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[CT 6276]

CONTOS & BUNCH
5855 Topanga Canyon Boulevard
Suite 400
Woodland Hills, California 91367-4694
Telephone (818) 716-9400

Attorneys for Defendant and
Cross-Complainant GERALD ARMSTRONG

 

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

CHURCH OF SCIENTOLOGY OF
CALIFORNIA, a California
Corporation,

Plaintiff,

vs.

GERALD ARMSTRONG, et al.,

Defendants.


AND RELATED CROSS-ACTIONS.


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CASE NO.: C 420 153

[Severed Action]

REQUEST FOR PRODUCTION OF
DOCUMENTS FROM CROSS-COMPLAINANT
GERALD ARMSTRONG TO CROSS-
DEFENDANT CHURCH OF SCIENTOLOGY
OF CALIFORNIA

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TO CROSS-DEFENDANT CHURCH OF SCIENTOLOGY OF CALIFORNIA AND TO

ITS ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE that pursuant to Code of Civil

Procedure, Section 2031, on September 9, 1986, at

10:00 a.m. at the Law Offices of Contos Bunch, 5855 Topanga

Canyon Boulevard, Suite 400, Woodland Hills, California,

Cross-Complainant requests Cross-Defendant to produce for

copying and inspection by counsel for Cross-Complainant each

 

 

 

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[CT 6277]

of the documents specified in Schedule A annexed hereto.

Such items are believed to be in Cross-Defendant's custody,

control or possession, not privileged, and relevant to the

subject matter of this action or reasonably calculated to

lead to the discovery of admissible evidence in this action.

PLEASE TAKE FURTHER NOTICE that, pursuant to the

express provisions of Code of Civil Procedure, Section 2031,

Cross-Defendant shall serve a written response, subscribed

under oath by an officer, director or managing agent of

Cross-Defendant to this Request within twenty (20) days after

service of this Request. Said sworn Response, pursuant to

the requirements of Section 2031(b), "shall identify the

documents, papers, books, accounts, letters, photographs,

objects, and tangible things falling within the categories

specified in the request which are in the possession, custody

or control of the responding party."

This Request calls for identification and produc-

tion of, and defines "documents" to mean, without limitation,

the following items, whether printed or recorded or

reproduced by any other mechanical process, including audio

and/or visual process, or written or produced by hand:

agreements, communications, city, state and/or federal

governmental proceedings and hearings, transcripts and

reports, correspondence, telegrams, memoranda, summaries of

records of telephone conversations or interviews, diaries,

graphs, reports, notebooks, note charts, plans, summaries or

records of meetings or conferences, summaries or reports of

investigations or negotiations, opinions or reports of

 

 

 

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[CT 6278]

counsel, consultants, photographs, tape recordings, cas-

settes, motion picture or television films, brochures,

pamphlets, advertisements, circulars, press releases,

articles, or any publications, drafts, files, letters, any

marginal comments appearing on any document, computer

print-outs and all other writings, or printed materials.

 

DATED: August 4 , 1986

CONTOS & BUNCH

By: [signed]
JULIA DRAGOJEVIC
Attorneys for Defendant
and Cross-Complainant
GERALD ARMSTRONG

3:27:14

 

 

 

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[CT 6279]

SCHEDULE A

 

1. All documents from which the entries on the

14-page "time track" were excerpted or on which the entries

were based. Said "time track" was produced as part of the

B-1 File during the Christofferson trial.

2. All documents contained in Cross-Complainant's

"ethics" and "personnel" files.

3. All records and documents concerning the

incarceration of Cross-Complainant in the US GO Intelligence

Bureau in Fifield Manor in June, 1976.

4. All documents generated as a result of the

interview of Cross-Complainant done by GO Intelligence

official, Brian Roubinek, in July/August, 1976 in Clearwater,

Florida.

5. All Compliance reports, progress reports or

any documentation whatsoever regarding each of the "steps" of

the "Gerry Armstrong Project of February 17, 1982, attached

hereto as Exhibit [A].

6. Any and all documentation containing

information culled from Cross-Complainant's pc (or preclear,

or auditing, or processing) files.

7. All documentation upon which the report of

September 30, 1982 re Dead Agenting Gerry Armstrong is based.

8. Any and all documentation, including

correspondence and reports to and from the private

investigators who surveilled Cross-Complainant and his wife

beginning in May, 1982, and who assaulted Cross-Complainant,

 

 

 

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[CT 6280]

ran into him, attempted to involve Jocelyn Armstrong and him

in freeway accidents, and who followed and harassed them

through September, 1982.

9. Any and all documentation concerning a visit

and subsequent telephone calls to Cross-Complainant by Marty

Rathbun from February through April, 1984. Said

documentation includes, but is not limited to, an "eval"

Mr. Rathbun stated had been done regarding Cross-Complainant,

as well as all documents relating to the "eval."

10. The mission, project or program orders

pursuant to which Terri Gamboa met with Cross-Complainant on

March 8, 1984, and subsequently wrote her "debrief' of

March 12, 1984 attached hereto as Exhibit [B].

11. All orders, reports, correspondence and

documents concerning surveillance and harassment of Cross-

Complainant by agents of Cross-Defendant in London in June,

1984.

12. All orders, reports, correspondence and

documents relating to the operation in June, 1984 to use

Cross-Complainant's folders to entrap him. This operation

was acknowledged by the two agents of Cross-Defendant, Mike

Rinder and "Joey," in the videotapes illegally taken of

Cross-Complainant in November, 1984.

13. All orders, reports, correspondence, and

documents relating to OSA INT Executive Directive 19, of

September 20, 1984, a copy of which is attached hereto as

Exhibit [C].

14. All orders, reports and documents concerning

 

 

 

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[CT 6281]

the photographing of Cross-Complainant by Cross-Defendant's

members on November 8, 1984 in Los Angeles, including the

original photographs taken.

15. All orders, reports, correspondence, materials

and documents concerning the burglarizing of the trunk of

Cross-Complainant's car on November 8, 1984, and the theft

therefrom of a manuscript and artwork of approximately

350 pages, and various documents relating to the within

litigation. This request includes the stolen materials

themselves.

16. All copies made by Cross-Defendant's agents,

known to Cross-Complainant as "Joey" and "Rena," of Cross-

Complainant's writings and drawings which "Rena" requested as

a potential publisher, and which Cross-Complainant loaned to

"Rena" on November 9, 1984. These consisted of approximately

250 pages of personal creative works.

17. All records, reports, orders, correspondence,

documents and audio and video recordings of a meeting

(arranged by Cross-Defendant's agents posing as "reformers")

between an attorney, Thomas Janeway, and Cross-Complainant in

November, 1984 in Encino, California.

18. All records, reports, correspondence, orders,

documents or materials relating to the obtaining of false

authorizations directing and/or authorizing the videotaping

and wiretapping of attorney Michael Flynn and Cross-

Complainant in November and December, 1984. Three of these

authorizations are attached hereto as Exhibit [D].

19. All records, reports, correspondence, orders,

 

 

 

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[CT 6282]

audio and video recordings, documents or materials relating

to an attempt by Cross-Defendant's agents to persuade Cross-

Complainant to fly to Las Vegas, Nevada in the fall of 1984

to meet with a proposed "backer" of Cross-Defendant's agents

posing as "reformers."

20. All correspondence, reports, statements,

documents or materials supplied to or received from the Los

Angeles Police Department, or any officer thereof, from 1982

through 1984 regarding various attempts to have criminal

charges brought against Cross-Complainant in connection with

Cross-Complainant's alleged theft of the Hubbard archives.

This includes, but is not limited to, documentation generated

through contacts with Officer S.J. Capuano in the

N.E. Detective Division of the Los Angeles Police Department.

21. All orders, reports, projects, programs,

briefings and debriefings, audio and video recordings, and

all related documents and materials concerning what the

Organization calls the "Armstrong Operation." This operation

involved the use of Cross-Complainant's friend, Dan Sherman

to get close to Cross-Complainant, feed him false

information, compromise him and frame him, with the goals of

destroying his reputation, his ability to testify in

Scientology litigation, his emotional and physical well-

being, his economic base, his marriage and his life. This

operation is referenced at page 2 of the February 17, 1982

"Gerry Armstrong Project," Exhibit A, under "Step 15."

22. All daily reports, weekly reports, battle

plans, battle plan reports, statistic reports, private

 

 

 

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[CT 6283]

investigator reports on a daily basis from at least 1982 to

the present, CSW's, mission orders, projects, programs,

evals,. targets, estimates, compliance reports, progress

reports, orders, nudges, debugs, requests for funds, budgets

(FP's), accounting reports, cross file sheets, excerption

sheets, computer data and files, briefings, drillings,

debriefings, audio and video recordings, wiretape recordings,

photographs and any other documents relating to the forgery

and attempted cashing of a $2,000,000 check on the Bank of

New England account of L. Ron Hubbard in 1982, and the

operation to frame Michael Flynn and Cross-Complainant with

the alleged crime.

23. All correspondence, orders, reports,

statements, documents, photographs, or materials relating to

the "Freedom" tabloid issue 61, published in August, 1984, a

reduced copy of which is attached as Exhibit [E].

24. All correspondence, orders, reports,

statements, documents, photographs, or materials relating to

the article entitled "Ex-U.S. Attorney's Role in Check

Forgery Surfaces in Boston Court" in the "Freedom" tabloid

issue 62, published in October, 1984, a reduced copy of which

is attached hereto as Exhibit [F].

25. All correspondence, orders, reports,

statements, photographs, documents or materials relating to

the "Freedom" tabloid published in April/May, 1985, a reduced

copy of which is attached hereto as Exhibit [G].

26. All correspondence, orders, reports,

statements, photographs, documents or materials relating to

 

 

 

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[CT 6284]

the "Freedom" tabloid published in May, 1985, a reduced copy

of which is attached hereto as Exhibit [H].

27. All correspondence, orders, reports,

statements, documents or materials relating to the

"advertisement" attached hereto as Exhibit [I] which appeared

in 'The Oregonian' newspaper of May 30,1985, in Portland,

Oregon, particularly with regard to the statement:

 

"Another one of Christofferson's

key witnesses, Gerry Armstrong, a

government informant, was

indisputably shown to have engaged

in an operation to infiltrate the

Church of Scientology. Armstrong's

plot, based on evidence submitted in

court, appears to have been

conceived with the advice and

consent of Flynn and members of the

IRs Intelligence Branch. It

indicated the planting of forged

documents in the church which could

then be "discovered" by government

agents in planned raids on church

premises. The forged documents

would incriminate the church in

nonexistent illegal activities and

would serve as a basis for the

indictment of current church

 

 

 

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[CT 6285]

management."

28. All correspondence, orders, reports,

statements, documents or materials relating to Cross-

Defendant's radio show "Freedom Magazine' on station WTTP in

Boston on June 11, 1985, a transcript of which is attached

hereto as Exhibit [J].

29. All correspondence, orders, reports,

statements, documents, payments, receipts or cancelled checks

sent to or received from L. Fletcher Prouty relating to

Cross-Complainant.

30. All edited versions of the videotapes which

had originally been made of Cross-Complainant in November,

1984. Attached hereto as Exhibit [K] is a flyer distributed to

Scientologists in April and May, 1985 directing them to a

showing of an edited version of the tapes.

31. All correspondence, orders, reports,

statements, documents or materials relating to the editing of

the videotapes, including the editing which occurred prior to

the Christofferson trial, as well as the audio sections

edited out of the videotapes.

32. All correspondence, orders, reports,

statements, documents or materials relating to the

delivering/sending of edited versions of the videotapes to

any members of the media.

33. All correspondence, orders, reports,

statements, documents or materials relating to Cross-

Complainant sent to any media including newspapers,

 

 

 

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[CT 6286]

television and radio stations.

34. All correspondence, orders, reports,

statements, documents or materials, relating to the showing

of the videotapes or edited versions thereof to staff or

public Scientologists; including any briefings given,

requests for "donations" or funds, any projects, programs or

evals related to this operation and any financial records of

said operation.

35. All correspondence, orders, reports,

statements, documents or materials relating to the

photographing of Cross-Complainant's residence in Boston,

Massachusetts on October 7, 1985, including all photographs

taken.

36. All correspondence, orders, reports,

statements, documents or materials relating to the mugging

and robbery of Cross-Complainant outside his residence in

Boston on October 25, 1985.

37. All correspondence, reports, statements,

documents or materials regarding an incident which occurred

on October 13, 1985, when a Scientologist reported to the FBI

that Cross-Complainant was posing as an FBI agent near the

Massachusetts Bay Transportation Authority Green Line

Auditorium Stop in Boston.

38. All correspondence, reports, statements,

documents or materials concerning the operation to bring

false criminal charges against Cross-Complainant via the FBI

as described in Request No. 37 above.

39. All correspondence, orders, reports

 

 

 

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[CT 6287]

statements, documents or materials relating to the "Freedom"

tabloid published in February, 1986., a reduced copy of which

is attached hereto as Exhibit [L].

40. All correspondence, orders, reports,

statements, documents or materials relating to the operation

to have several hundred copies of the "Freedom" tabloid

(Exhibit L) planted in the building where Cross-Complainant

works on February 11, 1986, during his deposition in the case

of Burden v. Church of Scientology.

41. All correspondence, orders, mission orders,

reports, telexes, statements, documents or materials relating

to an operation or mission in February and March, 1986

involving organization agent, Meryl Dubay, the purpose of

which was to "Black PR" Cross-Complainant among plaintiffs

and witnesses in various cases against the Organization.

42. All correspondence, orders, reports,

statements, documents or materials relating to the

photographing of Cross-Complainant's residence on March 21,

1986.

43. All correspondence, orders, reports,

statements, documents or materials regarding Cross-

Complainant delivered to the Internal Revenue Service in 1985

and 1986.

 

3:27:15

 

   

    

Exhibit [A]
Gerry Armstrong Project

Exhibit [B]
Gamboa Debrief 03-12-1984 [.pdf]

Exhibit [C]
OSA ED INT 19 " Squirrels" 09-29-1984

Exhibit [D]
(3) False Authorizations
Authorization 11-07-1984

Exhibit [E]
Freedom Issue 61 08-1984

Exhibit [F]
Freedom Issue 62 10-1984

Exhibit [G]
Freedom 04-1985

Exhibit [H]
Freedom 05-1985

Exhibit [I]
Advertisement in Oregonian 05-30-1985

Exhibit [J]
Transcript of Scientology's radio show "Freedom Magazine" 06-11-1985

Exhibit [K]
Flyer promoting Scientology's edited version of videotapes.

Exhibit [L]
Freedom 02-1986

   

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