                   UNITED STATES DISTRICT COURT

                            FOR THE

                   DISTRICT OF MASSACHUSETTS



LA VENDA VAN                                                       )

SCHAICK, et al                                                     )

                                                                   )

                    Plaintiffs                                     )

                                                                   )           CIVIL ACTION

v.                                                                 )           NO. 79-2491-G

                                                                   )

CHURCH OF SCIENTOLOGY OF                                           )

CALIFORNIA, et al,                                                 )

                                                                   )

                    Defendants                                     )



                   AFFIDAVIT OF CAROL GARRITY



I, Carol Garrity, being first duly sworn, depose and say:



1.    I was a member of the Church of Scientology from April 1975

through July 1980 and during that time I became a staff member and

worked full time for the Scientology Organization from August 1976

through July 1980.



2.    Between November 1978 and July 1980 I was a member of the

"Guardian's Office" of the Church of Scientology. The Guardian's

Office, more commonly referred to as the "G.O." by Scientologists,

is responsible for intelligence gathering, covert operations and

activities, spying and public relations. The Guardian's Office

administers "front" groups such as schools and drug programs which

are designed to make money. I have personal knowledge of the

foregoing matters and participated in various "operations"



                           - 1 -



conducted by the G.O."



3.    The Guardian's Office headquarters in the United States is in

California. However, the Guardian's Office has the power to go

into a local Scientology Church and literally take over any

section of it or the entire local church if necessary. This is

covered in a policy letter written by L. Ron Hubbard, entitled

"The Guardian". There is another G.O. headquarters at the Flag

Land Base in Clearwater, Florida.



4.    The Guardian's Office activities are conducted pursuant to

various Scientology policies including "Fair Game Doctrine" which

states:



     "Fair Game, may be deprived of property or injured by

      any means by any Scientologist. May be tricked, sued

      or lied to or destroyed."



5.    I have personal knowledge that the Scientology organization

has actively and covertly conducted operations against Attorney

Michael Flynn in an attempt to get him disbarred and to destroy

him and thereby eliminate him as a representative of those

individuals victimized by the Scientology organization. Attorney

Flynn was classified as a top "Enemy" of the Church of Scientology

and I was sent numerous "orders" to "attack" him in the news media

with a "black PR" campaign.



                           - 2 -



6.    One such operation occurred between January and July 1980,

when the Guardian's Office conducted a series of covert operations

to infiltrate the law office of Michael J. Flynn by placing a

"plant" whose code name was "Oscar" and whose real name was

William Broderick. I am aware that other "operations" were

proceeding against Attorney Flynn to get someone "inside" his

office.



7.    Prior to July 18, 1980, as an Assistant Guardian, I had

numerous conversations with Attorney Steven Burris in Las Vegas,

NV, who represents the Church of Scientology there. Conversations

related to the intent of the Church to find some basis to bring

law suits against Michael Flynn and those in his office and also

law suits against LaVenda Van Schaick, Ernest and Dell Hartwell

and Eddie Walters. These lawsuits were to be brought against

these people pursuant to the policy of the Church of Scientology

which states that lawsuits are to be used to harass and attack

people who seek to expose Scientology.



8.    In one of my conversations with Attorney Burris in July 1980,

he asked me to sign an affidavit in connection with a proposed

suit against Van Schaick, the Hartwells and Kevin Flynn. I told

him that I could not verify the information in the affidavit.

Attorney Burris told me that he was aware of the covert agent used

by the Church of Scientology. Attorney Burris asked me if I was

"compelled to tell the truth" in the affidavit. I told Attorney



                           - 3 -



Burris that I had always told the truth and he said that he would

get someone else for the affidavit.



9.    The Guardian's Office devised a covert operation to stop

Attorney Flynn's client, LaVenda Van Schaick, from speaking out

against the Scientology organization. The program was code named

"Shake and Bake" and pursuant to the program, G.O. agents,

including Gary Klinger, were sent to Massachusetts to interrogate

Ms. Van Schaick and to use various means to have her divorce her

husband and fire Attorney Flynn, including the use of her auditing

information.



10. The Guardian's Office perused Ms. Van Schaick's auditing

files, which contained the most personal and intimate details of

her life, and extracted confidential disclosures for the purpose

of using it against her in "Operation Shake and Bake".



11. The practice of reviewing confidential auditing files and

extracting private and intimate details of an individual's life is

a common Scientology practice. The data gleaned from an

unsuspecting individual's file is commonly transmitted to "Flag"

in Clearwater, Florida and to the California headquarters for



extortion and blackmail. This practice occurs regularly. I have

personal knowledge of auditing information being sent to

Clearwater and California for this purpose.



                           - 4 -

12. On one specific occasion, I received a Guardian's Office

order concerning Tonja Burden's auditing information. I was sent

from the Guardian Office's main headquarters in Los Angeles, a

document from Tonja's preclear folder called a "Wants Handled"

list. This was a list of things that Tonja wished to improve

herself with through auditing. I was also sent a list of "overts"

and "withholds" which means transgressions against L. Ron Hubbard,

Scientology, etc. The purpose of a person writing their "wrongs"

is the general concept of confession. This list is only to be

used to help the person face their errors, wrongs, etc. and

thereby free the person by having "confessed". These lists are to

be held in strict confidence. I was sent a huge stack of Tonja's

"overts and withholds" write-ups to take to the Review Journal

newspaper, along with the auditing list from her preclear folder.

The purpose of the above orders were to disgrace, embarrass,

humiliate Tonja and make her lose her credibility with the public

and the press, as she had filed a lawsuit against Hubbard and

Scientology and according to Scientology policy, anyone who does

this is an evil person called a "suppressive person" and must be

dealt with accordingly. I carried out my orders, however, her

auditing information was not printed in the papers, as the news

media thought it was a disgusting breach of privacy, which it was.



13. When I was first introduced to "auditing" or counselling in

the Church of Scientology, I was told that the information or

"confessions" I gave to my auditor would be held in strict



                           - 5 -



confidence and that the only persons who had access to my auditing

files were the auditor and the "case supervisor" - the person in

Scientology who "programmed" the cases and decided what auditing

the person should have and buy. This representation is made to

anyone who undertakes "auditing" and it is shown to them in

writing in the "Auditor's Code".



14. After I joined staff at the Las Vegas Organization, I had

many occasions to witness that many other people within

Scientology had access to the auditing files. These people could

go to the technical division and take the folders and read them

and study them and send information from the folders to other

Scientology executives if they were ordered to, or chose to do so.

This included information being sent to the Church of Scientology

of California in Clearwater, which was regularly done. It was a

regular practice in the Church of Scientology that the Guardian's

Office had access to any person's auditing folders at any time the

G.O. chose to take them.



15. The Guardian's Offices throughout the United States including

Clearwater, Florida are run by the United States Guardian's Office

which is part of the Church of Scientology of California. The top

executives and management are at the Church of Scientology of

California, both in Clearwater, Florida and Los Angeles,

California.



                           - 6 -



16. The routine use and circulation of auditing information is

done throughout the United States and outer "missions" send

information from a person's auditing folders to the nearest "Class

40rg" for ethics use or intelligence use in the Guardian Office

intelligence files.



17. When "missionaires" from the Church of Scientology of

California would come to Nevada, we were under instructions to

give them full back-up and cooperation and this included revealing

to them personal information about Scientologists and their

auditing folders and intelligence folders, if needed and

requested.



18. During executive meetings at the Church of Scientology, on

many occasions the executives would sit and discuss information

about staff members and public-paying person's auditing

information.



19. While on staff in the organization, I was in charge of the

division that sold all the auditing and training and books and I

was routinely given information from people's auditing folders so

that I could get them to buy more and more auditing. This was a

standard practice and this information would also be given to

"indicate" to the potential buyer what auditing they should buy

next, to "cure" whatever "insanity" it was they were trying to get

help with.



                           - 7 -



20. All of the above actions uniformly betray the trust that a

person gives to Scientology and their auditor when getting

auditing, and this creates a terrible fear about the possibility

of leaving Scientology and having your innermost thoughts,

feelings, desires, actions about yourself and others revealed to

anyone including your parents, spouse, relatives and the news

media.



21. When I thought of leaving Scientology after I realized I had

been tricked and lied to, these actions had me terribly fearful

that this type of blackmail would be inflicted on me.



22. I left the Church of Scientology on July 18, 1980 after being

a staff member for approximately four years. I had become upset

and in fear when I learned that the top leaders of Scientology had

been convicted of felonies in late 1979 and I did not agree with

their conduct of breaking and entering, harassing enemies of the

Church, spying on ex-members and other enemies of the Church and

trying to infiltrate enemies and all the other unlawful and

underhanded conduct conducted by the Church.



23. I had also been told that the alleged crimes top Church

leaders had committed were false and that the people were innocent

and being framed and suffering from "religious persecution". It

was uniformly stated to all Church members that the Church never

broke the law and didn't harass critics or enemies.



                           - 8 -



24. I hired an attorney in Las Vegas, Nevada to represent me and

my husband when we left Scientology so that we would have in

writing and on record the exact date we left and also to demand

the unused monies on account at the various organizations. My

attorney had a letter hand-delivered to the Church of Scientology

of Nevada on July 21, 1981 advising them of our intentions and

that any attempt to contact us would result in a restraining order

as we wanted no contact from any of them.



25. On day later, Maddie Reese, a top Guardian's Office staff

member from Los Angeles called Jane Peterson's house, another

former G.O. member, asking for me. Jane advised her that I was

not taking any calls from any of them and not to call back.



26. I began to receive telephone calls at all hours of the day

and night with people either being silent or hanging up.



27. My husband and I then received a new unlisted telephone

number and shortly thereafter, the calls began again. Sometimes

whoever was calling would ask for a person unknown to me and I

would advise them of that and they would call back over and over

and ask for the person.



28. My husband and I moved to a house on February 1, 1981 and

received a listed number and the calls continued.



                           - 9 -



29. In mid-March, 1981 I went home to discover my home had been

entered, every door in the house opened and my dog had been put

outside in the backyard. The sliding glass screen door had been

pulled off and was laying across the porch. The police came and

could not find a forced entry and a report was not filed.



30. My husband and I filed a complaint against the Church of

Scientology, L. Ron Hubbard and Mary Sue Hubbard in Federal Court

in Los Angeles on July 1, 1981.



31. I arrived home after work on my wedding anniversary, July 21,

1981, to find that my home had been broken into and my husband's

sports bike had been stolen. Said bike was valued of

approximately $2,000.00. The fingerprint people could find no

prints other than one partial footprint in the backyard and that

an oily substance had been sprayed on the windows, sliding glass

door and door knobs to apparently cover prints. A few days later

we discovered my husband's stereo turntable missing and again

found the oily substance.



32. I began receiving phone calls from a girl asking "are your

parents there"? I would say she had the wrong number but she

would continue to call back. This was very upsetting as I have

never recovered from my parents' deaths and this was one of the

main things Scientology was supposed to help me with in my

auditing (counselling).



                          - 10 -



         Later the same girl started calling and asking for my dad.

Finding my father dead and the related circumstances of his

illness and his death has always been very hard for me to accept

and I revealed this whole situation over and over in my auditing

in Scientology.



33. To this day I still receive calls where the person either

remains silent or hangs up when I answer. These seem to occur

shortly after I arrive home from work, even after I work overtime.



34. On July 28, 1981, exactly one week after the July 21, 1981

break-in, I went home to find my home had been broken into again.

This time it was totally ransacked, drawers dumped, closets gone

through and basically a total mess. This time the back bedroom

window had been broken out. We could find nothing stolen on this

occasion. The same officer who had arrived the other two times

came again this time and filed a police report.



35. On September 29, 1981, again I went home to find that my home

had been broken into. The side door screen had been ripped out

and the window opened and this was the point of entry. This time

all my jewelry, wedding rings, keepsakes from my mother and

father, my father's keepsakes from the war and college were all

stolen. My husband's camera equipment was stolen along with some

money and other things. The house had been totally and completely

ransacked, every drawer, box, closet in the house dumped on the



                          - 11 -



floor. The back rooms were also ransacked and everything dumped.

My briefcase with all of my Scientology papers and correspondence

from my attorneys, lawsuit information had been gone through. The

fingerprint people found no prints, however, did take pictures of

the rooms and the briefcase. I have talked to my neighbors and

this is not happening to them. The police have no leads and none

of the stolen goods have shown up around town that they know of.

The police do not know of another house on our block that has been

broken and entered this many times in this short a time period.

The previous owner of the house resided there for approximately

twelve (12) years with only one minor occurrence. My husband and

I have lost money due to insufficient insurance coverage on the

jewelry which we were not aware of and we have had to invest in

solid doors, bolt locks and other locks and have ordered iron bars

for every window in the house. The last three break-ins have all

occurred on a Tuesday, starting with our wedding anniversary.



36. Nothing like this ever happened to me before I left

Scientology in July 1980.



37. The psychological damage done to me while in Scientology

combined with the above harassment, break-ins, and strange

occurrences have caused great mental stress and upset.



38. My friend, Jane Peterson, who was also a Guardian Office

staff member and left Scientology, has received numerous death



                          - 12 -







threats, both oral and written, since she left Scientology and

this is very upsetting and frightening to me also.



39. I am aware that many similar operations were conducted

against Tonja Burden while I was working for the G.O. I am aware

that a G.O. agent, Bill Broderick was placed in a position to spy

on Tonja Burden and that the G.O. acquired an apartment in Tonja

Burden's apartment building to spy on her and harass her. This is

common practice of the G.O. against its enemies.



         Signed under the pains and penalties of perjury this 21st day

of May, 1982.



                            Carol Garrity



SUBSCRIBED AND SWORN TO BEFORE ME

THIS 21ST DAY OF MAY, 1982.



(CARRIE B. STEWART)

NOTARY PUBLIC



                          - 13 -

