DECLARATION OF KURT WEILAND
			
		I, Kurt Weiland, hereby declare:

		1.	I am a member of the Board of Directors of Church of Scientology

International ("CS1"), a position I have held since 1990. 1 have been an employee of CSI

since 1987.

		2.	I have been informed by the District Attorney that the defendant may attempt

to introduce evidence of the existence of a "fair game" policy and practice within the 

Scientology religion's beliefs and practices.

		3.	I submit this declaration in support of a motion in limine to preclude that

evidence. I will show: (a) that there is no "fair game" belief or practice in Scientology; (b)

the use of the term "fair game" was canceled by Scientology founder. L. Ron Hubbard. 32

years ago because it was intentionally mischaractcrized in a grossly negative fashion to

attack the religion and its adherents unjustifiably; (c) as originally used, the term merely

referred to the fact that certain individuals who had acted to harm the religion were

disqualified from invoking the Scientology ethics and justice system to resolve disputes

they might have with Scientologists; and (d) it is a fundamental principle of the

Scientology religion that Scientologists act ethically and honestly, that they speak the

truth, and that they comply with all applicable civil laws.

		4.	The positions I set forth herein are the position of the Church of Scientology

International, which is the senior ecclesiastical authority in the Scientology religion,

sometimes referred to as the "Mother Church". As such, the positions set forth arc

intended to state the official position of the Church with respect to its religious beliefs and

practices.

		5.	The term "fair game" first appeared in a 1965 policy letter, and was defined

as follows: By Fair Game is meant, without rights of self, possessions or position, and
			no Scientologists may be brought before a Commitee of Evidce or
			punished for any action taken against a Suppressive person or Group [which
			"becomes Fair Game".]

A subsequent writing by Mr. Hubbard, later in 1965, clarified that the term was meant to

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apply to preclude individuals who had acted against the Church from invoking the ethics

or justice system of the Scientology religion.

			By Fair Game is meant, may not be further protected by the codes and
			discipline of Scientology or the rights of a Scientologist.

		6.	Various other writings of Mr. Hubbard made clear that a person who was 

"fair game" was "outside of [Scientology] Justice Codes," and could not invoke any 

Scientology ethics or justice procedures against Scientologists, no matter what offense 

he claims was done to him. It was in this context that the often-quoted phrases "may be

tricked, sued, or lied to or destroyed" "without any discipline" were used, i.e., to highlight

the absolute unavailability of Scientology justice codes to such an individual. It was not, 

never has been, and is not a Scientology belief or practice that any Scientologist should

engage in deceitful, destructive, tortious, unlawful or criminal acts against another, as is

made clear by Mr. Hubbard's writings described below.

		7.	"Fair game" was canceled in 1968 because its use had been distorted and

mischaracterized.. [sic]

		8.	Even for the short time that there arguably was such a practice, it never
		
carried the meaning or had the effect that defendant will attempt to attribute to it. Rather,

the term was used in connection with the right of individuals to gain access to the internal

Scientology justice and ethics procedures, which are used to resolve disputes between

Scientologists. It meant simply that an individual so labeled was not entitled to the

protection of the Scientology system of justice. In this regard, it is similar to the Old

English concept of "outlaw" which was "A person who has been deprived of the benefit

and protection of the law." (Black's Law Dic(ionary, Rev. Seventh Ed. pg. 1128).

		9.	The Scientology ethics and justice system is a privilege and benefit for
		
Scientologists. Scientologists can and do avail themselves of the Scientology ethics and

justice system because they believe it is inexpensive, swift, sane, accurate and based solely

on getting to the truth. One is judged by a committee of his peers whose only task is to get

to the truth of disputes between Scientologists.

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		10.	Scientologists consider this ethics and justice system a major benefit derived

from membership in the religion. To expel a person from Church membership and thereby

withdraw the protection and availability of the religion's ethics and justice system is the

harshest penalty in the Scientology religion.

		11.	The 1967 passage which mentioned "fair game", read in context with the
		
entire body of Scientology scripture, simply denied recourse to Scientology's justice

system for ex-Scientologists who had been ex-communicated from the Church. It in no

way directed or authorized Scientologists to engage in deceitful, unlawful, tortious or

criminal acts against such individuals.

		12.	Precisely because anti-Scientologists attempted to mischaracterize the use of
		
the term, L. Ron Hubbard abolished its use as part of the Scientology religion in 1968

13.	In fact, the scriptures of Scientology are replete with admonitions to its adherents to

build their lives on the foundations of honesty and integrity. As Mr. Hubbard stated in a

technical bulletin titled "Auditor's' Rights Modified," written in 1972: "The road to truth

is begun with honesty." This is a road that all Scientologists, by definition, consider that

they are following.

		14.	Mr. Hubbard's injunction to be truthful covers all aspects of an individual's
		
and organization's activities. For example, he laid down a firm rule for Church of

Scientology staff in official dealings: "Never use lies." ("The Missing Ingredient."

[August 13. 1970]). in a policy directive entitled, "Safe Ground" (October 27, 1974), Mr. 

Hubbard reiterated this point: "l. NEVER SAY OR PUBLISH ANYTHING YOU

CANNOT PROVE OR DOCUMENT; 2. ALWAYS DOCUMENT THE TRUTH TO

OPPOSE LIES." This standard of conduct is not limited to simply those with whom a 

person works with directly but in fact all those with whom one may come in contact in the

community and within society:

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	1. An "auditor" is a Scientology minister who counsels parishioners. The term is derived
from a Latin term meaning one who listens.

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				A country has laws and regulations to coordinate its activities.

				One does NOT seek to get around these or avoid these or find
				loopholes in them. This is COMPLICATED AND
				DISHONEST.

				It is MUCH simpler just to know and obey them. 
				
"Regulations and Laws, Obedience To," 27 October 1973.

		15.	A proper understanding of the religious beliefs of Scientology is that
		
Scientologists should always act lawfully. honestly, and ethically, and that they should

neither lie, cheat, or steal.

		16.	Additionally, it is a fundamental tenet of the religion that Church policy must
		
be in writing to be valid ("in Scientology wwe say, 'if it isn't written, it isn't true"' ["The

Hidden Data Line, April 16, 1965]. The term "fair game" is not in the writings of the

Church and is not Church policy. All valid and enforceable Church policy is published 

and available to parishioners. The "fair game" policy has not been published since its

cancellation in 1968 and is not published in any current volumes of Scientologyy writings.

It is not something that is open to interpretation. It does not exist.

		I declare under penalty of perjure under the laws of the State of California that the
		
foregoing is true and correct.

		Executed this 5th day of October, 2000 at Los Angeles, California


												[SIGNED]
												-----------------------------------
												KURT WEILAND




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