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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

REPORTERS' DAILY TRANSCRIPT

Tuesday, May 15, 1984

VOLUME 12

Pages 1860 through 2030, incl.

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APPEARANCES:

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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.)

1899

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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?

1900

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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.

1901

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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,

1902

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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.

1903

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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.

1904

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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.

1905

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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.

1906

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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.

1907

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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.

1908

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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.

1911

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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.

1914

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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,

1916

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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.

1918

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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

1919

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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.

1920

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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

1921

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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.

1922

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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.

1923

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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.

1928

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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.

1930

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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

1931

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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?

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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.