HUB LAW OFFICES
Ford Greene, Esquire
California Bar No. 107601
711 Sir Francis Drake Boulevard
San Anselmo, California 94960-1940
Attorney for Plaintiffs
VICKI J.AZNARAN and
RICHARD N. AZNARAN
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
|VICKI J.AZNARAN and
RICHARD N. AZNARANPlaintiffs,vs.CHURCH OF SCIENTOLOGY OF
CALIFORNIA, et al.,,Defendants.
AND RELATED COUNTER CLAIM
|No. CV-88-1786-JMI (Ex)
DECLARATION OF FORD GREENE REGARDING ALLEGED “TAINT”OF JOSEPH A. YANNY, ESQUIRE
Date: September 9, 1991
FORD GREENE declares:
1. I am an attorney licensed to practice law in the Courts of the State of California, am admitted to the Bar of this Court, and am the attorney of record for Vicki J. Aznaran and Richard N. Aznaran, plaintiffs herein.
2. Defendants, and their counsel, have recently submitted an increasingly shrill litany of degrading aspersions regarding the nature of my alleged affiliation with defendants’ former lawyer, Joseph A. Yanny. The purpose of this declaration is respond
thereto in a general manner because a point by point refutation is not worth the time, effort and trouble required to articulate.
3. The suggestion, much less the claim, that I am somehow the puppet of Yanny is ludicrous. In short, my response to the allegations of defendants regarding the Yanny taint and the extent to which it has been alleged to be spread on me is as follows:
My writing in this case has thus far been stylistically and substantially consistent. As the court will note from my opposition to Scientology’s initial summary judgment motion (with the exception of the injudicious use of the term “Cult”) in this case to my most recent oppositions, I have a particular style of legal expression that is my own. The content and approach thereof is relatively consistent. The hand that so writes is mine, not Mr. Yanny’s.
4. I was responsible for articulating the theory which the California Supreme Court in Molko v. Holy Spirit Association (1988) 46 Ca1.3d 1096 found persuasive. That theory primarily deals with the interrelationship between deceit and coercion as those ingredients impact upon an individual’s ability to reason and capacity to exercise an informed consent to organizational affiliation. I am convinced that “brainwashing” is the intentional and deliberate application of specific and identifiable techniques designed to undermine an individual’s ability to reason and severely impair his capacity to exercise an informed consent so as to replace those volitional ingredients with an indiscriminate and unconditional obedience to the commands of the leadership. I understand the manner in which brainwashing attacks an individual’s sense of identity and achieves dominance of such individual. I am
convinced that a coercive, closed group or “cult” is a group of people, often masquerading in the guise of a religion, the members of which are unconditionally and indiscriminately obedient to the commands of a single leader who claims to have a direct relationship with God, or some greater-than-human source of authority.
5. In varying ways, and from different points of reference, my participation in the case at bar has involved the application, within the confines of the law, of the specialized knowledge I possess having to do the deceit and undue influence practiced by the Scientology organization. I believe my analysis in this regard, as it has been expressed in writing in this case, is ascertainable and has been consistent during the pendency of the case at bar. Joseph Yanny never has had anything to do with the way I think and the manner in which I apply and/or express the knowledge I possess.
6. I have met with John Koresko on a Saturday and Sunday in early August. In assisting Mr. Yanny accomplish the transition of the case back to my office, he delivered to me papers that had been filed in this matter during the period that Yanny was attorney of record (including papers, filed by defendants, which falsely stated that I had been in a rehabilitation facility for substance abuse). Mr. Koresko offered his assistance in helping me get up to speed. I provided Mr. Koresko with copies of Scientology’s table of authorities extracted from each of its six pending motions and sent him to the Marin County Law Library with instructions to make photocopies of each of the cases that was not a California case (I have a full-service California law library). I received no
litigation instructions of any sort from Koresko, Yanny originated or otherwise.
7. I am grateful for the on-going assistance that I have received from Gerry Armstrong. While I have worked – at times around the clock – he has assembled the products of my labors and ensured that they were prepared for filing and service. I have received no Yanny originated suggestions regarding how to litigate against Scientology from Armstrong and the suggestion that he is Yanny’s shill and that I am the dupe of both is laughable.
8. I am informed and believe and allege thereon that defendants have in the past, and will continue in the future, to exploit their fallen relationship with their former attorney as a manner of attempting to obfuscate the real issues in the case at bar. It is more expedient for Scientology to cry wolf and attempt to engender sympathy than to meet the issues head on and fight clean.
9. During my participation in the instant litigation, my office, my home, the home of girlfriend and her person have been the subjects of repeated and on-going surveillance. In spring 1989, Scientology operatives rented an apartment unit across the street from my office in order to maintain around-the-clock surveillance of me, my clients and friends. During the last month the street in front of my office and the parking lots across the street have been crawling with Scientology investigators with their cameras, video-cameras, binoculars, cellular telephones and yellow legal pads. My neighbors have expressed fear to me regarding the meaning of such activities. Scientology, through its chief “investigator” Eugene Ingram, has managed to generate
investigations of me by the F.B.I., Los Angeles County District Attorney’s Office and State Bar for allegedly committing perjury in what I am informed and believe has been an effort to obtain my “disqualification” from representing the Aznarans, or subject me to retribution for being so bold as to stand in opposition to the Scientology organization. I am informed and believe that the reason that Eric Lieberman telephoned me in February or March 1991 in order to seek a stipulated continuance of the April 9 trial date in the case at bar was so that Ingram would have enough time to generate a criminal prosecution against me. I am informed and believe that no such prosecutions will be forthcoming. I am informed and believe that in the spring of 1989 Scientology operatives searched through my office garbage, in order to find the names of cases, clients, and opposing counsel whom then were contacted in an attempt to stir up trouble for me; I have been contacted by such people who have reported such activities to me.
10. I am losing patience with the tactics of my adversaries. I assure the court that the moral conviction required to endure such extra-judicial harassment, and work around the clock responding to the pounds of motions filed by Scientology, would never exist were I another man’s puppet.
11. I am my own man and do not consult with Joseph Yanny concerning litigation strategies in this case.
Under penalty of perjury pursuant to the laws of the United States I hereby declare that the foregoing is true and correct according to my first-hand knowledge, except those matters stated to be on information and belief, and as to those matters, I believe them to be true.
Executed on September 4, 1991, at San Anselmo, California.
PROOF OF SERVICE
I am employed in the County of Marin, State of California. I am over the age of eighteen years and am not a party to the above entitled action. My business address is 711 Sir Francis Drake Boulevard, San Anselmo, California. I served the following documents:
DECLARATION OF FORD GREENE REGARDING ALLEGED “TAINT” OF JOSEPH A. YANNY, ESQUIRE
on the following persons) on the date set forth below, by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid to be placed in the United States Mail at San Anselmo, California: SEE ATTACHED SERVICE LIST
|[x]||(By Mail)||I caused such envelope with postage thereon fully prepaid to be placed in the United States
Mail at San Anselmo, California.
|I caused such envelope to be delivered by hand to the offices of the addressee.|
|[ ]||(State)||I declare under penality of perjury under the laws of the State of California that the above is true and correct.|
|[x]||(Federal)||I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made.|
DATED: September 4, 1991