December 1999

Daniel A. Leipold, State Bar No. 77159
960-A West Seventeenth Street
Santa Ana, CA 92706

Telephone:  (714) 796-1555
Facsimile:  (714) 796-1550

Craig J. Stein, State Bar No. 98041
11755 Wilshire Boulevard, Ste. 1230
Los Angeles, CA  90025-1518
Telephone:  (310) 479-0044

Ford Greene, State Bar No. 107601
711 Sir Francis Drake Blvd.
San Anselmo, CA  94960
Telephone:  (415) 258-0360

Attorney for Plaintiff,


SCIENTOLOGY OF CALIFORNIA		Defendant	))))))))))))	Case
No.: C 332 027Honorable Charles W. McCoyDepartment 24DECLARATION OF ROBERT

I, Robert Vaughn Young declare as follows:
/ / /
/ / /
1.	I am intimately familiar with the structure of the organization
known as Scientology.  I was in various Scientology organizations for nearly
21 years.  I was staff at a field mission in Davis, California, for over two
years and was promoted to the Church of Scientology of San Francisco where I
served for 2˝ in the Guardian's Office before being promoted to the U.S.
Guardian's Office in Los Angeles.  In early 1982, I was promoted to Author
Services, Inc. (ASI) where I served until I left the organization in 1989.
At the time I joined ASI, it was the most senior echelon in Scientology.  My
nearly 21 years gave me ample opportunity to learn the Scientology language,
structure and operation as well as its history and types of publications.
2.	I have personal knowledge of all of the facts contained within this
declaration and if called to testify thereto could and would be competently
able to do so.
3.	I have been asked to review the 65-page declaration of David
Miscarriage submitted in opposition to Plaintiff Lawrence Wollersheim's
Motion to Amend Judgment.  Following my review of the declaration of David
Miscavige, I reviewed thousands of internal Scientology documents that
reference to key issues in this case:
a.	The control that the Sea Organization exercises over all other
Scientology organizations.
b.	The position of David Miscavige at the very top of the Scientology
4.	This declaration presents evidence that Scientology has lied to this
court by presenting perjured testimony.  The evidence will be from
Scientology's own documents.
5.	RTC, CSI and Mr. Miscavige (hereinafter "Scientology") are
attempting to hide behind the arcane and difficult Scientology vocabulary
and organizational structure in the hope that the court will be baffled.  I
will take the court through this maze.  I will translate the language using
Scientology's own material (including a Scientology dictionary).  With
Scientology's own documents, I will show how Scientology is lying and why
Scientology's argument should be rejected. 

6.	Scientology is seeking to deceive this court regarding two primary
targets: (1) that the Sea Organization is a loose-knit "fraternal
organization" with no role in management; and, (2) that David Miscavige has
no role or position as it relates to the management of Scientology or
control over this case.  I will show with their own documents that these are
a lie.  The Sea Organization (sometimes called SEA ORG or SO) is the nexus
that permeates all Scientology "orgs" (Organization) and violates all
Scientology corporate structures and David Miscavige has controlled it since
7.	I am able to give this declaration because I was in Scientology for
over 20 years (including membership in the Sea Organization) and know the
vocabulary and the structure and can thus find their relevant publications
to present to the court.  My function for most of those years was to work in
Scientology Public Relations.  I was trained on how to misdirect the media
and the authorities.  Thus I am intimately familiar with how this is being
done now in this court.  I wrote an article for Quill, the magazine of the
Society of Professional Journalists on my role in Scientology public
relations and how I manipulated the media.  Fortunately for me, when I was
manipulating the media, there was no one of comparable status who could go
back to Scientology materials and challenge me on the smoke screens that we
were creating.  I also worked closely for years with Mr. Miscavige at ASI
and also knew him after he moved to RTC, making that the most senior group.
8.	 Scientology's best defense is its vocabulary and its structure
because there are two vocabularies and two structures.  One vocabulary and
structure is used internally by Scientologists (both members and staff) and
the other vocabulary and structure is what is conjured up for the
non-Scientology world to prevent the media, the courts and the authorities
from knowing what the organization is truly doing.
9.	The documents I will rely on will be internal documents, written for
Scientologists.  Scientology must hide these documents from the court
because they show how the organization actually operates.  These documents
employ a Scientology vocabulary and structure that is completely confusing
to a non-Scientologist.  The structure can even baffle Scientology members. 

10.	There are many types of Scientology publications.  By "publication"
I mean something issued in writing either to inform or to give directions.
Those that are meant to inform may be simple magazines or merely a few
printed sheets that are stapled in the corner.  The distribution may be to
staff or to all Scientologists. 
11.	The more complex publications that I will rely on take many forms.
Each form claims to have a specific public/audience and function.  The
following are examples:
12.	HCO Policy Letters or HCOPLs: "HCO" stands for "Hubbard
Communications Office." Hubbard is L. Ron Hubbard who called himself the
"founder" of Scientology.  The basic purpose of HCOPLs is to set the policy
for the organization itself.  Thus one finds HCOPLs on how to write a
dispatch, pay bills, hire personnel, deal with the media, etc.  HCOPLs are
issued to staff and members although distribution may be limited by the
listing in the upper left corner of the issue. 
13.	Sea Organization Executive Directives or SO EDs: These are issued to
Sea Organization personnel.  The most senior is the SO ED INT.  The "INT"
means "international" which means it applies to all Sea Org personnel.  Each
Sea Org unit or area is allowed to publish its own issue so the "INT" will
be replaced by the name of the unit or area, e.g., SO ED US (United States)
or SO ED EU (Europe.) 
14.	SO FOs or Sea Organization Flag Orders: In the 1960's and 1970's,
Hubbard lived and worked on a ship that sailed the Mediterranean.  In the US
Naval tradition, he called the ship that he worked from the "Flag Ship" or
"Flag."  Orders issued to the crew of the Flag Ship were called Flag Orders
or FOs. 
15.	Attached hereto is a true and correct copy of the HCO Policy Letter
24 September 1970R "Issues, Types of" to show how they describe their own
types of issues and their seniority.  See Exhibit "Z-99."
16.	It should be strongly noted that it is prohibited to cancel or
change anything written by Hubbard.  This was spelled out in Scientology
Policy Directive 19 of 7 July 1982 "The Integrity of Source" a true and
correct copy of which is attached hereto as Exhibit "BB-99."  Scientology
cannot, according to their own words, claim that something written by
Hubbard is no longer in effect or has been cancelled.  It cannot be.
According to the organization, Hubbard's words are "scripture."  They are
inviolate.  Thus any claimed changes to Hubbard-written issues are invalid,
unless they were made by Hubbard himself.  Since Hubbard died in January,
1986, there can be no changes since then, according to their own directive.
17.	The reason this is so important to this court is that it is one way
the organization seeks to confuse the authorities by shifting between
internal and external representations.  Internally, Hubbard's words are
etched in stone and are to be followed to the letter, with no
interpretation.  However, when something appears in a court or the media
that is embarrassing or possibly harmful, a representative can change the
meaning or even insist that Hubbard's words are merely "advice" or
"observational" when that is not how the organization actually operates.  In
fact, the primary purpose of the organization that Mr. Miscavige heads, RTC,
is to maintain the "purity" of Hubbard's "technology," and to demand that
his words be followed exactly. 
18.	While a Scientology magazine itself does not carry the force of
POLICY, it often reproduces Hubbard policies or directives and it also
carries their statements as to how Management wants to be viewed within the
Scientology organization.  Thus Scientology's internal magazines can offer a
true representation of the organization, one that they are seeking to hide
from the court.
19.	One of the first sleights of hand that Scientology tries to effect
on the courts is equating "Scientology" with "The Church of Scientology."
"Scientology" includes Churches of Scientology but it also includes
non-church organizations.  I made this point and explained it very early in
my Quill article.  Their own documents show how the organization actually
operates, as opposed to how they want the court to think they operate. 
20.	"The Command Channels of Scientology" is a booklet that was issued
to all Scientologists.  A true and correct copy of which is attached hereto
as Exhibit "X-99."
21.	There are two vital points to be made here.  First, the court should
first note that this does not say "Command Channels of the Church of
Scientology".  In their own perspective, "Scientology" is more than the
"church."  Second, this describes the COMMAND CHANNELS.  According to the
Scientology dictionary (and a Hubbard policy letter), "command channels" has
a specific definition: 
COMMAND CHANNEL, 1. (communications routing) command channels go up through
seniors over to a senior and down to a junior.  Or they go up through all
seniors.  It is used upward for unusual permission or authorizations or
information or important actions or compliance.  Downward it is used for
orders.  (HCOPL 25 Oct 72 I) 2. Junior to senior to senior's senior or on
down.  (HCO PL 25 Jul 72)[emphasis added]
22.	This definition shows there are senior echelons and junior echelons
and they operate in a military manner.  The senior echelon issues orders and
the junior echelon must comply.  The Sea Organization is central to this
structure.  They have their own command and compliance channels and they
have tried to hide these facts from this court. 
23.	The Command Channels of Scientology are not restricted to the
"Church of Scientology."  In the lower right hand corner of the chart, the
court will find the World Institute of Scientology Enterprises (WISE) and
the Association for Better Living and Education (ABLE).  WISE represents
itself in the non-Scientology world as a "non-religious" activity, offering
the "administrative technology" of Hubbard.  ABLE coordinates the activities
of The Way to Happiness Foundation, Applied Scholastics, Criminon and
Narconon which are activities that represent themselves to their various
communities as having nothing to do with the "Church of Scientology."  
24.	This is how the organization operates with two-faces.  To the
non-Scientology world, they will say they are not Scientology and try to
appear secular.  But in the "Command Channels of Scientology," their true
color is shown.  WISE and ABLE are on the same echelon as the Missions of
the Church of Scientology.  Their function is to bring people into
Scientology by pretending to be apart from the "Church of Scientology."  So
internally, they are part of "Scientology" but to the non-Scientology world,
they are "secular" and not part of Scientology.  This is a prime example of
how the organization does a flip-flop, changing its image, purpose, command
channel and structure to fit the occasion.  That is what they are trying to
do with this court with regard to the Sea Organization.
25.	An attempt is being made by Plaintiff to cast the Sea Organization
as a harmless, loose-knit fraternal organization on the order of the Elks or
Shriners with no authority or control of Scientology.  This is a lie and is
proved by Scientology's own documents. 
26.	I refer the court to the 65 page declaration of David Miscavige,
dated 24 Sept 99 and filed in this case.  In this declaration, Miscavige
states at page 6, paragraph 12: 
The Sea Org is a descriptive name for individuals who have pledged
themselves to eternal service of the Scientology faith….  The Sea
Organization is a religious fraternal order, like the Catholic priesthood,
with its own rituals and traditions that exemplify and foster member's
shared and deeply-held commitment to the religion.  It confers no corporate
or ecclesiastic authority.  Sea Org members are staff in many churches of
Scientology across the globe.  Any authority they have in the church entity
that employs them derives from their position in that church structure and
not their honorary status in the Sea Organization.

27.	The representation that the Sea Organization is a "fraternal order"
are the misdirections of Miscavige and others who seek to hide the true
function of the Sea Organization from this court.  They cannot provide one
single issue where Hubbard calls it a "fraternal order" and it was he that
created the Sea Org and gave the Sea Org its purpose.  Calling it a
"fraternal order" was something that came about later to hide its actual
function from the courts and the authorities.  Scientology's own documents
show that the Sea Org is a tough, elite, tight-knit organization that has
the authority to move into and take over any organization on the "Command
Chart of Scientology," regardless of corporate lines.
28.	L. Ron Hubbard's father was in the Navy and Hubbard sailed the
Pacific as a youth.  When World War II broke out, Hubbard joined the Navy.
When he fled the United Kingdom in the late 1960's he took refuge on a ship,
the Apollo.  He had his own "navy" and the para-military "Sea Organization"
was born.  He appointed himself "Commodore" and called the Apollo the "flag
ship" or merely "Flag."  Naval uniforms and ranks (and ribbons) appeared
along with naval and military jargon.  Another new element appeared during
this period: Sea Organization directives that gave the Sea Organization its
unlimited power.
29.	The Scientology vocabulary is so difficult that they even have
dictionaries for staff and members.  The largest is the Scientology
dictionary known as Modern Management Technology Defined.  In this large
volume, Scientology terms are defined by taking their meaning from various
Scientology writings.  The "various types of issues" used are listed in the
Table of Contents of the volume reprinted in 1986, the year of Hubbard's
death.  Of the 38 types of issues, 25 or 66% are Sea Org issues.  Those that
are underlined are Sea Organization issues:

	Aides Orders
	Base Orders
	Board Policy Letters
	Board Technical Bulletins
	Central Bureau Orders
	Central Office of LRH Executive Directives
	Commodore's Staff Orders
	Continental Orders
	Ethics Orders, US Base
	Executive Directives, Area Estates
	Executive Directives, Flag
Executive Directives, Flag Admin Org
	Executive Directives, Flag Advanced Org
	Executive Directives, Flag Bureau
	Executive Directives, U.S. Base
	Executive Directives, Worldwide
	Flag Bureau Data Letters
	Flag Conditions Orders
	Flag Debriefer Forms
	Flag Divisional Directives
	Flag Mission Orders
	Flag Orders
	Flag Orders of the Day
	Flag Personnel Orders
	Flag Project Orders
	Flag Ship Orders
	Founding Church Policy Letters
	Guardian Finance Order, Guardian Personnel Orders
Hubbard Association of Scientologists International 
Policy Letters
	Hubbard Communications Office Administrative Letters
	Hubbard Communications Office Bulletins
	Hubbard Communications Office Information Letters
	Hubbard Communications Office Technical Bulletins
	Hubbard Communications Office Training Bulletins
	LRH Executive Directives 
	Miscellaneous References [gives some Sea Org issues]
	Sea Organization Executive Directives
	U.S. Base Conditions Orders

30.	Vocabulary is the heart of the Scientology administrative
methodology and this shows that it was derived predominantly from the
influence of the Sea Organization.  This shows how the power of the Sea Org
has come to dominate the organization, right down to the vocabulary.
31.	As "Commodore" and source of the Sea Org, Hubbard's words are the
best way to view Scientology.  His words also happen to be what Scientology
relies on and they quote him constantly in their publications.  So
disregarding Miscavige's description to the court of the Sea Organization,
see Flag Order 1992, issued on May 14, 1969, by "Commodore" Hubbard, titled
"Purpose of Sea Org Revised." (A true and correct copy of which is attached
hereto as Exhibit "C-99."  Hubbard says the purpose of the Sea Org is:
Organizations].  [All caps in origins]

32.	These "Orgs" or "Units" are called Sea Org "Missions" and they are
what gives the Sea Organization its unlimited power.  Scientology's
documents show that Sea Org Missions are used to cross corporate lines and
to control all Scientology organizations and corporations, even into the
private business sector. 
33.	Hubbard first told all of Scientology that Sea Org Missions had
"unlimited powers" in 1969 in an HCO Policy Letter titled "Sea Org Zones of
Planning" dated Feb. 8, 1969.
The Zones of Activity of the Sea Org are therefore of general interest and
are outlined for future Sea Org planning.

The Sea Org sends its officers to individual orgs with unlimited powers to

34.	This policy giving "unlimited power" was reprinted in a 1987
directive from the Religious Technology Center that David Miscavige
authorized on the signature line.  It is "Inspector General Network Bulletin
No. l" dated April 19, 1987, a true and correct copy of which is attached
hereto as Exhibit "EE-99."  This is the type of publication he has withheld
from this court. 
35.	Sea Org Missions are also how the Sea Org gets its income.  As
Hubbard clearly stated in Flag Order 228 dated October 9, 1967, titled
"Purpose of the Sea Org: Character of Missions" a true and correct copy of
which is attached hereto as Exhibit "FF-99:"
The annual income of the Sea Org is obtained from a percentage of general
income of orgs and billings to orgs for mission services. [emphasis added]

36.	It doesn't matter that the organization didn't request the Sea Org
Mission.  That was the whole point of the Sea Org, to step in and take
command.  (They promote this in all of the Sea Organization magazines.) For
this, the organization was to be billed. 
	37.	Sea Org members are trained in "Mission Tech."  A Sea Org
"missionaire" has full authority to override all corporate authority.  See
Flag Order 2119 17 September 1969, a true and correct copy of which is
attached hereto as Exhibit "Y-99."  Note how the Sea Org Missionaire goes in
and takes control, as the most senior executive:
This is how it works
1.	A Missionaire enters the Organization senior to its most senior
2.	The Missionaire works with the Organization Executives at their
level to execute his Mission Orders.
3.	The Org Executives expedite the Missionaires' orders within their
4.	A Missionaire uses the Org personnel to execute his orders, via the
Organization Executives.
5.	A Missionaire works with the Org staff to execute his Orders.
(emphasis added)

In other words, the organization now follows the orders of the 

Sea Org Missionaire, who is in full control.  

/ / /
38.	The Sea Organization likes to publicize its power to Scientologists
and there is no better place to see this than in their own internal
promotional material, for example, In "High Winds: The Magazine of the Sea
Organization." Issue 10 (copyrighted 1990), is an article titled "The Sea
Org Removes All Stops to Expansion," they say:
Ethics exists to blast the obstacles and roadblocks out of the way of
expansion.  The primary purpose of the Sea Org is to get in ethics, and this
is often done with Sea Org Missions. 

As examples, they describe in this magazine how Sea Org Missions went into
three organizations around the world: the Stevens Creek Org in San Jose,
California, the Zurich Org in Switzerland and the Munich Org in Germany. 
· At the Stevens Creek Org in San Jose, "Two execs who refused to get the
show on the road were removed and replaced…" 
· At the Zurich, Switzerland, Org, when orders were not adequately followed,
a Sea Org Mission was sent.  "One executive who was not executing the
program, had to be removed…" 
· At the Munich, Germany, Org, an executive was removed and replaced. 
39.	These examples from their own magazine show that the Sea Org can and
does go into any Scientology corporation around the world and has the power
to fire and hire personnel as well as run the organization.  A true and
correct copy of this document is attached hereto as Exhibit "GG-99."
40.	Issue 19 of the Sea Organization magazine "High Winds" (copyright
1996) celebrated the 29th anniversary of the Sea Org.  This issue is a
highly accurate description of the Sea Org and what it does.  Here are some
quotes from the issue, to show how the Sea Org is represented (internally
and truthfully) to Scientology: 
What started with a handful of Scientologists assisting LRH [L. Ron Hubbard]
soon grew to a formidable force stationed on every major continent on the

The campaign required the establishment of an impervious and diamond-tough
Sea Org structure of Command personnel, strategically located in each

41.	Much of the magazine deals with court fights that, they say, were
carried on by the Sea Org.  The magazine also tells how the Sea Org fought
the German government and took out ads in the New York Times.  On page 56
are "highlights" of Sea Org accomplishments that are introduced in this way:
It would be impossible to list all the Sea Org achievements for the 1995/96
year, but every year places its own particular stamp on the time track
[Scientology jargon for "history"], and it would not be overstating the case
to say that this year saw the most dramatic forward strides  taken in Sea
Org history.

42.	Here is a sampling of the "accomplishments" listed on that page, to
show the extent of Sea Org control:
	Oct. 1995 - New booklets attacking psychiatry
	Oct. 1995 - The org in DC is reestablished and reopened
	Dec. 1995 - A new "Ron Mag" about Hubbard is created
	Feb. 1996 - Japanese leaders tour the base in Florida
	Mar. 1996 - New Era of Management begins:  "over 100 Sea Org
officers fire out from International Management Headquarters to take command
in every continental zone."
Mar. 1996 - Scientology is put on the Internet
	Jun. 1996 - An Italian court gives Scientology recognition
	Jul. 1996 - New Sea Org base created in Moscow. 
A true and correct copy of this document is attached hereto as Exhibit
43.	There is no question that the Sea Org did these things and much
more.  This is what the Sea Org is there to do.  It will send one or more
Sea Org Missions, each consisting of several personnel, into an area or Org
to accomplish an assigned task.  They will arrive in full naval uniform, as
pictured in the magazines.  They have "unlimited power" to accomplish what
they were sent to do and they get most jobs done.  Scientology members know
this.  The Sea Org takes pride in this accomplishment.  Now Scientology is
trying to tell this court that the Sea Org is really nothing more than a
loose-knit "fraternal order" and it has no structure or role.  This is not
true and it is not how the Sea Org presents itself in its own publications
nor is it how Hubbard describes them.  It is Scientology's red herring, to
try to misled the court away from the dominant role of the Sea Organization.
The Sea Org is the nexus that permeates the entire Scientology empire. 
44.	Nothing shows how far across corporate lines the Sea Org Missions
can extend than their takeover of a for-profit organization, Sterling
Management, in 1986.  Located in Southern California, Sterling Management
promotes itself as a business advisory group, helping small businesses to
become more successful.  They are not part of the Church of Scientology.
But they are a member of the World Institute of Scientology Enterprises
(WISE) and thus are on the "Command Channels of Scientology" in the lower
right hand corner as a "WISE Unit."  Although they are a for-profit
enterprise that claims to be totally independent from Scientology, they were
the target of two Sea Org Missions sent from the Commodore's Messenger
Organization (CMO) in 1986.  
45.	The Sea Organization is a para-military group, using the US Navy as
its model.  The uniforms, language, rituals, rules and disciplines all
reflect a naval battle tradition, as opposed to, e.g., the American Sea
Scouts.  There is an "enemy" and "battle plans."  Battle ribbons are awarded
or earned for various "campaigns" and worn on the uniform.  Books on war and
military intelligence and propaganda are studied on Hubbard's orders to
learn and apply the principles of combat.  
46.	As a para-military organization, the Sea Org has a military command
structure consisting of officers and enlisted personnel.  The most senior
echelon was at "Flag" with Hubbard who held the rank of "Commodore."  All
personnel and organizations were junior to him and Flag.  Only Sea Org
personnel were allowed to hold any senior positions in Scientology.
According to their own book What Is Scientology? (which was written and
designed to give to media and authorities outside of Scientology) at page
Sea Org members are the only individuals who may hold the senior
ecclesiastic positions in the Scientology hierarchy.  All advanced churches
and management-level church organizations employ only members of the Sea
Organization religious order. 


47.	Defendant and other Scientology officials have sought to lower the
profile of the Sea Organization and hide its role.  For example, when
applying for their tax exemption from the Internal Revenue Service ("IRS"),
the Church of Scientology International was asked to explain the Sea Org and
it replied: 
The Sea Organization is a religious order consisting solely of members who
have pledged themselves to one billion years of service to Scientology.
The Sea Organization is not incorporated, nor is it an unincorporated
association, and it has no formal or informal ecclesiastical or other
management structure. Despite its name, the Sea Organization is not an
"organization" or an "entity." It has no income, disbursements, assets or

It has been shown by their own documents that this is a complete lie: the
Sea Org is an actual organization that not only manages organizations but
has "unlimited powers" to take over any organization.  It also has an
income.  Sea Org Missions is how the Sea Org gets income but here they tell
the IRS that it has no income, a clear lie.  A true and correct copy of this
document is attached hereto as Exhibit "II-99."
48.	There are two types of ranks within the Sea Org: brevet and earned.
Earned ranks are awarded not unlike in military service, moving up one rank
at a time, from enlisted to officer.  As in the military, these are
permanent, unless the person is demoted.  They are given by a Sea
Organization Officer Selection Board.  However, as CSI explained to the IRS
in their application for tax exemption:
Brevet ranks are assigned to certain positions within the Church and have
the purpose of equating rank and ecclesiastical authority.  One holds a
brevet rank as long as one holds the position to which the brevet rank

See Exhibit "II-99."

49.	In other words, the most senior officer at an organization might
have an earned rank of lieutenant or even an enlisted rank but they are
given the brevet rank of "Captain" of the organization and wear that
insignia while he/she holds that position. 

50.	David Miscavige used this brevet/earned ranking to hide his true Sea
Org position and power from the court.  In his declaration to this court
dated September 24, 1999, he says (page 6, starting line 25):
I currently hold the honorary rank of Captain.  Many [sic] other individuals
also hold the rank of Captain in RTC, CSI and other churches of Scientology.
Many of those who hold the rank did so before I was a Captain.  Just as I do
not "outrank" them, they do not "outrank" me.

On page 7, line 11, he continues:
Any allegation that the "power structure" of Scientology stems from
membership or rank in the Sea Organization is ludicrous.  It is an invented
story that ignores the realities of corporate separateness in an attempt to
forward a legal strategy to extract monies from Scientology churches that
have never had anything to do with Wollersheim.  My authority stems from my
corporate position, and I neither need nor use my rank in the Sea Org in the
performance of my duties. 

51.	However, in CSI's  response to the IRS (page 3-5), CSI gives the
rankings of the most senior Sea Organization officers.  According to CSI,
the highest ranking officers in the Sea Organization are as follows:
David Miscavige Captain Captain
Marc Yager Captain (Brevet) Lt. Commander
Ray Mithoff Captain (Brevet) Lt. Commander
Mark Rathbun Captain (Brevet) Ensign
Mark Ingber Captain (Brevet) Ensign
Guillaum Leserve Captain (Brevet) Lt. Commander
Tom Ashworth Commander (Brevet) Petty Officer 1st Class
Ken Delderfield Commander (Brevet) Ensign
John Eastment Commander (Brevet) Lieutenant
Cherie Eves Commander (Brevet) Lieutenant
Greg Hughes Commander (Brevet) Midshipman
Diana Hubbard Commander (Brevet) Midshipman
Katherine Lemmer Commander (Brevet) Petty Officer 3rd Class
William Lindstein Commander (Brevet) Warrant Officer
Pablo Lobato Commander (Brevet) Chief Petty Officer
Myles Mellor Commander (Brevet) Chief Petty Officer
Ron Miscavige Commander (Brevet) Midshipman
Amy Mortland Commander (Brevet) Midshipman
Ellen Prager Commander (Brevet) Chief Petty Officer
Cathy Rinder Commander (Brevet) Warrant Officer
Mike Rinder Commander (Brevet) Ensign
Norman Starkey Commander RA Commander RA
Barbara Tompkins Commander (Brevet) Ensign
Jens Urhskov Commander (Brevet) Warrant Officer
Kurt Weiland Commander (Brevet) Midshipman
Barbara Widmore Commander (Brevet) Petty Officer 3rd Class
The court should note that David Miscavige is, by their own sworn document,
at the top of the rankings and the only person holding a non-brevet rank of
Captain.  And this list is, according to them, the highest ranking officers
in the Sea Organization.  His claim that there are "many" others who hold
the rank of Captain fails to point out that the others are brevet.  His is
the only non-brevet rank of Captain.  This is a clear attempt to hide his
true position from the court.  See Exhibit "II-99."
52.	Miscavige also told this court, "…I neither need nor use my rank in
the Sea Org in the performance of my duties." That too is a lie and can be
shown by Scientology's own internal documents.  
53.	Perhaps the most telling use of his rank and position in the Sea Org
occurred in 1988 when David Miscavige cancelled what had been presented as
the last message from L. Ron Hubbard, calling it a forgery.  Hubbard's
message was dated January 19, 1986, about a week before Hubbard died, and
was issued as Flag Order 3879, "The Sea Org & The Future." A true and
correct copy of this document is attached hereto as Exhibit "JJ-99."  At
that time, it was issued to all Scientologists and was even reduced in size
and issued (with Miscavige's approval) along with a photograph of Hubbard so
Sea Org members could put it on their desks.  In that Flag Order, Hubbard
said he was stepping down as Commodore and assuming the rank of Admiral.  He
also created a new Sea Org rank of "Loyal Officer" that was "directly above
the rank of Captain" and appointed Pat Broeker as the first Loyal Officer.
Pat Broeker had lived with Hubbard for years while Hubbard was in seclusion
and had become his closest aide and confidant.  This alone gave Broeker
considerable power and the promotion meant that he would outrank Miscavige
in the Sea Org. 
54.	With Hubbard's death, a power struggle ensued over the next two
years, culminating in David Miscavige canceling this Flag Order on April 18,
1988, claiming (with no proof or evidence) that it was fabricated by
Broeker.  The cancellation was issued as a Sea Organization issue with no
other authority but that of "Captain David Miscavige."  A true and correct
copy of the cancellation is attached hereto as Exhibit "KK-99."  [Box B,
flag conditions orders] It must be stressed that this is no small
accomplishment, to cancel what had been represented as Hubbard's last
message to all of Scientology, with no evidence or documentation but on the
word and rank of Miscavige alone. 
55.	Captain Miscavige was once deposed on this exact issue.  On July 19,
1990, Miscavige was in deposition in Bent Corydon vs. Church of Scientology,
International, Inc., et al.  Attorney for the Plaintiff, Toby L. Plevin,
tried to ask Miscavige about this cancellation of Hubbard's last message.
While Miscavige admits that he wrote the cancellation (p 246, line 13), when
he is asked what "investigation" he conducted to reach the conclusion that
it was a forgery, the three attorneys on his side of the table begin to
object (starting page 247, line 13) before Miscavige is finally instructed
not to answer and not say what evidence he had that Hubbard had not written
that "last message." (Page 249, line 2-12)  (See Exhibit "H-99.")

	56.	Further proof as to the importance of the Sea Organization
is found in their "Command Channels of Scientology" booklet which was issued
to all Scientology staff.  In that booklet, they say on page 8 that,
"International Management is the top echelon of the Church" that it
"comprises several units, each with its specific responsibility and duties.
The top level of this echelon is the WATCHDOG COMMITTEE." On page 9, they
say, "Different types of organizations in Scientology are grouped into
sectors and each of those sectors has management organizations to give them
direction." The Sea Org is shown as one of those sectors, hardly the
position one would give a loose-knit "fraternal order" that has no role in
management .  See Exhibit "X-99."
	57.	Also in their "The Command Channels of Scientology" booklet
they say on page 6:
The Chairman of the Board RTC [Miscavige] is the most senior position of the
Religious Technology Center.  The Chairman of the Board sees that RTC
accomplishes its purpose and he has under him the Inspector General, who
runs the day-to-day affairs of RTC.   

Then on page 7, of Exhibit "X-99," they say, "RTC is the organization which
polices the command channels of Scientology…"
58.	Since the command channels are those channels on which the orders
are given and compliances are sent back, there is no doubt that the
organization that "polices" these has the authority over them.
/ / /
/ / /
/ / /
	59.	In 1982, Miscavige headed a Sea Org Mission that went to San
Francisco to "instruct" franchise (called "Mission holders") holders about
the "new" structure of the Scientology movement.  This was reported in the
"Sea Org Expansion News,"  THE SEA ORG MOVES IN which went to all
Scientologists, a true and correct copy of which is attached hereto as
Exhibit "L-99."  At the time, Miscavige was the Chairman of the Board of
Author Services, Inc. (ASI), a for-profit corporation.  (I was also employed
at ASI at that time, and worked with him.) Yet from his Sea Org position, he
not only headed the delegation but had the authority to expel people from
the church.  In Exhibit "L-99," he is pictured pointing his finger at one of
the franchise holders that he (Miscavige) was expelling on the spot, with
nothing but his Sea Org authority.  Miscavige would later try to diminish
his role by saying he was nothing but the "Master of Ceremonies" of the
event.  But the lie is shown in the photograph and the text. 
	60.	In that same issue, Exhibit "L-99," on the last page under
"The Sea Org," it says: 
For over fifteen years, the Sea Organization has had the task and duty of
safeguarding and forwarding the use of Dianetics and Scientology spiritual
technologies, and keeping the forward motion going toward the goal of a
Cleared planet….

Today the Sea Org is many thousands strong, and maintains permanent land
bases in dozens of countries."

	This is hardly the role of a loose-knit "fraternal" organization, as
Scientology is trying to present to this court.  The Sea Org is exactly what
its directives and magazines say it is: a powerful group with unlimited
powers that can go into any organization and take it over and run it. 
	I declare under penalty of perjury under the laws of the State of
California that the foregoing is true and correct.  Executed this ___ day of
December, 1999, at Cincinnati, Ohio.

					Robert Vaughn Young

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