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I, Robert Vaughn Young, declare as follows:
1. I am over 18 years of age. I am a resident of Seattle, Washington. The matters set forth herein are of my
own personal knowledge and I would be capable of testifying if called to do so.
2. Because I have over 20 years as a staff member in Scientology, most of it as an executive and as part of
the elite "inner circle," I am most familiar with this organization and its tactics. I fled with my wife
in 1989. For the last year and a half, I have served as an expert legal consultant on Scientology in several cases,
including the case of Church of Scientolgy International (CSI) v. Steve Fishman and Uwe Geertz (91-6426-HLH
[Tx] [C.D.Cal.]) where once again Scientology clogs the courts with alarming and misleading facts and blatant false
testimony in a last-ditch attempt to discredit my testimony as well as that of my wife, Stacy Brooks Young.
3. Because my wife and I have 35 years in Scientology between us, we have considerable knowledge how this organization
operates. We presented not only our experience but Scientology documents to show how Scientologists are permitted
to lie and cheat in the name of Scientology. It is their notorious "Fair Game Dodrine" that I detailed
earlier with their own writings that allows them to violate the law with an end-justifies-the-means attitude that
they are above the law, that the law must be used to harass and destroy, rather than win suits. That is why they
withdrew from this case and now why they continue to fight to harass defendant Geertz, his counsel and his experts
consultants. It is why they fanatically harass others who oppose them.
4. In the named declaration, Rinder tries to say that they met with my wife and me to "set the record straight."
Let me clarify this. For over one month, Mike Sutter of the Religious Technology Center (RTC) called me, almost
daily, pleading with me
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to meet with them saying it would be "well worth [my] while" to do so. I declined but he persisted, week
after week. He and Mike Rinder (of Plaintiff CSI) even appeared on my front lawn, tapping on my windows, trying
to meet with me, insisting that it would be worth my time, clearly implying that they wanted to pay me money. I
continued to decline to meet with them or even discuss the matter. They called my wife, badgering her with the
same story. So the idea that they met with us to give us the opportunity to "set the record straight"
is a complete fabrication. They wanted to meet with us to pay us money to change our testimony.
5. At my wife's request, we met with them in Seattle. They told us that they wanted to get declarations sealed
or removed but they had no other avenue left but us. I told them they should talk to Geertz's attorney Graham Berry.
They called him names and said there was no value in doing that I told them they should talk to defendant Geertz.
They did the same towards him, calling him "crazy." They said if we helped them to seal the recods or
get them removed, they would "help" us. When we began to balk, they gave veiled threats of the power
of the organization, how it could be used to destroy us unless we accepted their offer and made a new declaration.
They would not say what the new declaration would say or what "agreement" I would have to sign. This
went on for days so I played along with them to see what it might be.
6. I wanted to see what "agreement" they would insist on and what they wanted me to say to "set
the record straight" because Vicki and Rick Aznaran had earlier met with Sutter and Rinder and had "recanted"
their declarations and were now making ridiculous statements on behalf of Scientology. I had heard that the Aznarans
had been paid a large amunt of money to retract their testimony and to "help" Scientology Instead. Thus
I wanted to see what the Sutter and Rinder approach was and how they might buy off a witness or potential witness.
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7. During days of talking with them, it was difficult at times to even stay in the same room with them and a couple
of times the meetings were very short. I simply had to call them off because I couldn't stomach their sense of
reality. But I kept coming back because I wanted to see their offer for they had made it plain that they would
not show us anything unless they were convinced that we were "sincere" and if I walked out, they wouldn't
let me see their cards. They finally asked us to draft what we might say to "set the record straight."
Since we had no intention of making such a statement, we took a couple of days "working on it" and came
back saying we were "having trouble" with the idea and could they offer us any direction or ideas? They
finally showed us "notes" of what they wanted us to sign for $200,000.
8. Until this time, the meetings had been held at our home, except for the very first day. But I had asked that
this meeting (when they showed us their ideas and the agreement) be at their room at the Doubletree Inn for I wanted
a place to walk out of for I knew what was about to happen. And I knew that if they were in my home, they would
have refused to leave and would have continued to press the issue. They showed us what they wanted us to declare
for money. Basically they said that we had led, that we were sorry for what we had done, that Graham Berry had
put us up to all of it, that we had done it only for money, etc. In short, exactly what Rinder has now tried to
claim. There was one set for me and one for Stacy. We read each other's. It was everything I could do to hold my
temper at their sheer criminal arrogance. We had told them time and again that everything we had said was true,
that Berry had not written anything for us, etc., and now it was as if nothing had been said. I saw that they really
thought they could simply buy our testimony.
9. I knew that if I blew it then, they would not show me the "agreemente" so I said I wanted to talk
to Stacy privately. We went out and agreed to hedge more so we could see their "agreement." We went back
in and when asked what we thought, Stacy said how their points "need some editing" but they were "in
the ballpark."
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Wanting a copy of it (so I could file it in court) I asked if we could make a copy of this so we could write our
declarations. They declined.
10. I then asked to see the "agreement." They showed it to us. Unlike the earlier document, this was
a full legal paper that we could have signed right then. It said that we would no longer work on any Scientology
matters, that we would never talk about the subject publicly, that we would never write about it, that we could
not meet with other former Scientologists, etc. In other words, we were being asked to give up all of our basic
Constitutional Rights. It also said we would "help" them to get the rest of the material in the Fishman-Geertz
case removed from the records. When I saw that, I knew that was how they had hooked the Aznarans. It explained
why the Aznarans continue to file declarations: they are "helping" according to their Faustian
contract, i.e., saying whatever Scientology wants them to say.
11. When Stacy and I had read what amounted to a gag order, we went out and talked and that was when we agreed
that it was time to end the meeting. We went back in and did. Sutter and Rinder both tried to convince us to stay
and talk about it some more but we refused and went home. They were supposed to fly out that day.
12. They called us a few hours later, trying to meet with us again. We refused. They apparently flew back to
Los Angeles. And for the next week, they continued to call us, asking us to meet with them again, promising that
they would make it "even better" for us, which I assumed meant more than the $200,000. We refused to
meet with them or discuss it.
13. There are several points I want to make about these meetings. First, it was Scientology that sought the
meetings and Scientology that made the offer that we change our testimony. It was Sclentology representatives that
threatened that they would "do anything" needed to destroy our credibility and to take us out of the
case.
14. During the meetings, at one point Rinder finally confessed to me that my wife and I are under continuing
surveillance. We were sitting out on the sea wall and I was
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remarking on the private investigators following me and Rinder tried to deny it. Come on, Rinder, I said. You're
not talkiug to a newcomer! I was in there for 20 years! I know how it works! Finally, he went, "Okay, okay.
So there are PI's [private investigators] all over you."
15. I have read my wife's declaration of this date. Her account of the meetings are accurate, drawn with her
own perspective and her emotions. Like her, I stand by all of my earlier declarations, especially those that detail
how Scientology is supposed to abuse the legal system to achieve its ends. That is what they are doing here.
16. Part of Rinder's problem is that he bought our tactic on the final day when we wanted to see their proposed
declaration and the gag order. His other problem is that he has to follow orders to do everything he can to destroy
our repute and thus he must twist the facts and even lie. Then again, 1 don't know how much he even believes any
more. My conversations with him shows that he is fully in the grip of the cult, as is his family and thus he no
longer has the ability or the courage to do anything else. This is sad. That he would take the last shreds of our
friendship and use it in this way is sad. But it is also in keeping with what he bluntly told us in our home: "There
is nothing I wouldn't do to protect Scientology. Nothing."
I declare under penalty of perjury and the laws of the United States and the State of Washington that the foregoing
is true and correct.
Executed this 14th day of December, 1994, in Seattle, Washington.
Robert Vaughn Young
