Gerry Armstrong--Declaration Mike Rinder 10-27-1994

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[CT 7417]

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

with apostate Scientologists Stacy and Robert Vaughn Young. The

Youngs left the Church in 1989, and approximately four years

later, in 1993, 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

[CT 7418]

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

[CT 7419]

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

[CT 7420]

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 Gone 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 resume," 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

[CT 7421]

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

[CT 7422]

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 Squirrel, 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

[CT 7423]

(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 "involvement" by

alleging that "the Church had negligently allowed Fishman to read

[CT 7424]

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.

[CT 7425]

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

[CT 7426]

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 no allegation of

wrongdoing had been made at the time, so it would be too tim

e 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

[CT 7427]

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

continually 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.

[CT 7428]

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

[CT 7429]

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

[CT 7430]

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

[CT 7431]

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]
Michael Rinder
MICHAEL RINDER

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