Flo. Flo said, in several of our phone talks, that neither Shelley or Miscavige cared a damn about her, and she was horrified into what monsters Scientology had turned her children. However, she promised to call Shelley again and ask for help.

166. I was deeply concerned about Flo's condition, but felt incapable of helping her as I doubted the effectiveness of auditing. I spoke with Camille, another daughter living with Flo, who said her mother refused to see the doctor because he hadn't helped her and said her condition wasn't serious. Camille said her sister Shelley and brother-in-law Miscavige knew about their mother's condition but refused to see her or have anything to do with her because, they said, Flo was making herself ill, refusing to see the doctor, and was "down stat.

167. Over the next few weeks Flo called me and I called her many times. We spoke frequently, sometimes for hours. On occasion Flo begged me to get rid of the suppressive BTs that were killing her; at others she refused auditing because, as she said, "That's what messed me up in the first place." I spent a lot of time listening to her and letting her talk - she had a lot of fears and hurts. She cried a lot on the phone. She was in constant pain, unable to eat or sleep, and wanted to die or kill herself. She was very scared of the "things" she was seeing and hearing. She often talked about the suppressive BTs, that they were torturing her and making her go crazy, that they were implanting bad things into her and that she had to make them stop or go away. She said she'd heard and seen the "things" for years, but "they" were strengthening their hold on her. Several times, Flo openly blamed CSI for her condition and spoke bitterly about how CSI messed her up in auditing, that Scientologists were callous and, now that she was out of money having given it all to CSI, no one cared about her enough to help, not even Shelley and Miscavige.

168. Camille verified that Flo had no money left and that was why CSI would not help her.

169. Two days after our last talk, Camille called and said Flo had shot herself. I was devastated.

170. Two days later, Camille called again. We talked about Flo. She said whereas she was grieving over Flo's death but relieved her pain was over, Shelley's response was cold and indifferent, and relieved the embarrassment was finally over. Camille asked Jerry and me to attend Flo's funeral which would be small and limited to family and close friends.

171. But the next day, Camille called again and asked us not to attend. She hoped we weren't hurt by her request, but Miscavige, Shelley and other CSI top executives had decided to be there after all because they felt it was a duty and "to put on a show." Therefore our presence, as former Scientologists, wasn't wanted and would cause tension. I was very cross and upset, because Flo's Scientology relatives had done absolutely nothing to help her, but were going to put on a show for her funeral. But I agreed, and we sent a large wreath and a card instead -- for Flo's sake. Later, Camille thanked us for understanding. That was the last I heard from Camille.

172. In his February 17, 1991 declaration, Miscavige wrote on page 1, attached herein, "My only association with this tragedy was to console my wife who was understandably emotionally traumatized and grief stricken." Camille gave me the completely contrary impression - that Miscavige's wife, Shelley, was uninterested in anything to do with Flo and greatly relieved that her embarrassing mother was finally out of the picture.

173. It is improbable that Flo, in her debilitated physical and psychological condition, shot herself three times in her chest and once through her head with a rifle, leaving no powder burns or marks, according to the Forensic, case, investigator and coroner reports, attached hereto as Exhibit 74. Yet, by all reports, this is what she did.

174. Facts that lead me to strongly doubt Flo died like that are the following: (1) she received three rifle shots through her chest and one rifle shot through her temple; (2) there were no powder burns or marks at the gun shot sites; (3) her debilitated physical and psychological condition didn't permit her to hold the rifle far enough away to shoot herself four shots without leaving marks.

175. According to both Flo and Camille, Flo was an embarrassment to Miscavige and Shelley, as; (1) Shelley visited Flo only once during her lengthy illness, Miscavige never did; (2) Shelley ended her visit to Flo by screaming at her; (3) they never took any action to assist Flo; (4) they considered Flo PTS due to her connection to former high ranking CSI officials, David and Julie Mayo, whom CSI declared Suppressive Persons, and her antagonism toward CSI; (5) they considered Flo a "squirrel" for receiving auditing from David and Julie Mayo.

176. However, Miscavige was also PTS because he was, " ... connected to a person ... opposed to Scientology ..." and was, " ... intimately connected with persons (such as marital or familial ties) of known antagonism to mental or spiritual treatment or Scientology." This per Hubbard's policy of 31 December 1978, "EDUCATING THE PTS," attached hereto as Exhibit 75, pages 425 & 426.

177. Therefore Miscavige could not remain Chairman of the Board, ASI, or hold any top command position according to Hubbard's 12 May 1972 policy, "PTS PERSONNEL AND FINANCE" attached hereto as Exhibit 76, because "IT IS UNSHAKABLE POLICY HEREAFTER THAT NO PERSON WHO IS PTS OR CHRONICALLY ILL ... MAY BE ON FINANCE ... LINES OR IN TOP COMMAND POSTS ..." (emphasis in the original). The only actions Miscavige could take were to get Flo back into CSI or disconnect from her completely.

178. I have seen two letters from Flo Barnett dated 28 September 1984, one addressed to David Mayo, attached hereto as, another to Julie Mayo, attached hereto as, who owned the Santa Barbara AAC, and a third note dated 7 May 1985 to Julie Mayo, all attached hereto as Exhibit 77. Knowing Flo's handwriting, I can verify that these three notes were written by Flo Barnett.

179. Quentin Hubbard, the oldest son of Hubbard and his third wife, Mary Sue, also committed suicide.

180. Hubbard wanted Quentin, a Class XII auditor and one of the highest trained, to take over his technical position when Hubbard died. Quentin didn't want to. His only wish was to become a pilot and fly. During the 1970s while we were aboard, I often saw him walking along the decks or passageways mimicking an airplane, with one or both arms outstretched, weaving from side to side as he walked and making engine sounds in his throat. He was never self conscious, but just smiled or laughed as he passed by and carried right on 'being' a plane.

181. Quentin went AWOL from the ship twice in 1975 while we were on board the "Apollo" in the Caribbean. Both times, teams of crew were sent ashore to look for him.

182. At one of those times, I was standing on B Deck Aft with Hubbard, his wife Mary Sue, some Aides and the Ship's Captain, about fifteen of us, waiting for Quentin's return. It was night time, and cold. Hubbard was mad at Quentin. He muttered under his breath on and off how much trouble Quentin was causing and the time he was wasting. Several times Hubbard ordered specific penalties to be assigned to Quentin after his return. Mary Sue was distraught and worried sick about her son. When Quentin finally returned, he was quiet and looked exhausted. Late that night, I heard Hubbard shouting in his B Deck cabin.

183. In 1976, after we moved to the Scientology HQ in Clearwater, Florida, I rarely saw Quentin as I was a senior executive and he was an auditor.

184. In late October or early November, 1976 in Clearwater, a GO staff member briefed us that on 28 October that year, Quentin was found unconscious in his car outside Las Vegas and was hospitalized. About two weeks later we learned he was dead. A few days after that, we heard that Mary Sue ordered three autopsies done, and the third located the cause of Quentin's death; he was suffering from a rare disease. We weren't told its name. I and others I knew, questioned why we were not given more information about how Quentin was found, hospitalized and how he died.

185. Many years later, I saw the Coroner's report and the Report of Investigation, both attached hereto as Exhibit 78, and I read that Quentin had a possible cerebral abscess when he died, but no trace of carbon monoxide toxicity. Attached as Exhibit 79, are the November 23, 1976, St. Petersburg Times and Tampa Tribune, and the November 25, 1976 St. Petersburg times news releases of Quentin's death.

186. Another crew member who committed suicide was Susan Meister. I was on board the "Apollo" in mid-1971 when she allegedly shot herself. The ship was in Moroccan waters. Hubbard was aboard.

187. Susan was on board about six months. She was "PTS" - her family was upset because the ship's location was confidential and they did not know where she was.

188. In mid 1971, in my office on A Deck, I heard a strange, sharp sound. It was traced to the aft bridge cabins where the senior Ship's Officers berthed, and specifically to that of Chief Officer Amos Jessup. Susan was found, shot, lying on the bunk in Amos' cabin. I helped Mary Sue Hubbard, who was in charge of the GO, to investigate the death. Mary Sue checked the aft bridge cabin where Susan died. I checked Susan's bunk below decks and her possessions, but found nothing amiss. Mary Sue had already removed Susan's letters, note books and other personal effects. I arranged for someone to send Susan's clothes to her family. We interviewed Amos Jessup, who was visibly upset and shaking on and off. He blamed himself, as Susan wanted a committed relationship and he didn't. Susan was in the cabin alone after he went to work. He didn't see her alive again. He had no idea she was suicidal.

189. We interviewed a deck hand who was working on A deck port side, aft of the bridge cabin, when the shot occurred. He reported the sound and located Amos. We interviewed Susan's superior, the ship's medical officer and several other people. They all said Susan was emotionally unstable. Mary Sue wrote a report for the Moroccan police.

190. Scott Leland, a good friend of mine, also committed suicide. I met Scott in 1965 in England. We went through several courses together including the Class Seven Auditor Training Course and the Clearing Course.

191. Afterward, Scott moved to Denmark, married and raised a family. He went through all the OT levels up to OT 6.

192. I did not meet him again until 1986, when out of the blue, he stopped to see my husband and me enroute to the Santa Barbara AAC for auditing. He did not look well. He cried several times over the next few days, telling me he'd been crazy for fifteen years and that the trouble started after he went Clear. When he started auditing on OT 3, he began hearing and seeing things and this gradually worsened to where he thought he was going nuts. He pleaded for help, saying he had no money for auditing at the AAC. I was very concerned and scared over Scott's condition.

193. The AAC said Scott could return at no charge, or if he wished, he could go to someone else and the AAC would provide case supervised instructions free of charge. Scott never acted on the offers.

194. Scott stayed with my husband and me for two weeks -- we fed and housed him. Scott mainly slept, ate, took long walks and read books. He looked and sounded much better when he left. He went to the US East Coast to see his mother before returning to his family, his wife and two young sons, in Denmark. I didn't hear from him again.

195. In 1987 I heard Scott hanged himself in his mother's house on the East Coast.

196. Another suicide occurred during the late 1970s while I was in Clearwater. A well known Scientologist at the Clearwater HQ was auditing her BTs and clusters. She drowned herself in the ocean off Clearwater Beach one night. Her death was declared a suicide. Reportedly no one knew she was suicidal. I don't remember her name. Her suicide was very hushed up by Scientology top command in Clearwater.

197. Other suicides which I know of are the following:

(a) Larrayne Johnston: She committed suicide in the mid to late 1980s by throwing herself off a bridge into freeway traffic in Los Angeles. She did this because Scientology would not help her after it alienated her from her husband and family.

(b) Rodney G. Rimando: He was a Scientologist from San Jose, California. He joined the Sea Org in Los Angeles in January 1986. He committed suicide by "falling" out of a window. Police were given a note by Church of Scientology officials which proved to be forged.


198. Roxanne Friend, a Scientologist, contracted cancer in the late 1980s. She was getting auditing for her condition at the Clearwater HQ, but was not doing well and repeatedly requested approval to see a doctor. Her requests were not granted. She was told continue on with her auditing. Finally, Roxanne left without approval and went back home to San Diego for medical treatment for her condition. In the early 1990s, her brother, according to his deposition in which he reports the following, and also a Scientologist got an RV, and with some of his friends, captured Roxanne, drugged her and drove her back to Florida, with Roxanne druggily protesting on and off all the way. The Scientologists/Sea Org members in Clearwater held Roxanne captive in their Clearwater complex for several months, against her will. She was finally able to get away and back to San Diego. Roxanne's illness has advanced since then. She still lives in San Diego and still wants to take action against CSI, and, if her current strength continues, feels she may be able to do something in that direction.


199. Some attempted suicides that I know of:

(a) Jim Hester was a preclear at the Miami Org in the mid to late 1970s. He attempted suicide in Miami and was then hospitalized in critical condition. He left a suicide note blaming Scientology, attached hereto in Exhibit 80, a copy of a GO report.

(b) Leah Theriery. She attempted suicide sometime in May 1974, attached hereto in Exhibit 81, a copy of a GO report.

(c) A friend of Gerald Simon's who was a Scientologist, attempted suicide by drinking a full can of RAID insect killer because he had been ordered to disconnect from his girlfriend.

200. I saw many Scientologists and Sea Org members go crazy and/or suicidal, like myself, while getting auditing.

201. During the early 1970s on board the "Apollo," I was Commodore's Staff Aide One, a position with international responsibility. Hubbard was my direct superior. A visiting Scientologist, auditing on the OT 3 level, went crazy, shouting, screaming, moaning incessantly and throwing himself around. I saw Hubbard give orders as to his care; he was to be confined in an aft cabin where his screams would not disturb top or middle management working in the fore and mid sections of the Apollo; three strong men were to guard him twenty-four hours a day, in eight hour shifts, until he was sane; he was to get three meals daily whether he ate them or not; his captors were to maintain complete silence around him at all times whether he spoke or not; Hubbard was the only person who could communicate with the man and he did so by writing notes; the captors were to have sufficient "cal-mag" (a Calcium magnesium drink of Hubbard's own recipe and reportedly conducive to relaxation and sleep) on hand for the man to drink if he wanted it.

202. Hubbard personally supervised the man's "case handling" during his imprisonment. He wrote the man daily. Responses, when they started, were brought directly to Hubbard. The man was given some medication, prescribed by Hubbard, but I don't know what. The man almost got away from the guard once and was forced back into the cabin and tied to his bunk. He was held captive for over two weeks. He gradually calmed down, was released into the shipboard community, got some auditing and finally returned to the USA.

203. At no time was he seen or treated by a qualified medical doctor. Hubbard's directives on handling the man were later used as a guide for similar cases.

204. During the early 1970s, Bruce Welsch, a crew member on board the "Apollo" went crazy, or Type 3 PTS. He was locked up in a port aft cabin by Stuart Moreau and Ron Anderson, two ship crew members. I was in the aft area a few days later on some work assignment and I could hear Bruce making almost animal type sounds. They were terrible, inhuman sounds. And I could hear what I thought could be chains rattling. I was not around when Bruce recovered. Attached hereto as Exhibit 82, page 2.

205. In 1980 I was auditing at the Clearwater Organization HQ in Florida. A young woman, who was receiving Life Repair auditing from another auditor, began hearing "voices" talking to her.

206. She was reassigned to continue her auditing with me. The voices really scared her; she couldn't think of anything but the terrible things they said to her and told her to do.

207. From then on, the hundreds of hours of auditing I gave her were directed, by the Case Supervisor and the Senior Case Supervisor, at resolving the "voices." To no avail. She was transferred to yet another auditor, and then finally went home. I never knew what happened to her.

208. In 1966, I audited a nine year old girl at Saint Hill Manor, England, simple locational processes. During the session, she became violent, screaming and shrieking abusively as she kicked and bit my hands and arms. She flung herself against the furniture and onto the floor, spat at me and gagged a few times with her eyes rolling. I tried to hold her, gently yet firmly, so she didn't hurt herself, but she kicked and bit me and screamed all the more. I was scared. I continued the session as long as I could, because Hubbard's doctrine ordered, "What turns it on will turn it off." As soon as the girl was quieter, I ended the session and got John McMaster, the Qualifications Secretary, to advise how to continue.

209. The family returned to Scotland though - young girl got no further auditing. John told me that her parents were happy with her auditing results. I never knew how she was thereafter.

210. In 1969 or 1970, while I was Deputy Commodore for the United States and stationed in Los Angeles, a young man in his mid to late twenties, was auditing on OT 3 at AOLA. He went "crazy" in session one day. He was incoherent, screaming and hallucinating, seeing "things" on the wall and on himself. At times he was violent and kicked the walls and threw himself around.

211. The AOLA staff locked him up in a 2nd floor auditing room at the back of their building. Sheets, mattress and a pillow were put in the room. Everything else was removed so that he could not harm himself.

212. He never received medical help. We did not know or trust any medical doctors enough to let one in on the flap. The man was fed and held captive in the room under twenty four hour guard. I don't remember how his bathroom trips were arranged.

213. I saw him three weeks after he was "sane". He apologized over and over for the trouble.

214. I reassured him as best I could. I was incredibly relieved he was all right. He left shortly thereafter and returned to his home elsewhere in California. I never saw him or heard of him again.

215. I also had contact with many former Scientologists who were suicidal. Larry lived with his wife in Washington State. They were long term Scientologists. In 1986 or 1987, he arrived unannounced at our home in Los Angeles. In rambling, disconnected sentences, he told my husband and me that he left Seattle in order to kill himself, he had thought about it for a long time, his wife did not know where he was and he did not want her to know. He said his business and marriage failed, his Scientology gains had disappeared, the more auditing he received, the worse he got, and it was all his fault. He was confused and scared. He said that when he reached Los Angeles he remembered where we lived and came for help. My husband and I were both shocked at his condition and very concerned for his safety. Larry stayed with us for several weeks in our home. We fed and clothed him.

216. He spent the first two weeks sleeping and eating. He read and watched TV a lot. We talked often. He got better. We encouraged him to see a licensed counselor or therapist for help, but he refused.

217. After three weeks, I got Larry to call his wife to let her know where he was, that he was safe and would be home soon. They spoke a long time. From then on, they talked regularly by phone. He and his wife now live in another state and are happy and doing well.

218. Larry was fortunate. I wish there were more who recovered like he did.

219. David Voorhees lives in Washington State. In 1982 or 1983, he had a similar experience in Los Angeles. He was auditing on the OT levels and experiencing great difficulty. He could not apply the materials to himself yet knew that he had to. He went crazy trying to audit the BTs and clusters. He was held captive in a room somewhere in Los Angeles for weeks and injected with Thorazine injections by his captors to calm him. In his more lucid moments, David was told by his captors that he was getting Vitamin B injections. Attached hereto as Exhibit 83. Another suicidal person was former Sea Org member, Ethel Budd Miller. Sometime in the mid to late 1970s, she wrote an SO1 letter which could have been a veiled suicide threat, attached hereto as Exhibit 84, a copy of a GO report.

220. Even today, Scientologists are still going crazy while applying Hubbard's auditing techniques. A recent expose from an English newspaper reveals shocking instances of Scientologists going crazy and being imprisoned at or near the Saint Hill Manor CSI headquarters in East Sussex, attached hereto as Exhibit 85.


221. Lori Wood, the daughter of long term Scientologists, Peter and Doran Greene, was also a Scientologist and Sea Org member. She served with me aboard the "Avon River" in the Mediterranean when I captained the ship. Lori was at the Scientology/Sea Org Clearwater HQ in 1978 or 1979, while I was there. She was receiving auditing on OT 5 (which exorcised more BTs and clusters), or "NOTS" as it was then called. She got quite ill at one point during her auditing and was sent to the Ethics Officer. For some reason that I do not know, the ethics matter, if it fact there was anything incorrect she was involved in regarding ethics matters, escalated and kept on escalating. I asked at one point what was going on but could not get an answer. A short while later, without recovering from the illness, Lori died. What upset me so terribly about her death was that: (a) she was a good Scientologist; (b) she was in the middle of an auditing program; (c) she was being harassed by the Ethics Officer, Rae Matheson ("Matheson"), while she was ill, which is unpardonable, and while she was getting physically worse. Her mother told me that when she, Doran Greene, challenged Matheson as to why he ordered the attack on Lori when she was in the middle of an auditing program as well as being ill, Matheson shrugged and huffed and said, "Where is that in writing?" Matheson's statement, though referring to a basic law of Hubbard's, "If it isn't in writing, it isn't true," never-the-less showed a characteristic Scientology attitude toward anyone who was in trouble or ill, who was making mistakes, or not making the expected progress in his auditing or training - it was the person's fault, it was always the person's fault, never that of Hubbard, his policy, his techniques or his organization ... never. The policy referred to is titled, "ORDER BOARD AND TIME MACHINE," attached hereto as Exhibit 86, which states, "In Scientology if it is not written it is not true. That's a major policy. It applies to all. Every order an Executive issues must be in writing."


222. I have known many Scientologists and Sea Org members who died from cancer. The common denominator among them is that they did not seek medical assistance rapidly, when they first noticed something wrong. The overwhelming belief among Scientologists and Sea Org members was to get audited or continue on with auditing (if they were already receiving auditing) with the conviction that auditing would resolve the cancer.

223. In Hubbard's 1975 edition of his book, History of Man, Hubbard wrote on page 20, "Cancer has been eradicated by auditing out conception and mitosis." Attached hereto as Exhibit 87. This, and similar claims for other illness in Hubbard's DMSMH, may have helped to bring about the disregard for the medical doctor. In the recent edition of the same Hubbard book, History of Man, which, ironically occurred after Hubbard's death, a rewrite of the statement above occurs, saying, "Cancer has reportedly (emphasis added) been eradicated by auditing out conception and mitosis." There is no accompanying statement in the recent edition of the book saying that Hubbard authorized the change prior to his death, which he would have had to do for the change to be valid.

224. A friend of mine, Yvonne Gillham Jentzsch, died of a brain tumor. In early August 1967 I joined Hubbard's Sea Project in Las Palmas, Canary Islands. Yvonne was already on the ship and we got to know each other well.

225. In 1969 and 1970, while I was stationed in Los Angeles as Deputy Commodore U.S., Yvonne was the Commanding Officer of the first Los Angeles Celebrity Center. We met frequently in a work capacity as well as socially.

226. During the early to mid-1970s, I flew to Los Angeles on assignment several times and met Yvonne.

227. During 1977 we exchanged letters. Her's were shorter than usual, just brief notes. I noticed the change as Yvonne was known for her lengthy letters. She said she was tired, losing weight and getting headaches, all unusual for her. I didn't think much about the last; I also had constant headaches.

228. In late 1977, Yvonne suddenly arrived in Clearwater, very ill. She talked with difficulty, lost track of what she said half way through a sentence and lost her balance while walking. Yvonne told me she had a brain tumor and that she was dying. She said she hadn't seen a doctor because she thought auditing would fix it. The illness started with an "out of balance" feeling which she assigned to lack of sleep. The doctor told Yvonne the tumor was removable if she had seen him earlier. We both cried. I knew auditing did not resolve everything, but I was shocked that her life was wasted through such neglect.

229. She said that Hubbard ordered her to Florida for auditing to ease the transition, meaning death, as well as to do an end of cycle on her "hats" so that someone else could take over her Celebrity Centers after she "dropped her body". One day she cried and blamed herself for the terrible overt of dying and deserting Hubbard. She was in continual pain but wouldn't take pain killers so that she could get auditing. On a later occasion, Yvonne was quite philosophical about her forthcoming death and said she was phasing out of her life and no one should grieve. I knew at that point that Yvonne had had auditing on her nearing death and that, in Scientologese, she had discharged any fear or trauma connected to it. Now I see that what occurred, as with all other auditing, was that Yvonne's reactions to death were temporarily desensitized.

230. Over the next few weeks Yvonne's condition deteriorated rapidly. One day when we were outside, she spoke with increasing difficulty and went unconscious several times for short periods. It took us a long time to get up the stairs from the garden to the building Lobby, even with my help, because she could not coordinate her leg movements. She never received medical treatment of any kind that I know of.

231. Yvonne died in early 1978. No one I know of, except her family, was informed about her death for days or about funeral service. Nor were her close friends, such as I, given an opportunity to do a proper closure with Yvonne. We had a short briefing in which we were told that Yvonne had dropped her body happily and was in good case shape to pick up the next one, and that as this was a happy occasion, there was to be no time wasted in unnecessary grieving. Those most affected were only given auditing sessions.

232. Hubbard, in a published memo after her death, applauded Yvonne's achievements and granted her a leave of absence for twenty one years until she rejoined the Sea Organization in her next reincarnation.

233. Another Sea Org member who died of cancer was Carol. She developed breast cancer after joining the Sea Org. She told me that she did not report it because she believed that auditing would cure it. She also did not want to bother anyone.

234. Carol never received medical treatment for the cancer. She never got regular PAP smears and mammograms.

235. In the late 1970s, after the cancer became terminal, Carol was hospitalized. Because I had an RN degree, Cathy Heard, a GO staff member, assigned me to take Carol home to her parents in England to die there. Cathy said she could not die in Clearwater as it would be bad PR for Scientology and the Sea Org.

222. Carol looked terrible when I saw her. She had lost fifty pounds, was very weak and her mind was wandering. She pleaded to stay in Clearwater because she did not want to go back to her family. I told Cathy but the request was ignored.

236. The hospital nurses said Carol could not travel in her condition, particularly as she did not want to. Her x-rays showed the cancer spread throughout her body into all major organs. Cathy instructed me to give the nurses a "shore story" saying Carol's parents wanted her to visit them for years, that Carol had disobeyed them for years, that they were now demanding her return, and we had found out and were desperately trying to intercede before it was too late. After hearing the story, the nurses became very helpful.

237. Her parents were very happy to see Carol though shocked at her condition. The family doctor was so disgusted after I gave him the medical reports the next day, and that Carol traveled while critically ill, that he refused to talk to me thereafter. The parents were very grateful that I had helped Carol get home. I stayed in England with the family for a week. Carol slept most of the time - she was too weak to get out of bed.

238. I then flew back to Clearwater and debriefed. I was deeply disturbed by the experience. Ironically, I was assigned a condition of "power" by Cathy and Liz for successfully handling a potentially dangerous and sensitive situation. Carol's death was not known about in Clearwater. For years afterward, I wondered if there was more to Carol's death than I knew. Because death is natural. It shouldn't be a "dangerous" or "sensitive" situation.

239. Sally Esterman (formerly Chaleff) was another Sea Org member who died of cancer in January 1987. She developed cervical cancer, which in 99% of cases is curable if caught early. Sally never received regular PAP smears or mammograms, and by the time she reported her condition, the cancer was terminal. She gradually weakened until she was unable to work.

240. Sally was put into a convalescent home near the Scientology Complex in Los Angeles. She was bed ridden, too weak to do anything, for over a year. The room she was in and her sheets, towels and night clothes, were filthy. She didn't have the strength to clean them. Sally had no visitors, not even her Scientology husband, Mitch, who worked nearby. He was mad at her, said she was lazy, that she allowed herself to get ill so as to shirk work.

241. Sally was left to die on her own. She was in terrible pain continually, with nothing to alleviate it. Dr. Gene Denk ("Denk"), a Scientologist physician, saw her occasionally. It was Denk who gave Hubbard's medical officers blank, signed prescription forms so Hubbard could get all the drugs he wanted. Denk still treats Scientologists and Sea Org members to this day. He told Sally one day that she was too far gone, and all that was left for her to do was die and that she better not mess that up. Fortunately, Sally had a friend who was no longer in Scientology. "Anne" saw Sally, after learning where she was, for the first time after she contracted cancer, at which time Sally weighed only 60 lbs. "Anne" looked after her from that point on for four months until Sally died. "Anne" cleaned out Sally's room completely, got her medication for the pain, clean clothes and sheets and other necessities, including flowers for her room. Sally suffered her last days on her own, abandoned by Scientology. Not even her former husband, Ira Chaleff, was told she died. Her death was very hushed up. She did have one friend though.

242. Some years earlier, Sally's former husband, Ira Chaleff, who was a declared suppressive person, came to Los Angeles, demanding to see his 17 yr old son, Sky. When he was ignored, Ira demanded to see Heber Jentzsch, CSI President. Ira was told to see the Ethics Officer because of his SP declare. Ira got mad, flashed his Congressional I.D. card, and suddenly that he didn't have to see the Ethics Officer and got to see his son instead. He found Sky was way below grade average and suicidal. Even though Sky worked a regular schedule at the Scientology organization, he was denied all services because his father was an SP. Ira took the boy back to Washington with him ... Sky just recently graduated Magna Cum Laude in Computer Science, and is now a healthy young adult with his whole life ahead of him.

243. Susan Todhunter, a long term Scientologist, died of cancer recently in San Diego. She was an opera singer and a Scientology 'celebrity.' Her family wealth allowed her continual auditing. I audited her in Clearwater between 1979 and 1981 when I was a "case cracking" auditor. Later on she completed OT 7, the highest OT level which exorcises BTs and clusters. She developed cancer in the 1980s. Because of her wealth, Susan got auditing from top trained auditors at the Los Angeles Celebrity Center almost up to her death.

244. Marie Passmore was a long term Sea Org member, a Class 8 trained auditor, and on the OT levels exorcising her BTs and clusters. She developed cancer in the late 1970s or early 1980s, and then got auditing in Clearwater, as she told me, to cure her cancer. She was convinced that exorcising her BTs on OT 5 would cure her. When the cancer became terminal, she was sent to Europe to die. I never saw her again. Her death was hushed up.

245. Phoebe Mauerer was also a long term Sea Org member. She was a trained auditor, and was exorcising BTs and clusters on the OT levels. In her last years, she was stationed in Los Angeles and Scientology's secret HQ at Gilman Hot Springs in the Southern California desert.

246. Phoebe did not believe in doctors and never got regular PAP smears or mammograms. After she found she had cancer, she went to Mexico for treatments. She eventually died.

247. Jens Bogvad was also a long term Sea Org member. He was Executive Director Tokyo Scientology Org when he contracted cancer. He had studied and graduated many of Hubbard's management courses, including the Org Exec Course, the Flag Briefing Course, and others. He was also a Class 8 auditor and on the OT levels, exorcising his BTs and clusters. He was finally sent home to Europe to die. His wife, Jeannie, is now the Exec Dir of the Los Angeles Org, and has remarried.

248. Betty Filisky was another long term Scientologist. She was the first person to complete OT 5 after its release in 1978, and received a lot of Scientology publicity on her achievement.

249. Betty was already suffering from cancer when she completed OT 5, but she believed she was cured. She relapsed six months later and died. Her death was so hushed up that not even her former husband and one child, also Scientologists, knew. He found out by chance about Betty's funeral service in Texas, and so was able to attend.

250. Peggy Bankston was also a close friend of mine. She was an original Sea Project/Sea Org member, a class 6 trained auditor and a graduate of the upper level OT 3 auditing. Peggy was already on board the "Avon River" in Las Palmas, in early August 1967, when I arrived. Peggy held various positions on board, the main one being that of Flag Banking Officer and Hubbard's personal Finance Officer. She was very admired by Hubbard and he gave her a number of assignments to do which she always did well. Sometime in late 1967, she suddenly fell into disfavor with Hubbard, then got ill. Shortly thereafter, she left the ship, quietly and quickly. I was away at the time and never found out what occurred exactly. When I returned, I found Hubbard had written an ethics order about her, which shocked me, attached hereto as Exhibit 88. Several years later I found out Peggy had died of cancer. She was living somewhere on the West U.S. coast at the time. I was never able to find out whether she had cancer when she was in the Sea Org or not. She did have a large, darkened skin blemish her left cheek, about an inch in diameter, somewhat similar to a mole but much larger, which Hubbard verbally abused her about. For example, he said to her, "You have that thing on your face because of overts, you know that, don't you?" ... and ... "If you're an OT, why don't you get rid of that overt on your face?" ... and ... "You haven't told all yet!" Then he would laugh at her and walk away.

251. Daphne Parselle was in Scientology in the late 1960s, in London and Saint Hill, East Grinstead. She achieved the state of Clear in 1967. During her Clear speech, (Clears in those days gave a short speech about their 'wins and gains' in reaching the state) in the Chapel at Saint Hill Manor, she claimed, very positively and enthusiastically, that she was cured of the cancer because of her auditing. However, she died of the cancer shortly thereafter.

252. Ellen Carder was an American, and a Scientologist in the early 1960s. She had cancer. She went to England for advanced auditing. While there, she claimed that Hubbard told her that if she studied the Clearing Course and then applied the auditing techniques to herself to achieve the State of Clear, her cancer would be cured. Ellen started on the course of action. However she died in June 1966 at Victoria Hospital, East Grinstead, England - from the cancer.

253. A high level German Scientologist who came to Clearwater for upper level auditing on BTs and clusters, died one day in his room. The "PR story" was he slipped in his bathtub one day and died. I don't remember his name. His death was very hushed up by Scientology top command in Clearwater.


254. In May 1978, I was assigned to the Rehabilitation Project Force ("RPF") in Clearwater, Florida, attached hereto as Exhibit 89. This is a Sea Org detention camp, a 'gulag,' to which are assigned Sea Org members who have (according to Hubbard's doctrine and policies) seriously erred or produced badly. My assignment was for being a failed executive and for not doing well on my job. In addition, a recent auditor of mine reportedly saw a specific E-meter needle reaction occur during my session. It was called an R/S. The R/S reportedly occurred while I was talking about Hubbard, his techniques or organizations, and that meant, again according to Hubbard, that I harbored bad intentions toward Hubbard, his techniques or organizations, and therefore, I was a bad person and required immediate isolation and "rehabilitation." I was commandeered off between two big Sea Org men, both already in the gulag, to the second floor garage of the Fort Harrison Hotel and locked up in solitary confinement for two or three days, in a small room, without windows and a mattress on the floor. I was devastated, in shock and numb ... (Needless to say, 18 months later, I was exonerated of the charges, as per Exhibit 90.)

255. It was common to treat Sea Org members this way, from top command to galley hands. And it was common for those assigned to the RPF, or gulag, to be locked up in solitary for one to several days or more until the person had 'calmed' down, come to his senses and realized he needed rehabilitation. He was then released into the arms of other inmates to do his 'time' and attend to his and others rehabilitation.

256. Some months later, also in 1978, a new person was assigned to the RPF, Lyn Froyland. She was to be my twin - meaning we were to help rehabilitate each other. I found out to my surprise that Lyn was a GO staff member from Los Angeles and on assignment to Washington, DC, and was sent from there to Clearwater. Customarily, GO staff weren't ever RPF'd with Sea Org members. I also rapidly learned that Lyn was devastated over something which occurred in Washington, DC. She said something terrible was going on, Hubbard and GO policy was being completely violated. She tried to correct the situation, only to find herself removed from the assignment and in the gulag with no recourse. To rehabilitate herself, Lyn was expected to talk about her upsets and problems in her gulag auditing. But she would not. She maintained that she had been bonded many times and could not and would not reveal security and confidential information about her organization, the GO, her position or her assignment. Because of the continued refusal to cooperate, Lyn was rapidly assigned to the RPF's RPF. This was several steps down from the RPF, in the boiler room under the Ft. Harrison hotel building. It was a dark, filthy, smelly place where the huge boilers roared and clanked day and night and where the rats lived. Lyn was chained to a pipe down there for weeks, under guard. She was taken meals and allowed toilet breaks, but no other hygiene. I tried desperately to get her to repent and get out of the hole, but she would not. The longer she stayed in the hole, the less she spoke and the more unwilling, sullen, filthy and feral looking she became. I was stunned by what was happening to Lyn. Finally, she did the actions necessary to get out of the hole and back into the RPF, though she was still under 24 hour guard. That night, Lyn somehow got away from the security guard ... and disappeared. I have not heard from her or about her since.


257. In his declaration, Mr. Moxon takes umbrage that CSI deponents might have to testify about their belief in past lives. (Moxon declaration, page 22)

258. There is nothing confidential or secret about past lives in Scientology, except for the OT levels. On the contrary, Hubbard himself wrote at least three publicly available books which delve extensively into past lives. They are: (1) Mission Into Time which covers several of Hubbard's claimed past lives, attached hereto as Exhibit 91, including treasure he buried in those lives. The book summarizes a 1968 expedition led by Hubbard to Mediterranean countries to locate and dig up his treasure. I was the Captain of the "Avon River" on that expedition. (2) Have You Lived Before This Life, contains forty-one alleged auditing case histories of past lives, one of which supposedly occurred 23 billion years ago, attached hereto as Exhibit 92, page 238. (3) Scientology: History Of Man, written by Hubbard, states in the Forward: "This is a cold-blooded and factual account of your last sixty trillion years," attached hereto as Exhibit 93. Hubbard continues: "This is useful knowledge. With it the blind again see, the lame walk, the ill recover, the insane become sane and the sane become saner." The book contains Hubbard's perspective of the history of the human race and describes strange past lives which he claims every person experienced from the beginning of time, including that of the Pilt Down man, later found to be a hoax. All three books are available in major bookstores as well as Public Libraries. They are sold to Scientologists in Organization bookstores, though at far higher prices than in retail stores.

259. Hubbard even developed a technique to resolve past life occlusion. In 1975 he wrote a bulletin, "PAST LIFE REMEDIES," attached herein as Exhibit 94. It states, "There are many remedies and considerable tech developed over the years on the subject of pcs (preclears) unable to go earlier than this life ... The earliest was getting the pc to locate and run imaginary [emphasis added] incidents ... Delusion tends to run off but the real incidents [emphasis added] move into view as well." I ran this 'remedy' on many preclears with mixed results -- some preclears ended up believing they lived in the past and were the identity they found; many did not. I know of many other auditors who did so as well, also with mixed results. It was run on me many times with limited result.

260. Getting a Scientologist to believe that what he sees in his mind is valid, is achieved step by step. At first, the lower level grade auditing gets him looking into his mind for this life memories, which he knows are true. As he often also achieves emotional highs in remembering something, his belief that his memories are valid is enhanced. His next step, according to Hubbard, is Dianetic auditing. At this point he may or may not go into past lives. If he does, he more willingly accepts those memories as valid because he knows that the earlier ones were valid. And he will accept 'memories' of past lives including some extraordinary and unbelievable ones. When he finally gets to OT 3 and learns that he has spiritual cooties all over him, and if he has been a true believer up to that point, he normally accepts that as well.

261. Despite the fact that Scientologists must believe in past lives and be able to audit them to reach the top of Hubbard's Bridge, the CSI attorneys have seen fit to attack the credibility of defendant, Steven Fishman, because he believes in past lives and has a belief he was Malchoot, or the father of Jesus Christ.

262. Fishman's belief is exactly the end result a preclear is expected to obtain during his Dianetic session, a belief that he lived as a particular identity some time in the past, often a famous one.

263. During the thousands of hours I audited others, a large number of my preclears remembered one or more of their past identities. About ten of my preclears believed they were Jesus Christ, about five believed they were Joan of Ark, four were convinced they lived as George Washington and one as Thomas Jefferson.

264. In 1968, I heard Hubbard say that who a preclear believed he was in a past life was unimportant. The importance lay in 'rehabilitating' the ability to recover past lives.

265. Most former Scientologists refuse to get mental health assistance for years because of Hubbard's belief that Mental Health professionals are destroying mankind and the world - that they are the cause of all illness, and familial, governmental, economic, educational, industrial and financial problems.

266. Regular PAP smears and mammograms are not provided in the Sea Org, nor is routine dental care. Hubbard believed he was invulnerable - so do Scientologists.

267. Miscavige's attempts to discredit Vaughn and Stacy Young as CSI experts was expected. (Miscavige declaration, page 15) He can do no less. Hubbard insisted that his critics and enemies be discredited, their names blackened, their lives ruined and their deaths demanded. Miscavige, being a true believer, has to follow Hubbard's orders. The Youngs will more than likely, receive more harassment.

268. This does not alter the fact that anyone who has served and worked in CSI and the Sea Org as long as Vaughn and Stacy Young, who received the extensive training they have, and held the positions they have, is an expert on CSI and the Sea Org.

269. I am sure that in response to this declaration, the Scientologists will further discredit me and manufacture more disclosures about me in their continued "Fair Game" actions to blacken my name and ruin my life. I expect nothing less of them, as they are duty bound to follow Hubbard's directives on their perceived enemies.

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.

Executed in Los Angeles, California this 8th day of March, 1994.

Hana Eltringham Whitfield

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