and penalties of perjury as follows:
dated March 19, 1986 which was used by Defendant Scientology
in the Summary Jury Trial proceeding in the case of Burden
vs. Church of Scientology, et al., and I have examined the
documents appended to Ms. Laubscher's Declaration.
Declaration are copies of documents which I collected in
1980 and 1981 and assembled in what became known as the
"Hubbard Archives;" e.g., the naval records (see Laubscher
Attachments 1 and 2), the Ledora May Hubbard manuscript
entitled "Economics and the Individual,"and L. Ron Hubbard's
Boy Scout book (see Laubscher Attachment 7).
negotiated by Hubbard's attorney, I delivered approximately
80,000 pages of copies of the documents from the "Hubbard
Archives" to an author, Omar V. Garrison, for the writing
of a biography of Hubbard. I also delivered Garrison a
number of originals which he was to sort through and copy as
needed. Towards the end of 1981 it became apparent to me
from an examination of the "Hubbard Archives" documents
that Hubbard had lied about virtually every part of his
history and that I had been defrauded, and I left Hubbard's
employ and his organization. Thereafter, because of what
I knew about the fraud, Hubbard and the organization mounted
an attack on me in compliance with Hubbard's policy called
"Fair Game." To defend myself I obtained from Garrison
copies of a number of the documents I had earlier provided
him, and a few originals, and I sent these to my lawyers.
These documents, which have become known as the "Armstrong
documents," in September 1982 were placed under seal in the
Los Angeles Superior Court and remain there at this time.
The Scientology organization sued me to obtain possession
of the "Armstrong documents," and a Judgment, attached hereto
as Exhibit A, was entered in my favor. Certain of the
exhibits to the Laubscher Declaration are copies of documents
included in the "Armstrong documents" still sealed in the
LA Superior Court; e.g., "Agreement to Enroll in Correspondence
Course" dated April 18, 1941, and letter from Baker, Beedy
& Magee dated May 27, 1941. I could, if necessary, locate
these and other exhibits to the Laubscher Declaration in
the "Armstrong documents" in Los Angeles.
to the Laubscher Declaration that the Scientology organization
is still using L. Ron Hubbard's documents to support its
claims, including copies of sealed "Armstrong documents."
Christofferson vs. Church of Scientology, Mission of Davis,
et al., number A 7704-05184, in the Circuit Court of the State
of Oregon, for the County of Multnomah, the Scientology
organization was ordered to produce and did produce copies
of some of the same documents which had been "Armstrong
documents" and sealed in the Los Angeles Superior Court.
this 12th day of April, 1986 in Boston, Massachusetts.