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 wa