                   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 -
