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

Attorneys for Defendant


Date: APRIL 4, 1994
Courtroom: 7
[Filed and served
concurrently with Dr.
Geertz's Bill of Costs.]



I, Scott Mayer, declare as follows:

1. I am a resident of the County of Los Angeles,
California. I have personal knowledge of the facts stated herein,
unless stated upon information and belief, and as to those
statements which are based on information and belief, I believe
them to be true. If called upon to testify as to these facts, I
could and would competently do so.

2. I am a designated expert witness in the case of Church
of Scientoloqy International v. Steven Fishman and Uwe Geertz,
U.S.D.C.C.D. CA Case No. CV 91-6426 HLH (Tx). The purpose of
this declaration is to rebut portions of the recent declarations
of Senior Scientology Officials that the Church of Scientology has
not instructed people to commit murder or engage in financial
fraud. 3. I have been previously designated and testified as
an expert in Scientology related litigation. After I left the
Church of Scientology, I became a personal assistant to Martin
Cohn, who in 1980 was senior counsel for the special cases
division in the Internal Revenue Service (IRS). I became his
assistant when the IRS went to trial against the Church of
Scientology in what has become known as the Tax Court case. I sat
in the courtroom with him and whenever a Church of Scientology
witness would reference a policy that justified what they were
doing or showed how goodthey were, I would write a note giving
him a policy reference that allowed the Scientologist to bypass
that policy. In addition, I was designated and testified as an
expert in Scientology administration and operations including Sea

-- 2-


Organization ("S.O") operations. In addition, I testified against
Scientology at the 1981 Clearwater hearings in Clearwater,
Florida. I had been all over the world for Scientology. I had
been on perhaps 20 different S.O. missions for L. Ron Hubbard
("Hubbard"). I had operated directly under Hubbard's authority.

I ran his ships, trained his missionaires, and trained Sea
Organization ("Sea Org") members. In addition, I testified
against Scientology at the 1981 Clearwater hearings in Clearwater,
Florida. Attached hereto as Exhibit A is a photocopy of an
excerpt of pages 273 to 283 of the Book "A Piece of Blue Sky --
Scientology and L. Ron Hubbard Exposed" by John Atack. As the
Exhibit passage states, after I left Scientology in 1976, I went
into hiding at Laguna Beach. In approx. 1978, I was the engineer
at one of the Laguna Beach hotels. I ran into Scientology
executives (David and Sue Anderson) in the street. Sue Anderson
who was Hubbard personal PRO at the time and her husband David I
believe was the Flag Ethics officer. Shortly after that, my car
mysteriously caught on fire in front of a friend's house when I
was visiting one night a~d many of my Scientology papers in the
trunk burned. On another occasion, the remaining Scientology
papers I had disappeared from a storage site in the garage from an
apartment I had in Ladera Heights, California.

-- 3--

4. Prior to joining Scientology, I had been in service in
the United States Navy in Vietnam where I developed electronic
warfare talents, other electronic talents, navigational talents
and learned docking an aircraft carrier electronically in totally
inclement weather. I was also experienced with self-defense
weapons and martial arts. Even when I was in the United States
Navy, I had always wanted to captain a ship. In the late 1960s, I
was living in Corona del Mar, California and working as a
stationary corporation field representative. I was bored and had
just broken up with my wife. I still had my dreams of skippering
a ship and had no ties to any place or any person. I was
approached by a representative of the Scientology Sea Org go into
a ship training program as a ship's master. Scientology needed
people to run Hubbard's ships because he wanted to expand the
fleet. When I was a Scientology fleet captain in 1973 and 1974,
we had only two ships and another small boat in the U.S. Pacific
Flotilla, but we were getting ready to have additional ships in
Mexico and San Francisco and part of my assignment was to put a
fleet together and to coordinate activities in training programs,
staff analysis and establishment of the flotilla.
5. In the course of being part of Scientology's ship
master's program, I learned that the ships always had fraudulent
licenses and papers. Such phony papers included radio licenses,
ship's papers, records, crew certifications, seaman's certificates
and other such matters. For this purpose, Scientology used Pat

Hunter, a woman who lived in South America. She had an excellent


command of the Spanish language and customs and would go to the
Panamanian authorities and act as the intermediary between
Operation Transport Corporation (Hubbard's personal holding
company) and the Panamanian consulate. Her name was Pat Hunter.
As a result of various subterfuges, we did not even have to
provide proof that people had successfully completed various
training programs to get certificates. Pat would just go to the
consulate, give them some money, get the books made up and have
them officially stamped. When a new crew member was posted to a
ship, Pat would take the papers down to the consulate and have
them authorized: ship's papers, seaman's papers, etc. When
courses were established, certificates from basic seaman up
through captains, deputy captains, first mates and others were
awarded by course supervisors of Hubbard's courses and then
processed through the consulate as described above.

6. I came to develop an understanding and belief that all
of these illegal things were done on the basis that WOGS (non-
Scientologists) were fouling up the planet and were basically
criminals who were running an insane world. Scientology professed
to be trying to straighten out the planet, trying to get rid of
the insanity and make things right again. So, my understanding
and belief was that this illegality was acceptable as part of a
Jihad or holy war. We were doing things to keep Scientology
working and the things that we were doing were just fine because
Scientology convinced us it was trying to make a better world. It
was similar to rioting for peace. You know it really doesn't work
but it is a way of getting mass agreement of Scientology's
movement towards Hubbard's goals for a clear planet.

-- 5--

7. The illegal conduct involved in Hubbard's ships included
receiving a percentage of money from all of the S.O. organizations
in Los Angeles and elsewhere in the world.~ In exchange for this
money, people would come on board the ship from all over the world
and be trained on various basic Sea Org procedures, basic staff
hatting procedures and then be sent back to their home
organizations to assume Scientology posts. At this time, I
floated back and forth between the ships in various executive
positions and other posts concerning the Los Angeles Flag
Operations Liaison office activities. At various times I was
responsible for preparing mission orders and briefing couriers
that would smuggle money out of the United States. I was also
responsible for sending various other missionaires to various
parts of the country to go into Scientology organizations and
force them to make more and more money. This was basically a form
of "Regging."

8. The purpose of the registrar is to make more money all
the time for Scientology. At the time, Scientology had various
sales courses that taught registrars to strip resistance from
people they were 'regging.' Registrars were taught how to push
various buttons with regard to their mortality and their
spirituality and their ability to be at peace as a being. Every
button that could possibly pushed was pushed in order to get a
person to make large advance payments. We got so good at it that
we were sending $250,000 to $500,000 a week out of the Los Angeles
area alone. The money would be sent out of the country to various

1 Wherein the S.O. billed for services provided to
Scientology organizations.

-- 6-

places in the world including accounts in St. Hill, England.

Five, six and seven couriers a week would go out from Los Angeles
with their little bundles of documents and their bundles of money
hooked into it. We had a communication center that we delivered
the missionaire to. The missionaires were fully briefed on how to
get through customs and we would take them to the airport and send
them where they were supposed to go which we learned from the
Director of Communications. I was told by the Director, Bill
Price, that there were five phony Scientology companies that
existed at that time and were recognized by customs. As far as
customs was concerned, these companies regularly sent businessmen
all around the world. Internal operations were never allowed to
know what was being sent to where. The only communications were
from the Flag communicator, through coded telexes, saying exactly
where anything was to go to Bill Price at any given time and how
it was to go. We had the money couriers so well briefed as how to
get through customs that they would not be sweating and would be
totally calm and cool. They would overwhelm customs with pieces
of paper if customs wanted to see them.



9. I understand and believe that sometime in 1973 and 1974,
Hubbard's wife, Mary Sue Hubbard, had had enough of being
constantly out at sea. She embarked on a campaign to convince
Hubbard that the Sea Org ships were just a white elephant and that
Scientology was paying too much money for what it got back and
that the fleet should be disbanded and Hubbard's operation brought
on shore.

10. Subsequently, it was decided to establish the Flag Land
base at Clearwater in Florida.

11. Prior to the establishment of the Flag Land base in
Clearwater, I actually saw the area on the Apollo where the
Guardian's office financial people were engaged in a massive
invoice altering project.2 My belief and understanding of the
reason for the project was that discrepancies that could have been
discovered between money `regged' or obtained from Scientology
organizations in the United States and when it arrived on the
Apollo, having previously been diverted in part to various
accounts in Luxembourg,,Switzerland or other countries. When my
wife and I came back from a Scientology mission to South Africa,
we brought back $5,000 each (Rand). Although that was not a lot
of money, it was money that was not supposed to go out of South
Africa into the United States.

2 Wendall Reynolds, the Guardian's Office Flag Banking
Office, took quite a deal of pride in showing me the project.




12. With regard to other scams, my understanding and belief
is that U.S. registrars were taking in checks in the various
Scientology organizations for huge amounts of money. The people
who gave the checks could not possibly have covered those checks
and yet the registrars were holding those checks and reporting
them as gross income. This would increase the weekly statistics
as Scientology requires. Later the registrars would try and
coerce the parishioners into making good on the check. The
registrars were not interested in whether the bank could cover the
check or not. Here was a person who had knowingly written
Scientology a bad check in the sum of $35,000-$40,000 and the
registrars were now going back and convincing them to pay.
Indeed, I personally pressured people to take out mortgages on
their homes in order to pay for Scientology services. Moreover,
at one point I put together a group of 8 or l0 registrars on the
Excalibur, trained them up under Jim Douglas and forced collection
of back monies from people who owed the Sea Org or Scientology
money. In essence, I just put together a credit collection team
and then started hitting the movie studios and others connected
with the record companies to rent out use of the U.S. ships. At
this time I was captain of the Excalibur which was an old navy
ship. I had it rented out to a few movie studios and had money
coming in. Indeed, we were making so much money that Scientology
could not prove the ship was not financially viable because we
were getting all this collection money. It was sometime after
that Mary Sue Hubbard caused me to be subsequently transferred to
the Apollo.

DATA~: 839~l-9-




Scientology regardless of corporate "structure" Hubbard had a

himself and the Sea Org (Flag). He would dream up a new course,
initially taught only on Flag, such as the "Flag Executive

Briefing Course" "Establishment Officers Course," "Ethics Officer

Courts", etc. Flag would put together a course book and check

sheet, Hubbard would write a few new policies and alreadyexisting
course." PR's dissemination would put together the "Ron's New

" "promotion. It would be issued as a Broad Public Issue

and then Flag would "order" all Scientology units to send people
to Flag to be trained. There was no choice about it. Orgs and/or
missions had to comply. They were, of course, billed heavily by
Flag. Eventually Ron would release the courses to S.O. Orgs to
teach locally, but there again, Flag billed heavily for providing
the course, course supervisor and materials. In most cases there
was very little new material, mostly re-packaged already issued

Where certain Class IV orgs or missions (Franchises)
protected S.O. missions were sent in to remove the Executive
Director and send them to Flag for Ethics Handling and
rehabilitation. I was part of a mission to Austin, Texas Org to
carry out that activity.

14. It was after I physically saw the Flagship's project of
altering invoices that I decided to leave the ship. I was newly
married and something told me that if I was on the ship with my

--1 h--

wife and the IRS made a raid and discovered that these invoices
were changed I may be in deep trouble myself. Accordingly, I went
to Kerry Gleason who was in charge of Operations for Flag at the
time and requested that he send me and my wife off on what turned
out to be a 14-18 month mission around the world to help make
money for Hubbard and his various organizations.


15. The Sea Organization was/is the most elite organization
in Scientology. Sea Organization members owed their loyalty
directly to Hubbard. I became a Sea Org member and signed the
standard billion year contract. If Hubbard sent a Sea Org member
on a mission to any Scientology organization, that Sea Org member
had complete power. Indeed, that Sea Organization member could
walk into any Scientology organization, remove the head of that
organization and send him back to Flag or to the Rehabilitation
Project Force ("RFP"). I personally observed the RPF when I was
captain of the Excalibur. At times, I would have "up to" 34
RPF'ers on board. From time to time 'Flag' would send missions
into various Scientology organizations in the Los Angeles area and
then call me up and ask if I could use various gangs of RPF'ers to
do certain projects. In fact, they used my RPF to move into the
Chateau Elyses on Franklin Avenue. Moreover, when other
organizations had too many RPF members they would just send the
extras down to the ship. There, we could use them for painting,
clearing the bilges and scrapping rust, etc. I never did any
"over boarding", but I heard about the practice when I first came
to the Sea Org.

16. AlthoughthereweremanydifferentScientology

-- 1 1--

corporations, they were really just shams. Scientology was a
hierarchial ecclesiastical organization run from top to bottom by
its ecclesiastical head, Hubbard. He maintained control through
the Sea Org which permeated all corporations.

17. When I was on the Apollo, I witnessed them making a new
Board of Directors for Operation Transport Corporation out of a
couple of galley hands and some musicians. Mary Sue Hubbard
picked them out and they signed the corporate papers where and
when she told them.

18. The organization board (Org Board) is one way Hubbard
maintained unity of control. Every Scientology corporation had
the same Org Board and so duties were assigned in such a way that
they were mirrored in every single Scientology or Dianetic Center
in the world. Accordingly, there wasn't one post in `lag' that
did not have somebody in each and every Scientology organization
around the world as an opposite number. So orders were passed
down into different people irrespective of whether they were in
different corporations. Every corporation had a Hubbard
Communications Office (HCO") ethics officer. They all had a
publications officers, dissemination officers, treasure/finance
personnel, etc. So orders were passed down into different people
irrespective of whether they were in different corporations. For
example, when I was running operations in Los Angeles, Flag would
send me a set of mission orders. I would be instructed to put
together a mission to do this or that. Then I would have to find
a couple of people that were capable of doing it. Then I would
write the mission orders for them to do it step by step, telling
them exactly what they had to do. Then I would bring them in and

-- 12 -

brief them. I would get them to the point where I felt they were
ready to go and do the mission. Then I would deliver the
missionaires to the Communications Department which would get them
onto a flight for wherever they were supposed to go and then get
them back. The mission orders would also include getting the
monies from the org to bring back with them. I would put in a
request for monies for the missionaires, basically a budget
estimate, what they would be spending and why, and that had to be
accounted for when they came back. If the mission was successful
or even unsuccessful, they would go into a briefing room and I
would debrief them on every point in their mission orders. Any
monies returned from the mission or the Org would go into the
treasury division. From there an ACl or AC2 form would be
completed by the Director of Income or the Treasury Director and
funds could then be allocated to various activities set forth
within that form and then sent to the Guardian's office for
approval. It was really one big financial operation and Corporate
Form had nothing to do with approved allocations.

-- 1 3 --


19. The reason Hubbard had S.O. operating thetans (OTs)
circulating was to create a state of awe. To give an example,
when I went to Austin, Texas on a mission I had a tape recorder.
For three days I was doing an analysis of the organization. I was
running around, looking into and asking questions about
everything. While I was making my rounds, I would be rewinding
the tape recorder to listen to what I had said. I did not find
out until four or five days later that these kids thought I was
messing with the tape recorder. They thought I was an OT so
essentially I could listen to the tape recorder at high speed.
They expected I could do anything. They thought I could go out of
my body (exteriorize) and they thought I could read their minds
and in some ways I could, because after you have gone through the
Scientology organization rigmarole, you learn how people make
mistakes. You learn they are making them and how they are being
reasonable and one of the sayings we used to use was a really
intimidating statement: "Get back in valence." Valence is a term
of differing characteristics of something from chemistry. The

characteristics of a series of molecules, but Hubbard used it as a

term for multiple personalities. According to Hubbard, your
engrams from the past would cause multiple personalities, multiple
characteristics that weren't really you but were functioning
through you. Having someone "get back in valence" was a way of
controlling them by getting them back into the present so that you
could give them another set of directions that they would then
comply with. They would get out of their destructive behavior
pattern. Indeed, we used it all the time. If somebody was in

-- 1 4 --

fear or they were confused or something like that, we would say

"get back in valence." And they would stop it. They wouldn't

know what to do so you could then take them over. Accordingly, I

believe Scientology practices do involve a form of hypnosis. In
using the word hypnosis I am defining it as a means of altering
awareness. One of the ways that you can hypnotize people is by

all of the Scientology courses that get people into this train of

thought that Hubbard was always right and if things were going

wrong, there was something wrong with the individual in his
application of Scientology processes and that had to be corrected
by more auditing. Then someone with the Scientology authority
would come along, usually a Sea Org member, Reg, or Guardian

Office member, and all they had to do was use a couple of short
command phrases to stop a person in their tracks and get them to
feel that they were not doing what Hubbard said. We would use
phrases from the Hubbard Philadelphia Doctorate tapes or anything

that applied to the situation in order to get an altered

awareness.Accordingly,itismyopinionthatyou cannot separate
hypnosis and auditing. once you get someone to believe that there

is substance to past lives, whether or not it is true from a real
spiritual sense, mystical, meta-physical sense or whether it is
true from a DNA sense, you have got someone to believe that there
lS something that can be transferred from the past to the present.
So, when you have someone that is desperately hoping to clear up
all the bad karma from their past lives, the mind provides him or
her with all the pictures he or she needs. The end product of the
auditing session is to get the person to change his or her
perception of life controlling them, to believing that he or she

-- 15--


controls life. To get them to rewrite the script that they
believe in, then that is hypnosis as far as I am concerned. While
it works, to a degree I don't believe that it is a healthy way for
a person to approach mental health. I believe it is far better to
find out what the person doesn't understand in present time and
get them to change their concepts about whatever it is they don't
understand or whatever they are confused about on a voluntary
basis and let them re-write their own scripts.


20. I had a friend who committed suicide after becoming
involved in and leaving Scientology, and I am aware of other
Scientology connected suicides. On the basis of my experience,
education and training in Scientology, I believe there is a very
strong connection between Scientology and suicide. Until someone
has progressed through to Scientology Level OT3 (Operating Thetans
3) and has recognized the absurdity of Scientology, they retain a
strong belief that auditing works and that what is wrong with them
can be corrected through the auditing process. Moreover, the
Ethics officers try to drive it into them that unless they
confront various items and come back into the fold, that their
very soul is lost. It is little different from the "Waco-Wackos."
You have taken a person and convinced them that they must become
`clear' of all these negative influences from present and past
lives. They have spent several years going through these
different and expensive courses and have been finding their life
getting better and better and their communication skills
improving. Even their fear of just looking somebody in the eye
has been conquered through training routines such as (TRO). After

-- 16-

a few years has passed, and all of these wins have been achieved,
the hoax is ready to be sprung. They now believe that the only
thing that will set them free is to go Clear and onto OT3. By
then, their own belief systems are working in conjunction with the
way Scientology is manipulating them. Moreover, they don't even
consider Scientology to be manipulating. They just consider it
reasonable and prudent to do what Hubbard says. Follow the policy
and the Tech. At that point, if they stop auditing for whatever
reason, they have trouble with the drug-like effect of auditing
and go into a self-induced state which Hubbard used to call 'a
spin.' If the person does not have any firm grasp of their
location and universe, they are just like a melting butterball.
They are mentally 'free-wheeling.' And if they have given most of
their money already to Scientology, and are now unable to go back
on line for auditing, they go into a really deep depression. It
is almost like having an anchor dug into the bottom of the ocean,
and then, when you pull it out, the ship starts to float. What
Hubbard does is make Scientology, the policies, the courses, and
the staff such an anchor"in people's lives that if they stop being
audited they will 'free wheel' as Hubbard uses the word. Unless
they are extremely strong people, and are somehow able to piece
all these things together for themselves, they could easily go
crazy or what is known in Scientology as PTS type 3 (Potential
Trouble Source Type 3). Their depression can become so deep that
they can and do commit suicide.

21. When I was in Scientology, I heard of Susan Meister
being a supposed suicide.


-- 17-

Quenton was one of Hubbard's sons. He was a class 12 auditor
whose specialty was to cure OT3's and one of the things that the
OT3 level was supposed to handle was homosexuality. It was widely
rumored that Quinton Hubbard was homosexual. Quinton Hubbard had
completed the OT3 level and was a class 12 auditor. It was
therefore an embarrassing enigma that Quinton Hubbard had not been
cured of his homosexuality by Scientology and his homosexuality
was also an embarrassment to his father. Because of this, I would
not at all be surprised if the Guardian's Office was involved in
manufacturing his supposed suicide.


22. While I was in the Sea Org, I was instructed to kill
another human being by the Scientology organization. At the time
Scientology had an office on Beacon Avenue in Los Angeles, very
close to McArthur Park. I was called in for a briefing by Alex
Sibryski. At that time, Scientology had a ranch at Rosarito in
Mexico which was being used as a nursery, a place for overflow
kids that could not be housed in Los Angeles and a place to grow
fruits and vegetables. Mexican bandits were allegedly harassing
and hustling the ranch and stealing produce from it. Jerry
McDonald and I were asked to put together a mission to go down to
Mexico, take some infrared optics and some guns and rifles, wait
for the Mexican bandits to attack the ranch again and then take
care of them. We were told to kill them if necessary. I received
these orders from Alex Sibryski. At the time he was Commanding
Officer Flag Operations Western U.S. ("F.O.L.O.W.U.S."). This
was part of Scientology's elite Sea Organization. I was the
Operations Officer at Flags Operations Liaison Office at the time



and it was my job to write the mission orders for this thing and
get us all briefed and ready to go. We figured that if we "took
out" the bandit leaders the rest would disband. It took 24-48
hours to get this done and in the course of that time I never saw
any written dispatches on this but the mission was then canceled
by Alex Sibryski. He said that there was a governess in-charge of
the ranch and that the bandits had tried to attack her at the
place and she had shot the bandit leader with a shotgun through
the door and taken care of the problem.

23. Jerry McDonald was widely rumored to have been a former
mercenary and a paid assassin in Europe. He was known throughout
the Sea Org for taking care of difficult problems. If someone was
giving a problem in some area Jerry McDonald would just appear
there. Because of his reputation as having been an assassin, if
he came on the scene, people would fear for their lives. They
believed that he was working totally for Scientology and that he
would do anything for Hubbard. Additionally, he was also the kind
of guy who would have people over to his house every now and then
and would get out his automatic weapons, clean them and put them
together in front of people. In this way, he would let people
know that he was really conversant with his craft. He carried a 9
mm pistol on him all the time and he was always talking about arms
sales and deals that he was doing. As things turned out, he and I
were not required to carry out the instructions to kill that we
had received. However, if the orders had not been canceled I have
no doubt that he could have performed the task.


24. On the basis of my experience and knowledge of

-- 19-

Scientology, I believe it very possible that Steven Fishman was
ordered to engage in the securities class action fraud by
Scientology, and then to murder Dr. Geertz and commit suicide.

For example, Alex Sibrisky's former Deputy Commander, Bill Foster,
turned up at the Sea Org headquarters in New York and told me a
story about being involved with some other guys in break-ins of
United States government offices, and possibly one senator's
office, where they had stolen materials that had to do with
Scientology. He said that there were U.S. government agents after
him and that Scientology and the Guardian's Office had hung him
out to dry. He was going to have to take a fall. Scientology was
going to deny any connection with his activities. I knew that he
had been allegedly routed out of Scientology for some sort of bad
financing practices in Boston a few years earlier. I recalled
there were allegations of improper 'regging' (high pressure sales)
practices. I thought this was strange at the time because it was
not like the Guardian's Office to kick out real money makers.
Neither was it like Hubbard to kick out real money makers
anywhere. As a result'of this conversation, I called up the
Guardian's office, Bob Reimer in Boston and said what's the deal
on Bill. He goes ..., Bill? Bill Who? I said you know who I
mean, and I told him the name and I said what's the deal on him,
and all Bob said was that "he was expelled a couple of years ago."
I then said "that's interesting because he is sitting right next
to me here and he has just told me a story about" . . . and I

started going into it. Bob said, "Don't talk about that on the

phone." And I said, "So in other words, that does exist. That

did exist and he has worked for you for the last two years

--2 0--


undercover and nobody in Scientology knew that he was working on
Guardian Office projects." Bob hedged and hemmed and hawed. Then
I said, "Listen, I am in a position here where I have to decide
whether to take on Flag or not over this guy because he is saying
that he has been working for some Scientologist in the Guardian's
Office all this time, but as far as everybody else in Scientology
knows, this guy is persona non grata and an enemy of Scientology."
So here I am, running Folo New York with my wife and this guy is
asking me for asylum and wanting back on Scientology lines and he
says he is being put out to dry. Moreover, Bob Reimer, head of
the Guardian's Office in Boston at the time, is denying it. So I
said, Bob, you've got to tell me the truth. I'd worked with Bob
before and he knew I would know if he is lying. Basically, when
he said don't talk about it over the phone I knew that they were
afraid of somebody listening in, and so I said, did he work for
you for the past two years under cover? And he said, well, yes.

I said Okay, thank you. So I then telexed ~Flag' and told them
that Bill wanted back on (Scientology) lines and I told them that
I did not know what was ~oing on but I knew that he had been
working under cover for the Guardian's Office for two years. He
wanted his Commission back and he said he was being hung out to
dry. I said Bob Reimer told me that he had been working on lines
under cover for two years, I said I was putting Bill back to
work. Then all hell broke loose. There were talks about what he
could not do here and they wanted me to kick him out and send him
packing. To force Flag and the G.O. to confront the situation I
sent Bill on a mission to the Toronto Org and got him out of the

-2 1-



25. After leaving Scientology in 1976 I had managed to get
Bob and Loy Young out of the Media Org at Flag. Bob Young was
originally a Director of Marine Operations and Flag Operations
Liaison Office. When they got to Los Angeles, he told me that he
had a friendly contact in the Guardian's Office and was warned
that he, his wife, myself and a few other people were on a hit
list. I had no reason to doubt this information and so went into
hiding. Scientology had already asked me to kill somebody, so why
wouldn't they ask somebody else to kill me, I reasoned.
Especially since I had been around virtually every Scientology
organization in the world, had been in the books of almost every
organization and knew all about the money being filtered from one
place to another, knew about it, how they did it, the people who
were responsible for it, etc. I knew about all the missionaires
doing these various money smuggling operations and had briefed
myriad missions myself during the early seventies. I was also
briefed for perhaps 20 such missions myself. After those missions
I was debriefed in confessionals or security checks to find out
whether any money was juggled etc.

I had also seen the B-1 hat packs and other church materials
dealing with how to conduct illegal and/or other activities. I
was declared a suppressive person by the church and I knew from my
knowledge of Scientology's fair game policy that I could therefore
be tricked, lied to, or in any manner destroyed by any
Scientologist, without that Scientologist being subjected to a
Scientology Committee of Evidence for doing whatever they did to
destroy me. Attached hereto as Exhibit B is a copy of an

-2 2-


Executive Directive dated January 27, 1983 and being a List of
Suppressive Persons. My name is on the lower right hand side of
page 5.

26. A few weeks ago, I stopped working as paralegal and
designated expert for the law firm of Lewis, D'Amato in this
litigation because my research of Scientology activities since my
departure in 1976-1977 caused me to become fearful for the
security and safety of my mother, sister and friends and
discovered through questioning same that they were all terrified
of my involvement in the instant matter.

DATA~: 8398.1 -23-

27. I have read the declaration by Robert Vaughn Young dated
October 25, 1993 and theexhibitstheretodealingwithScientology's
Fair Game policy and on the basis of my knowledge and experience
within the Church of Scientology, I can state from my o~ knowledge,
experience and training that its contents are true and correct.

I declare under penalty of perjury under the laws of the United
States and of the State of California that the foregoing is true and

Executed this
day of March,at Los Angeies California.
Scott Mayer


27. I have read the declaration by Robert Vaughn Young dated
October 25, 1993 and the exhibits thereto dealing with
Scientology's Fair Game policy and on the basis of my knowledge
and experience within the Church of Scientology, I can state from
my own knowledge, experience and training that its contents are
true and correct.

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

Executed this day of March, 1994 at Los Angeles,

Scott Mayer



I am employed in the County of Los Angeles. I am over
the age of 18 years and not a party to this within action; my
business address is 221 North Figueroa Street, Suite 1200, Los
Angeles, California 90012.

On March 9, 1994, I served on the interested parties
in this action the within document entitled: DECLARATION OF SCOTT

IX] by placing a true copy thereof enclosed in a sealed envelope
addressed as follows:


[X](BY MAIL) I caused such envelope(s) with postage thereon
fully prepaid, to be deposited with the United States Postal
Service at Los Angeles, California.

I am readily familiar with the firm's practice for
collection and processing of correspondence for mailing
with the United States Postal Service. Said correspon-
dence will be deposited with the United States Postal
Service on this same day in the ordinary course of
business. I am aware that upon motion of party served,
service is presumed invalid if postal cancellation date
or postage meter date is more than one day after date of
deposit for mailing as declared therein.
Executed on March 9 , 1994, at Los Angeles, California.

[ ] (STATE) I declare under penalty of perjury under the laws of
the State of California that the foregoing is true and cor-

[x] (FEDERAL) I am employed by a member of the Bar of this Court
at whose direction this service was made. I declare under
penalty of perjury under the laws of the United States of
America that the foregoing is true and correct.

Marcia Schwartz



Mr. Steven Fishman
8851 Sunrise Lakes Boulevard, #116
Sunrise, Florida 33322-1413

Jonathan W. Lubell, Esq.
750 Lexington Avenue
New York, New York 10022

Robert Wiener, Esq.
6255 Sunset Boulevard, Suite 2000
Los Angeles, California 90028