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andredec
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title: "Court Declaration — andredec"
source: https://www.cs.cmu.edu/~dst/Fishman/Declaration/andredec.txt
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---
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NOTES: DECLARATION OF ANDRE TABAYOYON RE: ACTIVITIES AT GOLDEN ERA,
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From: CTM@CORNELLC.cit.cornell.edu
Date: Fri, 2 Sep 1994 20:09:21 -0400
((Editor's comments in double parenthesis - Homer))
ANDRE TABAYOYON AFFIDAVIT
CD - 13
19 August 1994
Copyright (C) 1994 Andre Tabayoyon
Redistribution rights granted for non commercial purposes.
GRAHAM E. BERRY, State Bar No. 128503
GORDON J. CALHOUN, State Bar No. 84509
LEWIS, D'AMATO, BRISBOIS & BISGAARD
221 N. Figueroa Street, Suite 1200
Los Angeles, California 90012
Telephone: (213) 250-1800
Attorneys for Defendants
UWE GEERTZ, PH.D.
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
CHURCH OF SCIENTOLOGY Case No. CV 91 6426 HLH (Tx)
INTERNATIONAL, a California
non-profit religious DECLARATION OF ANDRE
organization, TABAYOYON RE: MOTION FOR
COSTS
Plaintiff,
Date: APRIL 4, 1994
VS. Time: 10:00 a.m.
Courtroom: 7
STEVEN FISH AND UWE GEERTZ,
Defendants.
DECLARATION OF ANDRE TABAYOYON
I, ANDRE TABAYOYON, declare as follows:
INTRODUCTION
1. I am over the age of 18 years.
2. I have been retained as an expert consultant and expert witness
by Dr. Geertz's counsel in the case captioned Church cf Scientology
International v. Steven Fishman and Uwe Geertz, No. CV 91-6426-HLH (Tx)
currently pending in the United States District Court, Central District
of California. The statements herein are of my own personal knowledge
or reasonably based on information and belief, and if called upon as a
witness, I can testify competently thereto.
3. This declaration is submitted in support of defendant Dr. Uwe
Geertz's motion for costs, attorneys' fees and sanctions.
4. In preparation for this declaration, inter alia, read the
declarations submitted by David Miscavige ("Miscavige") , Marc Yeager,
Ray Mithoff, Guillaume LeServe and Norman Starkey in an effort to
persuade this Court that CSI has complied with the orders of the
Magistrate Judge and this Court to attend depositions.
5. Since being designated as an expert witness herein, I have
become aware of the presence of myself being under surveillance. On a
trip to Arizona I was followed by a van and a car. In Mesa, Arizona I
was followed to breakfast and the person was even aware that we knew he
was watching us. While in Newport Beach we were followed to and from
Mr. Berry's office daily. I am currently in my home and there is a blue
late model pontiac waiting to follow me wherever I go.
PERSONAL SCIENTOLOGY BACKGROUND
6. Before I became a Scientologist, I enlisted in the United States
Marine Corps. I served one tour of duty in Vietnam. I was in the
infantry and assigned as a scout to secure sites, often behind enemy
lines, from which Marine snipers would eliminate targets using specially
constructed sniper rifles. It was also my responsibility to get the
highly trained and therefore very valuable snipers back safely to allied
lines. Because of the high likelihood that I would be operating for
extended periods of time behind enemy lines, I received escape and
evasion training both in the Philippines and in Vietnam. In addition to
escape and evasion training, I also received instruction on how to
resist anticipated brainwashing and coercive persuasion techniques