------------------------------------------------------------------- F.A.C.T.Net, Inc. (Fight Against Coercive Tactics Network, Incorporated) a non-profit computer bulletin board and electronic library 601 16th St. #C-217 Golden, Colorado 80401 USA BBS 303 530-1942 FAX 303 530-2950 Office 303 473-0111 This document is part of an electronic lending library and preservational electronic archive. F.A.C.T.Net does not sell documents, it only lends them according to the terms of your library cardholder agreement with F.A.C.T.Net, Inc. ===================================================================== DECLARATION OF GARRY L. SCARFF I, Garry L. Scarff, hereby declare and state: 1. I am a witness for the defendents in the case of Church of Scientoloqy v. Fishman and Geertz. 2. I am a former Scientologist and former operative of the Church of Scientology's Office of Special Affairs, i.e. "Guardians Office", where the firm of Bowles and Moxon, counsel of record for plaintiff in this case, actively coordinates their activities. 3. I have personal and substantiated knowledge of the facts set forth in this declaration and if called upon to testify, I could and would comptently testify thereto. 4. Since becoming a witness for the defendent in this case, I have been subjected to various forms of harassment and intimidation by members of the Church of Scientology and Bowles and Moxon, including death threats against me and my family, vandalism, and the filing of deliberately fabricated evidence in this case in the form of affidavits by alleged investigators and church members. 5. This declaration is intended to challenge and rebut the self-serving statements in the declaration of Orlando, F!erida investigator Jon C. Martin, whom was retained~ according to his affidavit, by Bowles and Moxon on January 4, 1994, to conduct an employment check of my former employment with Walt Disney World. 6. As an ex-Scientologist whom worked closely with chief Scientology investigator Eugene Ingram, a former police officer whose loss of employment with the Los Angeles Police Department was attributed to, in part, of filing a false police report and seeking a disability pension for a self- inflicted gunshot wound, which Ingram identified was result of gang violence, I am very knowledgeable to the consistent - 2 - methodology of church investigators whom embellish and distort information to paint a situation which acts favorably to the agenda and mission of the Church of Scientology. This tactic which is reflective of wholesale perjury is enthusiastically endorsed and encouraged by the law firm of Bowles and Moxon. Jon C. Martin's sworn affidavit is consistent with this methodology. 7. If it is reasonable and acceptable by Scientology members to formulate their own definitions of "truth" which is invariably opposite to the definition of truth based on fact which is generally accepted, then it is reasonable to presume their are different definitions of what constitutes "seasonal employment." 8. On October 19, 1993, I was hired by Walt Disney World for an "essential position" of Reservationist with the WDW Central Reservations Office. Since early 1993, due to economic woes, i.e., the failure of EuroDisney, and a drop in tourism due to a rash of tourist killings, Walt Disney World instituted a hiring freeze of all permanent, fulltime positions. All new employees are hired as "seasonal employees", or "CT's" (Casual Temporarys). For individuals hired into positions classified as "essential", as was my case, "seasonal" is defined as a probationary period leading to permanent fulltime employment, or what Walt Disney World refers to as "CR's", or Casual Regulars. 9. At the time of my hiring, I was advised that my status would remain "seasonal" for a duration of 90 days to 6 months. My reclassification to fulltime, permanent employment depended on numerous factors including job performance, attendance, and Disney's economic situation. The statements made by Jon Martin in his affidavit regarding seasonal employment at Walt Disney World (para 4) has no basis in fact. 10. On Tuesday, November 30, 1993, I was called into the office of my supervisor, Betsy Baker, whom informed me that I was the recepient of two guest letters in which I was commended for professionalism and excellent guest service. - 3 - 11. On Friday, December 17, in a meeting with Larry Feipel, Assistant Director of Central Reservation Operations, I was advised to look forward to being re-classified to permanent, fulltime status by February 1, 1994. 12. On Monday, Dec. 27, I was asked to sign a written evaluation completed on me where I was deemed to be an "excellent" candidate for reclassification to fulltime employment. 13. On Wednesday, Dec. 29, I was approached by Thelma Scott, a Central Reservations Manager who congratulated me for the excellent work performance I had demonstrated on the job. 14. On Friday morning, Dec. 31, two hours into my shift, I was summoned to the Administrative Office of Kim Cage where I was informed of my "termination" of employment (not laid off as stated in Martin's affidavit) because of "lack of professionalism" on the job and because of a conversation that had taken place with an attorney who advised Disney staff that I was an "admitted kidnapper" and that I had engaged in a conspiracy to murder an individual. 15. In numerous motions and evidence submitted by the plaintiff's counsel in this case, Bowles and Moxon, has coined me as an "admitted kidnapper and perjurer." While my participation in a murder conspiracy is true, it's ironic that it should be mentioned by attorneys from Bowles and Moxon whose chief counsel Timothy Bowles and Kendrick Moxon were co-conspirators in the murder plot to kill not one, but two individuals. 16. On February 4, I visited the Employment Offices at Walt Disney World referred to as Walt Disney World Casting. I was informed by a personnel supervisor that, in strict accordance with Disney policy, calls for employment verification are logged. I was advised that no record exists of any call from a "jon C. Martin" to Sarah Deal Jones, an employee of Disney's Employment Programming Division. Secondly, no - 4 - record exists of a call received by Ms. Jones, or anywhere at the personnel office of an employment verification call received by a licensed private invetsigator. However, there is record of a call received on January 5 by a man whom identified himself as a prospective employer of Garry Scarff seeking a job reference. It is clear that the statements made by investigator Jon Martin in his affidavit of January 9, 1994, is replete with fabrications. 17. Investigator Martin declares his affidavit under penalty of perjury, which calls into question his professional integrity. I declare under penalty of perjury that the foregoing is true and correct. Executed in Orlando, Florida this day of February 5, 1994. Garry L/Scarff ================================================================= If this is a copyrighted work, you are acknowledging by receipt of this document from FACTNet that on the basis of reasonable investigation, you have not been to obtain a copy elsewhere at a fair price, and that you are and will abide by the following copyright warning. WARNING CONCERNING COPYRIGHT RESTRICTIONS: The copyright law of the United States (Title 17, United States Code) governs the making of photo copies or other reproductions of copyrighted material. 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