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stacyii
---
title: "Court Declaration — stacyii"
source: https://www.cs.cmu.edu/~dst/Fishman/Declaration/stacyii.txt
retrieved: 2026-06-28
---
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Version: 5.5 -- Copyright (c) 1991/92, Anastasios Kotsikonas
From: CTM@cornellc.cit.cornell.edu
Subject: CD-21 Stacy Brooks Young Affidavit II
Date: Thu, 13 Oct 1994 17:37:57 -0400
Lines: 383
((Editor's comments in double parenthesis - Homer))
STACY BROOKS YOUNG AFFIDAVIT II
CD - 21
13 October 1994
Copyright (C) 1994 Stacy Brooks Young
Redistribution rights granted for non commercial purposes.
CHURCH OF SCIENTOLOGY
INTERNATIONAL, a California
non-profit religious
organization,
Plaintiff,
STEVEN FISHMAN AND UWE GEERTZ,
Defendants
Case No. CV 91 6426 HLH (Tx)
DECLARATION OF STACY BROOKS
YOUNG IN SUPPORT OF DEFENDANT
DR. GEERTZ'S (1) OPPOSITION
TO CSI'S MOTION FOR
CONTINUATION OF
CONFIDENTIALITY ORDER ENTERED
SEPTEMBER 22, 1993; (2)
OPPOSITION TO CSI'S MOTION TO
SEAL RE-CREATED VERSIONS OF
PLAINTIFF'S CONFIDENTIAL
UPPER LEVEL SCRIPTURES, AND
(3) OPPOSITION TO CSI'S
MOTION FOR ATTORNEY'S FEES,
COSTS AND SANCTIONS UNDER 29
U.S.C. ' 1927, ETC.
Date: April 4, 1994
Time: 10:00 AM.
Courtroom: 7
DECLARATION OF STACY BROOKS YOUNG
I, Stacy Brooks Young, declare as follows:
1. I am over the age of 18 years.
2. I have been retained as an expert consultant and expert witness
by Dr. Uwe Geertz's counsel in the case captioned Church of Scientology
International v. Steven Fishman and Uwe Geertz #CV-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 upon 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.
Geertz's Opposition to CSI's Motion for Continuation of Confidentiality
Order Entered September 22, 1993, Opposition to CSI's Motion to Seal Re-
Created Versions of Plaintiff's Confidential Upper Level Scriptures, and
Opposition to CSI's Motion for Attorney's Fees, Costs and Sanctions
Under 29 U.S.C. S 1927, Etc.
4. I was a Scientologist for nearly 15 years, from January 1975
until July 1989. I was in the Guardian Office ("GO") and its successor
(a name change only), the Office of Special Affairs ("OSA"), for most of
that time. I also worked in another part of Scientology called Author
Services, Inc. ("ASI").
SCIENTOLOGY'S UPPER LEVEL MATERIALS ARE ALREADY EASILY ACCESSIBLE
TO THE PUBLIC
5. It is incredible that plaintiff CSI is still concerned about
maintaining any degree of confidentiality of Scientology's so-called
"upper level materials." The information contained in these documents
has been available any large public or university library for many
years. attached as Exhibit 1 is a sampling of the many books and
newspaper and magazine articles in which these materials have been
published. The fact is that these materials are no longer confidential.
They are already broadly publicly available. For the Court to continue
to maintain their confidentiality" is somewhat like closing the barn
door after the cows have already escaped.
Dr. GEERTZ'S COUNSEL HAS NOT BEEN HARASSIVE IN HIS DEFENSE
6. CSI's counsel accuses Mr. Berry of being harrasive in his
defense of his client. This is ludicrous. I have personal knowledge
that Mr. Berry has not intended to be harassive nor has he acted in a
harassive manner. I have been advising him in this case as an expert on
Scientology practices, policies and language. CSI cites Mr. Berry's
use of certain Scientology words and phrases as an example of his
harassive tactics. In fact, I advised Mr. Berry that he would be much
more successful in communicating with Scientologists if he learned the
Scientology language and spoke it as much as possible when dealing with
Scientologists. In addition, that he learned the Scientology definition
of words that are in common English usage but are defined differently by
L. Ron Hubbard. In the past, communications between Scientology and
opposing counsel would have been like two ships passing in the night.
How can it be harassive when someone goes to the trouble to learn an
extremely complex language just so that he can better communicate? Or