DECLARATION OF STACY YOUNG
I, STACY YOUNG, declare as follows:
1. I was a member of the
Church of Scientology for fourteen (14) years, from January, 1975 until July,
1989. From October, 1979, until July, 1989, I was a member of the Sea Organization,
the most dedicated group of Scientologists in the entire organization. During
my tenure in Scientology I acquired extensive knowledge of the counseling methods,
as well as the administrative and management practices and procedures of the
2 . The facts set forth herein are of my own personal knowledge and I could and would be competently able to testify thereto.
3 . My first experience with
Scientology was at the mission of Atlanta, Georgia, where I attended a series
of introductory lectures in January, 1975. I received my first Scientology auditing
in Atlanta called "Life Repair" and I also took several courses.
4. I joined the Sea Organization ("Sea Org") at the Advanced Organization in Los Angeles ("AOLA") in October, 1975, signing a billion year contract to confirm my dedication to Scientology and "clearing the planet."
5 . All staff members involved in tho delivery of the confidential Upper Levels of Scientology processing ("OT Levels"), and all staff members involved in Scientology management are members of the Sea Org, living communally and under the authority of the Sea Org Command Lines 24 hours a day.
6 . At the end of 1977, I transferred to the United States Guardian's Office ("USGO") in Los Angeles. I was a staff member in the USGO from January, 1978 through January, 1982. The Guardian's Office was the part of Scientology that handled public relations, intelligence and legal matters for all of Scientology. The "USGO" was corporately part of the Church of Scientology of California ((XC). The Guardian's Office was renamed the "Office of Special Affairs" (OSA) in or about 1983.
7 . Starting in August, 1984, I worked in the Office of Special Affairs U.S. (OSA US). I wes assigned to handle public relations writing and to write articles for and edit a publication known as "Freedom" (discussed in further detail herein ). At that time the OSA US was part of the Church of Scientology of California (CSC).
8 . The office where I worked
in 1984 was in the Scientology "complex", formerly the Cedars of Lebanon Hospital,
This "complex" covers an entire block in Hollywood bordered by Sunset, North
Berendo, Fountain Avenue, and North Catalina.
9 . When I started working for OSA US, the OSA US offices were located on the third and fourth floors of a building in the "complex" known as the "American St. Hill Organization" or more commonly the "ASHO" Building.
10. It was common knowledge within OSA US that Lawrence Wollersheim, a former Scientologist, was suing CSC, and that Scientology and CSC had no intention of ever paying Wollersheim "one thin dime". The phrase "not one thin dime for Wollersheim" became a slogan for the Wollersheim case. .
11. In early 1985 the OSA US staff was briefed at a staff meeting about the "Wollersheim" case. The briefing was done by the Commanding Officer of OSA US, who as I recall, was David Butterworth at the time. The staff, including me, were told during the briefing that it looked as though Wollersheim might win his lawsuit. This would mean that the Court could order the corporation, CSC, to pay Wollersheim money, We all knew that this was a joke because CSC would never pay Wollersheim a cent. It was a matter of principal that Scientology would never pay an "enemy" like Wollersheim.
12. At this meeting we were briefed that Scientology's plan was to gut CSC of any and all assets. in this manner there would be nothing for Wollersheim to seize if he won his suit.
13. To accomplish this "gutting" the OSA US Treasury office and the Freedom Magazine office were to be moved, out of the "complex" and into an office across the street on North Catalina. The OSA US Treasury Office was going to be moved because that was where the financial records for CSC would be stored. The Freedom Magazine offices were going to be moved because it was a public office and would make it look like CSC was a functioning Corporation. In fact, money for Freedom would be funneled into CSC from other Scientology corporations to publish Freedom Magazine and for other projects. This money was always spent immediately so as to leave CSC without attachable assets.
14. The balance of the OSA US operations were to be transferred to another corporation or entity. If I recall correctly, these other OSA US operations became part of what is now known as the Church of ScientoLogy Western United States.
15. To the best of my knowledge, CSC was, for all intent and purposes "gutted" of any and all assets. These assets were transferred from CSC to other Scientology corporations. The asset transfers were for the express purpose of defeating Mr. Wollersheim's chances of ever collecting any money in this action.
16. I am aware that on or
about October 17, 1982, the Church of Scientology held a "U.S. Missionholders
Conference" in San Francisco. During the time I was a member of Scientology,
I became familiar with a multi-paged document entitled "International Management
Bulletin NBR 2 - Tools to Expand Your Org Reference Pack." This document was
directed 'to "All Org Staff, FOLO Staff and Flag." It was copyrighted in1982
by CSI. A true and correct copy of five pages of this document is attached to
my declaration as Exhibits "1-5". All copies have been reduced from legal to
standard size for purposes of this declaration. Exhibit "1" represents a copy
of the cover sheet of the "reference pack" of materials which contains 162 two-sided
pages. The reference pack consists of eight "executive directives" of various
dates. Exhibit "2" is a copy of the first page of the "reference pack" explaining
the purpose for distribution of the directives. Exhibit "3" is a true and correct
copy of executive directive SOED 2104 Int. dated 7 November 1982 and the first
eight pages of the transcript of the conference. The directive was a cover for
the transcript of the San Francisco Mission Holders Conference addressed by
"Commander David Miscavige," "Warrant officer Lyman Spurlock, Corporate Affairs
Director," and "Commander (RA) Norman Starkey," among others.
17, The covering directive identifies these individuals as "top officials of the Sea Organization." The Sea Organization '("Sea Org") is an unincorporated entity within Scientology which is the true structure of power within the Scientology empire. It is the Sea Org which Scientologists recognize as having power over them, not the corporate structure, which in fact is merely a hall of mirrors used to deal with the courts and to maintain tax exemption with the IRS. The corporate structure has nothing to do with the true hierarchy of Scientulogy. Internally, the corporate structure is ignored, not only in terms of authority but also regarding the flow of monies.
18. The transcript of the
San Francisco Mission Holders Conference offers a rare window through which
can be seen how power in Scientology is actually wielded. David Mizcavige was
Chairman of the Board of ASI , a for-profit corporation which was ostensibly
created to be a literary agency for Scientology founder L. Ron Hubbard. In reality,
Miscavige was running Scientology from his position as head of ASI when the
Mission Holders Conference was held. To the outside world, he presented himself
as COB ASI, but within the closed world of Scientology, he was Commander David
Miscavige, head of The Sea Org and thus, the head of Scientology.
19. "Warrant Officer" was Lyman Spurlock's Sea Org designation, but he was also the Corporate Affairs Director at ASI. It was from his position in this for-profit company that he orchestrated the corporate restructuring of Scientology, which was then announced at the Mission Holders Conference. "Commander (RA)" was Norman Starkey's Sea Org designation, but he was also the Deputy Executive Director for Legal Affairs at ASI (later to become Executive Director of ASI, directly under Miscavige).
20. Exhibits "4" and "5" It are true and correct copies of display charts used by Mr. Spurlock when he addressed the Conference. These documents specifically delineate how the various entities that were operating as the Church of Scientology of California, the "Mother Church of Scientology" were taken over and systematically stripped of all of its divisions, functions and assets by RTC (Religious Technology Center) and CSI (Church of Scientology International). This is Scientology's own version of their reorganization. Before Church of Scientology International (CSI) was formed in late 1981, Church of Scientology of California (CSC) was the "Mother Church". Exhibit "4" reflects the various church entities that were included as part of CSC at that time, including WDC (Watch Dog Committee); FSO (Flag Service Organization); ASHO (American St. Hill Organization); Church of Scientology Los Angeles; Church of Scientology San Francisco; USGO (U.S. Guardian Office), etc. The FSO, Los Angeles and San Francisco, entities were major sources of income for CSC.
21. Exhibit "5", the second chart, displays the end result of the "reorganization" that effectively gutted the assets and divisions of Church of Scientology California wherein CSC's divisions, Punctions and assets were rolled over into the newly formed corporations, Religious Technology Center (RTC) and Church of Scientology International (CSI). As noted in Exhibit "5", after "reorganization" CSI became the Mother Church and all the divisions, functions and assets of CSC such as the WDC, the Flag Service Organization and the San Yrancisco and Los Angeles Churches of Scientology were now controlled by CSI. The reorganization also diverted all revenue flow from CSC to CSI and RTC.
22. Based upon everything I know, and everything I observed while I was a member of Scientology, I believe that Scientology transferred all of the assets out of CSC after the filing of Mr. Wollershsim's lawsuit for the express purposes of preventing Mr. Wollersheim from recovering any money as a result of the Lawsuit.
23. While in the U.S. Guardian's
Office from 1978 to 1982, I was posted as the Organizing Officer ("Org Officer")
for the Public Relations Bureau, and later, as the Org Officer for the entire
Guardian's Office. As the Org Officer, my functions included the handling of
all personnel and organizational matters, such as correcting a staff member
who made mistakes, getting staff members into auditing or ethics handling when
they were sick or upset or in trouble, recruiting new people for staff, and
promoting or demoting staff members ae needed. I was also responsible for the
establishment and proper administration of all the Guardian's Office personnel
throughout the United States. As the Guardian's Office oversaw certain aspects
of the administration of all other Scientology organizations, I became very
familiar with the overall structure of Scientology and how the various organizatiuns
interact with each other and with the outside world.
24. In early 1982, I was posted as the Special Project PR Assistant under my husband, Robert Vaughn Young. Several months later, Special Project became what is now Author Services, Inc. (ASI) as described earlier, a for-profit company whose ostensible purpose was to be L. Ron Hubbard's literary agency. I was taken out of PR and made the Organizing Officer for ASI in April, 1982. Miscavige appointed Terri Gamboa Executive Director of ASI. He gave Norman Starkey the title of Legal Affairs Director of ASI. He gave Lyman Spurlock the title Corporate Affairs Director. In my position as organizing officer, I worked directly under David Miscavige, who was chairman of the Board of ASI, ("COB ASI"), to carry out his orders concerning the staff of ASI.
25. David Miscavige, known
as DM, has been the head of Scientology since 1981. He ran the Scientology Empire
from ASI until early 1987. He moved the seat of power of Scientology from ASI
to the Religious Technology Center ("RTC") in 1987, during a period of time
when the IRS wall investigating ASI's ties to the non-profit corporations of
Scientology. At that point, he appointed himself Chairman of the Board of RTC,
which is his current title. The fact is that Miscavige runs Scientology as a
dictator regardless of which corporation he is part of. The corporate structure
of Scientology is purely a cloak used to shield Scientology from all outside
26, Although ASI was established as a for-profit, non- religious corporation, in reality, while DM was COB ASI, the staff of ASI ran the entire Scientology network. This included the Church of Scientology of California, ASI had complete control over the management of all Scientology orgs and missions, all Office of Special Affairs activities (the Office of Special Affairs is the successor organization to the functions previously performed by the Guardian's Office), all transfers of funds between Church accounts and LRH accounts, every aspect of life of anyone who was a Scientologist, whether staff or public, (These powers were moved to RTC in 1987, when Miscavige appointed himself COB RTC.)
27. Because of my experience in ASI, I am familiar with the day-to-day activities of the highest level of management of Scientology. I have first hand knowledge of the establishment of the corporate structure of Scientology as it now exists, having worked with the staff who are responsible for creating it. The purpose of this activity was to create an impenetrable, legally defensible network of corporations such that neither the IRS nor any legitimate agency of government or any private individual engaged in a lawsuit against Scientology could "pierce the corporate veil" of Scientolagy organizations, thereby freeing Scientology management to transfer funds between organizations without concern for the law.
28. I can state from personal knowledge from my observation within Scientology that all Scientology corporations are a sham and that David Miscavige and his key aides can and do control every aspect of every Scientology corporation and can at any time directly take over and seize alI practical control of any and all Scientology corporations.
29. David Miscavige wields
such absolute authority over the entities known as Church of Scientology International
and Religious Technology Center that he should be recognized legally as the
managing agent of these two entities. It was true at the time I left in 1989
and I believe it is still true that both CSI and RTC have their seats of power
at the secret Scientology management compound in Gilman Hot Springs, California,
where Miscavige also lives and works. Nothing happens at the compound in Gilman
Hot Springs without Miscavige's direct approval or the approval of his circle
of aides, from the daily and weekly management of Scientology organizations
and finances around the world to the minute.details of the daily operations
of the compound..
I declare under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct.
Executed this 13th day of March, 1997, at Seattle, Washington.