I, Caroline Letkeman, declare as follows:

1. I am over the age of 18 years.

2. The statements herein are of my own personal knowledge and if called upon as a witness I can testify competently thereto.

3. On or about May 12, 1997 I suddenly became acutely ill due to poisoning by way of a contaminated herbal product. For at least a year prior to the onset of my illness, I had been purchasing this herbal cleansing product from Peter Gillam's Health Food Store in Los Angeles, CA. Peter Gillam's Health Food store is located within a block or so of Scientology's Complex on L. Ron Hubbard Way. It is a store that is managed and patronized by Scientologists who live in the vicinity, as well as by those who take Scientology services at the Complex. The contamination occurred in a specific batch of the herbal formula.

4. On May 16, 1997 the FDA issued the following warning regarding this product. (This warning is available in the archived FDA Warnings on the FDA's website.)

FDA WARNS AGAINST CONSUMING THE ARISE & SHINE PRODUCT "CHOMPER" The Food and Drug Administration is warning consumers not to purchase or consume "CHOMPER," one of a line of dietary supplement products distributed by "Arise & Shine" of Mount Shasta, California. FDA has determined that this product has been associated with a severe injury and that it may contain substances that may result in an abnormal heart rate and rhythm, and could potentially cause cardiac arrest. FDA has learned of a recent case where the consumption of this product as part of Arise & Shine "The Cleanse Thyself" program by a young woman apparently resulted in abnormal heart rate with heartblock, a potentially life-threatening condition. The agency is also investigating if other injuries have been associated with this product. The "Chomper" product is promoted as an "herbal laxative" and "cleansing" agent to be used as part of a regimen of dietary products distributed by this company. Laboratory analyses of the product revealed that it contains substances similar to those that affect the heart. Use of these powerful substances, which are found in a number of poisonous plants, may result in a severe, potentially fatal heartblock, even in otherwise healthy individuals. The agency has found that "Chomper" poses a potentially significant and unreasonable risk to public health. FDA urges all individuals who may have this product to avoid consuming it and to immediately consult their health care professional if they are experiencing any adverse effects associated with use of the product. These effects may include nausea, vomiting, dizziness, headache, confusion, hypotension (low blood pressure), vision disturbances and abnormal heart rate and rhythm.

5. At the time, I had no idea what was causing my illness. I had not seen or heard of the FDA recall. I thought that I was suffering from the sudden onset of a very bad flu.

6. During the initial month of my illness, I sought medical attention two times from Dr. Gene Denk at the Shaw Health Center. Dr. Denk is a Scientologist, and was L. Ron Hubbard's personal physician at the time of Hubbard's death. On both office visits, my vital signs were recorded and after being examined by Dr. Denk, he prescribed and administered expensive IV drips of vitamins to assist in recovery from the flu. I did not understand until much later that the symptoms I was experiencing were not symptoms of a gastro-intestinal flu, for which Dr. Denk was treating me. My symptoms matched the symptoms given in the FDA recall bulletin referenced above.

7. For my third and final visit to Shaw Health Center during the initial month of my illness I saw Dr. Megan Shields. After taking my vital signs and examining me, Dr. Shields recommended that I seek immediate emergency room treatment at Oliveview Hospital. She told me that she thought that I had Addison's disease, which I understand to be a very serious and medically incurable adrenal condition. She told me that Shaw Health Center did not have the facilities to fully diagnose Addison's disease and that is why I needed to go to the hospital.

8. Shaw Health Center is also a distributor of the line of products that was causing my illness. Shaw Health Center carried the exact formula that had been contaminated.

9. It became my later understanding, from attorneys representing the various manufacturers involved in the production of the contaminated product, that recall notices were sent out on a timely basis to all retail distributors of the contaminated product, which notices should have included Shaw Health Clinic.

10. I also saw Dr. Alf Garbutt on several occasions during the initial month of illness, prior to being hospitalized. Dr. Garbutt is a chiropractor and nutritional counselor. He is also a Scientologist.

11. Dr. Garbutt had me bring in all my supplements in order to adjust my supplement intake to help with my illness. By the time I saw Dr. Garbutt, my concern was that I was suffering a relapse of an Epstein Barr virus infection from a decade or so earlier. I wanted to ensure that I was doing everything possible to not bring on another full relapse of that illness. Dr. Garbutt tested my supplements and provided me with a list of supplements he tested to be beneficial for my current condition. He provided me with a written list of recommended supplements that I should continue to take. The list included the exact product that was later found to be causing the illness. I do not know for sure whether the actual bottle he tested was the contaminated batch of the supplement, as I had more than one bottle open at the time of my illness.

12. Dr. Garbutt sold some herbal formulas from the same company who had distributed the contaminated herbal supplement. I do not remember if he carried the exact herbal formula that had been contaminated.

13. I went to the emergency room at Oliveview Hospital on the same afternoon that I saw Dr. Shields at the Shaw Health Center. The emergency room tests revealed that I had a lethal level of digitalis in my system.

14. Digitalis is a strong heart medicine, made from an herb called foxglove. Approximately six months following this hospitalization, I learned that the digitalis in my system came from the herbal product that I had been taking, and that the herbal product was heavily contaminated with foxglove.

15. I had continued to take the contaminated herbal product while under the care of Shaw Health Center and Dr. Garbutt during the month prior to being hospitalized. I had been extremely ill for a month prior to being hospitalized, and was repeatedly exacerbating this condition by following my Scientology doctors recommendations. I very nearly died.

16. Because of the lethal level of the drug in my system, the hospital staff was gravely concerned that I was trying to commit suicide. I remember on one occasion that there were four psychiatrists in the room while I was questioned in this regard. Being a Scientologist, and already having prior experience of the extreme hassle Scientology puts you through for any psychiatric history, I was absolutely terrified that this incident would endanger my future eligibility for Scientology services.

17. As I was so close to death, the hospital doctors strongly urged me to consent to an operation to install a pacemaker. This was even more terrifying. I had no idea who or what was trying to kill me and I did not trust the hospital security. At the same time, I did not want to appear fearful, as that would further attract the psychiatrists. The type of pacemaker that the hospital staff wanted to install would allow my heart rate to be monitored and regulated at the nurse's station, completely outside of my control. I refused the pacemaker, much to hospital staff's upset and further concern over my psychological state.

18. Before I went to the hospital, Dr. Shields stressed to me that she wanted to make sure that the hospital would continue to take the Scientology patients that she sent to them. Dr. Shields did not visit me at the hospital; she told me she did not have hospital privileges. Later, Dr. Shields told me that she had stayed in touch with the hospital doctors who were in charge of my case. At least some of those doctors were psychiatrists. Dr. Shields relayed instructions to me through another Scientologist who visited me at the hospital. Her instructions were simply to do everything that the hospital staff requested of me.

19. Dr. Shields instructions were very alarming to me, as it was completely obvious that the doctors considered that I was a suicide case. I know this because the interns at the hospital had their daily briefings within hearing distance of my hospital bed. At one point, I interjected in their briefing and yelled at them that I was most certainly not a suicide.

20. Because Scientologists have very strong feelings against psychiatry, and consider them to be Public Enemy #1, I felt betrayed by Dr. Shields. I felt that by her readiness to agree with the doctors, she was placing her political and professional interests above my physical safety and spiritual freedom. I was petrified that the hospital staff was trying to intimidate me into a serious heart operation. I first verified with the doctors that the pacemaker would have no therapeutic value, and was only a last ditch measure to artificially control my heartbeat. I felt no more ill than I had been feeling for some time. I refused the operation but did willingly consent to an external pacemaker that could be used to resuscitate me if necessary.

21. I was later told by an independent medical examiner that because I refused to submit to the internal pacemaker, a far more expensive treatment became necessary to save my life. This alternative involved intravenous drips of a very expensive drug called Digibind; this drug was used to bind the digitalis in my system. To this day, I believe that in refusing the pacemaker, I saved my life.

22. Digitalis is sometimes abused as a recreational drug. One example of such abuse was Vincent Van Gogh--he took digitalis during the time when he was making yellow paintings. Digitalis creates a yellow halo effect when taken in large enough dosages. I experienced such effects in the extreme.

23. Another side effect of the binding drug is that it caused terrible hallucinations far more severe than any drug I had experimented with when I was an adolescent. No one advised me that the drug would cause these side effects, and I did not realize that the hallucinations were related to this drug. The objective facts and unknown facts of the poisoning were in my opinion severe enough to cause tremendous emotional stress in any normal person. On top of that, all of a sudden I was experiencing the hallucinatory effects of some drug. All I knew was that I had to fight for my life, and that I was on my own.

24. At one point after having had an intravenous drip of the binding drug, some Scientologists visited me in ICU. One Scientologist lived in the same house where I resided. Another Scientologist was the daughter of my closest friend. I asked them to close the curtains around me, and I confided to them about my fear over the hospital staff. What I told my visitors appeared to alarm them greatly over my mental state. One of my visitors jumped up on my bed and shook me, screaming that I needed to decide to live and get into present time. I had not given her any indication that I was trying to die my communication was simply that I was afraid of the hospital staff and that I thought they were putting drugs in my food.

25. On the afternoon I was released from the hospital, I went to Dr. Shields at Shaw Health Center and told her that I thought someone had drugged me in the hospital and I asked her for a drug screen for possible traces of hallucinogenic drugs. In doing so, I wanted to try and identify the drug and preserve the results of that screen for evidence. Dr. Shields authorized the drug screen. The drug screen results were, of course, negative.

26. I know that visitor reported to my other Scientology friends about her visits at the hospital, and that she had been updating my closest friend who was at Flag during that time. I have no reason to suspect that she did not report as accurately as she could with the information that was available to her.

27. It is common practice in Scientology, when Scientologists wish to report anonymously, they simply address their reports to the case supervisor. This way, copies of the reports do not go to the person being reported on. I believe that at least one report of this nature was filed on my condition while in the hospital. It would have been highly unusual for a Scientologist to not do so.

28. Before being released from the hospital, my doctors recommended that I refrain from taking any non-prescription supplements, which I complied with for six months, even though my Scientology doctor had already tested my supplements and I trusted his advice.

29. After six months I was still not well enough to go back to work, and I was getting worried about my financial situation. I had no hospital or health insurance. I decided then to go back to my original supplement regimen. I immediately became acutely ill with the same symptoms as before, and was hospitalized for the second time. However, now I at least finally knew the source of the poison.

30. After being released from the hospital, I called Peter Gillam's Health Food store and told them that there was a problem with the herb I had bought from them. The person I spoke with told me that Peter Gillam's had posted the FDA's recall notice about this product, and that the notice had been up on their wall for several months. (Because I was not taking those herbs after the first hospitalization, I had no reason to go to that store thus I was not informed of the recall.)

31. After the second hospitalization, I started investigating the companies involved in the manufacture and distribution of the herbal product. I also came to know that the FDA's recall notice had been broadly announced and published in major medical journals in May, prior to my first hospitalization. I located and filed insurance claims with the manufacturing companies, with the export/import companies of the mislabeled ingredient and with the hospital.

32. Scientology ethics policy prohibits Scientologists from suing other Scientologists, except as approved through Scientology's internal hierarchy. Although I had every legal right to file a claim against Shaw Health Center and Dr. Garbutt for malpractice, I still considered myself to be a good Scientologist and because of this reason alone, did not file claims against the doctors involved.

33. However, I did send faxes with the FDA warnings to Shaw Health Center and Dr. Garbutt. My concern was the protection of other patients against this deadly herb. Dr. Garbutt responded quickly to my fax, and offered his condolences. I had also requested that Dr. Denk call me, which he reluctantly did several days following my fax. Dr. Denk said to me, What do you want? in a manner that was totally devoid of any caring or concern for what I had just gone through. I told him that I wanted to alert him to the FDA warning, and wanted his confirmation of receipt. He acknowledged receipt, but in no way offered any apology or expressed any regret for his misdiagnosis or treatment. Dr. Shields responded in a similar way her response to my report was one of contempt that I would rail against the hospital, because they had, after all, saved my life.

34. I also wrote a report about the occurrence to upper Scientology management including the Religious Technology Center's Reports Officer. The RTC Reports Officer relays reports to the appropriate Scientology executives. I received a letter back from someone at the Office of Special Affairs, warning me to not involve Scientologists in the lawsuit. I don t recall the name of the person who wrote this letter, and I do not have the letter in my possession at this time.

35. Around June 1998, I needed to protect the Statute of Limitations in my pending insurance claims and so took the advice of another Scientologist in selecting a law firm to represent me. In exchange for his assistance, the Scientologist became my Field Staff Member (FSM). Scientology organizations pay commissions to FSMs for helping Scientologists go up the Bridge. In my case, the assistance rendered was advice regarding my legal case and representation.

36. My FSM, who was also an insurance adjuster and knew how to evaluate insurance claims, knew that the case would eventually result in a settlement. There had been a little discussion here and there about using this future settlement as collateral for a loan, to pay for immediate Flag auditing. However, I made it very clear that I was not going to participate in any such scheme. In late 1998, my FSM gave my telephone number to a sales person (called a registrar, or reg ) from the Flag Ship Service Organization ( FSSO , aka the Ship). I spoke with the reg a few times by phone and he appeared to be friendly. However, I remained unwilling to borrow money to do Scientology services. The reg showed up at my house unannounced one afternoon, and thus commenced a very emotionally charged interview.

37. The Ship reg had already been briefed on my story by my FSM, and he expressed what seemed to be genuine concern for my emotional and physical recovery from this terrible incident. As we talked, I began to cry. I remember feeling for the first time during this interview that maybe there was some hope for relief and I began to realize the depth of the emotional pain that I had been suppressing. At this point, he convinced me to give him my credit card to go to the Ship for some individualized services called an OT Debug. He convinced me that this service would help tide me over until I was able to go to Flag for advanced auditing.

38. Having been an auditor, I knew that there were probably reports in my preclear folder from my hospital visitors, and that the case supervisor would likely have questions about the facts of my hospitalization. I had already reported on the matter to ethics people and to RTC, but I was not sure what other reports I would have to defend myself against. I knew that the Ship might not accept me onboard until these matters were cleared up locally.

39. In normal circumstances, if a person asks for a refund from Scientology, they are never again allowed to have Scientology services. The reg assured me that if the Case Supervisor at the Ship did not give me security clearance, my cards would be re-credited. He explained to me that money is put in a special holding fund pending security clearance, and if security clearance were denied, the money would be returned without any stigma of a refund. On that basis I agreed to pay for the OT Debug. I also provided the reg with another report about the hospital incident so that the case supervisor could review it for security purposes.

40. Shortly before I was to go to the Ship, I called the reg and he told me that the Ship case supervisor denied my security clearance. Any semblance of caring and empathy were now gone from the reg. He told me that I would be required to pay for a security check, and he suggested that rather than re-credit my card, that I simply transfer that money to AOLA (Advanced Organization of Los Angeles) and start paying for a much more expensive security check. I flatly refused and demanded that he immediately re-credit my card.

41. About five minutes after I hung up, I received a call from a reg at AOLA, at which time he tried to convince me to pay for a security check at AOLA. (I can recall no one from Flag or AOLA who had called me or visited me since my illness, but now that there was money involved, the AOLA reg called quickly.) By this time I was absolutely furious and would have nothing to do with this new scheme. I refused to transfer any money, and I continued to insist that the Ship reg re-credit my card as he had promised. He finally told me he had done so.

42. When I got my next credit card statement, I saw that there was an outstanding charge that I had neither approved nor been aware of at any time prior to that. It was a charge of $264.00. I called the Ship reg and he explained to me that this was something he charged on my card as a prepayment for accommodations while on the Ship. I told him that since I was not going to the Ship, he should just re-credit that charge too. The reg explained that the accommodations money was not put into the same holding fund, and that it could not be refunded. I was outraged and I told him that he needed to re-credit it anyway, as I had not authorized this charge.

43. Because Scientology's ethics policy prohibits Scientologists from going to authorities, I knew I would be in big trouble if I told my credit card company the truth about the reg's crime. For about six months, I attempted to resolve this matter using internal Scientology reporting policy. I called the Ship reg repeatedly and I sent reports to OSA and to RTC, and to every appropriate Scientology official that I could think of, in effort to clear up this theft. Finally, when my own credit card company advised me that my credit was at risk over this non-payment, I reported the exact situation to my credit card company. Though I still get regular statements from the Ship saying I have that amount of money on my Ship account, the charge on my card was re-credited promptly only after reporting the theft to my own credit card company.

44. While in the course of trying to resolve this credit card crime, I broke Scientology's critical blackout rule, and began to look at critical information about Scientology on the Internet. I learned of Dr. Denk's involvement at the time of L. Ron Hubbard's death and that the circumstances surrounding Hubbard's death were very suspicious. I concluded that if I were to speak out about my experience with Shaw Health Center and Dr. Denk, Scientology might retaliate in effort to shield Dr. Denk from public inquiry.

45. Until January 2001, I continued to maintain a relationship with my daughter, who is a Scientologist. However, at no time did I speak with her about my disillusionment about Scientology or about the research that I was doing; I knew that doing so would cause Scientology to insist that she disconnect from me. Publicly speaking out against Scientology is considered to a high crime, of the same magnitude as murder or arson. Scientology labels such violators as Suppressive Persons which forces other Scientologists to disconnect from them. In my case, my daughter would be forced to disconnect from me. I felt I had no choice but to remain silent until I could find a way to address these matters with her safely and properly.

46. I anonymously submitted a critical essay that won a prize and was posted on the Internet. Scientology's Office of Special Affairs spent about six weeks trying to identify the author of that essay, and when they did, they did not contact me. They simply publicly announced my identity on the Internet and furnished my daughter with slanderous and libelous information about me. Further details of that event are given in my Declaration of April 27, 2001.

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

Executed in Sunland, California this 8th day of May 2001.