Subject: Scientology Lies: First Deposition of Vicki Aznaran
Date: Sat, 02 Dec 2000 11:30:32 -0800
Organization: Flat ASCII productions
Message-ID: <t9ji2tku8na664gdc715h3ied6epv2s65c@4ax.com>
AFFIDAVIT
I, Vicki J. Aznaran, of Mesquite, Texas, U.S. Citizen, Passport
No. 03197042, do herewith depose and swear:
1. That from the approximate dates of 1984 until 1987 I
held the positions of President and Chairman of the Board of
Directors in the Scientology organization called the Religious
Technology Center, INC, (RTC) which is now the senior governing
entity of the International Church of Scientology, the Church of
Scientology of California, and all affiliated organizations
within the U.S., as well as senior governing entity for all
foreign Scientology organizations and the civil associations of
Scientology such as those called Dianetica or Narconon in Spain.
2. That despite efforts to cloak the fact, the true role
of the Religious Technology Center, Inc. is that role explained
above, and it holds this managerial position within the matrix
of all of the interrelated organizations of Scientology: The
Church of Scientology International, Inc., The Church of
Scientology of California, Inc., The Church of Spiritual
Technology, Inc., Authors Services, Inc., Missions International
de Scientology, Inc., Relig ous Technology Center, Inc., Authors
Family Trust, Asociacion Civil de Dianetica, Asociacion Civil de
Narconon.
3. That these various organizations exist in this manner
to provide an "arm's length" appearance in order to protect the
current board of directors from actual legal culpability for any
illegal acts committed by or through the churches of Scientology
or any of their other affiliated organizations, as well as to
confuse any issues, investigations or litigation which might
expose the illicit actions of any individual Scientology
orqanization or member thereof.
4. That as a former senior executive of this body, from
1984 until 1987, I have observed and have certain knowIedge of
the activities of RTC and of its finances as well as its manner
of incorporation and related documents.
5. That during the period of my employment by the RTC I
reported to David Miscavige, who was at that time Trustee of the
corporation. Miscavige maintains absolute control over all
officers and board members of this corporation, controlling these
other members of the board of directors by fact of his possessing
undated, signed resignations of each member, the holding of which
gave and gives him complete control over each member of the
board.
6. That also, to my certain knowledge, David Miscavige
conceived, planned and ordered the implementation of the basic
strategic and tactical actions of the church against those whom
he considered to be causing legal or public relations conflicts
against any church or against his personal and absolute control
of Scientology. He also ordered the allocation of and made
available funding for the financing of these actions, which
included the declaring of those whom he considered to be his
"enemies' as Suppressive Persons, the implementation of the
policies known as "Fair Game" against these persons once
so declared, the infiltration of private and governmental
environments which he deemed hostile to his absolute control over
Scientology, the organization of vigilante groups within the
organizations of Scientology to be used against those individuals
whom he deemed to be his enemies.
7. That following Miscaviges' orders, I transferred monies
to Spain, and witnessed briefings by Miscavige to Heber Jentszch,
who was in fact the "puppet" president of the church, but who
actually is a .camouflage for Miscavige, concerning covert
operations taking place in Spain against former Scientologists
and concerninq false testimony and concerning the attempt to
offset a rumored investigation by the spanish authorltles lnto
the activities of Scientology in Spain, the very investigation
which resulted in the surprise arrest of Jentszch himself in
November of 1988. These operations included orders for
investigations by the private detectives employed by the
Scientology organizations to obtain information by any means
possible to incarcerate the leaders of a reform movement who had
not been silenced previously by Miscavige's policies and
declarations, with the express intent of obtaining their
incarceration.
8. That during this same period and as part of these same
operations, a plan was formulated to destroy the reform movement
in europe by completely eliminating the leaders of this reform
movement, William Robertson, John Caban and others, by any means
possible. This included the infiltration of the reform group in
Spain by covert agents of RTC, Kurt Weiland and William Knight,
continued investigation and harassment by detectives employed by
the scientology organizations in Spain and by recruiting others
who would help to splinter the reform movement and to render it
ineffective.
9. That additional orders were given to institute any
action necessary including false denunciations, assaults by
covert agents apparently in bad standing with the church, to
infiltrate, offset and attack those leaders of the reform
movement who were thought. to be responsible for reporting
Scientology activities to the spanish authorities and undermining
Miscaviqes intentions.
10. That the policies known as "Fair Game" are, as
described in the writings of L. Ron Hubbard, ethics policies, and
other organizational policies are in fact continued as originally
written by Hubbard, and that it is the purpose of the RTC to see
that all of his policies are followed exactly as intended. It was
common knowledge that the "Cancellation of Fair Game" referred
only to the use of the term, since it had obtained bad public
relations for Scientology, and that the same tactics and actions
which referred to those so-called Suppressive Persons were and
are continued in effect.
ll. That the organization known as the Guardian's Office,
while apparently abandoned, in fact was moved from the position
as a separate organization or network, and incorporated within
the organizational structure of Scientology, and all of the
purposes and most of the Guardian personnel have remained the
same. Again, the purpose of these changes were to obtain complete
control by Miscavige over all Scientology organizations, and to
obtain a more favorable image after Hubbard's wife was found
guilty of crimes as head of the Guardian's Office.
12. Since my departure from the church my husband and I
have been repeatedly threatened and harassed by members of
Scientology, and we are now in fear for our safety.
Many of the statements made above contain information which
has been testified. to by others and/or are matters of publlc
record within other areas of litigation within the United States.
I swear under penalty of perjury under the laws of the state
of Texas that the contents of this affidavit are true to the best
of my knowledge and recollection.
Date 1 - 27 -92 Vicki J. Aznaran (signature)
1-27-92
signature
Notary Public
Dallas County, Texas
USA
From: Joel J. Hanes <jhanes@dellnet.com>
Subject: Scientology Lies: Second Affidavit of Vicki Aznaran
Date: Sat, 02 Dec 2000 11:35:46 -0800
Organization: Flat ASCII productions
Message-ID: <0fji2tcaiphjc5oprd6ndup0j0n25a84s5@4ax.com>
- - DECLARATION OF VICKI AZNARAN (USA vs. Fishman)
- - SUPPLEMENTAL DECLARATION OF VICKI AZNARAN (USA vs. Fishman)
- - EXHIBIT A regarding the invesigation of Judge Swearinger and his
gay son an a tool to influence/remove Swearinger from the
case (USA vs. Fishman)
- - ORAL DEPOSITION OF VICKI AZNARAN (RTC vs. Wollersheim & Co$ vs.
Robin Scott - partial)
*********** Let the testimony begin! ********* DECLARATION OF VICKI AZNARAN UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA CASE NO. CR-88-0616-DLJ
UNITED STATES OF AMERICA,
Plaintiff,
v.
STEVEN FISHMAN,
Defendant.
I, VICKI AZNARAN declare as follows under penalty of perjury: I joined the Church of Scientology in 1972. In 1978, after approximately four years as staff members, my husband and I joined the Sea Organization. From 1978 to early 1987, my husband and I worked most of our waking hours, with very few days off, at our various assignments within Scientology. I eventually became President of Religious Technology Center and, supposedly, the top "ecclesiastical" authority within Scientology. Richard was a high-level security officer. During this period my husband and I became intimately familiar with the structure and activities of various Scientology organizations. Among other things, I was briefed on and was sometimes a participant in meetings involving litigation tactics and various means used to attack and fight "enemies" of Scientology. In numerous instances I was in the chain of command for approval for such activities. From 1984 to 1987, I held the office of Inspector General one of the highest worldwide offices in the organization and so was privy to the most arcane practices of the group. The legal strategy of Scientology and the existence of numerous potential legal problems, some of which are set forth below, were known to me when I was a staff member in Scientology. Enemies of Scientology are deemed to be "suppressive persons" ("SPs"). One becomes a "suppressive person" by doing a suppressive act, such as suing Scientology as a litigant or lawyer. In the jargon of Scientology, when one is "declared" this means that one has been declared a "suppressive person" and, therefore, may be harassed, hurt, damaged or destroyed without regard to truth, honesty or legal rights. It is considered acceptable within Scientology to lie, cheat, steal and commit illegal acts in the name of dealing with a "suppressive person." This practice or policy is sometimes referred to as the policy of "fair game." In the jargon of Scientology a person who is "declared" is understood to be a suppressive person. This means that the person is "fair game." The fair game policy was issued in the 1960s. It was never canceled. A document was issued for public relations reasons that purportedly canceled "fair game"; however, that document stated that it did not change the manner of handling persons declared "SP." In reality, the purported cancellation of fair game is at most a matter of semantics. Enemies of Scientology are treated as "fair game." David Miscavige was the Chairman of the Board of Author Services Inc., ("ASI") in 1984 and 1985. ASI was incorporated to be the funnel through which profits from Scientology were channeled to L. Ron Hubbard and, therefore, it was very important within Scientology. Miscavige represented Hubbard in all aspects of controlling Scientology. He attended regular meetings with myself and other top officials of Scientology organizations to review the status of all Scientology's activities, including its litigation and dirty tricks campaigns against Scientology's enemies. Because of my position and the regular reports that came across my desk I know that throughout my presidency of RTC that fair game actions against enemies were commonplace. In addition to the litigation tactics described below, fair game activities included burglaries, assaults, disruption of enemies' businesses, spying, harassive investigations, abuse of confidential communications in parishioner files and so on. I specifically recall seeing one report regarding attacks against Bent Corydon after Scientology became aware that he was writing a book against Hubbard. Other Hubbard writings encourage Scientologists to pursue litigation purely for harassment without regard to the merits of a claim to cause enemies to fold. Hubbard's writings state:
"The purpose of the suit is to harass and discourage rather than to win...The law can be used very easily to harass, and...will generally be sufficient to cause [the enemy's] professional decease. If possible, of course ruin him utterly." Hubbard, "Magazine articles on Level O Checksheet" American Saint Hill Organization 1968.As President of RTC and a Sea Organization member, I attended meetings concerning the numerous legal actions involving Scientology organizations. During this time period, I had personal access to all legal documents having to do with RTC. I received a report every day on my computer that included a synopsis of each ongoing legal case involving Scientology. I received, or so I was told, copies of every major motion filed in cases involving Scientology. I was on the "approval lines" for legal documents dealing with RTC. During this time period, I had the option of attending legal meetings, although some were mandatory. I attended many litigation meetings and became generally aware of Scientology's dirty tricks and legal maneuvers. On specifics, I frequently deferred to in-house and outside counsel; however, at least in theory, I was the head of RTC and had access to any business or litigation "secrets" of Scientology. It is the stated policy and practice of Scientology to use the legal system to abuse and harass its enemies. This crude, fundamental directive of Scientology is no secret. The policy is to do anything and everything possible to harass the opposing litigant without regard to whether any particular motion or maneuver is appropriate or warranted by the facts or applicable law. That policy was followed in every legal case I was involved with or learned about while a member of the Sea Organization. The management of Scientology consistently expressed and demonstrated a complete disdain for the court system, viewing it as nothing more than a method to harass enemies. Some examples of this are set forth below. During litigation between Gerald Armstrong and Scientology, which was before Judge Breckenridge of Superior Court for Los Angeles County, the court ordered the production of Armstrong's pre-clear ("PC") folders. These are files maintained by Scientology on those who submit to interrogation sessions in a process called auditing. During the course of that litigation I was ordered to go through Armstrong's folders and destroy or conceal anything that might support Armstrong's claims against Scientology. This practice is known within Scientology as "culling PC folders" and is a common litigation tactic employed by Scientology. During other litigation in Los Angeles known to me as the Wollersheim case, I was told that the judge had ordered the production of Wollersheim's folders. As ordered, I "culled" these files. In other words, I removed contents that might have been damaging to Scientology or might have supported Wollersheim's claims against Scientology. For example, I removed evidence of events involving his family, the anguish this caused him, evidence of disconnection from family and evidence of fair game. I was involved in numerous meetings concerning what is known to me as the Christofferson case in Portland, Oregon. This case was tried twice. In the first case, a Scientology witness by the name of Martin Samuels was coached and drilled for hours on how to lie convincingly or avoid telling the truth. Before or during the second trial he admitted to this course of conduct. In this litigation, a Scientologist by the name of Joan Shriver produced responsive documents that may have been incriminating. This was a serious breach of policy for which she was punished. These documents were ordered produced on such short notice that apparently files were not thoroughly "culled." In another case, an attorney was severely criticized and almost fired for failing to properly coach and feed the desired answers to Heber Jentzsch. Mr. Jentzsch was, for public relations reasons, the purported head of the Church of Scientology International. During his deposition, Mr. Jentzsch was unable to answer fundamental questions concerning the management of Church of Scientology International. In later 1979 and early 1980, there was a massive document destruction program undertaken to destroy any evidence showing that L. Ron Hubbard ("LRH") controlled Scientology. I participated in this activity in Clearwater, Florida and am informed that there was also intensive document destruction at facilities in Gilman Hot Springs, California. From at least that point onward there was a continuous effort to hide or destroy any evidence of Hubbard's control. For example, during an IRS investigation in 1984 and 1985, while in bed with pneumonia, I was ordered out of bed by Norman Starkey, who told me that they had received a tip from a Los Angeles police officer advising them of a pending IRS raid in Los Angeles. Mr. Starkey ordered me to go to a computer facility and insure that all information on the computers in Los Angeles that might show Hubbard's involvement and control of Scientology's money was destroyed except for one copy of each document. These copies were to be saved on computer disks which were to be hidden in secure storage places. At the time I was also instructed to destroy anything that would show the control of Mr. Starkey or Mr. Miscavige over Scientology. In or about 1981, while working in a Scientology organization known as the Guardian's Office, I had access to and observed various written and oral communication pertaining to illegitimate activities participated in by the Guardian's Office. The Guardian's Office attempted to infiltrate both governmental and private agencies including the IRS, the Department of Justice, and the American Medical Association and the National Institute of Mental Health. The purpose of this was to steal documents pursuant to Hubbard's "Snow White" program. The goal of this program was to eliminate any negative reports about Hubbard and Scientology that may have been held by these various agencies. While involved in Scientology I became aware of various operations directed against an author who had written a negative book about Scientology. The author, Paulette Cooper, was subjected to various forms of harassment. One operation included an attempt to frame her. A false bomb threat was written. Scientology agents lifted a fingerprint from Cooper's apartment. These fingerprints were then transferred to the bomb threat letter. Ms. Cooper was subjected to an investigation and was not cleared until an FBI raid resulted in the seizure of Scientology documents that exposed the operation as a frame-up. There was at least one other operation directed against Ms. Cooper. The substance of it was to plant a boyfriend to reinforce and play upon her suicidal tendencies in the hopes that she would commit suicide. In 1976 and 1977, the then-Mayor of Clearwater, Florida, Gabe Cazares, was involved with litigation against Scientology. Arrangements were made to have an attorney by the name of Merril Vanniere, a Scientologist, represent Mr. Cazares and sabotage his case. This plot was also exposed by documents obtained in an FBI raid of a Scientology facility. Also, in response to Mr. Cazares' litigation against Scientology, an attempt was made to implicate Mr. Cazares in a staged hit-and-run accident. During an IRS criminal investigation in the 1984 to 1985 time period, the IRS ordered production of various communications between Hubbard and Author Services, Inc. (ASI). The ASI staff worked literally day and night for several days reviewing documents so that unfavorable documents could be destroyed or otherwise concealed from the IRS. Lyman Spurlock and Marion M. Dendue, Scientologists involved in this operation, informed me of this operation. Also during this IRS investigation, my husband, Rick Aznaran, was ordered to remove and conceal any incriminating documents from certain locations. He was also directed to make the computer network "raid proof." This involved creating a system where incriminating documents could be deleted from computer storage rapidly and before the IRS could obtain control over the computers. I have examined certain documents regarding Steven Fishman's experience with Scientology, have had conversations with Mr. Fishman's counsel, and have reviewed the 1151-page autobiographical account of Mr. Fishman's Scientology experience entitled "The Lonesome Squirrel." Based upon my 15 years of experience in Scientology and my review of the Fishman materials, I offer the following conclusions: 1. I believe Mr. Fishman's assertions that he was a member since 1979 and that he was as actively involved as he states. This belief is based on my experience that only a committed member of long standing would know the details of the inner workings of the group; Mr. Fishman has such knowledge. Awareness of certain confidential projects could be achieved only by a member who was trusted by the hierarchy; Mr. Fishman had such awareness. Involvement in a group that thrives on secrecy and excludes most members from participation in high-level projects means that any member who exceeds a certain level of involvement enjoys the trust of the leadership; such trust would be earned only by extended membership. Mr. Fishman enjoyed that trust. His accounts of meetings with high-level officials and his knowledge of the operations and functions of the hierarchy are so detailed and accurate that they couldn't have been gained except through direct personal experience. 2. Refutation by Scientology officials of Mr. Fishman's membership prior to February 8, 1986, and their disclaimer of his involvement and their lack of any records pertaining to such membership is perfectly consistent with their standard procedure in protecting themselves. As noted above, I was personally involved in the destruction of records when it suited their purpose. Scientology propounds the belief that any action whatsoever taken to protect the organization is justified, as the group takes precedence over the individual. Any member performing criminal acts for the benefit of the group was kept at arm's length; if apprehended, the member was disavowed by Scientology. This procedure was used even on the wife of the founder of Scientology. Given the serious potential threat that Mr. Fishman's defense posed to the group, I find Mr. Fishman's account of certain members of Scientology's involvement in the plan to fabricate the threats against Mr. Fishman and his counsel and to thereby undermine Mr. Fishman's 15 credibility and render him useless as a witness against Scientology to be consistent with their modus operandi. I declare under penalty of perjury under the laws of the State of Texas that the foregoing is true and correct. Executed this XX day, of 1990, in Dallas, Vicki Aznaran - ---------------------------------------------------------- SUPPLEMENTAL DECLARATION OF VICKI AZNARAN I, Vicki Aznaran, declare: 1. I joined the Church of Scientology of California ("Scientology") in 1972, and was a member until I left in April 1987. From 1984 until 1987, I was Inspector General of the Religious Technology Center, an affiliated Scientology organization. At that time, this was one of the highest worldwide offices in Scientology. One of my offices was located at 4751 Fountain Avenue, Los Angeles. 2. By virtue of my high position, I was "in the loop" to receive communications about some of Scientology's most secret operations. The facts set forth in this declaration are based on my own personal knowledge, which came from many sources, including numerous discussions and meetings with top Scientology "intelligence officials" and other Scientologists and reading documents which passed across my desk or came to my computer. 3. During the 1984-87 period, Scientology operated a number of "dirty tricks" operations out of the Office of Special Affairs (OSA), including one called MFTC (for "Mission Find The Crimes") and the "WOLLY" unit (which targeted Lawrence Wollersheim, his attorneys, and his case). The orders for these operations would go directly from OSA to private investigators, although Scientology deceitfully tries to cloak such operations under "attorney-client privilege". 4. MFTC and the WOLLY unit each had about 8-10 staff, and engaged in whatever dirty tricks were necessary to attack people and entities which were considered to be "enemies" of Scientology. The dirty tricks they used included destruction of evidence, theft of documents, illegal surveillance or bugging, blackmail, bribery, physical assault and other intimidation, securing perjured testimony. MFTC's mission was to find or manufacture crimes for "enemies" of Scientology. 5. Before and during the trial in Wollersheim v Church Of Scientology of California, MFTC and WOLLY ran a number of operations directed against Wollersheim, his counsel, and the Court. One of these operations was an attempt to put pressure on Bill Swearinger, the son of the trial judge in the Wollersheim case, based on his alleged homosexuality. The idea was to dig up, or manufacture (perhaps by setting the son up in a compromising sexual position with a minor boy), dirt on the son which could be used to pressure the Judge to rule favorably for Scientology, or else to get the Judge disqualified. 6. Attached as Exhibit A is a true copy of an internal Scientology memorandum, dated 6/21/86, which discusses this "Swearinger Investigation". I received a hard copy of this document at about that time, and I believe I also received a copy of this document on my computer. The Linda referred to on the first page is Linda Hamil, who at the time ran the MFTC. The Marty referred to on the first page is Marry Rathbun, a top Scientology "intelligence" official, who ran this operation. 7. Scientology's "ambush interview", discussed in Exhibit A, makes the Mike Wallace/60 Minutes interview called by the same name look tame. The "ambush interview" generally involves doing whatever it takes -- threats, physical force, bribery, or whatever -- to get an unprepared and unsuspecting target to say what is wanted. 8. I understand that Lynn Farny has submitted a declaration stating that Scientology complied with Judge Swearinger's order in the Wollersheim case to produce Wollersheim's pre-clear files. This is false. As I stated in my Fishman declaration, I personally culled and destroyed (shredded) from these files evidence which would help Wollersheim and hurt Scientology in the case. I was personally ordered to do so by David Miscavige, the head of Scientology, and Marty Rathbun. The culling and destruction took place at the Fountain 30 Avenue building in Los Angeles. I was assisted in the document destruction by then Scientologist Jessie Prince. Lynn Farny was a low level Scientology official, and was not at the meetings where this was discussed. However, Lynn Farny is not telling the truth, because as a Scientology staff member he knows it is Scientology policy never to turn over information in litigation without first culling out (deleting and destroying) material that will harm Scientology. It is also, however, Scientology policy to lie to cover up such misdeeds. 9. Attached as Exhibit "B" to this declaration is a true copy of a document called "TRL", which is a Scientology training drill to teach Scientologists to lie convincingly. 10. I understand Scientology is trying to vacate Wollersheim's judgment on grounds that Judge Swearinger was biased against Scientology and his bias infected the jury. This is a typical Scientology tactic which it frequently uses in trials as insurance when Scientology loses an important case. Scientology will do things to set up a mistrial, such as calling jurors in the middle of the night and hanging up, threatening.
[note: the exhibit was somewhat garbled by the scanner] - -----------------------Begin Exhibit A---------------------- WOLLY INVEST I/C < .....
21-Jun-1986 10:37
e
To: WOLLY INVEST I/C
From: MFTC I/C
Re: Swearinger Invest
for your info and whatever else you can do with this... 20-Jun-1986 20:56 Dear Linda, What does JP want to do with Bill Swearinqer? What did Bowles say to him? Why would we want Bill S to have Royce confess? Confess to what? When will the rest of the 13 original targets be done? ~IL Marry 20-Jun-1986 20:40 Dear Sir, Compliance Report.
What was ordered:
I sent over a 18 step invest to revive the Swearinger Invest. In response you merc'd' "'Ilk, I'll expect the results of all of this by Friday.' (In this same comm you asked for the Mayer invest which is forwarded in a separate Merc.) What was done: The results of the Swearinger Invest are in the report below. The original targets are at the very end of this comm. This is DK. fill Linda Swearinger Invest results: resulted in a) two Swearinger neighbors recalling a White Cherokee by Bill's house a few times in the last 6 months {that's what Royce drives} and by Bill Swearinger calling up Tim Bowles wanting to end cycle of it all once and for all. Step by step results follow. 1. Learn[?] was not yet interviewed as she has not yet been located. However we did find out that she has left the employment of Varsity Communications and we found her last name, traced her through her parents and now have her unlisted phone number in Hollywood. She has not been in yet but should be able to be reached either tonight or Saturday. The good news is that she no longer works for the company so will not be under the thumb of Palmieri. Perry and Embinder have not been at the office or at home over the last days so have not yet been confronted. Ambush interview of Steve Perry (a.k.a. Bubba}. He could confirm the relationship of Bill S. and Walker. Photos were taken to Royce's neighbors and none recalled having seen Bill, None of Bill's distinctive cars in the vicinity. 5. Bill's neighbors were shown Royce, Bubba and Embinder and did not recognize them. They were also shown the photo of Royce's white Cherokee and two of his nearest neighbors independently recognized having seen such a car parked adjacent to the stairs leading up to Bill's house a few times over the last six months. One of these neighbors, Mr. Franklee (a film editor said that Bill frequently had parties where young boys were observed at Bill' s house but had no distinct memories of any faces. 6. We have not been able to confirm where Casey was 9-10-11 May due to terminals not being accessible. 7. The line to the secretary to get further data from the court reporter ran into a logistics snag and will need to be done Monday. 8. Though Royce has refused to speak at all with Francovich, a line to go in on to reestablish the comm has worked out which can be done early next week (Francovich will take over a check owed to Royce which will be coming in Monday or Tues,. 9. The young mexican we'd seen with Swearingor last month has not been identified. The neighbor checked with (Pranklee) recalled having seen him about a month ago walking away from the house, upset, originating to this neighbor "I can't go on like this any more, I'm really upset. And this neighbor hasn't seen him since. Checks were made at a local mexican restaurant the two had stopped at when under surveillance, no data, and a number in Guatemala possibly associated with this kid was checked but the only person at the number with contacts in LA was out of town for a week. So the kid could not be located to interview. 10. The spots where Bill was seen to stop on surveillance were checked for familiarity with Royce or his vehicle or friends and there was no recognition. The vicinity of an address where Royce had been seen dropping off two young men was checked and one neighbor, a foreigner, man (Mr. Behar) recognized having seen a car similar to Bill Swearinger's in the neighborhood. 11. Stuart and Steve's office was visited, they were not there but the current office manager related a story consistent with Royce Walker's description of Swearinger and Walker only casually knowing each other. 12. Royce & friend's photo was shown to the receptionist and security man at 69~ Hollywood (where Swearinger's office is located, but ~ot d~a~in~ attention to Swearinger). No recognition. His old office across the street was also checked, no reads. 13. It was found that Caryl Warner does still practice law and works out of 69~ Hollywood - Suite 500 - a full schedule every day. However a check made on Thursday revealed that he was out until Monday so no pretext interview has yet been done. A definite impingement was made from the actions taken Bill Swearinger phoned Tim Bowles at ~:15 today and said the following: that Al Bei[?] of Ingram investigations was asking his neighbors ~ his clients questions about the veracity of Royce Walker, was very upsetting and said he wants it to stop immediately. He wants to end cycle on this escapade on his knowledge of the Judge's prejudice "once and for all". He said he is not willing to submit to a deposition (because the federal judge ruled that such a depo is irrelevant). However, he said he is willing to meet with us to tell us what he knows. He insists there is no prejudice from his father. He termed our efforts 'shooting in a barrel with nonexistent fish", something like that. He said that if we can't come to an immediate resolution on [missing words] is he going to take "self-help". He specifically mentioned buying a gun or drafting and filing a motion for protective order in the federal case. He said he couldn't wait until Monday, he decided to resolve it now. It is of interest that Al Bei[?] did not interview any of the neighbors, that was done by Mark Marinc. Al Sr. went to the 6922 Hollywood building (Swearinger's office and Al Bei Jr. went to Royce's office at 7715 Sunset. We don't know who any of Bill's clients are (though one of the women interviewed by Marino could have been a client}. Next a) Have the confrontation with Swearinger and get him to tell the truth about this matter. If he insists he is being truthful, have him drag in Royce to confess, and Francovich can be there too. {the following steps to be done but called off if step (a) resolves it as continuing would be pointless.} b) Interview Leann (per last call her ~o~ate said she's expected to be there Saturday) who is no longer part of the Varsity office. She'll be checked out whether the boys went to Palm Springs as well. c) Ingram to call Casey to ask him Just one more question - the Palm Springs question he neglected to ask him during the interview. ~) P~.l ~ ~u~t reporter string via the secretary resource. e) interviews of Embinder and Bubba. f) Francovich to recontact Roy~ with check owed to him and get him in. f) Pull down Caryl Warner string through pretext interview. il Ambush interview on Leann, the secretary (she was the one other person mentioned in the depo of Walker as someone he talked to about Son. She will be gotten outside of the office as in the office someone could contact Palmieri and she'll clam up.) ambush interview of Steve Perry (aka Bubba). He could confirm ~i~g of Bill S. and Walker. ~q~ ~erv~e~ of Embinder as possible. Photo of Bill and Ron taken to Royce's neighbors to see whether ~~ seen them around. 5. Photos of Royce, Bubba, Embinder and Casey shown to Bill Swearinger's neighbors. 6. Find out where Casey Klinger was the weekend 9 - 10 - 11 May, i.e. whether he was in Palm Springs or not. (pretext has been worked out to get this.) If in Palm Springs, get identity of the two fags they were with. 7. Use secretary resource who has a good line already to the court reporters to find out anything further on the cash payment cycle, i.e. was the Judge irritated, who else may have been there, etc. 8. Francovich to re-establish comm line with Royce over some business dealing, and see what further can be obtained from this line, get him to cop out to what occurred (witness present). 9. Use our Spanish speaking PI (Joe) to suitably interview the young mexican (P. Garcia may be name) guy who was seen with Bill Swearinger at least three mornings, who may live with Swearinger, and get the data on Bill's relationship with Royce 18. Use the data we have on Bill's contacts (places he was observed ~oi.nO ~n~en under surveillance and known comm lines he has) to interview the contacts with pictures of Royce and Bill re: their relationship. 11. Stuart and Steve (Bill's former employers and Royce's friend) ~=en w/photos to establish how many times and for what reason Royce visited Bill. 12. Suitably inquire (with photos) at Bill's current law office about Walker, does he show up there frequently etc. 13. Pull down strings on any possible relationship between Swearinger and Caryl Warner (work in same suite though different offices) - through pretext interview. the above to be done by Friday, then analyzed and retargetted. - -----------------------End Exhibit A ----------------------
UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA RELIGIOUS TECHNOLOGY CENTER, a California corporation, et al., VERSUS ) CV 85-711 JMI ) ROBIN SCOTT, an individual, ) CV 85-7197 JMI (Bx) et al. ) RELIGIOUS TECHNOLOGY CENTER, a California corporation, et al., VERSUS - LARRY WOLLERSHEIM, an individual, et al. , AND RELATED COUNTERCLAIMS ORAL DEPOSITION OF VICKI J. AZNARAN August 2, 1989 Pages. 130-252 ANSWERS AND ORAL DEPOSITION OF VICKI J. AZNARAN, a witness produced at the instance of the Defendants, taken in the above styled and numbered cause on the 2nd day of August, 1989, at 10:55 o'clock_ a.m., before KIM S. JOHNSEN, a Certified Shorthand Reporter in and for the State of Texas, at the offices of Clark, West, Keller, 'Butler &.Ellis,. 4800 Renaissance Tower, 1201 Elm Street,' in the City Of Dallas, County of Dallas, State of Texas, in accordance with the Notice and Subpoena issued and the provisions set forth: (Defendants' Exhibit V. Aznaran Number 16 was marked for identification.) Q. Ms. Aznaran, do you know what Exhibit 16 is? A. Yes. It's an LRH executive directive. Q. have you ever seen it before? A Yes Q. Did you see it when you were with the Church of scientology? A. Yes. Q. May I see it for a moment? A. (handing) MR. FAGELBAUM: Mark as Exhibit 17 a one-page document bearing the notation TR-1. (Defendants' Exhibit V. Aznaran Number 17 was marked for identification.) A. Okay Q. Do you know what this document is? A. Yes Q. What is it? A. It 's known as TR lie. Q. TR lie? A. Yes Q. L-i-e? A. yes. Q. Have you seen this document before? A. Yes. Q. Where have you seen it? A. I first saw it in a mission in Dallas, later saw it in the Guardian's Office in Los Angeles. Q. When you say "mission in Dallas," is that a Scientology mission in Dallas? A. Yes. Q. And what is a TR lie? A. It's a training regimen where someone is trained to MR. MOXON: I object to the question. She answered before I could object on the basis of lack of foundation. Move to strike. Q. Do you know what the purpose of this document was for? MR. MOXON: Objection; lack of foundation. A. I know what it was explained to me that it was for. Q. Who explained it to you? A. A member of the Guardian's Office named Danny Chadwell. Q. When did this occur? A. 1974 or 5, I'd say. Q. And how was it explained to you at that time? MR. HELLER: Objection; hearsay. MR. MOXON: Same objection. A. That the purpose of it was to teach you to be able to lie when you needed to when you were asked questions that you didn't want to answer about persons, such as reporters or whatever. MR. MOXON: Move to strike. Q. Who was exposed to this procedure in the Church of Scientology? MR. HELLER: Objection; calls for speculation. MR. MOXON: I'll join in the objection. Also lack of foundation. A. I mean, I couldn't say over all the years who all was exposed to this. Q. Who was given this kind of training as a generic class, not an individual? MR. MOXON: Objection; lack of foundation. MR. HELLER: And speculative. A. People in B1 in the GO. MR. MOXON: Move to strike. A. And public relations staff and guardian area Scientologists, GAS is what they went by, GAS. MR. MOXON: Move to strike. Q. What are guardian area Scientologists? A. These are Scientologists that did work in the field for the Guardian's Office. Q. And what is B1 of the GO? A. Bureau 1 are the Intelligence Bureau. MR. HELLER: Sorry. A. In order to show compliance that it was occurring, and then I was involved in the approval of the new name for it. MR. HELLER: Objection; move to strike because the answer is hearsay answer. MR. MOXON: Join in the objection. Q. Now, was the process of TR-1 made available to personnel in OSA? MR. HELLEY: Objection; no foundation. MR. MOXON: Join in the objection. A. I think we could say the tech was certainly applied. The -- this document did not exist laying around there. MR. MOXON: Okay. And move to strike the first part of that answer based on my objection and because it's not responsive. Q. Are you aware of the tech being applied of TR-1 to personnel in the OSA? A. I'm aware of them applying it to others. MR. HELLER: Objection; no foundation. Again, move to strike. MR. MOXON: Join. Q. Bow were you aware of that? A. Well, let's start -- we can start with depositions. There are certain people offered up to be -- when a deposition is noticed for a corporation, there are certain people offered up to go and have that deposition taken. Before they do that, they are coached on what they should know and should and should not say. Q. Did you personally observe that happening? A. Yes, I have. Q. Have you observed that happening in this case? MR. MOXON: Today. A. I don't know if it was in this case or not. Q. Do you know of personnel affiliated with RTC being afforded this opportunity? MR. MOXON: Objection; vague and ambiguous, lack of foundation. MR. HELLER: And unintelligible. A. Yes. MR. MOXON: Also leading. Q. who? MR. MOXON: Move to strike. Object to the pending question. A. Jessie Prince. MR.. MOXON: Move to strike. Q. Do you know if Jessie Prince testified in the hearing in this case? A. As a matter of fact, he did. Q. Was he given TR-L training prior to his testimony? MR. MOXON: Objection; lack of foundation. MR. HELLER: I'll join in that objection. A. He was drilled as to what to say and what not to say. MR. MOXON: I want to caution the witness again. She 's obviously making some broad generalities that are not responsive necessarily to the questions, but if she's talking about attorneys speaking with some -- if she's referring to attorneys speaking to a client before they go into a deposition, I'm not sure if that's what she's talking about or if she's, you know, making up something new at this point. But to the extent she's referring to some attorney-client communication when she's making an inference or opinion about it, I instruct her that it's a privileged matter. MS. MCRAE: I'll caution the witness. I represent the witness, Mr. Moxon. MR. HELLER: Well, it's not for you to caution the witness. It's Mr. Moxon's privilege. It's his client which is being breached. Assuming you are the most reputable attorney in the world, it still is his job to caution the witness and make sure there are no disclosures of that as well as your job and as well, as I might say, Mr. Fagelbaum's job. I assume Mr. Fagelbaum is not going to get into it to make the determination in good faith, but in fact that's a job of an officer of the court, most particularly Mr. Moxon's job Q. Was Mr. Prince advised -- excuse me -- was Mr. Prince drilled by somebody other than an attorney in this case? A. Yes, he was. Q. Who was he drilled by? A. Myself. Q. Was there anyone else present at that time? A. I believe Jeff Shriver was. Q. Anyone else? A. I don't think so. Q. Did you follow the procedures set forth in TR-I? A. Not totally, no. Q. To what extent were they followed? A. Well, I worked out for him not to tell the truth about what happened when he was signing certain documents over in England. Q. What specifically did you tell Mr. Prince not to tell the truth about? A. It was more a situation of Jessie and I working out together what he was going to say. Q. Okay. A. And what he was not going to say. Q. All right. Can you describe what that conversation was? MR. HELLER: I'm sorry. Please repeat that. Q. Can you describe that conversation? MR. HELLER: Object to the extent it calls for hearsay. MR. MOXON: Join in the objection. A. There was a document signed by Jessie, handwritten by me, [missing word] document agreeing to something. It was signed by him and another party in this -- on the other side in this lawsuit. And we were concerned that this document would be if Jessie told exactly how this occurred that he signed that, that it would be seen as, I guess you'd say, a release so to speak or something along that line. Jessie agreed that he would say he did not have the authority to sign anything like that whereas when he was sent to England he did have the authority, and he also, of course, had it as a senior executive in RTC. Q. What was the purpose of sending Mr. Prince to Europe? A. England. Q. Yes. MR. MOXON: Object; lack of foundation. A. To get the people, one or more of the other people who were -- who were involved in the theft of the materials,
IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA RELIGIOUS TECHNOLOGY CENTER, A California Corporation, et al., )CV 85-711 JMI (Bx) Plaintiffs, )CV 85-7197JMI (Bx) vs. ROBIN SCOTT, An Individual, et al. Defendants. RELIGIOUS TECHNOLOGY CENTER, A California Corporation, et al.,) Plaintiffs, vs. LARRY WOLLERSHEIM, An Individual, et al., Defendants. AND RELATED COUNTER-CLAIMS ORAL DEPOSITION OF VICKI J. AZNARAN AUGUST 3, 1989 ANSWERS AND DEPOSITION OF VICKI J. AZNARAN, produced as a witness on behalf of the Defendants and Counter-Claimants, taken in the above-styled and -numbered cause on the 3rd day of August, A. D.., 1989, before Lori A. Belvin, a Certified Shorthand Reporter in and for the State of Texas, in the conference room of CLARK, WEST, HELLER, BUTLER & ELLIS, 4800 Renaissance Tower, City of Dallas, County of Dallas, State of Texas, in accordance with Federal Rules of Civil Procedure.
Q. What was that policy? MR. MOXON: Move to strike. Same objection. MR. HELLER: An objection on relevancy. THE WITNESS: There was an order from Hubbard -- actually more than one. One concerning Michael Flynn and another one concerning litigation in general, which state that lawsuits can be used and should be used to deplete anyone who sues you money and harass them and get them to back off. MR. HELLER: I move to strike .It's hearsay. MR. MOXON: I join. Q. Did you have any discussions with Church of Scientology management with respect to that policy? MR. MOXON: Same objection. Lack of foundation. THE WITNESS: Yes. Q. Who did you have such discussions with? A. Pat Broeker, Ann Broeker, David Miscavige, Lyman Spurlock, Marty Rathbun, Marc Yager MR. HELLER: I'm going to move to strike. I move to strike based on relevance. MR. FAGELBAUM: I don't believe the witness has finished her answer yet. MR. HELLER: Oh, I'm sorry. THE WITNESS: Jesse Prince, Mark Ingber, Wendell Reynolds, Steve Marlowe, Gary Reisdorf, Bill Franks. That's all I can think of right now. Q. Did you ever have such discussions with Norman Starkey? MR. HELLER: Objection. Leading. MR. MOXON: Objection. I join. THE WITNESS: Not that I recall. Q. Now, the people that you did identify that you had such discussions with, did they all approve of utilizing that church policy of using litigation as a weapon? MR. MOXON: Objection. Leading MR. HELLER: Let's take a very short break. MR. FAGELBAUM: Okay. (Time Noted: 10:38 a.m.) (Short recess.) (Time Noted: 11:02 a.m.) Q. While you were president of the RTC, were you aware of any Church of Scientology policy regarding compliance with discovery requests that were issued in lawsuits? MR. HELLER: I'm going to have to object on relevance as well as lack of foundation. MR. MOXON: And ambiguity. I join in it. MR. HELLER: That's true. It's an unintelligible question. MR. MOXON: Also calls for a potentially attorney/client communication, depending on the witness' understanding of that ambiguous question. Q. I'm only asking for information that was provided to you by someone other than a lawyer? MR. MOXON: That doesn't cure the problem, Mr. Fagelbaum, as you know. Communications can be -- can and were provided to her indirectly from attorneys. MR. FAGELBAUM: As you know, Mr. Moxon, you can't immunize facts by feeding them through a lawyer. Q. You can answer. MR. MOXON: So that means you're going to ignore the privilege? THE WITNESS: Yes, there was. MR. MOXON: I move to strike. Q. What was that policy? MR. MOXON: Same objection. THE WITNESS: Discovery requests as well as orders to produce documents or something by a judge were complied with only if what was being produced would not be damaging. If it was something damaging, then it was to be fought by the attorneys or destroyed or whatever, so that it wouldn't have to be produced. MR. MOXON: I move to strike it. [break in transcript] Q. In what manner? A. Larry Wollersheim is a part of this counterclaim, is he not? Wasn't he served part of this suit; is that correct? Q. Larry Wollersheim is a defendant in this lawsuit, and he's consulted. A. In the counterclaim? Q. Not in the counterclaim. One of the lawsuits filed by the Church of Scientology. A. Okay. So he's a part of this? Q. Yes. A. Okay. I and Jesse Prince removed documents from his files that would be auditing files, and personnel and ethics files that had to do with his RPF assignment; letters from his family; letters to his family; conditions assignments; and HCO bulletins concerning upper level materials. MR. MOXON: I move to strike. MR. HELLER: Are you finished? THE WITNESS: Yes. MR. HELLER: Move to strike as completely nonresponsive. The scope of the response has nothing to do with this lawsuit. Q. What was done with those documents that were removed? A. They were destroyed. Q. By whom? MR. HELLER: By whom? I didn't hear that last question. Q. By whom? A. By me and Jesse and some probably by Alison Andrus. Q. Is that Jesse Prince? A. Yes. Q. and Alison Anders? A. Andrus, A-n-d-r-u-s. Q. What's Alison Andrus' post? A. At that time she was my communicator or secretary. Q. By whose authority did you remove these documents and destroy them? A. By whose authority? Q. Were you ordered to do that? A. I was asked to do it, yes. Q. By whom? A. Marty Rathbun. Q. Were you told at the time why that was being done. A. I believe it was because those files had been ordered to be produced in the Wollersheim case. MR. MOXON: Objection. Speculation. MR. HELLER: And it's hearsay, and, again, the whole thing should be struck because the predicate of the question was: Was it done in this case. But clearly if the fact it ever occurred, it has nothing to do with this case. MR. MOXON: I join in the motion to strike. Q. The files you were referring to, the Wollersheim files, were those his PC files? A. They were his auditing files, his personnel files, and his ethics files. David Mayo's PC files were also destroyed. MR. MOXON: I move to strike. MR. HELLER: It's nonresponsive. Q. Did David Mayo have any auditing files? A. He had a great number of them. Q. Did David Mayo have any PC files? A. That's -- I use the same, PC, auditing files, same, same deal. Q. Did David Mayo have any ethics files? A. Yes. Q. During the pendency of this litigation, were any of those files destroyed? A. The auditing files were. Q. Why were they destroyed? A. So they wouldn't be available for any production requests and have to be brought into the courtroom. Q. How do you know these documents were destroyed? MR. HELLER: I move to strike the prior answer. It has no foundation and consequently speculative. MR. MOXON: I join the motion. THE WITNESS: David Miscavige requested that Jesse Prince and I have all the auditing files, PC files, if you will, destroyed of anyone we were in litigation with or were enemies that we might end up in litigation with. MR. MOXON: I move to strike Hearsay THE WITNESS: I then put together a project to do that. Paul Kellerhaus saw to the execution of that project, and I think he destroyed two or three truckloads of files. MR. MOXON: I move to strike - speculation. Hearsay. MR. HELLER: I join. Q. Where did this document destruction take place? A. Documents were removed from Gilman Hot Springs and taken to a place that's specifically for the destruction of documents, you know, that pulps them, and I don't know the name or location of that place. I never went there. Q. How did David Miscavige communicate his request to you? A. In person verbally. Q. Did he tell you at the time why he wanted that done? MR. MOXON: I object. It calls for hearsay. MR. HELLER: Same objection. THE WITNESS: Yes, he did. Q. What did he say? MR. MOXON: Objection. Calls for hearsay. MR. HELLER: I join. THE WITNESS: He said that we didn't -- we had problems with these things having to be produced in court. We didn't want them in the courtroom and to just get rid of them all now before the problem ever came up again. MR. MOXON: I move to strike. Q. Are you familiar with L. Ron Hubbard's handwriting? A. Yes. Q. Can you recognize it? A. I believe so. Q. Are you familiar with David Mayo's handwriting? MR. HELLER: I'm going to object to the last answer for lack of foundation and this question, as well. THE WITNESS: Yes. Q. Can you recognize it? A. I believe I could. Q. Have you seen examples of L. Ron Hubbard's handwriting while you were with the Church of Scientology? A. Yes, I have. Q. Have you seen examples of David Mayo's handwriting while you were with the Church of Scientology? A. Yes.
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