("RTC"). RTC has the responsibility of ensuring that the
nature and quality of the services and products associated with
the religion of Scientology and with its technologies of
spiritual counselling, ethics and administration are properly
applied in accordance with the standards set forth by the
Founder of the Religion, L. Ron Hubbard. I have personal
knowledge of the facts set forth below, and if called upon to
do so, I could and would competently testify thereto.
RTC, I also hold the ecclesiastical position of Inspector
General for Ethics. The function of that position is to ensure
the standard application of the ethics technology of the
Scientology religion. I am responsible for ensuring that the
ethical standards of Scientology are observed to the letter.
My life is dedicated to the support and preservation of the
Scientology religion and its scripture, which consists of the
religious writings of Mr. Hubbard.
accusations introduced against the Church of Scientology under
the guise of an explanation of Armstrong's "state of mind."
Armstrong was thus permitted to introduce evidence which
twisted and perverted the facts about his former religion and
its system of ethics and justice one hundred and eighty degrees
from the truth. In fact, Scientologists, as a group, comprise
the most ethical people, following the highest ethical
standards, of any group in the world today.
effectively prevented from placing into the record the
overwhelming evidence of Scientology's emphasis on honesty and
integrity, or from demonstrating to the Court the truth about
its system of ethics and justice which its parishioners prize
so highly. The trial court erred when it accepted, as has this
Court, Armstrong's evidence concerning his alleged "state of
mind" and then used that evidence to support findings of fact as
though such supposed evidence had been admitted for the truth of
the assertions. Consequently, the false accusations leveled by
Amrstrong were never answered, as they could have been, with a
resounding demonstration by the Church of the standards of
ethical conduct that are required of each and every
Scientologist and of the developments of L. Ron Hubbard which
led to the creation of an ecclesiastical ethics and justice
system that is honest, ethical and fair. This declaration is an
attempt to demonstrate to this Court just a fraction of the
evidence that the Church would have supplied to the Court below,
had it been allowed to do so, to prevent the reliance by that
Court and now this Court on the distorted picture of Scientology
created by Armstrong.
that an alleged practice of "fair game" made him fearful, and
that this fear was a justification for his theft of documents.
Armstrong's use and description of the term "fair game," and
his allegations of fear concerning it, are entirely belied by
Church scripture, doctrine and essential philosophy. "fair
game" was a term used in the Church for a short while in the
1960's. By the time Armstrong first entered the Church, the
term was no longer used, and the policy referring to it had
been expressly cancelled.
game" had not even the slightest resemblance to the wild
accusations made by Armstrong. It meant simply that an
individual so labelled 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 "one who is put
out of the protection or aid of the law." (Black's Law
Dictionary, Rev. Fourth Edition, pg. 1255).
privilege and benefit for Scientologists. Scientologists can
and do avail themselves of the Scientology ethics and justice
system as 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. Scientology justice committees do not
punish, they only get to the truth and attempt to rectify
injustices. The system is based on trust, and because
Scientology is predicated on truth and honesty, no
Scientologist in good standing would even think of lying in
such a proceeding or attempt to derail and misdirect a
proceeding through false and inflammatory testimony such as one
sees in civil cases in every courthouse.
is that man is basically good. As an individual becomes more
aware and able through the application of Scientology religious
technology, he becomes more honest, ethical, and interested in
helping others. This is why Scientologists become the most
valued members of society as they advance in Scientology.
L. Ron Hubbard developed a system of ethics and justice which
is based on this bedrock principle. The Scientology ethics and
justice system is built on the premise that honesty and
integrity are essential to happiness and survival.
a major benefit derived from membership in the Church. To
expel a person from Church membership and thereby withdraw the
protection and availability of the Church's ethics and justice
system is the harshest penalty in the Scientology religion.
Even then, however, because Scientologists believe that man is
basically good, the door is always left open for that person to
return to Church membership.
direct reference to what individuals who cannot have access to
the Scientology justice system are likely to receive at the
hands of the justice systems extant in society. Compared to
Scientology ethics and justice procedures, lay justice
proceedings are, in fact, barbaric.
throughout the trial of this case and repeated unquestioningly
by Judge Breckenridge, the basic values of honesty and
integrity are the bedrock upon which Scientologists build their
lives and upon which any individual must so build if he is to
live happily and in harmony with his fellows.
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 1/ Rights
Modified," written in 1972: "The road to truth is begun with
honesty." 2/ This is a road that all Scientologists, by
definition, consider that they are following.
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: "1. NEVER SAY OR PUBLISH ANYTHING YOU
CANNOT PROVE OR DOCUMENT; 2. ALWAYS DOCUMENT THE TRUTH TO
others goes much deeper than mere pragmatism. Honest and
ethical behavior enhance the well-being of an individual and a
group; dishonesty and unethical acts degrade a person and an
1) An "auditor" is a Scientology minister who counsels
2) Due to space limitations, copies of the writings of L. Ron
organization. In a book originally published in 1951, Mr.
Hubbard explained why maintaining high ethical standards is so
important, not just to Scientologists, but to everyone:
L. Ron Hubbard, Science of Survival, at 142-143 (1989 Ed.).
permeated Mr. Hubbard's writings throughout the years. In a
1960 issue entitled "Honest People Have Rights, Too,"
Mr. Hubbard stated:
* * *
Mr. Hubbard ended this bulletin with the reminder that:
writings dedicated to the subject of ethics, entitled
Introduction to Scientology Ethics. The book is replete
with basic truths on this subject which cannot be fully
discussed in this limited space. The following statements are
representative of the concepts which it contains:
L. Ron Hubbard, Introduction to Scientology Ethics, at
29 (1989 Ed.).
ethical, honest lives and showing respect for their fellow man
is quite simple: happiness. Albeit simple and indeed a basic
desire amongst all men, few know the requisites to true
happiness as well as a Scientologist.
* * *
(Introduction to Scientology Ethics, at 23)
Happy Life", Mr. Hubbard underscored the basic problem behind
the lack of human happiness:
* * *
progress in the Scientology religion, also referred to as
"case gain," Mr. Hubbard wrote a bulletin in 1985 called
"Honesty and Case Gain." In that Bulletin, he stated:
Another of his writings on this subject matter is a book
entitled, The Way to Happiness. This book has been the
source of a grass roots movement to improve life in the
world by providing non-denominational, common sense, moral
principles for this modern time. The book is divided into
different precepts, with titles such as "Be Worthy of Trust,"
"Fulfill Your Obligations," "Do Not Steal," "Respect the
Religious Beliefs of Others," "Don't Do Anything Illegal," and
"Seek to Live With the Truth." A few brief excerpts will show
* * *
3) The Bridge is the term which is used to describe the series
of gradient steps of spiritual awareness which one achieves in
the Scientology religion.
(The Way To Happiness, at 191-192; 198-200.)
The honesty of an individual is something that affects those
with whom a person lives and works. As Mr. Hubbard said in
a writing titled "Ethics and Executives," 3 May 1972R,
in one's dealing with others is harmful not only to the other
individual, but to one's self:
(The Way To Happiness, at 322 - 324.)
whom a person works with directly but in fact all those with
whom one may come in contact in the community and within
"Regulations and Laws, Obedience To," 27 October 1973.
Justice, and the Dynamics,"4/, L. Ron Hubbard wrote:
4) L. Ron Hubbard's most fundamental discovery was the
discovery that whatever else they were doing, all life was
seeking to survive. Survival is the common denominator of all
life. The basic urge to survive manifests itself in different
ways. These ways have been divided into eight parts, or
"dynamics". Each of these dynamics is interdependent on the
others. Each of us is striving to survive along or through
these subdivisions of the basic urge to survive: 1) the urge to
survive as an individual; 2) the urge to survive through sex
and the rearing of children; 3) the urge to survive through
groups; 4) the urge to survive as mankind, 5) the urge to
survive through living things, i.e., animals or plants; 6) the
urge to survive through the physical universe (matter, energy,
space and time [mest -- the physical universe]); 7) the urge to
survive through the spiritual universe; and 8) the urge to
survive through God, or the infinite.
point. The commission of dishonesties, of harmful acts against
another is the road to personal destruction, to the loss of
awareness, the loss of abilities, to personal unhappiness and the
destruction of positive interpersonal relationships. Only the
litigants who, due to their own harmful acts, have already
travelled down this route or those who, through misinformation
or ignorance know no better, would advance or believe that the
scriptures of the Church could support the commission of
harmful acts against one's fellow man.
scriptures detail how it is that harmful acts against one's
fellows bring about the loss of integrity and decrease one's
ability to handle life successfully. The mechanism at work
here was presented by Mr. Hubbard in 1968:
Bulletin of 20 May 1968, "Overt-Motivator Sequence."
Thus, an individual who commits harmful acts against himself,
another, the social order and so forth, grows invariably at odds
with the person or institution whom he has attacked.
lecture given to Scientology ministerial students:
Tape Lecture of July 2, 1964, "0/W Modernized and Reviewed."
road to oblivion. It is the descent not only into despair and
destroyed relationships; it is also the way to personal
degradation and criminality. "A criminal is one who is
motivated by evil intentions and who has committed so many
harmful overt acts that he considers such activities ordinary."
(Bulletin of 15 September 1981, "The Criminal Mind,") The
desperate straits to which the criminal has descended have been
clearly described by Mr. Hubbard:
5) The "bank" is a slang term referring to a person's "reactive
bank", that portion of a person's mind wherein all painful
experience is stored below a person's awareness. The reactive
mind is a stimulus-response unconscious mind which can exercise
control over the individual without that person's awareness.
honesty and integrity, down the dwindling spiral of the
overt-motivator sequence, to the depths of criminality
described by Mr. Hubbard in the attached bulletin arrives at a
point, where they are totally consumed by their criminality. A
person at this point sees all life as having the same sordid
motives he does. Of such an individual, Mr. Hubbard wrote:
* * *
and justice technologies of the Scientology religion is to
improve the spiritual well-being of the individual and to make
him more able so that he is able to assist others to attain
greater spiritual awareness. Of all of the religions in the
world, Scientology is unique in the degree it places emphasis
upon the value of self-determined right conduct, honesty and
personal integrity. The scriptures, however, do far more than
simply warn of the consequences of evil ways. They also set
forth techniques for the eradication of the harmful effects of
past transgressions and the rehabilitation of an individual's
personal integrity and abilities. Confessional counselling
sessions are standardly provided to Scientologists in order to
help them unburden themselves of past transgressions.
Through such counselling the individual Scientologist is made
more able and is brought to levels of increased affinity and
has honesty and integrity as its underpinnings. As a subject,
ethics consists simply of the actions taken by an individual on
himself to improve his survival. Through Scientology ethics a
person is taught not a rote series of do's and don't's, but
tools which he can use to make ethical and moral choices and
November 1982, entitled "The Basics of Ethics," Mr. Hubbard
wrote of the unfortunate state a person finds himself in when
he is unable to ethically deal with his daily life:
Hubbard is found in the ethics conditions and their formulas.
These are described in the book, Introduction to Scientology
* * *
(Introduction to Scientology Ethics, at 37-38.)
Doubt, Liability, Non-Existence, Danger, Emergency, Normal
Operation, Affluence, Power, Power Change. Each condition
carries with it a series of steps to follow, called formulas,
which result in improvement up the rising scale of
conditions. The application of the specific formulas for each
condition are a basic tool which Scientologists use to live
happier, more successful lives. Each condition describes a
level of survival in which an individual, business or other
activity can be located at any given moment. Mr. Hubbard has
laid out an exact formula, or set of steps, for each condition,
which, if correctly followed, will result in the attainment of
a higher condition. For example, both a new marriage and a new
business start out in a condition of "non-existence" and to
succeed, must follow the formula steps of getting in
communication with one's partner or potential customers,
finding out what is needed from that person, and providing
that. Whether one is doing well, poorly, or just getting by,
there is a condition formula which applies. (For a full
description of the various ethics conditions and their
individual formulas, see Introduction to Scientology Ethics,
pp. 56-104.) Through the use of the correct formula, one is
able to improve how he or she is doing.
situations, favorable and unfavorable, alike. For example, if
one made a bad error on one's job, he could use an ethics
condition, such as the Liability formula, as a guide to getting
back on top of the situation -- perhaps saving his job in the
process. And if one were doing very well in some area in life,
the Affluence formula would provide steps to help isolate the
important points of one's success and reinforce those.
system. Justice is applied in Scientology when an individual
fails to apply the tools of ethics to correct his own unethical
activities, and is causing problems for others.
premise that justice is to be used only so long as it is
necessary to restore the individual to self-determined ethical
conduct. It does not have punishment as a goal; rather, the
purpose is to rehabilitate the individual's ability to use and
apply the ethics technology. For this reason, the justice
system is a gradient one, consisting of a whole series of
actions which might be taken in an appropriate case to ensure
that ethical conduct is restored.
Mr. Hubbard dated 29 April 1965, entitled "Ethics Review." The
various tools are laid out in a progression of lightest to most
severe, ranging from actions such as "noticing something
non-optimum and commenting on it to the person," to the
severest discipline in the Scientology religion: "expulsion
from Scientology." None of the gradients carries with it
physical punishment of any kind.
of these levels are to be used first, and only increased as
necessary to help the person:
ecclesiastical fact-finding bodies and formal justice actions
which help determine the appropriate way to deal with a
Scientologist who has been causing difficulty for other
Scientologists. The first of these is an "ethics hearing."
Such a hearing consists of a meeting of the accused with a
"hearing officer." This is a fact-finding body; the accused
is presented with the written accusations, is given the
opportunity to question the people who have made the
accusations, if necessary, and is given the opportunity to
explain fully his own side of the story. The hearing officer
then makes a recommendation as to how the situation should be
ethics hearing that the person has been involved in some
violations of Scientology codes or procedures, a "Court of
Ethics" may be convened. The purpose of the Court is to
determine what discipline should be imposed for the
wrong-doing. For example, if a staff member is continually
late for or absent from his assigned duties, he might be called
before such a court and might be assigned a short, special
project to clean the slate for the problems he has caused.
Such an action would bring home to him that he is expected to
appear for work on time and should regulate his actions
accordingly. (See, policy letter of 26 May 65, Issue III,
"Courts of Ethics,").
Committee of Evidence. This is "a fact-finding body composed
of impartial persons properly convened by a convening
authority which hears evidence from persons it calls before it,
arrives at a finding and makes a full report and recommendation
to its convening authority for his or her action." (Policy
letter of 27 March 1965, "The Justice of Scientology -- its Use
and Purpose.) The individual or individuals who are the subject
of the Committee of Evidence are present at all times when
evidence is presented and are given the opportunity to examine
all witnesses. Once the Committee has determined the facts of
the matter, it makes its recommendation to the "convening
authority" who then reviews all the evidence and
recommendations and accepts, or modifies the Committee's
findings and recommendations. The protection which committees
of evidence provide for Scientologists from possible arbitrary
sanctions or sanctions arising out of momentary upset is
substantial. Thus, for example, staff members may not be
suspended, demoted, or improperly transferred to another job
without a committee of evidence. (Id.)
of the Scientology justice system as it is free, swift, sane,
accurate and based solely on getting to the truth.
Mr. Hubbard in 1965 in a policy letter entitled "The Justice
of Scientology -- Its Use and Purpose; Being a Scientologist":
justice codes of the Church of Scientology is expulsion from
the Church. Mr. Hubbard wrote in a 1965 policy letter that to
withdraw the protection and availability of the Scientology
justice system is the harshest penalty in that system; and that
is the effect of expulsion. Yet, even a person who has been
declared to be a suppressive and has been expelled from the
Church, however, is still afforded an opportunity to redeem
himself and to return to good standing. To do so, the person
must follow a simple, five step, procedure: (A) "cease all
attacks and suppressions so he, she or they can get a case
gain"; (B) make "a public announcement to the effect that they
realize their actions were ignorant and unfounded"; (B-1)
paying off all debts owed to any Scientology organizations;
(B-2) complete an approved amends project; (C) training from
the lowest level; (D) providing copies of the above steps to the
ethics officer who is dealing with him; and (E) providing a
similar copy to the International Justice Chief of the Church.
"Suppressive Acts, Suppression of Scientology and
Scientologists", 8 January 1981.
point that even an expelled person may turn around and re-enter
the Church. In "Expansion Theory of Policy", 4 December 1966
regarding expulsion from the Church, he wrote:
standard of ethics, Scientologists have a great respect for the
law. As Mr. Hubbard wrote in The Way To Happiness:
(Id., pp. 100 - 101)
portion of the hundreds of pages which Mr. Hubbard has written
on the subject of Ethics and Justice, all of which is in full
use and application in Churches of Scientology around the
globe. As the cited materials make clear, the undeviating
emphasis throughout this vast literature is that one must
maintain a very high standard of ethics, that one must treat
one's fellow man with dignity and respect and that one must
obey the laws and act in harmony with the codes of the society.
Moreover, the Scientology scriptures themselves are comprised
of over 50 million words which L. Ron Hubbard wrote
on the subject of the religion of Scientology. And
throughout all of this material, whether dealing with
techniques of counselling or with the ultimate abilities and
nature of the spiritual being that is the individual, Mr.
Hubbard has written from the premise that truth, integrity,
honesty and fair dealing with one's fellows, with groups and
races and with each of the dynamics, is the road to survival.
This is a standard which never waivers in the Church of
Scientology. And this is the reason that Scientologists are the
most ethical people you are likely to ever meet.
be presented to Judge Breckenridge in the underlying case --
Armstrong's assertions are patently absurd and unbelievable.
Armstrong attempted to take one line from a 1965 issue and to
assert that this cancelled issue, which he deliberately
misinterpreted to suit his own purposes, carries more weight
than the thousands upon thousands of pages by Mr. Hubbard
which directly and unequivocably state the exact opposite of
Armstrong's interpretation. Armstrong knew that the "fair
game" issue was cancelled by Mr. Hubbard in 1968, before
Armstrong was first exposed to the religion of Scientology.
When Mr. Hubbard learned that the line was open to
misinterpretation by those not versed in Church scripture,
he immediately cancelled it for that reason. The Church has
always been ready to accept a reformed suppressive person back
into the Church. Mr. Hubbard's writings are clear on this.
The expelled individual is simply denied recourse to the
Church's internal justice procedures for the resolution of his
disputes with Scientologists in good standing. The door is
always "left open a crack", as anyone is capable of reform. It
has always been and will remain the intention of the Church
staff to bring increased well-being and spiritual awareness to all
individuals on this planet. That is what the religion and
the Church of Scientology are about.
single mistranslated line that never made it into an edition of
the Bible. An apostate who, on the basis of this non-existent
piece of scripture, is attempting to allege that all of
Christianity is built upon a false premise and that all the
teachings of Jesus and his disciples are mere coverings for the
one line of alleged "scripture" which he feels "tells it all".
The Court would surely recognize the absurdity of this position
and would never permit the apostate to claim that his theft of
sacred religious documents was warranted by his "state of mind".
Yet this is an exact parallel to the situation which occurred at
the Armstrong trial and which was countenanced by Judge
Breckenridge and, so far, by this Court. Moreover, Armstrong
well knows that it is a fundamental tenet of the Church that
Church policy must be in writing to be valid ("in Scientology we
say, 'if it isn't written, it isn't true.'"["The Hidden Data
Line, 16 April 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
prior to Armstrong joining the Church and is not published in any
current volumes of Scientology writings, and indeed was never
published in any edition of any of the Scientology policy volumes.
It is not something that is open to interpretation by Armstrong,
Judge Breckenridge, or anyone else. It does not exist.
the nature and weight of Scientology scriptures. Now the
indefensible nature of Armstrong's "state of mind" defense is
clear. And further, now it is clear that Armstrong's asserted
defense has forced the Court into the role of interpreter of
the true meaning of Scientology scriptures, a role which is
anathema to the First Amendment. Church scriptures are
straight-forward on this matter: Church members and Church
organizations are expected to (and do) maintain the highest
standards of ethical behavior in their dealings with their
fellow men and with the institutions of our society.
life and his work to doing what he could to make life better --
and happier -- for all mankind. It is this care and dedication
which is carried on by Scientologists the world over, and their
own happiness and that of those around them reflect just that.
Mr. Hubbard expressed the purpose underlying his work in an
article entitled, The Aims of Scientology:
clear. These are the true facts about the ethics and justice
systems of the Church and the values which the writings of
L. Ron Hubbard advance. These are tools of personal salvation
which litigants against the Church violently malign and impugn.
From the blackened depths of their criminal minds, they seek to
destroy this hope for mankind through false pictures and wild
allegations which merely reflect their own sordid intentions and
actions. Yet, as this small sampling of the scriptures show,
the truth is very different. The religion of Scientology places
a premium upon ethical behavior; and Scientologists, as a group,
are the most ethical people in the world today. In fact, the
ethical standards which they maintain are far and above those
of any other group.
State of California that the foregoing is true and correct.
Executed in the State of California, the 13th day of August 1991.