ANDRE TABAYOYON AFFIDAVIT

19 August 1994

Copyright (C) 1994 Andre Tabayoyon
Redistribution rights granted for non commercial purposes.


GRAHAM E. BERRY, State Bar No. 128503
GORDON J. CALHOUN, State Bar No. 84509
LEWIS, D'AMATO, BRISBOIS & BISGAARD
221 N. Figueroa Street, Suite 1200
Los Angeles, California 90012
Telephone: (213) 250-1800

Attorneys for Defendants
UWE GEERTZ, PH.D.

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

CHURCH OF SCIENTOLOGY         Case No. CV 91 6426 HLH (Tx)
INTERNATIONAL, a California
non-profit religious          DECLARATION OF ANDRE
organization,                 TABAYOYON RE: MOTION FOR
COSTS
Plaintiff,
Date:  APRIL 4, 1994
VS.                           Time:  10:00 a.m.
Courtroom: 7
STEVEN FISH AND UWE GEERTZ,
Defendants.


DECLARATION OF ANDRE TABAYOYON

I, ANDRE TABAYOYON, declare as follows:

INTRODUCTION

1. I am over the age of 18 years.

2. I have been retained as an expert consultant and expert witness
by Dr. Geertz's counsel in the case captioned Church of Scientology
International v. Steven Fishman and Uwe Geertz, No. CV 91-6426-HLH (Tx)
currently pending in the United States District Court, Central District
of California. The statements herein are of my own personal knowledge
or reasonably based on information and belief, and if called upon as a
witness, I can testify competently thereto.

3. This declaration is submitted in support of defendant Dr. Uwe
Geertz's motion for costs, attorneys' fees and sanctions.

4. In preparation for this declaration, inter alia, read the
declarations submitted by David Miscavige ("Miscavige"), Marc Yeager,
Ray Mithoff, Guillaume LeServe and Norman Starkey in an effort to
persuade this Court that CSI has complied with the orders of the
Magistrate Judge and this Court to attend depositions.

5. Since being designated as an expert witness herein, I have
become aware of the presence of myself being under surveillance. On a
trip to Arizona I was followed by a van and a car. In Mesa, Arizona I
was followed to breakfast and the person was even aware that we knew he
was watching us. While in Newport Beach we were followed to and from
Mr. Berry's office daily. I am currently in my home and there is a blue
late model Pontiac waiting to follow me wherever I go.

PERSONAL SCIENTOLOGY BACKGROUND

6. Before I became a Scientologist, I enlisted in the United States
Marine Corps. I served one tour of duty in Vietnam. I was in the
infantry and assigned as a scout to secure sites, often behind enemy
lines, from which Marine snipers would eliminate targets using specially
constructed sniper rifles. It was also my responsibility to get the
highly trained and therefore very valuable snipers back safely to allied
lines. Because of the high likelihood that I would be operating for
extended periods of time behind enemy lines, I received escape and
evasion training both in the Philippines and in Vietnam. In addition to
escape and evasion training, I also received instruction on how to
resist anticipated brainwashing and coercive persuasion techniques
likely to be employed if I was captured alive. Because of the covert
nature of the operations to which I was assigned, I was also trained how
even the most innocent utensils could be used to end my own life and
thereby prevent any captors from extracting information that might
compromise my mission or my country. My missions required that I kill a
number of Vietnamese, including some at close range, some of whom died
in my arms. These events left a lasting and negative impression on me.

7. After returning from Vietnam, I was plagued by nightmares and
other disabling memories of my experiences as a front line combat
fighter. When I returned post traumatic stress syndrome was not well
understood. The military and veteran's hospitals provided almost no
assistance to me or a number of my companions who suffered from similar
problems. I was determined not to descend into the depths of
degradation that followed from the abuse of narcotics and other drugs,
whether legal or illegal.

8. While I was in this unsettled state, I was recruited into
Scientology. The attraction was, in part, the promise that Scientology
would provide me with the means to deal with these disturbing memories
and nightmares.

9. Various forms of coercive persuasion are used in all areas of
Scientology. A working term in Scientology is registration ("reg")
cycle. During a reg cycle, parishioners are coercively persuaded to do
something which a senior Scientologist believes will be good for
Scientology. In my 21 years of membership in Scientology, I personally
observed how auditors and others identify a person's "hot button." I
saw how auditors used many individual's hot buttons in the various types
of interviews (ethics, chaplin, registration, counseling, etc.) to
coerce the parishioner into donating money, doing the next service,
joining the Sea Org, going to the RPF and agreeing to forego spending
time with their children and families in order to devote greater time
and effort to the good of Scientology.

10. After joining Scientology, I became a member of the Sea
Organization ("Sea Org"). A Hubbard Communications Office policy letter
defines the Sea Org as: "The elite religious fellowship within the
Church of scientology. The Sea Org is not incorporated and is not part
of any corporation. Its membership is involved in Churn management and
the delivery of the higher level services of the Church." Finance
Series 11R. Exhibit A.

11. The indoctrination I received in the Sea Organization was
extensive. It fully acquainted me with the coercive methods that
Scientology uses on its staff and public. My training included the
following courses which had the content as indicated below:

(a) FLAG EXECUTIVE BRIEFING COURSE - All the policy ever written by
Hubbard about the running, debugging, and if needed, the creation of a
complete organization using thought reform ideas and practices in
conjunction with coercive persuasion on the staff and public.

(b) ORG EXECUTIVE COURSE - All the policy ever written by Hubbard
about the running, debugging, and if needed, the creation of a complete
organization using thought reform ideas and practices in conjunction
with coercive persuasion on the staff and public.

(c) SEA ORG OFFICER TRAINING - This course covered all of the Flag
Orders, Flag Ship Orders, Central Bureau Orders, mission school tech and
included all of the policy written by Hubbard about creating, running
and debugging a complete Scientology organization using thought reform
concepts and practices in conjunction with coercive persuasion on both
staff and public Scientologists.

(d) REHABILITATION PROJECT FORCE INDOCTRINATION TRAINING -

(e) REHABILITATION PROJECT FORCE SECTION OFFICER HAT -

(f) REHABILITATION PROJECT FORCE MASTER AT ARMS HAT - I learned in
the above course(s) how to use thought reform processes to make persons
amenable to persuasion.

(g) REHABILITATION PROTECT FORCE TECH IN CHARGE HAT - I learned how
to administer various thought, ideological and social reform procedures
to reorient now compliant subjects of thought reform- to accept
Scientology goals as articulated by Hubbard and/or Miscavige.

(h) REHABILITATION PROJECT FORCE QUAL IN CHARGE HAT - This training
taught me how to recognize misapplication of thought, ideological and
social reform procedures so as to maximize the effect that coercive
persuasion had on subjects under my supervision.

(i) REHABILITATION PROJECT FORCE CASE SUPERVISOR TRAINING - I was
taught how to use thought reform procedures to change the most
fundamental aspects of a subject's personality and exact a commitment
from the subject to further Scientology's goal of clearing planet Earth.

(j) REHABILITATION PROJECT FORCE AUDITOR TRAINING - I learned how
to use thought reform to coerce subjects into confessing their crimes
and sins against Scientology as a step towards their "rehabilitation" as
dedicated Scientologists.

(k) ROLL BACK TRAINING - I received training on how to trace
rumors, statements of disaffection or anti-Scientology thought back to
its source so that it could be obliterated and sources of disaffection
eliminated.

(l) BLACK PR RUNDOWN TRAINING - This training was to teach you how
to find out who is spreading negative information and to fully handle
him with coercive mind practices. I learned how to ferret out negative
information about Scientology; once found out, those who are guilty
become targets for internal "Fair Game" tactics such as the RPF's RPF.
RPF or general mental abuse.

(m) TRUTH RUNDOWN TRAINING - I learned how to use thought reform to
correct improper conduct by persons spreading rumors or black PR about
Scientology.

(n) INTROSPECTION TRAINING - I learned Scientological techniques to
reach persons who had suffered psychotic breaks during the thought
reform process. Persons in this condition were not capable of relating
to the real world. For the most part, introspection training focused on
limiting the stimuli to which the victims were exposed with the hope
that over time they would recover.

(o) FALSE PURPOSE RUNDOWN TRAINING - These are a whole series of
thought reform practices used to change people's way of thinking. I
learned how to supervise auditors reforming thoughts of people, while on
the RPF.

(p) FALSE DATA STRIPPING TRAINING - This is a technique to ferret
out and remove out tech (Non-orthodox Scientology) ideas and to replace
the out tech ideas with Hubbard's information.

(q) EDUCATION PROCESS KTL -This is a major training ordeal where
the person is completely re indoctrinated in the basic grammar and use
of the English language to communicate Scientological principles
concisely and correctly.

(r) TOO GRUESOME TRAINING - This training teaches a supervisor how
to instill complete terror and abject fear in subordinates so that the
subordinates will comply with the supervisor's orders without question.
I have been a member of various Churches of Scientology for 21 years
from 1971 to 1992. During this time, I received extensive and intensive
training as a Scientologist.

13. I was also a member of the Sea Organization ("Sea Org"),
which I joined in 1972. The Sea Org is a fraternal organization of
Scientologists zealously dedicated to the protection and advancement of
Scientology and its leaders. Sea Org members are expected to get their
assignments completed regardless of the obstacles. The staff of CSI,
RTC and all Scientology organizations above Class IV Orgs are Sea Org
members.

14. Hubbard established the Sea Org as an international solution
to periodic insolvencies which had afflicted various Scientology
organizations during the first decades of Scientology's existence.

15. Within Scientology, Sea Org members have unquestioned
authority over the affairs of Scientology organizations. This authority
is exercised in a number of ways. First, Sea Org members can be sent
into any Scientology Organization, or business owned by a Scientologist,
organization or a mission. Historically, Guardian Office Missions and
Sea Org Missions were one and the same. When Sea Org members are on a
mission, they have full ethics powers to take whatever steps are
necessary for the greater good of Scientology. CMO Int Messengers
(commodores messenger organization International Messengers) are always
on Mission so they had full authority to issue whatever orders they deem
appropriate. CMO Int Messengers had the full authority of Hubbard when
he was alive. Hubbard was then Commodore of the Sea Org. Now they have
the full authority of Miscavige.

16. The Sea Organization is to Scientology what the Communist
Party was to Soviet Russia and the Gestapo was to Nazi Germany. Indeed,
Sea Org members were not allowed to read communist doctrines, or
magazines and books about mind control and thought reform because of the
similarity to the Sea Org life that these documents present.

17. I signed the standard Sea Org contract requiring me to serve
the Sea Org for one billion years. This I would do by serving the Sea
Org in every one of my future lives with 21 year vacations at the
commencement of each life, so that the contract would not be void for
incapacity due to youthfulness or infancy.

18. As a Sea Org member, I received thousands of hours of training
in basic Sea Org policy. In 1977 I was assigned to the Rehabilitation
Project Force for 18 months. In 1980 I was assigned to the RPF for
another 2 1/2 years. In 1987 I was again assigned to the RPF for
another 18 months. Accordingly, I spent approx. six years in total on
the RPF. During these six years I also spent time --19 full days-- on
the RPF's RPF. The RPF's RPF is designed to totally destroy any
individual determinism to not want to do the RPF. RPF is a totally
involuntary type gulag or concentration camp. In order to get out, and
stay out, you must prove that you have altered the ideals, morals,
social and emotional and attitudinal values of another member of the RPF
of a long duration as evidenced by the physical actions and motions of
the person so altered. One must also prepare written evidence in the
form of success stories of how wonderful and voluntary the RPF was.
During my six years in the RPF, I spent five hours a day studying and
receiving instruction in Scientological matters. During the fifteen
years I spent with the Sea Org, when I was not on RPF, I spent two and a
half hours a day studying and receiving instruction in Scientological
matters. Applying simple math, I estimate conservatively that I
received over 28,000 hours of Scientology study and Scientology
instruction. My exposure to Scientology thought reform processes was
enhanced by other processes to which all Sea Org members are exposed.
These included: (1) indoctrination at daily musters; (2) briefings; (3)
missions; (4) Scientology justice actions; (5) crusades; (6) security or
sec checking; and (7) auditing. Auditing is the central practice of
Scientology. It involves the E Meter which is a simple
electrogalvanometer similar to, but not the same as, a lie detector.
One holds two tin cans attached to the E meter and goes into a hypnotic
state at the command of the auditor. These hypnotic states include
those called reverie and revivification.

19. I also studied and received instruction about Scientology
Policy, and Sea Org policy called Flag Orders. Information which
appeared in green printing on white paper and is called Hubbard
Communications Office Policy Letters ("HCO PLs"). I also studied and
received instruction about Scientology Technical Policy. This
information appeared in red printing on white paper and is called
Hubbard Communications Office Bulletins ("HCOBs.") I also spent
hundreds of hours listening to lectures taped by Hubbard. These tapes
included the Flag Executive Briefing Course tapes, the OEC tapes, the
Human Evaluation tapes and the Establishment Officer tapes to name a
few.

20. During my 21 years as a Scientologist, I also had many
occasions to see how these Scientology policies were applied in many
different contexts. The Hubbard Technology, often called Tech, was used
to supposedly help people. It was also used coercively to control the
behavior of people and to punish them for real or imagined
transgressions against Scientology.

21. During my tenure with the Sea Org, I held many posts. The
various posts or positions I held during my association with Scientology
included:

a. Commanding Officer, Master at Arms;
b. Missionary Unit, Commanding Officer;
C. Executive Director, Portland Crusade;
d. D/Executive Director, Los Angeles Crusade;
e. L. Ron Hubbard's Butler;
f. Executive Establishment Officer;
g. RPF Bosun WUS, Childrens RPF Bosun
h. LRH Spaces Set Up Mission 2nd;
i. LRH Studio Construction Mission In Charge;
J. LRH Renovations Mission In Charge;
k. Utilities Installation Officer;
l. Registrar;
M. Sea Org Recruiter;
n. Sea Org Ethics Officer;
0. Sea Org Officer;
P. Missionary;
q. Security Mission In Charge;
r. Berthing Security Watch, Hemet (Rover);
S. RPF Tech In Charge;
t. RPF Case Supervisor;
U. RPF Section Leader;
V. RPF Member;
W. RPF Qualifications In Charge; and
X. Estates Project Force Mission In Charge.

CONSTRUCTION PROJECTS AT HEMET BASE

While I was on various posts at Gold, near Hemet California, I was
also responsible for the following construction projects.

a. Constructing a full scale replica of a clipper ship complete
with sauna and jacuzzi. This was in the desert;
b. Construction of kitchens and dining facilities in all the office
facilities at the Hemet base;
c. A 20 Or 48 microphone battery lecture recording room;
d. An orchestra size music recording studio;
e. A film studio;
f. A complete 32 seat theater;
g. A complete film editing facility;
h. A complete sound editing facility;
i. A complete sound to film facility;
j. Two voice over studios;
k. A complete management office facility for CMOI;
l. A complete audio facility which had four individual recording
booths and three lecture mixing studios;
m. A 60' x 150' file archives facility;
n. A 65' x 165' tapes archives facility;
o. a 150' x 350' three story manufacturing facility;
p. A dining facility that could accommodate 1,100 people for a
minimum of three sittings per day;
q. A 200' x 500' construction and maintenance facility which houses
the planning and buildings areas;
r. A complete apartment complex for celebrities;
s. A complete office facility for Miscavige;
t. A complete lounge facility for Miscavige;
u. A complete dressing room for Miscavige;
v. A complete sound room for Miscavige;
w. A complete exercise room for Miscavige;
x. A complete security lighting system for the perimeter of the
Hemet base;
y. A complete deep well pump which provides 800 gallons per minute
to a 16" pipe supply system for the entire Hemet base;
z. A 1,000,000 gallon reservoir;
aa. A 1.8 mile exercise course;
ab. A nine hole golf course.
ac. Several miles of paved roads.
ad. Underground high voltage (12,500 volts) System
ae. An emergency generation station with 750 KW or power for
indefinite time.
af. A complete sewer system with 2 evaporation ponds to handle
4500 people.
ag. A 115 million gallon lake.
ah. A tennis court for Celebs and Miscavige
ai. Berthing facility for children at the Happy valley base.
aj. A large well for Happy Valley facility.

23. In these various Scientology posts, I observed how the inner
most parts of Scientology worked. I observed, participated in and was
victimized by coercive and manipulative thought control processes
designed to shape the thinking of the individuals upon whom these
procedures were imposed. These practices are particularly prevalent in
the Rehabilitation Project Force ("RPF"), a brainwashing and penal
operation very similar to what I had been trained to expect from the
Viet Cong, North Vietnamese and Red Chinese during my tour of duty in
Vietnam.

24. I knew L. Ron Hubbard ("Hubbard") personally. I worked
directly for Hubbard, the founder of the Scientology belief system.
Hubbard was Miscavige's predecessor as head of Scientology.

25. I worked personally with Hubbard on the ship called the
Apollo, from 1971-73. I personally observed Hubbard running all aspects
of Scientology and Sea Org and Guardian Office ("GO") networks. Indeed,
at the time I believed Hubbard has saved my life. I had been
"overboarded" or thrown aboard. Hubbard then ordered that I be pulled
out. Thereafter I believed Hubbard had saved my life and I became very
dedicated to both him and Scientology. I served as both steward and
butler for Hubbard. Accordingly, I was often alone with him -- even
when he was self injecting himself in the arm with a needle and
solution. This he did frequently. I would also lay out the pills he
took from 10 different numbered bottles.

26. I know Miscavige. I have also worked directly for him for
many years. Miscavige is a second generation Scientologist. He was
born into Scientology, a high school drop out and became one of
Hubbard's Commodores Messengers as a teenager. In this capacity, I have
been informed and believe that he was responsible for many multi-million
dollar illegal international currency transfers. He did this as an
innocent looking young courier. Miscavige has never known of a life
outside of Scientology. 'He is as close to a 'Rondroid' (L.R. Hubbard
droid) as it is possible to be. He rules Scientology like David Koresh
ruled Waco and the Branch Davidians. He endorses Hubbard's goal of
Scientology taking over the entire planet including all heads of
government and news media. See Exhibit____. Hubbard said "take all of
the people, put them in Scientology and have them run under the
processes of Scientology." Hubbard's plan is for Scientology to
interface with planet earth for one person to be in charge and for the
whole planet to be under a Scientology seven Division org board.

27. Miscavige is now the 'ecclesiastical' head of Scientology. He
is commander of the Scientology Sea Organization ("Sea Org"). He is
also Chairman of The Board ("COB") of the Religious Technology Center
("RTC").

SCIENTOLOGY IS ARMED AND DANGEROUS

28. In 1991 I had to prepare the base so that it could be defended
against the possibility of being taken over by the authorities in a time
of crisis. There are approx. 750 people at the base. I was in charge
of a project designing the base security system, the perimeter fence,
the ultra razor barriers, the lighting of the perimeter fence, the
electronic monitors, the concealed microphones, the ground sensors, the
motion sensors and hidden cameras which were installed and all over the
area -- even outside the base.

29. Church monies were used to purchase semi-automatic assault
rifles (HK 91 assault rifles capable of firing 300-350 rounds of
ammunition a minute, 45 caliber pistols, .380 automatic weapons and
twelve gauge shotguns were stockpiled. These weapons were not
registered. Church monies were also used to buy the ammunition.

30. Church monies were also used to purchase a large amount of
pounds of gunpowder for the construction of various types of explosive
devices to be used in the defense of the base.

31. The motorcycle guards were trained to carry loaded cocked 45
caliber pistols. The eagle scout, mounted high above the base, was
trained to carry a high powered rifle with a telescopic scope. There is
also a 1,000 millimeter telescope up with 'eagle'.

32. I developed three classifications of intruder and established
the level of deadly force to use for each. In addition to firearms, the
guards were taught how to effectively wield little batons. The basic
things like striking to the center of the heart, the center of the solar
plex and then to the side of the head, etc.

33. At church expense, I trained the security guards and other
base personnel in the use of these weapons and explosives. I also
trained them in the close quarter use of fatal force. We built a combat
range for training purposes and I instructed Scientologists on various
ways of shooting people. I also trained them in night vision and ambush
techniques. We used a ravine that was a natural round shield so the
noise would not cause any noisy inquiries.

DELIBERATE MISUSE OF THE HUBBARD TECH TO HARM SCIENTOLOGISTS WHO
HAVE FALLEN OUT OF FAVOR WITH MISCAVIGE: BLACK DIANETICS REVERSE
PROCESSING AND STEVEN FISHMAN.

34. During the more than two decades of experience I had in
Scientology, I observed on many occasions the Hubbard Tech being used as
intended to assist persons to come to grips with themselves and events,
persons and things around them. However, I also observed the Hubbard
Tech being deliberately misused to punish Scientologists who were out of
favor with either Hubbard or Miscavige. When the Hubbard Tech is
deliberately misused to cause harm, the practice is called Black
Dianetics or Reverse Processing. It is my opinion that Fishman was the
victim of Black Dianetics and was only saved, by the intervention of Dr.
Geertz, from an imminent suicidal incident. The basis of my opinion in
this regard is as follows:

(a) Fishman was not a Scientology minister or minister in training
yet he was sold E Meters;

(b) Fishman was an illegal p.c. (preclear) because of his past
psychiatric counselling;

(c) Fishman was sold Scientology materials such as the whole track
tapes, the Philadelphia tapes, the history of man book, auditing
materials and how to use the E Meter book.

This was the application of Black Dianetics because:

(a) Fishman was not properly trained in the use of the E meter;

(b) My experience as an RPF case supervisor in handling cases such
as Fishman leads me to the opinion that Fishman was being encouraged to
use the tech on himself rather than under the supervision of supervisors
and auditors. This would, in MY opinion, only lead to disastrous and/or
suicidal consequences. Indeed, L. Ron Hubbard in 'Some Notes on Black
Dianetics' states "a person can drive himself mad on Dianetics without
any trouble" ... "with Black Dianetics you could tailor make any kind
of insanity you want to. The person might not manifest this the next
day, maybe not for thirty days. Maybe three months later he is walking
down the street and feeling a little bit tired when somebody honks just
right or something of the sort, all of a sudden he goes crazy and there
he is -- insane! It's a wonderfully smooth way of committing murder."
Emphasis added. Exhibit.

35. My observations were direct and personal. I am a highly
trained RPF auditor. When I had responsibilities for overseeing how the
Scientology auditing technology is applied to cases of Scientologists
assigned to the RPF, I received orders directly from Miscavige, Marc
Yeager, Ray Mithoff, Sandi Wilhere and Hansuli Stalli, and others, to
misuse the Hubbard Tech to create extreme mental and emotional distress
and insanity in persons I was instructed to 'security or sec check'. We
used the Hubbard Tech, including security checking on the E-Meter, in
conjunction with well used coercive mind control techniques of sleep
deprivation, starvation, dehydration and denial of decent
accommodations. As an example of the appalling conditions to which
RPFers are sometimes exposed, on one occasion when I was on RPF, my
sleeping facility was a slab inside the vault of the morgue of the old
Cedars Sinai Hospital. While on the RPF at Gold, I also occupied the
chicken coop dormitory. This was an old chicken coop which still
smelled of chicken coop droppings. However, it was not only RPFers who
were deprived of adequate food and sleep. At Gold, hundreds of Sea Org
members would be deprived of adequate sleep and put on a diet of rice
and beans sometimes for six weeks at a time-and their weekly pay of
approximately S30.00 would be cut in half. This would be punishment for
lower ethics conditions such as poor production. However, when this
occurred, David Miscavige would still eat his bacon, eggs, sandwiches
and steak dinners.

36. The response of human beings to these conditions is somewhat
predictable. I saw many people undergo psychotic breaks. By psychotic
breaks I mean being reduced to incoherent babbling, stripping off
clothes, crawling around on the ground, banging heads, limbs and other
body parts against furniture and walls, barking, losing all sense of
one's identity and intense and persistent suicidal ideation. This is
what Scientology calls the PTS type III phenomena. There is a policy
which describes this. Exh O. I have seen many PTS type III cases. It
is my opinion that Fishman has been deliberately driven PTS type III by
Black Dianetics and/or reverse processing.

37. I participated in deliberately inflicting this process on
others in Scientology. I was a Case Supervisor on the RPF. This means
that I saw the auditing folders of all the persons assigned to the RPF
while I had this responsibility. I saw that the Tech was regularly
misapplied for harmful purposes. The case notes prepared by auditors
during auditing sessions were altered or deleted by senior executives.
This prevented a subsequent auditor from properly assessing and handling
the individual. It is like flying blind without instruments. The
potential for doing something seriously harmful is therefore greatly
enhanced.

38. I was advised by Richard Aznaran, Sinar Parman and Annie
Breeder that Hubbard was an unhandled PTS III when he died. According
to Sinar Parman, Hubbard was a psychopathic insane person screaming
about BT's and clusters at the top of his lungs.

39. I was also ordered to audit a number of persons, including
Stacy Young, while they were on the RPF. The files I was provided
relating to Stacy showed that I would be auditing a stable, well
adjusted person. When Stacy was led into the auditing room, I was
confronted with a disheveled, irrational and incoherent person whom I
hardly recognized. Stacy spent the first half hour or so of the session
babbling and crying hysterically. Her folder had obviously been altered
to maximize the likelihood that further auditing would harm her.

40. What I know from training and experience to be Black Dianetics
and reverse processing were also inflicted on me. I survived the
processing without experiencing a psychotic break. I believe the
extensive survival training I received as a Marine is allowed me to
escape the extreme degradation and self-degradation I saw others
experience.

SCIENTOLOGY RELATED MURDERS AND SUICIDES

41. I also observed a number of individuals go crazy when exposed
to the Hubbard Tech even absent malicious intent on the part of the
persons applying the Tech. For example, I saw John Colletto go
psychotic after he was exposed to the OT III level (Operating thetan
level III) materials. He got a pistol. In my presence, he shot his
wife in the head. She died instantly. Then John ran a short distance
before turning the pistol on himself and committing suicide. Moreover,
John Travolta's auditor told me of two occasions on which John Travolta
went into deep depression after auditing and therefore suffered a
psychotic break.

42. I personally observed a number of other Scientologists go
crazy and commit suicide as a result of the auditing processes. Bob
Shaffner and I were serving sentences on the RPF's RPF together.
Although inmates are not allowed to speak to each other while on the
RPF's RPF, Bob made it a point to tell me two or three times daily that
he was going to kill himself because of what he experienced during RPF's
RPF & OT III auditing. One day we were working on dangerous machinery
and Bob suddenly thrust his finger into the machine which cut his finger
off. Scientology management was fully aware of Bob's condition. He was
placed on the risk of suicide list. Because he was suicidal, his
berthing quarters while in the RPF were limited to first floor
facilities. Whatever was done, if anything, to help Bob failed. He
successfully committed suicide several years later.

43. I saw the Scientology thought reform procedures applied to a
large number of Scientologists who were placed on RPF or the RPF's RPF.
These procedures brought about long-lasting changes in the attitudes,
values, personalities and behaviors of the subjects. Some of the
victims I processed were Tom Ashworth, Clarisse Brousseau, Betsy Byrne,
Al Crevello, Steve Crevello, Julie Fisher, Janadair Hockaday, Fred
Houch, Annie Logan, Jim Logan, Judy More, Toni Prybilsky, Tom Saeker,
Johnny Schleshenger, Homer Schomer, Jeff Wrothwiler, Stacy Young and
many others.

44. I observed, participated in and was victimized by the use of
thought reform on RPF as a means to impose the "Fair Game" law on
dissident Scientologists. Despite claims to the contrary Fair Game has
never been, and will never be, cancelled. The words Fair Game used in
any issue is cancelled. However, the actions of handling suppressives
with trickery, lies, deceit and even destruction have not been cancelled
and are still being used today.

INSTRUCTIONS TO CAUSE SUICIDE

45. I received instructions directly from Ray Mithoff to use the
Hubbard Tech of thought reform to drive Tom Ashworth to a psychotic
break. The express object of the exercise was to drive Tom crazy and to
commit suicide. Tom went PTS Type III and attempted suicide. Later,
Tom escaped from RPF and was caught, brought back against his will,
isolated with 2 guards and more thought processes were used on him to
calm him down rather than have him kill himself.

46. I also saw and heard the Hubbard Tech of thought reform used
to drive Gary Epstein to a PTS Type III psychotic break as punishment
for his refusal to comply with orders he received from the Wayne Marple
mission.

47. I saw these same techniques used on persons who had not
violated any Scientology laws or requirements. The techniques were used
to compel persons to go up the Scientology Bridge to total freedom.
Advancing up the Bridge requires attending courses and auditing or
processing. Both the courses and auditing becomes more expensive the
further up the Bridge a Scientologist goes. So, these thought reform
techniques are callously employed to generate ever increasing sums of
income for Scientology.

USE OF ARMED GUARDS TO KEEP SCIENTOLOGISTS FROM LEAVING HEMET BASE.

48. At various times while I was stationed at the Gold base near
Hemet, I was assigned to different security functions. Persons assigned
to the security details were in constant radio contact with other
security personnel. We watched persons who were suspected of being
disaffected with Scientology and Miscavige closely (i.e. Vaughn Young
and Terry Gamboa). We were required to confirm that the suspects were
under surveillance to our seniors regularly. We also had an armed look-
out, code-named "Eagle," who was located so that he could watch over the
entire Hemet base and keep the occupants under surveillance with a
powerful telescope. When Miscavige wanted to give the persons working
at Hemet the impression that they were not being watched and to test out
his theories as to who was likely to blow their post, we would be
withdrawn from view and our surveillance responsibilities turned over to
"Eagle."

49. We also had well established and intensively drilled
procedures to follow if anyone appeared inclined to take unauthorized
leave from the Gold base. If disaffected members tried to leave in a
vehicle, it was security's job to get into the vehicle with the subject.
If they tried to leave on foot, we were trained to follow them while
remaining in radio contact with Gold base near Hemet.

50. If it was determined that a disaffected member was trying to
leave, we were instructed to call in private investigators who had been
retained by Scientology lawyers to deal with these problems. Once the
private investigators were briefed, they took command of the situation.
The private investigators would give us instructions. Once the private
investigators were involved, our role was limited to acting as the
private investigators' eyes and ears. We would be sent to places where
the disaffected members were likely to go. We would alert the private
investigators if we located the disaffected members. Once we located
the disaffected members, the private investigators took care of the
rest.

51. I was personally involved in efforts to retrieve Sinar Parman,
Jeff Walker and Julie Fisher. The efforts to retrieve Sinar Parman and
Julie Fisher were successful. We were unsuccessful in our efforts to
return Jeff Walker to the Gold base. As soon as he was off the base he
contacted the California Highway Patrol. He informed the Highway Patrol
that he did not want to return to Hemet base. To get this point across
to the Scientologists at Hemet base, Jeff returned to the Hemet base
with a Highway Patrol escort he picked up his belongings and announced
unequivocally that he wanted to leave and that he would take all
appropriate action to preserve his freedom. He left the Hemet base
under escort from the Highway Patrol.

52. Over the years I was at Gold base, a significant number of
people at the base announced, or by their conduct indicated, to me that
they wanted to leave. Julie Fisher stated repeatedly that she wanted to
leave. She said that she did not want to remain at Gold base. My
instructions were to keep her on the base. Mark Fisher, who was
severely beaten by Miscavige, repeatedly told Miscavige and others that
he did not want to be at the Hemet base. As Miscavige and others beat
Mark in my presence, Mark kept saying that his attackers could beat him
all they wanted but he still wanted to leave. Finally, Miscavige
expressed his contempt and disgust at Mark and left the guard house
where Mark was being held.

53. I also saw armed guards at the "berthing" (staff) quarters at
Gilman Hot Springs. The armed guards were stationed to prevent staffers
from leaving or "blowing" their posts during the night.

54. The function of the guards is not only to keep Scientologists
in but to keep "wogs" out. Wogs are non-Scientologists. In 1991 a
process server tried to get onto the base. He was beaten up and
arrested by security guards who put him in handcuffs. The Police
arrived and took the handcuffs off him saying "you guys can't do this,
Man, you guys are getting carried away. The process server later sued
and the case was settled. The security guard, Danny Dunnigan, was so
confused about what his senior told him to testify to that he perjured
himself about four times in the Courtroom.

55. I also have personal knowledge about the guarding of other
people being involuntarily detained by Gold Security, a division of CSI,
at the heavily fortified and armed Gilman Hot Springs base (Gold) and at
Happy Valley which is another Scientology base 11 miles away.

THE INTERSTATE KIDNAPPING, IMPRISONMENT AND SECURITY CHECKING OF
ANNIE BROEKER

56. In addition, I have personal knowledge in connection with the
retrieval and return of persons who have tried to flee and leave the
Scientology organization. This includes the involuntary detention of
Annie Broeker. I learned that Annie blew her post when Gold Security
approached me to ask if I had seen her. The security personnel asked me
if I had seen Annie. They informed me that she was not at her work
assignment and not at her berthing. Several days later, I asked what
had happened with Annie. Russ Andress told me not to ask about Annie.
Later, I saw Annie at Happy Valley. Persons who are believed to present
an embarrassment to Scientology are detained at Happy Valley. The
inference that Annie was being detained was underscored by the fact that
she was not on post and was not wearing her uniform. Furthermore, when
I saw here she was accompanied by the Director of Inspection and Reports
and the Master at Arms, who, at that time, was my son, Casavius
Tabayoyon. From my personal experience, persons being kept under
circumstances similar to those described above are being watched and
will be detained, if they try to leave. At a briefing, Miscavige said
that Marty Rathbun and another person from his staff had to hire a plane
to retrieve a staff member who had fled (Annie Broeker). This briefing
was in relation to how bad we (Golden Era Crew) were doing our jobs. It
is significant, in my opinion that the recently filed declaration of
Marty Rathbun indicated that he has been out of the U.S. jurisdiction
since late last year.

SCIENTOLOGY SECURITY GUARDS ACT LIKE THE MILITARY POLICE

57. As added measure to the situation of the crew being in Doubt,
a security watch system was ordered into existence at the berthing
locations of the Hemet base. When the crew were about to go home at
night, the guards were to be at their positions at the berthing areas.
Berthing is where the staff or crew sleep at Hemet and other Scientology
premises. Berthing is similar to bunking on a ship. I was put in
charge of six of the security guards. The shore story was that these
guards were a neighborhood watch to protect the staff when they went
home, but in fact the guards were there to prevent staff members from
going to Vons or a late-night restaurant. They were to insure that
staff members got off the bus and went directly to their berthing and.
went to bed. Shore stories were also introduced on the Apollo. A shore
story was a false story told to local port authorities so they would not
discover that we were Scientologists and order us to leave the port.

58. Another duty of the "berthing" guards was to prevent staff
from "blowing", which is the Scientology term for someone who leaves
Scientology to become a member of the real world again. If staff
members did blow, we were to get in the vehicle with them and detain
them, and if we were stopped by the police, the "shore story" was to be
that the person was having mental difficulties and we were going to
assist them to get back home. We were to make it look like we were
trying to help them, not hinder them. Another duty was to call the base
when everyone was secured and a full head count was done. As a watch
in-charge of the night berthing watch security guards, I was responsible
for roving the town of Hemet to look for staff who were not in their
berthing rooms when they were supposed to be. The berthing guards are
CSI employees. Miscavige personally issued the berthing guard orders.

MISCAVIGE IS THE MANAGING AGENT OF CSI: INDEED HE IS A MANAGING
AGENT OF ALL SCIENTOLOGY ORGANIZATIONS.

59. I have personal knowledge that Miscavige issues oral and
written orders and instructions to Scientologists irrespective of either
ecclesiastical lines of authority or corporate lines of is authority or
demarcation. Miscavige uses this omnipotent authority to exercise
personal control over any and all Scientology organizations whenever he
elects to do so. I observed that in running the various Scientology
organizations, Miscavige constantly crosses all corporate and
ecclesiastical command lines without regard to the fact that there are
numerous Scientology related corporations of which he is neither an
employee, officer nor director. He does not have to be to control any
Scientology organization. He is above all Scientology organizations as
the ecclesiastical head of Scientology, COB RTC and Commander of the Sea
Org. In this capacity, Miscavige acts as the managing agent of each
Scientology organization.

60. During my tenure at the Hemet base, Miscavige was always the
senior officer - over all Scientology organizations having business at
the base. While Hubbard was alive, Miscavige's orders had the same
effect as Hubbard's. Only Flag Orders issued by Hubbard could supersede
Miscavige's orders. Once Hubbard died, there was no authority senior to
Miscavige's.

61. I personally observed Miscavige take over this position of
ultimate power over all of Scientology after Hubbard died. I observed
Miscavige when he was COB RTC ordering into Golden Era Studios ("Gold")
, a CSI division, and ordering into the Commodore's Messenger
Organization International ("CMO Int"), another CSI division planetary
dissemination organization, etc. Both of these Sea Org units are
corporately part of CSI. RTC, CMO Int and Gold are all located at a
large compound outside of Hemet, California. It is called Gold. As I
learned, the Scientology corporate structure was only for the benefit of
the outside "wog" world. It didn't have any bearing on how Scientology
operated.

62. When Hubbard was alive it was common knowledge and I also
observed it personally that he was in direct control, via Miscavige and
Pat Broeker, of CM0 Int and Gold, and the rest of Scientology. After
Hubbard died Miscavige ousted Pat Broeker and Vicki Aznaran, who were
then in control of Scientology. After that, it was my experience that
Miscavige had complete control over Scientology just as Hubbard had when
he was alive. Miscavige took over Hubbard's place as managing agent of
all Scientology organizations.

63. The following are several examples of the power Miscavige has
over Scientology regardless of corporate boundaries:

(a) I was on a project in 1983-84 when Hubbard was still alive and
he was planning to move to Gold properties at Hemet, so we were
renovating Hubbard's living and working quarters at the Hemet compound
so that he could live and work there. I often spoke with Miscavige
about progress on these projects and received numerous orders on this
project directly from him. At that time Miscavige's corporate title was
Chairman of the Board of Author Services, Inc. ("COB ASI"). I was a
staff member of the Flag Operations Liaison Office Western United States
("FOLO WUS"), a division of CSI. I was ordered to the Hemet compound
by Deputy Senior Messenger Janadair Swanson, who was employed by CMO Int
to work on CMO Int's project for renovating Hubbard's house. Miscavige
ordered me to be in charge of the ceiling of the dining room in the
house. Many living and working quarters were being renovated and
Miscavige was overall in charge as Special Projects Operations ("Special
Project OPS"), which was what he was called inside Scientology
organizations. He would approve or reject the final product.

(b) Later in 1985 I undertook a project as a Golden Era Productions
employee (Golden Era is part of CSI) to construct Hubbard's studio. I
received many orders directly from Miscavige who now claims never to
have any authority with regard to CSI. One order that is clear in my
mind concerns the main shell of the music studio. We had just completed
the main shell, but when Miscavige inspected it he decided it would be
too small. He ordered that it be re-engineered so it would be bigger.
This order was given to me verbally and in writing from Miscavige via
the Deputy Senior Messenger of the Household Unit. This re-engineering
cost CSI an additional $449,000.00 which came from cash reserves of CSI
located in the main Los Angeles branch of the Sumitomo Bank.

(c) When a Portland, Oregon, jury awarded Julie Christofferson $39
million in damages against the Church of Scientology of California,
Miscavige ordered that every available Scientologist be sent to Portland
to protest the Court's decision outside the courthouse. This became
known as the Portland Crusade for Religious Freedom and and it involved
tens of thousands of Scientologists. On one day I counted 12,000
people. On another day there were 11,000 people outside the courthouse.
I was the Executive Director of the Portland Crusade. I received direct
orders from Miscavige on what actions to take for the Crusade even
though I was employed by CSI, a non-profit corporation, and he was COB
ASI, a for-profit corporation. Miscavige was personally involved with
the finances for the crusade submissions to Miscavige were known as
"writing it up to Department 21". There were many other people who also
received direct orders from Miscavige, completely regardless of to what
Church of Scientology corporation they belonged. This was battle. This
was war. Eventually the desired effect was achieved. Christofferson
was bought off and gagged and the documents sealed.

(d) Later, the judge declared a mistrial in the Christofferson
case. The Portland Crusade was over. Then I discovered that the
crusade had accumulated over $500,000 of debt. Miscavige ordered a full
inspection of the financial records. Once he had confirmed that the
records were in order, he ordered the $500,000.00 debt paid off out of
various Scientology organization accounts.

(e) Once the Portland Crusade was over, I went back to building
Hubbard's studio. We completed the studio. At a special ceremony, we
received acceptance of our work by Miscavige and Hubbard. This
established that the project was completed.

(f) During the time of the construction of the Golden Era studio, I
read several written orders from Hubbard about the ongoing renovations
of his home and studio, as well as other aspects of the daily operations
of Gold, CMO Int and RTC. Miscavige was directly responsible for the
implementation of these orders.

(g) Miscavige also crosses corporate lines to berate and scream
intimidating obscenities and profanities at persons not of RTC. Once I
did not achieve my target and Miscavige came at me, stood twelve inches
from my face, and called me a "mother fucker" and a "son of a bitch" for
about 10 minutes. I've also been at Sea Org musters where Wendell
Reynolds shouted "You're all a bunch of treasonous sons of bitches!"

64. I did many construction projects at the Hemet (Gilman Hot
Springs or Gold) compound for Gold, CMO Int and RTC, and in every one of
these projects, I received at least one order directly from Miscavige on
each particular project. On some projects, I received daily visits from
Miscavige. During each visit, he issued several orders.

STEVEN FISHMAN

65. I recall meeting Steven Fishman during the L.A. Crusade in
19-. Miscavige also ordered this operation. The LA Crusade was also
known as the Battle of L.A. The purpose was to assemble so many may
Scientologists outside the LA Superior Court during the Wollersheim
trial that the judge and jury would be intimidated. There were also
operations carried out to try and intimidate Judge Swearinger an