I, VICKI J. AZNARAN, hereby declare as follows:
1. I am over 18 years of age and a resident of the State of Texas. I have personal knowledge of the matters set forth herein and, if called upon to do so, could and would competently testify thereto.
2. On May 4, 1994, my husband and I each executed a series of declarations under penalty of perjury addressing a variety of issues. Among those declarations are one of mine that demonstrates that perhaps the most common litigation ploy that is used against Churches of Scientology is for opponents to submit false, inflammatory and accusatory declarations which make wild accusations irrespective of their falsity, lack of relevance, or lack of first hand knowledge.
3. I am executing this declaration on May 19, 1994 because I am certain that litigation opponents of the Church will react to one or more of my other contemporaneously dated declarations in precisely the fashion I describe in the preceding paragraph. Someone who knows nothing whatsoever of what transpired or why my husband and I have executed the May Lq1 1994 declarations will accuse us of "selling out" or being "bought out" or being forced by the Church to swear to matters that are not true.
4. Whoever makes any of those allegations or any similar allegations has no factual basis to make such a claim and has no knowledge of any of the pertinent facts. Their allegations are lies. The fact that they would make such an allegation at all is merely corroboration of my declaration of this date that litigation opponents of the Church will "just allege it" even if they have no competent evidence or facts. It is merely more evidence that they engage in a pattern of just alleging anything which forwards their positions, regardless of their truth. The statements I have made in my declaration are factual-and true and people who played no part in my independent decision to sign this and my other May ICT 1994 declarations know no facts to the contrary.
5. I have written this declaration as I know, both from my experience when a member of the Church, and since leaving the Church, that Church adversaries have routinely falsely alleged such actions against the Church. I also know both from my experience within the Church and from my experience since leaving, that these allegations are false and intended to incite prejudice against Scientology, which is then forced to defend itself and to attempt to overcome such charges.
I declare under the penalty of perjury under the laws of the United States of America, and under the laws of each individual state thereof, including the laws of the states of California and Texas, that the foregoing is true and correct.
Executed this 19th day of May, 1994 in Dallas, Texas.