GRAHAM E. BERRY, State Bar No. 128503
GORDON J. CALHOUN, State Bar No. 84509
221 N. Figueroa Street, Suite 1200
Los Angeles, California 90012
Telephone: (213) 250-1800

Attorneys for Defendant

CHURCH OF SCIENTOLOGY                 )  Case No. CV 91 6426 HLH (Tx)
INTERNATIONAL, a California non-profit religious Organization



Date: APRIL 4, 1994
Time: 10:00 a.m.
Courtroom: 7

[Filed and served concurrently with Dr. Geertz' Bill of Costs.]


I, Scott Mayer, declare as follows:

1. I am a resident of the County of Los Angeles, California. I have personal knowledge of the facts stated herein, unless stated upon information and belief, and as to those statements which are based on information and belief, I believe them to be true. If called upon to testify as to these facts, I could and would competently do so.

2. I am a designated expert witness in the case of Church of Scientoloqy International v. Steven Fishman and Uwe Geertz, U.S.D.C.C.D. CA Case No. CV 91-6426 HLH (Tx). The purpose of this declaration is to rebut portions of the recent declarations of Senior Scientology Officials that the Church of Scientology has not instructed people to commit murder or engage in financial fraud.

3. I have been previously designated and testified as an expert in Scientology related litigation. After I left the Church of Scientology, I became a personal assistant to Martin Cohn, who in 1980 was senior counsel for the special cases division in the Internal Revenue Service (IRS). I became his assistant when the IRS went to trial against the Church of Scientology in what has become known as the Tax Court case. I sat in the courtroom with him and whenever a Church of Scientology witness would reference a policy that justified what they were doing or showed how goodthey were, I would write a note giving him a policy reference that allowed the Scientologist to bypass that policy. In addition, I was designated and testified as an expert in Scientology administration and operations including Sea Organization ("S.O") operations. In addition, I testified against Scientology at the 1981 Clearwater hearings in Clearwater, Florida. I had been all over the world for Scientology. I had been on perhaps 20 different S.O. missions for L. Ron Hubbard ("Hubbard"). I had operated directly under Hubbard's authority.

I ran his ships, trained his missionaires, and trained Sea Organization ("Sea Org") members. In addition, I testified against Scientology at the 1981 Clearwater hearings in Clearwater, Florida. Attached hereto as Exhibit A is a photocopy of an excerpt of pages 273 to 283 of the Book "A Piece of Blue Sky -Scientology and L. Ron Hubbard Exposed" by John Atack. As the Exhibit passage states, after I left Scientology in 1976, I went into hiding at Laguna Beach. In approx. 1978, I was the engineer at one of the Laguna Beach hotels. I ran into Scientology executives (David and Sue Anderson) in the street. Sue Anderson who was Hubbard personal PRO at the time and her husband David I believe was the Flag Ethics officer. Shortly after that, my car mysteriously caught on fire in front of a friend's house when I was visiting one night and many of my Scientology papers in the trunk burned. On another occasion, the remaining Scientology papers I had disappeared from a storage site in the garage from an apartment I had in Ladera Heights, California.


4. Prior to joining Scientology, I had been in service in the United States Navy in Vietnam where I developed electronic warfare talents, other electronic talents, navigational talents and learned docking an aircraft carrier electronically in totally inclement weather. I was also experienced with self-defense weapons and martial arts. Even when I was in the United States Navy, I had always wanted to captain a ship. In the late 1960s, I was living in Corona del Mar, California and working as a stationary corporation field representative. I was bored and had just broken up with my wife. I still had my dreams of skippering a ship and had no ties to any place or any person. I was approached by a representative of the Scientology Sea Org go into a ship training program as a ship's master. Scientology needed people to run Hubbard's ships because he wanted to expand the fleet. When I was a Scientology fleet captain in 1973 and 1974, we had only two ships and another small boat in the U.S. Pacific Flotilla, but we were getting ready to have additional ships in Mexico and San Francisco and part of my assignment was to put a fleet together and to coordinate activities in training programs, staff analysis and establishment of the flotilla.


5. In the course of being part of Scientology's ship master's program, I learned that the ships always had fraudulent licenses and papers. Such phony papers included radio licenses, ship's papers, records, crew certifications, seaman's certificates and other such matters. For this purpose, Scientology used Pat Hunter, a woman who lived in South America. She had an excellent command of the Spanish language and customs and would go to the Panamanian authorities and act as the intermediary between Operation Transport Corporation (Hubbard's personal holding company) and the Panamanian consulate. Her name was Pat Hunter. As a result of various subterfuges, we did not even have to provide proof that people had successfully completed various training programs to get certificates. Pat would just go to the consulate, give them some money, get the books made up and have them officially stamped. When a new crew member was posted to a ship, Pat would take the papers down to the consulate and have them authorized: ship's papers, seaman's papers, etc. When courses were established, certificates from basic seaman up through captains, deputy captains, first mates and others were awarded by course supervisors of Hubbard's courses and then processed through the consulate as described above.

6. I came to develop an understanding and belief that all of these illegal things were done on the basis that WOGS (nonScientologists) were fouling up the planet and were basically criminals who were running an insane world. Scientology professed to be trying to straighten out the planet, trying to get rid of the insanity and make things right again. So, my understanding and belief was that this illegality was acceptable as part of a Jihad or holy war. We were doing things to keep Scientology working and the things that we were doing were just fine because Scientology convinced us it was trying to make a better world. It was similar to rioting for peace. You know it really doesn't work but it is a way of getting mass agreement of Scientology's movement towards Hubbard's goals for a clear planet.

7. The illegal conduct involved in Hubbard's ships included receiving a percentage of money from all of the S.O. organizations in Los Angeles and elsewhere in the world 1. In exchange for this money, people would come on board the ship from all over the world and be trained on various basic Sea Org procedures, basic staff hatting procedures and then be sent back to their home organizations to assume Scientology posts. At this time, I floated back and forth between the ships in various executive positions and other posts concerning the Los Angeles Flag Operations Liaison office activities. At various times I was responsible for preparing mission orders and briefing couriers that would smuggle money out of the United States. I was also responsible for sending various other missionaires to various parts of the country to go into Scientology organizations and force them to make more and more money. This was basically a form of "Regging."

8. The purpose of the registrar is to make more money all the time for Scientology. At the time, Scientology had various sales courses that taught registrars to strip resistance from people they were 'regging.' Registrars were taught how to push various buttons with regard to their mortality and their spirituality and their ability to be at peace as a being. Every button that could possibly pushed was pushed in order to get a person to make large advance payments. We got so good at it that we were sending $250,000 to $500,000 a week out of the Los Angeles area alone. The money would be sent out of the country to various places in the world including accounts in St. Hill, England.

Five, six and seven couriers a week would go out from Los Angeles with their little bundles of documents and their bundles of money hooked into it. We had a communication center that we delivered the missionaire to. The missionaires were fully briefed on how to get through customs and we would take them to the airport and send them where they were supposed to go which we learned from the Director of Communications. I was told by the Director, Bill Price, that there were five phony Scientology companies that existed at that time and were recognized by customs. As far as customs was concerned, these companies regularly sent businessmen all around the world. Internal operations were never allowed to know what was being sent to where. The only communications were from the Flag communicator, through coded telexes, saying exactly where anything was to go to Bill Price at any given time and how it was to go. We had the money couriers so well briefed as how to get through customs that they would not be sweating and would be totally calm and cool. They would overwhelm customs with pieces of paper if customs wanted to see them.


9. I understand and believe that sometime in 1973 and 1974, Hubbard's wife, Mary Sue Hubbard, had had enough of being constantly out at sea. She embarked on a campaign to convince Hubbard that the Sea Org ships were just a white elephant and that Scientology was paying too much money for what it got back and that the fleet should be disbanded and Hubbard's operation brought on shore.

10. Subsequently, it was decided to establish the Flag Land base at Clearwater in Florida.

11. Prior to the establishment of the Flag Land base in Clearwater, I actually saw the area on the Apollo where the Guardian's office financial people were engaged in a massive invoice altering project.2 My belief and understanding of the reason for the project was that discrepancies that could have been discovered between money `regged' or obtained from Scientology organizations in the United States and when it arrived on the Apollo, having previously been diverted in part to various accounts in Luxembourg,,Switzerland or other countries. When my wife and I came back from a Scientology mission to South Africa, we brought back $5,000 each (Rand). Although that was not a lot of money, it was money that was not supposed to go out of South Africa into the United States.


12. With regard to other scams, my understanding and belief is that U.S. registrars were taking in checks in the various Scientology organizations for huge amounts of money. The people who gave the checks could not possibly have covered those checks and yet the registrars were holding those checks and reporting them as gross income. This would increase the weekly statistics as Scientology requires. Later the registrars would try and coerce the parishioners into making good on the check. The registrars were not interested in whether the bank could cover the check or not. Here was a person who had knowingly written Scientology a bad check in the sum of $35,000-$40,000 and the registrars were now going back and convincing them to pay. Indeed, I personally pressured people to take out mortgages on their homes in order to pay for Scientology services. Moreover, at one point I put together a group of 8 or 10 registrars on the Excalibur, trained them up under Jim Douglas and forced collection of back monies from people who owed the Sea Org or Scientology money. In essence, I just put together a credit collection team and then started hitting the movie studios and others connected with the record companies to rent out use of the U.S. ships. At this time I was captain of the Excalibur which was an old navy ship. I had it rented out to a few movie studios and had money coming in. Indeed, we were making so much money that Scientology could not prove the ship was not financially viable because we were getting all this collection money. It was sometime after that Mary Sue Hubbard caused me to be subsequently transferred to the Apollo.


13. As proof of Hubbard's control over all of the Scientology regardless of corporate "structure" Hubbard had a [garbled] himself and the Sea Org (Flag). He would dream up a new course, initially taught only on Flag, such as the "Flag Executive Briefing Course" "Establishment Officers Course," "Ethics Officer Courts", etc. Flag would put together a course book and check sheet, Hubbard would write a few new policies and already [garbled] existing course." PR's dissemination would put together the "Ron's New " promotion. It would be issued as a Broad Public Issue and then Flag would "order" all Scientology units to send people to Flag to be trained. There was no choice about it. Orgs and/or missions had to comply. They were, of course, billed heavily by Flag. Eventually Ron would release the courses to S.O. Orgs to teach locally, but there again, Flag billed heavily for providing the course, course supervisor and materials. In most cases there was very little new material, mostly re-packaged already issued policies.

Where certain Class IV orgs or missions (Franchises) protected S.O. missions were sent in to remove the Executive Director and send them to Flag for Ethics Handling and rehabilitation. I was part of a mission to Austin, Texas Org to carry out that activity.

14. It was after I physically saw the Flagship's project of altering invoices that I decided to leave the ship. I was newly married and something told me that if I was on the ship with my wife and the IRS made a raid and discovered that these invoices were changed I may be in deep trouble myself. Accordingly, I went to Kerry Gleason who was in charge of Operations for Flag at the time and requested that he send me and my wife off on what turned out to be a 14-18 month mission around the world to help make money for Hubbard and his various organizations.


15. The Sea Organization was/is the most elite organization in Scientology. Sea Organization members owed their loyalty directly to Hubbard. I became a Sea Org member and signed the standard billion year contract. If Hubbard sent a Sea Org member on a mission to any Scientology organization, that Sea Org member had complete power. Indeed, that Sea Organization member could walk into any Scientology organization, remove the head of that organization and send him back to Flag or to the Rehabilitation Project Force ("RFP"). I personally observed the RPF when I was captain of the Excalibur. At times, I would have "up to" 34 RPF'ers on board. From time to time 'Flag' would send missions into various Scientology organizations in the Los Angeles area and then call me up and ask if I could use various gangs of RPF'ers to do certain projects. In fact, they used my RPF to move into the Chateau Elyses on Franklin Avenue. Moreover, when other organizations had too many RPF members they would just send the extras down to the ship. There, we could use them for painting, clearing the bilges and scrapping rust, etc. I never did any "over boarding", but I heard about the practice when I first came to the Sea Org.

16. Although there were many different Scientology corporations, they were really just shams. Scientology was a hierarchial ecclesiastical organization run from top to bottom by its ecclesiastical head, Hubbard. He maintained control through the Sea Org which permeated all corporations.

17. When I was on the Apollo, I witnessed them making a new Board of Directors for Operation Transport Corporation out of a couple of galley hands and some musicians. Mary Sue Hubbard picked them out and they signed the corporate papers where and when she told them.

18. The organization board (Org Board) is one way Hubbard maintained unity of control. Every Scientology corporation had the same Org Board and so duties were assigned in such a way that they were mirrored in every single Scientology or Dianetic Center in the world. Accordingly, there wasn't one post in `lag' that did not have somebody in each and every Scientology organization around the world as an opposite number. So orders were passed down into different people irrespective of whether they were in different corporations. Every corporation had a Hubbard Communications Office (HCO") ethics officer. They all had a publications officers, dissemination officers, treasure/finance personnel, etc. So orders were passed down into different people irrespective of whether they were in different corporations. For example, when I was running operations in Los Angeles, Flag would send me a set of mission orders. I would be instructed to put together a mission to do this or that. Then I would have to find a couple of people that were capable of doing it. Then I would write the mission orders for them to do it step by step, telling them exactly what they had to do. Then I would bring them in and brief them. I would get them to the point where I felt they were ready to go and do the mission. Then I would deliver the missionaires to the Communications Department which would get them onto a flight for wherever they were supposed to go and then get them back. The mission orders would also include getting the monies from the org to bring back with them. I would put in a request for monies for the missionaires, basically a budget estimate, what they would be spending and why, and that had to be accounted for when they came back. If the mission was successful or even unsuccessful, they would go into a briefing room and I would debrief them on every point in their mission orders. Any monies returned from the mission or the Org would go into the treasury division. From there an ACl or AC2 form would be completed by the Director of Income or the Treasury Director and funds could then be allocated to various activities set forth within that form and then sent to the Guardian's office for approval. It was really one big financial operation and Corporate Form had nothing to do with approved allocations.


19. The reason Hubbard had S.O. operating thetans (OTs) circulating was to create a state of awe. To give an example, when I went to Austin, Texas on a mission I had a tape recorder. For three days I was doing an analysis of the organization. I was running around, looking into and asking questions about everything. While I was making my rounds, I would be rewinding the tape recorder to listen to what I had said. I did not find out until four or five days later that these kids thought I was messing with the tape recorder. They thought I was an OT so essentially I could listen to the tape recorder at high speed. They expected I could do anything. They thought I could go out of my body (exteriorize) and they thought I could read their minds and in some ways I could, because after you have gone through the Scientology organization rigmarole, you learn how people make mistakes. You learn they are making them and how they are being reasonable and one of the sayings we used to use was a really intimidating statement: "Get back in valence." Valence is a term of differing characteristics of something from chemistry. The characteristics of a series of molecules, but Hubbard used it as a term for multiple personalities. According to Hubbard, your engrams from the past would cause multiple personalities, multiple characteristics that weren't really you but were functioning through you. Having someone "get back in valence" was a way of controlling them by getting them back into the present so that you could give them another set of directions that they would then comply with. They would get out of their destructive behavior pattern. Indeed, we used it all the time. If somebody was in fear or they were confused or something like that, we would say "get back in valence." And they would stop it. They wouldn't know what to do so you could then take them over. Accordingly, I believe Scientology practices do involve a form of hypnosis. In using the word hypnosis I am defining it as a means of altering awareness. One of the ways that you can hypnotize people is by all of the Scientology courses that get people into this train of thought that Hubbard was always right and if things were going wrong, there was something wrong with the individual in his application of Scientology processes and that had to be corrected by more auditing. Then someone with the Scientology authority would come along, usually a Sea Org member, Reg, or Guardian Office member, and all they had to do was use a couple of short command phrases to stop a person in their tracks and get them to feel that they were not doing what Hubbard said. We would use phrases from the Hubbard Philadelphia Doctorate tapes or anything that applied to the situation in order to get an altered awareness. Accordingly, it is my opinion that you cannot separate hypnosis and auditing. once you get someone to believe that there is substance to past lives, whether or not it is true from a real spiritual sense, mystical, meta-physical sense or whether it is true from a DNA sense, you have got someone to believe that there lS something that can be transferred from the past to the present. So, when you have someone that is desperately hoping to clear up all the bad karma from their past lives, the mind provides him or her with all the pictures he or she needs. The end product of the auditing session is to get the person to change his or her perception of life controlling them, to believing that he or she controls life. To get them to rewrite the script that they believe in, then that is hypnosis as far as I am concerned. While it works, to a degree I don't believe that it is a healthy way for a person to approach mental health. I believe it is far better to find out what the person doesn't understand in present time and get them to change their concepts about whatever it is they don't understand or whatever they are confused about on a voluntary basis and let them re-write their own scripts.


20. I had a friend who committed suicide after becoming involved in and leaving Scientology, and I am aware of other Scientology connected suicides. On the basis of my experience, education and training in Scientology, I believe there is a very strong connection between Scientology and suicide. Until someone has progressed through to Scientology Level OT3 (Operating Thetans 3) and has recognized the absurdity of Scientology, they retain a strong belief that auditing works and that what is wrong with them can be corrected through the auditing process. Moreover, the Ethics officers try to drive it into them that unless they confront various items and come back into the fold, that their very soul is lost. It is little different from the "Waco-Wackos." You have taken a person and convinced them that they must become `clear' of all these negative influences from present and past lives. They have spent several years going through these different and expensive courses and have been finding their life getting better and better and their communication skills improving. Even their fear of just looking somebody in the eye has been conquered through training routines such as (TRO). After a few years has passed, and all of these wins have been achieved, the hoax is ready to be sprung. They now believe that the only thing that will set them free is to go Clear and onto OT3. By then, their own belief systems are working in conjunction with the way Scientology is manipulating them. Moreover, they don't even consider Scientology to be manipulating. They just consider it reasonable and prudent to do what Hubbard says. Follow the policy and the Tech. At that point, if they stop auditing for whatever reason, they have trouble with the drug-like effect of auditing and go into a self-induced state which Hubbard used to call 'a spin.' If the person does not have any firm grasp of their location and universe, they are just like a melting butterball. They are mentally 'free-wheeling.' And if they have given most of their money already to Scientology, and are now unable to go back on line for auditing, they go into a really deep depression. It is almost like having an anchor dug into the bottom of the ocean, and then, when you pull it out, the ship starts to float. What Hubbard does is make Scientology, the policies, the courses, and the staff such an anchor"in people's lives that if they stop being audited they will 'free wheel' as Hubbard uses the word. Unless they are extremely strong people, and are somehow able to piece all these things together for themselves, they could easily go crazy or what is known in Scientology as PTS type 3 (Potential Trouble Source Type 3). Their depression can become so deep that they can and do commit suicide.

21. When I was in Scientology, I heard of Susan Meister being a supposed suicide.

I also heard of Quinton Hubbard's supposed suicide. Quinton was one of Hubbard's sons. He was a class 12 auditor whose specialty was to cure OT3's and one of the things that the OT3 level was supposed to handle was homosexuality. It was widely rumored that Quinton Hubbard was homosexual. Quinton Hubbard had completed the OT3 level and was a class 12 auditor. It was therefore an embarrassing enigma that Quinton Hubbard had not been cured of his homosexuality by Scientology and his homosexuality was also an embarrassment to his father. Because of this, I would not at all be surprised if the Guardian's Office was involved in manufacturing his supposed suicide.


22. While I was in the Sea Org, I was instructed to kill another human being by the Scientology organization. At the time Scientology had an office on Beacon Avenue in Los Angeles, very close to McArthur Park. I was called in for a briefing by Alex Sibryski. At that time, Scientology had a ranch at Rosarito in Mexico which was being used as a nursery, a place for overflow kids that could not be housed in Los Angeles and a place to grow fruits and vegetables. Mexican bandits were allegedly harassing and hustling the ranch and stealing produce from it. Jerry McDonald and I were asked to put together a mission to go down to Mexico, take some infrared optics and some guns and rifles, wait for the Mexican bandits to attack the ranch again and then take care of them. We were told to kill them if necessary. I received these orders from Alex Sibryski. At the time he was Commanding Officer Flag Operations Western U.S. ("F.O.L.O.W.U.S."). This was part of Scientology's elite Sea Organization. I was the Operations Officer at Flags Operations Liaison Office at the time and it was my job to write the mission orders for this thing and get us all briefed and ready to go. We figured that if we "took out" the bandit leaders the rest would disband. It took 24-48 hours to get this done and in the course of that time I never saw any written dispatches on this but the mission was then canceled by Alex Sibryski. He said that there was a governess in-charge of the ranch and that the bandits had tried to attack her at the place and she had shot the bandit leader with a shotgun through the door and taken care of the problem.

23. Jerry McDonald was widely rumored to have been a former mercenary and a paid assassin in Europe. He was known throughout the Sea Org for taking care of difficult problems. If someone was giving a problem in some area Jerry McDonald would just appear there. Because of his reputation as having been an assassin, if he came on the scene, people would fear for their lives. They believed that he was working totally for Scientology and that he would do anything for Hubbard. Additionally, he was also the kind of guy who would have people over to his house every now and then and would get out his automatic weapons, clean them and put them together in front of people. In this way, he would let people know that he was really conversant with his craft. He carried a 9 mm pistol on him all the time and he was always talking about arms sales and deals that he was doing. As things turned out, he and I were not required to carry out the instructions to kill that we had received. However, if the orders had not been canceled I have no doubt that he could have performed the task.


24. On the basis of my experience and knowledge of Scientology, I believe it very possible that Steven Fishman was ordered to engage in the securities class action fraud by Scientology, and then to murder Dr. Geertz and commit suicide.

For example, Alex Sibrisky's former Deputy Commander, Bill Foster, turned up at the Sea Org headquarters in New York and told me a story about being involved with some other guys in break-ins of United States government offices, and possibly one senator's office, where they had stolen materials that had to do with Scientology. He said that there were U.S. government agents after him and that Scientology and the Guardian's Office had hung him out to dry. He was going to have to take a fall. Scientology was going to deny any connection with his activities. I knew that he had been allegedly routed out of Scientology for some sort of bad financing practices in Boston a few years earlier. I recalled there were allegations of improper 'regging' (high pressure sales) practices. I thought this was strange at the time because it was not like the Guardian's Office to kick out real money makers. Neither was it like Hubbard to kick out real money makers anywhere. As a result'of this conversation, I called up the Guardian's office, Bob Reimer in Boston and said what's the deal on Bill. He goes ..., Bill? Bill Who? I said you know who I mean, and I told him the name and I said what's the deal on him, and all Bob said was that "he was expelled a couple of years ago." I then said "that's interesting because he is sitting right next to me here and he has just told me a story about" . . . and I started going into it. Bob said, "Don't talk about that on the phone." And I said, "So in other words, that does exist. That did exist and he has worked for you for the last two years undercover and nobody in Scientology knew that he was working on Guardian Office projects." Bob hedged and hemmed and hawed. Then I said, "Listen, I am in a position here where I have to decide whether to take on Flag or not over this guy because he is saying that he has been working for some Scientologist in the Guardian's Office all this time, but as far as everybody else in Scientology knows, this guy is persona non grata and an enemy of Scientology." So here I am, running Folo New York with my wife and this guy is asking me for asylum and wanting back on Scientology lines and he says he is being put out to dry. Moreover, Bob Reimer, head of the Guardian's Office in Boston at the time, is denying it. So I said, Bob, you've got to tell me the truth. I'd worked with Bob before and he knew I would know if he is lying. Basically, when he said don't talk about it over the phone I knew that they were afraid of somebody listening in, and so I said, did he work for you for the past two years under cover? And he said, well, yes.

I said Okay, thank you. So I then telexed 'Flag' and told them that Bill wanted back on (Scientology) lines and I told them that I did not know what was going on but I knew that he had been working under cover for the Guardian's Office for two years. He wanted his Commission back and he said he was being hung out to dry. I said Bob Reimer told me that he had been working on lines under cover for two years, I said I was putting Bill back to work. Then all hell broke loose. There were talks about what he could not do here and they wanted me to kick him out and send him packing. To force Flag and the G.O. to confront the situation I sent Bill on a mission to the Toronto Org and got him out of the country.


25. After leaving Scientology in 1976 I had managed to get Bob and Loy Young out of the Media Org at Flag. Bob Young was originally a Director of Marine Operations and Flag Operations Liaison Office. When they got to Los Angeles, he told me that he had a friendly contact in the Guardian's Office and was warned that he, his wife, myself and a few other people were on a hit list. I had no reason to doubt this information and so went into hiding. Scientology had already asked me to kill somebody, so why wouldn't they ask somebody else to kill me, I reasoned. Especially since I had been around virtually every Scientology organization in the world, had been in the books of almost every organization and knew all about the money being filtered from one place to another, knew about it, how they did it, the people who were responsible for it, etc. I knew about all the missionaires doing these various money smuggling operations and had briefed myriad missions myself during the early seventies. I was also briefed for perhaps 20 such missions myself. After those missions I was debriefed in confessionals or security checks to find out whether any money was juggled etc.

I had also seen the B-1 hat packs and other church materials dealing with how to conduct illegal and/or other activities. I was declared a suppressive person by the church and I knew from my knowledge of Scientology's fair game policy that I could therefore be tricked, lied to, or in any manner destroyed by any Scientologist, without that Scientologist being subjected to a Scientology Committee of Evidence for doing whatever they did to destroy me. Attached hereto as Exhibit B is a copy of an Executive Directive dated January 27, 1983 and being a List of Suppressive Persons. My name is on the lower right hand side of page 5.

26. A few weeks ago, I stopped working as paralegal and designated expert for the law firm of Lewis, D'Amato in this litigation because my research of Scientology activities since my departure in 1976-1977 caused me to become fearful for the security and safety of my mother, sister and friends and discovered through questioning same that they were all terrified of my involvement in the instant matter.

27. I have read the declaration by Robert Vaughn Young dated October 25, 1993 and the exhibits thereto dealing with Scientology's Fair Game policy and on the basis of my knowledge and experience within the Church of Scientology, I can state from my own knowledge, experience and training that its contents are true and correct.

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

Executed this [empty] day of March, 1994
at Los Angeles California.

Scott Mayer


Wherein the S.O. billed for services provided to Scientology organizations.

Wendall Reynolds, the Guardian's Office Flag Banking Office, took quite a deal of pride in showing me the project.


I am employed in the County of Los Angeles. I am over the age of 18 years and not a party to this within action; my business address is 221 North Figueroa Street, Suite 1200, Los Angeles, California 90012.

On March 9, 1994, I served on the interested parties in this action the within document entitled: DECLARATION OF SCOTT MAYER IN SUPPORT OF COST BILL FOR DR. GEERTZ'S MOTION FOR AWARD OF COSTS, EXPENSES, ATTORNEY'S FEES AND SANCTIONS

IX] by placing a true copy thereof enclosed in a sealed envelope addressed as follows:


(BY MAIL) I caused such envelope(s) with postage thereon fully prepaid, to be deposited with the United States Postal Service at Los Angeles, California.
I am readily familiar with the firm's practice for collection and processing of correspondence for mailing with the United States Postal Service. Said correspondence will be deposited with the United States Postal Service on this same day in the ordinary course of business. I am aware that upon motion of party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing as declared therein.

Executed on March 9 , 1994, at Los Angeles, California.

[ ]
(STATE) I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
(FEDERAL) I am employed by a member of the Bar of this Court at whose direction this service was made. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.
Marcia Schwartz


Mr. Steven Fishman
8851 Sunrise Lakes Boulevard, #116
Sunrise, Florida 33322-1413

Jonathan W. Lubell, Esq.
750 Lexington Avenue
New York, New York 10022

Robert Wiener, Esq.
6255 Sunset Boulevard, Suite 2000
Los Angeles, California 90028

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