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DECLARATION OF VICKI AZNARAN (July 18, 1990)

July 18, 1990 by Clerk2

Author: Vicki J. Aznaran
Download Document: Declaration of Vicki Aznaran (1990-07-18)

 

NURIK & KYLE, P.A.
Attorneys for Defendant
2937 S.W. 27th Avenue
Suite 203
Miami, Florida 33133
(305) 441-2400

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

CASE NO. CR-88-0616-DLJ

UNITED STATES OF AMERICA,

Plaintiff,

v.

STEVEN FISHMAN,

Defendant.

____________________________________________/

DECLARATION OF VICKI AZNARAN

I, VICKI AZNARAN declare as follows under penalty of perjury:

I joined the Church of Scientology in 1972. In 1978, after approximately four years as staff members, my husband and I joined the Sea Organization. From 1978 to early 1987, my husband and I worked most of our waking hours, with very few days off, at our various assignments within Scientology. I eventually became President of Religious Technology Center and,supposedly, the top “ecclesiastical” authority within Scientology. Richard was a high-level security officer. During this period my husband and I became intimately familiar with the structure and activities of various

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Scientology organizations. Among other things, I was briefed on and was sometimes a participant in meetings involving litigation tactics and various means used to attack and fight “enemies” of Scientology. In numerous instances I was in the chain of command for approval for such activities. From 1984 to 1987, I held the office of Inspector General, one of the highest worldwide offices in the organization and so was privy to the most arcane practices of the group.

The legal strategy of Scientology and the existence of numerous potential legal problems, some of which are set forth below, were known to me when I was a staff member in Scientology. Enemies of Scientology are deemed to be “suppressive persons” (” SPs”). One becomes a “suppressive person” by doing a suppressive act, such as suing Scientology as a litigant or lawyer. In the jargon of Scientology, when one is ” declared” this means that one has been declared a “suppressive person” and, therefore, may be harassed, hurt, damaged or destroyed without regard to truth, honesty or legal rights. It is considered acceptable within Scientology to lie, cheat, steal and commit illegal acts in the name of dealing with a ” suppressive person.”

This practice or policy is sometimes referred to as the policy of “fair game.” In the jargon of Scientology, a person who is “declared” is understood to be a suppressive person. This means that the person is ” fair game.” The fair

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game policy was issued in the 1960s. It was never cancelled. A document was issued for public relations reasons that purportedly cancelled “fair game”; however, that document stated that it did not change the manner of handling persons declared “SP.” In reality, the purported cancellation of fair game is at most a matter of semantics. Enemies of Scientology are treated as “fair game.”

David Miscavige was the Chairman of the Board of Author Services Inc., (“ASI”) in 1984 and 1985. ASI was incorporated to be the funnel through which profits from Scientology were channelled to L. Ron Hubbard and, therefore, it was very important within Scientology. Miscavige represented Hubbard in all aspects of controlling Scientology. He attended regular meetings with myself and other top officials of Scientology organizations to review the status of all Scientology’s activities, including its litigation and dirty tricks campaigns against Scientology’s enemies.

Because of my position and the regular reports that came across my desk I know that throughout my presidency of RTC that fair game actions against enemies were commonplace. In addition to the litigation tactics described below, fair game activities included burglaries, assaults, disruption of enemies’ businesses, spying, harassive investigations, abuse of confidential communications in parishioner files and so on. I specifically recall seeing one report regarding

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attacks against Bent Corydon after Scientology became aware that he was writing a book against Hubbard.

Other Hubbard writings encourage Scientologists to pursue litigation purely for harassment without regard to the merits of a claim to cause enemies to fold. Hubbard’s writings state:

“The purpose of the suit is to harass and discourage rather than to win…The law can be used very easily to harass, and…will generally be sufficient to cause [the enemy’s] professional decease. If possible, of course ruin him utterly.” Hubbard, “Magazine articles on Level O Checksheet” American Saint Hill Organization 1968.

As President of RTC and a Sea Organization member, I attended meetings concerning the numerous legal actions involving Scientology organizations. During this time period, I had personal access to all legal documents having to do with RTC. I received a report every day on my computer that included a synopsis of each ongoing legal case involving Scientology. I received, or so I was told, copies of every major motion filed in cases involving Scientology. I was on the “approval lines” for legal documents dealing with RTC. During this time period, I had the option of attending legal meetings, although some were mandatory. I attended many litigation meetings and became generally aware of Scientology’s dirty tricks and legal maneuvers. On specifics, I frequently deferred to in-house and outside counsel; however, at least in theory, I was the head of RTC

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and had access to any business or litigation “secrets” of Scientology.

It is the stated policy and practice of Scientology to use the legal system to abuse and harass its enemies. This crude, fundamental directive of Scientology is no secret. The policy is to do anything and everything possible to harass the opposing litigant without regard to whether any particular motion or maneuver is appropriate or warranted by the facts or applicable law. That policy was followed in every legal case I was involved with or learned about while a member of the Sea Organization. The management of Scientology consistently expressed and demonstrated a complete disdain for the court system, viewing it as nothing more than a method to harass enemies. Some examples of this are set forth below.

During litigation between Gerald Armstrong and Scientology, which was before Judge Breckenridge of Superior Court for Los Angeles County, the court ordered the production of Armstrong’s pre-clear (” PC”) folders. These are files maintained by Scientology on those who submit to interrogation sessions in a process called auditing. During the course of that litigation I was ordered to go through Armstrong’s folders and destroy or conceal anything that might support Armstrong’s claims against Scientology. This practice is known within Scientology as “culling PC folders” and is a common litigation tactic employed by Scientology.

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During other litigation in Los Angeles known to me as the Wollersheim case, I was told that the judge had ordered the production of Wollersheim’s folders. As ordered, I “culled” these files. In other words, I removed contents that might have been damaging to Scientology or might have supported Wollersheim’s claims against Scientology. For example, I removed evidence of events involving his family, the anguish this caused him, evidence of disconnection from family and evidence of fair game.

I was involved in numerous meetings concerning what is known to me as the Christofferson case in Portland, Oregon. This case was tried twice. In the first case, a Scientology witness by the name of Martin Samuels was coached and drilled for hours on how to lie convincingly or avoid telling the truth. Before or during the second trial he admitted to this course of conduct. In this litigation, a Scientologist by the name of Joan Shriver produced responsive documents that may have been incriminating. This was a serious breach of policy for which she was punished. These documents were ordered produced on such short notice that apparently files were not thoroughly “culled.” In another case, an attorney was severely criticized and almost fired for failing to properly coach and feed the desired answers to Heber Jentzsch. Mr. Jentzsch was, for public relations reasons, the purported head of the Church of Scientology International. During his deposition, Mr.

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Jentzsch was unable to answer fundamental questions concerning the management of Church of Scientology International.

In later 1979 and early 1980, there was a massive document destruction program undertaken to destroy any evidence showing that L. Ron Hubbard (“LRH”) controlled Scientology. I participated in this activity in Clearwater, Florida and am informed that there was also intensive document destruction at facilities in Gilman Hot Springs, California. From at least that point onward there was a continuous effort to hide or destroy any evidence of Hubbard’s control. For example, during an IRS investigation in 1984 and 1985, while in bed with pneumonia, I was ordered out of bed by Norman Starkey, who told me that they had received a tip from a Los Angeles police officer advising them of a pending IRS raid in Los Angeles. Mr. Starkey ordered me to go to a computer facility and insure that all information on the computers in Los Angeles that might show Hubbard’s involvement and control of Scientology’s money was destroyed except for one copy of each document. These copies were to be saved on computer disks which were to be hidden in secure storage places. At the time I was also instructed to destroy anything that would show the control of Mr. Starkey or Mr. Miscavige over Scientology.

In or about 1981, while working in a Scientology organization known as the Guardian’s Office, I had access to

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and observed various written and oral communication pertaining to illegitimate activities participated in by the Guardian’s Office. The Guardian’s Office attempted to infiltrate both governmental and private agencies including the IRS, the Department of Justice, and the American Medical Association and the National Institute of Mental Health. The purpose of this was to steal documents pursuant to Hubbard’s “Snow White” program. The goal of this program was to eliminate any negative reports about Hubbard and Scientology that may have been held by these various agencies.

While involved in Scientology I became aware of various operations directed against an author who had written a negative book about Scientology. The author, Paulette Cooper, was subjected to various forms of harassment. One operation included an attempt to frame her. A false bomb threat was written. Scientology agents lifted a fingerprint from Cooper’s apartment. These fingerprints were then transferred to the bomb threat letter. Ms. Cooper was subjected to an investigation and was not cleared until an FBI raid resulted in the seizure of Scientology documents that exposed the operation as a frame-up. There was at least one other operation directed against Ms. Cooper. The substance of it was to plant a boyfriend to reinforce and play upon her suicidal tendencies in the hopes that she would commit suicide.

In 1976 and 1977, the then-Mayor of Clearwater,

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Florida, Gabe Cazares, was involved with litigation against Scientology. Arrangements were made to have an attorney by the name of Merril Vanniere, a Scientologist, represent Mr. Cazares and sabotage his case. This plot was also exposed by documents obtained in an FBI raid of a Scientology facility. Also, in response to Mr. Cazares’ litigation against Scientology, an attempt was made to implicate Mr. Cazares in a staged hit-and-run accident.

During an IRS criminal investigation in the 1984 to 1985 time period, the IRS ordered production of various communications between Hubbard and Author Services, Inc. (ASI). The ASI staff worked literally day and night for several days reviewing documents so that unfavorable documents could be destroyed or otherwise concealed from the IRS. Lyman Spurlock and Marion M. Dendue, Scientologists involved in this operation, informed me of this operation. Also during this IRS investigation, my husband, Rick Aznaran, was ordered to remove and conceal any incriminating documents from certain locations. He was also directed to make the computer network “raid proof.” This involved creating a system where incriminating documents could be deleted from computer storage rapidly and before the IRS could obtain control over the computers.

I have examined certain documents regarding Steven Fishman’s experience with Scientology, have had conversations with Mr. Fishman’s counsel, and have reviewed

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the 1151- page autobiographical account of Mr. Fishman’s Scientology experience entitled “The Lonesome Squirrel.” Based upon my 15 years of experience in Scientology and my review of the Fishman materials, I offer the following conclusions:

1. I believe Mr. Fishman’s assertions that he was a member since 1979 and that he was as actively involved as he states. This belief is based on my experience that only a committed member of long standing would know the details of the inner workings of the group; Mr. Fishman has such knowledge. Awareness of certain confidential projects could be achieved only by a member who was trusted by the hierarchy; Mr. Fishman had such awareness. Involvement in a group that thrives on secrecy and excludes most members from participation in high-level projects means that any member who exceeds a certain level of involvement enjoys the trust of the leadership; such trust would be earned only by extended membership. Mr. Fishman enjoyed that trust. His accounts of meetings with high-level officials and his knowledge of the operations and functions of the hierarchy are so detailed and accurate that they couldn’t have been gained except through direct personal experience.

2. Refutation by Scientology officials of Mr. Fishman’s membership prior to February 8, 1986, and their disclaimer of his involvement and their lack of any records pertaining to such membership is perfectly consistent with

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their standard procedure in protecting themselves. As noted above, I was personally involved in the destruction of records when it suited their purpose. Scientology propounds the belief that any action whatsoever taken to protect the organization is justified, as the group takes precedence over the individual. Any member performing criminal acts for the benefit of the group was kept at arm’s length; if apprehended, the member was disavowed by Scientology. This procedure was used even on the wife of the founder of Scientology. Given the serious potential threat that Mr. Fishman’s defense posed to the group, I find Mr. Fishman’s account of certain members of Scientology’s involvement in the plan to fabricate the threats against Mr. Fishman and his counsel and to thereby undermine Mr. Fishman’s credibility and render him useless as a witness against Scientology to be consistent with their modus operandi.

I declare under penalty of perjury under the laws of the State of Texas that the foregoing is true and correct.

Executed this 18th day of July, 1990, in Dallas, Texas.

[signed]
VICKI AZNARAN

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Filed Under: Related Litigation Tagged With: Author Services Incorporated, By: Vicki J. Aznaran, Culling PC Files, David Miscavige, Declaration, Destruction Of Evidence, Fair Game, Gabe Cazares, Guardian Office, Infiltration, IRS Criminal Investigation, Lawfare, Mayor Cazares Handling Project, Merrell Vannier, Operation Freakout, PC Files: Armstrong, Religious Technology Center (RTC), SP Doctrine, Staged hit-and-run, US v. Fishman

ORAL DEPOSITION OF VICKI AZNARAN (Excerpt) (May 9, 1989)

May 9, 1989 by Clerk2

Author: Vicki J. Aznaran
Download document: Deposition of Vicki Aznaran (Excerpt) (1989-05-09)

 

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Vicki J. Aznaran – Volume 9 5-9-89

IN THE UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

VICKI J. AZNARAN AND RICHARD N. AZNARAN

VERSUS

CHURCH OF SCIENTOLOGY OF CALIFORNIA, INC.; CHURCH  OF SPIRITUAL TECHNOLOGY,  INC.; SCIENTOLOGY MISSIONS INTERNATIONAL, INC.;  RELIGIOUS TECHNOLOGY CENTER, INC.; AUTHOR SERVICES, INC.; CHURCH OF SCIENTOLOGY INTERNATIONAL, INC.; CHURCH OF SCIENTOLOGY OF LOS ANGELES, INC.; MISSION OFFICE WORLDWIDE; AUTHOR FAMILY TRUST; THE ESTATE OF L. RON HUBBARD;DAVID MISCAVIGE; AND NORMAN STARKEY

NO. CV 88-1786-WDK

ORAL DEPOSITION OF
VICKI J.AZNARAN

VOLUME 9

On the 9th day of May 1989, at 10:00 a.m. the oral deposition of the above-named witness was taken at the instance of the defendants before Roger W. Miller, Certified Shorthand Reporter in and for the State of Texas, at the offices of Stanley, Harris, Rice, 3100 McKinnon, Suite 1000, in the City of Dallas, County of Dallas, State of Texas, pursuant to the agreement hereinafter set forth.

STANLEY, HARRIS, RICE 214-720-4567
Vicki J. Aznaran – Volume 9 5-9-89 1495

A. What money was spent or how much money was  spent, which I believe was 250,000.

Q. Anything else you remember telling the FBI  about that incident?

A. I told them that it was Dick Story and Dick Bass were largely the players involved.

Q. Any other details you recall telling the FBI about that?

A. No, not offhand, I don’t recall anything else.

Q. Are there any other instances involving judges that you discussed with the FBI?

A. They wanted to know about Scientology executives going to see Marianna Pfaelzer one night.

Q. Anything else? That’s what you already talked about with Mr. Cooley, is it not?

A. Yeah. I think we went into that.

Q. Any other judges?

A. Yeah. Breckenridge and the Judge on the — the original Judge on the Wollersheim case. I don’t  know if “original” is the right word, but he was a judge on the case during, I believe, pretrial.

Q. What did you tell the FBI about Judge Breckenridge?

A. I told him about destroying documents that

 

STANLEY, HARRIS, RICE 214-720-4567
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Vicki J. Aznaran – Volume 9 5-9-89

 

Judge Breckenridge had ordered produced.

Q. What did you tell him about destroying those documents?

A. What did I tell him? I don’t remember specifically. That there were documents that he ordered his folders produced, and myself and some others went through those folders and took out and destroyed documents out of them that we did not want turned over.

Q. When you say he wanted his folders produced, who is that, judge Breckenridge?

A. Yeah. He ordered them turned over to him.

Q. His own folders?

A. Armstrong’s, Jerry Armstrong’s.

Q. And what did you tell the FBI about the first judge on the Wollersheim case?

A. Well, supposedly he had a son who was homosexual, and there was some — some operation with the son’s boyfriend, which was brought up to the Judge in order to try to get rid of that Judge, if —

Q. Do you recall any more —

A. I believe that’s what I told him, the drift of it, anyway.

Q. Do you recall telling him anything else about that incident?

A. Not specifically, no.

 

STANLEY, HARRIS, RICE 214-720-4567
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Vicki J. Aznaran – Volume 9 5-9-89

 

Q. Were you involved in that incident in any way?

A. Peripherally. No, not really. I was just there art of the time.

Q. It was not done at your instigation?

A. No.

Q. You did not participate in anything involving the Judge Pfaelzer incident directly?

A. Staff members — well, no, not really.

Q. You personally, I’m not —

A. Yeah. No, not really.

Q. Now, your knowledge of the facts that you related to the FBI concerning Judge Breckenridge is  firsthand, from what I understand you are saying?

A. The destruction of the documents?

Q. Yes.

A. Yes.

Q. You participated in it?

A. Yes.

Q. And you told that to the FBI?

A. Yes.

Q. And what is the source of your information concerning the first Judge on the Wollersheim case?

A. I believe David Miscavige.

Q. He told you about it?

 

STANLEY, HARRIS, RICE 214-720-4567
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STATE OF TEXAS
COUNTY OF DALLAS

This is to certify that I, Roger W. Miller, Certified Shorthand Reporter in and for the State of Texas, reported in shorthand the proceedings conducted at the time and place set forth in the caption hereof and that the above and foregoing pages contain a full, true, and correct transcript of said proceedings.

Given under my hand and seal of office on this the 9th day of May, 1989.

[signed]
Roger W. Miller, Certified
Shorthand Reporter No. 328
in and for the State of Texas

My commission expires December 31, 1989
STANLEY, HARRIS, RICE 214-720-4567

Filed Under: Related Litigation Tagged With: Aznaran v. Scientology, By: Vicki J. Aznaran, Culling PC Files, Deposition, Destruction Of Evidence, Judge Paul G. Breckenridge Jr., Lawfare: War Against Judges, PC Files, PC Files: Armstrong, Wollersheim v. Scientology

RESPONSE TO PETITION FOR WRIT OF SUPERSEDEAS OR OTHER APPROPRIATE STAY ORDER; MEMORANDUM OF LAW; STAY REQUESTED (December 22, 1988)

December 22, 1988 by Clerk2

Author: Paul Morantz, Esq.
Download document: Response To Petition For Writ (1988-12-22)
Exhibit: NOTICE OF MOTION OF BENT CORYDON TO UNSEAL FILE (October 11, 1988)
Exhibit: MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION OF BENT CORYDON TO UNSEAL FILE (October 11, 1988)
Exhibit: DECLARATION OF PAUL MORANTZ (October 11, 1988)

 

Filed Under: Armstrong 1 Appeals Tagged With: Armstrong 1 Documents Under Seal, Bent Corydon, Black Propaganda Campaign, Breckenridge Decision, By: Paul Morantz Esq., Case No. B038975, Destruction Of Evidence, Heber C. Jentzsch, Memorandum Of Law, Response

DECLARATION OF VICKI AZNARAN (August 9, 1988)

August 9, 1988 by Clerk2

Author: Vicki Aznaran
Download document: Declaration of Vicki Aznaran (1988-08-09)

 

I, Vicki J. Aznaran, make the following declarations on personal knowledge except where the context indicates knowledge based upon information and belief.

My husband Richard Aznaran and I are plaintiffs in the instant action wherein defendants (hereinafter referred to collectively as “Scientology”) have moved to strike our entire complaint and to prevent our attorneys from representing us.

2. As set forth in more detail below, my husband and I were involved with Scientology for approximately 15 years. For much of that time we were members of an organization known as the Sea Organization. This organization is an elite organization within Scientology. The Sea Organization has considerable influence and control over Scientology organizations. Generally, Sea Organization members hold the management posts within Scientology.

3. In 1978, after approximately four years as staff members, my husband and I joined the Sea Organization. From 1978 to early 1987, my husband and I worked most of our waking hours, with very few days off, at our various assignments within Scientology. I eventually became President of Religious Technology Center and, supposedly, the top “ecclesiastical” authority within Scientology. Richard was a high-level security officer. During this period my husband and I became intimately familiar with the structure and activities of various Scientology organizations. Among other things, I was briefed on and sometimes a participant in meetings involving litigation tactics and various

1

means used to attack and fight “enemies” of Scientology. In numerous instances I was in the chain of command or approval for such activities. The legal strategy of Scientology and the existence of numerous potential legal problems, some of which are set forth below, were known to me when I was a staff member in Scientology. Contrary to, what I understand to be claimed by defendants herein, Mr. Yanny did not reveal to me the legal strategies or secrets of Scientology. Nor did Mr. Yanny invent or open my eyes to the wrongs that I had suffered at the hands of Scientology.

4. I have become an “enemy” of Scientology. This has certain consequences that will influence what Scientology will do in this litigation. For example, it is important to understand that their value system allows dishonesty if done in the name of Scientology.

5. Enemies of Scientology are deemed to be “suppressive persons”(“SPs”). One becomes a “suppressive person” by doing a suppressive act, such as suing Scientology as a litigant or lawyer. In the jargon of Scientology, when one is “declared” this means that one has been declared a “suppressive person” and, therefore, may be, harassed, hurt, damaged or destroyed without regard to truth, honesty or legal rights. It is considered acceptable within Scientology to lie, cheat, steal and commit illegal acts in the name of dealing with a “suppressive person”.

6. This practice or policy is sometimes referred to as the policy of “fair game”. In the jargon of Scientology, a person who is “declared” is understood to be a suppressive person. This means that the person is “fair game”. The fair game policy was

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issued in the 1960s. It was, never cancelled. A document was issued for public relations reasons that purportedly cancelled “fair game”; however, that document stated that it did not change the manner of handling persons declared “SP.” In reality, the purported cancellation of fair game is at most a matter of semantics. Enemies of Scientology are treated as “fair game.”

7. It is my understanding, and I have so testified in my deposition, that when my husband and I escaped from Scientology we were not immediately declared suppressive persons or subjected to the fair game policy. Among other things, we were compelled to do certain things and sign various documents to escape and avoid being subjected to fair game treatment. As we have now sued Scientology, we are “fair game”.

8. From 1984 through early 1987, I was President of Religious Technology Center (hereinafter “RTC”). As President of RTC and a Sea Organization member, I attended many meetings concerning the numerous legal actions involving Scientology organizations. During this time period, I had personal access to all legal documents having to do with RTC. I received a report every day on my computer that included a synopsis of each ongoing legal case involving Scientology. I received, or so I was told, copies of every major motion filed in cases involving Scientology. I was on the “approval lines” for legal documents dealing with RTC. During this time period, I had the option of attending legal meetings although some were mandatory. I attended many litigation meetings and became generally aware of Scientology’s dirty tricks and legal maneuvers. On specifics, I frequently deferred to in-house and outside counsel, however, at least in theory, I was

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the head of RTC and had access to any business or litigation ” secrets” of Scientology.

9. As President of RTC, I was one of those responsible for retaining the services of Joseph Yanny as counsel for Scientology organizations. I supervised and worked with Mr. Yanny who served as coordinating attorney for RTC in 1985. I am not aware of any legal or corporate information concerning RTC that was available to Mr. Yanny but not available to me.

10. I am informed and believe that various Scientology organizations are contending that Mr. Yanny has somehow improperly educated me on the legal maneuvers, tactics and affairs of Scientology. Although such claims are consistent with litigation tactics of Scientology, which are not constrained by considerations such as truth and reality, the proposition that I need Mr. Yanny to educate me on the internal affairs of Scientology is simply wrong. I was one of the highest ranking members of Scientology and was involved in upper management. Mr. Yanny was a lawyer hired by management, of which I was a part, to work for it. Further, it was the practice during the time period in question to screen the information given to outside counsel such as Mr Yanny.

11. It is the stated policy and practice of Scientology to use the legal system to abuse and harass its enemies. This crude, fundamental directive of Scientology is no secret. In any event, this information did not come to me from Mr. Yanny. The policy is to do anything and everything possible to harass the opposing litigant without regard to whether any particular motion or maneuver is appropriate or warranted by the facts or applicable law. That policy was followed in every legal case I was involved

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with or learned about while a member of the Sea Organization. The management of Scientology consistently expressed and demonstrated a complete disdain for the court system viewing it as nothing more than a method to harass enemies. Some examples of this are set forth below.

12. During litigation between Gerald Armstrong and Scientology, which was before Judge Breckenridge of Superior Court for Los Angeles County, the court ordered the production of Armstrong’s pre-clear (“PC”) folders. These are files maintained by Scientology on those who submit to interrogation sessions in a process called auditing. During the course of that litigation I was ordered to go through Armstrong’s folders and destroy or conceal anything that might be damaging to Scientology or helpful to Armstrong’s case. As ordered, I went through the files and destroyed contents that might support Armstrong’s claims against Scientology. This practice is known within Scientology as “culling PC folders” and is a common litigation tactic employed by Scientology.

13. During other litigation in Los Angeles known to me as the Wollersheim case, I was told that the judge had ordered the production of Wollersheim’s folders. As ordered, I “culled” these files. In other words, I removed contents that might have been damaging to Scientology or support Wollersheim’s claims against Scientology. For example, I removed evidence of events involving his family, the anguish this caused him, evidence of disconnection from family and evidence of fair game.

14. I was involved in numerous meetings concerning what is known to me as the Christofferson case in Portland, Oregon. This

5

case was tried twice. In the first case, a Scientology witness by the name of Martin Samuels was coached and drilled for hours on how to lie convincingly or avoid telling the truth. Before or during the second trial he admitted to this course of conduct. In this litigation, a Scientologist by the name of Joan Shriver produced responsive documents that may have been incriminating. This was a serious breach of policy for which she was punished. These documents were ordered produced on such short notice that apparently files were not thoroughly “culled”. In another case, Mr. Yanny was severely criticized and almost fired for failing to properly coach and feed the desired answers to Heber Jentzsch. Mr. Jentzsch was, for public relations reasons, the purported head of the Church of Scientology International. During his deposition, Mr. Jentzsch was unable to answer fundamental questions concerning the management of Church of Scientology International. This may be what certain defendants are referring to when they say that they were dissatisfied with Mr. Yanny’s services and I protected him. There were those, including McShane, who were outraged by the embarrassing testimony of Mr. Jentzsch. This was blamed on Mr. Yanny. I did not wish. to discontinue using Mr. Yanny at RTC for this perceived problem.

15. In November, 1985, I was present at a meeting whereat Earle Cooley, a Scientologist lawyer, Lyman Spurlock and Norman Starkey, all high ranking Scientologists, announced that they were going to contact Judge Mariana Pfaelzer. Earlier that day Judge Pfaelzer had denied a Scientology motion for a temporary restraining order. After losing on the application there was a meeting to determine what to do about the situation. At the

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meeting Mr. Cooley had a file, that purportedly contained background and personal information on Judge Pfaelzer. During the meeting Mr. Cooley and the others announced that they were going to attempt to meet with Judge Pfaelzer that evening, at her house if necessary, concerning the litigation in which the temporary restraining order had been sought. Thereafter, Mr. Cooley and two others left with their file on Judge Pfaelzer. They returned several hours later at which time I was told that their attempts to contact Judge Pfaelzer had been unsuccessful.

16. In late 1979 and early 1980, there was a massive document destruction program undertaken to destroy any evidence showing that L. Ron Hubbard (“LRH”) controlled Scientology. I participated in this activity in Clearwater, Florida and am informed that there was also intensive document destruction at facilities in Gilman Hot Springs, California. From at least that point onward there was a continuous effort to hide or destroy any evidence of Hubbard’s control. For example, during an IRS investigation in 1984 and 1985, while in bed with pneumonia, I was ordered out of bed by Norman Starkey who told me that they had received a tip from a Los Angeles Police officer advising them of a pending IRS raid in Los Angeles. Mr. Starkey ordered me to go to a computer facility and insure that all information on the computers in Los Angeles that might show Hubbard’s involvement and control of Scientology’s money was destroyed except for one copy of each document. These copies were to be saved on computer discs which were to be hidden in secure storage places. At the time I was also instructed to destroy anything that would show the control of Mr. Starkey or Mr. Miscavige over Scientology.

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17. I have been informed and believe that a an improper affidavit was filed in a case brought by L. Ron Hubbard, Jr. in Riverside, California. The circumstances were as follows: The document purported to be an affidavit of L. Ron Hubbard. The signature of Hubbard was purportedly notarized by David Miscavige. It is my understanding that this affidavit caused the case to be dismissed. Subsequently, I was told by Pat Broeker, who had been living with Hubbard at the time, and by Miscavige, that Miscavige had not seen Hubbard between 1980 and Hubbard’s death in 1986. Accordingly, the affidavit was apparently signed, notarized and dated during a time period when Hubbard was in seclusion and not seen by the person who purportedly notarized the signature of Hubbard.

18. In or about 1981, while working in a Scientology organization known as the Guardian’s Office, I had access to and observed various written and oral communications pertaining to illegitimate activities participated in by the Guardian’s Office.

The Guardian’s Office attempted to infiltrate both governmental and private agencies including the IRS, the Department of Justice, the American Medical Association and the National Institute of Mental Health. The purpose of this was to steal documents pursuant to Hubbard’s “Snow White” program. The goal of this program was to eliminate any negative reports about Hubbard and Scientology that may have been held by these various agencies.

19. While involved in Scientology I became aware of various operations directed against an author who had written a negative book about Scientology. The author, Paulette Cooper, was subjected to various forms of harassment. One operation included an

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attempt to frame her. A false bomb threat was written. A Scientology agent lifted a fingerprint from Cooper’s apartment. These fingerprints were then transferred to the bomb threat letter. Ms. Cooper was subjected to an investigation and was not cleared until an FBI raid resulted in the seizure of Scientology documents that exposed the operation as a frame-up. There was at least one other operation directed against Ms. Cooper. The substance of it was to plant a boyfriend to reinforce and play upon her suicidal tendencies in the hopes that she would commit suicide.

20. In 1976 and 1977, the then Mayor of Clearwater, Florida, Gabe Cazares was involved with litigation against Scientology. Arrangements were made to have an attorney by the name of Merril [sp. Merrill] Vanniere [sp. Veneer?], a Scientologist, represent Mr. Cazares and sabotage his case. This plot was also exposed by documents obtained in an FBI raid of a Scientology facility. Also, in response to Mr. Cazares’ litigation against Scientology, an attempt was made to implicate Mr. Cazares in a staged hit-and-run accident.

21. During the time period of my involvement with Scientology, I also learned of various. attempts to influence judges or force their removal from cases. For example, a private investigator named Dick Bast obtained a statement from a prostitute concerning involvement with a certain judge in Washington, D.C. who was sitting on a Scientology case. This was then publicized. The judge did not continue on the case. The same investigator, Dick Bast was also hired for the purpose of attempting to force the removal of a judge in Tampa, Florida. This involved what I know as the Burden case, which was civil

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litigation brought by Michael Flynn. Dick Bast secured a yacht and attempted to get the judge on board for the purpose of filming him under compromising circumstances. The judge declined to go yachting and the operation was unsuccessful. Approximately $250,000.00 was spent on the operation.

22. I have been informed by Mark (Marty) Rathbun, a high ranking Scientologist, that his private investigator, Gene Ingram, “fed” a confession to Ala Tamimi when visiting him in an Italian prison. This false confession was, in substance, that Tamimi had been involved in a bad check scam involving an account of L. Ron Hubbard. This false confession implicated attorney Michael Flynn in the check scam. Michael Flynn was at the time considered a major enemy of Scientology because he represented numerous clients with claims against Scientology. This purported confession was used to slander and attack Michael Flynn. Michael Flynn has also been sued.by Scientology as part of its “strategy” for handling enemies.

23. During an IRS criminal investigation in the 1984 to 1985 time period, the IRS ordered production of various communications between Hubbard and Author Services, Inc. (ASI). The ASI staff worked literally day and night for several days reviewing documents so that unfavorable documents could be destroyed or otherwise concealed from the IRS. Lyman Spurlock and Marion M. Dendui, Scientologists involved in this operation, informed me of this operation. Also during this IRS investigation, my husband, Rick Aznaran, was ordered to remove and conceal any incriminating documents from certain locations. He was also directed to make the computer network “raid proof”. This involved creating a

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system where incriminating documents could be deleted from computer storage rapidly and before the IRS could obtain control over the computers.

24. In 1985, I attended a conference on “squirrels” attended by Miscavige, Starkey, Spurlock, and McShane, members of top management, and others. In Scientology jargon, “squirrels” are people who use or practice some procedures also used by Scientology but who do not submit to the total control of the Scientology organization and, perhaps most importantly, who do not pay a percentage of their auditing or counseling fees to Scientology. At this meeting, David Miscavige ordered that public Scientologists be organized and motivated to physically attack squirrels and disrupt their operations. This was stated to be pursuant to the standard guidelines of Scientology. Pursuant to such directives, efforts were undertaken to intimidate and disrupt these persons and their organizations.

25. In 1981, operation “Juggernaut” was commenced. The purpose of this was to destroy Michael Flynn who, as stated above, was representing various plaintiffs with litigation against Scientology. This operation contemplated the use of infiltration, propaganda and attempts to persuade clients to turn against him.

26. The Guardians’ Office got into so much trouble, and worse yet got caught, that it was decided in the early 1980’s that the Guardians’ Office should be disbanded. This was purely a public relations gimmick. In short, it was decided that the Guardians’ Office and Mary Sue Hubbard, its then leader, were to take the rap for all criticism and improper conduct. This scheme was laid out in various written communications I observed in 1981

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and 1982. (Of course, I was not allowed to keep or escape from Scientology with any such incriminating documents.)

27. Since the early 1970’s, Scientology has operated a forced labor camp known as the Rehabilitation Project Force (“RPF”). Staff members are incarcerated in the RPF for various real or imagined offense. People confined at this camp are forced to perform hard physical labor every day. They eat rice and beans, or left-overs, and wear rags. They are deprived of sufficient sleep. In 1987, I was confined in such a camp at Happy Valley for approximately six weeks. I worked all day and was confined in a room at night. To the best of my knowledge I was guarded 24 hours a day. They would not even let me shower alone. I had to obtain permission to use a bathroom. I was ill and not allowed to obtain medical treatment. I was not allowed to communicate with my husband nor was I allowed to obtain adequate sleep. I was told that I had gone insane and that my husband did not want to communicate with me. I was physically and psychologically abused both at Happy Valley and for numerous days thereafter in a process called “security checking”. Much oversimplified, I was grilled on a primitive lie detector called an E-Meter and made to understand that I would not be released, have my property returned, or escape fair game policy unless I eventually gave all of the “right” answers. Examples of ” right” answers were responses that I would not talk to a lawyer or consider suing Scientology. I had to give such answers before being released.

28. Recovering from the years of brainwashing, thought control and propaganda to which Scientology subjected me is a

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gradual process that I do not fully understand. I am not a psychologist or psychiatrist and do not fully understand the ramifications of what I have been through although I can observe and experience many symptoms. I have many nightmares and a fear of Scientology.

29. The suit brought by Richard Aznaran and myself is based upon real events that happened to real people, namely us. Just as my husband and I do not need Mr. Yanny to educate us on any secrets of Scientology, it is simply untrue that our claims were somehow invented or manufactured by Mr. Yanny. The whimsical notion that Mr. Yanny invented this litigation through my husband and me is simply false.

30. My husband and I consider Mr. Yanny to be a friend. Further, it might be noted that Mr. Yanny was to serve as my personal counsel in a class action against Scientology and numerous individuals including myself. Recent events have changed this, however, there was a period of time when Mr. Yanny was purportedly designated as my personal counsel with the approval of Scientology.

31. My husband and I feel quite strongly that we want Barry Van Sickle and the firm of Cummins & White to represent us in this case. Our reasons are both subjective and objective. We do not wish to list our subjective reasons, although we will do so if the Court requests it. Objectively, it might be noted that we had considerable difficulty finding counsel willing and in a position to undertake this extremely volatile, time consuming and expensive litigation. We are unable to pay hourly rates to pursue our claims and need a firm willing to work with us on a contingency

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fee basis. I anticipate great difficulty, delay and prejudice if forced to find other counsel.

32. Based upon my experience within Scientology and as a litigant against it, I understand that this is not routine litigation. If I am forced to find other counsel, prospective counsel will be presented with the following situation:

(a) A complex case that must be handled on a contingency fee and cost-advanced basis;

(b) A case that requires a litigation team and substantial financial resources;

(c) A case involving an opponent who has a practice and history of suing opposing lawyers as a tactic in addition to subjecting opposing lawyers to surveillance, depositions, infiltration, bad publicity and the full ramifications of the fair game policy;

(d) A case where the opponent is not constrained by a need to be cost effective, truthful, honest or reasonable; and

(e) A case that requires extraordinary security precautions.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Executed this 9th day of August, 1988, in Dallas, Texas.

[signed]
VICKI J. AZNARAN

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Filed Under: Related Litigation Tagged With: Aznaran v. Scientology, By: Vicki J. Aznaran, Check Forgery Frame, Culling PC Files, Declaration, Destruction Of Evidence, Enemies, Fair Game, Fair Game: Break-in of Government Offices, Guardian Office, Juggernaut, Lawfare: Culling PC Files, Lawfare: War Against Judges, Mary Sue Hubbard, Mayor Cazares Handling Project, Merrell Vannier, Operation Freakout, PC Files, Rehabilitation Project Force (RPF), Religious Technology Center (RTC), SP Doctrine, Squirrels

AFFIDAVIT OF GERALD ARMSTRONG (October 19, 1982)

October 19, 1982 by Clerk2

Author: Gerald Armstrong
Download document: Affidavit of Gerald Armstrong (1982-10-19)

 

Filed Under: Armstrong 1 Tagged With: Affidavit, By: Gerald Armstrong, Case No. C 420153, David Miscavige, Destruction Of Evidence, GA Bio, Gerald Armstrong Affidavit, L. Ron Hubbard, Norton Karno, Pat Broeker

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L. Ron Hubbard: Biographical

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Scientology Operations

1982 Mission Holders Conference Armstrong Operation Brainwashing Check Forgery Frame Christo Final Handling Eval Clearwater Project Code Name: Power Flag Landbase Setup Freeway Op George Edgerly Op Gerry Armstrong Project Goldmine Homer Schomer Salvage Mission Juggernaut Lavenda Van Schaick Production Plan List 1 Rock Slam Project London Op (June 1984) Los Angeles DA Frame/Investigation Loyalist Op LRH Safety Mayor Cazares Handling Project MCCS Mission MCCS Mission: II Mission All Clear Mitra Hall Frame Nobel Prize Project Operation Bulldozer Leak Operation Freakout Operation Off the Hook Operations Definitions Operation Snow White Operation Sore Throat Operation Weaver's Needle Project: Early Warning System Project Quaker Revolt In The Stars Scientology Victims Defense Fund Op Team Member System Theft of Briefcase Theft of IRS documents The Goodrich Suit Evaluation Thomas Janeway Op Tin Goose Unabomber Op Witness School
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