I, Stacy Brooks Young, declare as follows:
1. I am over the age of 18 years.
2. I have been retained as an expert consultant and expert witness by Dr. Uwe Geertz's counsel in the case captioned Church of Scientology International v. Steven Fishman and Uwe Geertz, #CV-6426-HLH (Tx) currently pending for purposes of hearing the accompanying motion in the United States District Court, Central District of California. The statements herein are of my own personal knowledge and if called upon as a witness, I can testify competently thereto.
3. This declaration is submitted in support of Defendant Dr. Geertz's motion for costs, fees, expenses and sanctions following the dismissal of this action with prejudice by the court on February 22, 1994.
4. As a result of my nearly 15 years in Scientology, I am qualified to discuss the policies, procedures and practices of Scientology, including the issue of "of and concerning," plaintiff CSI's assertion that it moved to dismiss this case because of "harassment" by Dr. Geertz's counsel, Scientology's hatred of psychology, Scientology's practice of harassing its critics, the treatment Steven Fishman received at the hands of this organization, and the fact that Miscavige and his lieutenants are managing agents of CSI. My Extensive History in the upper Echelons of Scientology Management Qualify Me as an Expert.
19. At the end of 1977 I transferred to the United States Guardian's Office ("US GO") in Los Angeles. I was a staff member in the USGO from January 1978 through January 1982. The Guardian's Office was the part of Scientology that handled Public Relations, Intelligence and Legal matters for Scientology.
20. Because of my technical background, I was posted as the Organizing Officer ("Org Officer") for the Public Relations Bureau and, later, as the Org Officer for the entire Guardian's Office. As the Org Officer my functions included the handling of all personnel and organizational matters, such as correcting a staff member who made mistakes, taking care of staff members who were sick or upset or in trouble, recruiting new people for staff, and promoting or demoting staff members as needed. I was also responsible for the establishment and proper administration of all the Guardian's Office personnel throughout the United States. Because the Guardian's Office oversaw certain aspects of the administration of all other Scientology organizations, I became very familiar with the overall structure of Scientology and how the various organizations interact with each other and with the outside world.
21. In early 1982 I was assigned to a unit known as Special Project as a Public Relations Assistant under my husband, Robert Vaughn Young. In this position I became familiar with the L. Ron Hubbard archives material, which was the complete collection of all of Hubbard's personal papers, including diaries, letters, and notes that he had kept from a very early age.
22. Several months later Special Project became what is now Author Services, Inc. ("ASI"), a for-profit company whose ostensible purpose was to be L. Ron Hubbard's literary agency. I was taken out of public relations and made the Organizing Officer for ASI in April 1982. In this position I worked directly for David Miscavige, who was Chairman of the Board of ASI ("COB ASI"), to carry out his orders concerning the staff of ASI.
23. David Miscavige, known as DM, has been the head of Scientology since 1981. His loyalty to L. Ron Hubbard and Scientology is absolute, and he is utterly ruthless about maintaining his power. He moved the seat of power from ASI to the Religious Technology Center (RTC) in 1987, because it was more defensible to run Scientology from a non-profit corporation than from a for-profit corporation. At that point he appointed himself Chairman of the Board of RTC ("COB RTC"), which is his current title.
47. One afternoon, I was informed, along with the other staff members of the FREEDOM office, that our office was to be moved to another location across the street, outside the big blue Scientology complex which used to be Cedars of Lebanon Hospital at Sunset and Berendo in Hollywood, California. We were instructed to move to an office on the second floor of B building on Catalina Street. I was told that the FREEDOM office and the Treasury office of OSA US were to move out of the Scientology Complex because it looked like Lawrence Wollersheim was going to win his suit against CSC and the corporation had to be gutted of all its assets before the decision was handed down. All that would be left of CSC would be a shell consisting of a Treasury office and the FREEDOM office. When Wollersheim tried to collect from CSC, he would discover that there were no assets at all in CSC.
Miscavige is the managing Agent of Plaintiff CSI
138. As stated earlier, I was a Scientologist for nearly 15 years, from January 1975 until July 1989. I was in the GO and its successor (a name change only), OSA, for most of that time. I also worked in another part of Scientology called Author Services, Inc. ("ASI"). I was a Sea Organization ("Sea Org") member during my tenure on all of these posts.
139. All of the positions I held from 1978 until 1989 enabled me to observe firsthand the line of command and the organizational structure of Scientology. There is no question whatsoever that Miscavige now holds the same position of absolute power over Scientology, cutting across all corporate boundaries, that Hubbard had before he died. Just as Hubbard was the managing agent for the original mother church, CSC, Miscavige is the managing agent for the current mother church, CSI, via his position as Chairman of the Board of the Religious Technology Center ("COB RTC").
140. I first became aware of Miscavige in 1981, when a coup took place within Scientology. Until then there had been two arms of Scientology. The Guardian's Office was run by Mary Sue Hubbard and took care of everything external to the organization, such as public relations, government relations, litigation, and anything else that might hinder the expansion of Scientology. The other branch, the Commodore's Messenger Organization ("CMO"), ran Scientology itself under the direct command of Hubbard (known as the Commodore). Reality was directly contrary to Hubbard's repeated claims that he had resigned all management responsibility in 1966. The CMO directed all internal operations via an unincorporated group of highly dedicated Scientologists known as the Sea Org.
141. In 1981, I was a senior executive in the United States Guardian Office ("US GO"). One evening we were informed that the GO was being taken over by the CMO. From that time on Miscavige has had complete control over all branches of Scientology.
165. Anyone who disagreed with Miscavige or challenged his authority in any way was branded by Miscavige as a traitor who was out to destroy Scientology. This was why David Mayo was ousted, along with most of his staff. Many others were thrown out in 1981 and 1982 and replaced with people who would obey Miscavige's orders unquestioningly. Ray Mithoff, who replaced Mayo, is today one of Miscavige's top lieutenants. John Nelson, head of the CMO and director of all the Scientology organizations, was also ousted by Miscavige and replaced by a loyal follower, Marc Yager. Today Yager is another one of Miscavige's top people.
221. Miscavige feared that his own perjury and criminal actions would be exposed, and he ordered the attorneys on this case to do whatever they had to do to get rid of it before he had to testify either in deposition or at trial. No one but Miscavige has the authority to have ordered the Scientology attorneys to file for dismissal. Without any doubt, Miscavige personally orchestrated the dismissal of this case. See Exhibit 36, "Report of the Board of Inquiry into Scientology," by Kevin Victor Anderson, Q.C., the lieutenant governor of the State of Victoria, ir the Commonwealth of Australia. It is a thoroughly researched report on the dangers of Scientology, and includes an account on pages 134 and 135 of a woman who was "processed into insanity." This report led to Scientology being banned in Victoria for a number of years. Although the ban was later lifted, the report remains an excellent overview of the Scientology cult.
I declare under penalty of perjury under the laws of the United States of America and the State of California that the foregoing is true and correct.
Signed - (Stacy Brooks Young)
