Scientology Crime Syndicate

Declaration of Joseph A. Yanny

         I, JOSEPH A. YANNY, having personal knowledge of the following
    hereby declare and state that :

         1. I am an attorney at law, duly admitted to practice before the
    United States Supreme Court, the Supreme Courts of the States of
    California and Illinois, and numerous other federal courts and
    administrative agencies.  This is the tenth year of my admission to
    practice law.  I am the sole shareholder of the entity known as Joseph
    A. Yanny, a Professional Corporation, which does business as Herzig and

         2. I have from time to time, represented the Plaintiffs herein
    (hereinafter collectively referred to as the "Cult") over the course of
    several years.  My Corporation and I are Defendants herein, along with
    several of my associates.  The Cult asks for equity, but their hands
    are unclean.

         3. One of the basic beliefs of the Cult is the much written about
    "FAIR GAME" policy which states that an "ENEMY" of Scientology:

         May be deprived of property or injured by any means by any
         Scientologist without any discipline of the Scientologis.
         May be tricked, sue or lied to or destroyed.

         A true and correct copy of which is submitted as exhibit A.

         4. The Corrolary to this "Fair Game" Doctrine is the "Religious
    Practice:  set forth in the Cults' "Scriptures" known as the "level 0
    checksheet" (a true and correct copy which is submitted as exhibit 1)
    and provides at the page marked as 55:

         The purpose of the lawsuit is to harass and discourage rather
         than to win, The law can be used very easily to harass and
         enough harassment on somebody who is simply on the thin edge
         anyway, well knowing he is not authorized, will generally be
         sufficient to cause his professional decease.  _If possibly,
         of course, ruin him utterly._

(emphasis added)
    That is the purpose of this suit against myself, my firm and my
    associates.  The Cult is so anxious to abuse process that it claims it
    needs expedited discovery, a special dispensation from the Rules of
    Discovery intended to allow a Defendant sufficient time to secure and
    brief counsel.

         5. The "Fair Game" doctrine has been discussed at length in
    numerous litigations including the one entitle _U.S.  v. Hubbard_
    reported at 474 F. 2d 64 (D.C.  .D.C.  1979), its predecessors and its
    progeny.  See e.g.m 572 F. 2d 321, 591 F. 2d 533, 650 F. 2d 293, 668 F.
    2d 1238, 436 F. Supp 689, 529 F. Supp.  945.  In that case, top
    executives of the Cult were eventually convicted of crimes including
    theft of U.S.  Government documents, obstruction of justice, and othe
    "fair game" related activities against the Government of the U.S., a
    known "ENEMY" of the Cult.  See Exhibit 25 and 27 submitted herewith
    i.e.  _Sentencing Memorandum and Stipulations of Evidence_

         6. As late as 1984, Judge Beckenridge of this Honorable Court,
    wrote an opinion finding that the infamous "fair game" doctrine was
    still in full force and effect, barring equitable relief against the
    defendant in that case, Mr.  Gerald Armstrong, who had actually stolen
    documents from the Cult.  A true and correct copy of _Hubbard v.
    Armstrong_ is submitted herewith as exhibit B.

    As Judge Beckenridge stated on page 8 of that opinion:

         In 1970 a police agency of the French Government conducted an
         investigation into Scientology and concluded, "this sect,
         under the pretext of 'freeing humans' is nothing in reality
         but a vast enterprise to extract the maximum amount of money
         from its adepts by (use of) pseudo-scientific theories, by
         (use of ) 'auditions' and 'stage settings' (lit.  to create a
         theatrical scene) pushed to extremes (a machine to detect
         lies, its own particular phraseology.  .), to estrange adepts
         from their families and to exercise a kind of blackmail
         against persons who do not wish to continue with this sect."2
         From the evidence presented to this court in 1984, at the
         very least, similar conclusions can be drawn.  In addition to
         violating and abusing its own members civil rights, the
         organization over the years with its "Fair Game" doctrine has
         harassed and abused those persons not in the Church whom it
         perceives as enemies.  The organization is clearly
         schizophrenic and paranoid, and this bizarre combination
         seems to be a reflection of its founder LRH.  Judicial Notice
         thereof is requested.

         7. I would call the Court's attention to the doctrine of
    collateral estoppel, best statued by the U.S.  Supreme Court in the
    case of _University of Illinois v. Blonder-Tongue Laboratories_, 402
    U.S.  313, 28 L. Ed.  2d 788, 91 S. Ct.  1434 (1971).  I could cite
    California and Federal authority for the propisition that once policy
    such as "Fair Game" is established, the burden shifts to the Church to
    establish "a change in circumstance."  However, I do not have the
    research on the subject nor my notes and copies of cases thereto (they
    are locked in this Court's jury room.)

         8. The Court should also see the case of _Allard v. Church of
    Scientology of California_, 129 Cal.  Rptr.  797 (2nd Dist.  1976),
    submitted as exhibit 5 herewith, and the full text of the _Stipulations
    of Evidence_ in the case of _United States v. Hubbard_, which sets
    fourth the various "Religious" practices of the Cult as including:

         III.  The conspiracy to intercept oral communications,
         Burglarize and steal and the substantive acts committed
         pursuant thereto.

         VI.  The conspiracy to Obstruct Justice, to obstruct an
         investigation, to harbor a fugitive and to make false
         declarations before the grand jury.

         9. Submitted herewith a collection of exhibits which consist
    mostly of pleadings, evidence, exhibits, and judges' opinion in legal
    cases, with the only exceptions being No.  15, a magazine article, and
    No.  12, complaints filed with the Massachusetts Board of Bar Oversees
    by the Cult.

    These materials are offered to show the chronic nationwide contempt
    which the Cult has shown for all judicial process, These materials
    clearly demonstrate that the Cult, according to written policy, will
    use any means legal or illegal to subvert and frustrate judicial
    process against them, and will willingly and knowingly abuse judicial
    process in order to attack perceived "enemies".  The victims of these
    attacks include lawyers, judges, witnesses, and party defendants.

         10.  The following is a brief characterization of each of the
    included documents.  True and correct copies of the exhibits are
    submitted herewith to wit:

         Exhibit 1:  _Purpose of a lawsuit_.  This exhibit includes two
    items.  The first is a magazine article written by L. Ron Hubbard, the
    founder of Scientology, describing how to use a lawsuit to harass
    opponents (see page 55).  The second one is an internal Scientology
    document, that was part of the court record in _United States v. Mary
    Sue Hubbard_, Cr.No.  78-401 (D.Ct., D.C.).  It states that the object
    of litigation with the I.R.S.  is delay

         Exhibit 2. _"Freedom of Speech Includes Freedom to Malign"._ This
    document, written by Jane Kember, includes a blunt description of how
    knowingly frivolous lawsuits can be used to drive publishers into
    submission.  Kember states that since in the U.S.  a person who loses a
    lawsuit is not required to pay the opponent's cost, frivolous lawsuits
    are an effective means of imposing unbearable financial burdens on
    publishers and thereby suppressing publications of materials on

         Exhibit 3-9 Various cases which the Cult lost including findings
    of frivolousness with the award of sanctions.

         Exhibit 10.  _Reader Digest Case_.  The Cult attempted to enjoin
    the publication of a Reader Digest article in Denmark.  The Court held
    that the suit was without merit and ordered the Cult to pay the Readers
    Digest Dkr.  2000.

         Exhibit 11.  _Lawsuits against Attorney Michael Flynn and Thomas
    Hoffman_.  Attorneys Michal Flynn and Hoffman represented plaintiffs
    who were suing the Cult.  The Cult has sued the attorneys and their
    employees.  This exhibit includes the cover sheets of the suits and two
    court orders dismissing the suits.

         Exhibit 12.  _Frivolous Bar Complaints_.  The exhibit includes
    cover sheets of frivolous bar complaints against attorneys representing
    plaintiffs who are suing the Cult.

         Exhibit 13.  _Church of Scientology v. Cooper_.  In this opinion,
    Federal Judge Hauck describes an incident in which a Cult member was
    found wandering around in a security area in the Los Angeles Federal

         Exhibit 14.  _Motion to Disqualify._ Self-explanatory

         Exhibit 15.  _Article from "American Lawyer_.  Describes a number
    of covert operations against judges who were sitting on Cult cases.

         Exhibit 16.  _Investigations of Judges_.  The three parts of this
    exhibit describe Cult operations to investigate the personal
    backgrounds and families of judges deliberating in Scientology cases.
    These exhibits are internal Cult documents seized by the F.B.I.  from
    Cult headquartets in 1977 and were part of the court records in _United
    States v. Mary Sue Hubbard_, supra.

         Exhibit 17.  _Affidavit regarding infiltration_.  This affidavit
    of Dennis Quilligan describes the efforts of a Cult lawyer to
    infiltrate the State's Attorneys office and his successful infiltration
    of the lawfirm, representing Mayor Cazares, who was then being sued by
    the Cult.

         Exhibit 18.  _Unsigned Stipulations of Evidence_.  This lengthy
    document was the agreed basis for the conviction of the Church's top
    leaders in Federal Court in Washington, D.C.  It includes a variety of
    criminal actions committed by the Scientologists, including obstruction
    of justice.

         Exhibit 19.  _Instruction on How to Lie_.  An internal Cult
    document containing instructions on how to lie effectively.

         Exhibit 20.  _Instructions on How to Steal Documents_.  This
    appaling document is self explanatory.  It was seized in the F.B.I.
    raid.  The second part of the exhibit shows full knowledge by Cult
    officials of ongoing burglaries.

         Exhibit 21.  _More Instructions+.  Self-Explanatory.

         Exhibit 22.  _"Bulldozer Leak"_.  This document describes an
    operation to frustrate service of legal process by fraudulent means.
    This document was seized in the F.B.I raid.

         Exhibit 23.  _Project Quaker_.  This document describes an
    operation to obstruct justice by concealing witnesses.  Also taken in
    the F.B.I.  raid

         Exhibit 24.  _Early Warning system_.  A scheme to frustrate legal
    process by fraudulent and criminal means.  This document was also taken
    in the F.B.I.  raid.

         Exhibit 25.  _Scientology Memorandum_.  This is a lucid
    description of the scope of criminal and tortious (sic) activities and
    abuse of the judicial system by the Scientologists.

         Exhibit 26.  _Lost of Scientology Lawsuits_.  This exhibit is a
    partial list of lawsuits brought by the Cult, intended to show the
    extreme litigiousness of the Cult.

         Exhibit 27.  The Signed Stipulations referred to in Exhibit 18.

         11.  I have personal knowledge of the fact that while the Cult
    claims in the verified complaint, to be religious, this Cult clams to
    be religious only within those jurisdictions where it is expedient to
    be so, e.g.  the U.S.  where there is a tax exempt status for such
    activities and a first amendment to hide behind when tortious (sic) and
    criminal activity must be defended.  However, I have personal knowledge
    that in such countries as Israel and many parts of Latin America, where
    it is not expedient to be a religious organization, (because of a state
    religion and a prohibition against ownership of property by Religious
    organizations, Respectively,) "The Cult" claims to be a philosophical
    Society.  I also have personal knowledge of documents which can prove
    these facts, which documents are in the possession of Thomas Small,
    Esq, of the firm of McDonald& Halstead, and Cult members such as Alan
    Cartright and a young lady named "Kirsten" (pronounced-Sher Ston).

         12.  The Court should also be aware of the verdict in tow recent
    cases, to wit:

         1) _Christoffersin (Tichbourne) v. CSC, Hubbard et all_,
         Portland, Oregon decided in 1985 (Case citation in Court's
         Jury room) (in which a jury awarded Mrs Titchbourne $39
         million dollars as a result of the "Fair Game" "Religious"
         practices directed at her); and the case of 2) _Wollersheim
         v. C.S.X._ in LA Superior Court before the Honorable Ronald
         Swearingger (citation in Courts Jury room) (in which the jury
         awarded Mr.  Wollersheim $30 million as a result of the "Fair
         Game" "Religious" Practices directed at him)

         13.  Since the outbreak of hostilities between the Aznarans and
    the Cult there is additional evidence of continued application of the
    "Fair Game Doctrine" present in the instant case, to wit:

         1) Ms.  Karen McRae, one of my alleged co-conspirators
         herein, after having been visited upon by various attorneys
         for the Cult (including two phone calls from:  Earle Cooley,
         Esq.  and one visit in Dallas, Texas, by a femal attorney
         from a D.C.  firm representing the Cult), was severely beaten
         by two unknown assailants in Dallas, Texas;

         2) Rick Aznaran, while under surveillance by agents of the
         Cult, was the object of a hit and run accident in the State
         of Texas;

         3) This past week, Ms.  Wilske, my fiancee, was the object of
         an auto accident involving the collision of the front and the
         rear of her vehicle, totally disabling it and injuring her;

         4) I, on Sunday June 26, 1988, at about 5:00 p.m.  was
         stopped by no less than four local police cars, in the City
         of Bellaire, Ohio.  The police called me by name that they
         had information that I was in posession of firearms and
         cocaine (the very same allegations made by the Cult in this
         case).  I was informed by the police that I had two options
         i.e.  to allow my car to be searched or be arrested on the
         spot.  Needless to say, I permitted the car my person and the
         person of my relative to be searched.  Nothing was found.
         The next day, Monday the 27th of June, the occupants of two
         out-of-state cars having Pennsylvania plates were questioned
         by local officials.  The occupants, stated that they had me
         under surveillance since Saturday, June 25, 1988 (before the
         search by the police), and that they had been hired by a
         Washington D.C.  firm (who represents the Cult) named
         Williams & Connolly.  A full report on this matter is now in
         the hands of the FBI.

         5) At a meeting held in the offices of Howard Weitzman, on
         June 15, 1988, I was informed by Mr.  Weitzman, that this
         suit need not be filed and "could be handled", if and only if
         the Aznaran suit would be made to go away.

         6) Since I stopped representing the Cult in or about November
         of 1987, my offices have been broken into on at least three
         occasions (once with a crow bar), and numerous documents are
         now missing relating to the cult.  These break-ins were
         conducted a number of months after __Mr.  Moxon (an
         unindicted co-conspirator in the__ _United States v. Hubbard_
         __case__) had 'cased the Joint" under the guise of wanting to
         rent space from me;

Now as to the players:

         14.  As to Mr Vallier, my former associate, an officer of my
    professional Corporation, and former employee, I state as follows:

         a) Mr.  Vallier, quit my employment in the month of February on a
    few days notice;

         b) Mr.  Vallier is a well known seller of large quantities of
    cocaine and has been so for years;

         c) I am informed by Mr.  Vallier that he was first busted and
    convicted on drug charges at age 17, I am informed that through the aid
    of his father (a local attorney), he had the matter expunged from his
    records.  Mr.  Vallier expressed concern to me during 1986 that he was
    being blackmailed by the Cult.  he stated that the Cult had confronted
    him with thefact of his prior drug conviction as a minor, a fact that
    was not public knowledge.

         d) I have personally seen Mr.  Vallier in possession of large
    quantities of cocaine which he stated was intended for resale; and he
    also stated that selling drugs was his way of supporting his own habit
    and supplementing his income;

         e) Mr Vallier has stated that he had been a supplier of cocaine to
    other known enemies of the Cult while he was in la school;

         f) Mr Vallier stated before departing my good offices that he had
    been an "operative" for the Cult in obtaining information from inside
    the offices of Charles O'Reilly, through an old "cuddle" (as he called
    her), whom I recall he identified as "Mary", stating that she was one
    of the O'Reilly attorneys' secretary.  Mr Vallier further stated that
    he supplied "Mary" with cocaine.  With respect to the O'Reilly
    operation, Mr Vallier stated to me that he was "run" by Warren

         g) There currently exists a dispute between Mr Vallier and myself
    as to fees earned.  It took Mr Vallier three times to pass the
    California Bar Exam.

         15.  Ms Peti;

         a) Worked for me from April 1987, (the time when the Aznarans made
    an escape from a secret cult prison location in the desert known as
    "Happy Valley") until shortly before, the institution of this action.
    She was emotionally distraught, a heavy substance abuser, and possessed
    of an extreme weight problem.  She was also a lover of Thomas Vallier
    with whom she spent the night during a visit to Oregon which we took in
    the Summer of 1987,

         b) I am within the last week, informed by a Mr.  Waysman that she
    was a former secretary of his and a key witness in a disciplinary
    proceeding which resulted in the 1986 published case of _Waysman v.
    State Bar of California_, 224 Cal.  Rptr.  101 (Cal.1986), involving
    allegations of drinking and drug abuse.  I am informed by Mr.  Waysman,
    that Ms.  Peti, worked for him only three weeks before running off with
    money and testifying to things she could have no knowledge of.

         c) I know believe that Ms.  Peti, was recruited to infiltrate my
    organization as a plant at about the time of the criminal incarceration
    of Vicki Aznaran, in early 1987, by the Cult because of Peti's peculiar
    experiences as witness in the Waysman case (see exhibits 17 & 20.)

         d) Prior to departing my offices, Ms.  Peti had numerous financial
    misfortunes, was sued for divorce by her estranged husband, (the law
    clerk referred to in the Waysman case), and was heavily using alcohol
    and drugs (which she stated she obtained from Mr.  Vallier, who she was
    regularly seeing after she left my employment).

         16.  As to Mr.  Warren McShane, I state that he has informed me
    that he was a high ranking operative in the "G.O.", during the days
    which saw the events which resulted in the _United States v. Hubbard_
    convictions.  His tendencies toward criminal behavior and disregard for
    the law were the subject of many complaints by me to Mrs Vicki Aznaran
    prior to her incarceration in the dessert by the Cult.  It was this
    tendency to criminality that resulted in his removal from his post and
    apparently gave rise to his current grudge match against me.  I was
    informed by Mr.  McShane the he was running plants in the inner circle
    of one David Mayo and that he was "culling" confidential confessional
    folders of cult members (known as "P.C.  folders") to gain information
    that would be used against them as blackmail or for impeachment
    purpose.  I personally observed this culling and objected to it.

         17.  As to Mr Moxon, I state that:  Prior to his completing law
    school, he was one of numerous unindicted co-conspirators in the case
    of _United States v. Hubbard_.

         18.  Mr Cooley (who in his last two outings for the church lost a
    $39 million dollar verdict in Oregon and another $30 million verdict in
    L.A.)  has personally ordered the destruction of evidence relating to
    Cult litigation in my presence.  These orders were given to Warren
    McShane and Mark "Marty" Rathburn

         19.  I was hired by Mrs.  Aznaran in 1984 to represent the Cult in
    trade secret, copyright and trade mark litigation matters.

         20.  I am informed and therefore believe, that sometime in early
    1987, Mrs.  Aznaran was abducted and taken to a "Johnestown-like" camp
    known as "Happy Valley".  As far as I know, she just disappeared.  It
    was not until many months later that Vicki, a personal friend, found
    the courage to initiate contact with me.

         21.  Prior to talking with Vicki, after her abduction, a number of
    extremely troubling occurrences happened involving my representation of
    the Cult; to wit:

         a) Sometimes in April or May 1987 I was summoned to a meeting on
    the 4th floor of the Cult headquarters in L.A.  and at that meeting
    were many high ranking officials of the Cult including, Linda Hamel
    (Director of Covert Intel operations), "Marty" Mark Rathburn.  and an
    indistinguished cast of others.  The subject matter of the meeting was
    to be "The Catholic Conspiracy and Charles O'Reilly."  At the meeting
    it was explained that Catholics were the enemies of the Cult and that
    Charles O'Reilly was their best hit man.  (O'Reilly had recently
    obtained a $30 million dollar verdict against the Cult in _Wollersheim_
    and previously tried the _Allard_ case).  Mr O'Reilly (whom I have
    personally sued for the Cult, obtaining an injunction against him in
    Federal Court), despite his human tendencies, remains one of the few
    lawyers in this country with the skill and courage to meet the Cult
    head on, beat it and not sell out.  Since he didn't have a price, it
    was explained by Mr Rathburn that he must be handled through blackmail.
    Three private investigators were present at that meeting.  I do not
    remember their names.  I and the others were told by "Marty" Rathburn,
    that on the orders of David Miscavige (the successor of the L. Ron
    Hubbard as the head of the Cult), that the medical records of O'Reilly
    were to be stolen from the "Betty Ford Center" and another location in
    Santa Barbara to show that he was using cocaine, discredit him, and
    possibly blackmail him into easing off on his 30 million dollar verdict
    now on appeal.  I objected to this as illegal and an alternative plan
    was quickly arrived at to "settle my nerves".  Within days, I informed
    the Cults' chief lawyer, John Peterson, that I wanted to substitute out
    of the cases in which I represented the Cult.  Soon thereafter Mr.
    Peterson died.  I substituted out as quickly as possible thereafter.

         b) I also became aware of numerous "cullings" of P.C.  folders by
    Cult members.  I was actually given P.C.  folder data to prepare for
    depositions of former members.  Again I objected.  The confidential
    materials were put in "prep packs".  When I objected to this practice,
    I was told by Mr.  McShane and a Mr.  Ryerson that this was standard
    practice in the Cult.  I again offered my resignation as their counsel.
    Within weeks, the prep packs were removed from my office by a team of
    Cult members headed by a Mrs Joyce van Dyke.  Prior to the break-ins
    into my office, I received receipts for the prep packs as they were
    turned over to the Cult team.  I have not been able to locate them.

         c) There was also wholesale destruction of evidence, theft of
    documents from private persons and attempts to infiltrate the Court
    chambers of Judges Lilly and Swearinger.

         d) This is but the top of the iceberg.  Many of the documents in
    this Court's Jury Room show recent attempts by this Cult to infiltrate
    courthouses, U.S.  government contractors such as Honeywell in Phoenix,
    to find out what classified projects these contractors were getting
    from the "Rockefellers" and the "DOD" and other "enemies of mankind".

         e) I was also informed of a Cult-organized group of vigilantes
    known as the "minutemen" who were to go beat up dissidents and had in
    fact done so.  I retained no originals of any documents that belong to
    the Cult, I simply retained copies, which I am permitted to do.  The
    enscrypting diskettes for the Cult computer, were turned over to them
    prior to the break-ins in my office.

         f) I also became aware of a plot to obstruct Justice or at least
    perpetuate a fraud to the Courts in the form of settlement agreements
    of numerous pieces of Cult litigation, which required that lawyers
    never take litigation against the Cult in the future, that no-one
    (lawyers or parties) testify against the Cult, and that all evidence
    and files be turned over to the Cult for destruction.

         g) Additionally, I became aware that witnesses such as Bill Franks
    and others signed contracts to keep quiet about what they knew.  In
    other words they were paid hush money,

         22.  I never engaged in the representation of the Aznarans or Mr
    Corydon, nor did I impart any confidential "privileged information to
    them."  We have one thing in common, a common criminal enemy -- the
    Cult -- who the governments of this country have allowed to physically
    beat its citizens, to betray their confidences, ignore their civil
    right and use the Judicial System to Destroy them.

         23.  That I had a difficult time sleeping knowing what I knew,
    having represented this criminal Cult -- I readily admit.

         24 From the time I wanted to substitute out of the Cult cases
    until present, the Cult failed to make payments for services rendered,
    A deep dispute arose, when questioned by Cult member Carol Martiniano
    about who would have facts to support my contentions regarding the fee
    dispute, I informed her Vicki and others would know.  Within a few days
    Vicki called me to tell me that she had received threats from Earle
    Cooley on the phone, that she better not remember the facts the way she
    was stating them or she would be sued by the Cult.  At that time Vicki
    informed me of the facts surrounding her incarceration and denial of
    medical treatment at "Happy Valley".  I informed her that she had a
    potential statute of limitation problem, that I probably should not
    represent her, but would help her find a lawyer.  I told her that she
    had a place to stay if she wanted one -- my home.  She, her husband and
    Ms.  McRae came to my home, found a lawyer and sued.  To this day, I
    haven't seen her full complaint, and no one in my office drafted any
    part of it.

         23.  It was my determination that I had no conflict of interest in
    the Aznaran matter, but in order to best serve the Aznarans' interest,
    they should find other council -- so the matter could be resolved on
    the merits, not by default or attrition.

         26.  As a result of Vicki's visit, I met Mr.  Corydon, Vicki's
    friend.  I began to gather evidence for my conflict with the Cult since
    the storm clouds were gathering.  I had read Mr.  Corydon's Book _L.
    Ron Hubbard - Messiah or Madman_, before meeting Mr.  Corydon, found
    the book both frightening and interesting, and submit the same as
    exhibit 28.  I recommend it to the court's attention.

         27.  Most of the alleged facts set forth in the Declaration of
    Peti are outright lies.  It is true that Mrs.  Peti worked for the firm
    of Herzig & Yanny for a little more than a year.  When she quit, she
    left in the middle of a business day and never returned, contrary to
    her statement that she came back to the from from time to time and that
    I made damaging statements to her.

         28.  In addition to the above, it is also true that my office has
    copied the work performed on behalf of the plaintiffs and the work
    performed by other offices to which our office responded on behalf of
    plaintiffs.  We have retained those copies.  It is further true that
    our office has retained the complete diskettes that contain the work
    that the Herzig & Yanny firm did for the plaintiffs, most of which has
    been filed and is therefor subject to public inspection.  I have also
    received communications from plaintiffs containing material which
    indicates that they were engaged in criminal activity.  I retained
    copies of those documents in order to establish that these criminal
    activities are such as to constitute a waiver of the attorney-client
    privilege and also establish that this lawsuit and their conduct
    towards me in initiating it are a part of a common purpose and plan
    carried out by the plaintiffs against all those people who leave their
    employment or who leave their church.  It is necessary for me to retain
    those copies to properly defend myself in this action.

         29.  I have had no opportunity to get fully informed advice from
    my attorney, or from any attorney, as to what I should do with the
    copies that I have formerly retained, which are now held by this Court.
    I believe that those documents will indicate that the plaintiffs have
    participated in a consistent conspiracy to obstruct justice and to
    perpetuate fraud upon the Court and that by reason thereof, and by
    reason of the provisions of California Evidence Code paragraph 956,
    such information is not subject to any privilege whatsoever.

         30.  Addressing myself to certain of the specifics of the Dorothy
    Ann Peti Declaration, my comment is as follows:

         At no time did I instruct Dorothy Ann Peti or anyone else in the
    employment of Herzig & Yanny to inflate the billable hours for the
    plaintiffs, or to any other clients of the office.  With reference to
    Thomas R. Vallier, on numerous occasions, I informed Mr.  Vallier that
    he was either incompetent or had lost sight of the true hours spent on
    the job, and that I could not bill the client the hours shown on his
    timesheets, and I drastically reduced the hours billed to the clients.

         31.  It is absolutely false that I charged Lisa Wilske's time at
    other than her normal rate, which ran from various time at $40 per
    hour, $75 per hour, and later, when she finished law school and became
    an attorney, at $125 per hour.

         32.  It is not true that Lisa Wilske or anyone else ever asked Ms.
    Petti to attend any proceedings at the home of Joseph a. Yanny and give
    an "impression" of conversation with any individuals.  Most of the time
    that Ms Peti was "at" my home was actually spent at a local bar called
    the "Poopdeck" and, on at least one of the days that she referred to,
    she called us to come and get her because she was so drunk that she was
    afraid to leave the bar by herself.  On one of those occasions, she
    bought me a shirt containing an advertisement of the bar, which is
    still owned by the Declarant.

         33.  I knew Vicki Aznaran because she had been the president of
    Religious Technology Center, one of the plaintiffs herein, during the
    time that I represented the plaintiffs.  After Ms.  Aznaran left the
    Church, and after I terminated my professional relationship with the
    plaintiffs, I had numerous conversations with her, and she advised me
    that she had terminated her relationship with the plaintiffs and that
    she had been, in effect, kidnaped and taken to the desert, deprived of
    medical care, forced to go on marches, and finally was able to escape.
    She said that she was going to come over and discuss the matter with
    me.  During one of the weekends at my home, in addition to the social
    pleasantries that were exchanged, she asked me if i could represent her
    in suits against the Church; I stated that I would have to review the

         34.  At that time, I had heard of Mr.  Corydon, but I had not met
    him until he came to visit with Vicki at my home in Hermosa beach.  I
    had known that he had written the book _L Ron Hubbard -- Messiah or
    Madman ?_, and that the plaintiffs were extremely angry with him over
    writing the book, but I knew little about him.  At no time did Mr.
    Corydon tell me he did not have financial resources to hire an
    attorney.  At no time did I discuss those lack of funds or Lisa
    Wilske's prior participation with the plaintiffs, nor did I ever offer
    to have Ms.  Wilske, or anyone in my office, represent Mr.  Corydon.
    At no time did I have Lisa Wilske or Richard Wynne or anyone else in my
    office research any issues concerning the Aznaran complaint.  The only
    research that was done was by Lisa Wilske and Mary Grieco as to the
    propriety or possibility of our firm representing someone adverse to
    the plaintiffs.  For many reasons, I decided it would be inappropriate
    to represent the Aznarans.

         35.  Neither I nor anyone else in the office of Herzig & Yanny to
    my knowledge drafted any portion of the planned or actual Aznaran
    Complaint, and it is an absolute lie (as is most of the Declaration of
    Peti) that I was present during the filing of that complaint.  It is
    also not true that I imparted any confidential material, or any
    material whatsoever, to the firm of Cummins & White or to any of its
    members to assist them in the preparation of the Aznaran Complaint.

         36.  It is true that a stack of documents were brought to my home
    on one of the dates referred to in the Peti Declaration.  These
    documents related to the break-in of government offices by agents of
    the plaintiffs in 1977 or 1978 which resulted in an action brought by
    the United States against the plaintiffs, and resulted in nine of the
    top executives of the Cult, including the wife of L. Ron Hubbard, being
    convicted and sent to spend time in the Federal penitentiary.

         37.  I felt they were relevant to my impending suit with the Cult
    in light of the numerous break-ins to my quarters.  The fanciful story
    told by the petitioner in paragraph 21 on page 6 and 7 of Ms.  Peti's
    Declaration is not only false, but it is intended to create an
    impression which Ms.  Peti knows is false.  The fact of the matter are
    absolutely to the contrary.  Ms Peti is well aware that the motion she
    refers to was prepared by the Church at their own offices and was
    brought to me by Thomas Vallier at Court when I was present during
    another matter.  I read the documents and refused to sign them.  I said
    that they were wrong and were not to be served.  I told Mr.  Vallier
    that they were wrong and were not to be served, and he left.  If I had
    known that they had been served, I would certainly have sent out a
    "notice of non-hearing."  I first learned that the documents had been
    served when I received the motion for sanctions.  I inquired of Ms.
    Peti, and she told me that she had received a call from the Church and
    that they had told her that I had advised them that she should serve
    the documents.  I told her that that was absolutely false.  The church
    insisted that I oppose the motions for sanctions and I did.

         38.  At no time did I lecture or otherwise inform Corydon or
    anyone else concerning the actual facts about the plaintiffs'
    "weaknesses."  I was advised and learned of some of those weaknesses,
    but that knowledge was one of the things that persuaded me not to
    represent the Aznarans in their suit against the plaintiffs.

         39.  It is true that, after Vicki Aznaran told me the facts of her
    imprisonment by the plaintiffs, I told her that she might have a
    statute of limitation problem and that if she was going to bring an
    action she had better be careful of the time limitations.  I also told
    her that I would recommend some attorneys she could go to.  She told me
    that there had been numerous agreements between the Church and numerous
    attorneys and witnesses wherein they had agreed not to represent anyone
    who had an interest adverse to the Church and the witnesses agreed not
    to testify for anyone who had a cause of action against the Church.

         40.  I have never seen the full Aznaran Complaint.  I am not aware
    of it ever coming to the office of Herzig & Yanny.  I was not aware
    that this was a possibility until my attorney read that portion of the
    Ms.  Peti statement to me on June 26, 1988, paragraph 24 of the Peti
    Declaration.  Under no circumstances did I assist in the preparation of
    any Complaint by Aznaran against the Church.

         41.  The declaration of Vicki Aznaran concerning the retaining fee
    dispute that I presently have with the plaintiffs came in some time
    prior to any meeting that I had with the Aznarans.  That Declaration
    was taken from my office during one of the many break-ins to my office
    following my termination as attorney for the Church.  During one of
    those break-ins, which was accomplished by the use of a crowbar, my
    individual office was broken into as well.

         42.  Paragraph 28 of Ms.  Peti's declaration is absolutely false,
    and Ms.  Peti must know that it is false.  Ms.  Peti had nothing to do
    with the billing at our office.  If she had taken the time to make an
    investigation of that billing, she would have discovered that all of
    the billing for Lisa Wilske, whether for the Church or any of the
    clients, was billed at Ms.  Wilske's regular rate, and was never billed
    at Yanny's higher partner rate.

         43.  The allegations of paragraph 21 in Ms.  Peti's Declaration
    are vicious and false, and are nothing but deliberate lies intended to
    place me in a bad light before this court.

         44.  At this point, I have not had sufficient opportunity to
    review the extensive documentation filed by the Cult in support of the
    pending Application.

         45.  As to the Declaration of Mr.  Vallier, I can only state that
    the contents of paragraph 2, appear to be generally correct but the
    contents of paragraph 3 and 4 are out right perjury.  As to paragraph
    5, I can only state that there was a break-in into my offices, I have
    no knowledge of what others believe or stated, that I staged no
    break-in.  The balance of Mr.  Vallier's paragraph 5 is a lie.  As to
    paragraph 6 and 7 of Mr.  Vallier's Declaration, I can only state that
    both Peti and Vallier (who are now on the Cult's payroll) are Liars and
    the implications are false.  As to paragraph 8, I did withdraw as
    counsel and executed substitution of attorney papers which were
    delivered to the Cult representatives for filing in Court.  As to the
    contents of paragraph 9, 10, 11, 12 and 13, I can only state that there
    was no "conspiracy," and I have no knowledge of Mr.  Vallier's
    conversations with Messrs..  Wynne and Grabowski, and that his alleged
    conversation with me is a figment of his tortious imagination.  The
    contents of paragraph 14 are also false.

         46.  As to the Declaration of Warren McShane, I can state that as

         a) paragraph 3, 4, 5, 6, - the contents are false as far as I
         know.  I never met McShane until 1984.

         b) The contents of paragraph 7 appears to be generally correct;

         c) I have no recollection of the allegations made in paragraph 8
         or 9 of the McShane Declaration, and all my files are with this

         d) The contents of paragraph 10 appears to be generally
         correct, except that the dates, and I did represent the Cult
         in the litigation specified in paragraph 11.

         e) As to paragraph 12 and 13, I can only state that Vicki
         Aznaran was and is my friend (a concept you will not find
         discussed in the Cult writings of L. Ron Hubbard).  In 1985,
         I was given a $150,000.  non-refundable retainer, "For 1985"
         not to be applied against billings, as an inducement to begin
         working nearly full time for the Cult as "co-ordinating
         attorney".  I did submit bills regularly and none of the 1985
         retainer was applied against billings.  The remainder of
         paragraphs 13, 14, 15, 16, and 17 are untrue except that I
         did often reduce my bills to compensate for the quality of
         work done by Vallier, who needed three tries to pass the Bar

         f) As to the contents of paragraph 18-24, I can only state
         that I have had correspondence with Mr Weitzman, but the
         balance is either untrue, distorted, or not in my memory
         banks or records.

         At no time have I ever conspired with anyone to disclose, nor have
    I disclosed, nor do I intend to disclose any privileged information
    pertaining to the plaintiffs in this lawsuit which was obtained during
    the course of the prior attorney-client relationship between Plaintiffs
    and Defendants.  I do not intend during the course of this lawsuit, nor
    at any time hereafter, to aid, counsel, or otherwise participate in the
    legal representation of Vicki J. Aznaran, Richard Aznaran, and Bent
    Corydon regarding their lawsuits with the Plaintiffs.

         I hereby declare under penalty of perjury under the laws of the
    State of California that all of the above is true and correct except as
    to those matters stated on information, and as to those matters I
    believe them to be true.

         Executed at Los Angeles, California on this 13th day of July, 1988


                                                Joseph A. Yanny


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