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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' DAILY TRANSCRIPT

Tuesday, May 15, 1984

VOLUME 12

Pages 1860 through 2030, incl.

 

APPEARANCES   (See next page.)

 

 

 

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

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APPEARANCES:

For the Plaintiff:

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

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

-and-

ROBERT N. HARRIS
The Oviatt Building
617 South Olive Street
Suite 915
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

 

 

 

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INDEX FOR VOLUME 12

Pages 1860-2030, inc.


DAY DATE SESSION
PAGE

Tuesday May 15, 1984 A.M. 1896
    P.M. 1959

DEFENSE WITNESS

DIRECT CROSS REDIRECT RECROSS

ARMSTRONG, Gerald
(continued)
1901      
(Resumed)
1959      
EXHIBITS
DEFENSE EXHIBITS IDENTIFIED

500-QQQ

- Copy of letter dated 5-13-47 1901
5000-RRR

- Copy of letter dated 4-2-58 1901

500-SSS

- Copy of letter dated 1-27-48 1902
500-TTT

- Copy of letter dated 2-26-48 1907
500-YYY

- Hubbards VA records 1959
500-ZZZ

- Record of proceedings on PC815 1957
4-A

- Letter dated 12-5-49 1908
4-B

- Document dated 3-18-46 1909
4-C

- Letter dated 8-26-47 1908
4-D

- Course II 1913
4-E

- Copy of handwritten document 1913
4-F

- Copy of handwritten document 1913
4-G

- Copy of handwritten document 1913
YY

- Naval records 1915
4-H

- Typed notes 1964
4-I

- Handwritten document 1964
4-J

- Copies of document in black binder 1960
4-L

- Handwritten letter dated 11-30-71 1941
4-M

- Brown folder and contents 1941
4-N


- Divorce proceedings between LRH
Louise Grubb Hubbard
1953
4-O - Letter dated 1-1-45  
 

 

 

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EXHIBITS (Continued)
DEFENSE EXHIBITS (CONTINUED) IDENTIFIED

ZZZ

- Record of proceedings on board PC815 1957
4-Q

- Guardian's office time track. 1969
4-R

- Letter dated 11-18-80 1968
4-S


- Documents relating to Puerto Rican
expedition
1970
4-T


- Documents sent out by Hubbard
about himself
1973
4-U

- Handwritten note 1974
4-V

- Letter dated 4-10  
4-W

Letter in LRH handwriting 1977
4-X

Document written by LRH 1978
4-Y

- Draft of letter by LRH 1978
5-A

- Documents to Constantine Diamontides 1984
ZZ

- Document entitled "What your fees buy" 1986
5-B

- Folder with contents  
5-C

- 2 cassette tapes  
5-D

- Inventory done in 1977 1992
5-E


- Documents relating to Hubbard
Explorational Company
1996
5-F

- 1-page handwritten document 2008
5-G

- Copy of legal memo 2009
5-H

- Copy of resignation as trustee 2010
5-I

- Copy of letter dated 4-18-63 2015
5-J

- Copy of document 1-9-78

2015
5-K

- Copy of document dated 6-22-78 2015
5-L

- Copy of document dated 1-22-78 2015
5-M

- Copy of document dated 1-28-78 2015
5-N

- Copy of document dated 2-16-78 2015
5-O

- Copy of document dated 3-22-78 2015
5-P

- Copy of document dated 2-16-78 2015
5-Q

- Copy of document dated 12-23-77 2016
5-R

- Copy of report dated 11-2-70

2016
5-S

- Copy of letter dated 6-12-80 2016
5-T

- Copy of document dated 9-17-65 2016
5-U

- Two-page documentdated 2-25-76 2016
 

 

 

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EXHIBITS (Continued)
DEFENSE EXHIBITS (CONTINUED) IDENTIFIED

5-V


- File relating to LRH personal
finacnes after his resignation in '68
2017
5-W

- Newsletter 2019
5-X


- Copy of document dated
3-7-68
2019
5-Y

- 2-page letter dated 3-13-68 2020
5-Z

- Copy of documet in LRH handwriting 2021
6-A



- Document relating to LRH
ordering elections of various
boards dated 7/25/66
2022
6-B


- Documents showing financial
transations between HEC and LRH
2022
6-C

- 2022
6-D


- Dispatch from LRH regarding use of
codes, etc.
2022
6-E


- Document indicating LRH use of
finding material to blackmail
2023
6-F

- Document in LRH handwriting 2024
6-G

6-H

6-I

6-J

6-K

6-L

6-M

6-N

6-O

6-P

6-Q

6-R
- "    "    "    

- "    "    "    

- "    "    "    

- "    "    "    

- "    "    "    

- "    "    "    

- "    "    "    

- "    "    "    

- "    "    "    

- "    "    "    

- "    "    "    

- "    "    "    

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2024

2029

2029

2029

 

 

 

 

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Los Angeles, California; Tuesday, May 15, 1984; 9:05 a.m.

---0---

 

THE COURT: All right, we are back in session. Counsel

are present.

I have not had a chance yet to look through that

material, group of materials that I indicated I would do

before we went into them, but I understand Mr. Flynn has

something?

MR. FLYNN: I might make a suggestion, Your Honor.

I spent three or four hours last night with

Laurel Sullivan going over her testimony, and from what I

have learned, a lot of the problem may be obviated. I will

make this as succinct as I can.

On page 5 of their memo they say, "Manifestly

Miss Sullivan as the individual in charge of a

specific legal project and dealing with attorneys

on behalf of the church obtained all of her

information in the course of an attorney-client

relationship where she was one of the individuals

designated by the church . . ." et cetera.

 

 

 

1897

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The evidence will unequivocally be that she

acquired the information for eight years before the project

began. Between 1972 and 1980 she had 98 percent of the

information and the evidence that she is going to testify

about before the project began. And she was assigned to the

project by L. Ron Hubbard for that reason. And the purpose

of the projection as she very succinctly puts it is to change

history, to change what has been done in the past, to create

a lie in the future.

I suggest that the approach to this problem should

be to put the thing aside. We won't go through it again on

Mr. Armstrong's testimony except with regard to identifying

the tapes and how he can into possession of them and perhaps

why he sent them to me, without getting into the contents.

And then after Miss Sullivan testifies, I think

the court would be in a better position to understand where

the source of the information comes from.

THE COURT: That is agreeable. No problem.

MR. HARRIS: Except, Your honor, except -- well, I guess

I am a little concerned because I went through all the MCCS

files last night in the hope I could get Your Honor something.

And I feel I have wasted my work. That is the first problem.

But secondly, if she is to testify in respect

to this, we would want an in camera proceedings before this

goes on the record out here because I think -- well, I mean

I have a potpourri of things that I just pulled from the files

which I think, under the circumstances -- though it is

Mr. Flynn's burden and he must show by extrinsic evidence

 

 

 

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the items in the file indicate communications to attorneys,

from attorneys within the organization in order to gather

information for the attorneys and the like. I would be

prepared to submit those to Your Honor. But --

THE COURT: It may be premature. Let's defer that for

the present. I have to deal now with the subject of these

writings. And that is going to take some time.

So I'll take a recess. We'll hope for a quarter

to 10:00. It may be a little optimistic. I'll see what I

can do.

(Recess.)

 

 

 

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THE COURT: All right, in the case on trial let the

record reflect that all counsel are present.

Mr. Armstrong, you may retake the stand.

 

GERALD ARMSTRONG,

resumed the stand, having been previously sworn, and testified

further as follows:

THE COURT: The record will reflect that I have read

the exhibits which are exhibits 500 quadruple-F, -E, -D,

-G, -I, and basically I'd like before we get into the matter,

I'd like to know more about where these particular documents

came from and where did you find then; and so forth.

Can you tell us about that, Mr. Armstrong?

 

 

 

 

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THE WITNESS: YOUR HONOR, they were included in the

materials obtained from the condemned hotel in the Yeoman

Hot Springs property called Del Sol. And they were amongst

the 22 or so boxes of material which were located in that

area and which I subsequently moved over to the public

relations bureau and then to Los Angeles.

I came across them sometime later that year.

They were not among the first materials which I went through.

THE COURT: Were they in any particular sequence, just

a group of papers that were individually stapled together,

or joined together or bound into certain volumes? Can you

describe the way they were apparently stored?

THE WITNESS: They were not all together. They were

in at least a couple of boxes.

I was able -- some of them were in chunks together

and the rest, I was able to assemble in a logical order.

I had to do that with a lot of Mr. Hubbard's

materials because they were -- a lot of the materials in those

Del Sol boxes were unsorted, uninventoried. And they had

to be put in some sort of a sensible order.

THE COURT: All right. Well, gentlemen, do you want

to be heard further on the subject?

MR. FLYNN: I would like to lay a little more foundation,

Your Honor, if I could before we get into the contents.

THE COURT: All right.

MR. FLYNN: If I could have the materials leading up

to -- there are just a few exhibits left before we reach those

actual documents.

 

 

 

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THE COURT: All right, looking at these exhibits, do

they apparently come from the material that left England and

got on board ship and has been aboard ship for awhile and

then moved apparently to Del Sol?

THE WITNESS: No, I don't think that this stuff went

to England, Your Honor.

It was material which had been kept at one time

in Washington, D.C. Mr. Hubbard was in Washington, D.C, in

the late '50's up until in 1959, at which time the Hubbards

moved to England, leaving behind all these materials, and

I don't believe this material ever went to England.

When the Hubbards moved to La Quinta, they ordered

this material sent from where it was in storage in Washington,

D.C., and then it followed from La Quint& to Gilman Hot Springs

and then from Gilman Hot Springs to Los Angeles.

THE COURT: All right, Mr. Flynn.

 

DIRECT EXAMINATION (Resumed)

BY MR. FLYNN:

Q Mr. Armstrong, I believe you explained yesterday

why you sent 500 triple Q to me in connection with the fact

that in 1947 Mr. Hubbard was seeking an eye examination from

the Veterans Administation; is that correct?

A Yes. This ties in with another letter, I believe

we had, from 1947 concerning that examination.

Q And with regard to 500 triple R, why did you send

that to me, Mr. Armstrong?

A this letter from Mr. Hubbard is dated 1958,

 

 

 

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April 2, 1958, and it is to the Veterans Administration and

in my mind there was a conflict between the fact that here

he is asking to have his V.A. checks sent to a particular

address in 1958, and in all the publications about Mr. Hubbard

he had claimed that he had been given a perfect score, perfect

mental and physical score by 1950 and by 1947 had completely

cured himself, and here he is still drawing a V.A. check for

this disability, and maybe it is okay to do that. It seems

like there was at least a contradiction and possibly an

unethical practice on his part.

Q And that was on April 2, 1858?

A Yes.

Q And do you know what the percentage of disability

that he had under his Naval pension?

A Originally it was at 10 percent. I believe it

went up to 50 percent.

Q And do you know whether between 1945 and 1950

he was continually filing appeals with the Veterans

Administration to raise the disability?

A There were a number of such documents.

Q And directing your attention to exhibit 500 triple S,

why did you send that to me?

A This is another letter from Mr. Hubbard to the

Veterans Administration, January 27, 1948, and in here he

mentions that he is penniless, that he was ill and broke in

November 1947, and it has to do with some debt that he then

owed the Veterans Administration. They had overpaid him at

some point.

 

 

 

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This is by a date which he had -- was per his

own handwriting he had been totally cured.

Q And does he state, "My health has been bad and

I feel that if I could just get caught up financially, I could

write a novel which has been requested of me and so remedy

my finances"?

A Yes.

Q Now there is a document that has been marked as

an exhibit both by the plaintiff in the original handwriting

of Mr. Hubbard called "My Philosophy" and by the defendant,

which is exhibit 5 of the plaintiff's, and by the defendant

in a published form by Mr. Hubbard which you have testified

earlier you believe was widely disseminated called "My

Philosophy."

Do you recall representations in that publication

about Mr. Hubbard not having any psychotic or neurotic

tendencies but being permanently disabled physically?

A Yes.

 

 

 

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Q And that he completely cured himself within

two years after World War II?

A Yes.

Q And was that publication of some significance

to you, Mr. Armstrong, in sending me the documents that

are now being marked as exhibits?

A Yes. Originally the fact that the man had

cured blindness, cured some crippling illness or crip- --

lameness, crippling injury, I believe he called it, using

what was then the very crude antecedent of Dianetics

had a great impact on me. That had great signficance.

I had not heard of people curing blindness

since the days of Jesus Christ. And that the man was

claiming that he had done it had at the time a great deal

of significance.

And to find, in fact, no such injury and no

such blindness ever existed had an equally great impact.

Q Now, was there -- when you were sorting these

documents, did you place particular significance on the

difference between whether Mr. Hubbard suffered from a

mental illness after World War II as opposed to a physical

illness from combat wounds which he cured with Dianetics?

A The original way that I perceived it was

the curing of physical things, the blindness, injured

optic nerves, physical thing; lameness, crippled, a

supposedly hopeless cripple. To me, it did not mean an

ulcer. It meant a cripple, a hopeless cripple. It was a

physical thing.

 

 

 

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And that is how I perceived what those

representations were and what they meant to me and what I

read originally when getting into Scientology.

Q Did you read Dianetics, the Modern Science

of Mental Health when you got into Scientology?

A Yes.

Q And what in general was your state of mind

after having read that book in general with regard to

what Dianetics offered in connection with health problems?

A That it offered the -- first of all, the

cure of all psychosomatic problems; that it offered also

the means of speeding up the recovery of any physical

problems and it offered immunization against colds, against

arthritis and that sort of thing.

Q And did you read Dianetics The Modern

Science of Mental Health and understand that Dianetics

could cure arthritis?

A Yes.

Q Did you -- when you became involved in the

Church of Scientology and having read these initial materials

that were published by the organisation of Mr. Hubbard,

did you at any time believe that Mr. Hubbard was mentally

ill after World War II?

A Prior to coming across the materials in the

Hubbard archives?

Q Prior to doing your research, did you believe

at any time that he was mentally or emotionally ill?

A No.

 

 

 

 

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Q And when you saw the last exhibit that was

marked yesterday which was exhibit 500 triple U regarding

Mr. Hubbard"s suicidal inclinations and depression, what

effect did that have on your state of mind with regard

to representations by Mr. Hubbard?

A Well, that, along with other material

contained in the archives, all the material in Mr. Hubbard's

handwriting, indicated to me that the whole picture was

in fact reversed from the way I had perceived it and

that Dianetics was not what in fact he had used to cure

physical. blindess and lameness. And it was not a physical

problem from which he was suffering, but that Dianetics

came out of severe mental problems and that Dianetics,

in fact, was the result of the mental problems, the

mental illness that the man was going through involved in

the war and post-war period.

Q And in your research did you see documents

relating to a diagnosis of Mr. Hubbard's mental illness?

A The only such statement that I recall was

included in the divorce proceedings between Mr. Hubbard

and his second wife, Sarah Northrup. That is the only

actual statement I recall seeing of that nature.

Q Now, you mentioned documents in Mr. Hubbard's

own handwriting with regard to his mental illness; without

going into the contents of the documents, are those the

documents that the court has been reading that are marked

as exhibit 500 triple L through triple --

THE COURT: Quadruple.

 

 

 

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MR. FLYNN: Quadruple D through quadruple G; are

those among the documents?

A Yes. Those particular documents that had a

profound impact on me.

Q Now, before we get to those, what was the

significance of exhibit 500 triple T and why did you send

that to me?

A This is a letter from the Veteran's Admini-

stration that had to do with Mr. Hubbard's claim for a

greater disability percentage.

He was given 10 percent at one point at

the end of the war. And he came back claiming that

there were other things wrong. And he was given a small

percentage for these various things. He kept -- in the

correspondence I was able to determine that he kept

claiming other things and things which did not show up on

medical examination; nevertheless, he was able to increase

his disability from 10 to, I believe 50 percent.

 

 

 

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Q Among the documents that have been marked

as exhibits and that are being marked, did you find many

more documents of this type that are not among the list

of exhibits that we have selected out?

A Yes.

Q And some under seal and some in the possession

of Mr. Hubbard's representatives at the present time?

A Yes.

Q And what is the significance of sending the

exhibit quadruple A, 500 quadruple A in the attached

letter?

A This was a letter in 1949 from the Veterans

of Foreign Wars, National Rehabilitation Service, and it

refers again to Mr. Hubbard's request at that time for

a physical evaluation, and I don't have any further proof

that he was at that point requesting an upgrade of his

then 50 percent disability, but it appears to be connected

to that.

Q And this was in 1949?

A Yes.

Q Four years after or two years after he

claimed that had aospletely cured himself?

MS. DRAGOJEVIC: Your Honor, if I may, I'd like to

be excused for about 15 minutes. I have an appearance.

THE COURT: Oh, certainly.

MS. DRAGOJEVIC: Thank you.

Q BY MR. FLYNN: Why did you send me exhibit

500 quadruple C, Mr. Armstrong? Did that, in general,

 

 

 

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relate to the same subject of his disability?

MR. HARRIS: Objection; leading.

THE WITNESS: Yes.

THE COURT: Oh, it just points his attention to a

certain matter; overruled.

THE WITNESS: It is another letter from Mr. Hubbard

to the Veterans Administration dated August 26, 1947, and

simply shows what he was intending to do at that point,

that he was getting into a school, Los Angeles Conservatory

of Music, or attempting to.

Q And with regard to 500 quadruple B dated

March 18, 1946, directing your attention to the third

paragraph, why did you send me that document?

A This is dated March 18, 1946, and it is

a letter from Mr. Hubbard to the Veterans Administration,

and in here he is again apparently broke and in here he

claims to have lost between 60 and 80 percent of his

vision. This in March 1946, and this was -- the address

is of some significance because this is at 1003 South

Orange Grove Avenue, Pasadena and that was the address of

John W. Parsons who was the then head of the OTO, the

Order of Templars Orientalis, the Crowleyite Black Magic

group. He was the head of the U.S. Lodge, Pasadena Lodge.

That was the headquarters then, and Mr. Hubbard is here

writing to the Veterans Administration saying his vision

is gone, that he is requesting a disability, increase in

the disability, and in later writings he said that he was

sent into this place in Pasadena while he was working for

 

 

 

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Naval intelligence to break up a black magic ring, and

it was simply another contradiction, another basis of

several lies.

Q And does he say that his income was zero

because of service connected injuries?

A Yes.

Q And that is in March of 1946; is that

correct?

A Yes.

Q And did you see other documents where he

claimed to be a Hollywood director at that time?

A Yes.

Q And was that the period where he supposedly

had $10,000 when he went on the Caribbean cruise from

having written "Dive Bomber"?

A Yes.

 

 

 

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Q Now, let me show you a document and I'll ask you,

you collected this document when you were collecting the

archives?

A I believe so.

Q Now, what is the date of that document,

Mr. Armstrong?

A 8-1-51.

Q And what is the document to your knowledge?

A It is a record of a medical examination called

"Special Orthopedic Examination" which was done on Mr, Hubbard.

Q In 1951?

A Apparently.

Q Now, this is approximately one year after Dianetics

was written and six years after -- five years after Mr. Hubbard

claimed to have completely healed himself; is that correct?

A Four years.

Q Four years.

And what is the nature of -- did you find

misrepresentations in that document?

A Yes.

Q And what did you find?

A Within the examining person's record of the

history, which apparently is an account of what Mr. Hubbard

gave to him, was a number of misstatements of fact,

misrepresentations.

Q What are they?

A A long history of three years of sea duty.

Q Did you find that to be false?

 

 

 

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A Yes.

Q What else?

A His first assignment in 1942 being with a merchant

ship which was assigned to transporting troops. That may

be the truth, but that is not how he later represented his

first assignment.

Q And with regard to spending over a year of his

service in hospitals in the latter period, how long did

Mr. Hubbard spend in the Oak Knoll Hospital?

A He was an outpatient during a great deal of that

time, from April through September, 1945.

Q And what was the nature of his illness during

that period?

A Duodenal ulcers and conjunctivitis, I believe.

Q Does he talk about falling down a ladder and

striking his hip in 1942 on board a ship?

A Yes.

Q And injuring his right shoulder.

A Yes.

Q And at that time do the records show a diagnosis

of multiple arthritis?

MR. LITT: At what time?

MR. FLYNN: The records that are being referred to in

1951.

THE WITNESS: Yes.

Q BY MR. FLYNN: And that there was no clinical

evidence of arthritis found at that time; is that correct?

A Yes.

 

 

 

 

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Q Now, was Mr. Hubbard seeking a disability at that

time?

A Yes.

Q And with regard to the claim that he fell down

and struck his hip on board a ship and the claim that his

eyes were bad from injuries suffered in World War II, when

you looked at exhibits 500 triple 4D through 500 triple 4G,

did you find references in connection with Mr. Hubbard using

those claims to avoid service?

A Yes.

Q And did you find references to Mr. Hubbard using

those claims to get a Veterans Administration disability?

A Yes.

 

 

 

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Q And did you find Mr. Hubbard using those claims

where he admitted to himself that the claims were false?

A Yes.

Q And did you find fn those exhibits an

area --

MR. LITT: Objection, Your Honor. Before we go

any further we would ask that we go in camera on the

record and we argue this matter fully.

Mr. Flynn's purported failure to refer

to contents is not only distorted but is referring to

contents. We would like the opportunity to argue this

matter fully and we want to be able to argue where we

feel we can argue it without the constraints of this

matter being argued in a public hearing, and what is

being argued is whether it can be gone into.

MR. FLYNN: Your Honor, what I am trying to do is

being restrictive.

Now, if Mr. Litt is willing to allow to go

into evidence --

MR. LITT: I am not willing.

MR. FLYNN: -- that small portion which we can

read into the record of those records relating to the

area of examination that I just covered, which I think is

much more descriptive than my questions with regard to

Mr. Hubbard's hip problem, eye probism,.going into the

Veterans Administration examination for the reasons that

are clearly set forth in there and with specific reference

to the word "laugh"; then restricting the use of those

 

 

 

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documents at this time to just that narrow portion

which does not cover some of the other areas that are in

those documents, I submit, is the foundation to show why

Mr. Armstrong sent me those materials.

THE COURT: Well it seems to me -- first, did you

want this marked as an exhibit?

MR. FLYNN: Please, Your Honor.

THE COURT: What are we up to, Rosie?

THE CLERK: Double Y.

THE COURT: YY. Mark it YY for identification.

What was the source of this double Y, do

you know, Mr. Armstrong?

THE WITNESS: Your Honor, I am not sure where this

one came from. Within the Hubbard archives are a number

of documents like this and my best recollection is that

this also is included in the materials which came from

the Del Sol materials, what I call the Naval records

went through 1941 up into the 1950's.

MR. FLYNN: I have this, Your Honor, from a

separate source and this has been on file with the City

of Clearwater since at least September 1981. In other

words, it may be among the Del Sol records, but I also

have it among records that my office collected prior to

Mr. Armstrong coming to see me.

MR. HARRIS: I get confused when Mr. Flynn represents

to the court that he's had items in his files which the

witness is also talking about which aren't under seal.

This particular item comes from your files,

 

 

 

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Mr. Flynn; double Y?

MR. FLYNN: That is correct, Mr. Harris, along

with some 10,000 pages of similar type documents.

THE COURT: We don't need all 9,999.

MR. HARRIS: I hope not.

THE COURT: I have read through these documents,

and without Mr. Hubbard being here to explain it to us,

it is not entirely clear in my mind what the purpose

of these documents were, and I am sure that nobody here

can give any first-hand evidence on that because only

Mr. Hubbard could tell us that, and he chooses not to

appear although he is seeking -- I won't say that.

I gather these are among the documents that

Mrs. Hubbard made some references to as being either personal

or very personal. I didn't have it correlated with that

exhibit.

MR. LITT: Yes, those are the documents that

Mrs. Hubbard listed as extremely personal.

THE COURT: I have a little trouble in here stating

that they are extremely personal to her. They might be

extremely personal to him.

MR. LITT: The notations that she made, her position

is that with respect to the privacy of either herself or

her husband, that both from the point of view of the claim

for equitable relief and from the point of view of the

intrusion that occurred, she can make that claim. The

court can ultimately sort that out however the court

chooses.

 

 

 

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She does not claim that that particular

document is one. She has never read that document until

I asked her about it. I am still not sure whether she's

read it. It is not a document that she is personally

familiar with. I described it to her sufficiently so

that she could give it a designation, but it is clearly

a very personal document, regardless of whether it is

personal to her or personal to Mr. Hubbard. But I did

want to clarify just the nature of the list that she made.

THE COURT: Well, frankly it seems to me that the

very limited inquiry that Mr. Flynn is suggesting, I don't

have any problem with that. It really doesn't go into the

matters which I would consider to be rather personal and

rather ambiguous in the manner in which they were expressed.

There are a lot of -- I don't know whether this was

intended to be some sort of positive reinforcement-type

program that he was engaging in to build up feelings of

inadequacy that he might have had or maybe true expressions

of his philosophy or just what. I am not really sure,

but it seems to me he does make some statements with

reference to these particular matters, and it is very

limited. What Mr. Flynn has suggested at this point,

I don't have any problem with that.

 

 

 

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MR. LITT: Your Honor, the problem is if we could --

I would like to argue this further, but I really feel

constrained in being able to express myself in open court

when the issue is to what extent this matter can be gone into.

THE COURT: Well, he has got a problem in the sense

that he is trying to explain why he delivered these papers

to his attorney, why he felt they were important.

If you don't want anything referred to, the only

thing I can conclude is the fact that they were there, the

fact that they were shipped; there is no issue to it; that

he has a privilege under the law. If you don't want to go

into it, I assume I would have to draw that conclusion.

MR. LITT: I'm asking that the court, under Evidence

Code 352, the Court has reviewed the materials; the materials,

as the Court has indicated, cannot reasonably be construed

to mean one thing or another.

So what I'm asking is that in light of that fact,

because you cannot reasonably know whether they constitute

factual statements by Mr. Hubbard or not, that the Court

exercise its discretion under 352 to rule that Mr. Armstrong

cannot go into that; not because he has a privilege but

because any construction that he attempts to give that these

are factual statements is not a reasonable construction of

the documents.

THE COURT: Well, his counsel has indicated a very

limited use of these documents for a very limited purpose.

The fact that that, for example, if I were to permit him to

go into that at this time won't mean that I am admitting these

 

 

 

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documents into evidence in this lawsuit; in fact, it would

be my position at this point that he could refer to those

specific points without the exhibits being received in

evidence; just to read into the record those precise points

that he wants to develop and support for his transmitting

these to Mr. Flynn.

MR. LITT: May we have a moment, Your Honor?

THE COURT: Yes.

MR. LITT: Your Honor, in addition, we would point out

to the court that under 352 Mr. Armstrong has gone on at great

length about the various documents and sending documents for

purposes of showing something about Mr. Hubbard's medical

records and whether things are accurate or not accurate.

And we would also just point out to the Court that we think

it is cumulative under 352. But I'm not sure what prodecure

the Court is suggesting at this point; that Mr. Armstrong

point to specific portions of the documents?

THE COURT: I think he has indicated certain things

he wants to develop with reference to what is apparently in

this exhibit YY; plus what may be some of these other matters

refer to in some of these other exhibits and then have the

witness identify specific portions and then read that into

the record, those specific portions.

Certainly, before he reads it into the record,

you have an opportunity yourself to check it. I assume these

aren't the only copies we have of these particular documents.

If there is an objection, I'll deal with it at

that point.

 

 

 

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MR. LITT: Yes, Your Honor, we have a copy.

MR. FLYNN: I'll show him the very narrow portion out

of all of these in this area of inquiry that we wish to put

on the record.

MR. LITT: What are we talking about? Is the Court --

Mr. Flynn has argued that this is foundational

for them going into this document further.

THE COURT: No. He may have said that at some time

in the past, but he just said at this point that he has these

things he wants to develop; that was the only purpose he

wanted to use these for at this particular time.

Is that correct, Mr. Flynn?

MR. FLYNN: That is correct, Your Honor.

What I intend to do, so Mr. Litt and the Court

will know, as the Court knows, there are areas of these

documents which are sensitive. There are other areas of the

documents which relate to a great deal of public information

about Mr. Hubbard.

The narrow purpose of the public information that

I am using them for now is with respect to this area that

I have just developed. And there are probably eight or

nine lines.

I don't intend at any time to use what could be

described as the most sensitive areas; even though I feel

that those are the areas that are probably most -- the public

would -- particularly Scientologists who have paid money

would be most interested in knowing about. But I don't

intend to use those. I intend to limit the examination at

 

 

 

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this point to the narrow issues with regard to the hip, the

eyesight, the excuses and the reasons why Mr. Hubbard made

all of these claims to the Veterans Administration. And there

are about eight or nine lines that go line by line and cover

the whole area.

 

 

 

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THE COURT: Well I think that as long as you are

limiting it to those particular areas I will permit you

to do so as long as you identify it for Mr. Litt first so

he will have a chance to see it before anything is actually

done.

Take the whole collection, Mr. Armstrong.

I suppose preliminarily exhibits there appear

to be in Mr. Armstrong's handwriting; is that correct,

the ones that are in handwriting as distinguished from

typewritten?

MR. FLYNN: These are Mr. Hubbard's handwriting?

THE COURT: Yes, Mr. Hubbard's handwriting, do

they appear to be in Mr. Hubbard's handwriting?

THE WITNESS: Yes, they are, Your Honor.

THE COURT: Why don't we take a 10-minute recess

while you are locating what you want to locate.

MR. FLYNN: Thank you, Your Honor.

THE COURT: Then maybe you could show them to

Mr. Litt before we get started.

(Recess.)

THE COURT: All right, in the case on trial, let

the record reflect that counsel are present.

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: All right, you may continue.

MR. FLYNN: Thank you, Your Honor.

 

 

 

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Q Mr. Armstrong, just yes or no, before you

read those portions were there other areas of exhibit

quadruple 4-D through 4-G other than what you are about

to read?

 

 

 

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THE COURT: You don't mean "quadruple 4"; do you? That

is sort of redundant.

Go ahead with your question.

Q BY MR. FLYNN: 500 quadruple D through 500

quadruple G which you found of much greater significance other

than what you are going to read and was that one of the

primary reasons that you sent me these documents, the area

of greater significance?

A Yes.

Q Now, would you read the portion relating to

Mr. Hubbard's Naval background and Veterans Administration

background that we have selected.

THE COURT: Let's first identify the exhibit that you

are referring to.

MR. FLYNN: It is exhibit 500 quadruple D, for the

record. And it is a handwritten note of Mr. Hubbard's with

no number on the page.

THE COURT: All right.

MR. LITT: Is that the document that has at the

beginning "course two"?

MR. FLYNN: Correct.

THE WITNESS: (reading:)

"Your stomach trouble" --

MR. LITT: Obviously, we object to any reading. I just

wanted to make it clear for the record.

THE COURT: I'll deem it that you are objecting to each

of these.

Overruled so long as Mr. Flynn is continuing the

 

 

 

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line of what he has already told me he is going to do.

MR. FLYNN: I am limiting it to that. And I have shown

it to Mr. Litt.

THE WITNESS: (Reading:)

"Your stomach trouble you used as

an excuse to keep the Navy from punishing you.

You are free of the Navy. You have no further

reason to have a weak stomach.

"Your ulcers are all well and never

bother you. You can eat anything.

"Your hip is a pose. You have a

sound hip. It never hurts.

"Your shoulder never hurts.

"Your foot was an alibi. The

injury is no longer needed. It is well. You

have perfect and lovely feet.

"Your sinus trouble is nothing. It

is not dangerous. It will vanish. The common

cold amuses you. You are protected from further

illness. Your cat fever has vanished forever

and will never return. You do not have malaria.

"When you tell people you are ill,

it has no effect upon your health. And in

Veterans Administration examinations you'll tell

them how sick you are; you'll look sick when

you take it; you'll return to health one hour

after the examination and laugh at them.

"No matter what lies you may tell

 

 

 

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others, they have no physical effect on you of

any kind. You never injure your health by

saying it is bad. You cannot lie to yourself."

 

 

 

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Q On the exhibit 500 quadruple E page 18,

subparagraph (g) --

MR. LITT: Your Honor, before that occurs,

Mr. Flynn has chosen out a series -- what is a subsection

(g) --

THE COURT: May I see it?

MR. LITT: -- from this document and at the top

of the previous page are the words "by hypnosis I must be

convinced as follows:" and then there are a series of

subsection (a), (b) at cetera from which Mr. Flynn wishes

to read subsection (g).

MR. FLYNN: I'd be happy to have the whole document

go into evidence.

MR. LITT: No, no, no. The words "by hypnosis" --

THE COURT: If you want that read, it may be read.

"By hypnosis I must be convinced as follows:" and then

skip to subparagraph (g).

MR. LITT: Yes.

THE COURT: The court will deem that the witness

has read what I have just read to avoid repetition.

THE WITNESS: This is (g), "That my eyes (which I

used as an excuse to get out of school) are perfect and do

not pain me ever."

Q BY MR. FLYNN: How, were you able to date,

Mr. Armstrong, when these documents were written by

Mr. Hubbard?

THE COURT: Well I think you should ask him if he

formed an opinion as to the time when these were prepared.

 

 

 

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He can't date them as a matter of personal knowledge.

He may have an opinion based upon his work with him.

Q BY Mr. FLYNN : Do you have an opinion,

Mr. Armstrong?

A Yes.

Q And what is that?

A In the period of 1946-1947.

Q And how did you arrive at that point?

THE COURT: Without going into the details of anything

that is set forth therein.

THE WITNESS: Yes. Because of the mentions of

what is occurring in his life at that time and the names

of people referred to, specifically Jack Parsons who was

John W. Parsons and Sarah, his second wife.

Q BY MR. FLYNN: Now, were those writings made

by Mr. Hubbard particularly with respect to lying on the

Veterans Administration examination prior to subsequent

histories given by Mr. Hubbard about his medical problems?

A Yes.

Q And how did that affect your state of mind

with respect to Mr. Hubbard's representations that he

couldn't lie to anyone without affecting his health and

then he lied in the future in subsequent Veterans

Administration exams?

MR. LITT: Objection; leading and conclusionary.

MR. HARRIS: And compound.

THE COURT: Well, it asked him, I suppose, how

it affected him. I don't think that is particuarly leading.

 

 

 

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MR. LITT: No, the statement that they are lies.

THE COURT: There has already been -- the witness

has formed some opinions upon the subject, I suppose.

If you understand the question, you may

answer it. If you don't, you can so state.

THE WITNESS: Okay, Your Honor.

When I read these and tied it in with

everything that I read up to that point, I was shocked.

At that point I began to perceive lies in much of the

materials. It became apparent to me that these things

were not just contradictions which I had been perceiving

which would be explained at some later time, but the

fact was the man had methodically lied. He had lied from

his earliest youth all the way through and he was lying

to me currently.

 

 

 

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And I was kept in the organization by a web of

lies, And I was appalled.

I set off on a campaign throughout 1981 to try

and rectify the lies and get the organization honest about

him and get him honest. And it just -- didn't work out.

Q How, did you perceive those lies right up to the

Dive Bomber letter of Mr. Hubbard in 1980?

THE COURT: Well, that is an ambiguous question.

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

Q What, if any, effect did those documents have

on you, Mr. Arwstrong, with regard to the intention of

Mr. Hubbard to methodically lie in the future after 1946?

A Well, I knew that at that point his stories given

to different people at different times were different. And

he was opportunistic and lied according to what he thought

the situation demanded. And he appeared to lie with what

he thought was impunity.

Q Now, do the words "intention' and "counter-

intention" in Scientology have particular significance?

A Yes.

Q And what is that?

A Well, intentions are something which in the

auditing process have a great deal of significance. And a

person is audited on his or her intentions regarding various

subjects. So it has that significance.

And there is also the organizational intention;

what is intended by Mr. Hubbard. There is something referred

to often as source intention, what was the source intention

 

 

 

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of a particular subject; Hubbard was the source. And anything

which ran counter to that was something called counter-

intention, counter-intention to any of Mr. Hubbard's plans,

projects, ideas; any questioning of anything that the man

had ever said was deemed CI, big C, big I, counter-intention.

It was something which was dealt with very severely; people

were PRF'd; sent away to the Scientology prison for counter-

intention.

Q In your experience had Mr. Hubbard written quite

a bit on what insanity was?

A Yes.

Q And did insanity have to do with the ability to

perceive time, place, form, and event, truth?

A Yes.

Q And did you correlate at all Mr. Hubbard's writings

with regard to insanity to his own inability to perceive time,

place, form, and event?

A Yes. There has -- since I set out on this project

or since probably the beginning of 1981 there has been an

increasing awareness of his inability to perceive time, place,

form, and event; of his inability to perceive the truth and

of his compulsion to lie to everyone, followers, courts,

everyone.

Q And when you joined Scientology did you understand

the pursuit of truth to be the foundation of Scientology?

A Yes.

Q Now, directing your attention to exhibit 500

quadruple K, why did you send that to me, Mr. Armstrong?

 

 

 

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A This is a document entitled "The Blood Ritual."

And it is a ritual -- it is a magical rite which

was -- which Mr. Hubbard has written. And it invokes the

powers of various, I believe, Egyptian gods. And it concerns

a ceremony that he and his second wife Sarah went through.

 

 

 

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The significance that this had to me is that

Mr. Hubbard claimed that he had broken up a black magic

ring. This was the black magic ring of the OTO in Pasadena,

California, and this just added to the preponderance of

evidence that showed conclusively that the man was not

working for Naval intelligence, did not break up the

black magic ring, but was himself involved in Crowleyite

Black Magic.

Q And that is in L. Ron Hubbard's handwriting?

A Yes.

Q And did you form an opinion as to the

approximate date that that was written?

A Yes.

Q And when was that?

A 1946.

Q And that was during the period when

Mr. Hubbard claimed he was blind?

A Yes.

Q Now when you were doing the biography project,

you testified that you met with L. Ron Hubbard, Junior;

is that correct?

A Yes.

Q And just yes or no, did L. Ron Hubbard, Junior

describe at length to you situations his father was involved

in between 1946 and 1950?

A Not during the time when I was working

directly on the biography project.

I visited him, along with Mr. Garrison, in

 

 

 

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November 1981 up in Carson City, Nevada, and at that time

he would not talk very much about anything. I had by

that time received four chapters of a book which he was

writing or had written, and I received a great deal of

information on the subject at that time, but that was

really the only contact or the only information I had from

L. Ron Hubbard, Junior up to that time.

Q You did learn, however, from documents,

particularly a time track on L. Ron Hubbard, Junior that

the organization had engaged in many operations against him;

is that correct?

A Well, I knew that they had assembled a very

massive chronology of documentation about him. I knew

at the time that I went to visit him of an operation.

I do not know the extent of the operations against him.

Q Did any part of your research into the

period from 1946 to 1950 confirm the truth of some of the

things that Mr. De Wolfe was saying?.

MR. LITT: What --

MR. HARRIS: Assumes facts not in evidence.

Q BY MR. FLYNN: Well, with regard specifically

to Mr. Hubbard's involvement in the OTO.

MR. LITT: I still don't understand the question.

There's been no question that Mr. Armstrong ever learned

anything from L. Ron Hubbard, Junior, whose name is

Ronald De Wolfe as I understand it today. He changed it.

THE COURT: Well, there is no need to get off on

the sidetrack whether he changed or didn't change it.

 

 

 

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MR. LITT: His name is presently Ronald De Wolfe.

It is not L. Ron Hubbard, Junior. But my point is there's

been no testimony that he told him anything, so how can

Mr. Flynn be asking him a question about corroborating

anything he told him.

MR. FLYNN: I will back up.

THE COURT: Okay, let's back up.

Q BY MR. FLYNN: Mr. Armstrong, did you write

in your letter to Cirrus Slevin that you thought that the

organization and Mr. Hubbard had treated Ronald De Wolfe,

formerly L. Ron Hubbard, Junior badly?

A Yes.

Q And dishonestly?

A Yes.

Q And you found in your research the time track

on L. Ron Hubbard, Junior; is that correct?

A Yes.

Q What is a time track?

A A time track is a consecutive record of

events.

Q And at some point in time did you have

a conversation with L. Ron Hubbard, Junior, Ronald De Wolfe,

about Mr. Hubbard's involvement in black magic and the OTO?

A Yes.

 

 

 

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Q And did the documents that you found confirm the

truth of what Mr. DeWolfe had said about Mr. Hubbard's

involvement in black magic and the OTO?

MR. LITT: Objection.

THE COURT: I'll sustain the objection. It obviously

gets into --

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

Q Why did you send me exhibit 500 quadruple M?

A This is a record of the divorce proceedings

between L. Ron Hubbard and Sarah Northrup. And I sent it

to you because it -- I believe the vast majority of it is

a matter of public record, but it had a lot of significance

to me because of the statements made in the record regarding

Mr. Hubbard's mental state.

Q Did you later understand that I had most of those

documents, Mr. Armstrong?

A Yes.

Q And are there any documents of particular

significance in these divorce proceedings relating to Alexis

that you recall?

A I believe that there is an award, something --

I don't -- my recollection is that there is a reference to

Alexis as Mr. Hubbard's son, an award of some monthly amount

that Mr. Hubbard was supposed to pay.

Q Now, did you find documents in L. Ron Hubbard's

handwriting relating to the fact that he was the father of

Alexis? Did he send a letter from Cuba at some point?

A Yes. There is a letter from Cuba. I'm trying

 

 

 

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to think.

There has been a dispute about the authorship

of that letter. There were definitely communications from

that period. 1951, 1952, 1953 in which there are references

to Alexis as Mr. Hubbard's daughter, his statement that she

was his daughter at that time.

Q Now, was this of particular significance to you

in terms of your relationship with the organization, leaving

the organization and later on sending these materials to me,

the situation involving Alexis and Sarah?

MR. LITT: I object to the "this."

Mr. Armstrong testified to one letter which he

said is of disputed authorship and then is asked, apparently,

whether the contents of this letter were of great significance

when it is of disputed authorship.

THE COURT: I'm not sure I understand what you are

referring to.

Are you referring to this collection of documents

which is an exhibit here?

MR. FLYNN: I am, Your Honor. I believe I clarified

it at the end of my question.

THE COURT: We're not talking about some other letter

that may or may not have been written by Mr. Hubbard, but

this particular group of documents.

Q BY MR. FLYNN: Were there two binders relating

to divorce proceedings involving Sarah Northrup and other

materials relating to Alexis that you sent to me,

Mr. Armstrong?

 

 

 

1938

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A Yes.

MR. FLYNN: As a matter of fact, we have skipped over

four L which was the one prior to that.

MR. LITT: I believe that file has already been marked,

Your Honor. Well, I'm not sure.

Q BY MR. FLYNN: Now, let's start here,

Mr. Armstrong.

Directing your attention to four L, we had

previously for the record referred to quadruple M; now,

directing your attention to quadruple L, which comes before,

first, when you found materials relating to Alexis Hollister

and Sarah Northrup, did those materials have particular

significance to you in the biography project?

A Yes.

Q And why is that?

A Well, Sarah Northrup was, obviously, his wife.

He had been involved with Sarah from 1945 through, at least,

1951.

They had gone through a pretty turbulent divorce;

she was around in the beginning of all of the Dianetics and

Scientology organizations. She was an important part.

I had also seen the allegations made by Mr. Hubbard

that she was part of SMERSH; that she was a Soviet spy; that

she was sent in to break up the Dianetics foundation.

 

 

 

1939

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I had seen these claims.

Q This was during the origin of Dianetics that

he was married to Sarah; is that correct?

A Right.

Q When did he marry Sarah?

A 1946.

Q Do you recall when?

A I don't recall the date. There is a marriage

certificate, I believe, right here.

Q Was it in July in Chestertown, Maryland?

A I see 10 August.

Q And where was it?

A Chestertown, Maryland.

Q Now at that time was he married to Louise Grubb

Hubbard?

A Yes.

Q And when did he divorce Louise Grubb Hubbard?

A Some time in 1947.

Q So now, would you continue. What was the

significance of the Sarah-Alexis situation with regard

to the documents that you found during the biography project?

A Alexis tied in because she was Sarah's

daughter. I knew that she was Sarah's daughter. I was not--

I had seen in a PR briefing that she was not Hubbard's

daughter.

At the same time I saw somewhere one of the

early books, I believe "Science of Survival" one of the

very earliest books was first dedicated to Alexis Valerie

 

 

 

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Hubbard, so I had some contradictions early on when I

began to get into it, and I also interviewed several family

members from Mr. Hubbard's family. These were cousins, an

aunt and so on and discussed Sarah and Alexis with them.

Some time after that from the LRH Pers Sec

US files I obtained this pack of materials on Alexis.

Q That is exhibit quadruple L for the record?

A Yes, and it had a great deal of significance

to me. It had a great deal of significance to Omar Garrison.

Q And why is that?

A It was in the man's life, really, I think,

an incredible set of events in which the daughter, after

not seeing her father, the person she believed for 20

years was her father, wrote to him in 1971, I believe it

was. Tried to get a communication to him.

The communication was received from the

Guardian's office or received by the Guardian's office.

They derailed it, took it, and they wrote to --

Jane Kember, the head of the Guardian's office, wrote to

L. Ron Hubbard because she viewed this as a threat.

The only thing was it was a daughter trying

to get in touch with her father, and L. Ron Hubbard's

method of handling what the Guardian's office and he

perceived as a threat was quite remarkable, and even his--

well, he had the Guardian's office write a letter on a non-

general-use typewriter. That had particular significance

to me because I knew that that was the Guardian's office

practice regarding the writing of letters which were to

 

 

 

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be used for a clandestine, secret purpose, some operation

of some sort. They would write one letter on one typewriter

and then get rid of the typewriter so that it was never

used for another reason, so the type faces could never be

matched up, and so that the source of these kinds of

letters could never be traced. That is what a non-qeneral-

use typewriter was. That is the only reason L. Ron Hubbard

would have said it, and then the letter was to/be read to

the girl. It was not to/be given to the girl, and it was

just the most appalling letter.

She was -- L. Ron Hubbard came off like a

shining knight and her mother, who had been taking care

of her through her whole life, came off like a total tramp,

and then he ended up this classic document with a note to

Jane Kember that "decency is a subject not well understood."

I can vouch for that. I can't think of many

more indecent acts than the one he pulled on the girl

that I conclude is his daughter.

Q And was she conceived during the marriage of

L. Ron Hubbard to Sarah Northrup?

A Yes.

MR. LITT: Is this being stated as a fact now?

Q BY MR. FLYNN: Well, among the records in

exhibit 4-L and quarduple M, were you able to ascertain

in your opinion whether or not she was conceived during

the marriage of L. Ron Hubbard and Sarah Northrup?

A Yes.

THE COURT: Well, it might be more appropriate if

 

 

 

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he had some date when she was born and some date of divorce,

and people are free to draw their own conclusions.

Q BY MR. FLYNN: Can you find a document in

here, Mr. Armstrong, which relates to her birth?

Incidentally, while you are looking for

that are the handwritten instructions of L. Ron Hubbard

regarding what to do in connection with Alexis part of

exhibit quadruple L?

A Yes.

 

 

 

 

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Q With the reference, "This is to be typed on a

non-general use typewriter"?

A Yes.

There is a note here -- this is a complaint for

a divorce which was filed April 23rd, 1951 in this court.

And there is a note here on the second page that plaintiff

and Sarah Hubbard ever since the 10th day of August have

lived together as husband and wife and on the 8th day of March,

1950, have had a child born to them, Alexis."

Q On the 8th day of March, 1950 Alexis was born?

A Yes.

Q And what color hair did Ron Hubbard have?

A Red.

Q Do you know what color hair Alexis has?

A Red.

Q Now, with reference to exhibit quadruple M, what

reason did you send that binder to me in connection with the

allegations made by Sarah that she had been tortured by

L. Ron Hubbard?

MR. HARRIS: Wait a minute.

The question, Your Honor, calls for a conclusion

and assumes a fact not in evidence; to wit, that it was sent

for that purpose.

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

Q Directing your attention to an area of exhibit

quadruple M, did you find documents in there that you sent

to me, Mr. Armstrong, which related to allegations made by

Sarah as to what L. Ron Hubbard had done to her?

 

 

 

1944

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A Yes.

Q And is that the reason you sent to me those

documents?

A Among other reasons that I have stated.

Q Now, the letter that you mentioned that was sent

from Cuba, is that in exhibit quadruple M? Do you know?

A Yes, it is. At least part -- I believe it is

all there.

Q And when you say the authorship is disputed, what

facts did you learn as to whether L. Ron Hubbard had written

or not written that letter?

A Well, I interviewed a man by the name of Richard

DeMille, son of Cecil B. DeMille, the foster son. And he

was with Hubbard at that time in 1951 in Cuba. And he said

that he did not recall that letter, but that it was very

likely that Hubbard would have written it because it was the

way he was at the time.

The organization had sent out some people to --

they had that particular letter checked by a handwriting

expert and then they, apparently, were trying to get the

attorney for Sarah Northrup, a man by the name of Caryl Warner,

to admit to a forgery of the letter, something to that effect.

There is also information on that incident that

this was in, at least, the mid-'70's when this thing was still

going on, they were still trying to prove the 1951 letter

that Sarah had claimed was a forgery. And I had seen other

correspondence in the Hubbard archives by Mr. Hubbard which

indicated that the handwriting on that particular letter was

 

 

 

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very much like what his handwriting was like in other periods.

He claimed in that letter that his right side

was paralyzed. And this was not an unusual sort of claim

for Mr. Hubbard to be making.

And that would also be attributable to the

difference in the handwriting between what was his normal

handwriting and what the handwriting was like in this letter.

I think the organization was in error in trying

to disprove that fact. I am fairly sure that the letter was

from Mr. Hubbard.

MR. HARRIS: Excuse me, Your Honor. If the witness

could be directed to state his opinion rather than going into

expertise in handwriting examinations and the like which

clearly doesn't have or, at least, it hasn't been

established --

THE COURT: Well, I think the witness is, obviously,

qualified as an expert upon many matters relating to

Mr. Hubbard's life. And I think he is entitled to express

opinions. They should be couched as such, however. At least

if he states something, we'll treat it as an expression of

opinion based upon that.

MR. HARRIS: Very well.

 

 

 

1946

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Q BY MR. FLYNN: Mr. Armstrong, with regard to

the letter that was to be shown to Alexis on the

instructions of L. Ron Hubbard, did you find representations

in that letter of Mr. Hubbard that were inaccurate?

A Yes.

Q And what were those?

A This is in the letter to Alexis?

Q Correct.

A Okay. He stated to his daughter that,

"Your mother was with me as a secretary in Savannah in late

1948."

Q And was she, in fact, his wife then?

A Yes. He writes here, "In July 1949 I was

in Elizabeth, New Jersey writing a movie. She turned up

destitute and pregnant. I do not know who she was living

with in Pasadena, but she was closely associated with

Jack Parsons."

I don't recall the date when she was born in

1950, but I believe she showed up in July 1949 and stayed

with him thereafter. It is Mr. Hubbard's child.

Q And on what basis do you believe that,

Mr. Armstrong?

A When the daughter was born.

Q You mean based on the date of birth of Alexis?

A Right.

Q This thing about, "I came up to Palm Springs,

California" -- "I came up from Palm Springs, California

where I was living and found you abandoned ... "

 

 

 

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Well actually what happened was I interviewed

the person who was with him at that time by the name of

Frank Dessler, and he and Frank Dessler took the child

and ran off and there was a kidnapping allegation at that

point in the newspapers.

Q Against Mr. Hubbard?

A Yes.

Q He had taken Alexis away from Sarah and run

off with her?

A Yes, went ultimately to Havana, Cuba.

Q And was he in Havana, Cuba with Alexis?

A Yes.

He claims that there was --

Q This is all in his handwriting; is that

correct?

A Yes. Here he claims that there was no --

her mother and Hollister, who she later married, he said,

"They obtained considerable newspaper. publicity, none of

it true, and employed the highest priced divorce attorney

in the U.S. to sue me for divorce and get the foundation

in Los Angeles in settlement. This proved a puzzle since

where there is no legal marriage, there can't be any

divorce."

And that was not the way it was at all. I

suppose if he meant if it was a bigamous marriage, that

was true. But, in fact, there was a marriage.

Q And there was a divorce?

A Yes. It just is a perversion of -- and

 

 

 

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there is no willingness on his part to admit any responsibility

for anything.

Q Now in your years in Scientology had you

seen a great deal of writings by L. Ron Hubbard on

marriage and fidelity and the care of children?

A Yes.

Q And were you aware when you were doing the

biography project of the manner in which L. Ron Hubbard

had treated Alexis, his daughter, and L. Ron Hubbard, Jr.,

his oldest son?

A During which period?

Q When you were doing the biography project.

A Yes.

Q And did you send me the materials relating

to Alexis in part for those reasons?

A Yes.

Q And did you feel that the -- what if anything

did you feel with regard to the representations made by

Mr. Hubbard about marriage and fidelity bore any relationship

to the truth of his life?

A I think again that he was opportunistic.

He was mad on the subject. He split up marriages. He

kept people who were married apart from each other.

 

 

 

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He took out his own frustrations on all

of his followers.

Q Do you feel he played a role in splitting up your

marriage to your first wife?

A My first wife was -- she told me that she was

ordered that she could not be in the CMO -- that is the

Commodore's Messengers, Hubbard's organization -- if she was

married to me; as a result of that, there was a divorce.

There was no attempt by Hubbard or the organization or the

CMO or anyone to apply any of what they called the technology

to keep that marriage together. It was simply decided by

Hubbard or the CMO that we were to be split up and that was

it.

MR. LITT: This is all his opinion?

THE COURT: Yes; it is his opinion.

Q BY MR. FLYNN: Was that your marriage to Terry

Gamboa?

A Yes.

Q Do you know where Terry Gamboa currently works?

MR. HARRIS: Asked and answered about three times, Your

Honor.

THE COURT: What point in time are you asking about?

BY MR. FLYNN: At this time, Mr. Armstrong, where

does she work?

A As of two months ago, I knew she was working in

Author Services Incorporated.

Q To your knowledge, what is Author Services?

MR. LITT: We have been through all of this, Your Honor.

 

 

 

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THE COURT: I'll sustain the objection.

Q BY MR. FLYNN: Why did you send me exhibit 500

quadruple O, Mr. Armstrong?

I think I have got a little bit ahead of myself.

Let me withdraw that for the time being and go back to 500

quadruple J, "L. Ron Hubbard and J.W. Parsons"; why did you

send me that?

A Inside the organization I had come across what

were called entheta newspaper articles dealing with or claiming

that Hubbard was connected with the OTO, the black magic

group.

Hubbard -- I had seen at that point a statement

which had been published in the -- I think it is the London

Sun Times which appeared to be a statement from the

organization refuting the original claim of a black magic

connection. And this was part of a pack of materials which

I had while in the port captain's office dealing with

Mr. Hubbard. And it was to be used as proof that Mr. Hubbard

was not connected to the black magic group, but in fact had

been working for Naval intelligence and had been sent in to

break it up because of the number of atomic scientists who

were connected to the group, which he did. And he rescued

a girl.

Throughout the course of the biography research

I found that Mr. Hubbard was not working for Naval

intelligence; was, in fact, connected to the OTO, the magic

group, and that the head of the group was John W. Parsons

who Mr. Hubbard was very much connected to.

 

 

 

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This pack concerns John W. Parsons and Allied

Enterprises. And Allied Enterprises is a company which

Mr. Hubbard, Sarah Northrup, and John W. Parsons formed in,

I believe, 1946.

Q And what was the purpose for the company?

A It was a profit-making company, but -- they

planned at one point to bring sailing vessels from the East

Coast to the West Coast and sell them at a profit on the

West Coast.

 

 

 

1952

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Q And how much money did Mr. Parsons put into

the project?

A I recall $10,000, but I don't -- I don't --

it is in this pack of materials, and I would have to

refresh my memory.

Q And how much money did Mr. Hubbard put into

it?

A I don't know if he put any in. I do recall

a figure of a thousand dollars, and I don't know if that

is from Sarah or from Mr. Hubbard.

Q Now at that point in time was Sarah Jack Parson's

girl friend?

A I -- here is what I know of that. I

interviewed a man named Lou Goldstone in San Francisco.

This would have been in the summer of 1980 and he had

been living at that time in the same place, John W. Parsons'

home in Pasadena. It was a very big home and he stayed

there, and he said that Sarah, who they then called Betty,

was Parsons' girl friend, and that Hubbard arrived in

December of 1945, and within a short time had taken Sarah

from Parsons and was living with her first in the house

and then in a trailer which was also parked on the property.

Hubbard then had a big trailer.

I also know the same story from another man

that I interviewed who was a current/head of the OTO in

California, a man by the name of Grady McMurtry, and he

had the same set of facts.

Q Did Mr. Parsons sue L. Ron Hubbard?

 

 

 

1953

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A Yes.

Q And is that lawsuit among the materials in

that pack?

A Yes.

Q And why did you send me that?

A Well again it tied into this story of

Mr. Hubbard's involvement with black magic. The significance

that this whole thing had to me was not so much his

involvement with the black magic, but it had to do with

the fact that he lied about his involvement and I had

been trained and drilled to lie about it, and that was

the significance. I really couldn't care if he was --

what he had done, but the fact that he had just continually

lied was what was important to me and this was a part of

the picture which showed that the story he had written and

he had, in fact, authored the London Sunday Times article,

I had the printed article, and I had the same thing in

his handwriting.

Q You had his handwritten notes that contained

the precise article?

A Yes, and the instructions in which he sent

it to be typed up and submitted to the newspaper.

Q Now, in 1946 was that the period that

Mr. Hubbard claimed that he was crippled and blinded?

A Yes.

Q When he entered into the business arrangements

with Mr. Parsons?

A Yes.

 

 

 

1954

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Q And with regard to exhibit 4-N, quadruple 4-N,

why did you send me that, Mr. Armstrong?

A This is the divorce proceedings between

L. Ron Hubbard and Louise Grubb Hubbard, and there is

another part of it. It was a claim by the National Bank

of Commerce in Seattle for some money which they owed,

but the divorce proceedings had some signficance and

that was because in what were called source briefings on

board the ship in which Mr. Hubbard briefed a great number

of people to go out and to give lectures in organizations

and missions, franchises internationally about him,

contained in that source briefing and also in the notes,

some autiobiographical notes for Peter Thompkins, there

are mentions of his first wife. There are derrogatory

mentions.

He's claimed at various times that she was

a dipsomaniac and he claimed that she had run off with

someone or become involved with a man during the war, and

that a judge in Port Orchard, Washington had told him to

divorce her, and so he had divorced her and he stated

also that the records, that you could simply check the

records in Port Orchard, Washington to confirm this.

Well, I went to Port Orchard and checked the

records and found that the man had lied; that she had

divorced him, and I was also able to determine that

contrary to his claim that she had run off with someone,

he, in fact, had run off with someone and by December 1945

he was living with Sarah Northrup in Pasadena, California.

 

 

 

1955

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Q And did you find that Mr. Hubbard had had at

least several girl friends during his marriage to Polly?

A Yes.

Q And did you find records relating to whether

or not Mr. Hubbard supported Polly between 1938 and

1945?

A Well, there were some very telling correspondence

from Polly on that subject and also in interviews with the

family. Her complaint was that he was always running off

and leaving them without any money or way of getting

along, and that complaint was very graphically written in

a number of letters between them in 1945-46.

Also, in interviewing Hubbard's cousins

and aunts, they had a very great deal of sympathy for Polly,

Louise Grubb, and the situation in which she was left in.

 

 

 

1956

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And they also indicated that Mr. Hubbard had not

provided for the family as he should have.

Q So when you were in the port captain's office

you were required to drill -- to disseminate lies about

Mr. Hubbard's relationship in the divorce from Polly; is that

correct?

MR. HARRIS: In his opinion?

Q BY MR. FLYNN: In your opinion.

A I don't believe that was part of the briefing.

It was part of the briefings which I received; it was a part

of what later became the story which we were to give out.

That would have been my story in the PR bureau. But I never

relayed that to anyone. I heard it.

Q You were drilled on it, to give that briefing,

but you were never required to actually do it; is that your

testimony?

A I don't believe I ever drilled that at that time.

I don't think it ever came up. It was not a point of attack.

I was later briefed on it. It is difficult --

it just was not included in the -- what were becoming the

standard line of attacks on Mr. Hubbard which I knew about

at that time.

Q So you felt that these materials in here were

contrary to your briefings; is that correct?

A Yes.

THE COURT: We'll take a recess at this time until 1:30.

(at 11:55 a.m., a recess was taken

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

 

 

 

1957

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LOS ANGELES, CALIFORNIA; TUESDAY, MAY 15, 1984; 1:30 P.M.

-oOo-

 

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

record reflect that counsel and the parties are here.

 

GERALD ARMSTRONG,

the witness on the stand at the time of the noon recess,

having been duly sworn, resumed the stand and testified

further as follows:

THE COURT: The witness has taken the stand. Just

state your name again for the record, sir. You are still

under oath.

THE WITNESS: Gerald Armstrong.

THE COURT: Very well, you may continue.

MR. FLYNN: Thank you.

 

DIRECT EXAMINATION (Resumed)

BY MR. FLYNN:

Q Now, Mr. Armstrong, we had gone over a couple

of exhibits.

Why did you send me exhibit triple Z?

A Exhibit triple Z is the record of proceedings

of the Board of Investigation convened on board the

USS PC 815, and this concerned the firing of the shots

on the coast of Mexico during the war during a shake-down

cruise in 1943, and I had sent it because it concerned that

incident and there was another record in another document

 

 

 

1958

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in which Mr. Hubbard had stated that his crew had lied

for him during this Naval Board of Investigation, and it

had particular signficance in that regard and it had

particular significance in that it was part of the overall

picture which showed that Mr. Hubbard was not the war hero

that he had claimed publicly.

 

 

 

1959

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Q Now, would you look through exhibit triple Y and

explain what it is and why you sent it this file to my firm,

Mr. Armstrong?

A Pretty well all of this file concerns Mr. Hubbard's

VA records, Veterans Administration. And it shows that he

was making claims for various illnesses during the period

when he was claiming two things: first of all, that during

or following the war he was cripled and blinded and that

within two years he had cured himself completely. And these

documents cover that whole period.

Q And do they basically cover the period from right

after the war all the way up to, at least, August 1, 1951

and contain numerous items of correspondence back and forth

between Mr. Hubbard and the Veterans Administration?

A Yes.

Q And do they create a chronology during that period

of the claims he was making with regard to his claimed

disability?

A Yes.

Q And, for example, in this document, in 1951 was

he claiming to have still suffered from war-related injuries

at a period when he had claimed in other publications that

he had totally cured himself?

A Yes.

 

 

 

1960

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Q And are these documents in general inconsistent

with the handwritten notes of Mr. Hubbard regarding whether

he suffered from eye problems, hip problems, or similar

injuries that are reflected in exhibit 500 four D through

500 four F?

MR. LITT: Objection.

THE COURT: Well, I think that he's already testified

to what's there. The Court can draw his own conclusions.

Q BY MR. FLYNN: And so you sent these to me because

they are the complete correspondence file and related Veterans

Administration documents throughout that period; is that

correct?

A Yes.

Q Now in that exhibit, Mr. Armstrong, did you find

numerous contradictions from one letter of Mr. Hubbard to

another letter of Mr. Hubbard?

A Yes.

Q One time he claimed one thing and another time

he claimed another; is that correct?

A Within that file there and within the Naval records

there are contradictions between at least what the medical

examiner or doctor is stating that he is getting from

Mr. Hubbard, the facts relating to his wartime experience

and his injuries and problems.

Q Now you had mentioned in exhibit 500 four J a

press release entitled "Hubbard Broke Up Black Magic in

America."

Do you see that?

 

 

 

1961

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A Yes.

Q And attached to that are the handwritten notes

of L. Ron Hubbard that are the same as the press release;

is that correct?

A Yes.

Q That Hubbard broke up black magic in America?

A Yes.

Q And did you find the handwritten notes of

Mr. Hubbard that he broke up black magic in America to be

contrary to other documents that you find such as the blood

ritual?

A Yes.

Q Now 500 four O, Mr. Armstrong, why did you send

me that document?

A This was amongst a great deal of correspondence

between Mr. Hubbard and his first wife which I sent you, and

the particular document which I thought we has selected out

is not this one. This one was noted because of his -- the

way he ended up saying, "I do love you even if I used to be

an opium addict."

 

 

 

1962

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Other than that, I do not believe this has a lot

of relevance exactly.

Q Why did you send me correspondence between

L. Ron Hubbard and his first wife?

A Well, because of the claims that Mr. Hubbard made

which I knew beginning in 1974 that his first wife Polly or

Louise Grubb was a dipsomaniac; that she had deserted him;

that he had been ordered or a judge in Port Orchard had told

him to get a divorce because she had been involved with

another man.

And I found that the letter showed this not to

be the case. And the letter showed the type of treatment

that he gave her; in particular, there was some correspondence

in 1945 having to do with the Alaska Radio Expedition and

having to do with the type of abuse which Mr. Hubbard heaped

on her throughout the several years of their marriage.

Q Does Mr. Hubbard -- strike that --

Has Mr. Hubbard written in condemnation of the

use of drugs in Scientology literature?

A Yes.

Q And did you find it significant that Mr. Hubbard

had been addicted to opium at one point?

MR. LITT: Objection.

THE COURT: I'll sustain the objection. There is this

reference in here. I don't know whether it is an allegorical

or what it purports to be.

Q BY MR. FLYNN: In exhibit four D to four G,

Mr. Armstrong, were there references to Mr. Hubbard's mind

 

 

 

1963

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being diseased because of drugs?

MR. LITT: Objection.

THE COURT: Well, I don't want to go back through those

and try to figure out where you are referring to.

MR. FLYNN: Let me try it this way, Your Honor:

Q When you were doing your biographical research

did Mr. Hubbard's state of mind with regard to the impact

of various drugs on his state of mind become a part of your

research?

A Yes.

Q And did you find that Mr. Hubbard had used drugs

between the periods of 1939 and 1946?

MR. LITT: Objection, Your honor.

Mr. Flynn is now trying by indirection to get

back into these documents that the Court has already said

you can't tell what they are to begin with. And so

Mr. Armstrong should, at least, be asked exclusive of that.

THE COURT: Well, I think --

MR. LITT: I mean --

THE COURT: I am inclined to agree at this point.

The reference is here, for whatever it is worth.

Q BY MR. FLYNN: Did you find statements in the

handwritten notes of Mr. Hubbard to be inconsistent with his

public position with regard to drug usage?

MR. LITT: Same objection, Your Honor.

This is still trying to go back to these things.

And it is --

THE COURT: Are you referring to these exhibits four E

 

 

 

 

1964

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through -I or whatever they were?

MR. FLYNN: In part, Your Honor.

THE COURT: Well, maybe you had better identify the

particular exhibit so we can find out what you are talking

about.

I remember some reference to hormones.

MR. LITT: Your Honor, I would like to repeat that the

particular documents that are being relied on here, they do

not lend themselves reasonably to any construction from which

you can conclude that statements made in there are statements

of fact. And except for this -- an initial portion of it

which is not the portion which Mr. Flynn seems to be relying

on, they are extremely private. They are completely out of

context. And this trial is quite extraordinary enough without

delving into this material.

 

 

 

1965

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THE COURT: Well, I would assume that if you didn't

want to pursue it, it wouldn't be here. In other words,

you are the plaintiff. You are seeking damages. He

is attempting to justify his conduct.

MR. LITT: I understand that, Your Honor, but I

still feel that it is an appropriate motion under 352 for

the court to make a determination that the document that

he is relying on cannot reasonably be construed in the

way he is attempting to construe, and he should therefore

turn to other documents.

THE COURT: Well, I read a number of documents and

they can be construed in a variety of ways.

MR. LITT: Precisely.

THE COURT: And I don't know that you can conclude

that they are not evidence of his own personal feelings

and beliefs at that particular moment or past experiences

or past feelings about the future, or they may be totally

allegorical. There may be something he was attempting

to set forth to program himself to attempt to overcome

what he perceived maybe as deficiencies.

There are a variety of interpretations that

can be put upon these, and at this point I am not sure

what he is referring to and if he has something specific

in mind, let's find out which exhibit and let's look at

it and then we will determine whether we should permit it

to be used.

So, if you can identify it, Mr. Flynn or

Mr. Armstrong.

 

 

 

1966

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MR. FLYNN: I really don't want to take a lot of

time on this, Your Honor. I just want to tie it into the

exhibit where he signed the "opium addict" in connection

with this witness's state of mind with regard to what

Mr. Hubbard had represented to thousands of Scientologists

about the use of drugs.

THE COURT: Well you have already had testimony,

I believe that he represented that drug use was not

appropriate and we have this letter for whatever it is

worth.

MR. FLYNN: You want me to first find the area,

Your Honor?

THE COURT: I want you to identify it and let

Mr. Litt see what it is you are referring to or Mr. Harris.

MR. FLYNN: About in that area, Your Honor.

THE COURT: He is looking at page 9 of exhibit 4-A,

Mr. Litt.

Do you have a copy of that available? I

don't really see what the connection is between Thiazole --

MR. FLYNN: That it had affected his brain, Your

Honor.

THE COURT: I will sustain the objection that if

he says that as such.

Q BY MR. FLYNN: When you were collecting the

documents, Mr. Armstrong, what was your state of mind

with regard to whether L. Ron Hubbard's mind was affected

between 1945 and 1947?

MR. HARRIS: "Affected"; ambiguous, Your Honor.

 

 

 

1967

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THE COURT: I will sustain the objection. I assume

that anything that happened or occurred may have affected

his mind in some fashion, in some way. I don't think

this witness is qualified as a psychiatrist either or a

neurosurgeon.

 

 

 

1968

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MR. FLYNN: Let me just ask this one question, Your

Honor:

Q Did you send me exhibit four D through four G

in part because you felt that there were references in there

that had to do with whether L. Ron Hubbard's mind was

affected?

A Yes.

Q And did you send me correspondence between

L. Ron Hubbard and his first wife which you felt reflected

Mr. Hubbard's imbalanced state of mind?

A Yes.

Q And is that the reason you sent it to me?

A In part, yes.

Q And for what other reasons did you send me

correspondence with his first wife?

A Because the correspondence showed that some of

the claims made by Mr. Hubbard from that period were not true

and that contrary to the picture that he was victimized by

his wife, the correspondence shows the opposite.

Q Why did you send me 500 four R?

A 500 four R has to do with correspondence to Nibs.

Nibs was L. Ron Hubbard, Jr., later changed his name to Ronald

DeWolfe.

And this group of papers showed that other people

had been writing to Nibs as if they were L. Ron Hubbard.

I had seen the letters which were sent to Nibs. I had seen

copies of them. and there copies of them in the files, in

the archives.

 

 

 

1969

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I obtained all of this information from Pers

Sec files which was sent to me in 1981. And this showed that

there were a number of people writing for L. Ron Hubbard,

signing for L. Ron Hubbard and that Nibs was being conned

in 1969 through 1980 about who in fact was writing.

Q And what does exhibit 500 4Q and why did you send

it to me?

A 500 4Q is what was called in the Guardian's office

a time track. It is an assembled chronology of events in

the life of Nibs, L. Ron Hubbard, Jr. And it shows who he

was communicating to at various times; it shows that the

organization had possession of correspondence; it shows that

they kept very close track of him.

Q And do you know who prepared it?

A I don't know the individual, but I obtained it

from B-1 Archives office U.S.

Q And why, again, did you send it, Mr. Armstrong?

MR. LITT: Objection. Asked and answered.

Q BY MR. FLYNN: Did you send it because you felt

that it showed Mr. DeWolfe had been treated unfairly by the

organization?

A Yes.

MR. LITT: Same objection.

THE COURT: I'll let it stand.

Q BY MR. FLYNN: Incidentally, during the period

of time that the time track was prepared, who, in your

understanding, was the head of the Guardian's office?

A Mary Sue Hubbard.

 

 

 

1970

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Q And who in your understanding inside the

organization was the only person who had authority over

Mary Sue Hubbard?

A L. Ron Hubbard.

Q And with regard to 500 4S, why did you send me

that?

A These papers relate to the Puerto Rican mineral

expedition which Mr. -- Mr. Hubbard has claimed at various

points that he did the first complete mineralogical survey

of Puerto Rico. And among materials which I obtained back

from Mr. Garrison were these. And this is only a very small

portion of the complete Puerto Rican mineralogical period.

And they show, at least to some extent, the

magnitude of the work which was done in Puerto Rico.

The top document had to do with Mr. Hubbard, his

father, actually. It is one document from the arranging of

the transport to Puerto Rico.

Michael Shannon had made the claim that Mr. Hubbard

had gone to Puerto Rico in connection with a Red Cross mission

to assist the -- I don't know if it was saving people -- in

any case, it had to do with a hurricane which had struck

Puerto Rico a year or so before and that L. Ron Hubbard went

down as part of the Red Cross mission.

The fact is he didn't. This had to do with the

transport which he took and Michael Shannon's information

connected into this as well. The extent of the survey that

was done in Puerto Rico was small. And this indicates some

of the legal entanglements which resulted from it.

 

 

 

1971

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It was not a success. And he ran into a number

of legal problems with his engineer who was the expert on

the survey.

 

 

 

1972

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Q Why did Mr. Hubbard go to Puerto Rico?

A To find gold.

Q Was it intended to be a complete mineralogical

survey?

A No.

MR. HARRIS: Just a second. I will object.

THE COURT: I will sustain the objection to the form

of the question.

Q BY MR. FLYNN: Well, when you sent me this

material did the reason relate to representations that

Mr. Hubbard had made about having done the complete

minerological survey of Puerto Rico?

A Yes.

Q And what in your opinion did those

materials show, Mr. Armstrong?

A These, together with the rest of the materials,

show that there was another Hubbard by the name of

Bela Hubbard who had done a mineralogical survey in

Puerto Rico some years before, my recollection is in 1924

through past 1928. Bela Hubbard had spent a number of

years in Puerto Rico and had done a very extensive survey.

L. Ron Hubbard had been there for approximately four to

five months, 1932 and 1933, and there is very little evidence

of a complete minerological survey and or even of much of

a survey at all having been done by Mr. Hubbard; that is,

L. Ron Hubbard.

Q In other documents in addition to the documents

that are marked 500 4S that are presently in the possession

 

 

 

1973

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of the organization that are not even under seal that

relate to this subject matter?

A Yes.

Q Now, with regard to 500 4T, what was your

reason for sending that to my firm?

A Throughout Mr. Hubbard's correspondence,

throughout his public statements, depending on the

situation, he characterized himself as different things

depending on how it was needed at the time. At certain times

he called himself or his followers called him a religious

leader. At tines he was a scientist. At times he denied

being a scientist. At times he railed against scientists.

Some of the material which I sent you

showed these different claims made at different times,

and this one here he requested, and this is to PR Person

from Saint Hill. This is dated 3 March, 1960.

There is a Derek, and there was two Dereks

there at one time. I think there was a Shoup and someone

else. I don't recall his name.

But here Mr. Hubbard states that, "In all

releases and statements make very sure that you stress

that I worked from the field of nuclear physics on live

sources and live energies."

Does not want to be labeled a spiritualist

and he says, "I am a research man, not a practitioner."

And he states that, "I follow up old beliefs

and superstitions about life and examine them from a rigid,

scientific basis."

 

 

 

1974

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This was part of what was put out on one

hand, that Scientology was a science and that is how I

at least was introduced to it and how I was led throughout

a great portion of that time to believe that it was a

science and that the religion was simply a necessary cover,

and here he is stating basically that fact.

Q Now at the time did you know that he was

not a -- did you learn from the documents that he was not

a nuclear physicist?

A Yes.

Q And is this document in L. Ron Hubbard's

handwriting?

A Yes.

Q Where he claimed that he was working from

the field of nuclear physics?

A Yes.

Q And why did you send me 500-4U Mr. Armstrong?

A 500-4U is a note which has been taken down

by a messenger, and I am not sure which messenger's hand-

writing this is, but it is the format in which notes were

taken down in longhand as Mr. Hubbard dictated.

In this document he states that he was not

the initiator of any Dianetics or Scientology Orgs. He

said, "Even the status of church was by a vote of

Scientologists. The first foundation and idea of

organizations was entirely that of other people," and

this was a document which later became what I was shown in

dispatch from Mr. Hubbard when I was originally briefed

 

 

 

1975

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for the MCCS mission.

Q Did you find a document dating from the

early '50's to Helen O'Brien from Mr. Hubbard that contra-

dicts Mr. Hubbard's claims in the exhibit you just referred

to?

A Yes.

 

 

 

1976

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Q And what was that contradiction, Mr. Armstrong?

A In here he originates the idea of a religion.

And he sends it out, the idea, to Helen O'Brien.

MR. LITT: "In here," being --

THE WITNESS: In the letter dated April 10.

And this would be April 10, 1953. And it is

entitled "Re Clinic HAS."

Q BY MR. FLYNN: And was a portion of that which

was particularly significant in reference to the last exhibit,

Mr. Armstrong?

A Yes.

Q And what is that?

A There are a couple of paragraphs here:

"We don't want a clinic. We want

one in operation, but not in name. Perhaps we

could call it a Spiritual Guidance Center. Think

up its name, will you? And we could put in nice

desks and our boys in neat blue with diplomas on

the walls and one, knock psychotherapy into

history and, two, make enough money to shine up

my operating scope and, three, keep the HAS

solvent. It is a problem in practical business.

"I await your reaction on the

religion angle. In my opinion, we couldn't

get worse public opinion than we have had or

have less customers with what we've got to

sell. A religious charter would be necessary

in Pennsylvania or N.J. to make it stick.

 

 

 

1977

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But I sure could make it stick. We're treating

the present-time beingness, psychotherapy treats

the past and the brain. And, brother, that's

religion, not mental science."

In other documents did he claim that he was working

in the area of mental science?

A Yes.

Q When you read that document did that suggest to

you that Mr. Hubbard originated the religion angle?

A Yes.

Q And is that why you sent it to me?

A Yes.

Q And what is 500 4W, Mr. Armstrong?

A It is a letter in L. Ron Hubbard's handwriting.

And it was to be written on Hubbard's Association of

Scientology International stationery. And it was to the

minister of health with all proper names, titles, and forms

of addresses.

And here he writes about proposing a program of

units in the field of mental healing and voluntary assistance

by our practitioners and --

Q In the prior documents had he said that he was

not working from the area of mental science?

A I don't recall if it said that exactly, mental

healing, maybe. I'm -- there are other documents in which

he claims to not be a mental healer and not be involved in

mental healing. And here he is writing claiming to be in

mental healing. And this was written during a period of time

 

 

 

1978

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when, obviously, Scientology had started and --

Q Who was that to be sent by?

A This was to be signed L. Ron Hubbard, PhD,

executive director.

I sent you this because of the contradiction

between this and other claims that he was making publicly

at the same or other times.

Q And with regard to 500 4X, why did you send me

that?

A This was something that was originated by

Mr. Hubbard. And I think it was to be written in someone

else's name.

But in any case, he makes claims in here that

you can increase the intelligence quotient of scientists

engaged in defense planning from 15 to 75 points; reduce to

30 percent reaction time of fighter pilots.

And this was addressed to Howard Pyle, deputy

administrator to the president.

In here there is a claim -- this is after the

initiation of Scientology. This is not Dianetics -- but there

is a strong implication that they are making very solid claims

of scientific workability of Scientology.

This had some significance to me because it was

those same scientific claims which caused me to become

involved.

Q Now, with regard to 500 4Y, is this in the

handwriting of L. Ron Hubbard?

A Yes.

 

 

 

1979

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Q And why did you send my office that document?

A This is a note regarding GUCK which he says is

slang for psychiatric and medical treatment for shock and

psychotics.

GUCK is something which was recommended for

Scientologists. And he claims it is a legitimate treatment

in medical and psychiatry.

At another point be claims that it was never

involved in treatment of any kind and that it was simply

spiritual.

I sent this to you because it is an indication

of the contradictions which Mr. Hubbard spoke and wrote many

times.

Also, in this document in which he claims that

the only people that got into "psychotic spins," as he called

them, were people treated by Winter, who was a doctor. And

this was just indicative to me of the way he lashed out

against anyone who was critical of him and refused to accept

any responsibility for the fact that in Scientology or under

Scientology treatment, people did go crazy.

 

 

 

1980

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Q And in that document did Mr. Hubbard claim

that he was not a science fiction writer but an adventurer?

A That is true.

Q And in reference to his science fiction

being a science fiction writer, he says, "I am not one.

My forte was adventure by profession, an adventure writer.

Campbell will testify to this."

Is that correct?

A Yes.

Q And had you found numerous other references

in Scientology publications that Mr. Hubbard was a

science fiction writer?

A Yes.

Q And this is in his own handwriting?

A Yes.

Q And when you were reviewing these documents

and finding these contradictions about Mr. Hubbard's

own self perceptions of himself, did you begin to

question whether or not Mr. Hubbard was mentally balanced

MR. LITT: Objection.

THE COURT: Well, overruled.

THE WITNESS: I still question it to this day.

Q BY MR. FLYNN: Now, were there references in

500 4X to brainwashing techniques, Mr. Armstrong?

A I believe so. I'd have to find it. The

typewritten section of this document continues after the

handwritten sections in here which are an insert.

This begins, "4. We have isolated methods

 

 

 

1981

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of determining liability of personnel beyond doubt by

improving lie detector techniques, erradicating the former

15 percent nul readings, and paragraph 5. We know now

enough about brainwashing to defeat the Russians."

Q Now, when is that document dated, Mr. Armstrong?

A The back one is dated 1957. This is from

Howard Pyle, August '57. I don't have a date on the rest

of them, but they would be around that time.

Q Did you feel that you had been subjected

to brainwashing when you worked for Mr. Hubbard?

THE COURT: You mean at the time or does he think

now?

Q BY MR. FLYNN: Well do you think that now?

A Yes.

Q And did you feel that way at the time?

A I think throughout 1980 and '81 there was

an accumulative certainty that I had been subjected to

brainwashing.

Q Now did you find a document in 1938 indicating

that Mr. Hubbard felt that he could sell his brainwashing

techniques to the Russians?

MR. LITT: 1938?

MR. FLYNN: 1938.

THE WITNESS: I don't recall any such document.

There have been references to an incident Mr. Hubbard has

claimed later. The earliest claims I saw of such an

incident were after the beginning of Dianetics and

Scientology. There was nothing in the correspondence or

 

 

 

1982

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anything from Mr. Hubbard's records of 1938 to indicate

that such a thing had actually happened.

Q BY MR. FLYNN: Did he make a claim that the

Russians had offered him a hundred thousand dollars in

1938 for his brainwashing techniques?

A I have seen a claim that they offered him

money, and I believe it was a hundred thousand dollars.

I don't now recall if it was for his brainwashing techniques.

I don't think that term was used, but I could be wrong.

Q Do you recall what term was used?

A I believe it had to do with his work in the

mind.

 

 

 

1983

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Q Now, did you send me exhibit 500 4X because you

felt that you had been subjected to brainwashing techniques?

A In part. It contains a number of claims and it

indicates that Mr. Hubbard felt that Scientology or Dianetics

was in that realm; he felt it was capable of such things.

Q Why did you send me the prenuptial agreement

marked 500 4Z.

THE COURT: Does it have another exhibit number?

THE CLERK: Yes.

MR. FLYNN: Marked as exhibit L.

THE WITNESS: To me they tied in an aspect of the

control which Mr. Hubbard ran regarding everyone connected

to him.

I knew at that time that people on the board of

directors were required to sign undated resignations.

I knew that he had removed Mary Sue Hubbard from

her position as controller. And --

MR. LITT: This is all still his opinion?

THE COURT: Yes.

THE WITNESS: And I felt like this was another piece

of that control.

Q BY MR. FLYNN: You felt that it indicated the

extent of his control over the -- at the beginning of his

marital relationship with Mary Sue Hubbard?

A Yes.

Q And with regard to exhibit 500 5A, why did you

send that?

A This is a pack of materials to a Constantine

 

 

 

1984

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Diamontides, I guess it is, a Greek, apparently, a Greek

individual.

I sent this because it was part of the proof that

contrary to Mr. Hubbard's public claims that he had resigned

as a director in 1966, he had in fact retained control of

Scientology and was in control.

And here he was even planning to move Scientology

to Greece.

There was also the claim that he did not make

10 percent of the income during that time. And these documents

showed his plan to re-establish this Greek company so that

he could have control in a country in which it would be

possible for him to take the 10 percent without running into

tax problems.

Q What are the dates of those documents,

Mr. Armstrong?

A The majority of them are 19 -- either, I believe,

November, '66 through sometime in 1967.

Q Now, are Mr. Hubbard's resignations under seal

or copies of the resignations?

A There is a copy of a -- a resignation as trustee.

I think that is sometime in March of 1966.

And then there is that one there, that document

you have in your hand.

Q You have already testified about exhibit L, the

policy letter of 1 September, 1966; the founder, which you

believed is set forth in the green volumes; is that correct?

MR. LITT: That is not exhibit L.

 

 

 

 

1985

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THE WITNESS: That may be our L and something else.

MR. FLYNN: 500 L.

Q It is a sealed document; is that correct,

Mr. Armstrong?

A Yes.

Q And it relates to the fact that Mr. Hubbard has

resigned from any management of any Scientology organizations;

is that correct?

A Yes.

Q And ". . .from the conducting of organizations

by myself," meaning Mr. Hubbard; is that correct?

A Yes.

 

 

 

1986

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Q And is there an indication that the name

"Hubbard" has been purchased by the organizations?

A Yes.

Q And is there an indication that, "My office

of LRH as founder remains mine as the public demonstrably

stays away from orgs that do not bear the name

L. Ron Hubbard and I do not wish to damage their traffic

volume."

A Yes.

Q Now did you work in the office of

L. Ron Hubbard?

A Personal office.

MR. LITT: I think we have heard that several times.

Q BY MR. FLYNN: And did you see that policy

letter prior to working in the office of L. Ron Hubbard?

A Yes.

Q And did you believe that the personal office

of L. Ron Hubbard was his?

A Yes.

Q Now are you familiar with the document

entitled "What your fees buy"?

A Yes.

MR. FLYNN: Now, may this be marked as the next

exhibit in order for the defense?

THE COURT: Double Z.

THE CLERK: Yes, Your Honor.

MR. HARRIS: Could we have a copy of it?

Q BY MR. FLYNN: This particular exhibit is

 

 

 

1987

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copyrighted in 1976 by L. Ron Hubbard. When did you

first see this document "What your fees buy", Mr. Armstrong?

A Well I had testified the other day I thought

I had seen this some time before either in Vancouver

or on the ship. You have just said it was copyrighted

in 1976.

Q Well that particular issue is.

Do you know whether there are other issues

entitled "What your fees buy"?

A I have seen them written in various ways,

not just on a promotional piece like this for whatever

it is, Flag or Florida.

Q Do you have a general knowledge that that

document "What your fees buy" is widely distributed among

Scientologists?

A Yes, it is.

Q And referring you to the first page, "None

of the researches of Dianetics and Scientology were ever

actually paid for out of organizational fees."

Did you prior to 1980 before you became the --

collecting biographical materials, did you believe that?

A Yes.

Q And after examining the documents that are

under seal; is that statement true?

A No.

MR. LITT: Objection.

THE COURT: In his opinion is it true? Is that

orrect?

 

 

 

1988

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THE WITNESS: In my opinion it is not true.

Q BY MR. FLYNN: And the notation is made,

"With my typewriter I paid for the research myself.

Occasionally organizations were supposed to, but they never

did."

In your opinion is that statement true?

A No.

Q And are there numerous documents under seal

that relate to the payment of fees to Mr. Hubbard through

church moneys?

A Yes.

Q And the statement is made, "Independent of

research costs the $13 1/2 million that orgs owed me for

services rendered, 10 percent the usual author's royalties,

lectures, loans, things paid out of my own pocket, I

never collected."

Did you believe that prior to collecting

the materials for L. Ron Hubbard?

A Yes.

Q And in your opinion after collecting the

materials that are under seal that we are going to get

into, is that statement true?

A No.

Q Now why did you send me 500-5B, Mr. Armstrong?

A This had to do with the -- Mr. Hubbard's

attempt to be accepted in psychological organizations or

in the field.

Q Is that in Mr. Hubbard's handwriting?

 

 

 

1989

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A Yes. The whole document is although --

Q And in your experience had Mr. Hubbard publicly

expressed an antipathy toward psychologists and psychiatrists?

A Yes. The document itself is to be signed

by Elliott of the NAAP, but it is Mr. Hubbard's handwriting.

Q So it was a document that he prepared for

someone else's signature?

A Yes.

Q And the document relates to what?

A It relates to the organization which -- I

don't know if we have a piece from it here or not; National

Academy of American Psychology, and he at that time was

terming what they did mental practice. This was in the late

'50's and it was when Scientology was also known as a

religion on one hand and as a science in the field of

psychology on the other hand.

 

 

 

1990

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Q In other documents had Mr. Hubbard claimed that

he was not a mental health practitioner?

A Yes.

It is an attempt to control the field of psychology

by having his group set up as an examining board, as a

control.

There is a loyalty oath which he has prepared.

And there are steps on the reporting of people who do certain

things to the FBI. And it is an attempt to gain control

within the field of psychology.

MR. HARRIS: Does Your Honor have the date of the

document? Is it on there?

THE COURT: I don't know. It is possible that it is

somewhere in here.

Q BY MR. FLYNN: Does this whole file relate to

that same subject, Mr. Armstrong?

A Yes, it does.

THE COURT: Do you know, Mr. Armstrong, what the time

frame is of this exhibit?

THE WITNESS: I believe, Your Honor, 1958.

Q BY MR. FLYNN: All of these documents relate to

the same subject?

A Yes.

Q And you have expressed the reasons why you sent

them to me?

A Yes.

Q Now, we come to the MCCS tapes; without stating

the contents of these tape recordings, do you know

 

 

 

1991

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approximately when they were made?

A September, 1980.

Q And do you know who was present?

A There are two tapes in here. And there were

different people present during the two meetings.

One of them, there was at least Charles Parcell

and Laurel Sullivan.

On the other one there was a larger meeting;

present were Laurel Sullivan, Alan Wertheimer, Charles Parcell,

Dick Sullivan, and an attorney named Ron Fugikawa. And there

were a few others.

MR. FLYNN: Your Honor, I would like to ask him why

he sent the tapes to me. And he will have to get into the

contents to explain that answer.

As I have indicated, the contents of the tapes,

I'm going to put in through evidence relating to the facts

of which the tapes concern which evidence Laurel Sullivan

obtained prior to the inception of the MCCS Mission.

THE COURT: Well, at this point it seems to the that

he can simply state that he sent them to you believing it

would be of assistance to him in his defense. And I suppose

if plaintiff wants to develop it to contradict it, we'll have

to deal with that in due course.

But I'll permit him to testify in conclusionary

language that that was his belief.

MR. HARRIS: I'll stipulate that that is what he would

say, Your Honor.

THE COURT: Do you accept that stipulation?

 

 

 

1992

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MR. FLYNN: Your Honor, the tapes, as Your Honor knows,

relate to --

THE COURT: At this point I don't want to get into

taking the time or going into whether or not there is

privilege on it.

You have indicated that you have another witness

that you want to present that may develop certain matters.

I presume this witness is not going anywhere;

he is available to be recalled if necessary.

MR. FLYNN: Rather than accept the stipulation, Your

Honor, let me do this:

Q Mr. Armstrong, did you send these to me because

you believed that they would assist in your defense relating

to financial transactions of the organization?

A Yes.

Q With regard to 500 5D, Mr. Armstrong, why did

you send that to me?

A This was an inventory that was done in 1977.

And it had to do with what were called LRH Val Docs, valuable

documents, which were contained in the LRH Pers Sec U.S. files

which were sent to me sometime in 1980 -- partially in '80;

mostly in '81.

I sent it to you because it is an inventory and

because it contained within that inventory a long list of

undated resignations which were held in the Hubbard Archives,

the LRH Pers Sec Archives.

And these are for Scientology organizations of

various kinds in various countries. And there are

 

 

 

1993

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approximately -- I don't know. There may be 100 names and

maybe 30 organizations or corporations.

Q Now, did you understand it to be the practice

throughout the period of time that you were in Scientology

for members of the boards of directors and officers of

Scientology organizations to sign undated letters of

resignation?

A I did not know it to be the practice when I first

got into Scientology.

I learned of the practice probably somewhere

around 1973, 1974. And I knew thereafter that it was the

practice.

I didn't have any -- having never been a director,

I didn't have first-hand knowledge.

Q Did you know officers and directors who had signed

undated letters of resignation?

A I was told by one of the directors of the Church

of Scientology of California, a man by the name of Bill

Fosdick, that he had done it and that it was standard

practice.

Q How about Kima Douglas; did you learn from her

that she had signed an undated letter of resignation related

to the Research Foundation?

A I don't believe she told me that. She mentioned

undated resignations when we were doing the back dating of

the board minutes for Operation Transport Corporation.

 

 

 

1994

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Q Now what was your state of mind with regard

to the control of Scientology organizations by L. Ron Hubbard

with the use of undated letters of resignation while you

were in the organization?

A Well, while I was in, I never thought of it

in those terms. I knew that he controlled Scientology

organizations and he simply controlled. I never thought

of it, that necessarily all the documents rested with him

although I could have surmised as much, but I simply knew

that he controlled.

It never struck me as any other way. I never

questioned that.

Q And with regard to sending me exhibit 500 5-D,

did you believe at that time that the list of undated

letters of resignation in there proved the element of

control by Mr. Hubbard?

A Well, I felt that it was an aspect of it

because by this time I had become very aware of the

organization defense in various cases. Their defense of

Mr. Hubbard that he did not control and that he had

resigned as a director, and I felt that this showed the

fact that the man retained in his personal archives

undated resignations from 30 corporations and a hundred

individuals showed certainly an element of control and tied

in with everything else that I had about L. Ron Hubbard

or I knew about L. Ron Hubbard or testimony from various

other witnesses, I thought it was conclusive.

MR. FLYNN: Is this time for a break, Your Honor?

 

 

 

1995

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THE COURT: I think so, about a minute unless you

have run out of steam.

MR. FLYNN: No, I have some more exhibits.

THE COURT: Okay. We will take a 15-minute recess.

(Recess.)

THE COURT: Okay. We are back in session. 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: All right, you may continue.

Q BY MR. FLYNN: Now, Mr. Armstrong, prior to

the break you testified that it was your belief that

Mr. Hubbard was not receiving any moneys from the

organization during a period of time that you were involved;

is that correct, prior to 1980?

A Yes.

Q And it is your understanding that belief

was held by Scientologists throughout the world?

A Yes.

Q And there were documents disseminated by

the organization to that effect including exhibit double Z;

is that correct?

A Yes.

 

 

 

1996

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Q Now, when you were collecting documents on the

biography project did you find documents referring to the

Hubbard Explorational Company?

A Yes.

Q And to a corporation called OTS?

A Yes.

Q And to a corporation called OTC?

A Yes.

Q And referring now to exhibit 500 5E, did you send

me documents relating to the Hubbard Explorational Company?

A Yes.

Q And why did you send me those documents?

A I considered that these documents were very

important because they showed that after Mr. Hubbard had

supposedly resigned in 1966, he continued to exert control

over Scientology and over Scientology personnel. And he

established HEC, Hubbard Explorational Cowpany as a vehicle

by which he could control at an arm's length basis with a

profit corporation Hubbard Exploraticnal Company.

I do not fully understand all the intricacies

on how this was done, but I do know that Scientologists were

used in this profit corporation; that a system was established

for the movement of funds from Scientology through to HEC

and that Mr. Hubbard had absolute control of these

corporations.

I considered it very significant as well because

I was involved in MCCS in establishment of a similar set of

corporations to achieve the same ends. And this was a pattern

 

 

 

1997

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which Mr. Hubbard had set up in 1966 when he supposedly

resigned and which continued up to the present time.

Q Now, are there numerous documents in the folder --

MR. LITT: What folder?

MR. FLYNN: 500 5E.

Q -- relating to the Hubbard Explorational Company?

A Yes.

Q And are many of these documents in L. Ron Hubbard's

handwriting?

A yes.

Q Now, with regard to the first document which is

a paper clipped and stapled series of documents that bear

at the top of the first page "Finance" in red and "Executive

Directive Organizational Contribution" when you were collecting

the documents, did you find that document, Mr. Armstrong?

A Yes.

Q And why did you send that document to me?

A Because it showed the control -- this is 27 April,

1967 when Mr. Hubbard wrote on the published Executive

Directive which had been put out by Mary Sue Hubbard under

the -- and under Mary Sue Hubbard's name as the Guardian

Worldwide is the board of directors of the Churches of

Scientology.

Mr. Hubbard has written on this Executive Directive

and given further instructions to Mary Sue, many of which

are very significant, I believe.

Q Would you point out and read the portion that

you felt was most significant?

 

 

 

1998

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A Well, the whole thing -- it is about nine pages

long -- is significant.

But this part here which concerns the establishment

of an LRH Good Will Repayment Account, "Establish a LRH Good

Will Repayment Account with your local bank."

Mr. Hubbard was to be repaid for his good will.

And Mr. Hubbard writes ". . .an Org that doesn't

comply must have its executive sec changed. An Org that

doesn't deposit must have its executive and treasury sec

changed as this indicates refusal to give LRH money and that

they are stealing it or, at least, not on our side."

And the thing goes on a great number of pages

to do with the sale of St. Hill property to Scientology; the

amount of money he was going to make from that. And the whole

thing indicates his control over Scientology and Scientology

accounts and control of Mary Sue Hubbard who was then the

Guardian.

 

 

 

1999

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Q Now, with regard to the next document which

is a stapled and paperclipped series of pieces of paper,

of which the first one bears at the top "Promissory note

from HEC to LRH."

What is the nature of this document,

Mr. Armstrong or why did you send it to me?

A There is a group of these documents which

are promissory notes, and there is a great deal of

money that is involved here, and they all are in 1967.

Hubbard Explorational Company appears to be

borrowing this money from L. Ron Hubbard. The directors

of Hubbard Explorational Company are Anton James,

Ray Thacker, John Lawrence at one point; Haskell Cooke,

Hank Learhuis, Darrell Tepoorten at another point, and all

of these people are Scientologists. There are, I don't

know if they are in here, but there are Articles of

Incorporation for Hubbard Explorational Company, and there

are notes regarding ownership of stock and Mr. Hubbard

was the owner of at least 97 percent of the stock in

Hubbard Explorational Company which was a profit-making

corporation.

I don't recall at this time the exact

significance of the loans from Mr. Hubbard to Hubbard

Explorational Company. I believe that they are tied in some

time later.

Q In other documents?

A Yes.

Q Now with regard to a document that bears at

 

 

 

2000

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the top Norton Rose Botterill, B-o-t-t-e-r-i-l-l, starting

"Gentlemen"; why did you send that document to me,

Mr. Armstrong?

MR. LITT: Just a moment. May I see those

documents, please? Just give us a moment if we may, Your

Honor.

Q BY MR. FLYNN: Do you recall why you sent

these series of documents involving Mr. Botterill or

Caterrill in the handwriting of L. Ron Hubbard?

A They formed part of the picture regarding

Hubbard Explorational Company. Hubbard Explorational

Company formed the first part of the Sea Organization,

and it was, in fact, a profit corporation.

In one of these -- it is this first letter

here, he mentions transferring the ships, overseas vessels

to flag of convenience and then, I don't know if it is in

this letter, but then he saye that they are going to set

up another corporation to take over once they deregistered

or once they have reregistered the vessel under a

flag of convenience, and that corporation became OTS which

became the owners of the vessel Apollo when it had a

Sierra Leone flag.

Q And I don't know if all that information is

in this file or not, but each one of these letters or

documents refers to Hubbard Explorational Company, moneys,

Scientologists involved in Hubbard Explorational Company

and Mr. Hubbard's control of those, that and Scientology

corporations.

 

 

 

2001

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Q Now, the crew members that were working on

board the ship at that period of time, did you learn in

the biography project whether those crew members were

working for Hubbard Explorational Company?

A Yes, they were. At least on one level they

were working for Hubbard Explorational Company. On

another level they were all members of what was called

the Sea Organization or originally the Sea Project, so

they sort of had two roles.

On books they would have been called Hubbard

Explorational Company, and within their own minds they

would be sea projects personnel.

Q Now, and with regard to this document,

"Re 50,000 you just transferred to Swiss, let it ride

along."

What is that document, Mr. Armstrong?

A Well, I think --

Q And when is it dated?

A it is dated 25 August, '67.

Q And this is more than a year after Mr. Hubbard

supposedly resigned?

A Well, he supposedly resigned on 1 September,

'66, so it is close.

He is writing to Marilyn.

Q Who is Marilyn?

A Marilyn Rootsen. She is a Scientologist.

Q There is a note "F-Treas"; what does that mean?

A Well, treas is treasury. I don't know what

 

 

 

2002

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the F at this point refers to.

Later it would be Flag Treasury, but I

don't know if that term was used at that time.

He says, "The $50,000 you just transferred

to Swiss, let it ride along as it is and I will submit

bills and then transfer it for use.

"HEC will have a beautiful building for

Base One to rent C of S. The deal is going on through."

HEC was a private corporation which

Mr. Hubbard controlled. Going to be renting a building to

C of S, and it indicates control of finances and obtaining

apparently 50,000 pounds which he was later going to

bill for.

 

 

 

2003

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Q And with regard to this next exhibit, it bears

at the top 21 March, '66; why did you send that my office,

Mr. Armstrong?

A This has to do with the trusteeship resignation,

a copy of which I sent to your office and which is under seal.

There is one letter which is sent "Dear Mr. Allen"

attached. And it again refers to the resignation as a trustee

21 March, '66.

Mr. Hubbard was then having tax problems.

". . .this is of definite interest

to you and the tax problems you are handling

for me. As this will leave none of the funds

reported by Mrs. Hubbard' -- I believe the next word

is "on" or -- "in tax returns even in my vicinity."

These and the Constantine Diamontides letters

indicate the tax problems which Mr. Hubbard was having and

because of the so-called nonprofit status of the organization

and his control and his obtaining funds and the steps that

he took to try and circumvent those problems.

Q And do these documents in general, Mr. Armstrong,

relate to the transfer of funds from church accounts to Swiss

accounts?

A Yes.

Q Regarding the relationship between Hubbard

Explorational Company and the Church of Scientology?

A Yes.

Q And do they in general indicate that the Hubbard

Explorational Company owned by Mr. L. Ron Hubbard was receiving

 

 

 

2004

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funds from the Church of Scientology after Mr. Hubbard's

resignation in 1966?

A Yes.

Q And when you were collecting these documents was

it your belief that these documents contradicted Mr. Hubbard's

claim that he hadn't received any funds from the Church of

Scientology?

A Yes.

Q And there are a series of documents relating to

a contemplated expedition by Mr. Hubbard?

A Yes.

Q And what was the nature --

MR. LITT: Is this all still part of 5E?

MR. FLYNN: It is.

Q What is the nature of those documents,

Mr. Armstrong, and why did you send them to me?

A There are two sets of documents or, actually,

two expeditions mentioned in these documents.

One set has to do with a mission to the -- and

expedition to the Red Sea and he was writing to the

Hydrographic Office of the U.S. Navy Department. And he was

able to obtain from the Navy Department a letter which was

used as a PR letter. I had a copy of it in the Port Captain's

Office.

And it was also used to show what Mr. Hubbard

was doing during that period of time; actually, the Red Sea

expedition never happened.

And in another one of these letters -- I don't

 

 

 

2005

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know which it is -- there is a statement to someone regarding

a geological survey and a search for likely looking spots

for drilling oil. And the two are in contradiction one to

the other. But they were simply PR -- they were to elicit

letters from authorities for these expeditions which in fact

never occurred.

 

 

 

2006

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Q And with regard to those alleged expeditions

and the transfer of church funds, would you examine a

stapled series of documents, the first page of which bears

telex 95212 Enchanter and referring to the third page,

"Confidential E.D. Worldwide" dated 2-9-67; do you recognize

that to be the handwriting of L. Ron Hubbard?

A Yes.

Q And would you state portions of that document,

Mr. Armstrong, that indicate Mr. Hubbard's control over

the Church of Scientology and the transfer of moneys to

him?

A This is addressed to the LRH Comm Worldwide,

the L. Ron Hubbard Communicator Worldwide. That is an

organization post, and he gives a series of steps, he says,

that are to be followed, carried out.

Q And he says first that this person "is to

personally see that the following orders are carried out

at once and without 'other reasons why' ... "

A Right.

Q And what are the steps?

A (Reading:)

"Enter into the C of S balance sheets

all debts reported by the LRH Finance Committee.

"2. Elect MSH and myself to the

Board of HEC as the only Board members.

"3. Draw up a contract between C of S of

California Board and the HEC to research areas

and establish bases it will then rent from HEC

 

 

 

2007

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on 'terms to be arranged.'

"4. Put together a ledger for C of S

showing 10,000 pounds per month since 1 January,

'67 for HEC services on the debit side and all

sums spent by C of S on behalf of HEC and

all sums given HEC to date."

And it goes on to various other -- do you

want me to read the whole thing?

Q That is sufficient.

Did you find other documents in other

files indicating that there was an amount of 15,000 pounds

per month being transferred to HEC -- strike that.

Let me show you these invoices showing

transfers from Church of Scientology of California accounts

to HEC, and would you give the date and the amounts that

show the transfers from Church of Scientology of California

moneys to Hubbard Explorational Company accounts?

A They are the first -- they are 1967, and

there is one for each month running between the lst of

January and the 1st of October 1967.

Q And what are the amounts, Mr. Armstrong?

A Fifteen thousand pounds.

Q And among the documents relating to HEC did

you find documents related to undated letters of resignation

from that corporation?

A Yes.

Q And did you find that to be a pattern

throughout Scientology organizations on which you collected

 

 

 

2008

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documents?

A Yes.

Q What was the corporation that came after

HEC, Mr. Armstrong?

A Operation and Transport Services.

Q And what corporation came after that?

A Operation and Transport Corporation.

Q That was the corporation that you worked for;

is that correct?

A Yes.

Q And again how much were you paid per week

when you were working for OTC?

A Between zero and $10 a week for the most

part.

Q And how many hours a week were you working?

A About 120.

Q Now what is exhibit 500-5F, Mr. Armstrong?

A This is a handwritten letter from -- it is

in Mr. Hubbard's handwriting. It is addressed to the

Hubbard Association of Scientologists in Camden.

Q Is there a date?

A No, but it would be probably 1953 or '54.

Q And why did you send me that document?

A Because it is Mr. Hubbard's handwriting and

he states in there, he states, "I will hold resignations

against good behavior."

He earlier says:

"Cancel third church. Send me undated

 

 

 

2009

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resignations for trustees for Church of

Scientology and American Science, one per each

church. I will hold resignations against good

behavior."

Q Then, "Hold trustees meetings authorizing

bank accounts, seals and by-laws."

A Yes. "Open account on my signature only,

Camden."

Q Now, and this is beginning in 1953 with

reference to the undated resignations?

A Yes.

Q And did you learn that right up to 1981 the

executive director international William Franks, was

required to sign an undated letter of resignation?

MR. HARRIS: From the document that he is looking

at in front of him or from Mr. Franks or from what source?

THE COURT: I am not sure.

Haven't we had testimony on this before?

MR. HARRIS: I think so.

Q BY MR. FLYNN: What is 500-5G, Mr. Armstrong?

A This is a -- it is called, "A legal

memorandum concerning the status of Scientology companies

and Mr. Hubbard's relation to them and Mr. Hubbard's

status and finances in the United Kingdom compiled

May 1963, history and background of Scientology companies."

 

 

 

2010

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Q And why did you send me that?

A Because this is a part of the picture which was

presented.

This was a document which I had seen in other

places, not just in the Hubbard Archives. And it presents

a particular picture which the actual documentation does not

show.

It is, taken along with all the other materials

available, it just shows another statement by Mr. Hubbard

which was not the truth, but just made because it was

opportune.

Q Does it state in there that that, "all previous

U.S. orgs were Dianetic organizations and were not owned or

controlled by Dr. Hubbard"?

A Yes.

Q And did you find extensive documentation which

contradicted that fact?

A Yes.

Q And 500 5H, why did you send me that,

Mr. Armstrong?

A This is a copy of the resignation of Mr. Hubbard

as a trustee. It is, I believe, dated 21 March, 1966. And

he resigned as a trustee.

On this document he did not resign as a director.

This, I felt was important because as much as a year or even

two years later, Mr. Hubbard was still in control of what

was called the trustee account. And he was issuing orders

regarding the trustee account.

 

 

 

2011

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Q Did you conclude that that resignation was a sham?

A Yes.

Q And with regard to 500 5I, is that in Mr. Hubbard's

handwriting?

A Yes.

Q And would you read what 500 5I states,

Mr. Armstrong.

A It is dated 18 April, 1963.

It is entitled "Re Reorganization of Churches."

"This is the first I have heard

of the matter of a new pattern of control for

the churches as per your letter of 15 April,

'63."

This is to an attorney by the name of Brinkman.

MR. LITT: Which number is this? Is this 5I?

Can I see that document, please?

Your Honor, this document is addressed to an

attorney. There is no indication that there has been any

waiver and we object to any use of it.

THE COURT: Maybe you had better let me see it, counsel.

Well, sir, do you have any information of the

source or anything else you have uncovered that at some time

in 1963 an attorney, Brinkman, was performing legal work in

some capacity for Mr. Hubbard?

THE WITNESS: Yes, he was, Your Honor.

THE COURT: I'll sustain the objection.

You can testify generally that you may have relied

upon it in some form for some purpose and you believe it has

 

 

 

2012

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reference to your defense. If the other side wants to cross-

examine on it, they may do so; otherwise, it will be received

without cross-examination.

MR. HARRIS: We'll assume that the witness is going

to claim with respect to each of those documents either by

a leading question or otherwise that they were for his

defense. That seems to be the pattern. I have seen it on

about 150 documents. And I don't believe it is going to

change.

So on that one, surely, I'll stipulate that it

was for his defense in some fashion.

THE COURT: Well, how many more documents have you got

that you have premarked, Mr. Flynn?

MR. FLYNN: We are up to 5I, Your Honor. And I think,

we go to 7J. So I think we are probably five-sevenths of

the way through.

THE COURT: I am disposed to take the position that

we have gone through this and the witness has demonstrated

a knowledge of these exhibits and what they are. Unless there

is something very specific that you want to develop or a

specific point that you wish to make, that we should just

deal with it in a general conclusionary way and leave it to

the other side if they want to cross-examine upon it and test

what he is saying. Then the court can evaluate it. But I'll

take the position that he has testified in detail and generally

speaking as he has done up to this point unless there is

something specific or some line or group that you want to

develop.

 

 

 

2013

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MR. FLYNN: Your honor, if I can just establish a record

on the circumstances under which Mr. Armstrong came into

possession of some documents relating to correspondence to

attorneys, then I'll leave it there for the time being.

THE COURT: Okay.

Q BY MR. FLYNN: Mr. Armstrong, for example, this

letter to Mr. Brinkman, what file did it come out of it you

recall?

A My recollection is that it came from a file from

Pers Sec WW. Those are the little tags that Pers Sec WW had

on their files.

I believe those are -- they were standard

throughout all of those files.

Q Did you have permission from Mr. Hubbard to

obtain these files and to give them to Omar Garrison, the

journalist?

A Yes.

MR. LITT: Objection; move to strike.

That is a conclusion. And as to the factual

basis, he has testified.

THE COURT: I sustain the objection.

If you want to ask him whether he specifically

discussed this particular document with Mr. Hubbard or any

of his messengers, you may do so. But what he is relying

on, he has already testified to.

Of course, that is something else. But your

question, implicit in there, is that he had a specific

consent on that particular exhibit.

 

 

 

2014

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Q BY MR. FLYNN: Well, first, Mr. Armstrong, when

you were conducting the collection of documents for L. Ron

Hubbard for the project over a period of almost two years,

was it your understanding that you had access to L. Ron

Hubbard's legal files?

A I had access to the files that I had. I did not

request access to the current legal files of ongoing

litigation. I had whatever was in Mr. Hubbard's files which

I had possession of.

 

 

 

2015

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Q Did anyone in the organization or did

Mr. Hubbard ever bar access to those files?

MR. HARRIS: Well I will object as compound; or

Mr. Hubbard. Maybe he could ask if he ever talked to

Mr. Hubbard or communicated to him about any legal

files.

THE COURT: Or did anybody ever bar access?

THE WITNESS: No, Your Honor.

Q BY MR. FLYNN: All right, with regard to

exhibits 500-5I through 500-5Q, did you believe those were

necessary for your defense, Mr. Armstrong?

A Yes.

Q And for example, 500-5J, did that relate to

a plan to conceal someone to get that person into

Mr. Hubbard's presence in 1978?

A Yes.

Q Through the use of different cars and drops

and things of that nature?

A Yes.

Q And did you --

MR. LITT: What document is that now?

MR. FLYNN: 500-5J.

THE COURT: Is that a situation when he was at

Hemet?

THE WITNESS: This was when he was in La Quinta.

Q BY MR. FLYNN: And was it labeled "Top

Secret"?

A Yes.

 

 

 

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Q And do you believe now that that indicates

a pattern of concealing Mr. Hubbard?

A That was part of the pattern.

Q And 500-5R, 5S, did you believe those necessary

for your legal defense?

A Yes.

Q And did 500-5S show that L. Ron Hubbard

controlled the move to the U.S. of Churches of Scientology

into Clearwater, Florida?

A This showed a part of that control. It is

just indicative of the complete -- of the complete control.

Q And with regard to 500-5T, did you believe

that necessary for your legal defense?

A Yes.

Q Now was it your understanding when you sent

me 500-5U that it showed that the personal office of

L. Ron Hubbard was owed by him and not by the church?

A I don't recall if this document shows that.

This document, I believe, indicated what the product of

this unit was and -- yes, the valuable, final product.

Acknowledgements of L. Ron Hubbard, his goals, purposes

and products, and then how many of these things they were

to obtain for Mr. Hubbard, and it was part of the picture

which showed that these people were, in fact, working

on L. Ron Hubbard's products, not organizational products.

Q Such as royalties for his books?

A That would be a part of it. This thing

specifically talks about Dianetics, the Modern Science of

 

 

 

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Mental Health book program. They were to obtain public

acknowledgements from world leaders, public acknowledgements

from national opinion leaders of each major nation.

This contained the statistics and products

of the first PRO international post.

Q Now, with regard to 500-5V, was that a

fairly significant file, Mr. Armstrong, relating to

L. Ron Hubbard's personal finances after his resignation

in 1968?

A Yes, it was significant in terms of the

overall picture.

Q Or relating to his personal finances in

1968, having resigned in 1966?

A Yes.

Q And are there documents in there that show

royalties coming to L. Ron Hubbard from Flag Banking Office

US in the amount of $17,325?

A Yes.

Q And does the document "What your fees buy"

say that Mr. Hubbard had never collected any royalties

from the Church of Scientology?

A Something to that effect is in here.

MR. LITT: Well, wait.

MR. FLYNN: You want me to read it?

THE COURT: Let Mr. Litt read it.

MR. HARRIS: Let me just see the document.

 

 

 

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Q BY MR. FLYNN: Would you read the pertinent

portion of "What your fees by," Mr. Armstrong.

A (Reading:)

"Independent of research costs,

the $13,500,000 that orgs owed me for services

rendered, 10 percent; the usual Author's

royalties, legal issues, loans, things paid

out of my own pocket I never collected."

Q Now, were there documents in here on LRH personnel

finances which indicate that Mr. Hubbard was receiving

10 percent?

A Yes.

Q And are there documents indicating that LRH Pers

Sec is the only one handling purely personal matters for

L. Ron Hubbard?

MR. LITT: What exhibits are we on now?

MR. FLYNN: 500 5V.

THE WITNESS: Yes.

Q BY MR. FLYNN: And is there a particularly

significant document dated 2 September, '67 "Confidential

regarding L. Ron Hubbard's finances and Church of Scientology

of California finances"?

A Yes. There was an issue which was made of one

of the dispatches which we noted earlier. This was a

Mimeographed executive directive from one of the handwritten

letters that was in earlier HEC files.

Q And are there numerous documents in this file,

including promissory notes and handwritten letters of

 

 

 

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L. Ron Hubbard, "Calculations of all sums used by me; credit

of his agent in Rhodesia Mission."

Are there numerous files of that type showing

L. Ron Hubbard's receipt of funds from the Church of

Scientology after his resignation?

A Yes.

Q Are there balance sheets that show those types

of items, Mr. Armstrong?

A Yes.

Q And with regard to 500 5W, did you send that to

me because it showed Ron's standing order number one, "all

mail addressed to me shall be received by me"?

A Yes.

Q In fact that was not true, was it?

A Yes, it was not true.

Q And with regard to 500 --

MR. HARRIS: That the order was not true, or that in

fact it didn't happen?

THE COURT: The representation was not true.

MR. HARRIS: The order, Your Honor. I don't think there

would be a representation, a standing order; "all mail sent

to me shall be received by me."

THE COURT: I assume that somebody might read that and

consider it to be a representation.

Q BY MR. FLYNN: Are there documents in 500 5X that

show the deposit of monies and transfer of monies by Mary Sue

in the OTC account into Swiss bank accounts?

A Yes.

 

 

 

 

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Q And it was the OTC corporation that you worked

for, Mr. Armstrong?

A Yes.

Q And did you believe that was necessary for your

defense?

A Yes.

Q And with regard to 500 5Y, does that detail

financial transactions involving Operation and Transport

Services Corporation and its relationship to the Church of

Scientology?

A Yes.

 

 

 

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Q And did you believe that necessary for your

defense?

A Yes.

Q And 500-5Z, did 500-5Z after Mr. Hubbard's

resignation in 1966 in connection with finances in March,

1967 show Mr. Hubbard in his handwriting creating Board

minutes for the president or secretary of the Church of

Scientology of California?

A Yes.

Q In which Mr. Hubbard said, "Please give me

a Board minute as soon as possible as follows:"?

A Yes.

Q And showing that Mr. Hubbard had drawn,

"For deposit to my own account check No. 41206 on Swiss

bank, Church of Scientology Mission for $125,000 as

advance on house sale. Church of Scientology, purchaser;

LRH, owner."

A Yes.

Q And did that exhibit show various deposits

and balances into Swiss bank accounts involving L. Ron Hubbard

and Scientology Missions?

A Yes.

Q And was this a document that showed the amount

that was put into the LRH goodwill repayment account in

1967?

A Yes.

Q And did you believe that, contrary to

representations that were being made, that L. Ron Hubbard

 

 

 

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was not receiving moneys from the Church of Sciontology

and other organizations?

A Yes.

Q And exhibit 500-6A, did that relate to

L. Ron Hubbard ordering the elections of various boards

for the Church of Scientology of California?

A Yes.

THE COURT: Do we have a date on that?

MR. FLYNN: 25 July, '66.

Q Is that correct, Mr. Armstrong?

A Yes.

Q And was exhibit 500-6B necessary for your

defense?

A Yes.

Q Showing financial transactions between HEC

and Mr. Hubbard's payment into Swiss accounts and his

receipt of 10 percent of church funds?

A Yes.

Q And with regard to 500-6C did you feel that

that was necessary for your legal defense?

A Yes.

Q And was 6D a dispatch from L. Ron Hubbard in

1967 regarding the use of codes, cryptography and code

subjects?

A Yes.

Q And did you observe the use of telexes and

coded telexes throughout the period you were involved

in the church?

 

 

 

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A Yes.

Q And with regard to 500-6E, did you feel that

was necessary for your defense?

A Yes.

Q And did this indicate Mr. Hubbard's use of

finding information to use it to blackmail people?

A I did not see the word "blackmail" in here,

but it was an effort to find -- he said, "You will find

criminal past if you look."

He gave instructions to the Branch 5,

this on 31 August, '66. This is a story of a woman

whose daughter had disconnected from her.

Disconnection in Scientology is a procedure

by which one no longer communicates. One severs all lines

with someone, and the woman was upset about this

disconnection that her daughter had apparently pulled,

and Hubbard ordered that her past be -- that she be

investigated as to her past and that they were to find

criminal past on this poor woman.

 

 

 

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Q and you do understand that was the type of

activity that L. Ron Hubbard had ordered through the Fair

Game Doctrine for years while you were involved?

A Yes.

Q Is that in the handwriting of L. Ron Hubbard?

A Yes.

Q And 500 6F, did you feel that those were necessary

for your legal defense?

A Yes.

Q And with regard to L. Ron Hubbard stating in his

handwriting, ". . .to find the unsavory side of their past"?

A Yes.

Q And 500 6G, did you find that necessary for your

defense?

A Yes.

Q And 500 6H, was that in the handwriting of

L. Ron Hubbard?

A Yes.

Q And was he instructing in that document to sue

for purposes of harassment?

A Yes.

Q What is the date of that, Mr. Armstrong?

A 10 December, '66.

Q And did you believe that that was an implementation

of the Fair Game Doctrine?

A Yes.

Q Did you find 500 6I was necessary for your defense?

A Yes.

 

 

 

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Q Did you find the numerous documents where L. Ron

Hubbard was stating in his handwriting to sue people to

harass them, claim that they were connected to Communists,

engaged in intelligence operations, that type of thing such

as 500 6J?

A Yes.

Q And does that include documents like 500 6K, 6L,

6M? "Don't defend; attack"?

A Yes.

Q In the handwriting of L. Ron Hubbard?

A Yes.

Did you say 6K?

Q 6M.

A I had 6K for a different reason.

Q What was the purpose of 6K?

A I'm sorry. This was mixed up with another letter.

This is included because of the Fair Game Doctrine back then

as well.

Q And does 500 6K indicate threats against a person

named Virginia?

A Yes.

Q And 6N, was that indicative of the Fair Game

Doctrine in your mind?

A Yes.

Q And 6O, are you familiar with the claim that

L. Ron Hubbard had canceled the Fair Game Doctrine?

A Yes.

MR. LITT: I object to 6O.

 

 

 

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THE COURT: I am sorry.

MR. LITT: Another letter to Mr. Brinkman, Your Honor.

THE COURT: Let me see it.

Well, this appears to be a handwritten document.

The heading is "Oscar Brinkman."

It says "Dear Mr. Brinkman," et cetera. I don't

know whether such a document was ever sent to Mr. Brinkman,

whether this is something written and not sent.

Do you have any knowledge one way or the other,

Mr. Armstrong, on that subject?

THE WITNESS: No, I don't.

THE COURT: Is there a date on that?

THE WITNESS: No, Your Honor. It would be in the late

'60's.

THE COURT: Do you know whether or not there was a

practice -- do you know where you got that copy originally?

Was that from the Pers Sec?

THE WITNESS: No -- I can't say right now where this

came from.

My recollection is that it came from the Controller

archives. That is my best recollection.

Q BY MR. FLYNN: Let me ask you, Mr. Armstrong,

were you familiar with a purported cancellation of the Fair

Game Doctrine in 1968?

A Yes.

Q And did that purported cancellation state that

the practice of placing Fair Games, declares and ethics orders

would cease because it caused bad public relations?

A Yes.

 

 

 

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Q But it would not cancel any policy regarding

the treatment of SP's?

A Yes.

Q Was that the purpose of the purported cancellation?

A Yes.

Q And what did you understand that cancellation

to mean?

A At which time?

Q Well, at any time after you saw the purported

cancellation, what did you understand it to mean?

THE COURT: Well I don't know. Were you made aware

of this Fair Game concept when you were a member of

Sea Orgs, for example?

THE WITNESS: Your Honor, my first dealing with the

concept of Fair Game, was in a PR briefing which I was

in the port captain's office at the time, and one of

the subjects which came up regarding Scientology was the

subject of Fair game.

 

 

 

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THE COURT: Okay. Now, just generally speaking, what

time period are you talking about, sometime in the early '70's,

or what?

THE WITNESS: Yes; around 1972.

And the answer to any questions about Fair Game

was that the policy had been canceled.

Later I found that this was not the truth. It

was not canceled. And the perception of enemies remained

the same. And the actual thing which is the document which

has been claimed to be a cancellation simply states that term

will no longer be used. The handling -- I believe it used

the term "handling" -- for SP's remains the same.

So my perception of that is that the term, Fair

Game causes bad public relations, but that the activity or

the actions or the way that SP's, suppressive persons, were

dealt with remained the same.

THE COURT: We won't go into it. I'll sustain the

objection.

I don't know whether anything ever was written

or not, but I'll accept the inference that it probably was

typewritten, sent to Mr. Brinkman.

You may develop whether he relied upon it.

BY MR. FLYNN: Let me ask you this: when you

found this in the document did you rely upon the fact that

pursuant to the handwritten instructions of Mr. Hubbard, the

Fair Game Doctrine was still in existence and had only been

modified in definition? and use?

 

 

 

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MR. LITT: Objection.

THE COURT: I will sustain the objection. It is

like reading it.

Q BY MR. FLYNN: Did you believe that this

was necessary for your legal defense with regard to

whether or not the Fair Game doctrine still existed?

A Yes.

Q And with regard to 500-6P through 6R, did you

believe that those were necessary for your legal defense?

A Yes.

Q And are those in the handwriting of

L. Ron Hubbard?

A Yes.

Q And we come now to a document which is of

some significance, Your Honor.

THE COURT: Okay. Then we will recess until

9:30 tomorrow morning.

 

 

 

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MR. LITT: Your Honor, may I make an inquiry just so

we have some idea of what we are dealing with in how much

longer Mr. Flynn intends to go on direct?

MR. FLYNN: I would estimate -- we are on 500 6Z. Your

Honor, I would estimate it would take an hour to finish.

When I finish the documents, I have one or two more questions.

THE COURT: What about the rest of those under seal?

Are you going to treat those in a general way and he can go

into them if he wants to, the other side?

MR. FLYNN: I'll ask him with regard to the rest,

whether the rest all relate to the matters set forth in these

in some manner or another and whether they all correlate in

such a way as to be relevant to his defense.

THE COURT: Counsel has the right to cross-examine

concerning any that he desires to. That will expedite the

process somewhat.

MR. FLYNN: How long would you expect the cross-

examination to be, Mr. Litt?

MR. HARRIS: About 10 days, Your Honor, so far.

THE COURT: Let's not make any dogmatic statements

because --

MR. HARRIS: I don't consider it dogmatic. It is a

good prediction, Your Honor.

THE COURT: We'll see.

MR. LITT: We are going into the fifth day of direct,

Your Honor.

(At 4:00 p.m., an adjournment was taken

until Wednesday, May 16, 1984; at 9:00 a.m.)

 

 

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