DECLARATION OF ROBERT VAUGHN YOUNG
ROBERT VAUGHN YOUNG, declare
1. I was a member of the Church of Scientology for twenty years from 1969 to 1989. For fifteen of those twenty years, I lived communally in the Church's organization. During my twenty years with the Church, I acquired extensive information and training in the methods of Scientology. I have worked directly with every phase and aspect Of Scientology from introductory levels to the highest management echelons.
2. The matters set forth herein are of my own personal knowledge and I could and would competently testify thereto. In my various capacities, I have had occasion to work directly with Scientology organizations and staff members in at least a dozen countries. Material that I produced was used in every Scientology organization at one time. I know the Scientology corporate structures and how they interlock. I am also familiar with the "secular" side of Scientology, groups that appear to be outside of the Church of Scientology but which are operated by the Scientology hierarchy. I have also completed what the Church considers to be one of its most confidential levels of personal counseling.
3. In 1968, I began studying Scientology while working in the Ph.D. program at the University of California, Davis. I even used Scientology books in the philosophy courses that I was teaching. In 1969, I left the Ph.D. program to help start the Dianetics and Scientology Mission of Davis. My functions at the Dianetics and Scientology Mission of Davis included giving introductory lectures, supervising the communications course, giving professional Dianetic auditing and handling of public
relations for the Mission.
4. In early 1971, I joined
the Guardian's Office of the church of Scientology, San Francisco. This organization
is presently titled the "Office of Special Affairs" or "OSA".
The Guardian's Office was that part of Scientology which dealt with external
matters such as media, lawsuits and government.
5. Upon joining the Guardian's
Office, I was immediately sent to Los Angeles for training in Public Relations
(commonly referred to as "PR" within Scientology). During my PR training,
I was required to study various official investigations into Scientology. I
also studied the press files which were extensive. I was also able to read internal
dispatches about these situations and problems with the media. My PR training
also included studying confidential material written by Scientology founder
L. Ron Hubbard and Guardian Office (GO) personnel on how to handle public relations.
This confidential material was viewed only by authorized GO personnel like myself.
The material was on defining, identifying and dealing with those viewed as enemies
of L.Ron Hubbard and Scientology.
In addition, my PR training
included "drills" which were exercises to teach me basic PR skills
such as how to write press releases, give press conferences, how to respond
to reporter's questions, how to divert a reporter, and how to avoid questions.
I underwent a "mini-hat" instruction to enable me to temporarily manage
other bureaus such as the Intelligence Bureau which ran Covert operations.
6. I was also trained and briefed from 1971 onwards on Scientology as a religion. At no time in nearly twenty years was the purpose of our image as a church ever designed or executed as anything but a PR, tax or legal ploy. However, there were occasions when Scientology or L. Ron Hubbard had to assume a secular mode and so I was also trained how to also make him and Scientology appear to be secular and how we could easily switch from one mode to the next, depending on the need. I was also trained on special circumstances, such as in Mexico, where we had to pretend to be Dianetics. We often practiced our responses. Thus if the audience were business people, we could promote our or Hubbard's secular side. If we were attacked, we would switch to a religious facade. This strategy came from Hubbard himself and I was privy to it.
7. When I completed my
PR training, I returned to San Francisco where I assumed the position of Assistant
Guardian (AG) and ran all bureaus. She was gone for perhaps four months. While
I was serving as the AG, the San Francisco organization encountered a severe
financial crisis. With the advice of the Guardian's Office U.S. in Los Angeles,
I stepped in, seized the accounts and ran the entire organization until it returned
to solvency. This experience taught me the financial structure of Scientology.
8. As the AG, I conducted
internal investigations into personnel in the organization by reviewing their
ethics files, personnel files and auditing folders. I learned how to alter records
in the organization to mask the trail of personnel going to the Intelligence
Bureau so that they could not be traced back to Scientology. It was standard
practice to destroy or alter records so that there was not trace of the persons
responsible for covert acts in the event that law enforcement should try to
9. As the Public Relations
Officer (PRO), I took orders from the Guardian's Office US (Los Angeles) and
the Guardian's Office World Wide (in England). I worked with all media in Northern
10. In late 1973, I was promoted from the San Francisco office to the Guardian's Office U.S. (GOUS) located in Los Angeles where I had previously received my PR training. GOUS's function was to direct and run all Guardian's Offices in the United States as well as Mexico.
My first assignment with
GOUS was to be the Public Relations Establishment Officer (PR EstO) where I
was to work with all personnel in the PR US Bureau. I also handled the budget
for the bureau, called the "FP" or "Financial Planning."
This was done in liaison with other bureaus. This position allowed me to learn
all functions in the PR US Bureau and how the finances for the continental office
11. After a few months'
of serving as the PR EstO, I was assigned to the position of Public Relations
Liaison US (PRL US). During this time, I was in charge of the PR section of
the most secret and largest program of the Guardian's Office - the "Snow
White Program." The "Snow White Program" consisted of several
programs written by L. Ron Hubbard and was designed to ferret out the source
of international criticism of Scientology. There were people assigned to each
bureau to carry out the Snow White program. As the PRL US, I was afforded the
come familiar with dozens of Scientology organization across the United States.
12. While working in the
Snow White Program, I was directly responsible for obtaining a number of key
acceptances and/or religious recognition from federal agencies for the Church
of Scientology. These came to the Church of Scientology on federal agency letterhead
and were addressed to me, giving Scientology Some form of acceptances, recognition
or permission, These came from various agencies such as the Department of Labor
and the Department of State. These letters to me were subsequently used widely
by Scientology in the media, in publications and in law suits to show how Scientology
had been accepted as a religion.
13. During this time, I
helped form front groups that were nothing but letterhead such as the National
Commission on Law Enforcement & Social Justice. While working in the Snow
White Program, I was able to obtain information that the International Criminal
Police Organization (Interpol) had a Nazi history. Once this information was
disclosed, it enabled Scientology to gain considerable media coverage for years
around the world. As a result, I testified twice before Congressional Subcommittees
and appeared on radio and television shows. For my success, the Church sent
me to England where the Guardian's Office World Wide (GOWW) was located. At
GOWW, I was given additional training in PR and learned further how the other
bureaus worked, especially in other countries. I was thus given an international
perspective in Scientology PR, Finance, Legal and Intelligence.
14. In July, 1977, the
Federal Bureau of Investigation (FBI) raided Scientology headquarters in Los
Angeles and Washington D.C. The Guardian's Office selected me as the National
spokesman for Scientology and briefed me as to what to say at the press conferences.
The FBI raid resulted in the conviction of L. Ron Hubbard's wife, Mary Sue as
well as ten other Guardian's Office personnel.
15. Before the trial of
Mary Sue Hubbard and the Guardian's Office personnel, I was given access to
the documents that the government was going to use at trial. I read and reviewed
thousands of highly confidential transmittals including communications with
the highest executives in Scientology. In 1979, while preparing for that trial,
I was sent to Washington D.C. to counter the negative publicity that Scientology
was getting with propaganda that was pro-Scientology, I wrote stories which
were published in Scientology publications such as 'Freedom"magazine.
16. After the trial and
conviction of the GO personnel, I returned to Los Angeles to head the Specialist
Branch at PR US which created Scientology propaganda booklets and publications.
It was there that I authored or helped on various articles and Books on Scientology.
17. About 1978, I joined
the Sea Organization ("Sea Org" or "SO") in Los Angeles,
where I trained as a Sea Org member. I also know how the Sea Organization, an
unincorporated entity, is touted to be a mere fraternal organization, as if
it has no power. It is, in truth, the actual infra-structure that I and others
used to direct, control and operate Scientology, whether it be "church"
or "secular". I lived communally with other Sea Org staff members
and therefore am intimately familiar with the Sea Org life style.
18. In 1980, I was informed
that the secret hiding place of L. Ron Hubbard near Hemet, California was about
to be exposed in the media. The location was also the secret international headquarters
of Scientology. The Guardian's Office ordered me to take command of the base.
With the permission of Mary Sue Hubbard, I converted it to look like a film
and tape production studio so that the media would not discover the true nature
of the base at Gilman Hot Springs, California.
19. In 1981, I was asked
to gather information from non-GO archives about L. Ron Hubbard in preparation
of his biography. The archives were run by Gerry Armstrong and contained about
25 filing cabinets full of Hubbard's personal papers and memorabilia. When Gerry
Armstrong disappeared from archives, I was left in charge of Hubbard's private
papers and able to read them in great detail.
20. In 1982, I joined "Special Project" which was being run by David Miscavige, the current head of the Church of Scientology. Special Project later became "Author's Services, Inc." (a.k.a. "ASI"). ASI was a for-profit group ostensibly created to serve as Hubbard's literary agency. The actual functions of ASI were three-fold;
1) to run the "All-Clear Mission" which was supposed to get rid of all lawsuits against L. Ron Hubbard;
2) make money for L. Ron Hubbard; and
3) run the Church of Scientology.
To the extent that ASI
ran the "All-Clear Mission", ASI was running the Guardian's Office
/OSA which was responsible for handling the suits.
21. Since ASI was the senior
Scientology organization, regular and numerous legal strategic meetings with
the Office of Special Affairs personnel were held at ASI. I was able to sit
in many of these meetings.
22. While a public relations
executive with ASI, I directed the operations of Hubbard's personal international
public relations network which operated in the Church of Scientology. The international
head of that network reported directly to me. I held meetings with these staffs
on church, as well as ASI property, and directed their training as well as their
23. While at ASI, I was
personally sent to the base at Gilman Hot Springs to handle various situations.
This base contained the film and tape production unit known as Golden Era Studios
as well as the international management organization that ran all of Scientology,
from the church to the "secular" side such as WISE (World Institute
of Scientology Enterprises.) I also gave a number of briefings to the entire
base. On many occasions, this was on Hubbard's direct orders. I handled personnel
and situations at every echelon, from musicians to members of the Watchdog Committee,
which was touted as the most senior body in the Church of Scientology. I was
thus privy to statistics as well as reports from around the world on the operations
24. Because of my position,
I have also been privy to the creation and restructuring of corporations within
Scientology much of this was done at Hubbard's direction. The purpose was usually
to mask his or our role in ASI when it came to running Scientology and yet to
facilitate the takeover of any group should it run out of control.
25. Since the FBI raids
in 1977 decimated the Church of Scientology's Intelligence Bureau, ASI became
the focal point for "intelligence." In an effort to prevent convictions
of Church personnel like those that occurred in 1977 from happening again, it
was decided that the more "sensitive" work was to be assigned to attorneys
and private investigators and call it "attorney work product." As
a result, I am familiar with how the legal and investigative arms of Scientology
came to be developed after the Guardian's Office was renamed the Office of Special
26. When the Church of
Scientology sued Gerry Armstrong (the man described above as controlling L.
Ron Hubbard's archives) in 1984, I was assigned to research Hubbard's life to
refute Armstrong's claims that Hubbard had lied to members of the Church of
Scientology. During the Armstrong trial, the Church called me as an expert witness
to testify as to what I found in my research on L. Ron Hubbard's life.
27. When L. Ron Hubbard
died in hiding in 1986, I was one of perhaps ten people selected to go that
night to the site of his death to handle the situation. My task was to deal
with the media and my effort appeared in a great many news stories.
28. After L. Ron Hubbard's death, a power struggle ensued between Pat Broeker and David Miscavige. David Miscavige won and consequently consolidated his position as head of Scientology- Since I was--viewed as being aligned with Broeker, I ended up on the "Rehabilitation Project Force" (RPF), which was a hard labor camp operated by the Church of Scientology at Gilman Hot Springs, California. Those sent to the RPF are kept under 24 hour guard until the Church believes that the prisoner is "rehabilitated" i.e. no longer thinking things which are critical of David Miscavige, Hubbard or how Scientology is operated. After 14 months on the RPF, I was considered "rehabilitated" and was reassigned to ASI by David Miscavige where I was assigned the task of producing "Ron Mags," a publication initiated by my wife and I in 1982 about L. Ron Hubbard.
When I refused to follow an illegal order several months later, I was physically assaulted and beaten by Norman Sharkey, Trustee. When I said I wanted to leave ASI and be assigned to the Office of Special Affairs, I was taken to the base at Gilman Hot Springs, California, for further "handling" by Greg Wilhere, the Inspector General, supposedly the highest ranking position in Scientology. When I did not change my attitude and I asked Wilhere about my status, I was told I was not going to be allowed to leave.
Pretending to be better,
I was subsequently allowed to visit my wife in Los Angeles. On July 3, 1989,
after filing a report with church attorney Kendrick Moxon about the beating
at ASI, my wife and I fled Los Angeles with a few items of clothing, leaving
the rest of our personal belongings behind.
29. After about two months
of travel, my wife and I finally settled in San Diego, California, to begin
our lives over. I subsequently began to write for a number of publications and
have won awards from the Society of Professional Journalists and the San Diego
31. As a longtime Scientologist,
staff member and a highly experienced and trained public relations specialist
(hereinafter " PR " ) I was and am familiar with Sterling Management
and the role they play in Scientology which was not unlike the roles I handled
as a PR many times.
30. After my wife and I
fled Scientology, we wanted to simply put it behind us. We wanted no contact
with anyone. All we wanted to do was to reconstruct our lives, without the fear
that we would be locked in a room and interrogated for days and even beaten
to force compliance or - if one will not comply - be dragged off to a gulag
and be kept under guard while working at hard labor until we were "rehabilitated."
That is the fear that Scientology imposes on its staff and that was the nightmare
we wanted to never see again.
31. When obtaining writing
jobs, I kept my Scientology background hidden because I needed time to recover.
I also knew that Scientology executives would monitor us to see how we felt.
This is done with private detectives who rummage through your trash, interview
neighbors,etc., to see if we were planning to make any publicly critical remarks
about Scientology. If they found that I was discussing Scientology with anyone
(and this I could be for professional, religious or medical reasons), they would
institute Fair Game, doctrine I will discuss shortly.
32. After more than three
years of this existence, three years of trying to hide my past, I began to come
to grips with what happened. I began to read texts that were forbidden to Scientologists.
(Scientologist cannot exercise their basic constitutional rights and read what
they wish, say what they wish and associate with whom they wish.) The first
book was Jon Atack's A Piece of Blue Sky. I had never spoken to or met Atack.
All I did was read the book. As I did, I realized that I had lived in an artificial
world in Scientology and had created another since leaving. I also realized
that I had friends back in the organization who were also suffering and that
as long as
people such as David Miscavige and Norman Starkey and Marty Rathbun and the others were allowed to terrorize and intimidate and harass and then dress in tuxedos like Mafia dons and pretend there was no blood on their hands, the abuse would only grow.
33. I also realized that
there had never been a person like me to have left Scientology, nor a couple
like my wife and me. Between us we had 35 years in the highest echelons. I knew
virtually every phase and level of activity. I knew the policies and directives
and orders that told us how to lie, deceive, bully, harass and destroy people.
34. I knew without a doubt
that if we spoke out, they would seek to destroy my wife and me. This is not
said lightly. I spent 20 years in those sections of Scientology where the lives
of "enemies" - from apostates to journalists to judges - were made
targets of destruction. I knew how Miscavige was ready to spend millions to
destroy anyone. I have sat in on those conferences as one of his top aides.
I heard the screaming profanities as people were ordered to "get"
a person at all costs. I also knew that the smiling, cordial attitude given
to the courts and the media was a facade that we practiced and how we laughed
later how a judge or journalist was fooled. I knew all those schemes and which
Hubbard "scriptures" told us to destroy anyone in Scientology's path.
That is why I have undertaken additional security measures including briefing
local law enforcement as to our situation.
35. One of the first results
of my decision was a feature article that I wrote for Quill, the publication
of the Society of Professional Journalists, titled, "Scientology: From
Inside Out," (Exhibit "A") My credentials for being published
in a professional journal that has included Pulitzer Prize winners is stated
in the article. I wrote it to try to educate the media on how Scientology abuses
and misleads them and what they can do about it. I wrote it after reading a
piece in Quill published two years earlier by Los Angeles Times writer Robert
Welkos who told how he had been the target of Fair Game when writing about Scientology.
(Exhibit "B") After reading it, I realized that it was not right that
such abuse continue in the media as well as the courts and that it was time
to speak out.
36. This was not an easy
decision. By speaking out, exercising my constitutional right, by being willing
to present sworn testimony, I am an "enemy" to Scientology. No Scientologist
questions this because Hubbard is senior to the Constitution and to the law.
They are willing to abrogate their rights' and even their lives to his will.
I am no longer willing to do so. I wish to present my sworn statements as to
the truth of the organization.
37. I have already served as a Scientology expert consultant to attorneys involved with a Scientology case in Michigan (Dickerson v. Sally Jesse Raphael, et al.; Washtenaw County Case Number NG-WA-92-007117 NZ). I am also serving as a Scientology expert in a case where Scientology is suing over a 1991 article in Time magazine. (Church of Scientology v. Steven Fishman and Uwe Geertz in US District Court, Central District of California, Case No. 910642HLH J (TX).)
38. I have been asked
to serve as a Scientology expert consultant in the case in which this declaration
is filed, Sterling Management v. Cult Awareness Network and have already filed
a declaration. My declaration explained why, although the Church of Scientology
and Sterling Management are two corporate entities, they are not truly separate.
What Scientology presents to the courts and to any legal entity is entirely
different from the actual practice conducted each day within Scientology.
39. Scientology executives
don't want me to testify to a truth that is known and accepted and even applauded
within Scientology. The reason is the same as if it were the Mafia: I am telling
people outside the secret circle, For that, a person becomes "Fair Game."
40. Hubbard's Fair Game
doctrine has already come into play in this case. It is directed at me and my
family for my willingness to expose it. The following is a documented account
of what Fair Game is and how it works.
41. Scientology seeks and
tries to crush and destroy what it feels are its "enemies." It tries
to use the courts to do this. The target can be an apostate, a potential witness,
an attorney or even a judge.
42. This end-justifies-the-means
method of retaliation is called Fair Game, a doctrine that Scientology officials
have insisted was cancelled in 1968. This is not true. I was in the movement
for over 20 years, from 1968-1989, much of that in echelons that dealt with
"enemies" of Scientology and so I know intimately that the practice
never stopped and cannot stop. The reason is that it is in the writings of Scientology
Founder Lafayette Ronald Hubbard which are now deemed "scripture."
Since, according to Scientology policy, no one but Hubbard can cancel or revise
his writings ("scriptures"), and since Hubbard died in 1986, his existent
writings stand. I will draw from those writings.
43. Fair Game is basically
the Hubbard doctrine that "enemies" of Scientology can and should
be destroyed. It is the product of a man that grew so paranoid that he lived
in hiding, under an assumed name and disguise, pretending this lifestyle was
part of his "research."
44. In 1955, Hubbard laid the groundwork for Fair Game in "The Scientologist: A Manual on the Dissemination of Material." In it he offers two instances when a Scientologist must attack: if arrested and if sued. Hubbard's orders what to do are clear. The following are excerpts from that "scripture":
flame to dance on the courthouse roof until everybody has apologized profusely
. . .
The DEFENSE of anything
is UNTENABLE. The only way to defend anything is to ATTACK . . . NEVER
BE INTERESTED IN CHARGES. DO, yourself, much MORE CHARGING, and you will
45. On using the law to harass (from the same text):
|"The purpose or the suit is to harass and discourage rather than to win. The law can be used very easily to harass and enough harassment on somebody who is simply on the thin edge anyway, sell knowing that he is not authorized, will generally be sufficient to cause his professional decrease. If possible, of course, ruin him utterly."|
46. There is also "investigation", Hubbard said in the same document. This is used when you want "somebody haunted." The purpose, he said, was to "crush" the people with what is called a "noisy investigation.":
|"When we investigate, we do so noisily always. And usually mere investigation stamps out the trouble even when we discover no really pertinent facts. Remember that - by investigation alone we can curb pushes and crush wildcat people and unethical 'Dianetics and Scientology' organizations."|
short, Hubbard (who died in hiding) felt that everyone should be as terrified
of an investigation as he was.
47. A few years later, Hubbard introduced the notion of manufacturing evidence against an enemy. In "Department of Government Affairs"(August 15, 1960) Hubbard wrote:
|"If we are attacked on some vulnerable point by anyone or anything or any organization, always find or manufacture enough threat against them to cause them to sue for peace. Peace is bought with an exchange of advantage, so make the advantage and then settle. Don't ever defend. Always attack."|
48. In the same "scripture" he said:
|"The goal . . , is to bring the government and hostile philosophies or societies into a state of complete compliance with the goals of Scientology. This is done by high level ability to control and in its absence by low level ability to overwhelm. Introvert such agencies, control such agencies. Scientology is the only game on Earth where everybody wins. There is no overt in bringing good order."|
49. An "overt"
in Scientology is a transgression, a wrong, In unethical act. What Hubbard is
saying is that no crime can committed as long as one's actions are "bringing
good order." This is what permits Fair Game in Scientology, that the non-
Hubbard laws can be broken when pursuing "enemies."
50. The doctrine of "Fair Game" was modified on March 7, 1965, when Hubbard issued "Suppressive Acts: Suppression of Scientology and Scientologists: The Fair Game Law". Hubbard wrote: "By FAIR GAME is meant, without rights for self, possessions or position, and no Scientologist may be brought before a Committee of Evidence or punished for any action taken against a Suppressive Person or Group during the period that person or group is 'fair game'." (A revision of December 23, 1965 changed it to read, "By FAIR GAME is meant, may not be further protected by the codes and disciplines of Scientology or the rights of a Scientologist.")
As to what was a "suppressive
person" Hubbard gave the definition: "A SUPPRESSIVE PERSON or GROUP
is one that actively seeks to suppress or damage Scientology or a Scientologist
by Suppressive Acts."
are calculated to impede or destroy Scientology or a Scientologist and which
are listed at length in this policy letter." Some of the suppressive acts
listed included "public disavowal of Scientology"; "public statements
against Scientology"; asking for a refund of fees paid; and "writing
anti-Scientology letters to the press." Even turning a Scientologist into
the proper authorities can gain one the label of a suppressive. The issue also
prohibits "1st degree murder, arson, disintegration of persons or belongings
not guilty of suppressive acts." (emphasis added)
51. A few months later, Hubbard gave specific orders on how to apply the Fair Game doctrine in HCO Executive letter 27 September 1965 on "Amprinistics". This was what he called a "splinter"group, a group that was using Scientology methods without his control. Hubbard's three-page issue blasts the Amprinistics leaders with a variety of sexual charges (one of his favorite topics for accusations) and says what should be done:
|"They are each fair game, can be sued or harassed [sic]. Corner can be barred out of any Commonwealth Country or England as he was the subject of a deportation order from England and his file has come alive again in the Home Secretary's Office. Harry Thompson's wives and victims are always looking for him to have him arrested. Watson is a set up for arrest as a homosexual. Any meeting held by them should be torn up. The names of any persons attended should be collected and they should be labeled SP [suppressive person] as they have left Scientology. . . . If these persons move into your area act through any agency you can to have them deported or arrested on whatever grounds. . . . Horner's UK deportation order, Thompson's police record and Watson's homosexuality make them very vulnerable to deportation or arrest. Hubbard does not stop there. He goes on to issue a five step-order that includes: (2) Harass these persons in any possible way. . . (4) Tear up any meeting held and get the names of those attending and issue SP orders on them and you'll have lost a lot of rats."|
This order is one of the
clearest examples of Hubbard's Fair Game doctrine. What he wrote has never been
cancelled and thus is still "scripture."
52. In 1966, Hubbard began
to codify those sections of Scientology that would implement Fair Game. For
example, on February 17, 1966, he created the Public Investigation Section with
a policy letter of that name and date. He said it would serve "the useful
functions of an intelligence and propaganda agency. It finds the data and sees
that it gets action." The statistic of the unit included "the number
of derogatory news stories appearing that week related to enemies of Scientology."
53. Hubbard also urged
the priority of finding evidence of "murder, assault, destruction, violence,
sex and dishonesty, in that order. Investigations which can uncover these factors
in the activities of individuals or a group attacking Scientology are valuable
in the degree that they contain a number of these factors." And note that
Hubbard's use of such evidence is not for law enforcement but to the media.
"In that way," he wrote, "we then get rid of suppressive groups
by investigation and disclosure."
54. On February 25, 1966,
Hubbard wrote an "Attacks on Scientology" policy letter, in which
he said to "Start feeding lurid, blood sex crime actual evidence on the
attackers to the press."
55. On October 18, 1967,
he issued "Penalties for Lower Conditions", whereby Fair Game was
automatically issued on anyone (including staff members) who was an "enemy."
They were, he said Fair game. May be deprived of property or injured by any
means by any Scientologist without any discipline of the Scientologist. "May
be tricked, sued or lied to or destroyed." (Emphasis added)
56. In the late 1960's, Hubbard was having growing public relations problems. One problem was Fair Game. To deal with it, Hubbard wrote an issue that is often cited by the church as evidence that Fair Game was cancelled. But a careful reading will show that nothing has changed but semantics. The issue is "Cancellation of Fair Game" dated 21 October 1968. The entirety of the policy letter (P/L) is as follows: "The practice of declaring people FAIR GAME will cease. FAIR GAME will not appear on any Ethics Order. It causes bad public relations. This P/L does not cancel any policy on the treatment or handling of an SP. (suppressive person)"
Notice that Hubbard did not cancel his "scripture" that suppressives could be "tricked, sued or lied to or destroyed." This so-called "cancellation of Fair Game" clearly states that those treatments (or "handlings") were to continue unabated. All that changed was the appearance of two words on a piece of paper.
57. As further evidence
of Fair Game continuing, four months later Hubbard wrote "Confidential:
Targets, Defense" on February 16, 1969, in which he listed "vital
targets on which we must invest most of our time . . The first and most important:
"T1. Depopularizing the enemy to a point of total obliteration."
58. On the same day, February 16, 1969, he wrote "Confidential: Battle Tactics", where he urged' the use of military tactics and strategy in dealing with the "enemy" He wrote:
|"A good general expends the maximum of enemy troops and the minimum of his own. He makes the war costly to the enemy, not to himself. One cuts off enemy communications, funds, connections. He deprives the enemy of political advantages, connections and power. He takes over enemy territory. He raids and harasses. All on a thought plane - press, public opinion, governments, etc."|
59. Hubbard wrote about
how to "embarrass, discredit or or remove an actual or possible opponent"
through "covert operations" in "Confidential: Intelligence-Actions:
Covert Intelligence: Data Collection: of December 2, 1969.
60. In 1977, Hubbard's
spy world exploded when the FBI conducted raids on the Intelligence Bureaus
of the Guardian Offices in Los Angeles and Washington, D.C. From evidence collected
in that raid, 11 top Scientologists went to jail, including Hubbard's wife,
Mary Sue. (I was Scientology's National spokesman on the day of the raid and
the months that followed.)
61. On October 6, 1979,
Hubbard's wife Mary Sue and eight other Scientology executives signed a 282
page (plus exhibits) Stipulation of Evidence that stated the government's case.
That document details the burglaries, forgeries, conspiracies to obstruct justice
and other crimes committed. However, it is the Sentencing Memorandum for Jane
Kember (The Guardian) and Mo Budlong (her intelligence chief) of September 16,
1980, by Assistant US Attorney Raymond Banoun that gives the most succinct view
of how--Fair Game was conducted after 1968. In fact, the memo discloses an admission
by defendants that Fair Game continued even beyond the conviction of Mary Sue
Hubbard, until mid-1980. (Banoun speculates in the memo "as to whether
these illegal activities were ever terminated by defendants.")
62. The memo relates how the defendants combined intelligence and legal to defraud and abuse the courts. Portions are hereby excerpted from it.
|"These crimes included: the infiltration and theft of documents from a number of prominent private, national and world organizations, law firms, newspapers and private citizens; the execution of smear campaigns and baseless lawsuits for the sole purpose of destroying private individuals who had attempted to exercise their First Amendment rights to freedom of expression; the framing of private citizens who had been critical of Scientology, including the forging of documents which led to the indictment of at least one innocent person; and violation of the civil rights of prominent private citizens and public officials."|
The memo points out how Mary Sue Hubbard had said on the witness stand that she and her codefendants "felt they could do to others whatever they perceived, however erroneously, others were doing to them."
"They presented this Court with a shabby attempt at impeaching Meisner's credibility [the Scientology intelligence agent who turned and started the investigation that led to the raid] by claiming that he stole money from the Church - the same false claim they made against another former Scientologist who had the courage to expose their crimes and thus fell victim to their fair game doctrine." Allard v. Church of Scientology of California, 68 Cal.App.3d 439, 129 Cal.Rptr 797 (Ct. App. 1976), cert:denied, 97 S.&t 1101 (1977) - page 14.
"The defendants' contentions that they committed the crimes of which they stand convicted in order to protect their Church from Government harassment collapses when one reviews a sample of the remaining documents seized by the FBI during the execution of the two Los Angeles search warrants. If anything, these documents establish beyond question that the defendants, their convicted co-defendants, and their unindicted co-conspirators [which included Ron Hubbard and current Scientology counsel, Kendrick Moxon], as well as their organization, considered themselves above the law. They believed that they had carte blanche to violate the rights of others, frame critics in order to destroy them, burglarize private and public offices and steal documents outlining the strategy of individuals and organizations that the Church had sued. These suits were filed by the Church for the sole purpose of financially bankrupting its critics and in order to create an atmosphere of fear so that critics would shy away from exercising the First Amendment rights secured them by the Constitution.
FOOTNOTE: The defendants
and their cohorts launched vicious smear campaigns, spreading falsehoods
against those they perceived to be enemies of Scientology in order to
discredit them and, in some instances, to cause them to lose their employment.
Their targets included, among others, the American Medical Association
((AMA) which had branded Scientology's practice of "Dianetics"
as "quackery"; the Better Business Bureau (BBB), which sough
to respond to private citizens' inquiries about the courses offered by
Scientology; newspapers which merely sought to report the news and inform
the public, law firms which represented individuals and organizations
against whom Scientology initiated lawsuits (often for the sole purpose
of harassment): private citizens who attempted to exercise their First
Amendment rights to criticize an organization whose tactics they condemned;
and public officials who sought to carry out the duties for which they
were elected or appointed in a fair and even-handed manner. To these defendants
and their associates, however, anyone who did not agree with them was
considered to be an enemy against whom the so-called "fair game doctrine"
could be invoked. Allard v. Church of Scientology, supra. That doctrine
provides that anyone. Perceived to be an enemy of Scientology or a "suppressive
person" "[m]ay be deprived of property or injured by any means
by any Scientologist without any discipline of the Scientology. [He m]ay
be tricked, sued or lied to or destroyed." Id., 58 Cal.App.3d at
413 n.1, 129 Cal.Rptr at 800 n.1.3 This policy, together with the actions
of these defendants who represent the very top leadership of the Church
of Scientology, bring into question their claim that their Church prohibited
the commission of illegal acts."
"It is interesting to note that the Founder of their organization, unindicted co- conspirator L. Ron Hubbard, wrote in his dictionary entitled 'Modern Management Technology Defined' that 'truth is what is true for you,' and 'illegal' is that which is 'contrary to statistics or policy' and not pursuant to Scientology's 'approved program.' Thus, with the Founder-Commodore's blessing they would wantonly commit crimes as long as it was in the interest of Scientology."
rewarded criminal activities that ended in success and rebuked those that
failed. The standards of human conduct embodied in such practices represent
no less than the absolute perversion of any known ethical value system.
In view of this, it defies the imagination that these
"It is clear from the press releases issued by Scientology following the jury's verdict, and their vicious actions against another member of this Court, that they have yet to learn the errors of their criminal ways."
63. The other member of
the Court that was being referred was Federal District Judge Charles Richey
who as the target of a sting operation conducted by a private investigator hired
by Scientology that forced the judge to recuse himself from the Scientology
case he was sitting on. The judge was allegedly set up with a prostitute. The
action was clearly Fair Game. Scientology publications however called it a "BIG
WIN." He would lot be the last judge to be the target of Scientology Fair
64. In 1981, a new campaign
was undertaken against Gerald Armstrong, a staff member who had fled with some
of Hubbard's files. Contrary to what Scientology executives have said, there
were Fair Game actions taken against Armstrong after the GO was "disbanded."
I know because I sat in on those strategy meetings and was ordered by Hubbard
as well as David Miscavige to "get Armstrong." For example, Hubbard
created a "reward" poster that would characterize Armstrong as a criminal.
I did not comply with the order, for which I was severely berated by Miscavige.)
The use of Fair Game on
Armstrong was confirmed in 1984 when California Superior Court Judge Paul Breckenridge,
Jr., ruled against Scientology with a opinion that included a statement about
the civil rights of members and Hubbard: "In addition to violating and
abusing its own members' civil rights, the organization over the years with
its 'Fair Game' doctrine has harassed and abused those persons not in the Church
whom it perceives as enemies. The organization clearly is schizophrenic and
paranoid, and this bizarre combination seems to be a reflection of its founder
LRH. The evidence portrays a man who has been virtually a pathological liar
when it comes to his history, background and achievements. The writings and
documents in evidence additionally reflect his egoism, greed, avarice, lust
for power and vindictiveness and aggressiveness against persons perceived by
him to be disloyal or hostile."
65. Another judge who stepped
down from a Scientology case was Federal District Judge James M. Ideman. But
as he did so, he filed a declaration in his court on June 21, 1993 which said,
in part: "Plaintiff has recently begun to harass my former law clerk who
assisted me on this case, even though she now lives in another city and has
other legal employment. This action, in combination with other misconduct by
counsel over the years has caused me to reassess my state of mind with respect
to the propriety of my continuing to preside over the matter." Part of
the problem, he said, was seeking to have Scientology comply with discovery.
They would not comply, he said. Judge Ideman later remarks how Scientology apparently
views "litigation as war" and seeks to break the opposition through
increased litigations costs. This is not news to members of the Guardian's Office,
now known as the Office of Special Affairs. This is part of Fair Game.
66. The reason that Fair Game does not stop is because the doctrine stems from policies and directives by Hubbard and they cannot be cancelled or exchanged except by him. Since he died in 1986, nothing past that point can be changed. This is also stated in an issue of July 7, 1982, called "The Integrity of Source which said: "It is hereafter firm Church policy that LRH issues are to be left intact as issued."
"No one except
LRH may cancel his issues."
"No one except
LRH can revise his issues whereby changes are incorporated into the text
and then reissued. Any valid revisions must hereafter be made in a separate
issue stating the change and how the revision is to be read. . . "
"Already existing issues stand intact and valid."
67. On Saturday, October
23, 1993, from 9:00 a.m. until 3:30 p.m., my deposition was taken by Kendrick
"Rick" Moxon, in Dickerson v. Sally Jesse Raphael, et al. I have known
Moxon since about 1973 when he was in the Legal Bureau of the Guardian Office
in Washington, D.C. After the 1977 FBI raid, Moxon was named as an unindicted
co-conspirator by the Federal Grand Jury that indicted Mary Sue Hubbard and
ten others. Moxon is thus a key example of how Scientology executives have lied
when they say that anyone involved in the Guardian Office was removed and none
remain. Moxon remained in the Guardian Office, even when it underwent the name
change to the Office of Special Affairs (OSA). Moxon is still OSA staff and
is now the lead in-house attorney for OSA, church of Scientology International.
His law firm (Bowles & Moxon) pretends to be an independent law firm when,
as it is well-known in OSA and all other senior ranks of Scientology, he and
the firm are controlled and operated by OSA and then by OSA's senior, the Religious,
Technology Center (RTC).
68. The stated purpose
of the deposition that Moxon took was that I might be called to testify as an
69. But not until the last
30 minutes or so of my deposition did Moxon even start to address my position
in relation to the case at hand. The time was spent trying to find the names
of those I have worked for or associated with since I left Scientology in 1989.
I knew the purpose: to initiate the "Fair Game." In 24 hours, I received
calls from two former employers who said Eugene Ingram, who was thrown off the
Los Angeles Police Department for his association with drugs and prostitutes
and turned to being a private detective for Scientology, had been trying to
find information about me.
70. They are also harassing
a woman who I had never met face-to-face. She has nothing to do with Scientology
or any case. We had corresponded via a BBS (bulletin board system, a form of
E-Mail) perhaps six months earlier and she had asked me to look at material
she had written. I agreed and she mailed it to me. I did not respond and instead
discarded the material. That Ingram had the material meant that he or someone
had taken it from my trash. This is a standard "noisy investigation"
My interest in BBSs was
generated by research I had conducted for an article in the May issue of Oranae
Coast magazine (Exhibit "C").
71. As a result of their
"fishing" tactics, one week after Moxon took my deposition in Dickerson
v. Sally Jesse Raphael, his partner, Timothy Bowles used a portion of the unedited
transcript to try to quickly exclude me as an expert witness in an unrelated
case (Church Of Scientology v. Steven Fishman and Uwe Geertz) with a motion
served on Fishman.
72. I left Scientology
after I was mentally and physically abused to the point of breaking. I had been
locked in rooms and assaulted until, like a prisoner of war, I had "confessed"
to pre-ordained crimes and ordered to put them into my own handwriting. (The
parallel of Scientology interrogation techniques to those of the Communists
in obtaining "confessions" is staggering. Like many Communists, the
Scientologist may even come to believe that he or she committed the fictional
crime. The purposes of these "confessions" - particularly in their
own handwriting - is to have material that can be used to blackmail or coerce
the person later and thus to keep them in the organization, keep them compliant
and to keep them from talking about the crimes being conducted in the name "religion".)
73. My wife was abused
and was nearly crippled for life. We were physically separated on several occasions
for months at a time to try and break our marriage. I had to literally sneak
out from my captors to visit her and then sneak back before my absence was known.
74. I was physically assaulted
by Hubbard Trustee Norman Starkey. I reported the felony in writing to Moxon
as a church attorney but he disregarded it. That and other incidents leave no
doubt in my mind that the people who still run this organization are capable
of continued abuse, harassment and physical assault upon myself and my family.
Their use now of a person who war thrown off the LAPD for association with prostitutes
and drugs also concerns me.
75. The conduct of Moxon
in my last deposition, harrassing me for hours, left no doubt what they intend:
to use the courts for Fair Game as they have in the past.
76. Although I wish to
exercise my basic constitutional rights of freedom of speech, freedom of association
and freedom of religion, my desire to do SO makes me a target of retribution.
I am "Fair Game" for merely wanting to walk away. No one walks away
from Scientology. In Hubbard's words, he would "rather see you dead."
77. Because I know how
abusive Scientology executives can become (especially via attorneys and private
detectives who are used as cut-outs), I have taken additional security measures
to protect myself, my family and my home. This includes briefing neighbors,
family friends and law enforcement of our situation and possible tactics and
methods and by whom.
78. I am not only willing but desirous to testify about the policies, practices and doctrines of Scientology as well as its link to Sterling Management and how Scientology abuses the courts and the law, But to do this fully, I require:
1. A non-Scientology
related location. I am fearful for my personal safety: I was physically
assaulted twice in Scientology organization by Scientology executives.
I have seen others physically assaulted. I have also been locked up, kept
under 24 hour guard, and interrogated for days on end until I broke. I
cannot give free testimony at a Scientology location such as at the in-house
attorney firm of Bowles & Moxon, nor any group affiliated with the
World Institute of Scientology Enterprises.
2. No deposition
recordings not authorized by the court. Surreptitious records (video as
well as audio) are standard Scientology intelligence methods, They were
done against federal agencies, federal judges and even private citizens.
I have seen these recordings and heard the audio tapes that were secretly
made. It is part of "Fair game"
3. No one in the
room or nearby but attorneys and officers of Sterling and/or Cult Awareness
Network. Scientology attorneys like to bring in others who have known
the deponent plus a private investigator (who was thrown off the Los Angeles
Police Department for his link to prostitutes and drugs.) The purpose
for bringing them in is intimidation while the attorney conducts the third
degree. I am willing to respond to an attorney, not a gallery. Nor do
I want any others on the premises, lurking in the halls or a nearby restroom
where I can be kidnapped, harassed or beaten as Scientology executives
have done and ordered done.
4. No harassment.
Their cop-turned-criminal has already undertaken the "noisy investigation"
on me, per Hubbard's "scriptures." This has included contacting
former employers and harassing those they think might know me, sometimes
misrepresenting himself as with the LAPD. My trash is also occasionally
stolen. And the middle-of-the-night phone calls have started. (This is
where the invention of the answering service is appreciated.) I want my
family, my friends and my home safe from their Fair Game harassment. They
have a right to investigate but not to conduct what Hubbard called "Black
Propaganda" where discreditable information is provided people under
the guise of an investigation.
5. No information
from my confidential Scientology files. Scientology touts how various
files are "confidential" and "priest/penitent." But
under Fair Game, they violate their fiduciary relationships and cull the
folders for what might be embarrassing or harassing. Some of this is "laundered"
by giving the information to other people who then testify about it. I
know how this is done because I saw these tactics used time and again.
I also know that Scientology executives deny it is done. This is a lie
and they know it. It is simply Fair Game.
6. No penetration of attorney work product in unrelated cases. In my last deposition, they sought to learn the names of other Scientology-related cases and attorneys I have been in contact with. They also tried to trick me into lifting the confidentiality of other cases so they could gain information. They also were listing the names of attorneys and cases to see if I had worked for any of them. All of this is Fair Game where they have complete disdain for the legal process.
79. I have a right to be
an ex- Scientologist and to express my expert opinion and to give sworn testimony
without being attacked, harmed, harassed or intimidated by thugs, executives,
attorneys or anyone in their hire. And my family and friends have the right,
to be free from Hubbard's Fair Game Doctrine.
I declare under penalty
of perjury that the foregoing is true and correct.
Executed this 23 nd day of November, 1993 at Orange, California
Robert Vaughn Young