------------------------------------------------------------------- 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 declares as follows: 1. I am a witness for defendant's counsel in the case of Church of Scientoloqy v. Fishman and Geertz. 2. I am a former member of the Church of Scientology, a former operative with the Church's Guardian's Office renamed the Office of Special Affairs after high-ranking members of the office were convicted of federal crimes, and a former client of attorney Timothy Bowles, of Bowles and Moxon, the plaintiff counsel in this case. 3. I acknowledge based on first-hand experience and personal knowledge that attorneys Timothy Bowles, Kendrick Moxon, and their associates in Bowles and Moxon actively coordinate their activities with the Office of Special Affairs, and have played a direct role in the coordination and implementation of unethical and criminal acts on behalf of, and "for the good of Scientology." 4. I have personal and substantiated knowlege of the facts set forth in this declaration and if called upon to testify, I could and would compentently be able to do so. 5. Since becoming a witness for defendent's counsel, I have been subjected to various and outrageous forms of harassment, intimidation and slander by my former attorney Timothy Bowles in an outrageous breach of his fiduciary responsibilities, and other attorneys from Bowles and Moxon, including, but not limited to the introduction of deliberately falsified affidavits and forgered documents. My family and I have also been subject to death threats, stalking by members of the church, and vandalism. Declaration page 2 6. This declaration is intended to challenge and rebut the declaration filed on January 24, 1994, by Orlando private investigator Jon C. Martin, whom by his own admissions, was hir~řa by Bowles and Moxon to investigate my employment record with Walt Disney World. By his own admission, Jon C. Martin declares himself to be a licensed private investigator in the state of Florida. According to the Licensing Division of the Florida State Department, there is no listing or record of Jon C. Martin being licensed by the state of Florida as a Private Investigator. 7. As an ex-Scientologist whom worked closely with chief Church of Scientology investigator Eugene Ingram, I am very knowledgeable to the consistent methodology of church investigators whom are paid highly by the Church to embellish, distort and invent information to paint a situation favorable to the agenda and mission of the Church of Scientology, International. This tactic, fully endorsed and implemented by the Church and it's legal representatives in Bowles and Moxon, is reflective of the wholesale perjury and scurrious motions filed by the law firm of Bowles and Moxon. The declaration by self-proclaimed investigator Jon C. Martin is consistent with this methodology. 8. As a Scientologist, I had filed false declarations which were created by attorneys of Bowles and Moxon and their paid employee, Eugene Ingram, a former police officer whose loss of career employment with the Los Angeles Police Department was attributed to, in part, of his filing a false police report and seeking a disability pension for a self- inflicted gunshot wound which Ingram claims was the result of gang violence near the environs of the Los Angeles Police Academy. Ingram's deliberately falsified declarations have been generously submitted in numerous court cases, including to over forty (40) SLAPP suits against the National Cult Awareness Network and its officers. Declarations Page 3 9. If it is reasonable and acceptable by Scientology attorneys and staff members to formulate their own definitions of "trut'h" which is invariably opposite to the "truth" defined by society in general, then it is reasonable to presume that different employers have different ideas of what constitutes "seasonal employment." 10. On October 19, 1993, I was hired by Walt Disney World for the "essential position" of Reservationist with the Walt Disney World Central Reservations Office. Since early 1993, due to economic woes, i.e. the financial problems of EuroDisney and decreases in tourism due to tourist murders, Walt Disney World instituted a hiring freeze of all permanent, fulltime positions. All new employees hired into "essential" positions are subject to a "seasonal" period of 90 days to 6 months, whereby they then are re-classified as permanent, fulltime employees, or in Disney World terminology, "CR's" (Casual Regulars). It is clear that self-proclaimed investigator Jon C. Martin's assertion that my position was classified as temporary, is without substantiation. 11. 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 my professionalism and integrity on the job. 12. On Friday, December 17, 1993, in a meeting with Larry Feipel, Assistant Director of Central Reservations Operations, I was commended for my work and advised that continued success would earn me permanent status at Walt Disney World by February 1994. 13. On Monday, December 27, 1993, I was asked to review and' sign a Performance Evaluation done on me which was rated as "Excellent." Declaration Page 4 14. On Wednesday, December 29, 1993, I was approached by Human Resources Manager Thelma Scott whom congratulated me for ~ny successes at work. 15. On Friday morning, December 31, 1993, two hours into my shift, I was summoned to the Administrative Office of Kim Cage whom informed me that I was being immediately terminated from employment because of "lack of professionalism" and due to conversations with a legal source which advised Disney of my past record of being "an admitted kidnapper" and a participant in bank fraud, as well as having involvement in a conspiracy to commit murder. Ms. Cage refused to divulge her sources and claimed I had no rights to this information, no rights to question my termination and no rights to an appeal. 16. In numerous motions and evidence submitted to the court in this case, the firm of Bowles and Moxon have scurriously coined the phrase in labeeling me "an admitted kidnapper and perjurer." While my role in a murder conspiracy as a member of the Church of Scientology is true, it's ironic it should be mentioned by Bowles and Moxon, when it was with their participation and from whose offices the conspiracy was formented, that murder was discussed of two perceived enemies of the Church. 17. On February 4, 1994, I visited the personnel offices of Walt Disney World referred to as the Casting Office. (Disney employees, in theatrical vernacular, are referred to as Cast Members). I was informed by a personnel supervisor that, in strict accordance to Disney policy, calls for employment verifications are logged. I was advised that no person identifying himself as "Jon C. Martin" nor as a "licensed private investigator" is logged on recor~ as having called Walt Disney World for verification of my termination. One call exists, however, from an individual identifying himself as a former employer of mine. Declaration Page 5 18. Sarah Deal Jones, of Walt Disney World's Employment Programming Division, whom investigator Martin identifies by name in his dec~,aration, does not recall ever speaking to Mr. Martin about my employment. 19. Self-proclaimed investigator Jon C. Martin filed his declaration under penalty of perjury which calls into question his professional integrity and that of the law firm which the facts demonstrated hired and paid Martin to lie and sign his name to a deliberately false declaration which has no substantiation in fact. I declare under penalty of perjury that the foregoing statements are true and correct to the best of my knowledge. Executed in Orlando, Florida this day of February 15, 1994. Garry L. Scarff 2269 S. 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