1                 DECLARATION OF CASAVIUS L. TABAYOYON

 2        I, Casavius L. Tabayoyon, hereby declare and state:

 3        1     I am over 18 years of age and a resident of Riverside

 4    County, California.  I am a member of the Scientology religion

 5    and the Scientology religious fraternal organization known as the

 6    Sea Organization. I am a staff member of Golden Era Productions.

 7    I have personal knowledge of the matters set forth in this

 8    declaration and, if called upon to do so, could and would

 9    competently testify thereto.

10        2.    I am the son of Andre and Mary Tabayoyon. I have read

11    the articles containing statements attributed to my father which

12    appeared on April 12 and 13, 1994 in the London (Daily) (Mirror).

13    I am also aware of other false allegations my parents have been

14    making about our life together in the Sea Organization and at

15    Golden Era Productions. The purpose of this declaration is to

16    set forth the truth with respect to those statements.

17        3.    My parents raised me as a Scientologist and   in the Sea

18    organization. I consider this to be a wonderful way to have been

19    brought up -- in a totally drug-free and ethical environment with

20    people around me dedicated to helping their fellow man. That my

21    parents now choose to desert their religion and make statements

22    that I know to be false is a tragedy. They are telling lies,

23    lies which are directly contrary not only to the observable

24    truth, but to what they have said to me so many times.

25        4.    The picture Andre and Mary are trying to paint of    the

26    lifestyle in the Sea Organization in general and of life at

27    Golden Era Productions in particular are completely different

28    from how things really are. I feel it is necessary that I speak



1 up about it. Obviously, nobody has challenged or investigated 2 Andre's statements, as they would be proven to be total lies. 3 5. Andre tries to make it seem as if the staff of Golden 4 Era Productions are some sort of "slave labor" force that is kept 5 on the property all the time and is not allowed any freedom. He 6 makes the property sound like a "prison camp." This is complete 7 nonsense. The vast majority of the staff do not even live on the 8 property and freely travel to and from work everyday. Before 9 Andre and Mary left here in 1992, we lived together in an 10 apartment in a nearby city. Andre would drive to and from work 11 in his own pickup truck and I would usually ride with him. Most 12 nights on the way home, we would stop for burgers or for a cold 13 drink. On Saturday nights, Andre, Mary and I would go out to 14 dinner--there was a Chinese restaurant we often went to. We 15 often rented videos to watch in our apartment while eating pizza 16 on Saturday night. On Sunday mornings, Andre would frequently go 17 for long drives on his motorcycle in the early morning hours, or 18 go flying in a private plane with a friend of his who is a pilot. 19 6. A couple of months before Andre and Mary left, the 20 three of us took a one week vacation together and drove to visit 21 relatives in Arizona. Approximately six months before that Andre 22 and Mary took a vacation by themselves. Thus, their claims that 23 people here are not free to come and go are just not true. 24 Similarly, when they characterize the working and living 25 conditions here as a prison or slave labor camp, they are not 26 telling the truth. 27 7. Over 750 people work on this property, the vast 28 majority of whom are involved in making films, video tapes and 2
1 cassettes which disseminate the Scientology religion, or which 2 train people how to apply its teachings. The people I work with 3 are dedicated to their religion and do their jobs well and with 4 pride. we enjoy what we are doing. The food served is top 5 quality, and our apartments in town are very nice. I cannot see 6 how anyone who actually sees the facilities here could think 7 differently. In fact, the living conditions of the staff here 8 are much better than where Andre's mother lives. I have been 9 there and have seen it. She lives in a rundown apartment, as do 10 other of his relatives. 11 8. Andre's description of the property here as an "armed 12 camp," his claims that our security guards have automatic 13 weapons--including HK 91 assault rifles--and that we are 14 stock-piling ammunition and gunpowder to make explosives are 15 ridiculous, and frankly, disturbing. The Church doesn't own any 16 automatic weapons, ammunition, gunpowder or explosives and no one 17 here is stock-piling them. I am well aware of the security 18 facilities for the property as my position in the organization 19 includes responsibility for the well being and safety of the 20 staff and property. Our security guards are well trained and 21 courteous. They are trained in first aid and act as volunteer 22 firemen for the local community. The whole reason we even have 23 security guards is that there are millions of dollars of film, 24 video and audio equipment here. Nevertheless, unlike guards at 25 the facilities of other major corporations, our guards do not 26 carry firearms. 27 9. In that same regard, Andre was never the "Head of 28 Security" here, as he now claims. I know the jobs he held and he 3
1 was never a senior executive and certainly never in charge of 2 security. He spent most of his time here as a construction 3 worker, part of a building and maintenance crew. 4 10. Andre claims that facilities at Golden Era Productions 5 were constructed for the exclusive use of certain celebrities or 6 senior church executives. These claims are also entirely false. 7 The Star of California Clipper Ship pool, which Andre says is 8 exclusively used by a select group of people is a good example. 9 I was married on the Star of California, as were at least half a 10 dozen friends of mine, and I have been swimming in that pool 11 many, many times. When the staff get together for a celebration 12 or a party, it is more often than not at that pool and local 13 residents of the area also hold special events there. I also use 14 the exercise facilities Andre claims are only for the use of 15 select people, as does everyone else here. I run on the par 16 course, work out with the weights and use the athletic fields. 17 While I don't personally play tennis, several of my friends 18 regularly play tennis on the court built here. 19 11. On the subject of the exercise facilities, Andre stole 20 another's personal bottled water from the gymnasium, so I know 21 for a fact that he went there himself, and that he knew that 22 other staff here used it. 23 12. The guest apartments that Andre claims were built for 24 Tom Cruise were here before the Church bought the property. In 25 fact, Andre and Mary themselves used to live in them. These 26 guest apartments (referred to as G units) were later renovated by 27 the staff here and are used by many visitors who need to stay 28 overnight. Access is not restricted to one or two select 4
1 celebrities, and never has been. 2 13. I see from the (Daily) (Mirror) article that Andre is 3 now making false allegations about David Miscavige, the Chairman 4 of the Board of Religious Technology Center. On many occasions 5 before he left here, my father expressed to me his respect and 6 admiration for Mr. Miscavige, so I cannot think he believes 7 anything he says to the contrary now. In fact, just a few days 8 before he left, he told me that he thought Mr. Miscavige was an 9 incredibly competent person for whom he expressed a great deal of 10 admiration, which matches my own personal observations about him. 11 14. Mary makes claims about being "forced" to have an 12 abortion. In fact, I know this was not true as she talked to me 13 about it before having the procedure done. She told me that she 14 had unintentionally gotten pregnant, and that she had decided to 15 get an abortion. This was totally her decision and she made it 16 on her own. She went to the clinic alone, and in fact, it was 17 from the clinic that Andre picked her up and they left the Sea 18 organization that day without informing me or anyone else. 19 15. I understand that my parents are being paid to make the 20 claims they are now making about the Church. I am deeply 21 offended that they would have so little respect for their former 22 religious beliefs and their friends that they would make up lies 23 for money, when this is directly contrary both to what they told 24 me they believed in and to the way in which they raised me. They 25 must know what they are doing is wrong and that what they are 26 saying is not true. 27 16. It also bears mentioning that Andre's portrayal of 28 himself is inaccurate. While he was in the Church, he certainly 5
1 wasn't an expert on Scientology. He never held himself out to be 2 one to me, nor did I ever think of him in those terms. In fact, 3 he was known for engaging in conduct that directly conflicted 4 with the ethics and mores of the Sea Organization and was known 5 for extreme outbursts of rage and incomprehensible hatred. I 6 have seen him in this condition numerous times. This sort of 7 conduct is not condoned in the Sea Organization and is contrary 8 to the mores of the group. I used to fear him and was scared he 9 would beat me up, but about three years ago I began standing up 10 to him and instead of cowering in fear, I began to confront him 11 with the irrationality of his actions. However, my mother 12 follows whatever he does and says, and I believe that is so 13 because she is scared by his crazy outbursts. Based upon my long 14 experience in observing his flights of rage and her frightened 15 reactions, it is likely that they are now making these false 16 statements and allegations as a manifestation of his irrational 17 anger and her fear of him. 18 17. It was only because he was in Scientology that he was 19 even tolerated. After all, we in Scientology know that people 20 can be in a bad state and it is our goal in life to help them. 21 For example, my father has told me that he served in the United 22 States Marines and fought in the Vietnam war. While this was 23 before I was born, I have no reason to doubt that he did these 24 things. I have seen him exhibit considerable skill with firearms 25 and with martial arts, so I know that he can be extremely 26 dangerous when he has one of these crazy outbursts. We realized 27 that Andre's behavior was the result of mental and spiritual 28 derangement and on many, many occasions Scientology staff members 6
1 would spend endless hours trying to counsel him. However, the 2 court should not be under the misimpression that it is common for 3 staff members to behave this way. Andre was a major exception 4 and only because of his previous background during the Vietnam 5 war and his experiments with drugs and so forth was he tolerated. 6 In other words, people understood the pressures he had been 7 subjected in his life. 8 18. However, I know that people were becoming less and less 9 tolerant of his violence. I am aware of Andre striking other 10 staff members, such as Jim Meadors, Mats Markowitz and Chris 11 Chaney, and threatening to beat up others. Andre also once told 12 Tom Webb that if he (Andre) was not a Scientologist, he would 13 kill Tom. While he makes up stories for money about his former 14 friends, it is those former friends who were subjected to his 15 abuse. In fact, in my own opinion, Andre would have long since 16 been reported to the police and convicted of criminal charges of 17 assault and battery were it not for the kindness with which 18 Scientologists treat people. To then accuse others of these 19 actions is despicable and factually a lie and Andre knows it. 20 19. After my parents left the Sea Organization, I spoke 21 with them on several occasions. They told me that I was old 22 enough to make my own choices as to how I live my life and that 23 what I did was up to me. These statements by themselves show 24 that what my parents are now claiming about the property is 25 completely untrue. If half of what they now say about the Sea 26 organization and Golden Era Productions were true, they would 27 never have told me it was my choice to remain here. And they 28 certainly did not consider me a "slave," a characterization they 7
1 have placed on not only me but all of my fellow Scientologists 2 who work with me. 3 20. I have chosen to live my life as a member of the Sea 4 Organization dedicated to helping people, and I deeply resent my 5 parents' attempts to make that lifestyle appear to be something 6 it is not, especially since they know that what they now say is 7 false. I know what I am doing and why I am doing it. If my 8 parents are able to throw away their religious beliefs and a 9 lifetime of work for some money, I cannot say the same thing 10 about them. 11 I declare under the penalty of perjury under the laws of the 12 United States of America that the foregoing is true and correct. 13 Executed this @day of May, 1994 at Riverside county, 14 California.
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