DECLARATION OF MICHAEL RINDER
 
I, MICHAEL RINDER, declare as follows: 

1. I am over 18 years of age and a resident of the State of California. I am a director of the Church of Scientology International ('CSI" or "the Church”), the mother church of the Scientology religion. By virtue of my position, I am familiar with the Church's legal affairs, and I have personal knowledge of the matters set forth in this declaration. If I were called upon to do so, I could and would competently testify thereto.  
 2. In July 1994, another Church staff member, Michael 
and I spent several days in Seattle, Washington, meeting apostate Scientologists Stacy and Robert Vaughn Young. They left the Church in 1989, and approximately four years they appeared as witnesses for hire in litigation against Churches of Scientology, Scientologists or businesses owned by Scientologists. Among the attorneys who hired and paid the Youngs for their testimony was Graham E. Berry of the Lewis, D'Amato firm, who used their purchased testimony many times in Church of Scientology International v. Fishman and Geertz, No. 91-6426-HLH (TX) (C.D.Cal.).  
 3. The Youngs' activities had resulted in the Church spending considerable time and energy to correct the falsehoods they had injected into these lawsuits. So we travelled to Seattle to meet with the Youngs in the hope that direct communication with them might lead them to correct their false statements and cease their campaign against the Church. We explained this purpose for our visit when we met with the Youngs first on July 9, 1994.  We told them that recently several other   litigation opponents of the Church had stated that they  had  wished we had been in direct communication earlier and it may  have prevented years of litigation and disputes. We told the Youngs that we sought to avoid that same situation from occurring with them.  
 4. We were direct and forthright with explaining why we wanted to meet with them. At the beginning of our discussion, both of the Youngs stated that they did not enjoy manipulating the facts to attack and embarrass their former religion, but that economic hardship had compelled them to embark upon that course. At the end, however, it was clear that “economic hardship" was simply a euphemism for amoral greed. Their professed guilt about the dishonest quality of their sworn statements could not overpower their craving for money. Thus, we resolved nothing in those talks. 
5. Stacy told us that she believed that it would be in everyone's best interest for the conflict between the Youngs and the Church to end. It was apparent that the reason they were talking to us was because they found it emotionally distressing to be involved in an occupation that required them to figure out how to manipulate and distort facts for use in litigation. Stacy said she could not stand living a lie and wanted out,  and that Vaughn also "hated" being involved in the litigation. We explained that we simply wanted to resolve matters, get the record set straight, and the Church and the Youngs could get on with their respective lives. They agreed that this was a desirable objective. 
6. Stacy recounted the story of what had happened to them 
 
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and how they had come to get involved with writing declarations in the first place. She said that neither she nor Vaughn were good with money and that after leaving the Church in 1989, they had run up tens of thousands of dollars in debts. She said that they first tried to live off various family members while Vaughn attempted to establish himself as a writer. The family eventually balked at that, and the Youngs were on their own. She said they used up their savings and over-extended their credit cards in an unsuccessful attempt to create a computerized, desk-top publishing business. Stacy said that she and Vaughn both wanted to work as writers and eventually took a series of jobs in several small newspapers in the San Diego and Newport Beach areas. These jobs did not pay well, and they were heavily in debt when the last paper for which they worked went bankrupt. Their financial situation worsened as Vaughn was unemployed and refused to take on any employment other than as a writer. Stacy earned the only income, working for an insurance sales firm which she said she hated.  
 7. Stacy told us that their financial situation deteriorated to the point that she had threatened Vaughn with divorce if he did not get a job. Vaughn then got a job driving a taxi cab. He was unable to continue this however, when, after running out of gas, he attempted to push his vehicle, lost control of it, and injured his leg. Additionally, Stacy said she had suffered a tubal pregnancy, necessitating an operation. Between the medical bills and the lack of a steady income source, Stacy explained that they ended up more than $50,000 in debt, It was in those 
circumstances that the Youngs turned to trafficking in 
 
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anti-Scientology allegations as a means of making money. 
8. Stacy said that in early 1993, at the depth of their financial crisis, a British anti-Scientologist, Jon Atack, introduced them to an active anti-religionist in the Los Angeles area named Priscilla Coates. It was through Coates and her attorney, Daniel Leipold, that the Youngs connected up with Graham Berry, for whom they eventually became paid ‘consultants.’  

9. At one point in our conversations, Stacy broke into tears and said that she and her husband only began consulting with and selling declarations to Graham Berry because she and Vaughn were so desperate for money. Stacy said she had been willing to say under oath whatever Berry wanted her to say if it would result in getting paid, as she could not face continuing to live under the financial pressure she and Vaughn were suffering. Stacy said that she had made a vow, like Scarlet O'Hara in Erie With The Wind, that no matter what it took, she would never be poor again. Vaughn explained that it was “a great way to utilize twenty years that I was trying to avoid on my resune, and that he..could work one afternoon and make what would be a weekly salary in any other job. 
10. In the course of the discussions, both Mike Sutter and I brought 
up how we could not understand how they could tell so many lies in the declarations they had filed,. especially those in the Fishman case. 
Neither denied that this was what they had done, but explained that in order to be able to survive, they provided testimony requested by the attorneys, and that they had to write what was wanted or they would not get paid. Stacy said it was “obvious” they would not be paid to write things that 

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 would be helpful to the Church.  
 11. We challenged them to explain how they could justify 
lying as a way of life, and they told us that what they had mostly done was twist facts and used "creative writing" and innuendo to paint a picture that was negative to the Church. They explained that they had tried to avoid explicitly lying about facts so they could not be accused of perjury. Vaughn especially seemed proud of this, and said that he was a writer by profession, which is why he was so good at preparing declarations and why he was paid so well. He claimed that unlike the Fishman case declarations of Andre Tabayoyon, Steve Fishman and Garry Scarff, where the lies and inconsistencies were obvious, his declarations were worded in such a way as to make them much more difficult to discredit. Nothing he said ever disavowed his explanation of how he manipulated facts to create false illusions.  
 12. Both of the Youngs readily agreed that they could easily 
set the record straight by writing new declarations which would 
”clarify” the statements they had made previously. Vaughn said 
that he did not want to write anything that would be a "direct 
contradiction” to what he had written earlier, but this was 
simply a matter of "interpreting" things differently. He said he 
intended to make his career as a writer and would need 
"credibility” in order to obtain future jobs, so wanted to do 
this "properly."  
 13. Stacy said that by writing such declarations they would 
"burn their bridges" with the anti-Scientology camp. She went. on 
to say that this would not be difficult to do as they did not  
  
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 want to be involved in anti-Scientology litigation matters any 
longer and in fact, they were "between jobs" at the time, so it 
was an opportune moment to bring this entire episode in their 
lives to an end.  
 14. Stacy and Vaughn spoke extensively about matters they 
had put in earlier declarations during the course of several days 
of meetings. They explained their true views and talked candidly 
about many matters. For example, in the Fishman case, Graham 
Berry wanted them to execute declarations to support the 
contention that Steven Fishman was an experienced Scientologist. 
Both Youngs said that this presented a problem as the very data 
which Berry had given them to orient them to the “facts” of the 
case proved that Fishman was a fraud. Upon reading Fishman's 
unpublished manuscript, The Lonesome Sauirrel, they told us they 
had the same reaction: That Fishman was psychotic and that his 
so-called experiences in Scientology described in his manuscript 
never occurred. Stacy specifically mentioned by way of example 
that the manuscript discusses meetings and activities allegedly 
done by a Church staff member, Lyman Spurlock. Stacy said that 
she knew that such incidents could not have occurred; that Lyman 
Spurlock would never have done the actions Fishman alleged and 
that Fishman's description simply does not match Mr. Spurlock. 
Further, she knew that the meetings described between Fishman and 
Church officials simply could not conceivably have occurred. She 
said the whole manuscript was ridiculous, a fabrication. Vaughn 
said he could not even finish the manuscript, it was so bad.  

 15. Similarly, they both described watching a video of 
Fishman describing the operation of a Hubbard Electrometer  

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(E-meter). The video was supposed to demonstrate Fishman's 
competence and knowledge in Scientology. The Youngs said Fishman 
explained that the meter's "sensitivity knob" was used to keep 
the meter's needle on its dial, and that this was such a 
ridiculous mistake that they burst out laughing and knew with 
certainty that Fishman was not an experienced, Scientology 
auditor.  
 16. Stacy also pointed out that they both knew that 
Fishman's claims of having completed the Saint Hill Special 
Briefing Course -- an advanced course in Scientology counseling -- was a lie, that it was physically impossible for anyone to complete the course in the six weeks Fishman claimed. In fact, after recounting these facts, both Vaughn and Stacy stated that they knew that Fishman and his co-defendant, Uwe Geertz, were both crazy and that their allegations about Scientology were false.  
 17. Stacy said she had to come up with a way of supporting 
Fishman's claims for Berry because she needed the money. She 
said she knew that she could not state in a declaration that 
Fishman was a long-term Scientologist as that would be, in her 
words, “completely untrue." Instead, she said that she played 
with words and concepts so that she could, without directly 
lying, construct a picture that would create the impression that 
Fishman knew what he was saying about Scientology. She said she 
even knew that Fishman was ineligible for Church services due to 
an extensive history of psychological treatment, and to solve 
that she had created a way of explaining his "involvements” by 
alleging that "the Church had negligently allowed Fishman to read  
 
church scripture," and that this “resulted in Fishman's mental 
state deteriorating." She said that she knew his mental state 
was not good, and that he knew some Scientology words and terms 
(though he usually misused them) and therefore this was a 
"credible” scenario that suited the attorney.  
 18. Stacy said that her theory was used to support the 
contention that Fishman had been “exposed” to upper level Church 
scriptures, even though he had never attained that level in the 
Church and the materials are kept strictly confidential in the 
Church.  
 19. She went on to explain that her distortions had extended 
to allegations about brainwashing, and that here she had quoted 
completely out of context from the writings of L. Ron Hubbard.  
She gave this as a classic example of how one can distort the facts. She said that it was ironic that while she was in the Church she had compiled a pack of materials written by L. Ron Hubbard where he had alerted people to the existence and dangers of mind control techniques through the use of pain, drugs and hypnosis. She had created the pack to rebut Falsehoods presented by Bent Corydon in his case against the Church and that it showed that Mr. Hubbard was in the forefront of the condemnation of brainwashing techniques and had developed the first techniques to counteract it. For the Fishman case, however, she explained that she took this very same material and pulled selected quotes out of context to give her declaration a 180-degree reverse “spin.” Her Fishman declaration then gave the false impression that Scientology techniques were mind control when, in fact, they are just the opposite.

 20. One of the falsehoods I brought up with Vaughn Young was 
his allegation that David Miscavige was involved in the death of 
his mother-in-law, and that Vaughn had stated that it was a murder.
 He said that "if you read my statements exactly ('Mr. 
Miscavige's behavior was overlooked in the investigation of the death of his mother-in-law... She died... from three shots to the chest and to the temple from a .22 rifle.') you'll see I didn't say David Miscavige murdered his mother-in-law." I told him that this was the impression he created and he replied “Exactly.” He said that he could never have directly made the accusation as it wasn’t true but he crafted his declaration to create that impression.
 
 21. Young said he had done the same thing when he attempted 
to create the impression that the Church was involved in the death of Steven Fishman's wife, even though he knew this was simply incredible. However, he explained that they needed statements that would support the defense’s position, so he worked with the material he had.  

 22. This is what led to him supporting Fishman's contention that he had been ordered to commit suicide or to "do an ‘end of cycle.’”  Young explained that the three words did have a meaning in Scientology, and even though he knew that Fishman falsely claimed the term was Scientology slang for suicide or murder, and that this in fact was further evidence that Fishman was not a Scientologist, he had enough to go on to fashion a statement for a declaration that would be interpreted to support Fishman's claims.
 
 23. Vaughn also said that the Church could be poisoned by  
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 throwing around numerous allegations about the Church ordering 
people to commit suicide or murder. This was especially difficult to respond to when the events were so old they could not be objectively verified, and where nc allegation of wrongdoing had been made at the time, so it would be too time consuming to attempt to correct them all.  
 24. Vaughn had further expanded on this theory when he stated that one cannot simply leave Scientology -- i.e., cease being a member of the Church -- because a Church policy states that it is better that a person "be dead" than to not be a dedicated Scientologist. Vaughn said he knew the quote was not meant to be taken literally, but again, it was something that as written he could not be charged with perjury for, yet he created a completely wrong impression. Ironically, both of them 
acknowledged that except for assistance from the Church to help them retrieve their belongings after they abruptly left the Church without notice, they had had no contact with any Scientologists from shortly after they left the Church until they began to file declarations against the Church, a period of more than three years.  
 25. Stacy also talked about her assertions that the upper 
level scriptures of the Church were in the public domain. She was challenged on this and admitted that she knew that the Church took great care to maintain the confidentiality of these scriptures as a matter of religious faith and actively would seek to prevent the improper distribution and exposure of these materials. She said she was willing to withdraw her declaration  on this matter, as she knew how important this was to  
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 Scientologists.  
 26. After Vaughn and Stacy had opened up and talked a great deal about what they had been doing in their anti-Scientology litigation, they also discussed some of the other witnesses who had been hired by Graham Berry to attack the Church. Their descriptions match my personal knowledge and made it obvious that these are not credible witnesses. Stacy specifically mentioned Gerry Armstrong and Larry Wollersheim, both of whom were also paid witnesses for Berry. Stacy told me that Armstrong is psychotic and lives in a delusory world in which he holds conversations with God. She said that Wollersheim is as crazy as 
Armstrong is.  
 27. They also talked about Andre Tabayoyon. Stacy was 
especially upset about him, and described an incident in which 
she and others were at the offices of Berry's law firm. 
Tabayoyon was upset that he had not been paid and began yelling in a  wild and uncontrolled manner and threatening to kill people. 
When Stacy told him to stop shouting and to act more professionally, he began to make threatening remarks to her. His yelling drew the attention of employees of the law firm who came to see what was going on. When they arrived in the conference room where Stacy and Tabayoyon were located, Tabayoyon abruptly stormed out of the office. Stacy also told me that Tabayoyon mistreated his wife, Mary, and that he regarded her as a slave. Both Stacy and Vaughn found this conduct very disturbing, and they said they would find excuses not to have to socialize with the Tabayoyons because they were not good company and had nothing worthwhile to say.  
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28. The Youngs said they would write declarations to set the record straight on points described above along with others.  
  
 However, they said that as they would no longer have a source of 
income they needed help in getting on their feet. They wanted to 
get into the environmental or animal rights fields. They wanted 
nothing to do with litigation any longer, and even said that once 
they got established they might be able to help forward the Church's environmental campaigns and programs. We said we would try to help find them jobs and might be able to assist them with a small loan or possibly even purchase of the rights to future writings to help them while they embarked on a new career.  
 29. We suggested that while we made inquiries about possible 
jobs for them, they should put together declarations which would 
rectify the falsehoods and misimpressions thay had created. They 
agreed that this would be easy for them to do.  
 30. Mike Sutter and I returned to Los Angeles and contacted 
Church staff and professionals who had connections in the environmental and animal rights areas and lined up several 
possible jobs for Vaughn and Stacy.  
 31. We returned to Seattle some days later to give Vaughn 
and Stacy the good news about the jobs we had found. We thought 
they wanted to resolve their differences with the Church and 
settle down to an honest living and that this would come as 
welcome news. It became clear almost immediately that they were 
not interested.  
 32. They said they had not written draft declarations, and 
in fact, had been thinking about it and had decided that they 
wanted the Church to pay them $540,000 -- enough money to live 

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 without having to work for five years. They claimed that if they 
were to set the record straight it would end their careers as 
anti-Scientology consultants and that this was a lot of future income to give up. They made no mention of the morality of their position, and when challenged on it, merely responded that this was just a matter of money, not of right and wrong nor truth or fact. They would do and say whatever would make them money. 
33. In an attempt to make their ridiculous demand sound reasonable, they stated that even for $540,000 they were not sure that they would write the declarations to correct the record as they had earlier agreed. They said that since we had left they had been in communication with some people they refused to identify, and had been given "legal advice' that if they were to 
correct the declarations they had filed, the insurance company could sue them for "breach of contract."  
 34. It should be made clear here that neither of the Youngs has any claim against the Church and both have stated such when asked this question directly in deposition. I brought this up to the Youngs to make clear to them that they couldn't even have a reason for thinking we owed them money. I told them that if they wanted peace they had to voluntarily provide truthful declarations to correct their lies and that we would not accede to their extortionate demand. While admitting that we didn't owe 
them anything for what they had done while in the Church, their answer was simple. It was not a moral question. They earned a good living distorting facts against Scientology, and for them to stop, we should pay up. Vaughn Young summed up their position by claiming that the more of an asshole one is the more one is  
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 worth in this game.  
 35. I told Vaughn that I could not believe he was demanding 
that the Church pay him an enormous amount of money SO he would not have to work at all. He became very indignant at this and threatened that he would "do more" and that we would wish that we had "paid him now rather than have to deal with what he would do to us in the future."  
 36. Thus the Youngs ultimately refused to put down on paper 
what they had so willingly told us in person, because we would not pay them for the truth like they had been paid to lie.  

 37. The Youngs never retracted their admissions that their publicly filed declarations created false impressions and contained lies. In fact, they even said they would now have difficulty carrying on with their "profession" as witnesses due to what they had told us.  
 38. In summary, the facts are as follows: When we met with them alone, the Youngs candidly admitted what we have been telling the court all along, they have been lying and intentionally distorting facts. They do it knowingly and will readily admit to it outside the presence of an attorney or Court Reporter. They feel comfortable in making these allegations because they know that unfounded accusations against Scientology are given much greater deference in the Courts than are false and degrading accusations made about others. They saw this themselves when they were in the Church, and now they exploit it for cash. 
 
 39. No doubt they will now try to deny the facts laid out in 
this declaration, but when they do so, their motivation should be 
 
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 remembered. They still have their jobs as anti-Scientology 
witnesses to protect.  

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

 Executed this 27th day of October 1994 at Los Angeles, California.  

Signed,

Mike Rinder