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DECLARATION OF GERALD ARMSTRONG

 

I, Gerald Armstrong, declare as follows:

1. On July 31 and August 1, 1986 my deposition was taken

by attorney Eric Blumenson in the case of Michael Flynn v. Church

of Scientology, et al., No. CV 85-4853-R(Mcx). During his

questioning of me, Mr. Blumenson revealed that the individual

who had filed the complaint against me with the FBI in Boston

in October 1985 was a woman named Mitra Hall. Prior to that time

I had never heard of Ms. Hall.

2. This morning I had business which brought me at

approximately 10:00 a.m. to the MBTA Green Line Auditorium stop

on Massachusetts Avenue in Boston. As I was about to enter the

station to take the train to work, I was approached by a woman

who asked me if I would like to take a "free personality test."

The woman was approximately 30 years old, about five feet four

inches in height, dark haired, light brown skinned, and big-

chested. She carried in her hand a bunch of cards with the words

"personality test' printed on them. Recalling that the complaint

filed against me with the FBI had alleged that I had identified

myself as an FBI agent to an individual handing out personality

test cards at this same location, I asked the woman her name.

She said, "Mitra Hall."

3. I then asked Ms. Hall if she knew who I was. She

said, "No." I asked her if she had ever seen me before. She

said, "No." I asked her a number of times and in different ways

if she was absolutely sure she had never seen me before. She

said, "No" to each question. It was clear that Ms. Hall had never

 

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seen me before. And I had never seen her before, and had never

been to the Auditorium stop nor that part of Boston at any time

before today.

4. I identified myself to Ms. Hall then questioned her

about the incident which had allegedly occurred last October.

She told me that she had been shown several photographs of me

by someone, whom she would not name, in the legal department of

the Boston Scientology organization, and had identified me as a

result of being shown the photos. She stated that she had been

accompanied by Scientology attorney Roger Geller when she went

to the FBI to file the complaint.

5. I told Ms. Hall that she had filed a false complaint

against me, and she stated she was justified "because (I was)

trying to destroy (her) church." She reiterated this charge, and

the charge that my attorney Michael Flynn was trying to destroy

her church, several times. It was clear from Ms. Hall's failure

to recognize me and from what she said that her complaint against

me was false, but that she considered her action in filing the

false complaint laudable because I was Scientology's "enemy."

Following our conversation, which lasted about three minutes, I

entered the train station and traveled to my workplace.

I declare under the penalty of perjury under the Laws of

the State of California that the foregoing is true and correct.

Executed this 12th day of August, 1986 at Boston,

Massachusetts.

[Signed] Gerald Armstrong
Gerald Armstrong

 

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