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Declaration of Vicki Aznaran

In this affidavit, Vicki Aznaran explains what brings apostates such as herself to make false declarations against Scientology. While you will often see the *initial* declaration of Vicki Aznaran used by critics, you will *not* often see it accompanied by this retraction.


Gerald L. Chaleff, SBN 39552
ORRICK, HERRINGTON & SUTCLIFFE LLP
777 South Figueroa Street, Suite 3200
Los Angeles, California 90017-5832
Telephone: (213) 629-2020

William. T. Drescher, SBN 93737
LAW OFFICES OF WILLIAM T. DRESCHER
PMB 338
23679 Calabasas Road
Calabasas, California 93102-1502
Telephone: (818) 349-8100

Attorneys for Non-Party
CHURCH OF SCIENTOLOGY INTERNATIONAL

Samuel D. Rosen, pro hac vice
PAUL, HASTINGS, JANOFSKY & WALKER LLP
399 Park Avenue, 3 1 st Floor
New York, New York 10022-4697
Telephone: (212) 318-6000

Alan K. Steinbrecher, SBN 79201
PAUL, HASTINGS, JANOFSKY & WALKER LLP
555 South Flower Street, 23rd Floor
Los Angeles, California 90071-2371
Telephone: (213) 683-6000

Attorneys for Non-Party
RELIGIOUS TECHNOLOGY CENTER

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

LARRY WOLLERSHEIM,  Case No. C 332 027
    Plaintiff,  Judge Charles W. McCoy, Jr.
                    DECLARATION OF
vs                  MICHAEL LEE HERTZBERG

CHURCH OF SCIENTOLOGY OF
CALIFORNIA,
    DATE:   October 15, 1999
Defendant.  TIME:   8:30 a.m.
    DEPT:   24

 

I, Michael Lee Hertzberg, hereby declare and state:

1. I am an attorney, admitted to practice before the courts of New York State, the District of Columbia Bar, Ninth Circuit Court of Appeals and the United States Supreme Court. I make the following statement of my own personal knowledge, and if called to testify thereto, I could and would do so competently.

2. I was counsel of record in Aznaran v. Church of Scientology of California, et al. I was present in May of 1994 in Dallas, Texas when Vicki Aznaran settled her then pending litigation against several churches of Scientology and related organizations. I was present to provide legal advice to the representatives of the defendants who were negotiating directly with Ms. Aznaran. She was represented by her attorney, Karen MacRae of Dallas.

3. On May 19, 1994 when Ms. Aznaran settled her litigation, she executed several declarations. Annexed hereto as Exhibits A - E are true and correct copies of the declarations executed by Ms. Aznaran. Her declarations cover a wide range of subjects. The most comprehensive declaration is annexed hereto as Exhibit A. This declaration provides an overview of her experience as a litigant against churches of Scientology, tactics used by individuals litigating against churches of Scientology, specific allegations from her complaint that she formally repudiated and ordered her attorneys to withdraw, the payment of thousands of dollars to witnesses for sworn statements against the churches of Scientology, and the addition of eleven pages of one of Ms. Aznaran's declarations by an attorney representing opponents of Scientology, Graham Berry.

4. The remaining declarations (Exhibits B - E), cover specific topics related to Ms. Aznaran's experiences as a litigant against churches of Scientology. Specifically, these declarations cover the following topics:

- Litigation tactics by Lawrence Wollersheim and Gerry Armstrong (Exhibit B);

- A specific refutation of claims that her testimony supports the contention that Church officials have destroyed documents in litigation (Exhibit Q;

- Ms. Aznaran's knowledge regarding Stacy Young (one of Mr. Wollersheim's witnesses) (Exhibit D);

- In this declaration Ms. Aznaran also repudiates allegations of corporate irregularities similar to those being made in the instant case (Exhibit A);

- A declaration in which Ms. Aznaran explains why she executed the other declarations and her response to what she anticipates other apostates will say about her for having revealed their tactics (Exhibit E).

5. I invite the Court's attention to particular passages relevant to the claims at issue here. Ms. Aznaran signed her declarations in May 1994, a year after her most recent statement cited by Wollersheim in support of his motion. In one declaration Ms. Aznaran explains how witnesses have been conditioned to sign affidavits to support whatever arguments opponents of churches of Scientology wish to "prove":

The abusive device most consistently utilized by litigants and counsel adverse to the Church occurs in connection with the filing of declarations or affidavits. It is common knowledge among the stable of disaffected ex-Scientologists who supply such sworn statements that the attorneys dictate the desired content of such testimony with the primary, often sole, purpose of presenting inflammatory accusations that prejudice the Church in the eyes of the court. In such declarations or affidavits, context, the truth, and relevance to the issues in the case are disregarded altogether. As time has passed and this technique has evolved, anti-Church litigants and their counsel have become more and more emboldened in making such declarations and affidavits because the tactic has proven to be so effective in poisoning courts and juries against the Church.

Thus, it has become a routine practice of litigants to make accusations against the Church, including even false allegations of threats of murder, which would be summarily thrown out of court as unsupported and scandalous in other litigation.

There is a group or "team" of anti-Scientology witnesses who are being paid for their testimony, and based on my experience, this testimony is being altered and falsified, either by the witnesses themselves or the attorneys.

(Ex. A, Declaration of Vicki Aznaran; 12, 17, 19.)

6. Ms. Aznaran even predicted that the attached declarations would be attacked by adverse litigants whose litigation tactics she has exposed:

On May 19, 1994, my husband and I each executed a series of declarations under penalty of perjury addressing a variety of issues. Among those declarations are one of mine that demonstrates that perhaps the most common litigation ploy that is used against Churches of Scientology is for opponents to submit false, inflammatory and accusatory declarations which make wild accusations irrespective of their falsity, lack of relevance, or lack of first hand knowledge.

I am executing this declaration on May 19, 1994 because I am certain that litigation opponents of the Church will react to one or more of my other contemporaneously dated declarations in precisely the fashion I describe in the preceding paragraph.

(Ex. E, Declaration of Vicki Aznaran; 2, 3.)

7. Ms. Aznaran identifies Stacy Young as employed by Graham Berry, Mr. Leipold's former co-counsel in Wollersheim, to create inaccurate affidavits:

I know from subsequent conversations I have had that Andre Tabayoyon is similarly employed, as are Vaughn and Stacy Young and others, each paid to create declarations for Mr. Berry when he needs them. On the basis of my knowledge of the Church and the declarants, I can state that these individuals are not "experts" 'in any recognized sense of the word as I understand it. They are nothing more than witnesses who are being paid to make sworn statements against the Church. More than just being paid, they are actually employed by Mr. Berry as a source of signed declarations of testimony or as a "source" of allegations, the need for such is decided by him.

(Ex. A, Declaration of Vicki Aznaran; 22.)

That Vaughn and Stacy Young are experts is not true. They are being called experts not due to expertise in Scientology but in order to collect insurance money for their testimony.

What this creates, and what the Youngs are part of, is a stable of people who, for pay, write declarations.

(Ex. D, Declaration of Vicki Aznaran; 7, 8.)

8. Ms. Aznaran also swore to Ms. Young's lack of knowledge of inside workings of churches of Scientology, both corporately and ecclesiastically:

In my staff capacities in the early 1980s, and later in my executive positions in the Religious Technology Center, I was directly or closely involved in meetings with senior staff members of various Church corporations. These senior staff made significant or major decisions which affected the future of the Church. I know that neither Vaughn nor Stacy Young were included in such senior decision-making processes. They were never senior or key Church executives. They were not consulted regarding, nor were they privy to, the meetings where major issues were discussed an decisions made.

I am informed that the Youngs have made claims to specialized knowledge about the corporate status and structure of the Church. Such claims are false. Neither of the Youngs were in a position to have detailed knowledge of the corporate and fiscal structures and operations of any Church of Scientology. In fact, Vaughn Young worked in the area of Public Relations for the entire time that I was acquainted with him. Stacy was primarily a writer in the Church public relations department.

(Ex. D, Declaration of Vicki Aznaran; 4, 5.)

9. Ms. Aznaran repudiated allegations of corporate irregularities that were contained in her complaint against the Church of Scientology of California. These allegations are very similar to those being made by Wollersheim in the instant case:

Paragraph 16 of the complaint included the allegation that I had been employed as a "missionaire" to remove assets of Defendant Church of Scientology of California to overseas trusts where they could not be accessed. This allegation was false, and it was not an allegation that either my husband or I requested be included in the complaint....

It was also alleged in paragraph 16 of the complaint that I was employed as a "missionaire" to "set up sham corporate structures to evade prosecution generally." This allegation is also false.

(Ex. A, Declaration of Vicki Aznaran; 8, 9.)

10. In another sworn declaration Ms. Aznaran identifies Wollersheim witness Gerald Armstrong as the source of a litigation technique utilized by this small group of witnesses:

The fundamental premise upon which the Church's adversaries and their lawyers operate is the likelihood that courts and juries are willing to believe any allegation made against the Church by a former member, without regard to plausibility, contrary evidence or the true facts. That concept was most succinctly expressed, on videotape, by anti-Scientology litigant, Gerald Armstrong, when he state that a lack of documents or evidence was no impediment to litigating against the Church when the litigant can "just allege it." The active pursuit of that litigation approach has now led to the formation of a small group of disaffected Scientologists who are now employed by an even smaller number of attorneys who are making a practice of litigating against the Church. This stable of witnesses can be relied upon to furnish "corroboration" for any allegation which an attorney wishes to make against the Church in pleadings, at deposition, in affidavits, and ultimately in trial testimony.

(Ex. A, Declaration of Vicki Aznaran; 5.)

11. Ms. Aznaran even addressed Larry Wollersheim's allegations:

While I was in the Church I witnessed the "Fair Game" allegations made by Gerry Armstrong and Larry Wollersheim in their litigation against the Church. My position in the church at the time gave me broad access to what was occurring and I would have known were the allegations made by Armstrong and Wollersheim true. Wollersheim, for example, made the allegation that a pipe bomb was found on his parent's lawn and, without any corroboration, blamed the Church. I know from my own personal knowledge that this outrageous allegation of Church involvement is absolutely false. During the Wollersheim trial, rumors began to spread throughout the trial courtroom that Judge Ronald Swearinger had been followed, his tires had been slashed, and his pet dog drowned, and that the Church was responsible for that supposed activity. All of those allegations of Church complicity were false, as I now personally attest. Armstrong alleged the Church was trying to kill him and this allegation was just made up. I know of its falsity of my own personal knowledge. Both Armstrong and Wollersheim, continue to make the same type of outrageous allegations of Fair Game to forward

their litigation to this day, due 'in no small measure to the fact that they practiced Fair Game so effectively in their earlier, victorious litigation against the Church."

(Ex. B, Declaration of Vicki Aznaran; 12.)

12. An allegation relied upon by Wollersheim is that David Miscavige ordered Vicki Aznaran and Jesse Prince to destroy documents, including documents compelled to be produced in this case. However, Ms. Aznaran states in another declaration:

During the time I was President of RTC, we fully complied to all discovery re uests, I have never received an order from David Miscavige, Norman Starkey or Lyman Spurlock to destro any documents related to litigation and I have no reason to believe that the Church would destroy any documents related to the consolidated cases...

(Ex. C, Declaration of Vicki Aznaran; 8.)

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

Executed this 20th day of September, 1999 at ______________.

MICHAEL LEE HERTZBERG

DECLARATION OF VICKI AZNARAN

I, VICKI J. AZNARAN, hereby declare as follows: I am over 18 years of age and a resident of the State of Texas. I have personal knowledge of the matters set forth herein and, if called upon to do so, could and would competently testify thereto.

2. From 1972 until 1987, I was a Member of various Church of Scientology ("Church") entities. During that time I held a number of important positions in the corporate and ecclesiastical hierarchy of the Church. I was also a devout believer in the religion of Scientology. In March of 1987, my husband Richard Aznaran and I left our positions with the Church and returned home to Texas from California. At the tine we left, Richard and I voluntarily executed certain releases and waivers in full settlement of any and all disputes we had with the Church. In April 1988, notwithstanding our execution of those releases and waivers, Richard and I filed a lawsuit against several Church entities and individuals in the United States District Court for the Central District of California.

3. During the time I was a senior Church executive, I gained first hand knowledge of the manner in which some apostate former Church members had pursued civil claims against the Church, and obtained successful verdicts or judgments or favorable settlements notwithstanding the merits. The courts consistently allowed the Church's adversaries leeway to introduce allegations without regard to the normal rules of procedure and evidence. At the time, this was a source of great concern to me, both as a Scientologist and a Church executive, particularly since my staff duties included responsibilities regarding certain areas of litigation.

4. Thus, having participated in Scientology litigation both as a Church executive and as a litigant against the Church, I bring two distinct, but related, perspectives to this declaration from my personal knowledge and observation. First, at the time my husband and I brought our own suit I understood that the legal system could be used to pursue my position. Later, upon having sued various Scientology churches and having allied myself with other litigants and their counsel suing Scientology churches, I observed first hand the ways in which the legal system is successfully used by litigants and counsel opposing the Church.

5. The fundamental premise upon which the Church's adversaries and their lawyers operate is the likelihood that courts and juries are willing to believe any allegation made against the Church by a former member, without regard to plausibility, contrary evidence or the true facts. That concept was most succinctly expressed, on videotape, by anti-Scientology litigant, Gerald Armstrong, when he stated that a lack of documents or evidence was no impediment to litigating against the Church when the litigant can "just allege it." The active pursuit of that litigation approach has now led to the formation of a small group of disaffected Scientologists who are now employed by an even smaller number of attorneys who are making a practice of litigating against the Church. This stable of witnesses can be relied upon to furnish "corroboration" for any allegation which an attorney wishes to rake against the Church in pleadings, at deposition, in affidavits, and ultimately in trial testimony.

6. The process of "just alleging it" begins with the complaint. For exanple, in the conplaint which was filed on our behalf against the Church, there were numerous allegations which were either false or which we could not substantiate. When I was initially deposed in our case, I conceded that numerous portions of the corplaint should not have been drafted by counsel in the fashion they were. Thus, for exanple, in deposition in June, 1988, 1 testified that the allegation in paragraph 7 of our complaint, that the "[Church' organizations were created solely for the purpose of making money from the sale of copyrights of the book Dianetics... was not true. I testified that I did not create corporate structures within the Church and that I do not where this allegation in paragraph 16 of our conplaint came frcm.

7. There were several other improper or incorrect allegations which should not have appeared in the complaint that I had to acknowledge in deposition. As another exarple, the complaint alleged in paragraph 16 that I worked for Author Services, Inc., in managing the sales of copyright of the book Dianetics. In deposition I testified that I never worked for Author Services, Inc. and was not aware of any such sale of copyrights.

S. Paragraph 16 of the corplaint included the allegation that I had been erployed as a "missionaire" to remove assets of Defendant Church of Scientology of California to overseas trusts where they could not be accessed. This allegation was false, and it was not an allegation that either my husband or I r requested be included in the complaint. I was definitely not employed for that reason, and I have never claimed that I was.

9. it was also alleged in paragraph 16 of the complaint that I was employed as a "missionaire" to "set up sham corporate structures to evade prosecution generally." This allegation is also false. I was never employed for that purpose. I had never even heard of that allegation until I read it in the filed cc-,plaint. I did not make that allegation, and I do not know where it cane from.

10. Paragraph 12 of the corplaint contains the false allegaticm that ny h-,;sI.-and and I were forced to "involuntarily ah~andon 'our] identities, spouses, and loyalties .... My depositicn testinony established that this was not the case. For exa7p2e, my hustand used to engage in his hobby of target shacting during his years in the Church. We had pets, including a Gerran shepherd which my husband trained in his spare time. I took riding lessons. I also trained in karate, because I was interested in learning that discipline. These were all ways in which my husband and I expressed our individuality while on staff and demonstrate no abandonment, forced or otherwise, of our individual interests.

ii. My husband and I both testified to numerous separate, factual errors in the complaint. our attorney firm, Curmins & White, and later our subsequent counsel, Ford Greene, were aware of these errors to which we testified. Even though we asked them to, no attempt to file a corrected or amended complaint was ever made, nor did any such correction ever occur.

4

12. The abusive device most consistently ~tilized by litigants and counsel adverse to the Church occurs in connection with the filing of declarations or affidavits. It is common knowledge among the stable of disaffected ex-Scientologists who supply such sworn s ;tatements that the attorneys dictate the desired content of such test.imony with the primary, often sole, purpose of presenting inflamriatory accusations that prejudice the Church in the eyes of the court. In such declarations or affidavits, context, the truth, and relevance to the issues in the case are disregarded altogether. As tire has passed and this technique has evolved, anti-Church litigants and their counsel have beco-,e more and 7--re emboldened in making such declarations and affidavits because the tactic has proven to be so effective in poiscning courts and juries against the Church.

13. The most common and probably the most devastating manifestation of this tactic is the use of allegations concerning the so-called "Fair Game" policy of the Church. The term "Fair Game" has been misrepresented and repeatedly used by the Church's litigation adversaries as a means to create prejudice against the Church. To accomplish that end, counsel fashions a declaration in which the witness identifies an ugly event -- real, imagined, or just plain invented -- and*then alleges that it was a deliberate act which was committed by the Church. The idea is to create the false impression that the Church is committing acts of retribution in pursuit of "Fair Game.11

14. A central element of exploiting the "Fair Game" tactic is to make certain that the allegations are crafted so they cannot be objectively disproved. In other words, the declarant makes an allegation of a bad or harmful or harassing act that cannot be documented in a tangible form, and then alleges that it was done by the Church pursuant to the Fair Gare "Policy." By so doing, the declarant has put the Church in the impossible position of trying to prove a negative and trying to prove it without documentation. It becomes a matter of the declarant's word against that of the Church, and by making the act alleged sufficiently despicable, the result is prejudice against the Church.

15. The Fair Game policy was a policy to forward Scientology's belief that any attacks on Scientology by those seeking to destroy it were to be vigorously defended by legal means and never ignored. It was not a policy condoning or encouraging illegal or criminal activities. The policy was misinterpreted by others and was thus canceled. It has since been used by litigants over the years as a vehicle to give credibility to allegations to try to prejudice courts against Scientology. An event happens such as someone's wife dies in a car accident, and the allegation is made that this is a murder committed by the Church pursuant to "Fair Game" policy. This technique is known to those who attack the Church and so they continue to use this term to try to prejudice the courts. These people feel comfortable making scandalous allegations, knowing that the Church does not have such a policy. I am unaware of any allegations of "Fair Game" being made by persons who have simply left the Church. Rather, the charges of Fair Game are invariably made by parties who have subsequently become involved in litigation with the Church and who have started working with other anti-Scientology litigants familiar with this tactic.

16. It has been my experience that these litigants and lawyers become emboldened because the history of Scientology litigation demonstrates that virtually any charge leveled against the Church in litigation by an avowed enemy, no matter how outrageous or unfounded, will be accepted and believed. Based on my experience it is a matter of common knowledge that efforts by the Church to refute such prejudicial allegations have commonly not been believed in the courts.

17. Thus, it has become a routine practice of litigants to make accusations against the Church, including even false allegations of threats of murder, which would be summarily thrown out of court as unsupported and scandalous in other litigation. They do it because it works, and they do it by deliberately mischaracterizing the term "Fair Game". They do it as an intentional means to destroy the reputation of the Church in the context of litigation so that they can win money or force the Church to settle.

18. The term "fair game" has become a catch phrase for those who attack the Church. When I was in the Church I never heard it referred to as a policy to be used, the only time it was discussed was in reference to litigation in which it was being alleged by Church adversaries. When I was in the Church, I knew that litigants opposing the Church were. constantly making fair game allegations against us and that those allegations were nonsense. I also know the frustration those allegations caused because of the willingness of courts and juries to embrace them. From my experience in litigating against the Church, I can see that nothing has changed in this regard. I also know from my experiences in suing the Church and from my association with other litigation adversaries of the Church that they know that "Fair Game" as they portray it is not Church policy. "Fair Game" exists only as a litigation tactic employed against the Church.

19. There are other things I have seen and experienced in anti-Scientology litigation that seem very unusual to me. There is a group or "team" of anti-Scientology witnesses who are being paid for their testimony, and based on my experience, this testimony is being altered and falsified, either by the witnesses themselves or the attorneys. For example, Graham Berry, counsel of record for a defendant in the case of CSI v. Fishman, filed numerous declarations from ex-Scientologists after the lawsuit was dismissed which had been purchased for many thousands of dollars. Mr. Berry told me that these payments were made possible because his client had insurance coverage.

20. In February of 1994, Mr. Berry called my husband and me and offered to hire us at the rate of $125 per hour for us to study materials in the Fishman case and to write declarations supporting issues Mr. Berry wished us to support in the Fishman case. Mr. Berry gave us an advance of $2,500, which we were expected to bill against services rendered. He told us that because his client in the Fishman case had insurance coverage, the insurance money enabled him to do this. He said he was able to get the insurance company to pay our salaries by naming us as "experts", which also enabled the use our declarations without regard to whether we were actually witnesses to the events at issue in the Fishman case, which we were not.

21. Mr. Berry told us he had assembled a team of former Scientologists for use in litigation, all of whom were employed by hin in the F-ish7,an case as so-called experts. Although we were not eager to get involved in Fishman's litigation, we agreed to do because the $2,500 advance by Mr. Berry was attractive. Mr. Berry sent us some documents from the court record in the Fishman case, which I read, since I was being paid $125 per hour to do so.

22. I know from subsequent conversations I have had that Andre Tabayoyon is similarly employed, as are Vaughn and Stacy Young and others, each paid to create declarations for Mr. Berry when he needs them. On the basis of my knowledge of the Church and the declarants, I can state that these individuals are not "experts" in any recognized sense of the word as I understand it. They are nothing more than witnesses who are being paid to make sworn statements against the Church. More than just being paid, they are actually employed by Mr. Berry as a source of signed declarations of testimony or as a "source" of allegations, the need for such is decided by him.

23. Later in February 1994, Mr. Berry called us again. He said that the Church had dismissed the Fishman case and he needed declarations from us on an immediate basis for use in his notion to recover attorneys fees and costs. I thought this was odd, since it seemed to me that one would support such a motion with receipts, bills, invoices, and such. Even though it seemed senseless to provide declarations after the case was dismissed, I told him I would provide a declaration because he had already paid and I would rather have done this than return the money he had paid us. He then told us what areas of testimony he wanted us to cover in the declarations. Accordingly, I transmitted to Mr. Berry's firm a eight-page declaration which I had prepared on my word processor and signed on the last page bearing the date of February 24, 1994.

24. 1 recently learned that Mr. Berry actually filed a nineteen-page declaration purportedly signed by me. Mr. Berry attached my signature to a declaration which I never saw or authorized.

25. Passages inserted without my knowledge or authorization in the version of my declaration filed by Mr. Berry include statements that are untrue and/or about which I have no personal knowledge. Not only did I not make these statements, I never heard of them before. The following are some examples of these falsities:

a) In my declaration there are statements concerning "Project Quaker" which are false. In fact I have never heard of "Project Quaker," and the statement in the version of my declaration Mr. Berry filed (paragraph 7) was not in the declaration I sent to Mr. Berry. It could not have been as I have never heard of "Project Quaker";

b) The statements in the filed declaration concerning the death of Michelle Miscavige's mother were added to without authorization by me. This included mention of the death of Heber Jentzsch's wife which is not something I had ever spoken to Mr. Berry about, and I have no knowledge and never heard anything that indicated there was anything unusual about Mr. Jentzsch's wife death. She died of natural causes. The statements concerning Flo Barnett's death were not put in context and were not meant to imply that there was any wrongdoing surrounding her death.

In approximately September 1985, when I was the Deputy Inspector General of Religious Technology Center ("RTC"), I learned that Mary Florence Barnett, Mrs. Miscavige's mother, had committed suicide. She had been involved with a group of disaffected former Scientologists who practiced altered versions of Scientology. I only know that after hearing about her death, both David and Shelly Miscavige were very upset over the fact that Flo Barnett had killed herself. I also wish to make known that I have seen mention in an affidavit by Vaughn Young that David Miscavige ordered the ratter "hushed up." This was stated in the context of indicating wrongdoing on Mr. Miscavige's part and insinuating he had some participation in the matter. A careful and literal reading of the statement shows that Mr. Young never actually says he knows Mr. Miscavige was involved in this suicide, or that there was any evidence of such, but by innuendo his statement still leaves this impression. To my knowledge there was never any order by David Miscavige or anyone else to keep the matter quiet. If any such order existed, it would most likely have been given to me. And since I took actions to rake the matter quite well known and never heard anybody, let alone David Miscavige, ask for the matter to be hushed up, I know this statement and the innuendo to be false;

c) the entirety of paragraph 16 on page 10 of the declaration filed by Mr. Berry concerning L. Ron Hubbard and the IRS was written by someone other than me and was inserted into my declaration without my knowledge or authorization. This entire paragraph makes unfounded and outrageous allegations intended to create the impression that David Miscavige or any other Scientologist would want Mr. Hubbard to die in order to avoid supposed IRS problems. This is unthinkable to any Scientologist, and I never heard this or any similar statement made by anyone in the Church.

d) Paragraph 15 of the declaration claims that "Earle Cooley Esq. and others convinced the San Luis Obispo coroner not to do an autopsy on Hubbard's body" implying there was something hidden or covered up about Mr. Hubbard's death. This is false. It was not written by me and I know of no such thing. I was in a position to have knowledge of this matter and I know that Mr. Hubbard died of natural causes and the statement attributed to me is a complete fabrication.

e) There is also a statement made in paragraph is that Mike Rinder's child received "Hubbard's baby care technology." The implication is that the child's death had something to do with Scientology which I never believed to be the case. I did not rake this statement and have no information that this was the case.

f) In fact, paragraphs 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35A and 35B were not in the version of the declaration that I sent to Mr. Berry to be filed. He added them after the fact, and I never saw them before this declaration was filed and I never gave authorization for Mr. Berry to add any of these things to my declaration.

g) The statements concerning the Church of Scientology International (11CSI11) and whether the Time article concerned CSI, and the corporate structure of the Church (paragraph 20) were also not in the version I signed and sent to Mr. Berry. And again, I know the statement to be entirely false.

h) One other point I wish to clarify concerning the use of "End of Cycle." There is nothing in Scientology writings which relates the term "End of Cycle" to connote murder or suicide. To my knowledge, this characterization of the term "End of Cycle" was invented by Steven Fishman. I have never heard this term used by the Church to mean "suicide" or "murder" and even though I an a disaffected ex-Scientologist, I know it to be a false-allegation. Its only use is to smear the Church for litigation purposes as detailed earlier. I earlier verbally told Mr. Berry this when he first contacted me for this exact information.

26. I gave no authorization for my declaration to be changed after I sent the signed copy of it to Mr. Berry and the changes made to my declaration were made without my knowledge or consent. Mr. Berry never contacted me after he filed the manufactured 19 page version of my declaration. Had I not later obtained a copy of the declaration filed by Mr. Berry from another source, I never would have found out about any of these alterations.

I declare under the penalty of perjury under the laws of the United States of Anerica, and under the laws of each individual state thereof, including the laws of the states of California and Texas, that the foregoing is true and correct.

Executed this 19th day of May, 1994 in Dallas, Texas.

Vicky Aznaran

DECLARATION OF VICKI J. AZNARAN

I, VICKI J. AZNARAN, hereby declare as follows: I am over 18 years of age and a resident of the State of Texas. I have personal knowledge of the matters set forth herein and, if called upon to do so, could and would competently testify thereto.

2. From 1972 until 1987, I was a member of various Church of Scientology ("Church") entities. During that time I held a number of important positions in the corporate and ecclesiastical hierarchy of the Church. I was also a devout believer in the religion of Scientology. In March of 1987, my husband Richard Aznaran and I left our positions with the Church and returned home to Texas from California. At the time we left, Richard and I voluntarily executed certain releases and waivers in full settlement of any and all disputes we had with the Church. In April 1988, notwithstanding our execution of those releases and waivers, Richard and I filed a lawsuit against several Church entities and individuals in the United States District Court for the Central District of California.

3. During the time I was a senior Church executive, I gained first hand knowledge of the manner in which some apostate former Church members had pursued civil claims against the Church, and obtained successful verdicts or judgments or favorable settlements notwithstanding the merits. The courts. consistently allowed the Church's adversaries le eway to introduce allegations without regard to the normal rules of procedure and evidence. At the time, this was a source of great concern to me, both as a Scientologist and a Church executive, particularly since my staff duties included responsibilities regarding certain areas of litigation.

4. Thus, having participated in Scientology litigation both as a Church executive and as a litigant against the Church, I bring two distinct, but related, perspectives to this declaration from my personal knowledge and observation. First, at the time my husband and I brought our own suit I understood that the legal system could be used to pursue my position. Later, upon having sued various Scientology churches and having allied myself with other litigants and their counsel suing Scientology churches, I observed first hand the ways in which the legal system is successfully used by litigants and counsel opposing the Church.

5. The fundamental premise upon which the Church's adversaries and their lawyers operate is the likelihood that courts and juries are willing to believe any allegation made against the Church by a former member, without regard to plausibility, contrary evidence or the true facts. That concept was most succinctly expressed, on videotape, by anti-Scientology litigant, Gerald Armstrong, when he stated that a lack of. documents or evidence was no impediment to litigating against the Church when the litigant can "just allege it." The active pursuit of that litigation approach has now led to the formation of a small group of disaffected Scientologists who are now employed by an even smaller numb er of attorneys who are making a practice of litigating against the Church. This stable of _ witnesses can be relied upon to furnish "corroboration" for any allegation which an attorney wishes to make against the Church in pleadings, at deposition, in affidavits, and ultimately in trial testimony.

6. The abusive device most consistently utilized by litigants and counsel adverse to the Church occurs in connection with the filing of declarations or affidavits. It is common knowledge among the stable of disaffected ex-Scientologists who supply such sworn statements that the attorneys dictate the desired content of such testimony with the primary, often sole, purpose of presenting inflammatory accusations that prejudice the Church in the eyes of the court. In such declarations or affidavits, context, the truth, and relevance to the issues in the case are disregarded altogether. As time has passed and this technique has evolved, anti-Church litigants and their counsel have become more and more emboldened in making such declarations and affidavits because the tactic has proven to be so effective in poisoning courts and juries against the Church.

7. The most common and probably the most devastating manifestation of this tactic is the use of allegations concerning the so-called "Fair Game" policy of the Church. The term "Fair Came" has been misrepresented and repeatedly used by the Church's litigation adversaries as a means to create prejudice against the Church. To accomplish that end, counsel fashions a declaration in which the witness identifies an ugly event -- real, imagined, or just plain invented -- and then alleges that it was a deliberate act which was committed by the Church. The idea is to create the false impression that the Church is committing acts of retribution in pursuit of "Fair Game.

8. A central element of exploiting the "Fair Game" tactic is to make certain that the allegations are crafted so they cannot be objectively disproved. In other words, the declarant makes an allegation of a bad or harmful or harassing act that cannot be documented in a tangible form and then alleges that it was done by the Church pursuant to the Fair Game "Policy." By so doing, the declarant has put the Church in the impossible position of trying to prove a negative and trying to prove it without documentation. It becomes a matter of the declarant's word against that of the Church, and by making the act alleged sufficiently despicable, the result is prejudice against the Church.

9. The Fair Game policy was a policy to forward Scientology's belief that any attacks on Scientology by those seeking to destroy it were to be vigorously defended by legal means and never ignored. It was not a policy condoning or encouraging illegal or criminal activities. The policy was misinterpreted by others and was thus canceled. It has since been used by litigants over the years as a vehicle to give credibility to allegations to try to prejudice courts against Scientology. An event happens such as someone's wife dies in a car accident, and the allegation is made that this is a murder committed by the Church pursuant to "Fair Game" policy. This technique is known to those who attack the Church and so they continue to use this term to try to prejudice the courts. These people feel comfortable making scandalous allegations, knowing that the Church does not have such a policy. I am unaware of any allegations of "Fair Came" being made by persons who have simply left the Church. Rather, the charges of Fair Care are invariably made by parties who have subsequently become involved in litigation with the Church and who have started working with other anti-Scientology litigants familiar with this tactic.

10. It has been my experience that these litigants and lawyers become emboldened because the history of Scientology litigation demonstrates that virtually any charge leveled against the Church in litigation by an avowed enemy, no matter how outrageous or unfounded, will be accepted and believed. Based on my experience it is a matter of common knowledge that efforts by the Church to refute such prejudicial allegations have commonly not been believed in the courts.

11. Thus, it has become a routine practice of litigants to make accusations against the Church, including even false allegations of threats of murder, which would be summarily thrown out of court as unsupported and scandalous in other litigation. They do it because it works, and they do it by deliberately mischaracterizing the term "Fair Came". They do it as an intentional means to destroy the reputation of the Church in the context of litigation so that they can win money or force the Church to settle.

12. While I was in the Church I witnessed the "Fair Game" allegations made by Gerry Armstrong and Larry Wollersheim in their litigation against the Church. My position in the Church at the time gave me broad access to what was occurring and I. would have known were the allegations made by Armstrong and Wollersheim true. Wollersheim, for example, made the allegation that a pipe bomb was found on his parent's lawn and, without any corroboration, blamed the Church. I know from my own personal knowledge that this outrageous allegation of Church involvement is absolutely false. During the Wollersheim trial, rumors began to spread throughout the trial courtroom that Judge Ronald Swearinger had been followed, his tires had been slashed, and his pet dog had drowned, and that the Church was responsible for that supposed activity. All of those allegations of Church complicity were false, as well, as I now personally attest. Armstrong alleged the Church was trying to kill him and this allegation also was just made up. I know of its falsity of my own personal knowledge. Both Armstrong and Wollersheim continue to make the same type of outrageous allegations of Fair Game to forward their litigation to this day, due in no small measure to the fact that they practiced Fair Came so effectively in their earlier, victorious litigation against the Church.

13. The term "fair game" has become a catch phrase for those who attack the Church. When I was in the Church I never heard it referred to as a policy to be used, the only time it was discussed was in reference to litigation in which it was being alleged by Church adversaries. When I was in the Church, I knew that litigants opposing the Church were constantly making fair game allegations against us and that those allegations were nonsense. I also know the frustration those allegations caused because of the willingness of courts and juries to embrace them. From my experience in litigating against the Church, I can see that nothing has changed in this regard. I also know from my experiences in suing the Church and from my association with other litigation adversaries of the Church that they know that "Fair Game" as they portray it is not Church policy. "Fair Game" exists only as a litigation tactic employed against the Church.

I declare under the penalty of perjury under the laws of the United States of America, and under the laws of each individual state thereof, including the laws of the states of California and Texas, that the foregoing is true and correct.

Executed this 19th day of May, 194 in Dallas, Texas.

Vicki Aznaran

DECLARATION OF VICKI J. AZNARAN

I, VICKI J. AZNARAN, hereby declare as follows: am over 18 years of age and a resident of the State of Texas. I have personal knowledge of the matters set forth herein and, if called upon to do so, could and would competently testify thereto.

2. From 1972 until 1987, I was a member of various Church of Scientology ("Church") entities. During that time I held a number of important positions in the corporate and ecclesiastic hierarchy of the Church.

3. Religious Technology Center ("RTC") is the owner of the trade secret rights in certain confidential scriptures of the Scientology religion referred to collectively as the Advanced Technology or the "Upper Level Materials." These confidential materials are commonly known individually as Power, SOLO Course, R6EW, Clearing Course, OT I - OT VIII and several higher OT levels which to my knowledge have not yet been released. Training in these highly confidential scriptures is available only in certain Churches of Scientology and only to Scientologists who have completed the required levels of, spiritual training which, as a matter of ecclesiastic doctrine, are a prerequisite to accessing the Advanced Technology. The Upper Level Materials are trade secrets and are treated as such. RTC and the Churches which offer the services based upon these confidential religious writings go to great lengths to protect the secrecy and confidentiality of the Advanced Technology. They are kept under lock and key and the copies of the materials are numbered and monitored through a logging system to ensure that only Scientology parishioners who have attained the requisite level of spiritual awareness are allowed access to the Upper Level Materials. Even then, such parishioners do not gain access to these scriptures until they have signed secrecy and confidentiality agreements. Moreover, parishioners who have access to these materials are not permitted to copy them, make notes from them, or remove them from designated rooms.

4. The Advanced Technology is otherwise not available to anyone. Thus, as to any version of any of the scriptures that comprise the Advanced Technology, if the material in question is in anyone's hands other than pursuant to the prescribed procedures, it must either have been stolen or otherwise misappropriated in violation of a covenant of confidentiality.

5. RTC and the Church take special care to protect and enforce its intellectual property and trade secret rights and to prosecute any theft, infringement, or unauthorized disclosure of the Upper Level Materials. When I was President of RTC information came to my attention which implicated David Mayo in the receipt of certain of the Upper Level Materials stolen from a Church in Denmark. That information led to the filing of the consolidated cases called Religious Technology Center v. Scott, et al. and Religious Technology Center v. Wollersheim, et al., Nos. CV 85-711 and CV 85-7197 were filed against David Mayo and others in the United States District Court for the Central District of California ("the consolidated cases").

6. After I left the Church, I met with Jerold Fagelbaum, one of the attorneys for David Mayo in the consolidated cases, in late June or early July 1988 when he cane to Dallas to gather information from me that would be of use to him in the litigation with RTC and the other Church plaintiffs. I have also executed a declaration for Mr. Fagelbaum's use in the consolidated cases in October of 1988 and have had my deposition taken in the consolidated cases. At no time in my interview with Mr. Fagelbaum, or in any of the above testimony -- or at any other time -- did I claim to have seen any handwritten manuscripts of those portions of the Upper Level Materials stolen in Denmark. What I did testify to is that I had seen the original version of these materials. They were all in typed form. Some of the typed originals had some minor handwritten notations on them. I never saw any original version of these materials which was handwritten by anyone let alone David Mayo.

7. However, I see from reviewing documents in the consolidated cases, that on several occasions Mr. Fagelbaum has argued that I had seen such handwritten manuscripts. This just is not true. Mr. Fagelbaum has also argued several times that I knew that materials from Mr. Hubbard's spiritual counseling folders were used in the creation of New Era Dianetics for Operating Thetans. This is also not true and I never told that to Mr. Fagelbaum, nor testified to such a fact. The truth is that I saw the original versions of these materials and the information which Mr. Hubbard used to create them. I never saw anything that would have come from Mr. Hubbard's spiritual counseling folders.

a. Mr. Fagelbaum has also argued that I said that the Church was engaged in massive document destruction in order to give the impression that documents related to this case were destroyed. I never said that. During the time I was President of RTC, we fully complied to all discovery requests. I have never received an order from David Miscavige, Norman Starkey or Lyman Spurlock to destroy any documents related to litigation and I have no reason to believe that the Church would destroy any documents related to the consolidated cases, especially regarding the authorship of the New Era Dianetics for Operating Thetans materials. All the documents I saw relating to the authorship of these materials showed that L. Ron Hubbard was the author and not David Mayo. I can see from Mr. Fagelbaum's arguments and papers that he created the impression that documents related to this case were destroyed in order to win the case, and that he used my testimony entirely unrelated to this matter as the prime support and corroboration of this false claim. He has misinterpreted what I said, and taken my testimony entirely out of context, as I never alleged any such thing, and in fact know the opposite to what he has argued is the truth.

I declare under the penalty of perjury under the laws of the United States of America, and under the laws of each individual state thereof, including the laws of the states of California and Texas, that the foregoing is true and correct.

Executed this 19th day of May, 1994 in Dallas, Texas.

Vicki Aznaran

DECLARATION OF VICKI J. AZNARAN

I, VICKI J. AZNARAN, hereby declare as follows:

1. I am over 18 years of age and a resident of the State of Texas. I have personal knowledge of the matters set forth herein and, if called upon to do so, could and would competently testify thereto.

2. From 1972 until 1987, 1 was a member of various Church of Scientology ("Church") entities. During that time I held a number of senior positions in the corporate and ecclesiastic hierarchy of the Church.

3. From 1981 onward I knew both Vaughn and Stacy Young, whom I met and had contact with as a result of my work as a staff. r,ember in the Church of Scientology. I am familiar with their positions in the Church.

4. In my staff capacities in the early 1980s, and later in my executive positions in the Religious Technology Center, I was directly or closely involved in meetings with senior staff members of various Church corporations. These senior staff made significant or major decisions which affected the future of the Church. I know that neither Vaughn nor Stacy Young were included in such senior decision-making processes. They were never senior or key Church executives.. They were not consulted regarding, nor were they privy to, the meetings where major issues were discussed and decisions made.

5. I am informed that the Youngs have made claims to specialized knowledge about the corporate status and structure of the Church. Such claims are false. Neither of the Youngs were in a position to have detailed knowledge of the corporate and fiscal structures and operations of any Church of Scientology. In fact, Vaughn Young worked in the area of Public Relations for the entire time that I was acquainted with him. Stacy was primarily a writer in the Church public relations department.

6. Another false allegation is Vaughn Young's claim to be not only knowledgeable about but personally affected by a dispute in 1986 and 1987 between David Miscavige and Pat Broeker concerning Scientology scriptures. I was with Broeker during this period and was aware of this situation. To my knowledge Vaughn Young was not in a position to know what happened during this dispute.

7. That Vaughn and Stacy Young are experts is not true. They are being called experts not due to expertise in Scientology but in order to collect insurance money for their testimony. When Graham Berry retained me for $2,500 to write declarations, he made it clear to me he would get me classified as an "expert" so the insurance company would pay.

8. What this creates, and what the Youngs are part of, is a stable of people who, for pay, write declarations. The Fishman case is a good example. Neither the Youngs nor I have ever met Steve Fishman.

9. Stacy Young apparently claims special expertise regarding Scientology scriptures. This is just another part of the sham that has been erected around this litigation. She doesn't hold herself out as an "expert" in her life outside of this litigation. It is only when testimony is needed for Mr. Berry th at the "expert" title is used.

10. To give an example of how this "expert" plan works, Vaughn Young claims, as an "expert," that Steven Fishman was known and discussed by senior Church executives and staff. For years in the inid-1980s I was one of the highest ranking executives in all of the Churches of Scientology. Furthermore, I never heard David Miscavige or Marc Yager, whom I had regular contact with, ever mention his name. Thus it is inconceivable to me that Vaughn Young would have heard any Church staff member or executive talk about Fishman. He was not in a position to know and I was.

11. The Youngs rely on innuendo to make allegations under the guise of "expert knowledge." Here are some specific exanples: a) that End of Cycle within the Church means committing suicide. There is no such policy and in fact this is totally contrary to Church policy and they know this; b) that members of the Church are involved in murder of adversaries. This never occurred at any tire and it is a lie that anyone connected with he Church would recognize including the Youngs; c) Vaughn Young implied that there might be something suspicious about the death f L. Ron Hubbard. This is fictitious scandal. I was a senior executive and can state that L. Ron Hubbard's death was not by anything other than natural causes; d) inferring that the death of Flo Barnett was covered up by Mr. Miscavige. There was never ny question that the cause of her death was due to self-inflicted gunshot wounds. Additionally, the facts are that there was never any order by David Miscavige or anyone else to keep the matter quiet. If such an order existed, I would have known about it: e) an additional forum in which this false information is spread in FACTNET. This is a computer base which seeks to create the impression that Scientology is somehow responsible for the deaths of certain individuals. Anyone who knows Scientology or has been involved with it knows this is not realistic.

12. The above are examples of the falsehood and innuendo created by the stable of false "expert" witnesses that has been created here.

I declare under the penalty of perjury under the laws of the United States of America, and under the laws of each individual state thereof, including the laws of the states of California and Texas, that the foregoing is true and correct.

Executed this 19th day of May, 1994 in Dallas, Texas.

Vicki Aznaran

DECLARATION OF VICKI J. AZNARAN

I, VICKI J. AZNARAN, hereby declare as follows: I am over 18 years of age and a resident of the State of Texas. I have personal knowledge of the matters set forth herein and, if called upon to do so, could and would competently testify thereto.

2. On May 4, 1994,.my husband and I each executed a series of declarations under penalty of perjury addressing a variety of issues. Among those declarations are one of mine that demonstrates that perhaps the most common litigation ploy that is used against Churches of Scientology is for opponents to submit false, inflammatory and accusatory declarations which make wild accusations irrespective of their falsity, lack of relevance, or lack of first hand knowledge.

3. I am executing this declaration on May 19, 1994 because I am certain that litigation opponents of the Church will react to one or more of my other contemporaneously dated declarations in precisely the fashion I describe in the preceding paragraph. Someone who knows nothing whatsoever of what transpired or why my husband and I have executed the May Lq1 1994 declarations will accuse us of "selling out" or being "bought out" or being forced by the Church to swear to matters that are not true.

4. Whoever makes any of those allegations or any similar allegations has no factual basis to make such a claim and has no knowledge of any of the pertinent facts. Their allegations are lies. The fact that they would make such an allegation at all is merely corroboration of my declaration of this date that litigation opponents of the Church will "just allege it" even if they have no competent evidence or facts. It is merely more evidence that they engage in a pattern of just alleging anything which forwards their positions, regardless of their truth. The statements I have made in my declaration are factual-and true and people who played no part in my independent decision to sign this and my other May ICT 1994 declarations know no facts to the contrary.

5. I have written this declaration as I know, both from my experience when a member of the Church, and since leaving the Church, that Church adversaries have routinely falsely alleged such actions against the Church. I also know both from my experience within the Church and from my experience since leaving, that these allegations are false and intended to incite prejudice against Scientology, which is then forced to defend itself and to attempt to overcome such charges.

I declare under the penalty of perjury under the laws of the United States of America, and under the laws of each individual state thereof, including the laws of the states of California and Texas, that the foregoing is true and correct. Executed this 19th day of May, 1994 in Dallas, Texas.

Vicki Aznaran

Gerald L. Chaleff, SBN 39552 ORRICK, HERRINGTON & SUTCLIFFE LLP 777 South Figueroa Street, Suite 3200 Los Angeles, California 90017-5832 Telephone: (213) 629-2020

William T. Drescher, SBN 93737 LAW OFFICES OF WILLIAM T. DRESCHER PMB 338 23679 Calabasas Road Calabasas, California 93102-1502 Telephone: (818) 349-8100

Attorneys for Non-Party CHURCH OF SCIENTOLOGY INTERNATIONAL

Samuel D. Rosen, pro hac vice PAUL, HASTINGS, JANOFSKY & WALKER LLP 399 Park Avenue, 31 st Floor New York, New York 10022-4697 Telephone: (212) 318-6000

Alan K. Steinbrecher, SBN 79201 PAUL, HASTINGS, JANOFSKY & WALKER LLP 555 South Flower Street, 23rd Floor Los Angeles, California 90071-2371 Telephone: (213) 683-6000

Attorneys for Non-Party RELIGIOUS TECHNOLOGY CENTER

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

LARRY WOLLERSHEIM, Case No. C 332 027 Plaintiff, Judge Charles W. McCoy, Jr. DECLARATION OF vs. NEIL LEVIN CHURCH OF SCIENTOLOGY OF CALIFORNIA, DATE: October 15, 1999 Defendant. TIME: 8:30 a.m. DEPT: 24

I, NEIL LEVIN, declare and state:

1. I am the President of Church of Scientology of California ("CSC"), the defendant in this action. I was a staff member of CSC from 1984 through 1992. I have served as CSC's President since 1993.

2. Auditing is one of Scientology's core religious practices. It is a form of one-to-one counseling that is conducted in a precise manner strictly in accordance with the Scientology Scripture and under the ethical guidelines of the Auditor's Code. The person receiving auditing is called a pre-clear, abbreviated as "pc." The "pc file" is a confessional formulary and contains a record of the parishioner's spiritual progress through his or her auditing. The pc file is maintained in strictest confidence by the auditor and the church.

3. In June 1985, approximately two weeks before this case was scheduled for trial, Wollersheim's counsel moved to have CSC produce his pre-clear file at trial. CSC opposed Wollersheim's attempt to compel the disclosure of the priest-penitent material contained in these files despite the fact that this material could have helped CSC to discredit Wollersheim as a witness during trial.

4. Wollersheim's motion was granted and CSC was ordered to produce his pre-clear files. (A true and correct copy of the Order is attached as Exhibit A.) The trial transcript confirms that the requested files were turned over to the Court. A banker's box containing Wollersheim's pre-clear files was turned over to Judge Swearinger who later stated in court, "I have been through them twice." He in turn provided Wollersheim's counsel with the opportunity to review them. (A true and correct copy of the relevant pages is attached as Exhibit B.)

5. CSC gave Judge Swearinger the originals (not copies) of Wollersheim's pre-clear files and they have remained in the custody of the Court ever since. CSC has retained a copy of the files it produced, which consists of approximately 2,000 pages.

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

Executed this 19th day of September 1999 at Los Angeles, California.

Neil Levin



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This web site is NOT created by a Scientologist. It is created by a Scientology EX-MEMBER who is critical of Scientology. However, this ex-member is ALSO critical of the anti-Scientology movement. This does not make him a Scientologist, nor a defender of Scientology.

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