Gerry Armstrong--Reporters Transcript of Proceedings 05-10-1984

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

DEPARTMENT NO. 57 HON. PAUL G. BRECKENRIDGE, JR., JUDGE

CHURCH OF SCIENTOLOGY OF CALIFORNIA,

Plaintiff,

vs.

GERALD ARMSTRONG,

Defendant.

MARY SUE HUBBARD,

Intervenor.

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No. C 420153

REPORTERS' TRANSCRIPT OF PROCEEDINGS

Thursday, May 10, 1984

APPEARANCES:

(See Appearances page.)

VOLUME 9

Pages 1389 - 1563

NANCY L. HARRIS, CSR #644
HERB CANNON, CSR #1923
Official Reporters

APPEARANCES:

For the Plaintiff:

PETERSON & BRYNAN
BY: JOHN G. PETERSON
8530 Wilshire Boulevard
Suite 407
Beverly Hills, California 90211
(213) 659-9965

-and-

ROBERT N. HARRIS
The Oviatt Building
617 South Olive Street
Suite 915
Los Angeles, California 90014
(213) 623-7511

For the Intervenor:

LITT & STORMER
BY: BARRETT S. LITT
Paramount Plaza
3550 Wilshire Boulevard
Suite 1200
Los Angeles, California 90010
(213) 386-4303

-and-

BARRETT S. LITT
BY: MICHAEL S. MAGNUSON
The Oviatt Building
617 South Olive Street
Suite 1000
Los Angeles, California 90014
(213) 623-7511

For the Defendant:

CONTOS & BUNCH
BY: MICHAEL J. FLYNN

- and-

JULIA DRAGOJEVIC
5855 Topanga Canyon Boulevard
Suite 400
Woodland Hills, California 91367
(213) 716-9400

VOLUME 9

I N D E X

Day	Date	Session	Page

Thursday	May 10, 1984	A.M.	1389
		P.M.	1479

W I T N E S S E S

DEFENDANT'S WITNESSES:

DIRECT

CROSS

REDIRECT

RECROSS

ARMSTRONG, Gerald

E X H I B I T S

DEFENDANT'S	IDENTIFIED	RECEIVED

N - Publication PRO News	1393
O - Book, "Dianetics The Original Thesis	1399
P - book "All About Radiation"	1399
Q - Document "My Philosophy"	1403
R - Book "Successes of Scientology"	1404
S - Biographical sketch of L. Ron Hubbard	1406
T - "Operation Earth"	1406
T-1 - Page "Advance 7"	1409
U - Bond	1465
V - 1977 W-2 Form	1467
W - Vetting policy write-up	1486
X - (Not described on the record)	1488
Y- Memo from L. Ron Hubbard	1508
Z - L. Ron Hubbard response, 2-8-80	1511
BB - (Not described on the record)	1535
CC- Outline of collection of documents	1548

1389

LOS ANGELES, CALIFORNIA; THURSDAY, MAY 10, 1984; 9:07 A.M.

-o0o-

THE COURT: Very well, in the case on trial let

the record reflect that counsel and all parties are present.

Mr. Flynn, you may proceed.

MR. FLYNN: Thank you, Your Honor.

Mr. Gerald Armstrong, please.

Your Honor, I take it the practice out here

is counsel can sit during examination of the witnesses.

THE COURT: Yes, you may sit if you desire to.

MR. FLYNN: In Massachussetts that would be a real

no-no.

GERALD ARMSTRONG,

the defendant herein, called as a witness in his own behalf,

was sworn and testified as follows:

THE COURT: Please state your name for the record, sir.

THE WITNESS: Gerald Armstrong.

1390

DIRECT EXAMINATION

BY MR. FLYNN:

Q Where do you live, Mr. Armstrong?

A Costa Mesa, California.

Q How long have you lived there?

A About two years and four months.

Q Are you a resident of California?

A Yes.

Q And are you currently employed?

A No.

Q What was your last employment?

A It was at a law firm.

Q What was the name of the firm?

A Feldsott, Lee and Van Gemert.

Q What was the nature of your duties at that

firm?

A I was a paralegal for the most part in the

accounting department.

Q How long did you work for that firm?

A For two years.

Q And why did you leave?

MR. LITT: I object. Is that relevant to this case?

THE COURT: It may be. I don't know.

Overruled. You may answer.

THE WITNESS: I left because this trial was coming

up and I had to prepare for the trial and be here during

this trial.

Q What was the date that you left?

1391

A March 2nd.

Q Now, where were you born and brought up,

Mr. Armstrong?

A In Chilowac, British Columbia, Canada.

Q Did you go to high school in British Columbia?

A Yes.

Q And at the high school did you learn about a

franchise of a scientology organization?

A Yes.

MR. LITT: Objection. Leading.

THE COURT: It is a preliminary question.

Overruled.

Q BY MR. FLYNN: Where was that, Mr. Armstrong?

A The franchise was in Vancouver.

Q What was it called?

A Scientology Little Mountain.

Q Was it called a church, or a franchise?

A It was a franchise.

Q Did you become involved with any activities

relating to that franchise of Scientology?

A Yea.

Q What activities were those?

A In the summer of 1969 I attended some lectures.

And in September of 1969 I began some courses in Scientology.

Q Now, in connection with the commencement of

those courses, did you read any materials that were distributed

by the Scientology franchise?

A During that period or prior to me actually

	1392
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28	beginning courses, I read a number of publications, both magazines and books. Q And at some point did you join a group called the Sea Organization? A Yes. Q And when did you join the Sea Organization? A Beginning of 1971. Q And between the time that you became involved in the activities of the franchise and the time you joined the Sea Organization, do you recall any of the publications that you read that were disseminated by Scientology Organizations? A Yes. Q And what do you recall? A Are you referring to the Sea Org ones, or just any? Q Did you read certain publications that induced you to become involved with Scientology organizations?

1393

MR. LITT: Objection. The question is leading. Also,

what period of time are we talking about? Are we talking

about 1971? Are we talking about 1969?

MR. FLYNN: I will withdraw it, Your Honor.

THE COURT: All right, you can reframe it.

Q BY MR. FLYNN: Between 1969 and the time you

joined the Sea Organization did you read various publications

disseminated by Scientology organizations that you relied

upon in connection with your joining the Sea Organization?

A Yes.

Q Let see show you this publication.

THE COURT: You want to show it to counsel, first?

MR. FLYNN: I have a copy for the court.

THE COURT: All right. What is your next in order?

THE CLERK: N.

THE COURT: All right, mark it N for identification.

Q BY MR. FLYNN: Do you recognize that document,

Mr. Armstrong?

A Yes.

Q Exhibit N?

A Yes.

Q And what is it?

A It is a publication put out by -- it is called

PRO News, and it was a newsletter which was distributed

within Scientology during that period. I don't know if it

still is. It may be discontinued, but it was in the early

days.

Q Now, were there any representations in Exhibit N

1394

that you relied upon in connection with your joining the

Sea Organization?

MR. LITT: Objection, Your Honor. The question as

framed is leading. Also, there is no foundation as to even

what is being referred to.

Let us get where we are in this document.

The way of framing these questions, "as relied upon"; one,

we contend that this is completely irrelevant. What has

that to do with what happened in 1982, what Mr. Armstrong

read in 1969?

THE COURT: We don't need a speech, Counsel. I know

what you are saying. I think the question is very simple.

It is probably compound and a little bit

leading. Why don't you just ask simple questions, Mr. Flynn,

and we will get along with this witness.

Counsel is entitled to develop his case as he

sees fit and he will be permitted to do so. Let's try to

make them simple questions, though.

Q BY MR. FLYNN: What representations, if any,

did you rely upon that are contained in exhibit N,

Mr. Armstrong?

A Well, there is a great number of them here.

I heard of the Sea Organization within, I don't know, the

first short while of becoming involved with Scientology,

and I understood from all written and from verbal communications

that it was the elite of Scientology. It was the organization

which was bringing to the world, and the head of the Sea

Organization was L. Ron Hubbard.

1395

MR. HARRIS: May the witness' answer be stricken as

non-responsive to the question, Your Honor?

THE COURT: I will let it stand.

THE WITNESS: And the information in here on L. Ron

Hubbard was a great deal of reason which motivated me to

become further involved and ultimately to join the Sea

Organization, and it was some of the things which were

offered here which I felt were attainable or which were

promised, and my being more involved offered a greater

possibility for me to attain these things, and those things--

some of them are mentioned here, but more particularly, the

representations about L. Ron Hubbard, I think, were the

most significant factor in my joining the Sea Organization,

which was promoted to me as working for him, working with

Ron, working for Ron.

I saw here that here was a man of remarkable

achievements, and I knew that I didn't have particularly

remarkable achievements and I felt like I could contribute

to what this man was apparently doing and that I could gain

those things which mere promised in here.

Q BY MR. FLYNN: Now, can you identify specific

representations that were made in exhibit N that you relied

upon?

A Regarding myself and one of the things which

was promised was that the intelligence quotient of a person

could be raised about one point per hour or processing,

a thing which was considered impossible a few years ago

and that was something which had a great deal of significance

1396

to me, perhaps because of how I viewed myself at the time.

But it was very significant and that was something which I

expected throughout the course of my auditing or processing,

I guess it is called here, in Scientology.

Q With regard to representations about L. Ron

Hubbard, can you identify specific representations in

exhibit N that you relied upon?

MR. LITT: Your Honor, I just want to make clear at

this point since we have gotten into it, the questions being

asked, in particular Mr. Armstrong's last answer, but this

whole line of questioning, we just want to repeat our

position on the First Amendment, they are going directly

into representations surrounding the joining of a religion

and somehow trying to make that a basis of his defense.

1397

We want to make clear that we think this whole

thing is barred. I won't stand up each time and say it,

but this is the first time it had come up in testimony. So

I wanted to make clear our position. This is not permissible

under the First Amendment.

THE COURT: Very well.

Q BY MR. FLYNN: Do you recall the question,

Mr. Armstrong. I could --

Do you wish me to read from this, or just to

answer from off the top of my head?

Q If you could refer to the page and the

representation on exhibit N that you relied upon when you

joined.

A Okay. Here I am reading from the back part

of exhibit N. It is called "A brief biography of L. Ron

Hubbard." And its pages, I believe, are numbered.

I put a great deal of reliance on the

representation that L. Ron Hubbard spent several years and

traveled around Asia; that he had been in China and India

and studied with Llama priests; that is on page 1.

That he was a nuclear physicist; although I

don't see that in here. It was just that he was a member

of the first U.S. course in formal education of what is

called today nuclear physics.

That he excelled in his subjects.

That he headed expeditions to study savage

peoples; the fact that he was a member of the Explorers'

Club; that he had done considerable movie work. And all of

1398

the war service that this could be sort of capsulized with

the fact that he was a hero.

I had seen these and other biographical

sketches by this time in which he was represented as a

commander of a squadron of Corvettes; that he had been

wounded in action, blinded.

I relied greatly on the claims from that

period that Dianetics and Scientology were sciences.

And the next section here, 'A science is born"

on page 4, there is a statement by L. Ron Hubbard, "It was

inevitable that a man who spent his youth in Asia and who

studied at the mathematics and physical science of the West

would become interested in the mind and any such man combining

what he knew would probably have discovered Dianetics and

Scientology."

Further down, he says, "Scientology is an

organized body of scientific research, knowledge concerning

life, life sources and the mind and includes practices that

improve the intelligence, state and conduct of persons."

These were things which I relied upon, the

claim that it was a science and was demonstrably true and

especially that L. Ron Hubbard had, apparently, spent a

great deal of time studying in Asia, studying the wisdom of

the Far East and combining it with his knowledge of mathematics

and sciences.

Q Did you rely on any aspect of Mr. Hubbard's

educational background?

A Yes. I think I have mentioned something about

1399

that. His claim that he was an atomic physicist; that he

had graduated from George Washington University; that he was

an engineer.

Q And during that period of time did you also

read several books written by L. Ron Hubbard?

A Yes.

Q Let me show you these two books.

May they be marked as exhibits O and P

respectively, Your Honor?

THE COURT: Identify which is O and which is P.

MR. FLYNN: "Dianetics, the Original Thesis".

"All About Radiation by a Nuclear Physicist

and a Medical Doctor" is exhibit P.

Q Between 1969 and the time you joined the

Sea Organization, did you read those books, Mr. Armstrong?

A Yes.

Q And what, if any, representations about

Mr. Hubbard that were made in those books did you rely upon?

A Do you wish me to look at the books?

Q Can you recall any without looking at the books?

A Well, I think during that period of time each

one of the books had either about the author sections or dust

jacket material which contained a fairly standard story about

Mr. Hubbard.

The thing which stuck in my mind through

many years was his claim to have been crippled and blinded

during the war and that he cured the injuries and the

blindness using what he knew of the mind and that this was

1400

the precursor of Dianetics.

This was -- to me at the time this is what it

was all about. This was the thing it could do.

He claimed to have twice been pronounced dead.

It was a matter of medical record that he was twice pronounced

dead.

Again, the war career came up. He claimed to

have been a commander of a Corvette squadron, been extensively

decorated; saw service in several theaters of war; was

obviously in combat. The claims of having studied in the

Far East, having studied under Llamas and having combined the

wisdom of the Far East with the knowledge of nuclear physics.

Most of them claimed that he was a graduate of George

Washington University.

1401

Q And in the --

MR. HARRIS: Excuse me, Your Honor. Just so I can

get this straight.

Is the witness now stating that these are

things that he read between 1969 and 1971 when he joined the

Sea Organization or is he encapsulating what is in exhibits?

THE COURT: Well you can clarify that, Counsel.

Q BY MR. FLYNN: Well, what you have just

testified to, Mr. Armstrong, is that a summary of what is in

exhibits N, O and P?

A Yes.

Q And in exhibit P, "Dianetics the Original

Thesis" does it state that he graduated from Columbian College,

part of George Washington University?

MR. HARRIS: Objection; leading and suggestive.

THE COURT: That is not particularly. Overruled. He

asked whether it so states.

MR. HARRIS: May the record reflect the witness is

reading the book?

THE COURT: Well he is looking at it. I don't know

if he is reading the entire book, but he is looking at a

page, appears to be looking at it or was.

Q BY MR. FLYNN: What page in exhibit P contains

biographical background of L. Ron Hubbard, Mr. Armstrong?

A 158 and 169.

Q And did you read that prior to joining the

Sea Organization?

A Yes.

1402

Q And are there any representations in there

about Mr. Hubbard's biographical background that you relied

upon?

A Yes.

Q And would you read them, please?

A (Reading):

"Much of Hubbard's early youth was spent

in the American West and he traveled extensively

in Asia, as a young man. He studied sciences

and mathematics at George Washington University,

graduating from Columbian College. He attended

princeton University and obtained a degree as

Doctor of Philosophy, Ph.d. from Sequoia University."

Q If I can stop you there, is it your understanding

that Columbian College is a college of engineering and

mathematics at George Washington University?

A My understanding is that it is at least the --

MR. LITT: Objection as to what his current under-

standing is. Was this his understanding in 1969 to 1971

when he read it and relied on it.

THE COURT: Well, I suppose if he knows what it is,

it may be a fact which is something that can be testified

to as distinguished from what he was relying upon at that

time, so I will overrule the objection.

THE WITNESS: My understanding was that he graduated

from George Washington University, of which Columbian

College was a part.

Q BY MR. FLYNN: And when you read exhibit O, did

1403

you understand that Mr. Hubbard was a nuclear physicist and

a medical doctor?

MR. LITT: Objection; leading.

MR. FLYNN: Withdraw it, Your Honor.

Q What if any understanding did you have with

regard to Mr. Hubbard's biographical background when you

read exhibit O, Mr. Armstrong?

A That he was a nuclear physicist.

Q And let me show you a document entitled

"My Philosophy" by L. Ron Hubbard.

May this be marked, Your Honor, as exhibit Q?

THE COURT: So marked as Q.

Q BY MR. FLYNN: Did you receive that before

joining the Sea Organization?

A Yes.

Q What, if any, representations did you rely

upon about Mr. Hubbard's background in that document,

exhibit Q?

MR. HARRIS: In joining the Sea Org? Is that the

reference, Your Honor?

MR. FLYNN: In joining the Sea Organization.

THE COURT: All right.

THE WITNESS: Again here is the claim of having

wandered through Asia; that he had been through a terrible

war and suffered terror and pain uneased by a single word

of decency or humanity.

But he had been blinded with injured optic nerves

and lame with physical injuries to hip and back at the end

1404

of world War II; that he faced an almost nonexistent future;

that his service record stated, "This officer has no neurotic

or psychotic tendencies of any nature whatsoever." That it

also stated "permanently disabled physically."

That he was abandoned by family and friends

as a supposedly hopeless cripple and probable burden upon

them for the rest of his days; that he yet worked his way

back to fitness and strength in less than two years, using

only what he knew and could determine about man and his

relationship to the university.

That he had no one to help him and that he was

studying when he couldn't see.

Q And did you believe all those representations

at the time?

A Yes.

Q Let me show you several other publications.

Do you recognise a book called "Successes of

Scientology," Mr. Armstrong?

A Yes.

Q And did you read that before joining the Sea

Organization?

A Yes.

MR. LITT: If I can -- it is the page that contains

longhand?

MR. FLYNN: Correct, with a picture of Mr. Hubbard,

and may this be marked, Your Honor, as next in order?

THE COURT: Okay.

Q BY MR. FLYNN: And did you rely on representations

1405

in there about Mr. Hubbard and his background under his

picture?

A Yes

Q And were those similar representations as to

what you have already testified about?

A Yes, I believe this is a duplication of one

of these that I read.

1406

Q And with regard to this biographical sketch

that you now have in front of you, Mr. Armstrong, do you

recognize that?

A Yes.

Q And it bears the caption at the top "L. Ron

Hubbard"; is that correct?

A Yes.

MR. FLYNN: May that be marked next in order, Your Honor?

THE COURT: Exhibit S.

Q BY MR. FLYNN: Did you read that before

joining the Sea Organization?

A Yes.

Q And were similar representations made by

Mr. Hubbard in that document?

A Yes.

Q Did you rely on those?

A Yes.

Q And with regard to a document entitled "Advance 7,"

did you see that before joining the Sea Organization?

A Yes.

MR. FLYNN: May that be marked as exhibit next

in order, Your Honor, entitled "Operation Earth"?

THE COURT: That will be exhibit T.

MR. LITT: Could we have the names of the

publications that R, S and T are from?

THE COURT: Give us that again, Mr. Flynn.

MR. FLYNN: T is from a publication entitled "Advance 7."

THE COURT: Is there a date on it?

1407

MR. FLYNN: I believe it is 19 January, 1970 on the

back page.

MR. HARRIS: And the church or mission that published

it?

MR. FLYNN: Advanced Organization, Los Angeles.

"Successes of Scientology" is copyrighted 1968

by L. Ron Hubbard; published by Publications Organization

Worldwide.

MR. LITT: Exhibit S?

MR. FLYNN: Exhibit S, Your Honor, is the one-page

biographical sketch of L. Ron Hubbard.

THE COURT: Yes.

1408

Q It is from a magazine entitled "Scientology

L. Ron Hubbard.

THE COURT: You are losing us rapidly, Counsel, the

way you are doing this.

MR: FLYNN: The page, Your Honor, that is from this

book is a page that bears at the top "L. Ron Hubbard" in

large --

THE COURT: That is exhibit S?

MR. FLYNN: Exhibit S.

THE COURT: You want the whole book marked S; is that

correct?

MR. FLYNN: Correct, Your Honor.

MR. HARRIS: Do you have a copy of the whole booklet

for counsel?

MR. FLYNN: I don't. What we are primarily relying

upon is that page, Your Honor, but it comes from the book.

THE COURT: Okay.

Henceforth, I don't know whether you have any

more publications, but let's mark the publication and then

sub-mark the pages T-1 or T-2 or something like that.

MR. FLYNN: That is fine, Your Honor.

That is all I have for now.

THE COURT: Okay.

Q BY MR. FLYNN : What is on exhibit T?

THE COURT: Haven't got to T yet.

MR. FLYNN: That is that "Operation Earth."

THE COURT: Okay, "Operation Earth."

1409

MR. FLYNN: From "Advance 7."

THE COURT: Let's mark the book as T and this particular

page as T-1.

MR. FLYNN: So then "Advance 7" is T and the page will

be T-1.

THE COURT: "Advance 7" is some new system of

numbering.

Q BY MR. FLYNN: Now, what in connection with

the publication that appears at the top "Operation Earth"

did you reply upon, Mr. Armstrong?

A Statement here about the Sea Organization, that

the Sea Organization was formed to compose a superiorly

disciplined, elite group, working directly under Ron to aid

the creation of a new civilization on this planet.

Q Now, in connection with those publications,

in all of the publications you read before joining the Sea

Organization, can you summarize the representations about

L. Ron Hubbard that you relied upon in joining the Sea

Organization?

A First of all that he was the head of the Sea

Organization and that I would be working for him. That he was

a hero, an explorer, a scientist, a nuclear physicist, a

mathematician. He was an engineer.

That he had studied for a great period of time

in Asia and India and China, Mongolia, and that he had combined

the wisdom that he learned first hand in the East with the

scientific training in western universities, and the result

was the science of Scientology, and the Sea Org were the elite

1410

of Scientology who were working directly with him to create

a civilization out of barbarism, which is earth.

THE COURT: How old were you at this time?

THE WITNESS: Twenty-three.

Q BY MR. FLYNN: And what was your educational

background at that point, Mr. Armstrong?

A Well, I had attended high school. I never

graduated from high school.

I had taken a half a year of university at

the University of British Columbia and had dropped out at

that time.

Q And did you believe that Mr. Hubbard was a

highly educated man?

A Yes.

Q And did you believe that he was a war hero

during World War II?

A Yes.

Q And did you believe that he was a nuclear

physicist?

A Yes.

Q Now would you describe what happened in the

circumstances under which you joined this organization called

the Sea Organization?

A As a result of everything that I had read and

attending some lectures given by Sea Org recruiting personnel

up in Vancouver, I flew down to Los Angeles. I sold everything

I had and put together enough money to go down to Los Angeles,

and I signed at that time a billion year contract and

1411

within a few days of that I went on board -- it was called

a station ship at that time, a little, former military

vessel called the Bollivar which was in Long Beach Harbor,

and I was on board the Bollivar for seven days, and then I

was flown to Madrid, Spain, and then I was put on a train

down to Algeciras and across from Algeciras, Spain to Tangiers,

Morocco where the Apollo, which was the flagship of the

Sea Organization, was docked at that time, and I went on

board the Apollo and I was on board for the next four years

or more.

Q Now when these lectures were given by a Sea Org

recruiter, what was the nature of those lectures?

MR. HARRIS: The nature of the lecture is vague. If

it is to be a conversation or a lecture, who was present,

who was the speaker, et cetera.

THE COURT: I don't think that is necessary. I

think you can describe generally what it is all about. We

don't have to have the speech in its entirety, but you can

describe generally what it was all about.

THE WITNESS: Well, someone from the Sea Organization,

a Sea Org officer or someone involved with recruiting for the

Sea Organization came occasionally to the outer franchises

and talked to people who would be assembled to listen to the

talk, and it had to do with what the Sea Organization was

doing, what Ron was doing, what the Sea Organization offered

to anyone who joined it, and that was principally what it

was.

Q BY MR. FLYNN: And were representations made

1412

about Mr. Hubbard during those lectures?

A Well, always there was talk of him and the fact

that we would be, the Sea Organization worked directly for

him, and always there was the talk of how great he was and

that sort of thing.

I don't recall specific representations at that

time that people read from the biographical sketches at that

time. That occurred on a regular basis later, but not at

that time.

Q Now were there representations made about

Mr. Hubbard's honesty, integrity and moral character?

MR. LITT: In the lecture given by this unnamed Sea Org

person?

MR. FLYNN: I will withdraw it.

Q Prior to you joining the Sea Organization,

were there representations disseminated about Mr. Hubbard by

Scientology organizations about Mr. Hubbard's honesty,

integrity and moral character?

A I believe so. The subject of honesty and truth

permeated virtually everything that he wrote. It was the

major factor which got me into Scientology with the promise

of truth and the promise of honesty, and it was in all of

his materials.

1413

Q In fact --

A Never could one glean from the material that it

was dishonesty which was looked up to by either him or the

organization.

Q Would you turn to the back page of exhibit N,

the long biographical sketch "PRO News"?

Is there a reference on the bottom of that in

large type, Mr. Armstrong?

A Yes.

Q And is that under the picture of L. Ron Hubbard?

A Yes.

Q And under his name?

A Yes.

Q And what does that say?

A "Truth is the exact time, place, form and event.

Axiom 38. LRH."

Q And did you understand truth to be the

underlying basis of all of the Scientology principles?

A Yes.

Q And that it was Mr. Hubbard that that principle

emanated from? Did you understand that?

A Yes.

Q And was that one of the primary bases for your

joining the SEA Organization?

MR. LITT: Objection. Leading.

THE COURT: Well, he has already testified to that.

I'll sustain the objection.

Q BY MR. FLYNN: When you arrived on board the

1414

ship in Morroco, would you describe what duties you were

assigned to.

A Initially, over the first couple of days, I did

introductory packs, introductory briefing packs which

everyone who came on board had to do.

Thereafter I worked for a brief time in the

Galley unit of the ship as a storesman. And I was connected

with the Galley, washing dishes, that sort of thing, for

probably a couple of weeks.

Then I became the -- I joined what is called the

Deck Project Force. And I learned deck skills. And I

principally was painting and chipping the ship for another

couple of weeks.

Then I became the boat and transport in charge.

And during that time I had under me all the ship's life

boats, some sleds, motor boats and the vehicles which were

on board the ship which we disembarked -- when we came into

port, we took them off the ship and the people who had

business in port used them. So there was a number of

Mopeds. And I was responsible for those.

Sometime in mid-April --

Q This is what year, now?

A 1971.

Sometime in mid-April we took off the ship

Hubbard's cars because we were taking them to a villa which

he had in Tangier at that time. So we took them off the

ship. And one of them was a small Fiat car. And he ordered

that I be driver of that car.

1415

So for the next eight or ten months, I guess,

until approximately February of '72, I just drove the car.

That became my job. And I drove people around who had

business in the ports where we visited.

So we took the car off the ship whenever we came

into port and I drove it for transporting goods and people

and put the car back on when we sailed.

Q Now, between the time you joined the ship in

Morroco and up to the time you completed your duties as a

car driver, did you participate in any religious activities?

Just yes or no.

MR. LITT: Objection.

Is this calling for this witness' opinion, or is

this --

Scientology is a religion. The court has found

that Scientology is a religion.

THE COURT: He just asked if he participated in any

religious services.

What is so difficult about that?

MR. LITT: What he is going to say --

THE COURT: I don't know what he is going to say.

MR. LITT: He is going to get into a discussion about

whether certain activities are religious or not which is not

justiciable. He is going to say, "No, I didn't."

And we'll say, "Yes, he did."

Is the court going to decide which is which?

THE COURT: I am not worried about that. I can't see

any big problems about that.

1416

MR. HARRIS: Could I give the court a few First

Amendment cases?

THE COURT: We are not getting into any First

Amendment cases. He just asked him if there were religious

services.

MR. HARRIS: Is that his state of mind, Your Honor?

THE COURT: I have no idea what the answer is going to

be.

THE WITNESS: I believe the answer to your question,

if I recall the question correctly, is no.

Q BY MR. FLYNN: And during that period of time

did you participate in briefings as to who you were working

for when you were doing the duties you described,

Mr. Armstrong?

A Yes.

Q And were these regular briefings?

A Well, what they were was immediately that

someone came on board, they were briefed; they had to do a

pack of materials; they had to study these materials and

they had to drill the answers to -- before they were allowed

off the ship they had to be checked out on the shore story.

There was a Shore Story which was originated by

Hubbard which was the -- it was what we represented to the

local people.

Q What did you represent to the local people?

A We were to tell them that we were something

called "Operations and Transport Corporation," Limited. It

is a Panamanian corporation. And it was a business

1417

management company; that the function of our business was

to -- we performed two functions. We managed other

businesses around the world and we were paid by a percentage

of increase in profits of those corporations or businesses

which we managed or provided managerial expertise to.

The other part of it was that we brought people

on board, both OTC personnel and personnel from other

corporations around the country -- around the world to train

on board. And we received moneys for teaching them this

very advanced business technology.

Q OTC is Operation and Transport Corporation?

A Yes.

Q Was that a profit-making corporation?

MR. LITT: If you know.

Q BY MR. FLYNN: If you know.

THE COURT: If you know.

THE WITNESS: Yes. I know on both scores.

What we were to represent to the local people

was that we were a profit-making corporation. And according

to the articles of OTC, we were also a profit corporation.

Q BY MR. FLYNN: Did you have possession of the

Articles of OTC at some point when you were on the ship?

A Yes.

Q Under what circumstances did you have those

articles. Mr. Armstrong?

A Well, after I was the ship's driver, I became

what was known as the ship's rep, ship's representative.

And at that time I was in charge of on board legal

1418

activities.

I was the point of contact between the ship and

the customs people, the immigration, police, port

authorities, ship's agent and any sort of legal dealing

which we had of a local nature; for example, with the

Panamanian Consul. We were a Panamanian vessel. OTC was a

Panamanian corporation. And I occasionally had dealings

with the Panamanian Consul, that sort of thing.

So to answer your question, it was in the

context of being the ship's representative that I had

OTC papers.

Q From whom did you take your orders when you were

the ship's representative?

A The chain of command ran basically L. Ron

Hubbard; down to the captain. Down to the port captain;

down to me. That was when I was the ship's representative.

At any point there could be a bypass in the

line. So occasionally I took them directly from L. Ron

Hubbard or from the captain.

But generally, on a day-to-day basis, for most

activities I would take them directly from the port captain;

sometimes directly from L. Ron Hubbard.

1419

Q And this shore story, as you put it, what does

the term "shore story" mean while you were in the position

you were in on board the boat?

A Well it became obvious to me that it was a

cover. A shore story was a cover which was developed in order

to present to the local people and the local authorities

a different picture from what we really were.

Q And did you receive wage vouchers while you

were on board the Apollo?

A Yes.

Q And what type of wage vouchers did you receive?

A Well they were basically what was produced,

entered into evidence, but these ones had OTC on the top of

them.

Q And what was your pay, Mr. Armstrong?

A It varied between nothing per week up to $17.20

per week.

Q And was it your understanding at the time that

yu were an employee of OTC, Operation Transport Corporation?

A Well, it is a bit confusing. We probably in

a legal sense were really employees of OTC, but we weren't

really paid as employees of OTC. We weren't paid like normal

employees would be paid.

However, each person on board the ship had to

sign on the -- had to sign the ship's articles as a crew

member of the ship, and the reason for that was to circumvent

the marine regulations regarding passenger vessels because

the ship vas not safe as a passenger vessel.

1420

It would not have passed inspection, so they

circumvented that by having everyone sign on as a crewmember,

so it then became a yacht.

So, there was approximately between 350 and

430 crew on board, and each one in signing ship's articles

became in that way an employee of OTC, Operation Transport

Corporation Limited, but each person also knew that he was,

in fact, a member of the Sea Organization and that fact was

kept from the public. Local authorities were not to know that

we were the Sea Organization. We were to be a business

management corporation, so the local authorities we were to

tell them that we were employees of OTC.

When the subject of pay came up, we were to

either not answer or tell them that, "Oh, yes, we are very

paid, but I'd rather not talk about what I get."

Q And did you make those representations to

numerous people in various ports in connection with the

duties on board the ship?

A Yes, probably to thousands of people.

Q Now you were paid by a business management

corporation?

A Yes.

Q And was everyone on the ship who signed the

ship's articles as a crew member drilled to do the same thing?

A Yes.

MR. HARRIS: How could he possibly know, Your Honor,

that everybody on the ship --

THE COURT: Well, I don't know. This is obviously a

1421

belief.

You can lay a further foundation as to how he

would have that belief.

Q BY MR. FLYNN: How do you know that, Mr. Armstrong?

A Because it was my duty to brief everyone.

Q And when did you assume those duties?

A The beginning of 1972.

Q And what was your title at that time?

A Ship's representative.

Q And it was your responsibility to drill these

people on these fabrications?

A Right.

Q And at the time --

MR. LITT: Objection to the term "fabrication",

Your Honor.

THE COURT: All right, I will sustain the objection.

BY MR. FLYNN: Well, at the time that you were

drilling these people, Mr. Armstrong, did you understand

that these representations were false?

A Yes.

Q And in what way were they false?

A Well each person knew that he was a member

of the Sea Organization. Additionally each person who came

there from an outer organization to do courses on board or

be audited on board knew that he was not a crew member.

No one knew before they were coming to the ship that they were

going to be OTC. Each person thought that he was coming to

do a Scientology course of some description, and the local

1422

authorities were never told about OTC or about Scientology

and, in fact, we would deny any connection.

Q And were there training manuals to teach you to

lie about those facts?

A Well, there was packs of material. I guess

they could be called training manuals, but the drilling was

very extensive. The person had to get the shore story very

firmly in his mind, and I myself was trained to ask questions

and trip them up and then give them the information which

would have them broaden the story sufficiently in their own

mind so that they would be able to field any question if asked

by local people.

Q And who do you know that this was done in part

in order to avoid the marine regulations relating to

passenger vessels?

A Well, because that situation came up a number

of times throughout the history of my time on board in which

the local port authorities would, because we did not have what

is called a SOLAS certificate, safety of life at sea -- there

is a SOLAS convention which proscribes what is necessary for

safety equipment or standards of the ship for vessels of

certain tonnage with certain numbers of people on board.

1422

And our vessel was not safety certificated. And

the way we got around that -- because the -- Hubbard did not

wish to bring the vessel up to standard. My guess is to

save money --

THE COURT: Let's not get involved in guesses.

Strike that.

THE WITNESS: Okay.

Q BY MR. FLYNN: In any event --

A As a result, we signed everyone on board because

we ran into that problem on occasion with harbor masters or

port authorities in various ports that we visited.

Q At any time on board the ship did you learn

whether Mr. Hubbard owned Operation Transport Corporation?

A Yes.

Q And under what circumstances did you learn that?

A Well, first of all, there was the original

articles of incorporation. And there was some information

on shares that were kept in the port captain's office files.

Additionally, in 1973, I believe OTC was

incorporated, in '67 or '68. But I believe it was '67.

In 1973 I was involved in the back-dating of

some Board minutes back to either the same day or the day

following the day of incorporation. And those Board minutes

took Hubbard off the Board of Directors at that time. And I

had to get Hubbard's signature authenticated by the

Panamanian Consul in Lisbon at that time.

I also had authenticated the signatures of the

other incorporators or the other original Board so that

1423

their resignations were either the same day or -- Anyway,

the first Board minutes in the corporation, but it was six

years later.

Q How long did you remain on board the ship, the

Apollo?

A From February '71 through, I guess, September of

'75.

Q Now, at any time during that period did you

understand that you worked for any organization or

corporation other than Operation Transport Corporation?

A No.

Q At some point did you become the port captain?

A Yes.

Q And when was that, Mr. Armstrong?

A That was -- it was just a brief period. And

that was in early 1974.

Q What were the port captain's duties?

A Well, the port captain was over the ship's

representative and over the intelligence officer and over

some of the PR positions on board. And he was the captain

of the ship as far as the port authorities were concerned

when the ship was in port.

There was another captain who was the actual

captain for navigation purposes. But the port captain

assumed that role as far as the port authorities were

concerned while the ship was in port.

Q Now, throughout the period of time that you were

on board the ship did you become involved in briefings with

1424

regard to whether Mr. Hubbard was receiving any money from

Scientology organizations?

A Well, that was part of the -- when I got into

the port captain's office, we were briefed on other subjects

as well because occasionally it would happen that we would

be noticed.

The ship had a prior record as being a

Scientology ship; additionally, Scientologists would

occasionally show up at the ship, hoping to come aboard or

to talk to Hubbard or something. So these were

Scientologists who were not supposed to be in the area that

the ship was in, but they would arrive there.

So we had briefing packs in which we were to

handle some of the questions which came up about Hubbard or

about Scientology. And that subject would come up. And

the -- about whether or not Hubbard was getting 10 percent

of the income of Scientology organizations.

That was a question which arose often in the

press. And we were trained to handle those questions, to

deny that he received any money from Scientology and to deny

any real connection to Scientology; that he had resigned as

a director in 1966.

Q Now, throughout the period of time that you were

on board the ship did you observe Mr. Hubbard's activities

with regard to issuing orders to ship's personnel?

A Well, I would have seen it, not on a daily basis

necessarily, but sometimes for brief periods during a day or

sometimes for a great length of time during a particular

1425

day.

But I was able to see him probably hundreds of

times issuing orders throughout the time I was on board.

Q What is your understanding as to who exercised

ultimate supervisory authority over the day-to-day

activities of the ship while you were on board?

A Hubbard.

Q And were you taught to deny that that was the

fact when you dealt with official agencies at the various

ports that you went into?

A Yes.

Q And were you taught to deny that to people who

came to the ship asking questions about the ship or

Mr. Hubbard?

MR. LITT: Objected to, Your Honor, as leading and

suggestive. Asked and answered.

THE COURT: Overruled.

You can answer.

THE WITNESS: Yes.

Q BY MR. FLYNN: Throughout the period of time

that you were on board the ship did you participate in any

religious activities?

MR. HARRIS: Is this a characterization, Your Honor?

THE COURT: The activities which you believed to be

religious; you may answer it in that form.

THE WITNESS: There was -- there was one.

Q BY MR. FLYNN: And one in how many years?

A Four years. All that time, four years and

1426

several months.

Q What was that one event?

A That is when I was married.

I wasn't really married. I should explain.

Q What were the circumstances surrounding your

marriage?

A Well, I was married legally off the ship. We

were in Free Port in the Bahamas at that point. And I got

married. Just prior to that we were in Nassau, one of the

other islands. And I got legally married.

Then we had a ceremony on board the ship in

which the Scientology wedding ceremony was read. But it

wasn't -- it was just a ceremony; it wasn't a marriage.

1427

Q And did Mr. Hubbard participate in your wedding?

A Yes.

Q And in what way did he participate?

A He gave away the bride.

Q And what was your wife's name?

A Terri, Terri Gillan.

Q Do you know what her present name is,

Mr. Armstrong?

A Yes, Terri Gamboa.

Q And do you know whether she presently has a

role with any of Mr. Hubbard's organizations?

A Yes.

Q And what is that?

A She is part of what is called ASI, Author

Services Incorporated.

Q Now throughout the period of time that you

were on board the ship were there on-going and continuous

representations made to people who came on board the ship

about Mr. Hubbard?

A Yes.

Q And were any of these representations made

in any type of a formal way?

A Well, yes.

Q And in what formal way?

A Right. There were briefings on board the ship

and, in fact, there was an LRH public relations officer on

board the ship who occasionally gave briefings, and the

briefings would be about Ron. Much of the material

1428

of the briefings would be what is contained in these exhibits.

Additionally, there were during the time on the

ship, there were some other biographical sketches created

on board and published on board, both mimeograph and I believe

notations of this nature.

Q Did you see Mr. Hubbard create those biographical

sketches?

A Not those ones.

Q Did you see him create any biographical sketches?

A Not the actual creation. I have seen things in

his hand which are identical to these materials, so I have

seen --

MR. LITT: Which materials?

Q BY MR. FLYNN: For example exhibit N, the long

biographical sketch of Mr. Hubbard in exhibit N, have you seen

Mr. Hubbard's handwritten biographical sketch which was later

typed up and made a part of exhibit N?

A Yes.

MR. HARRIS: Just so I am clear on this, Your Honor,

I am not sure for what purpose this is being introduced; in

respect to his archives post or as inducement to join the

Sea Organization?

THE COURT: Well, it goes to developing the total

picture as to a course of events that led up to the events

in question. Overruled.

Q BY MR. FLYNN: Did you see that, Mr. Armstrong?

A Yes.

Q Do you know where it presently is, the handwritten

1429

version of exhibit N?

A It is ---- I can tell where I last saw it.

Q Where did you last see it?

A It was in the archives in the Cedars Complex.

Q Now when you were working on board the ship

for the OTC corporation, did you have any understanding as to

whether or not you were also working for L. Ron Hubbard?

A Yes.

Q And what was that understanding?

A Well that was the real truth of what we were

doing. Each person -- that is who we were working for. He

was the Commodore of the Sea Organization. We were all

Sea Org members. There was no one senior to him and we all

worked for him.

THE COURT: Who was the billion year contract, who

were the parties to that if you can recall?

THE WITNESS: It was just a contract which bound me

to the Sea Organization.

THE COURT: You were the only person that signed it?

THE WITNESS: Yes.

THE COURT: Oh.

THE WITNESS: I should say there was a witness to my

signature, but that's it.

THE COURT: All right.

Q BY MR. FLYNN: Now, throughout the period

you were on board the ship did you have access to public

relations material relating to representations about

L. Ron Hubbard's background?

1430

A I had access to this kind of material. I had

access also to some of what you would call unfavorable material

which had appeared in newspapers and magazines and that sort

of thing, what the organization called "entheta" so I had

seen and had in the port captain's office files of some of

that type of material.

Q And did your duties as port captain or ship's

rep relate in any way to dealing with unfavorable materials?

A Well, not a lot directly. We were briefed on

it and occasionally, as I say, someone from outer organizations

or from what's called the field, some other country would

show up at the ship and we would have to handle their questions.

In Curacao and actually in Barbados, Trinidad

and later in Curacao, and this was in the summer and fall of

1975, a number of questions at that time came up about

Hubbard because by this time the cover had been blown regarding

OTC and those countries had identified the ship as a

Scientology ship and knew that Hubbard was on board.

1431

So at that point I became more intensely drilled

in handling Hubbard's representations.

Q And did you make any representations about him

in response to questions as to whether he was a director

from Hollywood?

A During that period of time?

Q Yes.

A Yes. As a matter of fact, because in Curacao,

particularly in Curacao and even earlier, we had on board

something called the Photo Shoot organization. And part of

the PR surrounding the Photo Shoot organization, which was

going off the ship into the community and either

photographing local cites or photographing staged sets and

scenes later to be used in scientology publications, there

was the PR surrounding that; that Hubbard was a Hollywood

director, former Hollywood director.

Q And were there specific movies that you

represented to people that he directed?

A No, not at that time.

Q At a later time?

A No, no. I have never heard what he had

directed, just that he was a Hollywood director.

Q Did you make any representations to people about

whether he had written a screenplay of the movie "The

Divebomber" at that time?

A No. The -- there was a PR -- there was a

biographical sketch which was created around that time. And

that contained a representation about "The Divebomber." But

1432

I myself did not ever mention "The Divebomber" to anyone

until sometime later.

Q During the period of time that you were on board

the ship did you observe how people who had either made

mistakes or had become antagonistic to Mr. Hubbard or

anything that he ordered were treated?

A Yes.

Q And what did you observe?

MR. HARRIS: Could we have some specifics as to who

these individuals were?

THE COURT: I assume that can be developed.

You may continue.

THE WITNESS: What sticks in my mind is that in the

beginning of 1974 Mr. Hubbard created something called RPF,

the Rehabilitation Project Force, it was called. And people

were ordered by Hubbard, if they had -- if they had what he

called counter-intention, CI. And it was counter-intention

to his orders, his policies, and any counter-intention to

any project that he was involved in, what he wanted to get

done.

And people were on a daily basis throughout a

great deal of 1974 routed into the RPF. And the RPF was a

segregated group of people who were -- that were treated as

prisoners.

They had to perform -- it is something more than

menial tasks. It was forced labor under extreme conditions.

And they wore black boiler suits. And that is how they

stood out from the rest of the crew.

1433

A great number of people were ordered by Hubbard

into the RPF which was created at that time.

Q Now, did you ever observe anyone locked up in

the ship's chain locker during the period you were on board

the Apollo?

MR. HARRIS: Objection. Leading and suggestive, Your

Honor.

THE COURT: Overruled.

THE WITNESS: during the time I was on board, yes. I

saw one little kid. He was a -- that is the only one during

that time that I recall. And he was a kid, I guess, about

13 or 14.

Q BY MR. FLYNN: How long was he locked in the

chain locker?

A I don't know exactly how long, but it was -- I'd

say at least a day, maybe longer.

Q What was the chain locker, Mr. Armstrong?

A The chain locker was in the bow of the ship.

There was two of them. We had twin anchors up forward. And

the chain, which had links about a foot across, when the

chain was drawn in and the anchor was lifted up into the

haws pipe, the chain fell down into about a four-foot square

iron -- steel tube. And that was the chain locker. It had

a metal lid on it.

Someone assigned to the chain locker would

simply sit on this pile of chain links during the time that

they were in the chain locker.

Q And other than your actual observation of that

1434

one 13-year-old child did you understand that to be a

routine punishment?

MR. HARRIS: I don't know if we are getting a

compilation of hearsay, reputation, or what, Your Honor.

This is for his state of mind, not the

actuality, I presume?

THE COURT: He, apparently, was there for four years.

He probably has a pretty good idea of what discipline was

involved.

MR. LITT: Are we talking about what he knows, what he

heard, or what he thinks?

THE COURT: What he saw, observed over a period of

time.

Overruled.

You may answer.

THE WITNESS: During the time I was on board, it was

not a form of punishment which was often used.

I heard of someone else being put in during that

time. I don't even recall the name at this time. So it was

unusual.

Q BY MR. FLYNN: What was your mental state while

you were on the Apollo, Mr. Armstrong?

THE COURT: That covers a lot of time, counsel. I

don't know what you have in mind. Four years of mental

states?

Q BY MR. FLYNN: Is there any particular emotion

that you recall, Mr. Armstrong, as being the dominant

emotion while you were on board the Apollo?

1435

A Yes. I think that aside from the hours in which

I was sleeping and occasionally during moments of relative

lightness. I think that I was pretty much in fear the whole

time.

THE COURT: I think we'll take a 15-minute recess.

(Recess.)

1436

THE COURT: All right. In the case on trial let the

record reflect that counsel are in place and the witness

has retaken the stand.

Just state your name again for the record, sir.

You are still under oath.

THE WITNESS: Gerald Armstrong.

THE COURT: You may continue, Counsel.

Q BY MR. FLYNN: Now, Mr. Armstrong, do you

recall your testimony that you were briefed to state to

people inquiring about Mr. Hubbard's status on board the

ship that he vas not receiving any money from Scientology

Organizations; do you recall that testimony?

A Yes.

Q Did you know why you were on board the ship

whether Mr. Hubbard did or did not receive funds from

Scientology Organizations?

A I did not know that.

Q Now in 1973 did Mr. Hubbard leave the ship for

a period of time?

A He left actually in the fall of 1972.

Q And for how long a period did he leave?

A He left -- in the fall of 1972 he moved ashore

to his villa in Tangiers. The ship at that point sailed to

Lisbon, and we were in dry dock and wet dock in Lisbon.

He showed up somewhere around Christmas time 1972, maybe

around the 1st of the year, between Christmas and the 1st of

the year, and he stayed at that point off the ship in a hotel

in Lisbon, and at that point he left and arrived back at the

1437

ship in approximately September 1973.

Q Do you know where he went?

A Yes.

Q Where did he go?

A To New York.

MR. HARRIS: And is that personal knowledge, Your

Honor, or hearsay?

Q BY MR. FLYNN: How do you know that,

Mr. Armstrong?

A I have spoken to the two people who lived with

him during the time when he was in New York, and I had a

debrief which was written by one of the people who accompanied

him, and I have seen photographs which were taken of him and

of the area and of the house in Queens, New York where he lived.

Q And who were the people who were with him?

A Paul Preston and Jim Dincalci.

1438

Q How do you spell "Dincalci"?

A D-i-n-c-a-l-c-i.

Q And to your knowledge did Mr. Dincalci take

those photographs in Queens, New York?

A Yes.

Q And at a later point in time did those

photographs come into your possession?

A Some of them, yes.

Q And when was that?

A It was in April 1982.

Q Now, in 1974 were there a lot of inquiries about

Mr. Hubbard's background from people who came to the ship?

A I -- I don't know. There were not a lot of

inquiries that were made of me.

Q When you were the ship's representative did you

deal with claims from outside sources that the things that

were being said about Mr. Hubbard such as are set forth in

the various exhibits that have been marked into evidence

were untrue?

A Let me see if I get your question.

Did I deal with the press or anything like that

which contradicted the claims in these publications?

Q Correct.

A Yes. I received a number of those -- of such

publications which we called N-Theta during that period.

Q At that time did you continue to believe that

the representations that are set forth in exhibits N through

T were true?

1439

A Yes.

Q How did you reconcile in your mind those two

conflicting claims, Mr. Armstrong?

A Well, first of all, the claims were being made

on one hand by Mr. Hubbard who I assumed to be telling me

the truth.

On the other hand, by people who I viewed at

that point as enemies. And we -- we were briefed quite

regularly on board about activities of the Guardian's

Office. And they were involved at that point in what they

called Dead Agent Capers, false report corrections. And

they were attempting -- the claim was made -- to clear up

false reports which were being spread about Mr. Hubbard in

the media and between governmental agencies.

Q Did you understand the term "enemy" to have a

particular significance in terminology used on board the

ship?

A An enemy of Scientology was someone who was

critical of Scientology, critical of Mr. Hubbard; someone

who printed something derogatory about Mr. Hubbard. It was

the psychiatrists, psychologists, the medical profession;

these were -- the IRS, CIA, FBI; these were the agencies

which were the enemies of mankind and the enemies of

Scientology.

MR. HARRIS: Is this his understanding, Your Honor? I

take it it is still going in for that purpose. Because

right now there has been utterly no foundation laid.

THE COURT: The man was on board the ship for four

1440

years; he was deck captain; it would seem that he would have

some familiarity with what was happening and what was being

discussed and the things that were going on.

You certainly have a right to cross-examine on

all of these matters.

Q BY MR. FLYNN: In 1974 did you learn that there

were policies that related to how to deal with enemies?

A Yes. There was a number of -- there were a

number of policies which dealt with that.

In 19- -- by 1974 I had been the port captain.

And I was also in 1974 the intelligence officer on board the

ship. And I knew through the intelligence officer policies

and intelligence officer hat which was originated by L. Ron

Hubbard that there was a certain approach taken to enemies.

I also knew that -- prior to that, from briefing

packs of materials the existence of something which was

called the "Fair Game Doctrine" and that set up the way in

which enemies were to be treated, were to be viewed. That

is principally it.

Q Now, in 1974 did Mr. Hubbard deliver what was

called a source briefing?

A Yes.

Q And what was that, Mr. Armstrong?

A A number of people, maybe somewhere between 10

and 20 people on board the ship were chosen to be PRs,

public relations personnel. And each one of them was

briefed by Hubbard. They were all briefed together. And it

was called a source briefing.

1441

Packs of materials was given -- were given to

each of these people. And then they were sent out to all of

the organizations and missions or franchises

internationally. And they gave lectures or talks or

briefings to all the people at these centers

internationally.

1442

Q And what did Mr. Hubbard say in these briefings

relative to his biographical background?

MR. LITT: Just a moment. I don't think it has been

established whether or not Mr. Armstrong was at these briefings

or I guess it is a briefing.

THE COURT: You can develop that as to whether he was

or he wasn't.

Q BY MR. FLYNN: Were you there, Mr. Armstrong?

A No.

Q Did you at some point receive materials from

these briefings?

A Yes.

Q What materials did you receive?

A I received a -- the pack of materials which

the various public relations people took with them when they

gave the briefings, and I received the transcript of the

briefing that Mr. Hubbard gave to all these missionaires

before they were sent around the world.

Q And where did you receive this pack of materials

from or who did you receive it from?

A Well, the pack of materials was people on the

ship were also the recipients of a source briefing, so

one of the people did that and I only caught a part of it,

but I did have the pack of materials relating to Mr. Hubbard

at that time. So it would be 1974.

Later in 1980 when I was actually in Hubbard's

PR bureau, I had the pack and I also had the transcript of

the briefing.

1443

Q Now in 1974 did you read at least a part of

the briefing relating to certain medals that Mr. Hubbard

claimed he received in World War II?

A 1974?

Q Correct.

A Well, yes, that is the part that actually sticks

out in my mind, and that is because a color plate was made,

a big eight by ten color photo of the medals which Mr. Hubbard

claimed to have learned during the war. In that photograph

there was 21 pedals and palms. A couple of the medals had

palms on them, and subsequently I saw in the briefing that he

had said, "Well, actually there was 28 and that some of

them are missing."

He claimed that some he was given in secret

and they actually couldn't award it to him, and this had to

do with sinking a couple of enemy submarines, and the reason

why he could not be awarded those things out in the open

was because it would have been embarrassing to the naval

command to have had a couple of subs sunk in their own back

yard.

MR. HARRIS: Just because I am totally unclear about

this, the source of this is he hearing Mr. Hubbard saying

this or/is he reading something in 1980 or 1974? Very unclear.

THE COURT: Okay, will you tell us?

THE WITNESS: The first one was in 1974. At that time

I saw the color print which was made available.

At that time I also knew of the claim that there

was more involved there.

1444

Subsequently I had possession of the transcript.

This would be in 1980 and I possessed it throughout the course

of the biography research and also provided it/to Omar Garrison.

So from that point on it sticks in my mind very vividly.

Q BY MR. FLYNN: Now, at some point in time did you

leave the Apollo, Mr. Armstrong?

A Yes.

Q And when was that?

A In September of 1975.

Q And where did you go?

A I went on a leave with my wife at the time.

Q Who was then Terri Gamboa -- Terri Gamboa

Armstrong?

A Terri Gillam Armstrong, yes.

Q How long was your leave?

A About a month.

Q And after your leave, where did you go?

A To Daytona Beach.

Q And did you meet Mr. Hubbard in Daytona Beach?

A I just saw him real briefly.

Q And did you begin assuming certain duties for

any organizations relating to Scientology and Daytona Beach

at that time?

A At that time -- some time in October, November

of '75 I was for perhaps two or three weeks, I was in the

Guardian's office in the intelligence bureau. We had a very

small guardian's office at --- it was a motel we were

occupying under the name United Churches.

1445

Q Were you paid at that time?

A Yes.

Q And what organization or corporation were you

paid by during that period of time?

A Well, there was no name on any disbursement

voucher at that time and I never asked at that time who I

was paid by.

Q And were you paid in cash?

A Yes.

Q And what was your understanding as to what

corporation you worked for, if any?

A Well, it was unclear at that point because we

were told that we were United Churches, United Church of

Florida, so it really depended on who I was talking to.

The only thing I knew for certain, and this

was the only thing which was certain throughout the whole

time I was in the Sea Org was that I worked for L. Ron Hubbard.

What corporation I was a part of was extremely unclear, and

for the most part each one of us involved, and I think at

least myself, I knew that I worked for the Sea Organization

for L. Ron Hubbard. The rest of it was simply a facade

and it was a cover of some sort. So who I worked for back

then, I am not sure.

Q Now, what were your duties in Daytona Beach?

A I had two jobs in Daytona Beach. The first one

was in the Guardian`s office, and in the Guardian's office I

was principally involved at that point in coding and decoding

telexes and gathering local intelligence, and I dealt with the

destruction of security materials.

1446

Q And when you say coding and decoding, what did

that involve, Mr. Armstrong?

A All telexes in and out of the Guardian's office

were coded and decoded.

We had a number and letter system and a

transposition system. And each telex had to be put into a

particular code. And when we received a telex which was in

a particular code, we had to decode it so that it was then

in plain English.

Q How many codes were there?

A Well, at that point there were two codes in use

by my office. And one was the Guardian's office code and one

was the office of the controller code.

The office of the controller was, in fact, the

same office that I was in at this tine.

Q Do you know how many codes the Guardian's

office used at that time other than the two codes that you

were directly involved in?

A No -- I should say there was a third code at

that time that I knew of. And that was a code between the

Guardian's office Ounter Organizations, small organizations;

one between GOUS, which was the central Guardian office head-

quarters in North America. And then there were the Ounter

Guardian's office; for example, New York may have a junior

Guardian's office. And they had a particular telex code at

that time. So I had actually the three codes, one between

GOUS and U and GOWW. Guardian's office worldwide from UK

would use the same code. And then there was the controller's

1447

code.

Q You mentioned you were involved in the destruction

of security documents; what did that involve?

A Well, at that time we simply took out whatever

was not an active file. And it could be a telex master.

It could be that sort of thing. And I took and burned it.

We did not have at that small project shredding

facilities to amount to anything, not enough to handle the

volume that we had.

So I went down the coast, Daytona Beach,

and in an incinerator burned the stuff.

Q Were there instructions on what to destroy

and what not to destroy?

A Nothing that I was aware of at that time.

This was simply material that was given to me

by the various people in the office.

Q So you were just ordered to destroy it?

A Right.

Q And what other duties did you have other than

those duties in the Guardian's office in Daytona?

A I was busted, I guess you would say, from the

Guardian's office at that time.

The I worked on a project -- this had to do

with the move into Clearwater, Florida by the personnel

from the ship and by the Guardian's office. And we were

part of that. We were like a staging area from which the

overall plan was originated and coordinated by Mr. Hubbard.

And he operated several missions, probably dozens of missions

1448

at that time.

And I was at that time busted to the mimeo unit.

So I was printing mission and project orders originated by

Mr. Hubbard and on which people would be brief and then fired

to Clearwater or to some other location to perform part of

their overall move into Clearwater.

The ship at that point was in free port in the

Bahamas. So it was a major task to bring all the materials

from the ship in containers to the base and to establish the

various facilities in Clearwater, the Fort Harrison Hotel,

the Bank of Clearwater building and other buildings.

Q Now, when this move to Clearwater took place as

supervised and coordinated by Mr. Hubbard, did the move take

place under the name of the Church of Scientology?

A No.

Q Under what name did it take place?

A The property was purchased in the name of

Southern Land Development. I believe it was a corporation.

The organization then became United Churches of

Florida. That was the shore story at the time. And that

was the cover which we used up until the beginning of 1976

or a little later.

Q Did you know that the cover using the name

United Churches of Florida was a lie?

A Yes.

MR: LITT: Objection. What --

THE COURT: The words of what they are. I don't know

what you mean by "a lie."

1449

Q BY MR. FLYNN: In fact, was their organization

that existed called United Churches of Florida?

THE COURT: If you know.

Q BY MR. FLYNN: If you know.

A I believe that it was registered or incorporated

in this way.

Were we in fact United Churches of Florida? No.

Q And when you used the term "mission" what did

you mean by that term, Mr. Armstrong?

A I guess the equivalent would be a military

mission, people sent in to perform a particular operation

in another location and then brought back to a base of

operations.

Q Now, at the time of that move did you know

Mr. Dincalci?

A Yes.

1450

Q And to your knowledge did Mr. Dincalci make a

tape recording of orders of L. Ron Hubbard relating to this

mission?

A Well that is my knowledge now. I did not know

about it at the time.

MR. LITT: Is that knowledge based on hearsay or

personal knowledge?

Q BY MR. FLYNN: How did you learn about the tape

recording, Mr. Armstrong?

A I was given a copy of it by Mr. Dincalci.

Q And was it Mr. Dincalci's tape recording?

A Yes.

Q And during that period of time what term did

Mr. Hubbard use to describe a Scientology organization?

THE COURT: Well, wait a minute. Are you talking about --

you said "during that time"; is that something that he learned

at that time or that he learned now?

Q BY MR. FLYNN: During the period of the move

to Clearwater in 1975 did Mr. Hubbard use a term in your

presence regarding Scientology organizations?

A The only thing I can think of is Org.

Q At that period of time did you hear the tape-

recording?

A No.

Q At a subsequent time did you hear the tape-

recording?

A Yes.

Q And do you recall hearing the words "the

1451

company" on the tape recording?

MR. LITT: Your Honor, this is improper. If

Mr. Armstrong is listening to a tape recording provided to

him by one Jim Dincalci, which tape recording has not been

authenticated in any way, Mr. Dincalci is going to testify.

THE COURT: All right, I think you are correct, Counsel.

MR. FLYNN: I will withdraw it.

Q Did you ever hear Mr. Hubbard use the term

"the company" to describe Scientology organizations?

THE COURT: Other than on the tape.

Q BY MR. FLYNN: Other than on the tape?

A I don't believe so. I don't think it ever came

up.

Q Now, when you were working on the mimeo machine,

were you in a particular office of L. Ron Hubbard?

A I was not in what was actually called the personal

office of L. Ron Hubbard at that time.

Q At some time did you move into the personal

office of L. Ron Hubbard?

A That followed the mimeo machine.

Q And when was that?

A That was the beginning of December 1975.

Q And where was that office located?

A Well the personal office -- there were personal

office personnel who were with Hubbard in Daytona Beach. He

was living at that time in a hotel near, you know, a couple

of hundred yards from the motel where all of us were staying

who were in Daytona Beach.

1452

At one point I was assigned to the personnel

office and I was briefed up in Hubbard's suite of offices

by Mike Douglas who was one of Hubbard's personal staff.

Following the briefing I was sent to Dunedin,

Florida which is about six miles from Clearwater, and it was

in Dunedin where I stayed for the next several months in

Hubbard's personal office.

Q And was Mr. Hubbard there?

A Hubbard arrived about four or five days, maybe

three or four days after I arrived in Dunedin. I arrived

in order to set up the communication lines, the telex machine

and mail lines and that sort of thing, and to get the place

ready for his arrival, so he arrived a couple of days later.

Q Now when you were working in the personnel

office of L. Ron Hubbard, what was your understanding as to

who you worked for?

A L. Ron Hubbard.

Q And what did you do in Dunedin?

A I was the -- for the first couple of months I

was the deputy LRH External Com Aide, and the External Com

Aide was Mike Douglas, and I was involved at that point in

again coding and decoding telexes, and the receipt and

distribution of mail which came to all the people in the

personal office who were staying in Dunedin and in the sending,

the transmittal of mail from Hubbard and from the others

in the personal office out to organizations, either in

Clearwater or across the world.

Q And what, in general, did this telex traffic --

1453

is that the term that was used, "telex traffic"?

A Yes.

Q What in general does the telex traffic relate

to?

A Well, I had two sets of telex traffic at that

time, and I was using two codes at that time.

We were at that time called UCE, United Churches

Extension, and the reason for that was to get the telex

machine established in this -- it was actually a condominium

project.

1454

And in order to lease the Telex machine there we

used the name United Churches Extension.

The traffic related or was for the controller's

office or for L. Ron Hubbard. and so we used two codes.

One was the controller's code; one was the LRH code.

Q Now, did you make any observations at that time

as to whether Mr. Hubbard was managing or directing

Scientology organizations throughout the world?

A Well, yes.

Q What observations did you make?

A That was that he was. He was -- whatever he

cared to look at, he looked at. And whatever he cared to

handle, he handled.

He was senior to anyone anywhere.

Q At that time did you receive wage vouchers in

connection with your pay?

A Yes.

Q And what, if anything, was on the wage vouchers?

Q They were blank.

Q Were you paid in cash?

A Yes.

Q After you worked in Dunedin where did you go?

A I think approximately May, late May 1976 I took

a -- I, along with three other people, we were fired on a

mission to establish a staging area for Mr. Hubbard in

Culver City here in Los Angeles. And we drove across the

country taking with us a Telex machine.

Whenever we needed to at that point set up

1455

communication lines within the -- it was an apartment

complex in Culver City. And we took three or four days to

get across the States. And then I spent another week or so

in the Culver area, Culver City staging area, code name

Astra, A-s-t-r-a.

Q What did you do in Culver City?

A I established a -- set up a Telex machine; set

up a phonetic coupler line between our Telex machine and the

GOUS Telex machine; set up a Telex machine in the Guardian's

Office, Telex room in GOUS which was then in the Feifield

Manor in Hollywood.

We set up a mail and air freight line between

our unit and GOUS and between GOUS, which was, again, in

Feifield and Clearwater and the UK.

Q Did Mr. Hubbard at some point arrive at Astra?

A Yes.

Q And when was that?

A It was about a week after my first arrival

there.

First Mary Sue arrived. And she was there for a

couple of days and then Hubbard arrived.

Q Now, were all of these moves, the move into

Dunedin and the move to Astra done with great security and

under-cover?

A Yes.

Q What was your understanding as to why that was

done, Mr. Armstrong?

A Well, at that time in Dunedin or -- Mr. Hubbard

1456

had been identified as living in Dunedin at that time. And

also there were a number of situations arising in Clearwater

which stemmed from Guardian's Office operations in

Clearwater, again, the local officials and also there was a

great deal of public upset toward Scientology in Clearwater,

principally because of their arrival under a false cover,

United Churches.

And the press was engaged in what Scientology

called an attack on Scientology at that time and on Hubbard.

There was a fear at that time that Hubbard was

going to be served, either as a witness or as a party in one

of the actions which were being brought at that time. And

so he fled.

And the cover into Astra was very tight. And it

was simply to be a staging area from which a personal

residence could be set up for Hubbard which would be very

secure.

1457

Q Now, when you were at Astra, what was your

understanding as to who you worked for?

A L. Ron Hubbard.

Q Did you consider your work for L. Hon Hubbard

to be separate and apart from any Church of Scientology?

A In a sense. See, this is two levels of this,

you know, working for L. Ron Hubbard.Everyone in the SEA

ORG. knew that they were working for L. Ron Hubbard, but

additionally, anyone who worked in the personal office

worked for him personally, and that had more weight than just

someone working broadly. I was in another position again

where I was actually living with the man, so I worked for him

just in the sense that I was in the SEA Organization.

I worked for him by virtue of the fact that I

was in the personal office and I worked for him by virtue of

the fact that I was living with him and taking all my orders

from him.

Q When you were in Astra, what year are we in,

what month?

A May and the beginning of June,1976.

Q Now, up to that point in time, did you ever

understand that you worked for the Church of Scientology of

California?

A No.

Q After working in Astra, what did you do?

A I was ordered by Hubbard to be locked up, and I

spent about three weeks under guard in the Fiefield Manor in

the GOUS Building.

1458

Q And why were you ordered by Hubbard to be

locked up?

A Because I had sworn at Mary Sue's communicator

and he deemed me at that point a security risk. They had

some concern that the cover or the location or Astra might

be blown, and so I was, for security reasons, locked up.

Q And when you say "locked up," were you actually

locked in a room?

A Yes.

Q And was there actually a guard at the door?

A Yes.

Q When you say "security risk," what type of a

security risk were you?

A Well, I wasn't a security risk, but what I --

they were concerned at that point, and Hubbard was very

concerned that his location might become known, at which

point someone could serve him with papers in one of the

actions originating from Clearwater.

MR. HARRIS: Just so I am sure. This is the witness

talking to Mr. Hubbard about his concern?

MR. LITT: Is this based on a statement made by

Mr. Hubbard or his state of mind?

THE COURT: Gentlemen, let's just one lawyer object

at a time.

MR. LITT: I apologize.

THE COURT: Are you relying now about personal knowledge

or what, sir?

THE WITNESS: Your Honor, I was told by two people.

1459

One was Mike Douglas who was my direct senior at that time,

and the other one was the person who picked me up, and he

was the head of the intelligence bureau at that time, Dick

Weigand, intelligence bureau in GOUS, and he told me at that

time that Hubbard had requested it. I never spoke to Hubbard

at that time.

Q BY MR. FLYNN: What was the command line?

MR. LITT: Well, wait.

MR. HARRIS: I take it all of this is apparently being

offered for the man's state of mind at this point? Because we

are getting multiple hearsay.

THE COURT: Well, state of mind. Also shows his

relationship to the organization, his contention who he was

working for and whatever rights and obligations he had at a

later date when all of the events germinated here.

MR. HARRIS: Well, as long as we are clear what is

hearsay and what is personal knowledge. There's been a lot of

vast generalities.

THE COURT: Well, there is a statement made by an

agent within the scope of his authority as the agent of the

principal. There are a lot of things here which seem to be

relevant material and competent evidence. So let's go forward.

Q BY MR. FLYNN: At that time, Mr. Armstrong, what

was the command line within the personal office that you

worked in?

A L. Ron Hubbard to Mike Douglas to me.

Q So it was Michael Douglas and Mr. Weigand

personally came and picked you up and locked you up?

1460

A That is correct.

Q During the period you were locked up, where did

you eat your meals?

A In the same room.

Q Were you ever allowed to leave the room?

A I was taken out every -- after the first

approximately ten days, a week to ten days, I was taken out

and I was driven on a daily basis to the UCLA Library.

Q And what did you do there?

A I had to go through the microfilm records to

locate and copy any information on -- there was a number of

medical doctors and some psychiatrists. There was a list of

names. These were people who were all deemed enemies of

the organization or people who had been critical of Hubbard.

Q Now, after your period of being locked up,

where did you go then -- strike that.

Were you paid during that period?

A No.

Q After being locked up, where did you go?

A Then during the last couple of days of my being

locked up, I was joined by my wife at the time, Terri. And

the last couple of days we were both locked up.

We were brought a Telex which was from Hubbard

which he had sent to GOUS, and it was shown to us and read to

us, and it said that we were ordered returned to Clearwater.

Hubbard ordered us returned, so we went sent or we were

actually accompanied by a B-1 -- B-1 is the intelligence

bureau, and Dick Weigand assigned one of the B-1 agents to

1461

accompany us, and we were flown back to Clearwater, Florida.

Upon our arrival in Clearwater, we were taken

to what is called the bank building, to LRH's personal

communicator who at that time was Ken Urquhart, and he

showed us and read us a Telex which he had received from

Hubbard in which it said that Terri and Gerry are assigned

to the RPF, and so I spent the next 17 months in RPF.

Q What was the grounds for your being assigned

to the RPF?

A The way it read was, "Gerry attacked the

Guardian's office, and Terri went into agreement with him."

And then there was an issue which was brought

out subsequently which stated that, and the order stated the

charge was insubordination.

1462

Q Now, while in the RPF what did you do?

A Well, when -- when Terry and I first entered RPF

we were the only people at that time. There were only two

people in the RPF. And we began -- we gathered up -- we

found a place to stay at that time.

We were staying in the -- in one of the

bathrooms in the laundry room in the Fort Harrison. And

then another few people joined us within a couple of days or

weeks and we moved up to a storage room up on the 10th floor

of Fort Harrison.

And I was at that time, just due to the fact I

was first assigned, I was the head of the RPF. Within the

RPF I was called the RPF boatswain. And we worked on menial

tasks and we assembled the course packs and the materials

which are necessary to get out of the RPF.

There is a certain course which you have to

follow, a certain procedure, certain steps that you have to

go through to get out of this condition in which you are

assigned.

The RPF grew throughout that period up until the

point where I left, there was approximately 100 people in

it. And I finally got out after -- on December 1st, 1977.

Q Now, during that period of time did you make any

observations as to the level of paranoia within the

organization about security?

A Well, security was --

MR. LITT: Your Honor, this is opinion, I take it?

THE COURT: Well, this is, you know --

1463

MR. HARRIS: Unless he is qualified, Your Honor.

MR. FLYNN: I'll withdraw it, Your Honor.

THE COURT: All right.

Q BY MR. FLYNN: While in the RPF did you receive

pay?

A Yes.

Q What did you receive?

A $4.30 a week.

Q How many hours a week were you working?

A I guess 100 or more hours.

Q And, incidentally, while you were on the Apollo,

on the average how many hours a week did you work,

Mr. Armstrong?

A 120 hours.

Q And while you were in the personal office of

L. Ron Hubbard at Dunedin and Astra, on the average how many

hours a week did you work?

A 100.

Q Up to the time that you went into the RPF did

you ever have any understanding in your mind that you worked

for the Church of Scientology of California?

A Huh?

Q Did you ever understand that you worked for the

Church of Scientology of California?

A I'm sorry. I --

THE COURT: We'll take a five-minute recess.

(Recess.)

1464

THE COURT: We are back in session.

The witness has retaken the stand.

State your name again for the record. You are

still under oath.

THE WITNESS: Gerald Armstrong.

Q BY MR. FLYNN: Up to the time you were in the

RPF, Mr. Armstrong, did you ever understand that you worked

for the Church of Scientology of California?

A No.

Q And while you were in the RPF was it your

understanding that you worked for the Church of Scientology

of California?

A At this time, during this period, I understood

that the cover came up United Churches and at that -- or

sometime in there, the organization, that is, all the people

in Clearwater, whatever those corporations were, were set in

corporately under Church of Scientology of California.

I heard about that just in either the rumor line

or passing of information back and forth.

I don't believe I ever saw any documents to that

effect.

All I knew for a fact was that I was in the RPF;

I was part of the SEA organization and I worked for L. Ron

Hubbard.

1465

Q Now, let as show you something. Appears to bear

the date of March 18, 1977.

MR. LITT: Can we see the document?

MR. FLYNN: Here is a copy for you.

May this be marked exhibit next in order, Your

Honor? I believe it is W.

THE COURT: U.

Q BY MR. FLYNN: Do you recall that document,

Mr. Armstrong?

A Yes.

Q And do you recall signing it?

A I am not totally positive signing it. I signed

during that period a number of documents, and I know that

there was either one or two or three documents like this,

all of which I signed, so I don't recall exactly when I did

sign it. I know that I never signed -- I know that I did

not sign in front of a notary public, but I did sign a

number of such documents.

Q And what were the circumstances under which

you signed documents?

MR. LITT: All documents? This document?

Q BY MR. FLYNN: These series of documents that

you just testified about.

A They were given to us to sign. We were

ordered to sign. Everyone in the RPF signed them.

Q And did you read them?

A I don't believe so. I never understood them.

It wouldn't have mattered anyway.

1466

Q If you had been ordered to sign them, you

would have signed regardless of what they said; is that your

testimony?

MR. LITT: Objection; leading.

THE COURT: All right.

You can rephrase your question.

Q BY MR. FLYNN: Would you have signed those

documents under any circumstances at that time, Mr. Armstrong?

MR. LITT: Same objection.

THE COURT: Overruled.

THE WITNESS: I would have signed virtually anything

at that time.

Q BY MR. FLYNN: Did you understand Exhibit U to

be a non-disclosure and release bond at the time you signed it?

A Frankly, I still don't know exactly what a non-

disclosure and release bond was. It may have had that name

at the top. It undoubtedly did, but what that means, I

definitely wasn't certain then and I still am not.

Q Did you understand when you signed this

document that you were bound to the Church of Scientology of

California to pay the sum of $10,000 if you disclosed any

information, data or knowledge about the Church of Scientology?

A I believe I heard that at the time, yes.

Q You heard that. Was that explained to you?

A No, nothing was explained to me, but I have

signed probably -- I don't know, seven or eight of such

documents to do with various things, and I understood that

there was various dollar amounts involved.

1467

Q Now, in 1977, did you receive a W-2 Form from

the Church of Scientology of California?

A I don't believe so.

Q Let me show you a wage and tax statement

dated 1977. Did you receive that, Mr. Armstrong?

A No, not until it was produced in this case.

Q And there is one for 1978; is that true?

A Yes.

MR. FLYNN: Apparently, Your Honor, I don't have an

extra copy.

Would you hand that to the Court, Mr. Armstrong,

and may that be marked next in order, Your Honor?

THE COURT: Okay. V, as in Victor.

Q BY MR. FLYNN: Now in the 1977 wage and tax

statement, do you see where you were paid some $340 or so?

A Yes.

Q And do you recall receiving any amounts of

cash in 1977?

A Everything was cash.

Q Were there any wage vouchers that said the

Church of Scientology of California on them?

A No.

Q And in 1978, according to Exhibit W, how much --

THE COURT: You mean V.

MR. FLYNN: Pardon me. Exhibit V.

Q How much were you paid?

A $34.40.

Q Now, did you receive any wage or tax statements

1468

from any other organization relating to the Church of

Scientology in 1978?

A I don't believe so.

Q In 1978, did you receive funds greater than

$34 from any source for wages?

A Yes.

Q And how much did you receive greater than the

$34 that is reflected on that exhibit?

A Maybe $800.

Q And where did you receive that money from?

A That was -- at that time, I was in La Quinta,

California, and I was paid by the treasury in La Quinta.

Q Did you receive a wage or tax statement for

that $800 that you just testified about?

A I don't believe so.

Q Do you know whether one exists?

A No.

1469

Q When did you arrive at La Quinta?

A December 30, 1977.

Q And that was after you left the RPF?

A Yes, sir.

Q And what were you duties as La Quinta?

A I was involved for the first six months or so in

making movies. I worked in virtually all the departments of

the production of movies that was going on at La Quinta.

Q Was there a term that described the location or

base at La Quinta?

A We were called a number of things.

We were called "SU" which meant "Special Unit."

We were also called during that period -- this

was the property known as WHQ, Winter Headquarters. There

was supposed to be another one set up so that we could move

from place to place. It was going to be Summer

Headquarters.

Q Who were you working for then?

A L. Ron Hubbard.

Q What type of movies were you making?

A They were movies concerning Scientology.

Q And did you have a cover story there?

A Yes.

Q As to who you were working for?

A Yes.

Q And did you receive briefings on that cover

story?

A Yes.

1470

Q What was the cover story?

A There were two which developed during that

period.

The first one was that everyone on the property

was there because we were friends of Norton Karno who was, I

later found out, Hubbard's tax attorney.

The next story had to do with we were making

educational movies and they formed a movie company called

"Perfect Pictures."

So when I was out there was times when I was the

location scout. And when I set up various locations for

shooting movies, I used the name "Perfect Pictures" and the

people involved in the shooting of the movies, many of them

had Perfect Picture T-shirts. So it looked like a movie

company.

Q Was it your understanding that this movie

company was under the control and direction of L. Ron

Hubbard?

A Yes.

Q What was your understanding as to -- if any --

whether that company was related to the Church of

Scientology?

A Well, it was related to the Church of

Scientology because everyone who was making movies was a

SEA ORG member.

Hubbard was the head of the Church of

Scientology; the head of SEA ORG. We were all connected

through him.

1471

Q Did he control all the details of your work?

A Yes.

Q Did you personally take directions from him

during that period of time?

A Yes.

Q What were the command lines while you were at

the Special Unit at La Quinta?

A When -- generally they ran directly from Hubbard

via a messenger to me on whatever function that I was doing.

The messengers, as ordered by Hubbard, were in

control of virtually every aspect of it down to the most

minute detail.

On some matters I would have an organizational

senior who I would either also receive orders from or who

would relay the orders from Hubbard or from the messengers.

My senior during a great deal of my time was

Norman Starky.

Q Now, were these messengers referred to at that

period of time as "Commodores Messengers"?

A Yes.

Q What was a Commodores Messenger?

A The Commodores Messengers were individuals; they

were generally young people who were Hubbard's personal

messengers. And they relayed orders from him and relayed

information to him.

Q Now, did L. Ron Hubbard issue at that time what

I believe has been marked as exhibit K, a flag order, 3729

issued under his name as L. Ron Hubbard, Commodore; the

1472

subject of Commodores Messengers?

A Yes.

Q Now, did the command lines of the Special Unit

follow the orders of L. Ron Hubbard as set forth in

exhibit K?

A Yes.

Q And what was the practice or understanding among

people at the Special Unit such as yourself as to obedience

to an order of a messenger?

A Must be obeyed.

1473

Q And was it to be obeyed precisely as an order

emanating from L. Ron Hubbard?

A Yes.

Q Now, during that period of tine did you also

receive blank wage vouchers and get paid in cash?

A Yes.

Q And did you have an understanding as to

whether this film unit was the personal film unit of

L. Ron Hubbard?

A Yes.

Q And was it commonly referred to as such by the

people working on it?

A Yes.

Q How long did you work in the special unit,

Mr. Armstrong?

A The special unit came to be known as both a

location and as a sub-group in that location. We changed

locations at the end of 1978 during a time when I was again

in the RPF.

Q And why were you ordered to the RPF at that

time?

A I was assigned by L. Ron Hubbard for -- he

thought that I was joking about a -- about his film production.

Q And how long did you spend in the RPF?

A Eight months.

Q And where was the RPF located at that time?

A In La Quinta and then in December we moved to

Gilman Hot Springs.

1474

Q And what were your duties or what did you do

in the RPF during that period of time?

A Principally during that time we had -- during

the time that we were in the La Quinta area we worked majorly

on L. Ron Hubbard's house which was in La Quinta.

We tiled the floors. We painted it. We

carpeted it. We cleaned the whole place out. Took out all

the insulation, reinsulated all the heat and air ducts, and

that is mainly what La Quinta was about.

Sometime in early December we moved from

La Quinta, the RPF moved from La Quinta to Gilman Hot

Springs; and in Gilman Hot Springs again we were working on

a house which was being renovated on the Gilman Hot Springs

property for Hubbard.

Q And how much did you get paid during that

period of time?

A $8.60 a week.

Q And how many hours a week were you working?

A Oh, probably 120.

Q And did all of that work relate to working on

L. Ron Hubbard's house?

A Yes.

Q Do you know in whose name the property was

held that was L. Ron Hubbard's house?

A I didn't know at the time.

Q Did you subsequently learn?

A I obtained a deed for the property from the

Riverside County Recorder's Office.

1475

Q And was that as part of your archives duties?

A That was subsequent to the -- after I left the

organization.

Q Did you have any understanding as to whether

that property belonged to the Church of Scientology of

California when you were working on L. Ron Hubbard's house?

A No.

Q Was L. Ron Hubbard living in the house that you

were working on at the time?

A No, the working -- well. I was in the RPF,

and this went to approximately April 1979, I worked on the

house continually through that period. Then I was able to

get out of the RPF, and I continued on working on the house,

and we were working day and night at that point in order to

make it ready for him.

We were expecting him to arrive at the end of

April. He never did, in fact, arrive to reside in the house

because again the cover for the property was blown; and as a

result, sometime later he went into hiding completely, but

he did arrive a number of times later in 1979.

We had, by the summer of '79, the house was --

even earlier, probably by May, it was habitable and had been

fully renovated, but he never came other than the

occasional time.

There was about a week period when he arrived

on a daily basis or actually at night, and he came to the

house and then went to -- there was a small studio which had

been established in a reservoir, an underground reservoir on

1476

the property, and he came and conducted some still photo-

graphy at that time. He came another several times

throughout that year, principally to meet with Mary Sue.

Q Now, during that period of time, did you

receive orders from the Commodore's Messengers that this

house was being readied for L. Ron Hubbard?

A Yes.

Q And, to your knowledge, where did all the

funds come from to do all those renovations?

A I -- they came from the same place that all

other funds came from.

Q And where was that?

A That was from something called SEA ORG

Reserves.

Q And in April 1979, did you have a title in

connection with your duties involving the house renovation?

A To begin with, I was the LRH renovation

purchaser, and this was for a couple of months after

getting out of RPF.

1477

Then I became LRH's renovations in charge. And

I continued on that post up until the end of 1979.

Q Now, LRH stands for L. Ron Hubbard?

A Yes.

Q Was there a term used at that time called "The

Household Unit"?

A Yes.

Q And what was that -- what did that term apply

to?

A The Household Unit contained the personnel who

worked for L. Ron Hubbard directly taking care of personal

household needs; that is as opposed to the personal office

personnel who took care of needs outside the household, his

accountant, so on.

The Household Unit contained the LRH cook; LRH

steward; LRH driver. I was the LRH renovations in charge.

And I was the deputy commanding officer of the Household

Unit on the Gilman Hot Springs property. And it contained

the COHU, the Commanding Officer of the Household Unit.

Q Who was that?

A Up until the beginning of 1980, that was Kima

Douglas.

Q Did you get paid while you were the LRH

renovations in charge in the Household Unit?

A Yes.

Q And who did you get paid by?

A Either -- I believe Gary Press was the person at

that point who was taking care of disbursements for the CMO

1478

Personal Office staff.

Q Were you paid in cash?

A Yes.

Q Did you receive wage vouchers?

A Yes.

Q Were they blank?

A Yes.

THE COURT: We'll take a recess at this time. We'll

reconvene at 1:30

(At 11:58 a.m. a recess was taken

until 1:30 p.m. of the same day.)

1479

LOS ANGELES, CALIFORNIA; THURSDAY, MAY 10, 1984; 1:32 P.M.

---oOo---

THE COURT: Very well. In the case on trial, let the

record reflect that counsel are present.

GERALD ARMSTRONG,

resumed the stand and testified further as follows:

THE COURT: The witness has retaken the stand.

Just state your name again for the record, sir.

You are still under oath.

THE WITNESS: Gerald Armstrong.

THE COURT: You may continue, Mr. Flynn.

MR. FLYNN: Thank you, Your Honor.

DIRECT EXAMINATION (Resumed)

BY MR. FLYNN:

Q Mr. Armstrong, prior to lunch, do you recall

your testimony about the period that you were working at the

special unit at La Quinta?

A Yes.

1480

Q And what was the date again that you were

working at the Special Unit at La Quinta?

A From December of 1977, December 30, '77 to the

beginning of December 1978.

Q Do you recall your testimony that Mr. Hubbard's

cover was blown at La Quinta which caused a move to Gilman

Hot Springs? Do you recall that?

A Yes.

Q What were the circumstances under which

Mr. Hubbard's cover was blown?

A There was an elderly couple named the Hartwells

from Las Vegas or somewhere in Nevada. And they had been

recruited to come out to the La Quinta property and be

involved in a shooting of movies. And they were apparently

promised various things which were not delivered.

They subsequently left the property and went to

the press or the authorities and there was -- the cover was

blown through this elderly couple, the Hartwells.

Q Now, was there a briefing that took place with

regard to security at La Quinta during that period of time?

A Well, I was briefed when I arrived at the

La Quinta property.

Q And what was that briefing?

MR. HARRIS: And who gave it if he knows, for

foundation, Your Honor.

Q BY MR. FLYNN: Why don't you describe the

circumstances of the briefing, Mr. Armstrong?

A There was a briefing pack of materials which

1481

laid out what the shore story was for the La Quinta

property. And I was briefed and checked out on those -- on

those materials in what is called the Qualifications

Division, INQUAL, in La Quinta in one of the buildings.

1482

Q Now, were there precautions taken with regard

to the service of process on Mr. Hubbard at La Quinta?

A Yes.

Q And what were those precautions?

MR. HARRIS: And how did he know, Your Honor? We are

getting into --

THE COURT: Well, if you have an objection, counsel,

please state it.

MR. HARRIS: No foundation and hearsay.

THE COURT: If you know, you can state it. If you

don't know, you can so state. You, of your own personal

knowledge. Counsel may be able to develop it in other ways.

We are talking about basically matters that you

are capable of responding to of your own personal knowledge.

THE WITNESS: All right. I was familiar with the

procedure to be followed regarding service of process

through two ways.

First of all, I was a guard on the property.

In addition to the regular duties in connection with shooting

the movies, a few times a week for a great deal of that time

I had guard duty, and the guard duty -- the guard was

stationed on Mr. Hubbard's -- the grounds of his residence;

and before assuming guard duty, I was briefed and drilled on

how to handle people making inquiries or process servers.

But, in addition to that, everyone on the

property was briefed at crew briefings, so everyone was

briefed on exactly how to handle process servers or anyone

like that.

1483

Q BY MR. FLYNN: And how were process servers to

be dealt with?

A Well, first of all, it was specifically -- if

they had asked for anyone, and more particularly Mr. Hubbard,

we were to deny that we knew that he was on the property or

who he was, and we were not to accept any papers. If they

forced them on us, we were to kick them away.

Q And were there other precautions taken with

regard to Mr. Hubbard's security at that time?

A Well, the guard, of which I was one, had a

walkie-talkie which had a preset channel which set off an

alarm in several locations on the property and several of the

buildings.

Additionally, if anything -- if we were

approached by anyone, we were to first of all push the alarm

button on the walkie-talkie and alert the CMO member on duty.

There was always a messenger on duty in Mr. Hubbard's house

24 hours a day, and we were to alert them. There was a car

kept back of Mr. Hubbard's house which was to be used as a

getaway vehicle, and we were to keep whoever it was outside

the property until such getaway could be made.

Q Now, and you were actually personally guarding

L. Ron Hubbard; is that correct?

A That is correct.

Q And you were being paid at that time in cash

with blank wage vouchers?

A Yes.

Q And I believe you testified this morning that

1484

Mr. Hubbard dictated all the details of your work at the

Special Unit at La Quinta?

A Yes.

Q And what again was the cover story at La Quinta?

What was the nature of the organization you were supposedly

working for?

A Well, we were all to be friends of Norton

Karno. Norton Karno, it turned out, was Hubbard's tax

attorney.

Q Now, was there shredding or vetting or burning

of documents at La Quinta that you participated in?

A Yes.

Q And what did that involve?

A There was a couple of times in 1978 while I

was on the property that we vetted or shredded materials

which at that time showed either a connection to the

Guardian's Office, connection to Mary Sue Hubbard or

Hubbard's control of Scientology. Those were the criteria

set down for vetting of materials.

1485

Q Were you briefed on what --

What is "vetting"?

A Vetting is the examination of any document and

the cutting out of the portion which, in this case, linked

Hubbard in, for example, if he ordered a particular thing

and there was an "LR" at the bottom, then the "R" could be

cut out and then no one would know who in fact had ordered

it.

Q You testified earlier this morning about

messengers. And you referred to exhibit K with regard to

the policies of messengers following Mr. Hubbard's orders;

were logs kept of those orders, the oral orders to

messengers?

A As long as I knew -- and this goes back to the

beginning of 1971 -- every order that he ever gave was kept

in a messenger log.

Q When did you last see any of those messenger

logs?

A 1978.

Q And where did you see them?

A They are kept in the Messenger Office over at --

in the same residence in which Mr. Hubbard lived in 1978.

Q Do you have any knowledge of the fact that those

messenger logs were subsequently buried in concrete bunkers

anywhere?

A No personal knowledge.

Q Now, were you given briefing or briefings on

what vetting is?

1486

A Yes.

Q And you have just testified about what vetting

is; is that correct?

A Yes.

MR. FLYNN: Your Honor, may this be marked next in

order?

THE COURT: It will be marked W.

Q BY MR. FLYNN: Would you examine exhibit W,

Mr. Armstrong?

Does that generally relate to the policies in

which you were briefed on vetting?

MR. HARRIS: Objection, Your Honor. Vague.

If he saw this before and he can lay a

foundation for it, that is something else.

THE COURT: You may proceed in that fashion, counsel.

Q BY MR. FLYNN: Have you seen this particular

vetting policy, Mr. Armstrong?

A Not while in the organization.

Q Did you see a vetting policy similar to that?

A Yes.

Q In what way did the two differ?

A This is more extensive. It is longer.

The other one was on a single sheet of paper.

The instructions on the other one dealt mainly

with L. Ron Hubbard and connections to he Guardian's Office.

The mentions of the criminal activities were not made in the

vetting write-up which I saw.

Q At a later point in time did you see this

1487

vetting write-up that has been marked as exhibit W?

A Yes.

Q When was that?

A It would have been some months ago.

You showed it to me.

Q Now, when you were doing the vetting at the

Special Unit did you follow the procedure outlined in that

policy?

THE COURT: Which policy?

Q BY MR. FLYNN: As set forth in exhibit W, of

using a razor blade to vet out information from documents?

A That is correct.

MR. LITT: Your Honor, we won't belabor it, but we

believe that all of this is irrelevant and is improper.

MR. FLYNN: I'll tie it all in, Your Honor.

THE COURT: All right.

Q BY MR. FLYNN: You testified this morning that

after your duties at the Special Unit which you have

described, Mr. Hubbard ordered you to the RPF; is that

correct?

A Yes. That was during my time in La Quinta.

Q And during that period of time were you ordered

to undergo security checks?

A Yes.

Q What is a security check, Mr. Armstrong?

A In a security check a person undergoing the

security check is made to hold onto the two electrodes of a

small device which is similar or operates the same as a lie

1488

detector. And he is interrogated on various subjects and

must answer the questions until the appropriate read is

obtained on the device called the E-meter.

MR. HARRIS: Your Honor, I move to strike unless the

witness' expertise in the operation of a polygraph is

established.

MR. FLYNN: Your Honor --

THE COURT: The witness said similar. I'll overrule

the objection.

Some of these cases that have been submitted to

me and the in-limine motions dealt with an E-meter. So I

have some awareness of what has been written up in judicial

opinions, for whatever it is worth.

MR. FLYNN: Your Honor, may this be marked as next in

order?

THE COURT: Exhibit X.

Q BY MR. FLYNN: when you were working for

Mr. Hubbard did you read and were you trained with respect

to policies on security checks?

A Yes.

Q And does the exhibit that is now in front of you

constitute the policy that you read and were trained on with

respect to security checks?

A This is one of many.

Q And with respect to your testimony that the

device that you described was used as a lie detector,

does it so state in that policy?

A Yes.

1489

Q And were you generally interrogated in a

security check about your intentions or attitudes toward

Mary Sue Hubbard and L. Ron Hubbard?

A Many times.

1490

Q How many security checks did you undergo while

you were working for Mr. Hubbard?

A Hundreds.

Q Now after the period that you were in the

rehabilitation project, you testified this morning that you

went to the Gilman Hot Springs property and became the

L. Ron Hubbard renovations in charge of the household unit;

do you recall that?

A Yes.

Q What was the cover story with regard to the

activities that were being conducted at the Gilman Hot Springs

property?

A There were a number of cover stories through a

period of time.

Q And what were they?

A The first one was that we were members of the

Scottish Highland Quietude Club -- excuse me for laughing.

The next one was we were Friends of Richard Hoag.

Q And you held yourselves out to the public as

being members of the Scottish Highland Quietude Club?

A Yes, that was very brief, and then we became

Western States Scientific Communications Association.

Q And were you drilled to hold yourselves out as

such to people outside the property that you were working

on?

A Yes.

Q Now in January of 1980 did you receive a

briefing with regard to a potential government raid on the

1491

property at Gilman Hot Springs?

A Yes.

Q And what was that briefing?

A That such a raid may happen and that we were

having an all-hands vetting and shredding project.

Q Was that briefing done orally or were you given

written instructions?

A We had a small note of criteria on which to

base the shredding, and we were briefed orally.

Q And what was the criteria?

A Anything which connected L. Ron Hubbard to

the Gilman or La Quinta properties; anything which showed any

connection to the Guardian's office; anything which showed

Hubbard's control of Scientology or Scientology finances;

anything which showed any orders being written by Hubbard

into the Scientology organizations.

Q Who did yon receive that briefing from?

A It was from one of the messengers.

Q Do you recall which messenger?

A I believe it was Shelley Miscavige -- Shelley

Barnett.

Q Barnett was her maiden name?

A Yes.

Q And did you in turn give a briefing to the

people who were working for you?

A Yes.

Q And how many people were working for you at the

time?

1492

A About six.

Q And what generally were their duties?

A Each person was to go through his or her

respective areas and all documents, all papers in their

respective areas and vet or shred.

At this point almost everyone involved had

done this process before, had gone through and vetted

materials in their area.

The degree of security had been stepped up so

that materials which had previously been vetted; that is, a

little section cut out with a razor blade were not be shredded

unless they were absolutely essential, so it required that

even materials which had been gone through before be now

re-evaluated and this time shredded. It was a massive

shredding with a much higher degree of security than

previously, so I briefed each one of any people, all together

actually on what the situation is and on what to look for and

what to do.

Q Now these five or six people, what were their

duties in the household unit?

A I had Don something-or-other who was the

carpenter, and he was the LRH carpenter.

I had Paco Suarez who was the LRH steward.

I had Brenda Black. Her title was the LRH gear

in charge.

Q What did that mean?

A She was in charge of all of Mr. Hubbard's

materials which were stored on the Gilman Hot Springs property,

1493

and there was someone -- Lucy something-or-other who was in

charge of LRH grounds and animals.

Q And all of these people worked for -- strike

that.

All of these people had duties in which they

were working in connection with activities for L. Ron Hubbard

personally?

MR. LITT: Objection; leading.

THE COURT: If you know, you can answer. Overruled.

THE WITNESS: Yes they were.

Q BY MR. FLYNN: At that time, Mr. Armstrong,

what were you being paid per week?

A My recollection $20.

Q And how many hours a week were you working?

A Probably a hundred.

Q Were you being paid in cash?

A Yes.

Q And what if anything was stated on the wage

vouchers that were given to you when you were paid?

A Nothing other than my name.

1494

Q Approximately how many people at the Gilman

Hot Springs -- strike that.

What was the Gilman Hot Springs property called?

Did it have a code name?

A It was called SU or some of us called it

SHQ.

Q Now, approximately how many people at the SU --

is that Special Unit?

A Yes.

Q Approximately how many people at the Special

Unit were involved in the shredding and vetting operation

in January, 1980?

A Virtually everyone on the property. And that

would probably be in excess of 200 people at the time.

Q Where did you obtain shredding equipment?

A The shredding equipment was rented. It was a

very big industrial shredder. And it was rented by a man

Sheldon Maysel and brought on to the property by him.

Q When you say "a large industrial shredder,"

can you give us an idea as to its dimensions?

A Yes. The -- when I call it an industrial

shredder, we had several shredders on the property. It was

always procedure to shred things. But the smaller shredders

which we had could not handle that kind of volume.

this could take in like a quarter of an inch

of paper at one time. It was a massive shredder. It was

probably three feet square. But the important factor was the

amount of -- the motor power, the jaw size.

1495

Q And how were documents brought to the shredder?

A In boxes, en masse.

Q And how were the shredded pieces of paper

removed from the shredding area?

A They were packed up and trucked off the

property.

Q And how big were the trucks?

A I believe they are called five ton trucks.

Q How long did the shredding operations go on.

A At least two weeks.

Q And do you have an estimate as to the volume

of paper that was shredded?

A A million pages.

Q In connection with the duties that you and

your staff had to shred, what did you do?

A The materials which I went through personally

had to do with Hubbard's orders regarding the Gilman Hot

Springs property.

I shredded any order from him regarding work

to be done on the property and then anything in which

financial records, I cut out any reference to him.

I oversaw the work which was being done by all

my juniors.

Q Now, Brenda Black was one of your juniors?

A Right.

Q What were her duties in the shredding operation?

A She had exactly the same orders; she was to go

through the LRH storage area.

1496

Q Where was that located?

A Principally in the top floor of a condemned

hotel on the property.

Q What was the hotel called?

A Del Sol.

Q Did you instruct her to do that?

A Yes.

Q Were you generally aware of what was kept on

the top floor of the Del Sol Hotel?

A Generally, yes.

Q What was your understanding?

A That it was Mr. Hubbard's personal materials,

anything which he owned.

Q And at some point in time did Brenda Black come

to you with materials that she had retrieved from the top floor

of the Del Sol?

A Yes.

Q When was that?

A It was during the same time period. It was one

of the first nights of the vetting operation.

Q And would you describe what occurred at the time

she came to you?

A She came to me; I was in the carpenter shop

which is where my office was. And she brought in an old box

and she asks, she said she had found these things and she

wondered whether or not they should be shredded.

Q Now, under the criteria that had been established

for shredding, should they have been shredded?

1497

A Yes.

Q And what decision did you make?

A I evaluated that materials which I looked at

that point predated Dianetics. And I thought that there

could be no reason why the FBI or whoever was going to raid

the property could tie Hubbard in via these documents. So --

Q What connection did they have to Hubbard?

A Well, the fact they were obviously identifiable

as his and they would have identified the fact that his

materials were being stored at the property; thus indicating

a control.

No one else on the property had a whole top

floor of the hotel dedicated to their personal belongings.

Q So one of the criteria for shredding, namely,

the location of property that was connected to Hubbard which

was stored at Gilman Hot Springs; under that criteria this box

of materials should have been shredded; is that right?

MR. LITT: Objection. Leading.

THE COURT: He already testified to it.

Q BY MR. FLYNN: Under the other criteria you

deemed that they predated Dianetics; is that correct?

A Right. I made the independent judgment at that

point that I recognized the historical value and I saved

them for that reason.

1498

Q What did you do with this box?

A Well first I questioned Brenda Black as to

where she got it. She actually told me right away where it

had come from, first from the garage and then up to Del Sol

and then going through the materials she discovered it.

So I asked her if there was anything more.

My recollection is she wasn't sure at the time, but she had

already located one other thing and that was a trunk of

materials relating to the death of Quentin Hubbard, and I

went with her at that time and looked at those materials

concerning the death of Quentin Hubbard, and then I took the

one box over to one of the buildings on the property, the

Massacre Canyon Inn where the L. Ron Hubbard PR Bureau had

an office, the reason I did that was because I saw historical

value. The materials I saw related to a small diary from

the period when Mr. Hubbard was in China, and I thought at

that time that here was the proof of these things and that

they had value, and that I already was familiar with Laurel

Sullivan because we had been very close prior to that. I had

been her junior, and I knew at that point of the biography

project and I thought that they would have present value

for the biography. So I determined to send them to her.

Q Now, at that point in time was it your decision

not to shred the materials?

A Yes.

Q What else -- what were the contents of the box

other than the China diary that you described?

A There were a number of personal letters, principally

1499

between Mr. Hubbard and his first wife. There was a book of

handwritten short stories or outlines for stories which

appeared to be from Mr. Hubbard's youth.

Those are principally what I recall at this

time.

Q Now, the L. Ron Hubbard China diary, is that

currently under seal?

A Yes.

Q How long of a period of time does the diary

cover?

A Just a couple of weeks.

Q And was Mr. Hubbard in the Boy Scouts at the

time -- strike that.

Was it part of a YMCA trip to China?

A Yes.

Q And how long did the trip last according to

the diary?

A I recall a couple of weeks. It was only --

in China itself it was simply a train ride into China and a

visit of the Great Wall and a visit to Peking.

Q Now you brought the materials to Laurel Sullivan

and what did she do with them if you know?

A She had one of the girls who worked for her

by the name of Share Karl photocopy them and then they were

put into plastic bags and they were then given to a messenger

by the name of Karen Clavel, and they were kept under

Karen Clavel's bed, the reason being it was still deemed that

the FBI could come in and take these documents.

1500

Q Now in addition to the historical value that

you have testified about, at that time when you prevented

the documents from going to the shredder, did you see any

other value in them?

A Well, that was principally it. Their values in

the creation of a biography was what I immediately saw. There

was collective value in addition to that. I was aware to some

degree that people were collecting up L. Ron Hubbard memo-

rabilia and that such a set of documents would have value.

Q Now in connection with the value to the

biography project, did you determine that there was value in

the truth that could be found in the contents of the documents?

A Well, I assumed at that point that with the

documents that I found and the documents that I found over

the next few days they would be able to put to rest the

allegations which had been made in various of the media

regarding Hubbard's past. I felt like here we had the

documentary proof.

Q And at that point in time did you read through

very carefully all of the contents of these documents that

were in the box and in the trunk?

A No.

Q You just skimmed them?

A I only ascertained what they were, the fact that

they were his, and never really got into the contents at

that point.

Q Now, in your mind at that time. Mr. Armstrong,

what was their primary value?

1501

A I think in being able to document the truth of

the man and to create the foundation for a biography.

Q And after you collected the documents and gave

them to Laurel Sullivan, did you then send a petition to

Mr. Hubbard?

A Yes.

1502

MR. FLYNN: For the record, Your Honor, this has been

marked as exhibit F, I believe.

THE COURT: All right. Exhibit F.

Q BY MR. FLYNN: Do you know what Laurel Sullivan

did with the copies of the -- that she made from the contents

of the box from the trunk of the van what was buried or --

strike that -- other than what was placed under the bed of the

messenger?

A I was told at the time by Laurel that they were

going to go to the PR Bureau in Clearwater and to the PERS SEC

WW in the United Kingdom.

MR. LITT: I move to strike on the ground of hearsay,

Your Honor.

THE COURT: It is evidence of what was told to him,

his personal state of mind at that time.

Q BY MR. FLYNN: Do you recall the date of your

petition, Mr. Armstrong?

A Yes.

Q And when was the date?

A 8 January, 1980.

Q And at the time of the petition what essentially

were you petitioning for?

A To be able to collect up all the records, files

of Mr. Hubbard; to assemble them and to do the research for

his biography.

Q And did you feel that it related to the success

of various of Mr. Hubbard's personal undertakings?

A Yes.

1503

Q And did you put that in your petition?

A Yes.

Q And did you feel that it related to the success

of the Nobel Prize project?

A Yes.

Q What was the Nobel Prize project?

A Mr. Hubbard had ordered in the end of 1979

that a Nobel Prize be obtained for him for his discovery or

creation of the Purification Rundown. It was a series of

steps which he felt could eliminate toxins and radio active

particles from the body.

Q Did you work on that Nobel Prize project?

A Yes.

Q What did you do?

A I did some of the research to find out who the

nominating committee was and to see whether or not we could

locate anyone in the Scientology network who had a connection

into any of the members of the nominating committee.

Q And did you petition Mr. Hubbard to collect

up the materials for the success of his biography and press

legal handling?

A Yes.

Q And how did you know about the biography at that

point in time?

A Because I was familiar to some degree with the

work that Laurel Sullivan was doing.

We had been in RPF together for some months;

we had worked together on the LRH renovations project and had

1503-A

become familiar with the fact that there had been one

planned for several years.

1504

Q What did you mean when you wrote Press/legal

handlings?

A Well, Mr. Hubbard had been the subject of press

criticism for a long period of time. I know about this from --

on the ship. I knew about it from Clearwater. I knew about

it from La Quinta, and I knew about it from Gilman Hot Springs,

and always the story which was told to the people inside the

organization was that these were just rumors and lies being

created by the media, and I felt that with the documented

proof we could put to rest all the entheta or the lies being

spread by the media.

Q So you felt that you would alleviate threats

to Mr. Hubbard?

A Yes.

Q And you petitioned for that?

A Yes.

Q And you felt by doing this project, you could

insure his free movement and the free movement of his actions

and projects and ideas?

A Yes.

Q Did you petition to do this project to preserve

valuable documents relating to L. Ron Hubbard?

Was the box that Brenda Black brought to you

when you found it exposed to the weather?

A Yes.

Q And would you describe in general its condition?

A It was in a very beat up, raggedly cardboard box.

Q Now, at the time that you made this petition

1505

was anyone also collecting personal documents of L. Ron Hubbard

if you knew at the time?

A I don't know of anyone at the time, not that I

recall.

Q And in the petition did you tell Mr. Hubbard

that you had found his box of personal papers in the Del Sol?

A Yes.

Q And did you tell him that they were of immeasurable

value to a biography?

A I believe so.

MR. LITT: Objection, Your Honor. The petition speaks

for itself.

THE COURT: Yes, it does.

Q BY MR. FLYNN: Were they Navy documents that

you found in the Del Sol, Mr. Armstrong?

A I found a great deal of Navy documents there.

Q And did the Navy documents pertain to L. Ron

Hubbard?

A Yes.

Q Now when you petitioned, Mr. Hubbard, did

you describe what your duties would be in this project?

A Yes.

Q And what were those duties that you envisioned?

MR. LITT: Is that a question as to what is described

in the petition?

Q BY MR. FLYNN: What were the duties that you

petitioned for?

A Do you wish me to read them?

1506

Q Do you recall what they are?

A I think principally, yes.

THE COURT: Well, the writing is the best evidence of

what his request was.

Q BY MR. FLYNN: In any event, you did lay out a

whole series of the duties in your petition to Mr. Hubbard?

A Yes.

Q And what did you do with the petition?

A I put it in an out-basket and it went to

Mr. Hubbard.

Q And did these duties include the fact that you

were going to collect documents all over the world relating

to L. Ron Hubbard?

A I believe so, yes. That was the intention of

it.

Q Do you know whether it went to Mr. Hubbard?

A Yes.

Q And how do you know?

A I received an answer back from Mr. Hubbard

approving my petition.

Q Now, during your at this point ten years of

involvement of working for Mr. Hubbard, had you become

aware of the normal procedures for getting communications to

and from Mr. Hubbard?

A Yes.

Q And what generally were those procedures?

A It varied according to the time period, but

during this time we had on our property the LRH External

1507

Communications Bureau and I knew during this time that

Mr. Hubbard vas living in Hemet, and I knew of the procedure

of mail drops, so I know that a petition to him during that

period could get to him.

Q Did you have personal knowledge that he was

actually living at Hemet, California on January 8, 1980?

A No.

Q What knowledge did you have?

A I had the knowledge that I received an answer.

I received a subsequent answer. I confirmed with the person

from whom I -- who typed, whose initials are on the bottom of

his response that indeed it came from him and the person

told me that yes, --

MR. LITT: Objection: this calls for hearsay.

THE COURT: Well it is his state of mind.

THE WITNESS: Since the initials on the bottom of it

are BD, and they stand for Barbara Decelle, and I spoke to

Barbara Decelle and she confirmed that he had indeed dictated

the communication and that she had received it, the taped

message and had typed it into the dispatch which I received.

I knew also from working with Laurel.

1508

Q BY MR. FLYNN: When had you last seen Mr. Hubbard

prior to January 8, 1980?

A Sometime in late 1979.

Q How did you know that he was living at Hemet?

A Because I was in the Household Unit at the time

and I was involved in drops and pickups of people,

transferring them to the Hemet location.

Q What are drops and pickups?

A No vehicle would drive straight from the Gilman

Hot Springs property to the Hemet address. We would simply

arrange a drop and both vehicles would arrive there and then

a transfer would be made at that point.

Q Were these part of the security precautions

taken to prevent Mr. Hubbard from being served with process,

if you know?

A Yes.

Q Who was with him at the Hemet property at the

time if you know?

A I'm aware of a number of people who were there

at the time.

Q Who are they?

A Mike and Kima Douglas; Lola Russo; Paco

Suarez -- all of these are during, at least, part of that

time -- Pat Nanenbroker.

Q And were there routine and regular

communications between Mr. Hubbard in Hemet and the Gilman

Hot Springs property where you were located?

1509

A There were communications. I don't know how

regular they were.

There was a regular run, a regular traffic run

every day.

Q Now at some point in time did you receive an

answer to this petition?

A Yes.

Q And do you recall when that was, Mr. Armstrong?

A It was just a few days following this.

MR. FLYNN: May that be marked next in order, Your

Honor?

THE COURT: We are up to Y.

Is this two pages, or is it one?

MR. FLYNN: I'll try to clarify that with the witness,

Your Honor.

THE COURT: All right.

Q BY MR. FLYNN: What did you first receive in

response to your petition, Mr. Armstrong?

A I received the document which is the very bad

copy here.

Q What is the document which is the bad copy?

A That is Hubbard's response approving the

petition.

There is a note on the top saying "Re your

petition." There is no date on it that I can see.

It appears to be a very bad copy.

Q Where did you get this copy?

A This was produced by the organization in the

1510

course of this case.

Q Now, the copy is very difficult to read; do you

recall what it said?

A I can read it a little bit.

(Reading:)

"This sounds like an excellent

idea. You'll have to be replaced properly, of

course. Get with your senior and EC and get

this carried out and let me know what you have

worked out.

"LR. "

Q Now, what did "LR" signify in your experience?

A Love, Ron.

Q And had you seen numerous documents in your

years of involvement with Mr. Hubbard in which

communications came back from him in that manner?

A Yes.

Q And was it generally accepted by people who

worked for Mr. Hubbard that that signified communications

from him?

A Yes.

Q And was that the routine procedure in January

1980 with regard to receiving communications from him?

MR. FLYNN: Your Honor, maybe that first one should be

marked Y and the second one will be marked separately.

THE COURT: All right.

Q BY MR. FLYNN: Did you receive another

communication relating to your petition?

1511

A Yes.

Q And what was that communication, Mr. Armstrong?

A It was another note from Mr. Hubbard. And it is

after the petition was approved.

I wrote up what is called a non-existent formula

in which I asked people with whom I'll have a relationship

while I am working on a post or project, I inform them what

I am intending to do and ask them what they need and what

from me. It is just a means of briefing people on what I

was doing.

I, in fact, had created a new post with this

thing. It had never been done before.

And once I had the petition approved by

Mr. Hubbard, I sent various of these no-existent formulas or

briefings to people, one of whom was Mr. Hubbard. And this

is his response.

Q So the collection of Mr. Hubbard's personal

documents originated for the first time with you on a new

post approved by him; is that correct?

A Yes.

MR. LITT: Objection. Leading, Your Honor.

THE COURT: I'll let the answer stand.

Q BY MR. FLYNN: Would you look on the routing of

the document dated February 8, 1980 --

Exhibit Z, Your Honor?

THE COURT: All right; Z.

Q BY MR. FLYNN: -- and describe to the court what

that routing means.

1512

A The top left corner is the name "Senior TRO

Researcher." That was a post title which I developed so

that it was recognizable and correspondence could be sent to

and from me via organization communications lines; all the

CCs refer to posts of individuals who receive copies of

Mr. Hubbard's answer. The "F" at the bottom is simply "to

file." That is Mr. Hubbard's file.

1513

Q Now, in your experience with Mr. Hubbard and

the Church of Scientology, were any of those posts church

posts?

A Each one of these people is a person who worked

directly for Mr. Hubbard.

MR. LITT: Objection; nonresponsive.

THE COURT: All right. I will strike it as nonresponsive.

If you know, are they church posts?

Q BY MR. FLYNN: In your experience --

THE COURT: Let's get an answer, or you withdraw it?

MR. FLYNN: I will get to it.

Q In your ten years of experience at this point

with Mr. Hubbard in Scientology organizations, was a dis-

tinction made between working for Mr. Hubbard and working for

the Church of Scientology?

A Not really, but at a certain level, as I

explained before, there was degrees of working for

Mr. Hubbard, and I was probably in the ultimate degree at this

point. Each one of these people answered only to Mr. Hubbard.

They didn't even know about Church of Scientology of

California.

MR. HARRIS: Is this witness purporting to state what

was in the minds of the others, that they didn't know about

the Church of Scientology, Your Honor?

THE COURT: You want to read the last question and

answer.

(The record was read.)

THE COURT: I will strike the latter portion unless

1514

there is some foundation shown.

Q BY MR. FLYNN: What is the basis of your

understanding, Mr. Armstrong, that you were working for

L. Ron Hubbard in January of 1980?

A Well, to begin with, I had been working for

him for the last nine years, and I was in the -- at the point

I wrote the petition, I was in the household unit and was

working only for him. I worked on his house. I took care of

his animals, his grounds, his offices. I had no communi-

cation whatsoever with the Church of Scientology of

California.

He was the only one that I answered to, so

then when I petitioned, I petitioned him to take possession

of his archives and work on his biography, in his PR office,

in his personal office.

Those were the bases that were in my mind,

although it never was a question at that time. It was just

obvious to me.

Q And at that time were you performing personal

services for L. Ron Hubbard?

A Yes.

Q When you were performing these personal

services for L. Ron Hubbard, were you engaged in any type of

ecclesiastical or religious activity for the Church of

Scientology of California?

MR. LITT: Objection; that calls for a conclusion, or

are we asking him his opinion?

THE COURT: Well, I will overrule the objection.

1515

THE WITNESS: No.

Q BY MR. FLYNN: Now, the initial appears in the

lower left-hand corner of Exhibit Y, capital R, and then a

colon, small bd.

What does the R signify?

A Ron, and L. Ron Hubbard.

Q What does the bd signify?

A Barbara Decelle.

Q And who was she?

A She was at that time the LRH personal secretary

on the Gilman Hot Springs property.

Q Now, you mentioned a document involving a non-

existence formula; is that correct?

A Yes.

MR. FLYNN: For the record, Your Honor, I believe

that's been already marked as Exhibit E.

THE WITNESS: No, I believe that is a separate one

that I sent to Mary Sue Hubbard.

Q BY MR. FLYNN: Okay. Well, let me ask you this:

Do you have a copy of the document that you

previously described in your testimony as to nonexistence

formula?

A No.

Q Do you know where it is?

A It was left in the organization when I left.

THE COURT: What is the significance of the words

"nonexistence post"? Where did you get that?

THE WITNESS: Your Honor, within Scientology there

1516

are various conditions relative to a post or something that

one goes up, and nonexistence is at the bottom. I was non-

existent at the time that I wrote it. No one knew of the

existence of such a post. It was a brand new thing, so I

wrote a briefing to each person involved laying out what

function I was going to be performing. Hence, I, in that

way, get out of nonexistence with those people.

1517

Q BY MR. FLYNN: You left the -- strike that.

What was this other document? Was it just a

description of what you just told the court?

A More or less.

In the meantime, a number of things had happened

between the point that I had written the petition and the

point I wrote the non-existence briefing.

I had by that time obtained possession of a

great number of the documents from Del Sol. So in addition

to the first one or two boxes, I now had about 16 of them.

Q 16 boxes?

A Right; which I had gone through roughly and laid

out in my communication to Mr. Hubbard what they were.

I had also transferred -- by that time I had

turned over all my records and finances connected with the

LRH renovations post and I had moved over and was then

working as the Senior PERS PRO researcher.

Q How many pages was this document, Mr. Armstrong?

A My recollection, it was three pages.

Q And its purpose was to inform other individuals

of the creation of the new post?

A Well, the one I sent to Mr. Hubbard was

different from the one I sent to Mrs. Hubbard, a copy of

which has been made available to the court. It was a

broader description of what I had found up to that point.

Q And why did you send a broader description to

Mr. Hubbard and a less-broad description to Mrs. Hubbard?

A Well, it was Mr. Hubbard's biography that was

1518

being done and Mr. Hubbard's records which were being

located and assembled in the PR Bureau.

Q Was it your state of mind at the time that these

were more personal and confidential to him?

A Well, perhaps that was a part of it. They were

his.

If some of them by that point had been noted as

Mrs. Hubbard's, it was very few. But it was his biography

that was being done.

Q Did you send the petition to -- strike that --

the non-existence formula to Mrs. Hubbard as a matter of

protocol?

A No. I actually -- I attached to the one I sent

to her, my recollection, a copy of the one I had sent to

him.

It wasn't protocol so much, but the fact that

Mary Sue Hubbard, who had been the man's wife, was obviously

going to play a part in the biography. I wanted to alert

her to what was being done and to --

I requested of her in my non-existent briefing

any information on herself which she cared to pass on at

that time. That was principally --

I sent these briefings to dozens of people on

various posts internationally, asking each one of them to

send me whatever they had.

Q Did you get responses from these people?

A Yes.

Q And what responses did you get?

1519

A Well, from Mary Sue, I received a copy of a

history of Mary Sue. This was provided by her secretary,

Nikki and other people that I communicated with as well;

Susan Anderson in the PR Bureau sent me some information. I

don't recall any others right now, but various people

responded.

MR. FLYNN: Your Honor, if this other document exists

in the files of the plaintiff or the intervenor, I would

request that it be produced. I believe we have tried to get

it before and have not been able to do so; namely, the

communication to Mr. Hubbard.

MR. HARRIS: If we can get a further description of it

from Mr. Armstrong.

Your Honor, I understood there was one

nonexistent formula that is in the court's possession. This

is a whole new one.

If we could clear it up that there were more

than one and the approximate date, we'll certainly look in

our files.

THE COURT: Can you be more specific as to the date

when perhaps this thing was executed?

THE WITNESS: It would have been sometime in early

February 1980. And it was one which was sent to

Mr. Hubbard. My guess is that there were a number of carbon

copies. And that is based on the fact that he has carbon

copied a lot of people on the return document.

I know of the existence of such a thing because

on my non-existence formula to Mary Sue, which would be

1520

around the same date, but it would be a few days prior to

that, I mentioned in that document that I had sent one to

Mr. Hubbard.

1521

Q And, in fact, that notation is made in the top

first sentence on the second page of Exhibit E; is that

correct, Mr. Armstrong? Namely, that "I have sent my non E

formula to R and informed him what I plan to do in the

biog."

THE COURT: Does that have a specific heading or

title or just a letter?

THE WITNESS: It would be just like -- it would be

something similar to the one sent to Mary Sue in which I

wrote, "New post non E formula R biography handling."

At that point I said, "Attached is my non-

existence formula which I have sent to R and various

executives in SU Pac, Flag and the UK."

So it was various executives in the Special

Unit out in Los Angeles. That is Pac. Flat is Clearwater,

and UK. That would be at Saint Hill in the UK, and the top

executives in each of those areas. Their files could be

checked.

The people at Flag would be LRH Personal

Communicator, LRH Personal Secretary.

At Pac would be LRH Personal Secretary. SU

would be all the top SMO Personnel, and the UK would be

David Gaiman, Sheila Gaiman, who were the Guardian and

Guardian PR.

THE COURT: Well, did you ever see any of these

copies later on at the Cedars Complex?

THE WITNESS: Oh, they were there when I left the

organization.

1522

THE COURT: You know where they were physically so

you could -- I mean, in what box or series of boxes, what

room or whatever?

THE WITNESS: Yes, they were in a file cabinet left

in the archives area which I believe now has all been moved

up to Mr. Vorm. I can't tell you the color of the file

cabinet, but it would have been one of the file cabinets,

and it would have contained information dealing specifically

with the biography. There were various files. There was

files to do with Oman Garrison, correspondence between Omar

Garrison and various organization personnel; Omar Garrison

and Mr. Hubbard, me and Mr. Hubbard, me and Mrs. Hubbard,

and a great deal of information relating to the biography

project.

MR. HARRIS: Your Honor, I have seen within the last

week something that is called a "nonexistence formula"

written by Mr. Armstrong.

However, I am confused because by his testi-

mony I understand there to be two such things, and I will

produce what I found.

THE COURT: Well, produce whatever you found and

have Mr. Vorm check further and generally where the witness

has indicated, and we will take a 15-minute recess.

(Recess.)

THE COURT: All right. Let the record show that

counsel are present. The witness has retaken the stand.

Just state your name again for the record, sir. You are

still under oath.

1523

THE WITNESS: Gerald Armstrong.

THE COURT: Yes, Mr. Harris?

MR. HARRIS: Yes, Your Honor.

Though you didn't anticipate that I would be

able to obtain it for you over this period of time, in fact,

I have. This is the only one I have seen, and I think I

have been through about everything there is and I will

produce it to Your Honor, and I have given a copy to

Mr. Flynn.

THE COURT: I don't have any particular need for it

unless it is going to be used in the trial. I presume it

will be.

MR. HARRIS: And I think it is on the defendant's

exhibit list, too.

Q BY MR. FLYNN: Mr. Armstrong, would you look

at what Mr. Harris has referred to that was produced; is

that the nonexistence formula that you sent to L. Ron Hubbard

that you testified about?

A No, it is not.

Q What is that?

A This was a document from the same time period

which was sent to various other people. For Mr. Hubbard

there was a different document, more -- a longer document,

more detailed than this.

MR. FLYNN: May this be marked next in order, Your

Honor?

THE COURT: Okay. Double-A.

Q BY MR. FLYNN: Who did you send this to?

1524

A This was sent to people from whom I requested

information. The principal reason was to obtain sources of

either documents or data which would be helpful in the

biography for the museum project.

1525

Q Now, when you sent communications to

Mr. Hubbard, did you use a particular routing formula?

A It would have gone via Senior PERS Bureau to

messenger on duty to Mr. Hubbard.

Q Now, let me show you the routing formula on your

petition; would you describe to the court what that routing

is? What does the "R" stand for?

A That is L. Ron Hubbard.

Q And then there is under that a "M on D." What

is that?

A It is "messenger on duty."

Q And then your name?

A Yes.

Q When you sent the non-existence formular you

described to L. Ron Hubbard did you use the same routing?

A To my recollection, I would have put via the

Senior PERS PRO Laurel Sullivan.

Q Does that mean you would have just included her

in the routing process?

A Right. And I would have used the designation at

this point, Senior R PERS Bureau Researcher. And I wouldn't

have just used the name Gerry Armstrong.

Q When was that?

A This would have been in early February 1980.

Q What was the purpose of your sending the non-

existence formular to Mary Sue Hubbard?

A To brief her on the fact that the biography

project was being done; that I had located these materials;

1526

that as a result of locating them, we could now proceed with

the biography and to elicit from her any information on

herself in that she was going to be a -- obviously, a player

in the biography; that is, in the book, the substance of the

book because she was married to the subject.

Q After having secured approval of the project

from L. Ron Hubbard did you need any approval of any nature

or description from Mary Sue Hubbard in order to proceed

with the project and collect documents?

A No.

Q And when you wrote to her in connection with the

non-existence formula did you specifically ask her for her

input into the project?

MR. LITT: Objection. The document speaks for itself.

THE COURT: If you want to highlight something in

particular, you may do so. But the letter does speak for

itself.

Q BY MR. FLYNN: Is there anything in the document

which has been marked as 5 February 19780 Non-Existence

Formula, exhibit E, in which you specifically elicited a

particular type of response from Mary Sue Hubbard?

A The majority of the letter is actually concerned

with that.

But I do ask specifically:

". . .to facilitate immediate

data-gathering do you have any biographical

data on yourself which you could send me?

Geneology, I think, could be very useful, any

1527

data, actually, on any facet of your life, on

Ron, the children, family anecdotes, the

formative years of Scientology, facts,

expansion, et cetera, which you wouldn't mind

having known would be wonderful."

Q Is that on page 2?

A Yes.

Q So you were specifically requesting from her

biographical data on her for the biography; is that correct?

A That is correct.

Q And did she respond by letter dated February 11,

1980 which has been marked as exhibit D?

A Yes.

Q And did you receive that communication in

response?

A Yes.

Q And did Mrs. Hubbard state in response to you:

". . .as regards my part in the

book, you'll have to maintain a line with Nikki

so that data may be obtained and checked by

me"?

MR. LITT: Objection. The document speaks for itself.

Q BY MR. FLYNN: when you received that,

Mr. Armstrong, did you understand that Mrs. Hubbard, per

that communication, had to approve your collection of

documents for the biography project?

A No.

Q What did you understand?

1528

A That regarding the biographical information on

her, which I requested, she wanted me to get in touch with

Nikki, who was her secretary, for the obtaining and her

checking of that biographical information.

1529

A Now in your petition to Mr. Hubbard, your

initial petition, why did you put your name, your full name

in the upper left-hand corner?

A Because I was not petitioning from a post but

as an individual, so I never had a post title from which to

communicate. I was not petitioning as the LRH renovations

in charge, which I was at that tine. I was petitioning as

Gerry Armstrong, an individual.

Q And at any time during the period that you were

collecting these documents, did you ever understand that you

needed Mary Sue Hubbard's persission to collect documents

for the biography project?

A No.

Q Was it ever an issue, Mr. Armstrong?

A No.

Q Did you in fact, check with Nikki Merwin to get

data on Mary Sue Hubbard?

A Yes.

Q And what did you do in connection with trying

to obtain that data?

A I wrote to Nikki and she wrote back and she

sent me a biographical piece which she told me had been

included in a -- I am not sure of the right name. It was a

presentencing report from the criminal case.

Q And Nikki Merwin sent you that?

A Yes.

Q Did she send you any other material?

A That was all.

1530

Q then was the next time that you communicated to

Mary Sue Hubbard if you presently recall regarding the

biography project?

A To my recollection there were a few times

throughout that period, but there is a couple which stick

in my mind. The first was a biography project or program which

was written some time in December of 1980, and that was sent

to Mary Sue for approval because it was -- she was the senior

available person, and there were targets which are steps

to be done by people in the Guardian's Office or in the

Controller's Office, so she had to approve of this thing

because the project itself included Controller's Office and

Guardian's Office personnel and targets to be done by these

people.

Q Who wrote that program up?

A Laurel Sullivan and myself.

Q How many pages is it?

A I believe it is three or four pages.

Q And what is it called?

A I seem to recall LRH biography project.

It is the central office of LRH ED.

Q Is it called a COLED?

A Yes.

Q And what is your best memory as to the date of

that COLED?

A Some time in the summer of 1980.

Q What does the term "COLED" stand for?

A Central Office of LRH ED.

1531

Q What does "ED" stand for?

A Executive Directive.

Q When is the last time you saw that COLED?

A Some time in 1981.

Q And do you know where it is at the present

time?

A Inside the organization somewhere.

Q Whose name is on it?

A I don't recall if it was names. You mean as

authors?

Q It originated from you and Laurel. Did you

both sign it?

A Yes, it had both of our -- either our names

or our post titles. I believe post titles.

Q And who was it routed to?

A I don't recall, but there are -- all of the

people who had targets received copies. It was a broadly

issued document.

Q And you know for a fact that that went to

Mary Sue Hubbard?

A Yes.

Q And how do you know that?

A Because I know the routing that the originals --

CSW it is called, the request was sent on, a description of

what was to be done and the reason for doing it. It was

stapled on top of the proposed mimeograph.

1532

And that had to be approved before the -- before

the thing which was finally published was in fact published.

She was on the approval line.

Q You mentioned that she was at that time the

senior individual to authorize certain types of activities;

what did you mean by that, Mr. Armstrong?

A Mary Sue Hubbard was the controller; so she was

over top of the Guardian's Office. And to -- she would have

had to approve orders coming from us which involved

Guardian's Officer personnel.

Q And why were you seeking to -- what were you

seeking to do with Guardian's Office personnel?

A Well, utilize the Guardian's Office PR network

and for the tours and that sort of thing to do with the

promotion of the biography.

Q So basically it was a proposal for that purpose,

just COLED; is that correct?

A It was an approved plan. The proposal was what

was attached to the plan which finally got approved and

published.

Q When you say "published," what do you mean by

that?

A Within the Scientology network, it was run off

in a mimeograph form so that each part of the complete

network would be informed of the project and their

respective parts in it.

Q So they could assist you?

A Right.

1533

Q And did you actually see an approval from Mary

Sue Hubbard of this COLED?

A Yes.

Q And do you have that?

A No.

Q When did you last see that?

A That would have been at the time it was

approved.

Q Did Laurel Sullivan see that approval?

MR. LITT: I object. That calls for hearsay.

Q BY MR. FLYNN: If you know.

A I don't know.

Q Was she in your presence when the approval came

back, if you recall?

A No, I don't recall that.

Q Laurel Sullivan did participate in the

preparation of the COLED; is that correct?

A Yes.

Q When did you next communicate with Mrs. Hubbard

if you can recall relative to the biography project?

A I sent her a briefing of what had been done, a

lot of archives materials which I was finding, some of the

situations which I was finding within the process of

checking these things and what I was doing with the

biography. And that would have been -- I believe it has

already been shown to the court; although I am not sure --

sometime in 1980, perhaps August.

THE COURT: Where were you stationed now in August,

1534

here in Los Angeles, Gilman, or what?

THE WITNESS: In Los Angeles.

MR. LITT: Is this in reference to the October 15,

1980 document?

MR. FLYNN: Right.

Before I get to that, though, I am going to go

through this.

Q The document that you just referred to, is that

in fact dated 15 October 1980, Mr. Armstrong?

A Yes.

MR. FLYNN: For the record, that has been marked

exhibit J.

Q Now, before you sent that did you request any

type of an order from the Personal Office of L. Ron Hubbard

that you could use to collect documents and information?

A Yes.

Q And what did you do to solicit such a document,

Mr. Armstrong?

A Well, at that time I was in Los Angeles. And

Pat Brice, who was then the LRH PERS SEC, she was called;

was also in Los Angeles. And I requested of her at that

time, which was just at the time I was planning a trip up to

Washington state and Oregon, to locate some of the places

where Mr. Hubbard had lived in his pre-Dianetics days and to

interview some of his family members who were still living

and who lived in that area.

It was for that purpose and to give me entry

with Mr. Hubbard's family that I requested this of

1535

Miss Brice.

MR. FLYNN: May that be marked as the next in order,

Your Honor?

THE COURT: All right. Double B.

Q BY MR. FLYNN: In connection with your request

to receive exhibit BB, did you actually send a written

communication soliciting exhibit BB?

A I don't recall if I did or not. I may have.

I spoke to her a number of times.

There was a situation at the time I actually

wanted such a letter from Mr. Hubbard because that would

have been the obvious thing for gaining an entrance in to

see the family.

She was afraid of obtaining something from

Mr. Hubbard because of the attempts at that point to have

him served by use of the fact, the claim that he was getting

his mail. If he were to sign such a document at that time,

it would show that he knew what was going on. And --

MR. LITT: Objection. This is all hearsay, I gather.

I assume he is reciting what is purportedly a conversation.

THE COURT: I am not sure. Maybe you can clarify it,

Mr. Flynn.

Q BY MR. FLYNN: Was this the understanding inside

the Personal Office of L. Ron Hubbard in regard to whether

he could sign documents that could go out to the public?

A Right. This is what I got. I knew it to be the

case. And it was the reason I ended up with this type of

document from the SEC rather than one coming from

1536

Mr. Hubbard.

MR. LITT: I'll make the same objection, Your Honor.

I don't know whether he is speaking of some collective

knowledge, his personal knowledge, or if it is purportedly

of his personal knowledge what the foundation of that

knowledge is.

He is making assertions about what he knew.

THE COURT: I'll let it stand.

Apparently he obtained this from Miss Pat

Brice.

Proceed.

Q BY MR. FLYNN: Mr. Armstrong, did you have the

original of exhibit BB in your possession at some time?

A Yes.

Q Do you know where it is now?

A It was left in the organization.

Q And was the original actually signed by Pat

Brice?

A Yes.

Q And on the copy that we have, it is a poor copy.

And you can barely make out the signature; is that correct?

A Yes.

Q Now, you testified that the next communication

you sent to Mrs. Hubbard was on 15 October 1980; is that

correct?

A Yes.

Q Now, let me show you what has been marked as

exhibit J.

1537

Do you recognize that as the communication that

you sent to her?

A Yes.

1538

Q How did you route it to her at the time?

A From me. I was the senior Pers Pro Researcher.

I sent it via senior Pers Bureau who was Laurel, and via

Controller Communicator who was Nikki Merwin to the Controller

was Mary Sue Hubbard.

Q What was the purpose of your sending Mrs. Hubbard

exhibit J?

A Laurel asked that I send Mary Sue a briefing

on what was being done and Laurel expressed to we that in

that Mr. Hubbard wasn't around, it was good to keep

Mrs. Hubbard briefed. She was very interested in the

materials which I have been locating and she had been

enthusiastic about the fact that I had located materials

which Mr. Hubbard had thought had been stolen in 1953, and

Laurel said Mary Sue was very happy about that and she wanted

me to just lay out a briefing of my activities and the

success I was having at the time.

MR. LITT: I assume this is introduced for the background

of this communication and not for what Miss Sullivan purportedly

said?

THE COURT: Yes, as to what happened and the sequence

of events and why it happened.

Q BY MR. FLYNN: In fact, with regard to the

notation that Mr. Hubbard thought his materials had been

stolen prior to 1953, do you have any knowledge whether he

had communicated that to Omar Garrison which was attached to

the subsequent contract that was entered between PDK and

Mr. Garrison and Mr. Armstrong?

1539

A Yes, he did.

Q Now, were there to your knowledge routine

communications in 1980 while you were collecting documents

between Laurel Sullivan and Mary Sue Hubbard?

A Yes, on practically a daily basis.

Q And to your knowledge was Laurel Sullivan

personally very close to Mary Sue Hubbard?

A Yes, she was.

Q And it was Laurel Sullivan that asked you to

write a complete briefing to Mary Sue Hubbard of everything

that you were doing; is that correct?

A Yes.

Q And again at that time did you need Mary Sue

Hubbard's approval to collect documents from around the world

for this project?

A No.

Q You did it because Laurel Sullivan asked you to?

A Yes.

Q Now did you tell Mrs. Hubbard that in January

there had been a raid threat at the Special Unit which resulted

in your collection of the initial set of materials?

MR. LITT: Objection. Mr. Flynn is simply reading from

the document. The document speaks for itself.

THE COURT: It is true. It is not in evidence yet.

MR. FLYNN: Well, I'd move it into evidence at this

time.

THE COURT: Any objection?

MR. LITT: Well, yes.

1540

I mean, what is the purpose for which it is

introduced, Your Honor?

THE COURT: I suppose it is a communication from this

witness inferentially to C of 10-15-80.

MR. HARRIS: Given the witness' testimony, we have

no objection to that going in.

THE COURT: All right, it will be received. J is in

evidence.

Q BY MR. FLYNN: And did you make an effort to

list some of the materials you had collected to that point

in time?

A Yes.

Q Now at this point in time in October of 1980

what is your estimate, Mr. Armstrong, as to the quantity of

materials that you had collected for the biography of

L. Ron Hubbard?

A Probably a couple of hundred thousand pages.

Q And you told her, did you not, that the list

goes on and on; do you recall saying that?

A Yes. I don't know quite what the list was I

was referring to, but -- at this point. I do recall that

statement in the document, though.

Q When you left your position collecting documents

for the biography of Mr. Hubbard, approximately how many

documents had you collected to that point in time?

A Maybe five or six hundred thousand.

Q And of the documents under seal what is your

estimate as to approximately what percentage of the documents

1541

under seal has in relationship to the overall number of

documents that you collected?

A Maybe one or two percent.

Q Now did you tell Mrs. Hubbard that many

documents were being lost and destroyed because of their lack

of being attended to and collected and you had discovered

that fact?

MR. HARRIS: Insofar as the question as phrased,

"Did you tell Mrs. Hubbard" --

MR. FLYNN: I will withdraw it, Your Honor.

Q Did you become concerned, Mr. Armstrong, that

in the collection process you were finding that many documents

were kept in damp, mildewed, unheated areas and were subject

to being lost or destroyed?

A Yes.

Q And did you find that to be the case?

A Yes.

Q And where did you find that to be the case?

A That was in the case in GOPR Archives WW.

Q And did you go to GOPR Archives WW?

A Yes.

Q And that is Guardian's Office Public Relations

Archives at Worldwide?

A Yes.

Q And that was in England?

A Yes.

Q And when did you go there?

A In about September of 1980.

1542

Q And would you describe how large of a building

those archives comprised in September 1980?

A It is not a particularly large building. The

PR Archives which you saw would have amounted to several

hundred thousand pages.

1543

Q Were they all housed in one building?

A What I saw of them were all in one building,

yes.

Q Now, is there anything of particular

significance in your communication to Mrs. Hubbard of

October 15, 1980?

MR. HARRIS: Can we refer to the exhibit as opposed to

Mr. Hubbard? It is addressed to Mrs. Hubbard, but that was

specific testimony that she didn't receive it, Your Honor.

Q BY MR. FLYNN: Referring to exhibit J --

A I'm really not sure what "your communication"

means.

Q BY MR. FLYNN: It was your purpose, was it not,

to keep her fully abreast of what you were doing?

A Yes. That is correct.

MR. LITT: Objection. Leading, Your Honor.

THE COURT: Why did you head this off with "Dear

Sir:"?

THE WITNESS: Your Honor, in the SEA Organization

L. Ron Hubbard is the Commodore and she is the Deputy

Commodore. And it is a -- in retrospect, I must admit it is

a para-military organization which contains --

MR. LITT: We'll move to strike, Your Honor.

THE COURT: I think he is trying to explain. I'll

permit him to explain.

I have already drawn the conclusion that it is

sort of Navy-oriented. I was in the Navy myself at one

time.

1544

Go ahead.

THE WITNESS: everyone in the SEA Organization has a

rank of some kind.

I rose to the rank of Ensign.

And depending on the situation, senior officers

were called "Sir."

Mary Sue was a senior officer. And within the

SEA Organization, as opposed to within the Guardian's

Office, for example -- well, Guardian's Office personnel did

not go by the SEA Organization military designations. They

went -- they would refer to her as Mary Sue.

THE COURT: All right. You may continue, counsel. I

didn't mean to interrupt.

Q BY MR. FLYNN: Was it common for you to use the

term "Dear Sir" in addressing Mary Sue Hubbard in her

position as controller?

A Yes.

Q Was that commonly done by other people in your

observation?

A Yes.

Q Did you receive a response from Mary Sue Hubbard

to exhibit J?

A Yes.

Q And what was the response?

A I don't recall in detail, but I definitely got

an acknowledgement from her of receipt of this letter.

Q And when did you last see that?

A In the organization, sometime before I left.

1545

Q Do you know whether Laurel Sullivan received

that response?

A I don't recall if we discussed it or -- but we

probably would have.

MR. FLYNN: Your Honor, if that is available, may that

be produced together with the COLED and the response, if

any, of Mary Sue Hubbard to the COLED?

THE COURT: Well, were these noticed to produce, any

of these documents at any time?

MR. FLYNN: They were, Your Honor.

MR. LITT: They were? Can you provide that?

MS. DRAGOJEVIC: I believe we received the COLED at

one time, Your Honor. We simply can't locate it in our

office at this time. We did receive it from the church. We

have been looking for it and can't fine it in the office.

The other items, I believe, were requested. We

don't have our request for production in the court, but I

would be willing to go back and look.

THE COURT: Well, the only thing that I'm concerned

about, I gather there are thousands and thousands of places

to look. And I would think that if we can identify where

these are likely to be if they are in existence, maybe that

would be of assistance here and it wouldn't involve somebody

with an order that would require an exercise of thousands of

hours of effort here.

I don't propose to do that.

MR. FLYNN: Well, --

Q Do you know where they were left, Mr. Armstrong?

1546

A Yes. All of that type of communications was in

one file cabinet in which were also contained the

communications with Omar Garrison relative to the biography

and any communications from Mary Sue Hubbard including

communications from Omar Garrison and Mary Sue Hubbard and

the various copies of my non-existence formulas and any

other documents relating to the biography or archives or

museum project were all in one file cabinet.

Q Where was that file cabinet when you last

saw it?

A It was alongside of a wall where there was a

bank of file cabinets inside the archives room.

1547

Q And were there file folders with headings on

them that related to these or that may have contained these

particular items; namely, the COLED, the response of Mary Sue

Hubbard to the COLD and the response of Mary Sue Hubbard to

exhibit J?

A They would have all been in a file called

"Biography Project." There was a few files which were

biography project files which were not archives exactly,

but related correspondence and documents relating to

archives and to the biography project.

THE COURT: Well, I will make an order, Counsel, that

personnel make reasonable effort to try to locate those

documents and report back.

MR. HARRIS: The COLED I am given to understand, Your

Honor, has a number on it.

Maybe with this witness familiarity he could

tell us what the number was or even the hundred or whatever

within a hundred of what it was.

THE WITNESS: I think if you were to just check the

COLEDS which were issued in 1980, that would narrow it down

within a hundred.

MR. HARRIS: And the next is the alleged approval or

acknowledgement of the exhibit J; is it?

THE COURT: Yes, by Mary Sue Hubbard.

MR. HARRIS: I have looked, Your Honor, and on that

I know there is no such thing, and I have looked in the files.

But I will check with personnel.

THE COURT: All right, see what they can find.

1548

MR. FLYNN: Your Honor, I believe the church or the

intervenor did introduce what has been marked as exhibit J,

so they might look in the same file where exhibit J was filed.

MR. LITT: That has already been looked at, Your Honor,

but we will see if it is anyplace else.

THE COURT: All right.

Q BY MR. FLYNN: Now, from your nonexistence

formulas, Mr. Armstrong, I understand that you were creating

the LRH biographical archives; is that correct?

A Yes.

Q And did you prepare an outline of where you

were collecting documents from for the biography project?

A Yes.

MR. FLYNN: And may that be marked as the next

exhibit in order, Your Honor?

THE COURT: Double C, I believe.

Q MR. FLYNN: How, would you explain, Mr. Armstrong,

exhibit double C to the court.

A This shows the sources of at least the greatest

percentage of the materials which were provided to me or made

their way into the space which was designated LRH Biographical

Archives, and also some of the materials which during that

time were provided or went to Controller Archives.

Q Now in some instances, for example, you have

got an arrow from GOWW Archives directly to Controller Archives,

but not over to LRH Biographical Archives; what does that

mean, Mr. Armstrong?

A Well, GOWW Archives actually was the source

1549

of what became the bulk, at least of the Controller Archives.

Q And did you receive directly any documents

from GOWW Archives without going through Controller Archives?

A No.

Q What persons did you deal with to get documents

from GOWW Archives?

A Well, there were -- I guess I dealt with

Tom Vorm. Ultimately it came from his -- his Controller

Archives came from there.

Q And did you have an understanding when you

received those documents from Controller Archives where they

had come from?

A Only through conversations with Tom Vorm and

the fact that I knew of the trunks from when I was on the ship,

and I knew roughly at that time the history of the trunks.

1550

Q What did you know about the history of the

trunks?

A About their being brought to the ship by Wally

Burgess.

Q What knowledge did you have when you were

collecting these documents of how GO-WW archives worked?

A I don't believe I had much knowledge of that at

all.

Q Well, you had been there; is that correct?

A We are not talking about GO-PR archives.

I never obtained any material during that time

from GO-PR archives. They sat during that time in the UK,

to the best of my knowledge.

GO-WW, something else; they housed at a certain

period what became controller archives and they were shipped

over.

Q Do you know where GO-WW archives were kept in

the United Kingdom in England?

MR. LITT: What time frame are we talking about?

Q BY MR. FLYNN: Did you learn while you were

collecting documents where GO-WW archives had been kept

prior to the creation of controller archives?

A In Saint Hill Manor, the exactly location, I

don't know.

Q What is your understanding as to when controller

archives was created?

A It would be in the late '70s.

1551

Q And the LRH Biographical archives was created

with your position; is that correct?

A That is correct.

Q Did you understand or have any understanding

that GO-WW archives contained master copies or a master

inventory of everything in controller archives?

A I wasn't sure if they contained everything. But

it seemed likely, having seen GO-WW, that they contained at

least the bulk of them.

Q Was that your understanding from Mr. Vorm?

A Mr. Vorm and I never discussed that.

Q How did you arrive at that understanding?

MR. LITT: Can we have the understanding clarified,

Your Honor?

THE COURT: I think it was an assumption or inference

that he drew rather than -- he made a comment, "It seemed

likely." And I don't --

THE WITNESS: I don't have any first-hand knowledge to

be able to answer your question on that.

Q BY MR. FLYNN: Well, when you were collecting

documents from Mr. Vorm, was that your understanding?

MR. LITT: Was what his understanding?

MR. FLYNN: That the GO-WW archives were the master

archives for the controller archives from which the

controller archives were coming.

THE WITNESS: I understood that all the controller

archives came from there. I don't know that it was master

archives.

1552

Q BY MR. FLYNN: Okay. Now, in the creation of

the controller archives, there were two other arrows from

"PERS COM FLAG N Purchased Items"; what does that mean?

A During the course of my work collecting up the

biographical archives, I had the files which were designated

"PERS COM FLAG files" sent to Los Angeles from Clearwater.

Those files covered principally the period of

time on board -- while Mr. Hubbard was on board the ship and

shortly thereafter in Clearwater and Dunedin.

These things were kept off the property in

Clearwater in a closet in Clearwater, one of the berthing

buildings for the base.

I found that in a trip I did to Clearwater in

May of 1980 and I made arrangements for these things to be

sent to me.

When they arrived -- and there was a great

number of them, about 30 or 40 boxes -- within the boxes

themselves were a number of what we call technical or policy

materials. And those were delivered directly to Mr. Vorm.

The materials which were not technical and were

not originals or carbon copies of policies which Mr. Hubbard

had written, I took into my archives, biographical archives

area.

They could have been to do with any number of

subjects. But the technical materials, Mr. Vorm, went to

the PERS COM boxes and took out the technical materials

himself. And I went through some and delivered them

directly to Mr. Vorm.

1553

The purchased items, the reason that the arrow

is there is because during the course of my traveling around

the country, I would on occasion come across materials which

I purchase. And if on -- a lot of times, it was materials

that I did not have any interest in, but which I felt

Mr. Vorm, in his capacity or the organization may have some

interest in.

They were not biographical. They were technical

materials. So that kind of stuff, I would make arrangements

and purchase.

For example, there was a number of tapes.

Mr. Vorm had the tape archives of all of the tape masters of

lectures done by Mr. Hubbard. It was not complete. And

Mr. Vorm and others were attempting to obtain the complete

list of the complete tape library.

So when I located people from the early days of

Dianetics or Scientology who had tapes, I compared them with

a master list which Mr. Vorm had to see whether or not

included in the tapes which the people had were ones which

Mr. Vorm did not have.

And on those occasions, I purchased the tapes

and brought them back to Mr. Vorm. So tapes and on another

couple of occasions, I purchased technical originals or

original technical writings by Mr. Hubbard which Mr. Vorm

did not have. And I brought those back.

These were not things which I was going to be

needing because Mr. Garrison was not going to -- this was

not going to be a book about Dianetics and Scientology; it

1554

was going to be strictly biographical.

So I made the decision and sent those things

directly to Mr. Vorm.

1555

Q So, is it basically fair to say that the

technical items went into the controller archives and personal

items relating to L. Ron Hubbard went into the LRH biographical

archives?

A Yes.

Q And was this the understanding of everyone

throughout the period of time that you worked on this project

that you dealt with?

A Yes.

MR. HARRIS: To the extent the witness can generalize

about the understanding of everyone, Your Honor.

THE COURT: Well it was rather conclusionary,

but I will let it stand.

Q BY MR. FLYNN: Is there anyone that you dealt

with in any Scientology organization throughout the period of

time that you worked on the biography project, Mr. Armstrong,

who refused to give you materials because they were personal

records of L. Ron Hubbard?

A No.

Q And, in fact, you had the letter from Miss Brice;

is that correct?

A Yes.

Q Now, there is a notation "Del Sol storage."

Approximately what quantity of materials came from Del Sol

storage that went into the biographical archives?

A There were 21 or 22 boxes all together,

different sizes and different shapes, and I think that the

total must have been a hundred to two hundred thousand pages.

1556

Q And that was acquired by you right at the

beginning of the collection process; is that correct?

A Yes.

Q And did Laurel Sullivan know that you had

acquired those boxes right at the beginning of the collection

process?

A Yes.

Q And how long thereafter did you continue to

collect documents relating to the biographical archives?

A Right up to at least the point I left the

organization.

Q Which was when?

A December 12, 1981.

Q Now during that period of time did anyone

ever tell you to remove the Del Sol storage boxes from the

biographical archives?

A No.

Q Now you have an arrow from the Pers Sec Flag

files.

Approximately what quantity of materials did

you receive from that source for the biographical

archives?

A I would say another hundred or one hundred fifty

thousand pages.

Q What in general types of documents were involved

in the Pers Sec Flag files?

A There was a great deal of correspondence between

Mr. Hubbard and friends, family, wives, father, mother, son.

A lot of correspondence in those files.

1557

Q Who had possession; what person did you deal

with to get possession of those materials that you just

described?

A Pat Brice.

Q And she authorized you to have those materials?

A Yes.

Q And she was L. Ron Hubbard's personal secretary?

A Yes.

Q And what in general was the nature of the

documents that came from Del Sol storage?

A They were documents with -- they were early

documents. The majority of them predated Dianetics, so they

were pre-1950 documents. There were some documents included

in there which went into the '50's, probably up to the mid-

50's.

Q You had mentioned the documents pertaining to

Quentin Hubbard as coming from Del Sol storage; do you recall

that?

A Yes.

Q Now do you know how those materials got into

Del Sol storage?

A No.

Q Did you ever give materials relating to the

death of Quentin Hubbard to Omar Garrison?

A Yes.

Q What did you give to him?

A There was a bunch of materials which was provided

by the Intelligence Bureau to Vaughn Young who was then working

1558

with me on the biography project, and Vaughn had access to

the Guardian's Office and obtained these things for me to

deliver to Omar.

Q Where did Vaughn Young obtain these from?

A From B-1, Bureau 1 of the GOUS.

Q Who is Vaughn Young?

A Vaughn Young was at that time a member of the

US Guardian's office in the public relations bureau.

Q And who was his supervisor?

A At that time I don't know.

Q Mary Sue Hubbard was the controller over

the Guardian's office; is that correct?

A Yes.

MR. LITT: What period of time are we talking about?

THE COURT: Well, what period of time do you have

reference to?

THE WITNESS: This was in late 19- -- in the fall of

1980.

Q BY MR. FLYNN: Now, do you know how these materials

got into the Del Sol storage?

A No.

1559

Q Do you know where Vaughn Young got his author-

ization to get materials from the B-1 files relating to the

death of Quentin Hubbard?

A No.

He did tell me that he got them from B-1.

Who there, I'm not sure who made them available.

Q What quantity of materials did he get from the

Pers Sec WW files?

A There was a very large box and a couple of

smaller boxes. So I would say maybe 15,000 pages, maybe

less.

Q What in general was the nature of those

materials?

A They were Mr. Hubbard's files which had been

maintained in the Pers Sec WW area which is inside the

Saint Hill manor. They principally dealt with ships, with

Hubbard's explorational company, with OTS, with Horticulture,

activities in which Mr. Hubbard was involved at Saint Hill in

the '60's.

Q What is OTS?

A Operation and Transport Services.

Q And was that a corporation which was the

predecessor to OTC?

A Yes.

Q So the documents relating to the Hubbard

explorational company came from the Pers Sec WW files; is that

correct?

A Not all of them.

1560

MR. HARRIS: Objection. Ambiguous, Your Honor.

The files, there has been already testimony

from Mr. Vorm and is on an inventory list of a mass of HEC

documents.

THE COURT: You can reframe the question.

Q BY MR. FLYNN: Where did the materials come

from, Mr. Armstrong?

A They came from either the controller's archives

or from the Pers Sec WW files.

There was also some in Pers Sec files.

Q What is the difference between Pers Sec files

and Pers Sec WW files?

A Pers Sec Flag.

Q There were HEC materials there also.

A yes.

Q Do you know of any other place where there were

Hubbard explorational company files?

A I can't say for certain, there is something in

my mind when I went through the GO PR Archives at WW in

finding files on that subject there.

Q But in any event, you are certain HEC Hubbard

explorational materials came not only from controller archives

but from these other sources too; is that correct?

A Yes.

1561

Q And approximately what quantity of materials

came from Pers Com Flag for the biographical archives?

A That was again probably a couple hundred

thousand pages.

Q And what is general was the nature of those

materials?

A Those were principally from the period when

Mr. Hubbard was on the ship, and some subsequent from Dunedin,

and that was principally it.

Q And approximately what quantity of materials

came from purchased items for the archives?

A Very, very small amount, maybe 300 pages.

Q And what was the nature of those items?

A There were two main sets which come to mind.

The first was from Barbara Snader, who was a girlfriend of

Mr. Hubbard's in the early '5Os, and the other set was from

a woman by the name of Helen O'Brien, who was the head of

Dianetics-Scientology is the U.S. in the early 1950's, 1952.

Q And the last category, B-1 files, what

quantity of materials came from B-1 files that went into the

biographical archives?

A I would say there was maybe a thousand pages.

Q And what in general was the nature of those

materials?

A Those referred to Quentin Hubbard, Mr. Hubbard's

naval records obtained under the Freedom of Information Act.

Maybe these would be 2,000 pages total, and the pack of

materials entitled "Estimate and Reader's Digest."

1562

Q Did Vaughn Young give you those?

A Yes.

Q And do you know whose authority he did it with?

A No.

Q So there were naval records in the Del Sol

storage and naval records in the B-1 files; is that correct?

A Yes, at least.

Q There were also some naval records in Pers Sec

Flag files, but the the most extensive sources were the

Del Sol storage and the B-1 files.

Q And there were Quentin Hubbard documents in the

B-1 files and in the Del storage; is that correct?

A Yes. However, the Quentin Hubbard files in

Del Sol storage, I believe, were sent off the property in

the beginning of 1980.

1563

I went to Laurel and mentioned that they were

there. And it was considered at that time that it would be

safer to move them off the property. Where they went at

that point I am not sure.

Q Who made the decision to move them?

A Laurel.

This is what I got from her. I dropped the

subject at that point.

Q And did the subject come up at a later point in

time?

A I don't believe I have ever discussed it with

her.

MR. FLYNN: Perhaps this would be a good time to

break, Your Honor.

THE COURT: We'll accept that.

We'll recess until 9:00 o'clock tomorrow

morning.

(At 4:00 p.m. an adjournment was taken

until Friday, May 11, 1984 at 9:00 a.m.)

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