Affidavit of Robert Vaughn Young

signed 10/6/99 - filed 10/7/99

From: (Rod Keller)
Newsgroups: alt.religion.scientology
Subject: Affidavit of Robert Vaughn Young, 10/6/99
Date: 12 Oct 1999 21:48:51 GMT
Message-ID: <7u0ac3$>
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Kennan Dandar
Dandar & Dandar
1009 North O'Brien Street
Tampa, FL
Tele: (813) 289-3858


ESTATE OF LISA McPHERSON, by and through the Personal
Representative, DELL LIEBREICH,




 Defendant )

Case No.: 97-01235

AFFIDAVIT OF ROBERT VAUGHN YOUNG [signed 10/6/99 - filed 10/7/99]

 I, ROBERT VAUGHN YOUNG, declare and say:

 1. I am over eighteen years of age and am a resident of the State
of Washington. This declaration is of my own personal knowledge and
if called upon to testify to the facts herein, I could and would
competently testify thereto.

 2. I have read the affidavit of Jesse Prince recently filed in
this case and am qualified to address its validity and relevance. I
was in the Scientology organization for nearly twenty-one years and
am familiar with the organizational structure he describes and its
procedures. For that reason, I have been retained by counsel for
the plaintiff as an expert consultant. I also happen to have known
Mr. Prince while in the organization.

 3. At issue in this case is the command structure of Scientology
and the issue of who might have known what or issued orders
regarding the incarceration of Lisa McPherson. The organization is
seeking to keep the controversy isolated to the Clearwater
organizations, but this is not how Scientology has ever operated. I
will explain how it operates and how a corporate "shell game" is
employed to baffle and thwart the courts and the authorities.

 4. The current corporate structure of the Scientology organization
was created (starting in 1981) to prevent the intrusion of the
courts and the authorities, by throwing up what appeared to be
distinct corporations. This structure came about after the FBI raid
of Scientology in 1977, which produced considerable evidence that
the organization had been burglarizing federal (and other) offices
as well as conducting other illegal activities. For these
activities Mary Sue Hubbard, the wife of Scientology founder L. Ron
Hubbard and ten of her executive staff were jailed. Hubbard,
himself, was named as an unindicted co-conspirator.

 5. At that time, the Scientology corporate structure had been
pretty much an afterthought, created merely to do business. The
actual structure had evolved over the years and was fairly simple
and was never effected by the incorporation of various entities
over the years. No one paid any attention to the corporate
structure. At the top of the actual structure was Hubbard with his
aides. His wife, Mary Sue, headed Scientology's Department 20 which
concerned itself with external matters, such as the media,
government licenses or inquiries, the courts and perceived or
imagined critics or "enemies." This section was known as the
"Guardian's Office" (GO).

 6. I was asked to join the Guardian's Office in 1971, because of
my PR (public relations) and media experience. (I had been working
for over two years at a Scientology franchise.) I joined the San
Francisco GO as an "Assistant Guardian for Public Relations" and
was trained at the US (national) GO in Los Angeles. My training was
not only in PR but the entire structure of the GO and how it
interfaced to the rest of the organization. When I was done about
five months later, I returned to the San Francisco GO, which was
responsible for all external matters in Northern California. I held
that position until I was promoted to the PR Bureau in the USGO in
1973, where I remained until early 1982.

 7. The GO was headed by "The Guardian" who was headquartered in
the United Kingdom. The GO initially had four bureaus, each headed
by a "Deputy Guardian" for that bureau: PR, Legal, Finance and
Intelligence. PR took care of media and public officials. Legal
took care of all legal matters, including court cases. Finance
oversaw the income of the organization. The Intelligence Bureau
dealt with internal security (not only within the GO, but for all
Scientology organizations) as well as gaining information about any
external "threats." This meant surveillance via spies, plants and

 8. A "Tech" (technical) and "Social Coordination" bureau were
later added in the early 1970's. The Tech Bureau oversaw "auditing"
(Scientology's counseling and confessional method) and the Social
Coordination Bureau coordinated the various front groups where
Hubbard was seeking to have his material accepted on non-religious
fronts, such as drug rehabilitation and study methods. These groups
represented themselves as not being affiliated with the Church of
Scientology but were being controlled by the GO to make sure they
made inroads and money.

 9. Every continent had a "Deputy Guardian" ("DG") for that
continent, with a replication of the same bureaus. Thus the US had
a DG for PR, Legal, Finance, Tech, Social Coordination and
Intelligence. Every major organization replicated the structure
again with an "Assistant Guardian" ("AG"). Thus in the US there
would be an AG San Francisco, Los Angeles, Washington, DC, Miami,
Detroit, etc. In fact, the presence of an AG's office was what
designated an organization as a "Class IV organization" (org) vs.
the franchises.

 10. Prior to the 1981 re organization, the GO had more power than
the Sea Org. The GO (from the actual Guardian and down through to
the AG's) had the power to confiscate the bank accounts and to take
control of the local organization. This was given to the GO by
Hubbard and was to be exercised if the organization was failing or
threatened, perhaps by a lawsuit.

 11. Complementing the Guardian's Office (GO) was the Sea
Organization ("Sea Org" or SO). The SO directed the day-by-day
internal affairs of the organization while the GO took care of
external affairs. In fact, Hubbard even wrote how "the two most
effective arms of Scientology" were the GO and the SO. He ran the
SO and his wife ran the GO. This was done from the ship "Apollo"
where Hubbard had been forced to take refuge, in the Mediterranean.
He assigned himself the SO rank of "Commodore." The Apollo was
known as the "Flagship" or "Flag."

 12. Between Hubbard and his immediate aides on the Apollo were
FOLOs (Flag Operations Liaison Office) which were fully staffed by
Sea Org personnel. Each continent had a FOLO, just as it had a
Deputy Guardian's office. The FOLO took orders from "Flag" and
replicated Hubbard's aide's structure there, as each GO replicated
it's higher command echelon. The purpose of the FOLO was to relay
orders from Flag and to send reports and information (to Flag).
They were the "middle management" echelon. These units were all set
up without regard to corporate structure, which was there just to
make things look legal. The paradigm that Hubbard was using was the
military structure, which was why there were ranks and echelons and
command channels. If one is to understand how the organization is
actually structured and operates, the military model is the one to

 13. Hubbard was enamoured of the military lifestyle. The
Scientology structure, the language, the types of directives and
the manner of command follow a military (in his case, naval) model.
Ranks were assigned along with uniforms and military procedure.
Many of his directives employ military language. He wrote often how
one should plan with military thinking and strategy and peppered
his directives with military language. In that vein, there was
military discipline.

 14. On the ship, Hubbard had "aides" who operated as his personal
council. They were known as "Commodore's Staff." Mary Sue was
"Commodore's Staff Guardian" or CS-G. While she (and all the
others) held Sea Org ranks, the GO itself (off the ship, in various
countries) were not Sea Org. The reason was to keep the GO away
from the SO command channels, because of the nature of the GO's
work, especially the Intelligence Bureau. It was also to keep the
GO at "arm's length" from Hubbard, should anything go wrong, which
is exactly what happened with the FBI raid of 1977, which will be
discussed later.

 15. The GO (as well as other organizations) all reported up the
command channels in a similar fashion. Each section of each bureau
made its reports as to activities for the week. This was compiled
by the AG and forwarded to the DG (the continental bureau) which
collected the reports for that area (and possibly recompiled them)
and forwarded them to The Guardian who did the same with her area
and then forwarded them to CS-G (Hubbard's wife) who reported to
Hubbard himself. This was also done for individual orders that may
have been issued by Mary Sue Hubbard or any junior. When the order
was done, a "compliance report" was sent back up the command

 16. Reports were also made on threatening situations, as soon as
they happened, e.g., a lawsuit, a bad news story, a death, or
anything that posed either a legal problem or an embarrassment.
These reports were made immediately along with a plan for
"handling" the "situation," as they were called. The situations and
on-going handlings were then reported on weekly or whenever there
was some change or development. If it involved other bureaus (such
as a lawsuit that produced media) then there was coordination
between the bureaus. A "program" (a series of steps to "handle" the
"situation" was often written and proposed for approval or issued
and had to be followed with "compliance reports" as to each step.
(This reporting method was kept in place despite reorganizational

 17. In 1977, the FBI conducted what was then the largest raid in
the history of the bureau. Their target was the Intelligence
Bureaus in DC and the US headquarters in Los Angeles. An
Intelligence Bureau agent (Michael Meisner) who had participated in
burglaries and wiretapes of federal offices had defected and
talked. With that information, the FBI conducted its raid and
walked out with hundreds of thousands of documents detailing how
Intelligence Bureau agents had infiltrated the government (as well
as private companies) and been stealing files. (There was a
considerably more that they were doing, illegally.)

 18. On the day of the raid, I was at the Los Angeles headquarters
and was named the "national spokesman" to respond to the charges
then and in the months to follow. The GO tried to denounce Meisner,
just as the leadership is eager today to denounce Jesse Prince and
me and anyone who speaks out. But their problem was that the FBI
had the incriminating documents to show that the GO Intelligence
Bureau was operating on a Hubbard-written program (code named "Snow
White," which was cited in the search warrant) and were writing
compliance reports to him and Mary Sue Hubbard. Weekly and
"situation" reports were also going to them. It was only by the
narrowest of margins that Hubbard himself was not indicted but he
was named as an unindicated co-conspirator, along with dozens of

 19. The raid and the subsequent legal threats tore the GO to
shreds. One of its primary functions had been to keep Hubbard at
"arm's length" and away from any legal threats and now the
floodgates had opened. One lawsuit after another named him because
he was not only implicated with his Snow White program but it was
clear that the entire organization was operating on his tactical
and strategic policies.

 20. With the raid, Hubbard went hiding to avoid being served.
Meanwhile, despite the screams and protestations about "religious
persecution" that the GO was issuing, Mary Sue Hubbard and the 10
named aides signed a "Stipulation of Evidence" and accepted the
charges and went to jail. With her and The Guardian and other key
executives jailed and Hubbard in hiding, elements of the Sea Org
moved in to take command. A "corporate sortout" project had already
been underway to restructure the organization to allow Hubbard to
return and take command and to give him new protection. This was
augmented by a "Special Project" headed by David Miscavige that
went to Los Angeles in 1981 to take command. Amongst their tasks,
was the secret creation of several corporations, including Author
Services, Inc. (ASI) and Religious Technology Center (RTC).

 21. In early 1982, I was invited by Miscavige to join "Special
Project" to head up the PR section. The idea was forwarded to
Hubbard who approved of my appointment in mid-February. I was then
informed that "Special Project" (and Miscavige was "Special Project
i/c" or "in-charge") was in reality ASI but we could not admit to
it yet.

 22. ASI was formed as a for-profit corporation on the guise that
it was Hubbard's "literary agency." While we had that function, our
actual function was to be Hubbard's contact point back into the
Scientology organization. (He was long gone from the ship and had
no viable command channels because he was in hiding.) We at ASI
reported to him and he issued orders to us (how this was done will
be taken up later) which we then issued down into the organization,
thus making ASI the most senior entity in the Scientology
hierarchy. This did not come easy for Hubbard was prevented from
saying that ASI was his replacement for "Flag" because that would
have defeated the entire purpose and linked him back to the
non-profit churches. So there was considerable arm-twisting and
threats and demotions as Miscavige and ASI consolidated its power
over the very Sea Org units that had been in control. (ASI was, by
the way, staffed only by Sea Org personnel. I had joined the Sea
Org earlier.)

 23. In mid-1982, ASI established itself in private offices at 6464
Sunset Boulevard with about 15 staff. Any visitor would get the
impression that we were merely Hubbard's "literary agency" since we
did have that function. While even the most prolific authors might
have one agent in a firm, Hubbard had (for starters) 15 who worked
for him and when we were asked why such an imbalance, we said it
was because he was "so prolific." The truth was that the "literary
agency" part took little time. So many were needed because ASI was
running the Scientology empire, along with his book sales and
personal finances.

 24. Because ASI was at the top of the Scientology empire, it was
often the site of meetings with various officers from different
Scientology organizations. They had come to learn that we (at ASI)
were now Hubbard's personal representatives and spoke for him so
the ASI boardroom became the site of clandestine meetings of
various corporations so Hubbard's orders could be issued. Of
course, this was all quite illegal since ASI was a for-profit
corporation and we were issuing orders to non-profit entities. We
had simply replaced the earlier structure and disregarded corporate
lines as we had always disregarded corporate lines. The difference
was that the power was no longer distributed between the GO and the
SO but held in one place: Miscavige and the ASI that he controlled.

 25. ASI was the site of meetings (often chaired by Miscavige) that
directed legal strategies, telling different corporations and their
attorneys what to do or what to sell and how much money should come
to ASI, which was then funneled into Hubbard's personal accounts.
If anyone disagreed, they were simply removed and replaced with
someone who complied.

 26. Throughout this period, Hubbard issued his orders as
"advices," rather than "orders," and attempts were made to make him
a "consultant" while he was busy doing "writing and research." In
truth, he was fully in command as much as he had been when he was
on the ship Apollo. David Miscavige was in charge of ASI and he had
assumed the title of "Chairman of the Board" (COB) of ASI so he
(and we, if necessary) could claim that he was not the Executive
Director or an officer of ASI. This was done to give him an "arm's
length" protection, just like Hubbard, to avoid any litigation. But
titles aside, there was never any question in the minds of the
Scientology hierarchy who was in charge: David Miscavige.

 27. This became known to the field in 1982 when Miscavige
organized a "Mission Holder's Conference" in San Francisco. (The
franchises had been renamed "missions" to give them a better
religious image, for the purpose of a sought-after tax exemption.)
With all of the shakeups and Hubbard being unable to appear, the
"field" (meaning the franchises) was threatening to revolt. Mission
holders (those who owned the franchises) were protesting new
demands for more money and more control being exerted over them.
Gathering staff from ASI (and one from another Sea organization),
Miscavige and his crew donned Sea Org uniforms and took over and
terrorized the Mission Holder's Conference, even expelling some of
the franchise holders on the spot and threatening to do the same to
others who protested. It was a show of brute Sea Org strength and
it was even touted in the "Sea Org Expansion News[letter]" that was
sent to all Scientologists, showing that Miscavige and the Sea Org
were now fully in control. A true and correct copy of the Sea Org
Expansion News entitled "The Sea Org Moves In" is attached hereto
as Exhibit "A." The guise, of course, was that they were
"protecting the Tech" or getting people "on source" (meaning
following Hubbard's directives) when really it was nothing more
than a consolidation of power. It worked. The dissenters were shut
up. I did not attend the meeting but I listened to the "war
stories" of Miscavige and some others from ASI who went with him
(Norman Starkey and Lyman Spurlock) when they returned to ASI,
laughing and boasting how they are terrorized this or that person
and how successful their "raid" was.

 28. In 1983, we were told that, according to some of our
intelligence sources, the IRS was considering a raid on ASI and
possible some other Scientology organizations. There was no doubt
in our minds what they would find if they got our documents, as the
FBI had done in 1977. Such documents would have shown Hubbard
running the Scientology empire via ASI and our bleeding it for
millions of dollars, most of it under the guise of "licensing
agreements" drawn up by Spurlock, all of the money going into ASI's
and then Hubbard's personal accounts. Some monies were converted to
precious metals or jewels that were couriered directly to Hubbard.
Some were couriered to overseas banks (usually in Luxumborg or
Lichtenstein) that had secret accounts in his and ASI's names.
(This allowed him to tap into them directly, should he need the
funds.) Since ASI was incorporated as a for-profit organization, we
knew that ordering non-profits to come up with incredible sums
sometimes in a matter of hours (a $25,000 "licensing fee" from just
one organization was not unusual) was all in violation of IRS laws
and it could put Hubbard and ASI at risk. So we implemented
Miscavige's orders to hide the evidence.

 29. We were ordered to go through our files and to pull all
correspondence with Hubbard that involved his or our connection to
the various Churches of Scientology. Since that had been mostly
what we had been doing for years, it was most of our files. These
documents were then gathered and moved down to an office that had
been quickly rented on the fourth floor. (We were on the ninth
floor.) When we were done, there were perhaps 20 four-drawer filing
cabinets filled with documents connecting Hubbard, ASI and the
various Scientology organizations. The room had a 24-hour guard
that rotated amongst ASI staff (about every two weeks), including
myself. We had to do our work there and then at night, we slept on
a cot. We were connected to the main ASI office by telephone and
radio, as well as TV surveillance cameras, with orders that should
anyone demand entry (such as the IRS with a search warrant) to
sound the alarm while refusing entry. We also had the home phone
numbers of our attorneys should the raid occur after hours,
refusing entry until they arrived and took action. This secret
office was maintained for a couple of months, until we were finally
told that the crisis had passed and we could return to some degree
of normalcy.

 30. At the same time that we were briefed to take action to hide
our connection to Hubbard and the Scientology "nonprofits," Other
Scientology executives were called to the ASI boardroom and given
the same briefing and told how to implement actions at their end.

 31. After this "near call," it was decided to beef up the
Religious Technology Center (RTC) to take some of the functions
from ASI, thus reducing the threats. Until then, RTC had been
junior to ASI only because the most senior organization was where
Miscavige was working. (He also had an office at Golden Era Studios
at Gilman Hot Springs, California. That was where Hubbard's orders
physically arrived, via a courier, and compliances and monies were
sent to him. Pat Broeker was the courier. He was Hubbard's closest
aide and companion at the ranch where Hubbard was hiding. No one,
not even Miscavige, knew where that was. As it turned out, if was a
few hours away.) Miscavige began to spend more time at RTC, which
was taking on the function of running Dept. 20, which was renamed
as the "Office of Special Affairs." RTC could thus be the
"enforcement" section so ASI personnel didn't have to implement
another "Mission Holder's Conference" and put Miscavige in the

 32. In 1985, an adverse court ruling in Portland, Oregon, prompted
Miscavige to show his command. He called in key Scientology
executives to the ASI offices and ordered that 100,000
Scientologists flood into Portland to protest. He ordered
organizations to charter airplanes, empty their course rooms, send
their staff and do anything to meet that quota. (The actual number
turned out to be more like 5,000, which was still impressive.) I
was sent from ASI to take command of the PR aspects of the massive
protest. (Except for a meeting with the editorial board of the
local newspaper and then giving some quotes to the New York Times
and the St. Petersburg Press, I kept a low profile, using my staff
to coordinate and implement actions.) We all represented ourselves
as "individual Scientologists" when really the entire event was
strongly coordinated and directed by Sea Org personnel reporting
directly to Miscavige, who came several times to see how it was

 33. When Hubbard died in 1986, I was one of a ten-person
contingent (it included attorneys and was headed by Miscavige) who
were rushed to the ranch that night. (My task was merely to take PR
control of the area, should it be needed.) It was there that the
story how Hubbard had "moved on to his next level of research" was
concocted for the announcement to Scientologists in Los Angeles. I
stayed on at the ranch and got to know Pat Broeker. When a power
struggle ensued between Broeker and Miscavige and Miscavige won,
and I was sent to a Scientology "rehabilitation" camp for 16 months
as part of the purge of people loyal to Broeker. Miscavige declared
(using his Sea Org rank) that a "final message" from Hubbard that
put Broeker in command was a forgery. (No other "final message" was
ever produced, which would have been quite unlike Hubbard to not
leave one.) Miscavige was now in full control. I "graduated" from
the camp as "rehabilitated" and returned to ASI in 1988. By that
time, Miscavige had moved fully to RTC which was now in control of
ASI and every other Scientology organization, because Miscavige was
running RTC. I fled in 1989.

 34. In my nearly 21 years in various Scientology organizations and
echelon, from when Hubbard was in charge to after he was dead, the
basic structure and operation of the organization never really
changed all that much. The manner in which orders were issued or
situations reported remained on a military model. Whether the
orders came from Hubbard or Miscavige, the manner that they were
issued and enforced never changed even when the organization name
(the GO or RTC or ASI) changed. Nor was compliance and reporting
ever changed. Corporate entities were merely ways of giving the
impression that there was a different structure when there wasn't
one. We didn't pay attention to corporate structure before the 1977
raid and we didn't pay attention to it after the reorganization of
1980-81. The only difference was the power of the Sea Org and the
Guardian's Office was consolidated. The task of executives remained
the same: forward orders from "command" while ensuring that the
senior not implicated if anything goes wrong. If this meant hiding
or destroying documents or shifting personnel or even lying, it was
done. That is an unchanging pattern that the organization developed
with Hubbard and then Miscavige. Just as an army protects its
general or command central, so does Scientology (working on the
military model) protect those who are in command.

 35. I have seen the protests of the higher level organization that
they knew nothing of Lisa McPherson, from the time of her initial
automobile accident to her isolation to her death. To the
uninitiated, this seems plausible. To those who know how the
organization works, this is ludicrous. That excuse has been
conjured up by the organization for every flap to protect the
hierarchy. Sea Org members (as it was true for GO members) deem it
their duty to "take responsibility" and let the buck end with them
when "senior command" is threatened. For example, when the 11
Guardian Office executives were indicted after the 1977 raid, not
one of them cooperated with the authorities, even for a reduced
sentence. They would rather go to jail than to implicate Hubbard or
even Mary Sue, regardless of the documented evidence. Only people
of that mind are allowed at that echelon and that is what is being
presented to this court. Only the most fanatically loyal who are
willing to sacrifice themselves to protect the courts or the
authorities from reaching "command" are brought forward. Those who
say otherwise (such as myself or Jesse Prince) are denounced as
viciously as we denounced Michael Meisner in 1977, trying to
convince the courts and the media that he was a low-level, lying
clerk who was in it for personal gain. That is the reaction of any
group who seeks to hide the facts and protect its leadership. Like
Mafia leaders, suddenly they are just little, innocent businessmen
with families being persecuted by bigoted law enforcement agencies.
Those who claim to have inside knowledge are denounced as frauds.
But those of us who do speak out have more than our own experiences
to show the courts and the authorities. We have the long,
unchanging pattern of behavior of this organization not only in the
US but in other countries where it has been documented that the
organization will lie and cheat and defraud the government and the
courts to protect itself.

 36. Thus based on my nearly 21 years experience in doing just that
(my task was to manipulate the media and the membership), I fully
concur with Jesse Prince's conclusion that there is no way that the
highest echelon of this organization did not know about Lisa
McPherson. From the time that she took off her clothes in the
street, she presented herself as at least a PR danger, if not a
legal one. Those reports are instantly sent to the top of the
command channel with recommended handlings and the lowest echelon
knows that it cannot admit to it because it would involve
"command." They must "make it their own" (to quote a Scientology
communications drill called TR1) even if it wasn't theirs to begin
with. Every staff member learns this very early on. "Make it your
own" means that it is yours, even if it isn't. Thus the staff
member who gets an order from Miscavige must "make it their own"
which means that if asked whose idea it is, the staff member is
capable of saying in all honestly, "It was my idea," even if it
wasn't. That is TR-1, one of the most basic instincts drilled into
every staff member for years.

 37. Jesse Prince also knows how this organization operates,
despite their protests or attacks on him. I knew him when he held
his positions and what he described in his declaration is either
true by my personal knowledge or fully consistent with what I know
about this organization and its policies and its history. I can
find nothing in his declaration that contravenes that experience. I
also know that for telling the authorities what he has that he will
be subjected to intense attacks. It is in the nature of the
organization. It can do nothing else but deny and attack. These are
Hubbard's policies (collectively known as "Fair Game") and they do
not change, which is why the organization does not change. It

 38. Like Mr. Prince, I too have seen records kept on Lisa
McPherson and I concur that she was held against her will with the
knowledge and consent and direct orders of Scientology executives
that would come directly from the Religious Technology Center
(RTC.) RTC would have been the first to be told and be kept
updated, as Mr. Prince states. The saddest part is that the
organization demands such information not for the benefit of the
person involved or hurt but to protect the image of the
organization. The Scientology maxim is, "The greatest good for the
greatest number." When it comes to protecting the organization
itself, that determines the morality of the act. It is "the end
justifies the means." That is why she was isolated and that is why
there are records missing. The organization and its "command" must
be protected at all costs. That is why Lisa McPherson died.

 39. In conclusion, let me say that any attempt to say that these
various Scientology organizations are distinct and separate is like
saying the kidneys and lungs are separate organs of the body. They
are but they are connected and controlled by a blood, endocrine and
nervous system and in Scientology that nexus is the Sea Org. It
connects and commands the entire Scientology empire and has since
Miscavige took control in 1982.

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


[signed 10/6/99 - filed 10/7/99]

Life and Death of Lisa McPherson