Title: Declaration of Charlotte L. Kates submitted in the appeal of RTC v. Henson
Author: clkates@aol.com (CLKates)
Date: 22 Oct 1998 19:35:55 GMT

I made the following Declaration in support of Keith Henson's appeal of RTC v.
Henson, discussing the practice of medicine in Scientology. Keith's posting of
NOTS 34 fell, in my estimation, decidedly within the bounds of "fair use"--for
public comment and warning. Scientology's practice of medicine is widespread
and fraudulent, and it seeks to hide behind "secret" documents such as NOTS 34.
This Declaration describes my experience with fraudulent medical claims in
Scientology, and helps to illustrate why it is so necessary that people like
Keith inform and warn the public about the dangers of such practices. By
exposing NOTS 34, Keith Henson was saving lives; that is public warning, and
that is fair use. 

A webbed, signed copy of this Declaration can be found at
http://members.aol.com/clkates/affidavit.html

DECLARATION OF CHARLOTTE L. KATES

I, Charlotte L. Kates, do declare as follows:

1. I am over the age of 18 years. 

2.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. I was a member of the Church of Scientology in Philadelphia, PA, from
January through May, 1998. During that time, I was at the Org nearly daily,
taking Scientology courses, and volunteering at the Org as a receptionist. 

4. During that short time in Scientology, I witnessed several occasions in
which CoS staff members, medically untrained, with no qualifications,
recommended people cease medications, not seek out traditional medical
treatment, and use CoS services as a cure for their illnesses. 

5. To protect CoS from lawsuits, before taking Scientology services,
Scientologists are required to sign a disclaimer form which officially
disclaims CoS of any responsibility for the promises of its representatives and
staff members. However, these promises and sales pitches are delivered in a
uniquely high-pressure environment, using tactics pioneered and detailed by
Scientology's founder L. Ron Hubbard in such works as the "Hard Sell Course
Pack" in order to raise income. I believe the disclaimer forms are required
specifically because CoS fully supports and intends staff members to make
medical claims and promises of medical cures for CoS services in the fraudulent
pursuit of hundreds of thousands--perhaps millions of dollars.

6. CoS literature is studded with testimonials to the medical benefits of CoS
auditing services, as are many of L. Ron Hubbard's writings. It is my
experience that it is a common belief of CoS members and staffers that
traditional medicine is ineffective, and that CoS treatment is an effective
medical substitute, and that this belief is officially supported by CoS. It is
further my experience that CoS services are not perceived as "faith healing"
miracles, but as effective, "scientific" substitutes for traditional medicine,
as specific processes which always bring about certain results, including
medical cures. 

7. I witnessed several occasions of CoS services being prescribed for medical
problems, and the use of traditional medicine distinctly discouraged and
frowned upon. I was personally ordered by Tiffany Woods, the Senior HAS
(Hubbard Communications Office Area Secretary) EUS (Eastern United States) and
Jenny Porta, the LRH Communicator EUS, to stop taking medication that had been
prescribed for me by a doctor to alleviate my thyroid condition--Grave's
disease--upon my signing of a Sea Organization contract. Ms. Woods and Ms.
Porta told me that I would otherwise be ineligible for Scientology services,
and told me that my medical condition could be cured with PTS (Potential
Trouble Source) handlings and Scientology auditing. I was informed that the
cause of all illness is "PTSness", and showed a reference from L. Ron Hubbard
indicating that the root of all illness and/or injury is a PTS condition.
Scientology believes it can handle and cure any and all such "PTS conditions".
I was told therefore, I did not need the medicines prescribed to me by my
physician, and that Scientology auditing would cure my illness. It was not
promoted as "faith healing" or "miraculous." Scientology procedures were
instead described to me as an effective substitute for traditional medicine.
Scientology procedures were specifically not designed to complement traditional
medicine; in fact, I was told that if I continued to take my prescribed medical
drugs, I would be ineligible for this Scientology cure. I was not told to visit
or ask a doctor's advice. I was ordered to cease medication on the advice of
two medically untrained Scientology staff members.

8. In the official Dianetics and Scientology Technical Dictionary, copyrighted
1975 by L. Ron Hubbard, "PTS" is defined as follows: "1. means potential
trouble source which itself means a person connected to a suppressive person.
All sick persons are PTS. All PCs who roller-coaster (regularly lose gains) are
PTS. Suppressive persons are themselves PTS to themselves. (HCOB 5 Dec 68) "
Emphasis added. Scientology purports to have the only technology proven to
always handle such "PTSness".  

9. I witnessed several other cases of Scientology being promoted as a medical
cure, including the case of one public Scientologist active at the Philadelphia
Organization. She became involved with Scientology in mid- 1997. Years before,
she had suffered from Lyme disease, which had been treated by a medical doctor.
Not long after her initial involvement with Scientology, she suffered a
recurrence of the illness, which became apparent to her as she began to suffer
from memory loss, periods of blacking out, severe headaches and similar
effects. A medical doctor did confirm her symptoms as being a recurrence of
Lyme disease; however, before beginning medical treatment, she sought the
advice of Scientologist chiropractors, nutritionists and other alternative
medical practitioners. Scientologists deeply distrust traditional medicine, a
viewpoint promoted by Scientology founder  L. Ron Hubbard since the time of
Dianetics, and commonly refrain from medical treatment at all costs.

10. It was recommended to her that she cease medical treatment for Lyme
disease; she was informed, as was I, that the cause of all illness was
"PTSness." She received many PTS handlings, at the cost of thousands of 
dollars in auditing fees. However, as she was still ill, she was now sold NED
(New Era Dianetics) Assists (Scientology processes used to "handle" illness or
injury) as a cure for illness. NED Assists are commonly sold to ill
Scientologists as cures for illness, and as replacements for medical care. 

11. In the official Dianetics and Scientology Technical Dictionary, "New Era
Dianetics" is defined as follows: "a refinement of all previous Dianetics
techniques from 1950 up to present time as well as the development of new
technique giving much faster results and far higher gain per hour of auditing
and speedy resolution of Dianetics cases...(LRH ED 301 INT)" The term
"Dianetics" is defined in the Technical Dictionary as well. Relevant is
Definition 3:"Dianetics addresses the body. Thus Dianetics is used to knock out
and erase illnesses, unwanted sensations, misemotion, somatics, pain, etc.
Dianetics came before Scientology. It disposed of body illnesses and the
difficulties a thetan was having with its body. (HCOB 22 Apr 69)".  Emphasis
added. Thus, the "auditing" she was sold, New Era Dianetics Assists, are
specifically defined as cures and and "handling" for, in fact "erasing" of,
illness. Similarly, New Era Dianetics for OTs (NOTs), are also promised cures
and handlings for illness as are all forms of "Dianetics" used in Scientology.

12. After thousands of dollars and many months spent for a cure at Philadelphia
Organization, which never did materialize, she was "regged" (subjected to a
uniquely high-pressure hard-sell sales session) to go to the Flag Land Base in
Clearwater Florida for additional handlings and NED assists. She was, once
again, not referred to a physician by anyone at the Philadelphia Organization
or at the Flag Land Base; the Case Supervisors who reviewed her PC (preclear)
folders knew she was being treated for illness, and knew she was not receiving
medical treatment, as did her auditors, in addition to the Registrars who sold
her these cures at an eventual cost of tens of thousands of dollars. 

13. She was sold several intensives (12 1/2 hour blocks of time) of Scientology
auditing at the Flag Land Base on the premise that there, at "the mecca of
technical perfection," her Lyme disease would be finally "handled," and that,
therefore, the auditing was worth the exorbitant prices. She took out a second
mortgage loan on her house to pay for these intensives of auditing. When these
did not "handle" her Lyme disease, she was told she had not purchased enough
auditing. In a very intense registration session, she nearly maxed out her
credit cards to purchase further intensives of Flag auditing, and was further
promised a cure for her Lyme disease. Once again, she was not recommended to
see a doctor, and was, in fact, discouraged from doing so. 

14. She returned to Flag for further "handling" for her Lyme disease, which was
continually worsening as she put off medical treatment on the advice of CoS
representatives. Once again, after receiving numerous "intensives" Flag
auditing, she was still afflicted with Lyme disease. Nevertheless, Scientology
continued to exploit the situation for money, involving her again in an intense
registration session.  She was told that she would need $8000 worth of
additional auditing.  She explained repeatedly to the registrar that she had
nothing,  that she had spent her last $2000 for her 4-year-old daughter's
International Association of Scientologists Lifetime Membership, that she could
simply not afford another intensive.  As mandated in Scientology policy, the
reg continued the hard sell until she felt that she honestly would not get out
of that cycle if she did not agree to buy the intensive. She was given a list
of the names and telephone numbers of wealthy Clearwater Scientologists, and
told to call them until one of them agreed to let her put her intensive on his
credit card. She resisted the idea, and once again, felt forced to back down.
Calling down the list, asking people she did not know for a credit card number
for an $8000 intensive, she hated the idea
but her resistance had been broken down. Eventually, one agreed. 

15. She received the intensive. After spending approximately one hundred
thousand dollars on Scientology's cures, she had "learned" in her auditing
sessions that billions of years ago, in a past life, she had been forced to
"zap" her mother with a ray gun by an evil space government, yet she was still
afflicted with Lyme disease.  She had maxed out all of her credit cards, taken
out loans, and otherwise expended all of her resources--and given all of her
money to Scientology in return for a much-promised, never-materialized cure for
her Lyme disease. She was repeatedly discouraged from visiting a doctor, and
sent back again and again, to Flag, for more NED Assists, more auditing, one
more intensive, one more process, eventually leaving one Scientologist with
untreated Lyme disease, and the CoS thousands of dollars richer.  She still
owes one Scientologist in Clearwater $8000. Scientology still promises her a
cure, still attempts to lead her on the medical runaround.

16. Scientology practices medicine. Scientology auditing is sold as a
collection of proven processes.  I know from her story, and I know from my own.
Scientology still lies about it publicly, and internally, defrauds
Scientologists of thousands--perhaps millions--of dollars yearly for false
medical claims. Scientologists believe that Scientology has a cure for physical
illness; such promises of cures are used as the "hook" to recruit people, and
to register people for various services. 

17. Such unlicensed practice of medicine in Scientology is deeply dangerous. My
medical situation was greatly worsened; in the case I mention above, she
manifested more and more symptoms of late-stage disease the further CoS'
"handling" progressed. It is my belief, based on personal knowledge, that
thousands of people, in various ways, and to greater and lesser extent, have
been deleteriously affected by Scientology's unlicensed practice of medicine. 


I declare under penalty of perjury under the laws of the United States of
America and of the State of New Jersey that the foregoing is true and correct. 
Executed in Collingswood, New Jersey this 11th day of October, 1998. 

CHARLOTTE L. KATES