Charlotte: I made the following Declaration in support of Keith Henson's appeal of RTC v. Henson, discussing the practice of medicine in Scientology. Keith's posting of NOTS 34 fell, in my estimation, decidedly within the bounds of "fair use"--for public comment and warning. Scientology's practice of medicine is widespread and fraudulent, and it seeks to hide behind "secret" documents such as NOTS 34. This Declaration describes my experience with fraudulent medical claims in Scientology, and helps to illustrate why it is so necessary that people like Keith inform and warn the public about the dangers of such practices. By exposing NOTS 34, Keith Henson was saving lives; that is public warning, and that is fair use.

Charlotte's last name has been removed for privacy reasons.


I, Charlotte L. K, do declare as follows:

1. I am over the age of 18 years.

2.The statements herein are of my own personal knowledge or reasonably based on information and belief, and if called upon as a witness, I can testify competently thereto.

3. I was a member of the Church of Scientology in Philadelphia, PA, from January through May, 1998. During that time, I was at the Org nearly daily, taking Scientology courses, and volunteering at the Org as a receptionist.

4. During that short time in Scientology, I witnessed several occasions in which CoS staff members, medically untrained, with no qualifications, recommended people cease medications, not seek out traditional medical treatment, and use CoS services as a cure for their illnesses.

5. To protect CoS from lawsuits, before taking Scientology services, Scientologists are required to sign a disclaimer form which officially disclaims CoS of any responsibility for the promises of its representatives and staff members. However, these promises and sales pitches are delivered in a uniquely high-pressure environment, using tactics pioneered and detailed by Scientology's founder L. Ron Hubbard in such works as the "Hard Sell Course Pack" in order to raise income. I believe the disclaimer forms are required specifically because CoS fully supports and intends staff members to make medical claims and promises of medical cures for CoS services in the fraudulent pursuit of hundreds of thousands--perhaps millions of dollars.

6. CoS literature is studded with testimonials to the medical benefits of CoS auditing services, as are many of L. Ron Hubbard's writings. It is my experience that it is a common belief of CoS members and staffers that traditional medicine is ineffective, and that CoS treatment is an effective medical substitute, and that this belief is officially supported by CoS. It is further my experience that CoS services are not perceived as "faith healing" miracles, but as effective, "scientific" substitutes for traditional medicine, as specific processes which always bring about certain results, including medical cures.

7. I witnessed several occasions of CoS services being prescribed for medical problems, and the use of traditional medicine distinctly discouraged and frowned upon. I was personally ordered by Tiffany Woods, the Senior HAS (Hubbard Communications Office Area Secretary) EUS (Eastern United States) and Jenny Porta, the LRH Communicator EUS, to stop taking medication that had been prescribed for me by a doctor to alleviate my thyroid condition--Grave's disease--upon my signing of a Sea Organization contract. Ms. Woods and Ms. Porta told me that I would otherwise be ineligible for Scientology services, and told me that my medical condition could be cured with PTS (Potential Trouble Source) handlings and Scientology auditing. I was informed that the cause of all illness is "PTSness", and showed a reference from L. Ron Hubbard indicating that the root of all illness and/or injury is a PTS condition. Scientology believes it can handle and cure any and all such "PTS conditions". I was told therefore, I did not need the medicines prescribed to me by my physician, and that Scientology auditing would cure my illness. It was not promoted as "faith healing" or "miraculous." Scientology procedures were instead described to me as an effective substitute for traditional medicine. Scientology procedures were specifically not designed to complement traditional medicine; in fact, I was told that if I continued to take my prescribed medical drugs, I would be ineligible for this Scientology cure. I was not told to visit or ask a doctor's advice. I was ordered to cease medication on the advice of two medically untrained Scientology staff members.

8. In the official Dianetics and Scientology Technical Dictionary, copyrighted 1975 by L. Ron Hubbard, "PTS" is defined as follows: "1. means potential trouble source which itself means a person connected to a suppressive person. All sick persons are PTS. All PCs who roller-coaster (regularly lose gains) are PTS. Suppressive persons are themselves PTS to themselves. (HCOB 5 Dec 68) " Emphasis added. Scientology purports to have the only technology proven to always handle such "PTSness".

9. I witnessed several other cases of Scientology being promoted as a medical cure, including the case of one public Scientologist active at the Philadelphia Organization. She became involved with Scientology in mid- 1997. Years before, she had suffered from Lyme disease, which had been treated by a medical doctor. Not long after her initial involvement with Scientology, she suffered a recurrence of the illness, which became apparent to her as she began to suffer from memory loss, periods of blacking out, severe headaches and similar effects. A medical doctor did confirm her symptoms as being a recurrence of Lyme disease; however, before beginning medical treatment, she sought the advice of Scientologist chiropractors, nutritionists and other alternative medical practitioners. Scientologists deeply distrust traditional medicine, a viewpoint promoted by Scientology founder L. Ron Hubbard since the time of Dianetics, and commonly refrain from medical treatment at all costs.

10. It was recommended to her that she cease medical treatment for Lyme disease; she was informed, as was I, that the cause of all illness was "PTSness." She received many PTS handlings, at the cost of thousands of dollars in auditing fees. However, as she was still ill, she was now sold NED (New Era Dianetics) Assists (Scientology processes used to "handle" illness or injury) as a cure for illness. NED Assists are commonly sold to ill Scientologists as cures for illness, and as replacements for medical care.

11. In the official Dianetics and Scientology Technical Dictionary, "New Era Dianetics" is defined as follows: "a refinement of all previous Dianetics techniques from 1950 up to present time as well as the development of new technique giving much faster results and far higher gain per hour of auditing and speedy resolution of Dianetics cases...(LRH ED 301 INT)" The term "Dianetics" is defined in the Technical Dictionary as well. Relevant is Definition 3:"Dianetics addresses the body. Thus Dianetics is used to knock out and erase illnesses, unwanted sensations, misemotion, somatics, pain, etc. Dianetics came before Scientology. It disposed of body illnesses and the difficulties a thetan was having with its body. (HCOB 22 Apr 69)". Emphasis added. Thus, the "auditing" she was sold, New Era Dianetics Assists, are specifically defined as cures and and "handling" for, in fact "erasing" of, illness. Similarly, New Era Dianetics for OTs (NOTs), are also promised cures and handlings for illness as are all forms of "Dianetics" used in Scientology.

12. After thousands of dollars and many months spent for a cure at Philadelphia Organization, which never did materialize, she was "regged" (subjected to a uniquely high-pressure hard-sell sales session) to go to the Flag Land Base in Clearwater Florida for additional handlings and NED assists. She was, once again, not referred to a physician by anyone at the Philadelphia Organization or at the Flag Land Base; the Case Supervisors who reviewed her PC (preclear) folders knew she was being treated for illness, and knew she was not receiving medical treatment, as did her auditors, in addition to the Registrars who sold her these cures at an eventual cost of tens of thousands of dollars.

13. She was sold several intensives (12 1/2 hour blocks of time) of Scientology auditing at the Flag Land Base on the premise that there, at "the mecca of technical perfection," her Lyme disease would be finally "handled," and that, therefore, the auditing was worth the exorbitant prices. She took out a second mortgage loan on her house to pay for these intensives of auditing. When these did not "handle" her Lyme disease, she was told she had not purchased enough auditing. In a very intense registration session, she nearly maxed out her credit cards to purchase further intensives of Flag auditing, and was further promised a cure for her Lyme disease. Once again, she was not recommended to see a doctor, and was, in fact, discouraged from doing so.

14. She returned to Flag for further "handling" for her Lyme disease, which was continually worsening as she put off medical treatment on the advice of CoS representatives. Once again, after receiving numerous "intensives" Flag auditing, she was still afflicted with Lyme disease. Nevertheless, Scientology continued to exploit the situation for money, involving her again in an intense registration session. She was told that she would need $8000 worth of additional auditing. She explained repeatedly to the registrar that she had nothing, that she had spent her last $2000 for her 4-year-old daughter's International Association of Scientologists Lifetime Membership, that she could simply not afford another intensive. As mandated in Scientology policy, the reg continued the hard sell until she felt that she honestly would not get out of that cycle if she did not agree to buy the intensive. She was given a list of the names and telephone numbers of wealthy Clearwater Scientologists, and told to call them until one of them agreed to let her put her intensive on his credit card. She resisted the idea, and once again, felt forced to back down. Calling down the list, asking people she did not know for a credit card number for an $8000 intensive, she hated the idea but her resistance had been broken down. Eventually, one agreed.

15. She received the intensive. After spending approximately one hundred thousand dollars on Scientology's cures, she had "learned" in her auditing sessions that billions of years ago, in a past life, she had been forced to "zap" her mother with a ray gun by an evil space government, yet she was still afflicted with Lyme disease. She had maxed out all of her credit cards, taken out loans, and otherwise expended all of her resources--and given all of her money to Scientology in return for a much-promised, never-materialized cure for her Lyme disease. She was repeatedly discouraged from visiting a doctor, and sent back again and again, to Flag, for more NED Assists, more auditing, one more intensive, one more process, eventually leaving one Scientologist with untreated Lyme disease, and the CoS thousands of dollars richer. She still owes one Scientologist in Clearwater $8000. Scientology still promises her a cure, still attempts to lead her on the medical runaround.

16. Scientology practices medicine. Scientology auditing is sold as a collection of proven processes. I know from her story, and I know from my own. Scientology still lies about it publicly, and internally, defrauds Scientologists of thousands--perhaps millions--of dollars yearly for false medical claims. Scientologists believe that Scientology has a cure for physical illness; such promises of cures are used as the "hook" to recruit people, and to register people for various services.

17. Such unlicensed practice of medicine in Scientology is deeply dangerous. My medical situation was greatly worsened; in the case I mention above, she manifested more and more symptoms of late-stage disease the further CoS' "handling" progressed. It is my belief, based on personal knowledge, that thousands of people, in various ways, and to greater and lesser extent, have been deleteriously affected by Scientology's unlicensed practice of medicine.

I declare under penalty of perjury under the laws of the United States of America and of the State of New Jersey that the foregoing is true and correct. Executed in Collingswood, New Jersey this 11th day of October, 1998.

Charlotte L. K

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