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that, through the years, attempts to malign me personally and
create a false picture of the Church with sensational
allegations have been the stock-in-trade of litigants
opposing the Church and the former Scientologists upon whom
counsel rely to swear to matters they do not know and to make
false allegations for which they have no basis. I believe
that the Youngs' awareness of that litigation ploy explains
their involvement in this case and defines the role they are
playing.
24. For example, part of Vaughn Young's attack is his
complete mischaracterization of my role in the dismantling
and permanent disbanding of the Guardian's Office ("GO"). The
Guardian's Office and the fallout that resulted from it is
particularly significant as it is the linchpin of a
litigation tactic that has been employed for years against me
and the Church. Vaughn Young is simply revisiting the same
path trod by others before, but as this has now been injected
into the case I feel it important to address this matter,
even if necessarily briefly.
25. Young would have the Court believe that I was an
opportunist, using the jailing of Mary Sue Hubbard as a means
of taking control of the GO, while leaving its criminally
tainted substance unchanged and operating under a different
name. This is a complete perversion of the true events, as
set forth below. I would not have expected Young to know all
of the details of how I directed the disbanding of the GO and
the permanent expulsion of its leaders and other wrongdoers,
as he was in a low level position in the GO at the time.
However, he knows that when the staff of other Church units
completely took over the GO offices and put an end to it as
an organization, literally hundreds of his fellow GO staff
members were dismissed, expelled from the religion, and
forever barred from ever holding any position in any Church
organization again.
DISBAND OF THE GUARDIAN OFFICE
26. To understand the magnitude of this upheaval, a
description of the history, power and authority of the GO is
vital. The GO was established in March of 1966 because legal
and other external facing matters were consuming the time and
resources of Churches of Scientology. In particular, Church
leaders were being distracted from their primary functions of
ministering to the spiritual needs of their expanding
religious communities and building their organizations.
During the 1970s the GO operated as an entirely autonomous
organization unchecked and unsupervised by the ecclesiastical
management of the Church. The power of the GO was absolute.
Unless a member of the GO, one could not even enter their
locked offices. They held all corporate directorships. They
and they alone dealt with legal affairs of the Church. The GO
operated in complete secrecy, and conducted its affairs
independently of the Church and its management and personnel.
Any attempt to find out their affairs, by Church
ecclesiastical staff or any Scientologist, was met with the
same "treatment" they handed out to others. For instance, GO
staff carried out illegal programs, such as the infiltration
of government offices for which eleven members of the GO were
prosecuted and convicted. There were also instances in which
GO staff used unscrupulous means to deal with people they
perceived as enemies of the Church -- means that were
completely against Scientology tenets and policy, not to
mention the law.
27. In 1981, a Church investigation was begun into the
activities of the GO. That investigation was prompted by the
existence of a number of civil law suits which had been filed
at that time against Church of Scientology of California and
Mr. Hubbard, and which the GO was supposed to be responsible
for handling. Not only was the GO not handling these suits,
the GO, and particularly Mary Sue Hubbard, even refused to
answer our questions about the suits because they viewed
themselves answerable only to persons within the GO. My
involvement in the purge of the GO arose from my position at
the time, Action Chief CMO International. My duties included
directing Church missionaires conducting the investigation of
the GO to determine the reasons for the GO's ineffectiveness
and why the GO had departed from its original purpose.
28. Our attempts to get information were thwarted by Mary Sue
Hubbard. She informed us that she did not appreciate our
investigation of the GO and that if one were needed she would
do it. In March 1981 she cut all of our communication lines
to the GO, except through herself. It must be noted that Mary
Sue Hubbard believed her position as Controller and as the
"Founder's wife" to be unassailable and beyond reproach by
anyone but Mr. Hubbard -- who was not around at the time, a
fact that she was well aware of. This, plus her absolute