SCI
page 5 / 25
senior echelons, such as RTC or ASI. The corporate structure is not a
matter of interest or concern within the cult itself. Most Scientologists
do not think of Scientology in corporate terms at all. Instead of thinking
of plaintiff Church of Scientology International ("CSI") or any other
corporate entity when Scientology is mentioned, Scientologists think of
all the organizations which apply the Hubbard Technology. Those
organizations which apply the Hubbard Technology include the
geographically located Churches of Scientoloay (e.g., Church of
Scientoloay of San Francisco, Church o' Scientology of Miami, etc.), the
geographically located missions (e.g., Church of Scientology, Mission of
Ft. Lauderdale, etc.), the management organizations (e.g., RTC and CMO
Int), the public self-improvement organizations which apply the Hubbard
Tech (e.g., WISE, Narconon, Sterling Management, etc.), the front groups
with political action agendas (e.g., Citizens Commission for Human Rights,
etc.), and the autonomous, extra-corporate organizations for
administrative and money management (e.g., Sea Org and Flag Banking
Office, etc.)
41. In short, even dedicated Scientologists would not think
of CSI when they read about "Scientology" or "Scientologists," such as in
the two paragraphs of the May 1991 Time Magazine article which are the
subject of this litigation. Additionally, even a Scientologist would not
think of CSI if he or she read something about the "church" in material
referring to Scientology. Certainly no one outside of the Scientology cult
would think of CSI when reading about "Scientology," "Scientologists," or
the "church," for the obvious reason that no one outside of Scientology is
likely to have heard of CSI as distinct from Scientoloqy as a general,
generic amalgam of organizations. Indeed, since CSI was created in late
1981 and throughout my tenure at the upper echelons of Scientology, I
found that only a small circle of Scientologists, in OSA and the senior
management such as RTC and ASI, made reference to CSI on a regular basis.
These are the persons who need to maintain the facade of corporate
separateness to the outside world so as to obtain various tax and
litigation advantages.
42. For CSI to claim that the words "Scientology,"
"Scientologist" and/or "the church, " as they appear in that portion of
the Time Magazine article which mentions Dr. Geertz and Mr. Fish man, are
"of and concerning" CSI is disingenuous in the extreme. Based on my
education, training and experience in Scientology, the words
"Scientology," "Scientologist" and "the church" as they appear in the Time
Magazine article can only be reasonably understood to refer to Scientology
generally, generically and without particular reference to any one of the
hundreds of Scientoloqy corporations that have been established for
various purposes over the years. The vast majority of the corporate
entities do not appear on the scientology command chart. The fact that
separate corporations exist on paper has no effect on the daily life of
Scientologists or the operation of Scientology. The corporate boundaries
are ignored.
43. When I was a staff member in the GO, ASI and later OSA,
it was common knowledge that the corporate structure was a contrivance
created purely because of the tactical benefits it bestowed on Scientology
for purposes of interfacing with the "wog" world. All Scientologists,
particularly Sea Org members, regard the Sea Org as an elite group of
superior beings whose job it is to get everyone else in the world into
Scientology. Meanwhile, Sea Org members and Scientologists generally
refer laughingly to unenlightened non-Scientologists as "wogs."
44. To get along with these wogs and keep them from hindering the forward
progress of Scientology, it is necessary to create the appearance that
Scientology operates by the same rules as the rest of society. A large
part of OSA's role is to maintain this facade through public relations and
legal actions. In fact, Scientologists think it is quite funny when wogs
accept the facade as real. The arrogance of Scientology's senior
management, and the contempt in which it holds any court or other wog body
which falls for the mascarade is astounding.
45. The contempt became
apparent to me in conversations I had with other staff, in comments made
by Miscavige, Norman Starkey, Lyman Spurlock, Steve Marlowe, and other
executives during staff meetings, and in instructions I was given about
how to position certain agencies and individuals when I wrote stories for
Scientology propaganda publications, including FREEDOM Magazine.
46. I was in the FREEDOM Magazine department of the public relations
division of
OSA US during the trial of Wollersheim v. Church of Scientology of
California, in 1985. At the time, OSA US was still, for corporate
purposes, part of the Church of Scientology of California ("CSC").