------------------------------------------------------------------- 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. ===================================================================== Scarff\Scarff5 - re CAN\Page.00001 1 DECLARATION OF GARRY SCARFF 2 I, GARRY SCARFF, declare as follows: 3 1. All the facts contained within this Declaration are 4 within my personal knowledge and if called to testify thereto, I 5 could and would be competently able to do so. 6 2. I persona 11y acted as an agent for the Church of 7 Scientology's Office of Special Affairs in covert and overt 8 operations directed against the Cult Awareness Network for a number 9 j of years. 10 3. As part of my operations against the Cult Awareness 11 Network, I was encouraged to file a baseless lawsuit against the 12 Cult Awareness Network. The lawsuit, which was never filed, was to 13 be filed in the Circuit Court for the State of Oregon for the 14 County of Multnomah. It was drafted by my attorneys, the law 15 offices of Bowles t Moxon, which is also the in house law firm for 16 the Church of Scientology International, and part of the Office of 17 Special Affairs for the Church of Scientology International. A 18 true and correct copy of the lawsuit is attached hereto as Exhibit 19 nA' to this Declaration. 20 4. I had numerous conversations with the representatives of 21 the Office of Special Affairs of the Church of Scientology 22 International and attorneys at Bowles & Moxon regarding the filing 23 of this lawsuit on my behalf against the Cult Awareness Network. 24 Everyone involved in this conversations was aware of the fact that 25 the lawsuit I was going to file against the Cult Awareness network it only being filed in an effort to get the 26 was baseless, and that 27 Cult Awareness Network to go bankrupt defending itself. As part of 28 the plan to bankrupt the Cult Awareness Network, it was decided 46831.1 Scarff\Scarff5 - re CAN\Page.00002 1 that an outside attorney that was not associated with Bowles & 2 Moxon, should be brought in for the prosecution of my lawsuit. One 3 of the attorneys engaged was an Oregon attorney, Michael Gordon. 4 I recently wrote to Mr. Gordon and demanded he turn over my file to 5 me. A true and correct copy of the file I received from Mr. Gordon 6 is attached hereto marked as Exhibit B. A quick review of the 7 documentation contained within Exhibit B, will reveal numerous 8 communications between Mr. Gordon and agents of the "Church'(, 9 including Aaron Mason and David Butterworth, in which the Church of 10 Scientology had promised to raise the money for Gordon to prosecute 11 an action on my behalf against the Cult Awareness Network. 12 I declare under penalty of perjury, that the foregoing is true 13 and correct. 14 Executed thisIC~ay of September, 1993 at Los Angeles, 15 California. 16 17 18 RY QCARFF, r ~ant 19 20 21 22 23 24 25 26 27 28 46831.1 2 ================================================================= 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. 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