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    Armstrong is a former clerk for the Church of
Scientology of California who, as part of his duties, was
entrusted with the care of thousands of pages of personal
records belonging to L. Ron Hubbard. In December 1981,
Armstrong left the Church and took with him more than
10,000 pages of records belonging to Mr. Hubbard and the
Church. This included 5,000 pages of original documents
for which no copy was left behind.

    As the custodian of confidential Church papers,
Armstrong had a fiduciary responsibility not to disclose
these documents to individuals outside the Church. In
breach of this obligation, Armstrong loaned the documents
to one Omar Garrison, an author who at one time had been
retained to write a biography of Mr. Hubbard, a project
which fell through. Armstrong gave these documents to
Garrison not to assist him in writing the biography but to
enable Garrison to deliver them to attorneys representing
litigants involved in suits against the Church.

    In April 1982, Armstrong also made contact with
Michael J. Flynn, who was the lead attorney in more than
a dozen lawsuits against the Church. Armstrong showed
Flynn two private archival documents. Thereafter, from
May until August 1982, Armstrong continued to give stolen
documents to Flynn for use in Flynn's cases against the
Church, even though the litigation did not .involve
Armstrong. Ultimately, Armstrong gave Flynn thousands of
documents, including original and private Navy records and
diaries of Mr. Hubbard from the 1940s.

    On May 26 and May 27, 1982, the Church wrote to
Armstrong demanding return of all the stolen documents,
but Armstrong denied having them. Subsequently, however,
Armstrong admitted that he indeed had possessed the stolen
documents on those dates.

    The Church sued Armstrong for the return of the
documents. Trial began in the California Superior Court
in May 1984. The Court received the testimony of
Armstrong and his witnesses, many of whom were clients of
attorney Flynn in other actions against the Church. These
witnesses for Armstrong were permitted to testify as to
Armstrong's purportedly imperiled state of mind. The
Court did not permit the Church to present any of its own
witnesses to rebut the testimony of hostile witnesses
about Armstrong's alleged "state of mind."



    Judge Paul G. Breckenridge also heard " evidence"
from Armstrong consisting of distortions, half-truths, and
outright falsehoods, amounting to a justification defense
that Armstrong had stolen the documents to protect himself
in the event of "retaliation" by the Church. The result
was a negative decision for the Church.

    Since the case was heard, Armstrong has adopted a
degraded life-style and developed some odd financial
ideas. He is the self-proclaimed founder of the
"Organization of United Renunciants." In November 1992,
the Marin Independent Journal attempted to explain
Armstrong's philosophy of life in an article entitled "Is
money the root of problems-" The story featured a
photograph of an apparently naked Armstrong, eyes closed
and smiling, sitting in a lotus position embracing an
enormous globe.

    According to the article, "Gerald Armstrong has an
idea for dealing with the national debt -- write it off.
Forget it. It doesn't exist."

    "It's that easy.

    "The novel prescription for fixing the fiscal fiasco
is only part of Armstrong's larger message that money
should be abolished ... Armstrong can count only a handful
of friends as converts, but he is trying to get the word
out. Detailed proposals have gone out to Bill Clinton,
Ross Perot and Pete Wilson (no one has tapped him for an
economic advisory post just yet). He has also written to
the New York Times and other mega-media.

    "Ted Koppel has not called."

    Armstrong's ideas include "no more pay checks, no
more loan payments, no more taxes, and forget that $20 you
owed your brother-in-law." SECTION 1

    Today, Armstrong is hooked up with Cult Awareness
Network, which is primarily a referral agency for those
who engage in the illegal activity of kidnapping adults
for the purpose of forcibly persuading them to abandon
their religious beliefs. In November 1992, Armstrong
attended CAN's convention in Los Angeles. He has the ear
of Priscilla Coates and appears to be on excellent terms
with CAN's leadership.

Armstrong Plotted to Take Over Church Assets

    Since the trial, the Church has discovered
new evidence which was completely unavailable in 1984.



This evidence shows conclusively that Armstrong's
"justification" defense was a sham and a fraud. He was
not remotely in fear of retaliation by the Church and was
actively plotting the Church's downfall.

    Armstrong considered the materials he had stolen
useful not only as a lever against the Church and Mr.
Hubbard in ongoing litigation with Flynn's clients, but he
also sought to use the materials in pursuit of his plan to
undermine the Church for his own financial benefit.

    As part of his plan, Armstrong actively sought out
Church staff members who would be willing to "defect" and
assist him in discrediting Church leadership. After
leaving the Church, he contacted Church member Daniel
Sherman to enlist Sherman's aid in attacking the Church.
Sherman, without Armstrong's knowledge, consulted Church
staff for advice. It was decided that the Church would
obtain authorization from the Los Angeles Police
Department to make "undercover" videotapes of Armstrong's
conversations with Sherman and any other Church dissidents
or defectors.

    The police authorized the investigation and
videotapes, at which point Sherman embarkedon an effort
to ascertain the full extent of-Armstrong's intentions.

    Sherman informed Armstrong that a group of staff
members who were dissatisfied with Church management might
be interested in working with him in his efforts to
undermine the Church. This wholly fictitious group was
dubbed "the Loyalists."

    Sherman enlisted the aid of two other persons, David
Kluge and Mike Rinder, who agreed to pose as "Loyalists"
and meet with Armstrong. Kluge assumed the code name
"Joey," and first met with Armstrong in the late summer of

    Armstrong told "Joey" that part of his plan was to
use the auspices of the Internal Revenue Service to attack
the Church. Armstrong wanted "Joey" to plant in the
Church's files the documents Armstrong would fabricate, so
that Armstrong could tell the Criminal Investigation
Division (CID) of the Los Angeles IRS office to conduct a
raid and find the "incriminating" documents. He reassured
"Joey" that he would be able to create the needed
documents "with relative ease" since he had done "it for a

    Armstrong also explained to "Joey" how he intended
to go about forging the new documents, based on his



ARMSTRONG: "So it seems to me that the use of the
communication lines, I don't know maybe you guys are using
them, but it seems to me that you don't have a way of
printing anything to get an issue on the lines, used for
anything. Right? I'm saying that I can do it. I can
type those goddam things and duplicate them and make them
look exactly the same. You can't, you would not be able
to tell the difference."

    Armstrong also made it clear that he had developed a
personal program intended to undermine and eventually
destroy the Church. His goals were to oust the current
management of Scientology, to obtain an advisory position
within the restructured Church by becoming a consultant to
the "Loyalists" and to plunder the Church for his own
financial gain. His program to remove current Church
management included the filing of a civil suit, based on
evidence that he would manufacture. In a conversation
with another co-conspirator, who, unknown to Armstrong,
was still faithful to the Church, he insisted that the
suit could be launched based on manufactured allegations.

ARMSTRONG: "They can allege it! They can allege it!
They don't even have - they can allege it!"

MIKE: "So, they don't have to -- like, they don't have to
have the document sitting in .front of them, and then.

ARMSTRONG: "I'm f-king saying the organization destroys
the documents . ...!"

MIKE: "The point -- the point I'm trying to get across is
that that's not criminal. That's the -- that's the civil
complaint in there and that would have to be proven."

ARMSTRONG: "Show me the lines you're talking about."

MIKE: "Well, it's over here."

ARMSTRONG: "Where are the -- we don't have to prove a
goddam thing. We don't have to prove sh-t. We just have
to allege it. SECTION 2

    At other meetings between Armstrong and his
"co-conspirators," Armstrong described in detail his plans
for bringing about the collapse of the Church so that he
and the other "Loyalists" could move in and take over.
Armstrong's goal, as revealed in his own words on
videotape, was to overthrow existing Church management and
to set up in its place a new set of Church executives who
would settle all of the civil damages suits brought



against the Church by the attorneys representing
Armstrong. His plans included wresting control of the
Church, planting forged incriminating documents in Church
files, to be discovered by a government raid, and
blackmailing a senior Scientologist executive through
attempted sexual entrapment. SECTION 3

    In sum, Armstrong's plans consisted of:

A) Stealing documents from the Church to serve as
models for forgeries. SECTION.4

B) Plotting the forgery of false incriminating
evidence in Church files. SECTION 5

C) Orchestrating a coup in which agents of Armstrong
and the U.S. government would take control of the Church
of Scientology from its lawful management; SECTION 6

D) Suborning perjury in order to keep his conspiracy
under cover. SECTION 7

Armstrong also worked closely with Michael Flynn and
two members of the IRS CID, A1 Lipkin and A1 Ristuccia.
In late summer or early fall of 1984., Armstrong contacted
Sherman and explained that he and his IRS contacts had
come up with a plan to create false documents and plant
these on Church premises, where they would be seized in a
CID raid. According to Armstrong the IRS agents wanted
the "Loyalists" to plant covert electronic bugs in Church
offices. Armstrong offered eavesdropping and special
photographic equipment.

    Armstrong informed "Joey" that the " Loyalists" would
be placed in the federal witness protection program and
would receive tax-exempt status in exchange for
participating in the covert operation.

    Armstrong instructed "Joey" how to lie under oath
about their plans to disrupt Church management. Armstrong
wanted "Joey," if deposed, to say that he and Armstrong
had merely discussed a "global settlement" of Church

ARMSTRONG: "OK, what are our conversations, should it come
down to it?"

"JOEY": "What do you mean?"

ARMSTRONG: "What do we talk about? You're deposed. You
walk out there, and there's a PI hands you a paper, saying
you're deposed, Jack, and not only that, you're out of the
organization. And what do you say in deposition. Well



Armstrong and I talked about this, and he had a whole
bunch of ideas about how to infiltrate the communication
lines and spread turmoil and disaster, you know. What are
we doing here- That's my question, before I tell you my
ideas on documents."

"JOEY": "Well, what I got is basically -- Loyalists gotta
-- we gotta move -- we've got the suit coming up and I
guess we need other lines to get stuff going . ..."

ARMSTRONG: "OK. So as far as the doc ... Let me just say,
ah, you and I get together, we get together because we
have a goal of global settlement. You have felt that the
turmoil and abuses and so on have gone on too long ...
Hence we get together and discuss things. We have not
discussed anything about a destruction of the tech, or
Scientology is bad, or anything like that. Are we
agreed?" SECTION 8

    During one meeting with "Joey," Armstrong's alleged
claim that he "feared" Church retaliation was revealed as
a complete falsehood.

" JOEY": "Well you're not hiding!"


"JOEY": "You're not hiding."

ARMSTRONG: "F-k no! And ..."

"JOEY": "You're not afraid, are you?-"

ARMSTRONG: "No! And that's why I'm in a f-king stronger
position than they are!"

"JOEY": "How's that?"

ARMSTRONG: "Why, I'll bring them to their knees!"

    New evidence of Armstrong's fraudulent intentions
was revealed in a declaration of November 18, 1991, in
which he admitted that he never intended to stick to the
terms of the settlement agreement he signed with the
Church in 1986. In his declaration, Armstrong asserted
that he had read and understood the settlement agreement,
but that he "put on a happy face" and went through the
charade of signing it even though he told his lawyers that
he never intended to abide by its terms. Armstrong's
stated reason for signing the agreement in the full
knowledge that he would violate it later is so that he
could receive the "financial wherewithal". to "get on with
the next-phase of [his] life." SECTION 9



Armstrong's motives were money and power. This is
also shown by a letter to Church attorney Eric Lieberman
on June 21, 1991. Armstrong wrote that he had been asked
to testify against the Church in a case in South Africa.
He laid out specific terms for the settlement of that
case. SECTION 10

    The Church later appealed the Breckenridge judgment
and a decision was issued by the Court of Appeal in 1991.
The Church had sought to introduce evidence showing
Armstrong's attempts to organize a conspiracy to bring it
down, but the Appeals -Court stated that it could not
accept the new evidence because it had not been a part of
the trial record. The Court's decision upheld that of the
lower court, but stated that Breckenridge's negative
comments about the Church were to be taken to indicate
Armstrong's state of mind at the time he stole the
documents, and not for their truth.

    Armstrong's state of mind is illustrated by various
"literary" writings authored by him, none of which more
clearly demonstrated it than a document now known as the
"pig letter," in which Armstrong purported to describe a
dream. SECTION 11

    All the documents Armstrong stole have now been
returned to the Church. As mentioned above, Armstrong
never intended to abide by the terms of the agreement,
which included staying out of other court cases involving
the Church. Armstrong meddled in these and tried to
prejudice their outcome. So, in 1992, the Church filed a
new suit against him for breach of settlement. The Court
entered an injunction preventing Armstrong from violating
the settlement agreement by assisting anti-Church
litigants. SECTION 12

    During the trial in 1984, Armstrong had made
numerous false allegations about L. Ron Hubbard,
pretending to the judge that while in the Church, he had
thoroughly researched Mr. Hubbard's life. However,
Armstrong's incompetence as a researcher is well
documented. Ironically, it was Armstrong's lack of
research into the various facts and incidents regarding
Mr. Hubbard's life that led him to his false claims.

    In the court transcripts, Armstrong admitted to his
own incompetence as a researcher. While being
cross-examined concerning his "research" regarding L. Ron
Hubbard's career as an officer in the Navy during World
War II, Armstrong stated the following about himself:

1. He was never trained in how to research a




    2. He never searched out and obtained official
documents from any agency of the United States government.

    3. He was not aware that there was an agency of the
United States Navy that kept records of ships.

    4. He never attempted to find out what data the
Naval Historical Center had on the subchaser 815, the ship
under the command of L. Ron Hubbard during World War II.

    5. Armstrong concluded that Hubbard was not a
Commander of a squadron of Corvettes as he did not do the
necessary research to locate the documents in Navy files
which established that Hubbard was in command of a
squadron of Corvettes (English term for subchaser).
Armstrong was not even aware that the initials SC stood
for Submarine Chaser.

    When questioned during the trial on evidence
substantiating Mr. Hubbard's combat record, Armstrong
admitted that he merely "went through some books on the
subject. But that was it. I never went to D.C. And I
obviously never checked the sources that whoever did this
research was; able to check. So I stand corrected." SECTION 13

    Armstrong also challenged Mr. Hubbard's claim that he
(Mr. Hubbard) had been made a blood brother of the
Blackfeet Indian tribe. Yet just recently that nation
celebrated Mr. Hubbard's 70th anniversary as a blood

    A reliable account of Mr. Hubbard's career in the
Navy is given by L. Fletcher Prouty, former senior U.S.
intelligence officer with the Pentagon.

    Mr. Prouty, who joined the Army just a month before
Mr. Hubbard joined the Navy, is experienced in reading
and understanding military and intelligence records.
There is an intelligence process called "sheep dipping,"
wherein additional or cover files are created which mask
the true activities of the intelligence operative. Mr.
Prouty's knowledge is based on firsthand experience in
creating such files.

    His analysis of Mr. Hubbard's files shows that
there are at least two and more likely three separate and
different files in existence: a "false" file created by the
Navy; a personnel file: and a file which contains Mr.
Hubbard's true activities as an intelligence officer. It
is this last file which appears missing and therefore



there is an incomplete record of Mr. Hubbard's career.

    Detailed examples are provided in Mr. Prouty's
affidavit. SECTION 14

    Regarding Mr. Hubbard's medical history, Mr.
Prouty points out that Mr. Hubbard's Notice of Separation
paper indicates he was awarded the Purple Heart twice.
The Purple Heart is awarded only to those wounded in

    Another document from the U.S. Naval Hospital in
Oakland covers Mr. Hubbard's condition following the war:

    "Eyesight very poor . ... Lame in right hip from
service connected injury. Infection in bone . ... All
service connected."

    In sum, Mr. Hubbard's past is exactly what he
stated it is.

    Mr. Hubbard's achievements completely belie
Armstrong's allegations. Through hundreds of books and
literally thousands of articles and lectures, L. Ron
Hubbard communicated and taught the methods which today
are used by millions to improve their own lives and the
lives of those around them. His career spans more than 50
years during which he produced more than 530 published
works which have sold more than 100 million copies in more
than two dozen languages. In developing the religious
philosophy of Scientology, he delivered and recorded 6,000
lectures. In country after country, he has received wide
acclaim for his accomplishments in bettering mankind.



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