UNITED STATES DISTRICT COURT
                     CENTRAL DISTRICT OF CALIFORNIA

CHURCH OF SCIENTOLOGY                  Case No. Cv 91 6426 HLH (Tx)
INTERNATIONAL, a California
non-profit religious                   DECLARATION OF MARY TABAYOYON
organization,                          RE: MOTION FOR COSTS
Plaintiff,                             Date:  APRIL 4, 1994
                                       Time:  10:00 a.m.
VS.                                    Courtroom: 7

STEVEN-FISHMAN AND UWE GEERTZ,
Defendants.


DECLARATION OF MARY TABAYOYON

[deletia]
11. While at the base, I knew of several instances of staff getting pregnant and being coerced to get an abortion. Some instances were relayed to me by the victims themselves and others were relayed to me by another. In two instances, the couples to keep their child despite extensive course of ethics method and thus were banished to a failing Class IV organization. In every instance they had to go through ethics handling designed to prevent them that it would be far more advantageous to Scientology and the Sea Org for each of them to have an abortion. Some of these women went through extensive pressure methods to convince them to have an abortion. The severity of the Ethics handling was directly proportional to the prospective mother's desire and insistence to keep the child. I myself got pregnant in 1993 and gave up my child due to my greatly misguided obligation and dedication to the Sea Org.

[deletia]
16. A friend of mine, Betty Hardin, who works in the treasury division of Golden Era Productions, told me that she used to transport the pregnant women at the base to Riverside, California for their abortions. For about a year, she transported women almost weekly to the Planned Parenthood Center, in Riverside, so that they could have their abortions and follow up check ups that were needed. She said it just became routine. Pregnant Sea Org members were sent to the Planned Parenthood Center to get their abortions. When they returned to the base they went to Ethics.

[deletia]
23. The following are the brief stories of women I knew who had abortions after undergoing coercive ethics sessions and being threatened with exile to a Class IV organization. Because this topic wasn't something that we were supposed to talk about, for the sake of Public Relations, within and outside the Base to protect the women involved from retribution and to preserve their privacy, I have not given their names.

A. Case I: She was my friend and also worked in my department at the time of her pregnancy and abortion. She appeared very upset about it and really wouldn't talk about it at first. I got her to talk about it one day when we were alone. She said she would have loved to have kept her baby but after she got through her ethics cycle (which I remember lasted for at least a week) she realized she wasn't ready to have a child. (She was 20 years old). She said her husband was completely thrilled she was pregnant and wanted so much to keep the baby. He was very adamant on keeping the baby. But after the ethics cycle he looked at the fact that he would probably never be able to come back to the base and he would lose his beloved job and position in Gold. He would have to go to a Class IV Org. At any rate, the ethics actions convinced them to be "good Sea Org members" and abort the child so they could stay "On Purpose" in the Sea Org. "On Purpose" in the Sea Org just means you are being and doing what is needed and wanted in furthering the purpose of the Sea Org. 1 (Note: I will later explain the coercive methods of the ethics techniques in Scientology).

B. Case II: Her husband worked in the same area I did at the time of her first pregnancy. He confided in me as a friend, that his wife was pregnant and had decided to keep the baby again! She had been talked out of it once already by ethics but now decided again to keep it.. I talked to her later and asked her if she was pregnant. She said yes and that she was going to keep it. She said it very adamantly. I said good. We discussed the reference in Hubbard's book, Dianetics. the Modern Science of Mental Health, where Hubbard it very clear that he is against abortions. (See Exhibit 2) She was clearly glad to have someone on her side. Sometime later, I heard she went ahead and had the abortion. She also landed on the Rehabilitation Project Force ("RPF"). The RPF is basically a prison camp in the Sea Org. Some months later, I was told she got pregnant again. The fact she became pregnant against while on RPF is remarkable because RPFers' living quarters are segregated from those of other Sea Org members on the base (including spouses) and by her husband was under guard because he was believed to be security risk during her incarceration. This time rather than submit to an abortion she successfully escaped from the base and never returned to the Sea Org. We later found out that she went to England and had her baby there. I read the letter Tina sent her sister. She had sent pictures of her beautiful baby girl. She was a very proud mother and very much in love with her baby.

C. Case III: I was told that sometime in 1986, Case III got pregnant. It was a huge flap because she had always, up to that time, been a top Commodores messenger (meaning L. Ron Hubbard's messenger). She and her husband were very determined to keep the baby. She was put through very extensive ethics, with heavier and heavier threats and penalties until She finally submitted and had her abortion. Around 1990, I saw that he had gotten pregnant again. Coincident with her pregnancy I saw her off post and only doing manual labor. Her husband told me that they were determined to keep their baby. Months later they both successfully escaped. They have not returned to the Sea Org, and I understand that she and her husband have been blessed with an adorable son.

D. Case IV: I was told she was pregnant. She went through Ethics Procedure and had an abortion.

E. Case V: She appeared to be going through hell. She often looked as though she'd been crying. She often looked to be in a state of emotional collapse. I tried to be extra friendly and tried to get her to talk, but she just put on a smile and changed the subject. She and her husband were taken off post and put through extensive ethics handlings because they were determined to have the baby. Then one day I saw them both looking happy and back on post. I asked the husband about what had happened with their baby. He said they had both gone through the lower ethics condition formulas and came out of "Doubt", and she had gone ahead and gotten an abortion. Months later I saw her looking like she was in shock and mentally destroyed after being thrown in the lake with about 6 other Qual staff for not making a target of what they were assigned to accomplish that day. She later blew with another man who was also on staff in the same division.

[This is just a short extract. Many more details are given in the full affidavit.]