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emotionally traumatized and grief stricken. Vaughn Young's
effort to exploit this tragedy is malicious in and of itself,
but his innuendo and attempts to recast the incident, despite
the uncontroverted evidence as to the true cause of Ms.
Barnett's death, show the depths to which he is willing to
sink.
20. At this point, I have stated all I know of Steve Fishman
and Uwe Geertz and anything that could possibly be relevant
to this case. However, Vaughn and Stacy Young have taken it
upon themselves to introduce into this case their version of
my history with the Church. I cannot understand the relevance
of this under any circumstances, but since counsel has now
refused to take my deposition while concurrently leveling
threats, I feel I am forced to give a brief history of what
actually occurred to be in compliance with the Court's order
if such is considered relevant, and to show in proper context
how Vaughn and Stacy Young are simply incapable of
competently testifying to events they have "described" in
their declarations.
HISTORY OF FALSE ALLEGATIONS
21. False allegations leveled against me in the context of
litigation or in the media are nothing new. I raise this
point only so that the Court will understand that the sort of
scurrilous personal attack on me launched by Geertz's counsel
and Vaughn Young is the latest in a pattern of such attacks
in litigation over the years. I recognize that it is not
uncommon for leaders of organizations and movements to be
subjected to such attacks. I can only assume that I am
attacked because I am visible as the ecclesiastical leader of
the Scientology religion. I note that I am the ecclesiastical
leader of the religion, not the Church. The
mischaracterization of my role made by the editors of
Premiere magazine in an editorial note cannot convert me from
the leader of the religion to the head of the Church. Neither
can the imprecise use of language by Ted Koppel on ABC's
Nightline Show. Both of those erroneous designations are
examples of the media not understanding the nature of what I
do or the nature of my relationship to the Church. In the
case of Premiere, the same article that contained the
erroneous statement by the editors, also contained a photo
caption which I did compose and which did correctly identify
my position as "David Miscavige, Chairman of the Board of
Religious Technology Center, Holder of the Trademarks of
Dianetics and Scientology." On "Nightline," I was sitting on
live, nationwide TV, engaged in rebutting a set up video for
the show, containing 15 minutes of false and outrageous
charges about Scientology and did not deem it important to
pause from correcting those false charges so I could educate
Mr. Koppel on matters of corporate structure.
22. My name has now been dragged through the mud in this
litigation, not only by means of a mean-spirited personal
attack, but also as part of what appears to be a tactic of
hurling false and irrelevant allegations against Church of
Scientology International, the Scientology religion and its
Founder. It is unfortunate that I am now put in the position
of defending my reputation and refuting lies about my
religion that have become part of the record in this case. In
that regard, I must note that in reviewing the sordid and
outrageous allegations made about me by Geertz's counsel and
Mr. Young, I was struck by their technique of using vague,
innuendo-filled vignettes and unsubstantiated rumors in an
effort to sound authoritative. I was also struck by the way
that their declarations attempt to portray normal things as
abnormal. I can only submit that trying to make the usual
seem strange and trying to color events by innuendo are the
tools by which bigotry is crafted and prejudice is spread.
23. The personal attacks on me, as well as many other
irrelevant and malicious falsehoods that have been brought in
this case, have largely been introduced through declarations
of Robert Vaughn Young and Stacy Young and forwarded by
Geertz's lawyer, Graham Berry. The Youngs left Scientology
almost five years ago, have no personal knowledge of the
current activities of RTC, CSI, or any other part of
Scientology and, by their own admission, have no personal
knowledge of the defendants in this case. Neither Vaughn nor
Stacy Young ever worked with me or even near me during the
entire time I have been employed by RTC. They couldn't
possibly testify to any of my activities as RTC's Chairman of
the Board since 1987 because they simply were in no position
even to observe such activities. They are not experts on
anything relating to Scientology, but have apparently been
hired to file inflammatory declarations on non-issues in this
suit. The Youngs are, however, generally aware of the fact