Last modified August 14, 1998
                                                      From FACTNet


AFFIDAVIT OF JESSE PRINCE

I, Jesse Prince declare as follows:

1. I am over 18 years of age and currently reside in the state of
Minnesota, County of Hennepin. This declaration is of my own
personal knowledge and if called upon to testify to the facts
herein I could and would be competently able to testify thereto.

2. I am intimately familiar with the Scientology organization,
movement and beliefs because I was in Scientology for 16 years
(1976-92) and served in the highest ranks, including as the second
in command of the Religious Technology Center (RTC). At that time,
my position was "Deputy Inspector General, External" which meant
being in charge of all activities outside the body of Scientology.
This included being in charge of all litigation by or against any
Scientology organization, intelligence (spying, covert operations)
brought against perceived or imagined "enemies" (which ranged from
critics to media to the courts), trademark registrations, and the
licensing of trademarks to other Scientology organizations, which
was how we tightly controlled all Scientology corporations while
creating the false impression of "corporate integrity."

3. It is incumbent on this and every court, as well as the
authorities, to realize the amount of deception, chicanery, lying,
manipulation and outright criminality that Scientology will employ
to hide the truth about their criminal activities. They will spend
any amount of money to do this. I know because I was part of it
for years. I received orders to break the law. I issued orders to
break the law. I got others to break the law, and then I helped to
hide these criminal activities just as they are hiding them now.

4. In fact, this tactic is one of the most coercive used by the
Scientology hierarchy: to involve members in criminal acts for
which they are then liable, which then prevents the person from
speaking out. Even if the member manages to leave or flee, they
will be reluctant to speak to the courts or the authorities
because they were part of criminal activities. Plus the
organization is ready to use Mafia-like tactics to threaten an
ex-member if the hierarchy is afraid of their testimony. If the
ex-member does speak, the organization will claim no knowledge and
blames the individual, calling them a criminal when that person
was doing nothing more than following orders under duress.

5. Members of Scientology are induced to confess to acts that, if
not outright criminal, are embarrassing or possibly destructive to
the person's job, marriage or profession, for example,
shoplifting, adultery, masturbation, or drug abuse. The member is
urged to write these down in their own handwriting, under the
guise that it is a "religious confessional" for the member's good.
The truth is that these "confessions" are kept to blackmail and
extort the member should they dare to speak out. The member is
also coerced to sign documents that are self-damaging while
protecting the organization, solely in case the member dares to
leave their control and speak the truth. I know because I watched
this done to others, I did it to others and it was done to me.
That is why I respectfully urge this court to recognize
Scientology's tactics and treat them for what they are: criminal
deceit to defraud this court at any cost.

6. For the past five years since I fled Scientology, I have been
silent because it was my intent to create a new life for myself,
away from their obsessive control, and it required all the energy
that I could muster to do that. About two weeks ago, I finally
became curious as to what was happening within the Scientology
world and I used the Internet to look up Scientology and was
stunned to discover former friends who had also left and the
conflicts being waged in the courts. I contacted one (Stacy Young)
who had been a close friend for many years in the cult who told me
what had been happening, with former members fighting to have the
abuses and the criminality exposed.

7. Because I have intimate and personal knowledge of issues in
this case, she put me in touch with attorney Dan Leipold and I
traveled to his offices in Santa Ana, California. After speaking
with him and others, I realized that this level of criminal fraud
and deceit can no longer continue without opposition. I could no
longer remain silent, regardless of their terrorism. I offered to
tell the court how Scientology really operates with trademarks,
copyrights and the courts. In fact, I am doing this at the risk of
enduring the hate campaign this pseudo-religion will wage against
me, as they have against others, including judges.

8. Let me begin with some basic information about my own
Scientology history: I first became involved with Scientology in
September 1976, in San Francisco. In late 1976 I joined the elite
Scientology paramilitary organization known as the Sea
Organization, also known as the "Sea Org" or the acronym "SO." The
Sea Organization is the actual nexus that controls the Scientology
empire. Sea Organization personnel are authorized to take over and
control Scientology organizations and to demote personnel, move
bank accounts and run the corporation as if the SO personnel were
employees or representatives of that corporation but they are not.
This is true if the organization was part of the "Church of
Scientology" or one of the secular areas such as Bridge
Publications. This is possible because the only personnel allowed
into executive positions in these organization are those who are
in full agreement that the Sea Organization is the commanding
organization. This weeding out process guarantees there will be no
executives who will resist or protect their corporate integrity.
This is how the Sea Organization can operate with impunity, and
continue to claim that it is merely a "fraternal organization."
The Sea Organization is a "fraternal organization" the way the
Cosa Nostra is. 9. Before I was recruited into the Religious
Technology Center (RTC) in 1982, most of my experience was with
Scientology technical material; the actual codified techniques
used within the organization. This gave me considerable time to
become familiar with the material, most of which was written by
Scientology founder L. Ron Hubbard. It was that familiarity that
prompted my promotion to a technical position at RTC.

10. Physically, I was transferred to and lived and worked at what
is known as "Golden Era Studios," near Hemet, California. It is
also known as "Gold" or simply "the base." RTC's presence at Gold
was fully known to all at the base, but was kept hidden from all
others, to try to make it appear that Gold was merely a movie/tape
production studio when really the movie/tape production is nothing
but a front to mask, hide and protect the top of Scientology's
actual power structure so they cannot be served with subpoenas.
(The security system is more befitting a top secret military
installation, with its motion detectors, buried sensors,
high-speed cameras, night cameras, guards on motorcycles, and
barbed wire fences wired to detect anyone touching it etc.)

RTC was at that time the most senior, most powerful and most
influential organization in all of Scientology. All at RTC were
Sea Org members, as are all at the base. But because of RTC's
position, we were the elite at the base. 11. In March 1983, I
became the Deputy Inspector General, External, and a member of the
Board of Directors for RTC, as Treasurer. (The only other board
members were Warren McShane as Secretary and Vicki Aznaran as
President, during this time.) At the time I was appointed a member
of the Board of Directors of RTC I was forced to sign an undated
letter of resignation. This is standard practice with all
Scientology board members and is another means by which the
Scientology corporations are controlled while giving the
appearance of corporate integrity.

12. In that capacity for the next few years, I traveled about the
US and outside of the US on behalf of RTC. I traveled to Germany,
Italy, Australia, the United Kingdom, Denmark, Mexico and Canada,
with several trips to some of these countries. These trips were to
put together an infrastructure that would then interface with RTC
for the purpose of trademarks. I became familiar with the law with
regard to each area, interviewed and approved law firms, and put
the personnel in place that would report to RTC and be our
on-the-ground representatives in dealing with the attorneys etc.

13. When Hubbard died in 1986, there was a power struggle in
Scientology for the next 18 or so months that resulted in
Hubbard's closest and most powerful aide (Pat Broeker) being
removed. The power was taken over by David Miscavige who purged
the organization of anyone who was friendly with Broeker. In
mid-1987, I was removed from my position and put under armed guard
at Happy Valley, a property the organization owns that is a few
miles west of Gold and located deep in the Soboba Indian
Reservation. I assume the undated resignation I provided on being
appointed to the Board was then dated and used to make it appear
that I had resigned, when I had not. After a few months, it was
decided that I would not escape and I was given various jobs at
Gold but kept under watch. My pay was standard Sea Org pay, $24
per week.

14. I should clarify why I (and others) tolerated such treatment
for so long. The ability to tolerate such abusive conditions and
treatment are one of the most basic requirements for promotion in
the Sea Organization and RTC. We were selected and promoted
because we vowed such loyalty and demonstrated it daily. Not
unlike a military unit, it is the ability of the Sea Org member to
take orders, carry out the assignment and to tolerate
self-degrading conditions that ingratiates them to their seniors
and to the system. That was why I was promoted so highly and why I
then tolerated more. Looking back on it, I cannot believe that I
actually tolerated such denigration and such abuse and actually
deluded myself that it was for my good as well as the good of
others.

15. In late 1991, my wife Monika became pregnant and although we
were elated, she was ordered to abort the child. The reason for
the abortion order is that Sea Org members were not allowed to
have children. The order devastated both my wife and me. Our
dedication as Sea Org members clashed violently with our
intentions as parents and we went through a personal nightmare
with me opposing it, to no avail. She got the abortion and
afterwards she was not the same. She was devastated at the impact
of what she did and that was when she told me she wanted to leave.
We fled, with the organization close behind us, trying to find us.
They finally did and convinced us to return so we could "leave
properly."

16. Once they had us again behind the barbwire and watched by
security, my wife was threatened that if we did not sign certain
papers, she would no longer be able to see her father and her
sister, who were both in the Sea Organization.

17. This is another coercive power that the organization wields.
Like a police state, it can order and enforce family members to
alter their relations, and even get them to turn against each
other. Monika and I knew that if the organization said she would
be kept from her father and sister (by control over them), that
she would not again be able to talk to them or see them, let alone
visit. This is called "disconnection" in Scientology. We agreed to
sign the papers and were able to leave.

18. On July 26, 1998, one of the cult's attorneys sent a long fax
to Dan Leipold that is their first not-so-veiled threat to me,
warning me to be silent. The attorney included the document they
prepared for me and that I signed under the conditions I just
described. I am attaching his letter and the documents I was
forced to sign under duress as my first evidence of what this
criminal cult does to silence anyone speaking out. (Exhibit 1). It
does not surprise me, as it is a standard tactic, to force a
person to create or sign a self-damaging document to use when
ready.

19. I have also been privy to the destruction and alteration of
documents to protect the group. On or about April of 1983 I was
present at a meeting, which took place in Los Angeles, California
at a Scientology office called Author Services, Inc. (ASI). ASI
presented itself as the "literary agency" for Hubbard but it was
actually the top of the Scientology empire at that time. All of
Scientology was being directed from ASI in 1982. ASI was where
various Scientology corporations went to receive orders.

20. Present at the meeting was David Miscavige, then the chairman
of the board of ASI, Vicki Aznaran then the Deputy Inspector
General of Religious Technology Center, (RTC) and Lymon Spurlock,
who was "Director of Client Affairs" for ASI. Mr. Miscavige
expressed concern at this meeting that there might possibly be a
raid on Scientology by the IRS. At that time, none of the churches
of Scientology had received tax exempt status.

21. One principle reason why tax exempt status had not been
granted was the IRS's position that Scientology founder L. Ron
Hubbard (LRH) was actually the managing agent of Scientology in
complete disregard of the corporate structure of Scientology. We
knew this to be a fact but also knew that it violated IRS rules
and thus had to be hidden.

22. There was concern that the IRS would obtain the hundreds of
daily, weekly and monthly LRH orders written by Mr. Hubbard and
distributed throughout Scientology. These orders were commonly
referred to in Scientology as "advices" to avoid the appearance
that LRH was actually running Scientology. In fact, LRH was
running Scientology. The principle concern expressed at this
meeting was that the LRH orders or "advices" would be used to name
L. Ron Hubbard as the managing agent of Scientology.

23. Because of an already existing fear that an LRH "advice" might
fall into the wrong hands, these orders from him were written in a
way that we could deny it was from him. His name was not on them.
He was never cited in the dispatch except in the third person.
There was no signature and a salutation in reply was never more
than "Dear Sir." The routing at the top referred to him merely as
"*," an asterisk. However if a person (or an agency) got enough of
these, there would be little doubt that we were in touch with
Hubbard (via ASI) and he was telling us and each corporation what
to do to make him more money.

24. David Miscavige specifically stated that ASI was "already
dealing with the problem", ridding ASI of any documents that would
implicate L. Ron Hubbard as managing agent of Scientology. He
stated that under his directive the LRH orders, or "advices", were
being collected and transferred by truck to a Riverside County
recycling plant where the documents were to be "pulped". This
method of destruction was considered to be better than shredding.
I was also given instructions that I was in charge of purging the
remainder of the Scientology organization of LRH orders. This was
to include Church of Scientology of California (CSC); Church of
Scientology International (CSI); and RTC.

25. Several weeks after this first meeting I attended a second
meeting at the ASI offices concerning the continuing destruction
of Scientology corporate documentation. In attendance at the
second meeting were David Miscavige, Lymon Spurlock, Vicki
Aznaran, Norman Starkey and Marty Rathburn. At this meeting, David
Miscavige for the first time stated that Scientology had been
ordered by a court to produce various documents concerning a
former Scientology member named Lawrence Wollersheim who had a
lawsuit pending in Los Angeles against the Church of Scientology
of California. The court had ordered Scientology to produce Mr.
Wollersheim's entire "preclear" (PC) file.

26. A "PC " file is one of several files kept on members. The PC
file is the file that includes all written records of all
"confessionals" done by the member. This means that it includes
not only the most self-damaging material but it also reflects
every problem the person might have had with the organization,
including complaints. This PC file grows with the person's tenure
in Scientology.

27. Mr. Wollersheim's PC file was several thousand pages in length
and stood as high as a six-foot tall man. Initially at this
meeting it was decided that Mr. Wollersheim's PC file would be
redacted and culled of any evidence or documentation which might
assist Mr. Wollersheim in his lawsuit against CSC. There was also
concern that the materials known as Clear, OT I, OT II, OT III and
NED for OT's (NOTS) would be open to public inspection if Mr.
Wollersheim's files were produced as ordered. Scientologists are
taught that a person could catch pneumonia and die if that person
is prematurely exposed to these "upper level" materials without
first having taken many hours of preparatory auditing. Ultimately,
approximately 50 pages were produced pursuant to the court order.
Mr. Wollersheim's PC file was culled based on a direct order from
David Miscavige.

28. Later, I was informed that a second court order was issued to
produce Mr. Wollersheim's entire file. Faced with the prospect of
having to produce the entire file David Miscavige gave orders that
the entire file simply be destroyed by being pulped.

29. Pursuant to Mr. Miscavige's orders I ordered Rick Aznaran to
take Mr. Wollersheim's PC files to the recycling plant in
Riverside to be pulped. Several hours after I gave the order to
have Mr. Wollersheim's PC files destroyed, Mr. Aznaran returned
and confirmed that the records had been pulped and even showed me
a small bottle of pulped material, saying "Here's what's left."

30. The material that David Miscavige ordered destroyed and which
Rick Aznaran had pulped was the same material that the court had
ordered produced in Mr. Wollersheim's Los Angeles court case
against CSC.

31. In early 1983 I attended a meeting at Scientology's ASI office
in Los Angeles. In attendance at this meeting were David
Miscavige, Lymon Spurlock, Vicki Aznaran, Patricia Brice and Edith
Buchele. The meeting concerned Scientology copyrights. In
particular, David Miscavige stated that Scientology was "in
trouble" concerning the copyright status of the many published
materials of founder L Ron Hubbard. Concern was expressed that
many of Mr. Hubbard's published materials had become 'public
domain" because the materials had not been registered with the
United States Copyright office for many years. David Miscavige
stated that Scientology had failed to register copyrights for
thousands of pages of Scientology material written by Mr. Hubbard.
These records included the numerous policy letters and bulletins
published by Mr. Hubbard. In particular, Mr. Hubbard published
"Policy Letters" (always published in green ink on white paper and
intended as administrative directives) LRH ED's (Executive
Directives) which are used for various topics, (always issued as
blue ink on white paper) and "Technical Bulletins" published with
red ink on white paper covering technical aspect of Scientology
such as Auditing techniques, Policy and Ethics.

32. At the same meeting in early 1983 David Miscavige specifically
ordered Patricia Brice (who at the time was L. Ron Hubbard's
personal secretary and an employee of ASI) to begin the process of
mass copyright registration filings for all of L. Ron Hubbard's
materials. This order was given despite the fact that Mr.
Miscavige was already aware that many of the materials in question
were already in the public domain. Thus, I know from personal
knowledge that in mid 1983 Scientology began a massive program to
register Mr. Hubbard's material with the United State's Copyright
office.

33. Based on my many years of reading and studying Scientology
directives including my time as a "Co-Audit Supervisor" and
"Inspector General Cramming Officer" I became intimately familiar
with the content, form, manner of distribution and publication of
Scientology works and directives including the works of L. Ron
Hubbard. As a Cramming Officer it was my job to insure that those
who employ Scientology "tech" properly adhere to the official
guidelines adopted by Scientology.

34. I was requested by counsel for Mr. Wollersheim to review the
exhibits to BPI's renewed motion for summary judgement. These were
contained in more than 20 banker's boxes.

In reviewing these boxes of exhibits I selected out documents at
random to inspect. The chart below explains the result of my
examination of certain of the exhibits. In examining the
plaintiff's exhibits I compared the alleged LRH originals
submitted by the plaintiff's as exhibits to some early editions of
Scientology compilations which contains the policy issues in
question. I employed a "1st edition" of the Organization Executive
Course, and a "First printing of the Scientology Technical
Bulletins for comparison to what BPI has claimed are the LRH
originals.

35. I have attached hereto copies of various LRH materials that
were published by Scientology in the early 1970's that prove
conclusively that the copy right notices on BPI's purported "LRH
originals" were not present then, but placed on the "originals" at
a later date.

Exhibit Date Issued Copyright Registration Title

B-1287 1954 27
January 1975 The Church of Scientology Creed FACTNet copy bears no
resemblance to original

B-1289 1953,ca.endMay 2 May 1956 (renewal
7 February 1983) LRH PAB No. 2 A Summary of SOP 8A Copyright
notice 1953 Copyright res. for compilation published Dec. 1955

B-1292 1953 ca.end July 2 May 1956 (renewal 7 February 1983) LRH
PAB No. 6 No title Copyright notice 1953 Copyright res. for
compilation published Dec. 1955

B-1293 1953 ca. mid. August 2 May
1956 (renewal 7 February 1983) LRH PAB No. 7 Six Steps to Better
Beingness Copyright notice 1953 Copyright res. for compilation
published Dec. 1955

B-1290 1953 ca. mid June 2 May 1956 (renewal 7
February 1983) LRH PAB No. 3 Certainty Processing Copyright notice
1953 Copyright res. for compilation published Dec. 1955 Exhibit
Date Issued Copyright Registration Title

B-4 2 June 1959 22
December 1987 (renewal 22 December 1987) HCO PL Purchasing
Liability of Staff Members Copyright notice 1959 but original
contains reference to CSI which did not exist until 1981

B-2 2 May
1957 24 December 1985 (renewal 24 December 1985) HCO PL
Dissemination Original offered by BPI is substantially different
from that published as an original in OEC Vol. II 1st Ed. 1970 ;
Copyright notice 1957, registration 1985

B-1291 Ca. mid-July 1953
2 May 1956 (renewal 7 February 1983) LRH PAB No. 5 About PABs

B-1291 BIP original contains no copyright notice. However FACTNet
copy and copy of document published in 1st printing of Technical
Bulletins Vol. I contain 1953 copyright notice. Copyright
registration is 1955 as part of compilation

B-1288 20 July 1956 22
September 1983 (renewal 26 December 1984) Article From LRH to HGC
Staff "How to really split a valance." No Copyright notice in
claimed original

B-371 16 December 1958 12 May 1983 (renewal 22
January 1986) HCOB Extension Course Curriculum BPI original
contains notice 1958, however copy of document published by
Scientology in 1976 in Technical Bulletins Vol. III 1st printing
contains no copyright notice Exhibit Date Issued Copyright
Registration Title

B-59 21 March 1965 28 January 1988 (renewal 9
September 1993) HCO PL Staff Members Auditing Outside PCs BPI
original contains copyright notice 1958, however, copy of document
published in 1970 OEC Vol. I 1st Ed. contains no copyright notice.

B-249 28 April 1973 28 April 1988 HCO PL Good Service BPI original
shows on face it was 1st published Dec. 23, 1968, not claimed date
of April 28, 1973

B-157 2 September 1968 28 January 1988 HCOPL
Chaplain BPI original shows on face 1st appeared as Sea
Organization Flag Order

B-94 24 August 1965 28 January 1988
(renewal 3 November 1993) HCO PL Cleanliness of Quarters and Staff
Improve Our Image BPI "original" contains 1965 copyright notice.
However, "original" references CSI which did not exist until 1981

B-248 27 December 1972 28 January 1988 HCO PL Speed of Service BPI
original shows on face published 1968, not claimed date of 1972
Exhibit Date Issued Copyright Registration Title

B-214 4 January
1971 2 May 1991 HCO PL Competence BPI original contains no
copyright notice C-3 5 February 1958 27 January 1995 HCO PL No New
Charters BPI original contains no copyright notice

B-215 25
January 1971 28 January 1988 HCO PL Squirrel Admin Claimed
original contains 1971 copyright notice. However, also contains
reference to CSI which did not exist until 1981

B-1 25 January
1957 24 December 1985 (24 December 1985) HCO PL Concerning the
Separateness of Dianetics and Scientology BPI original shows on
face not original but Issue II

B-369 25 November 1958 12 May 1983
(renewal 22 January 1986) HCOB Step 6 BPI "original" contains a
1958 copyright notice. However, 1st printing of Technical
Bulletins in 1976 Vol. III contains no copyright notice for this
document Exhibit Date Issued Copyright Registration Title

36. The above chart documents my observations in reviewing the
documents that I selected at random to review. The important
points that I believe the Court should note with reference to
these documents are as follows:

1. Exhibits B-1289; 1290; 1291; 1292 and 1293 contain a 1953
copyright notice. However, the copyright registrations submitted
by BPI are for a compilation published in 1955.

2. Exhibits B4; B-94 and B-215 all contain copyright notices from
the 50's, 60's and 70's that contain notations to CSI. CSI is the
Church of Scientology International, which did not come into
existence until 1981. Therefore, either BPI's "originals" are not
originals as claimed, or the copyright notices were placed on
these documents long after they were published. (Exhibits 2, 3 and
4 attached hereto).

3. Exhibits B-59; B-369; and B-371 contain copyright notices from
1958. However, when these originals are compared to first
printings or first editions of compilations put out by Scientology
in the 1970's, these copyright notices are not present, indicating
that they were placed in the "originals" subsequent to the
compilations being published. (Exhibits 5-7).

4. Exhibit B-2 is substantially different from that published as
an original in OEC Vol. II, 1st Ed. 1970. (Exhibit 8 attached
hereto).

5. Exhibit B-1287. The FACTNet copy bears virtually no resemblance
to the BPI original.

6. Exhibits B-1288; B-214; and C-3. The BPI originals contain no
copyright notice.

7. Exhibit B-1 shows on its face it is not an original but "Issue
II."

8. Exhibits B-248; B-249; and B-157 show on their face they were
published elsewhere prior to the claimed original publication.

37. Based on my knowledge gained as a staff member of Scientology,
including my assignment as "Chief Cramming Officer" and based on
my examination of the exhibits submitted by BPI in support of
their renewed motion for summary judgment, it appears that
numerous "originals" submitted by BPI are not originals at all and
that copyright notices were placed on documents long after
publication back-dating them to the date of publication.

Further declarant sayeth naught.

I declare, under penalty of perjury under the laws of the United
States of America and the State of California that the foregoing
is true and correct. Executed this 27th day of July, 1998, at
Santa Ana, California.

JESSE PRINCE

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