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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

Wednesday, May 16, 1984

VOLUME 13

Pages 2031-2173, incl.

 

APPEARANCES   (See Volume 11)

 

 

 

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

I

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INDEX FOR VOLUME 13

Pages 2031-2173, incl.


DAY DATE  
PAGE

Wednesday May 16, 1984 A.M. 2031
    P.M. 2097

WITNESS

DEFENSE:

    DIRECT CROSS
 
ARMSTRONG, Gerald
(resumed)     2031-F 2085-L
(resumed)
      2097-L

EXHIBITS

 

PLAINTIFF'S:
FOR
IDENTIFICATION
 

23- book, "Scientology: A World Religion
Emerges in the Space Age"

 

2169
DEFENSE:  

500 6S

500 6T

500 6U

500 6V

500 6W

500 6X

500 6Y

500 6Z


500 7A

500 7B

500 7C

 

- Black binder #276

- Yellow piece of paper & letter, 4-24-59

- letter, 9-25-73 & photographs

- Small card with writing & 2-page document

- 10-page handwritten letter to Explorers Club

- Copies of 2 letters & attachments

- 1-page report 12-21-76 & document 12-19-76

- letter 11-15-41, letter 4-1-46,
6 sheets blank stationery & certificate

- 4-page, 3-page & 2-page documents

- 2-page letter 5-25-52 & 4-page letter 6-14-52

- documents 10-29-81, 15 pages

2044

2063

2063

2066

2066

2066

2066


2066

2068

2069

2069
 

 

 

II

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INDEX FOR VOLUME 13 (Continued)

EXHIBITS

500 7D

500 7E

500 7F

500 7G

500 7H

500 7I

500 7J


AAA

BBB

CCC
- 1-page letter 11-17-80

- 2-page handwritten letter

- 2-page handwritten document

- NOT USED

- Copy of 1-page letter 7-29-80

- Two copies of documents "Data on L. Ron Hubbard"

- 2-page document 3-31-68, copy of note
4-4-68 and 1-page letter 3-20-68

- Copy of 2-page document 12-16-69

- Copy of document "Intelligence and Security"

- Copies of three dedications to Alexis
Valerie Hubbard in books by Hubbard
2069

2069

2069



2069

2069


2069

2047

2073

2138
 

 

 

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Los Angeles, California; Wednesday, May 16, 1984; 9:47 a.m.

---0---

 

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

record reflect that counsel are present.

 

GERALD ARMSTRONG,

resumed the stand, having been previously sworn, testified

further as follows:

THE COURT: The witness has retaken the stand. Just

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

under oath.

THE WITNESS: Gerald Armstrong.

THE COURT: You may continue, Mr. Flynn.

MR. FLYNN: Thank you, Your Honor.

 

DIRECT EXAMINATION (Resumed)

BY MR. FLYNN:

Q Now, Mr. Armstrong, do you recall letters that

were written by Mr. Hubbard to the FBI and the Defense

Department in the mid-1950's relative to Mr. Hubbard selling

brainwashing techniques to the FBI which you sent to me?

A I sent you letters from that period which my

recollection is were letters from Mr. Hubbard to the FBI and

to other government agencies, and I do recall letters to the

Defense Department. I don't know if Mr. Hubbard in those

letters stated that he was selling brainwashing to them.

 

 

 

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At times he claimed that he had a way of combating

brainwashing. At other times it appears that he had the

brainwashing technology. I don't recall the way it is used

in these letters. But it is on the subject of mental

technology. And the term "brainwashing" or something similar

is used within those letters.

Q And for what reason did you send that to me, those

letters?

A They evidenced Mr. Hubbard's continuing paranoia

which was from the 1940's through into the '50's and beyond.

And they showed that Mr. Hubbard was claiming at that point

to governmental personnel that the subject was a science;

they showed contradictions between what he has claimed in

other places publicly what Scientology is and what he was

involved in and what his intentions were.

Q And are some of those materials set forth in

exhibit 6C?

A Yes.

Q Turning now to exhibits 6E through 6Q which we

went through quickly yesterday which called for -- which

recited in Mr. Hubbard's handwriting that among other things,

he should find the unsavory part of a person's past and the

criminal activities of a person's past and pursue for

harassment and items of that nature, when you sent those to

me did you correlate the statements of Mr. Hubbard in those

documents to statements that he had made in what has been

marked exhibits 500 4D through 4G?

 

 

 

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MR. LITT: Objection, Your Honor.

THE COURT: Overruled.

THE WITNESS: Those 4D through 4G are the documents

that we have called at various times the affirmations or the

admissions, and there are some parts of those documents which

were very significant to me, having to do with --

MR. LITT: Just a moment.

MR. FLYNN: Well, before you get into this, Your Honor,

I'm going to do this on a very step-by-step basis, and then

I will lay the foundation, and then I will inform the court

of just several lines in the documents that correlate to

these documents which the witness found extremely significant.

Q Now, did you find several statements by Mr. Hubbard

in exhibit 4D through 4G that correlated to statements he

had made in the 1960's pertaining to attacks on enemies and

the Fair Game Doctrine?

A Yes.

Q And those statements are in exhibits 4D through

4G; is that correct?

A Yes.

Q And what was your state of mind, Mr. Armstrong,

when you found the documents in the 1960's in Mr. Hubbard's

handwriting relative to attacking enemies?

THE COURT: Maybe you better identify what are you

referring to now? Is this something in the 6 series?

MR. FLYNN: In exhibit 6.

THE COURT: Try to be a little more specific.

Q BY MR. FLYNN: 6E through 6Q.

 

 

 

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Now, in 6E you testified that Mr. Armstrong wrote

about finding the criminal part or past of a particular

individual; is that correct?

A Yes. It was Mr. Hubbard, yes.

This was a woman whose daughter had disconnected

from her pursuant to Scientology policy, and Mr. Hubbard had

ordered legal officer Branch 5 to investigate her past and

psychiatrists' past and find the criminal part -- criminal

past of these people.

Q Now at that time were you familiar with the Fair

Game Doctrine that has been marked as an exhibit to lie, sue,

cheat, and destroy enemies?

A Yes.

Q And in several other exhibits in Mr. Hubbard's

handwriting, did you find similar statements about finding

the unsavory side of their past with reference to enemies?

A Yes.

THE COURT: Now, what exhibit do you have before you?

MR. FLYNN: That is 6F.

MR. LITT: Where is the word "enemy"?

BY MR. FLYNN: And would you read that part which

refers to finding the unsavory side of their past?

MR. LITT: Let's have the whole paragraph.

THE WITNESS: Okay.

"As we are having local counsel

trouble, detach an investigator full time to

that situation with orders to isolate the two

or three members who give trouble and then to

 

 

 

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find the unsavory side of their past."

Q BY MR. FLYNN: Now, with regard to 6H did you

find similar statements in Mr. Hubbard's handwriting with

regard to 6H?

MR. LITT: What is the date of 6H?

MR. FLYNN: 16 December '66.

THE WITNESS: Yes.

THE COURT: Well, what specifically did you find in

that?

 

 

 

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Q BY MR. FLYNN: How many pages is 68,

Mr. Armstrong?

A It is approximately 20.

Q And are there specific statements or does the

document as a whole deal with attacking a particular

individual by a variety of means?

A Yes, they all have to do with attacking and the

use of the courts. The final paragraph reads:

"If we play this right, these

people go on trial, not us, and if we hit hard

enough with our statement, we may never even

have to appear in a courtroom."

Q Does that document also deal with finding

information about a person's past?

A Yes.

Q And is there a particular statement?

A There is here a number of -- those whole thing

refers to information which he wishes to make public about

these people and there are allegations if you want me to read

that.

Q Please do.

A (Reading:)

"Rather than just sue for libel,

additionally our statement of charges must

include the gory facts as follows: we have

attached to them from the Ministry of Health

a bitter man whom we have interviewed who goes

around sending people off for electric shocks

 

 

 

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in his opinion if they look depressed, and he

keeps a large number of the East Grinstead

population on heavy drugs to which there is

no end.

 

 

 

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"This can be added up into hypocrisy

and a grave concern.

"counsel has no grave concern over

the torture and death of their citizens by

psychiatrists despite the fact that these people

never get well after treatment.

"Psychiatry is a conspiracy to

injure people so as to extort funds.

"If we use -- I think it is --

"Werner's Demand, we have it in writing for

100,000 pounds. The bribe not to stampede

Parliament goes this way. He, a known blackmailer

and head of the community for national health

and national security, private group in Victoria.

"The theory behind our suits, the

theory in all of this is that we must state the

real problem and motive; only that blows it in

the third dynamic. We cannot defend as they can

come in with technology which can't be tried in

court; no technology can ever, as it is being

tried before laymen; thus, if we can force them

to countersue us for scare head charges, we can

prove they go into heaven; they are since tried

and not ours.

"We are very pale news copy. Theirs

is sensational, injury, murder, extortion,

insanity, misappropriation, aristocrat" -- I don't know

what the next word is -- "our objective is to cause

 

 

 

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Robinson to resign under a cloud just by filing

a suit, to cause psychiatry to be looked on as

an extortion racket that demands money under

the threat of torture.

"You'll find this will mob hysteria

people. And to cause Bal Neil and the connected

MP's to resign.

Q MP's is Ministers of Parliament?

A Members of Parliament.

"All of this on filing our suit

statement, when we have mopped up here, we'll

go to Victoria and overthrow that one; then,

South Africa and Rhodesia connection; thus, our

statement must be violent. A well-placed attack

should cause the enemy to prove our case by his

actions.

"Religious prejudice is horrid to

the English. So perchance that can be salted

in.

"In short, if we do this right,

we cause a political uproar, a stampede,

against psychiatrists and enough resignations

to make the enemy too weak to fight.

"If we merely defend, we have

only to keep to draw back to.

"Now is the time for all our

boiling oil before they batter in the main

gate.

 

 

 

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"The dishonest always have left

crimes lying around. So I set out to discover

them. When somebody attacks Scientology, it

happens accidentally. He almost always has a

criminal past. That is our good fortune for

all we need to do is expose it.

"So this is our basic theory

behind these current suits. They are savage

front line impact hitting at the real

intentions. If we hit hard enough, they won't

really recover; therefore, I have been working

out good screaming front-page news copy that

we can back up. We take us off the stand and

put them on. It will take a lot of impact.

This is not a court case. It is a filed

statements case.

"They went to government, that

private company, both national mental health

association, to hit us. So we have to remove

government from their line of attack.

"Counsel here used the NC planning" -- that

is, I believe, town and country planning -- "to

execute psychiatric attack on us. But how we

prove it, I am not sure.

"Right wing is a spit word in

world press today. So we must insert it where

we can.

"If we could write, but we can't,

 

 

 

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right wing torture groups run the largest multi-

billion dollar extortion racket in history.

"Would make world headlines.

"We can, however, insinuate it

any way we can. And thus snap left wing press

over on our side. If we play this right, these

people go on trial, not us, And if we hit hard

enough with our statements, we may never even

have to appear in a courtroom.

"The best.

"R.H."

 

 

 

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MR. LITT: Your Honor, may the record reflect that it

took Mr. Armstrong approximately 10 minutes and that he was

reading excerptions.

THE COURT: Well, I don't know what the time was, but

he did read. He left portions out. He read excerpts.

MR. FLYNN: Your Honor, we'd be more than happy to have

the whole document go into evidence.

THE C0URT: Let's not worry about that. Let's just

go on to the next question.

Q BY MR. FLYNN: Now, Mr. Armstrong, in exhibit 500

6J starting under paragraph eight, do you recognize that to

be in the handwriting of L. Ron Hubbard?

A Yes.

Q And did you find similar times of requests by

Mr. Hubbard to the organization to engage in the type of

activity that you just read; namely, finding criminal past

and activity of people to expose them?

A Yes.

Q And would you read that, please?

A There is a point here, number four, in a program

on handling this particular problem of -- it is an order to

Mary Sue, and he is hiring a Pinkerton detective and one of

the points is:

"We want evidence of collusion

between the person who signed the warrant for

Smith or his superiors and the APA or AMA" -- American

Psychiatric Association or American Medical Association --

"We want the name of every doctor who sought to

 

 

 

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get into this case and we want that doctor's

background. Trace it if possible to Communist

connections or orders from APA under AMA.

"The operative should understand

that we have been harassed by anti-American

interests in many past cases and that this

investigation is a routine assurance that we

always take. We have traced 18 out of 22 persons

publicly attacking us to criminal or Communist

backgrounds."

This is the part you were referring to?

Q And is there a part in Mr. Hubbard's handwriting

where he states that:

"He should also understand that

we are no crackpots. I am ex-B-3 of ONI. We

hold the only systems that can raise pilot

reaction time, increase the intelligence of

scientists and counter-brainwash. Russia has

been too interested in us since 1938 when they

offered $100,000 for the basic use of Dianetics

which when published in U.S. were hard hit by

Commi-connected persons."

Now, in these documents in referring to that

document 500 6I, 6K, 6L, 6M, which says "don't defend; attack,"

6N, 6O, relating to modifications of Fair Game, 6P --

MR. LITT: Your Honor, 6O -- Mr. Flynn -- the Court

ruled yesterday that 6O was privileged. Mr. Flynn

conveniently --

 

 

 

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MR. FLYNN: Strike 6O.

THE COURT: Strike the comment.

Q BY MR. FLYNN: 6P, "The suit is tactical. It

is not in hope of gain. We must attack"; 6Q and 6R, and

without going through the specific references in each and

6S dated October 8, 1961 relating to Michael Plynn and a

psychiatrist named Dr. John Clark.

Now, when you found those materials, were you

aware of the existence of the Fair Game Doctrine?

A Yes.

Q And at that time were you aware of the policy

of the organization to cull PC files, auditing files to

collect information from people such as yourself?

A Yes.

MR. LITT: Such as yourself at the time? What are we

talking about?

Q BY MR. FLYNN: Well, throughout the period of

time that you were involved in the organization, Mr. Armstrong,

did you understand that it was a regular practice to cull

auditing files and gain information on people such as

yourself?

A I only learned of that practice in 19 -- late

1975.

Q And how did you learn of the practice?

A I was working in the Guardian's office in Daytona

Beach and I saw a great deal of correspondence, both Telex

and written correspondence, which concerned people who were

viewed as enemies or potential threats in the correspondence

back and forth contained information taken from their PC files.

 

 

 

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Q And a PC file is what?

A During the process of auditing a person, a PC

or preclear is asked questions by another person, and auditor,

while the pre-clear holds the electrodes of an electronic

mechanism which is basically a lie detector which measures

galvanic skin response and other reactions. And the person,

the PC, answers the auditors questions. And the questions

can concern any part of his life, his history, his family,

his thoughts, virtually every aspect, every person he has

ever known, any familial connections, anyone of any

significance in his life; any incident in his life. And all

of this is written down in longhand in note form by the

auditor complete with time, place, form, and event. And under

some circumstances, when a Sec Check is being done, a lot

of details are gathered so that the exact time, who knew about

it, who was there, who should have known about it, any crimes,

anything for which the person can be blackmailed, all of this

stuff is recorded and those form the PC files, the auditing

reports.

Q Now, at some time did you learn that there was

a routine practice and a policy to cull those PC files by --

cull the auditing files by the Guardian's office and collect

that information to be used against the people who had been

audited?

A I learned of the practice when I was in the

Guardian's office in late 1975.

In 1976 and 1977 I was in the RPF in Clearwater.

And we were continually ordered to cull individuals' PC files,

 

 

 

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people who either asked to leave or were viewed as a potential

threat for whatever reason.

And anyone who asked to leave, their folders were

culled for any crimes, for anything embarrassing, anything

for which they could be blackmailed; a list of such crimes

or incidents was typed up into a statement which the person

had to sign before he could leave.

So I knew in 1975 of the practice of culling

folders.

In 1976, '77, I was engaged in it on a continual

basis as ordered by the Guardian's office.

In 1978 in La Quinta I also participated in it.

And it wasn't until after leaving the organization

that I saw a written order concerning that policy.

But I had been -- I knew that it was the policy.

And I participated in it; was ordered to participate in it

for several years prior to that.

Q And that was one of the reasons that you left

without routing out; is that correct, knowing that you would

be forced to participate in that?

A That is correct.

Q And is this document under the name of Mary Sue

Hubbard the policy that you saw later with regard to culling

PC files?

MR. LITT: I'll object, Your Honor. If he didn't see

it when he was in the Church of Scientology of California,

what relevance does it have to anything that has to do with

this case?

 

 

 

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THE COURT: Maybe to confirm the other part of his

testimony. I don't know what this is.

It is two pages of paper, printing.

THE WITNESS: Yes. This is the program order that I

saw there.

Q BY MR. FLYNN: Do you wish to see it, Mr. Litt?

MR. LITT: No. I have seen it from you before,

Mr. Flynn.

MR. FLYNN: May it be marked as next in order, Your

Honor?

THE COURT: Okay. AAA.

Q BY MR. FLYNN: Now, on the second page of that

policy it states, does it not, to --

MR. HARRIS: I'll object to what it states, Your Honor.

This witness, after he leaves the organization,

apparently gets this from Mr. Flynn who has passed it to

Mr. Litt as well.

MR. FLYNN: I'll withdraw it.

Q Is it your understanding, Mr. Armstrong, that

that policy is consistent with the testimony you have just

provided to the court?

A Yes.

Q What are processing files?

A Processing files are the auditing reports, PC

folders, PC files.

 

 

 

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Q Now, when you read the handwritten papers of

Mr. Hubbard and became aware of Mr. Hubbard's instructing

the organization to find a criminal past among other things,

and when you were aware in 1980-81 of the practice of culling

auditing files by the organization to use as you testified

for purposes of blackmail, did you correlate that to statements

made by Mr. Hubbard in exhibit 4D through 4G, 500 4d through

500 4G?

A Yes.

Q And what statement or statements did you correlate

it to?

MR. LITT: Objection; is this a question about 4D

et cetera or is this a question about 6?

THE COURT: I am not sure.

What do you mean by "correlate"?

BY MR. FLYNN: Did you understand that the practice

to use information about a person's past was used to control

the person and to attack them mercilessly?

A Yes.

Q And did you find evidence of that in 4D through

4G?

MR. LITT: Just a yes or no.

THE COURT: You can answer it yes, no, or you don't

know.

THE WITNESS: I need to qualify it a little bit.

THE COURT: All right.

THE WITNESS: I did not find within 4D onwards the use

of PC folders because that came later, but I did find

 

 

 

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information on the --- Mr. Hubbard's intention to be merciless

toward people who countered him and his statement that he

had the right to be merciless.

Q BY MR. FLYNN: And did you find a statement that

"men are my slaves"?

MR. LITT: Just a moment, Your Honor.

THE COURT: I will sustain the objection. Let's get

the document out, what exhibit you have reference to. Let

counsel see it and we will have a preliminary inquiry on

whether --

MR. FLYNN: This will be the last reference, I believe,

to this document.

MR. HARRIS: Thank goodness.

Q BY MR. FLYNN: While Miss Hart is trying to find

that, Mr. Armstrong, was it your understanding from 1975

onward that Mr. Hubbard used information from PC files to

control members of the organization?

A Yes.

Q And did you see that on a regular basis?

A Yes.

MR. LITT: You saw Mr. Hubbard?

Q BY MR. FLYNN: The organization on the orders

of Mr. Hubbard; did you see that on a regular basis?

A Yes.

Q And can you find the reference?

And on 4D what is the eighth --

THE COURT: Do you have this exhibit 4D?

MR. LITT: Eighth page? My 4d has two parts to it.

 

 

 

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MR. FLYNN: There is no numbering.

THE COURT: Yes, it starts with "forced to" at the top.

Q BY MR. FLYNN: And on 4F --

THE COURT: Well, let's do one thing at a time.

MR. LITT: Your Honor, after the court looks at it,

I think we are going to have to look at your copy.

 

 

 

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THE COURT: Have counsel had a chance to find it?

MR. HARRIS: We're not sure where it is, Your Honor.

THE COURT: You can approach the bench over here and

you can refer to the Court's exhibit.

MR. FLYNN: Your Honor, to save time, they might want

to look at this part while they are at it.

I have a few more foundational questions, Your

Honor, and then I would like to read the one sentence

starting with "Men" and the other sentence starting with

"You can be. . ."

THE COURT: Well, what are your questions that you want

to ask?

Q BY MR. FLYNN: Mr. Armstrong, after you left the

organization you knew that a Suppressive Person Declare had

been issued on you; is that correct?

A Yes.

Q And I take it you were aware of the practice of

culling PC files?

A Yes.

Q And was it your belief at the time that the

organization had culled your auditing files?

A Yes.

Q And when you left the organization before the

SP Declare was issued on you, what was your state of mind

with regard to whether or not the organization would use those,

PC files against you?

A I hoped that they wouldn't, but I recognized that

it was very likely.

 

 

 

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Q Now, is your entire life history and virtually

every incident that you have been involved in in your life

set forth in those PC files?

A Yes.

Q And when you were working or between 1980 and

1981 did you begin to have a developing awareness that you

had been the slave of L. Ron Hubbard while you were working

for $4 a week, 100 hours a week?

MR. LITT: Your Honor, this --

MR. HARRIS: His opinion, I guess,

MR. LITT: This is ridiculous. I mean --

THE COURT: It depends on the eye of the beholder what

is ridiculous and what is not.

MR. LITT: Mr. Armstrong was voluntarily in the church

while he was in the church. If he regrets it now, he is

entitled to do so.

But are we going to have in testimony that he

was a slave while he was in the church?

THE COURT: I suppose it is a conclusion.

MR. FLYNN: Your Honor, it does relate to the issue

that Mr. Armstrong relied on extensive representations of

Mr. Hubbard. Whether he was voluntarily in the church goes

to whether he was defrauded and believed those representations

to be true and later found them to be false.

The element of voluntariness goes to the element

of misrepresentation.

MR. LITT: Which goes exactly to the religious fraud

issue that we have said all along which is really at the heart

 

 

 

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of this theory.

MR. FLYNN: Whether L. Ron Hubbard is a nuclear

physicist?

THE COURT: Gentlemen, you get off on these little

tangents and get me away from the point we are trying to

resolve.

Let's go back and have the question read.

(The pending question was read.)

 

MR. LITT: I think the court sustained the objection.

THE COURT: It is a compound question as well as

conclusionary; it is rather leading as well.

BY MR. FLYNN: What, if any, understanding did

you have in connection with your working for L. Ron Hubbard

between 1980 and 19817

MR. HARRIS: We have been through this. This has been

asked and answered before about a half dozen times.

He thought he was working for L. Ron Hubbard.

THE COURT: I am not sure that is what counsel wants

to develop at this time, having in mind his previous question.

BY MR. FLYNN: Specifically with reference to

exhibit 4D through 4G --

MR. HARRIS: I'll object. 352 at this point, for sure,

Your Honor.

It is now cumulative and prejudicial. It

outweighs any relevance. He has been through all of this

before.

THE COURT: When did you first read these documents

 

 

 

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4D and 4E?

THE WITNESS: sometime in 1980.

THE COURT: Well, did that create any impression in

your mind about your status in the church or in your

relationship with Hr. Hubbard?

THE WITNESS: Your Honor, from that point onward there

was a continuing and a growing awareness that I had been used

and that I had continued to be used and that I had through

representations and various physical and mental mechanisms,

had been virtually enslaved by the man.

THE COURT: Ask your next question.

BY MR. FLYNN: And did you correlate that to

Mr. Hubbard's intentions which he set forth in his writing

in 1946 as set forth in exhibit 4D and 4E?

MR. LITT: I'll object, Your Honor. It is absolutely

impossible for a reasonable person to draw any conclusions

from those documents about this issue and what intentions

are expressed.

The Court has read it and cannot reasonably draw

a conclusion about what it means; so whatever conclusions

Mr. Armstrong drew have to have been from other things. And

under Section 352, we would ask that testimony of this be

excluded. It is not reasonable. It is -- you can't reasonably

construe that statement to mean anything.

The beginning of one of them, it says, "You are

not accountable for anything that is said here."

So how is it that one can reasonably be relying

on this?

 

 

 

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Whatever Mr. Armstrong relied on, it is not this.

And it is just an effort to get into what is extremely private

and it should not be allowed. And it is not particularly

germane to this case.

I just don't think that the court should permit

this constant effort to sort of push and push here and there

to try to get portions of this document in.

 

 

 

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THE COURT: Well I think that the witness should be

permitted and can be permitted to testify as to what his

state of mind was. What his belief is and whether or not

it is reasonable, that is for the court to conclude at a later

date. If these had some bearing upon his state and mind and

why he did what he did, it seems to me it is relevant and

admissible. So, I will overrule the objection.

MR. LITT: Is the Court going to permit a reading from

this?

THE COURT: Those excerpts and, of course, if you want

in later testimony to develop the context or something to

affect it, you may do so.

Please identify the exhibit that you are referring

to before you do it.

MR. FLYNN: 4D, 500 4D.

Q It states, "Men are your slaves."

Is that correct, Mr. Armstrong?

A Yes.

MR. LITT: Well, doesn't the next sentence get read,

too?

MR. FLYNN: We will read whatever you wish, Mr. Litt.

MR. LITT: Let me just take a look at it first.

Can I see that, please?

MR. FLYNN: Do you wish me to read it?

MR. LITT: The next sentence only.

MR. FLYNN: (Reading:)

"Elemental spirits are your slaves."

Q And referring to exhibit 4F it states, "You can

 

 

 

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be merciless whenever your will is crossed and you have the

right to be merciless"; is that correct, Mr. Armstrong?

A Yes.

Q Now were you here when Mary Sue Hubbard testified

that she was mentally raped by your having possession of the

documents under seal?

A Yes.

Q And I believe you --

MR. HARRIS: I think that misstates the testimony.

She was mentally raped because he sent them to

Mr. Flynn, Your Honor.

THE COURT: I am not quite sure. It sounds like that

is my recollection, but we have the actual words here. Let's

go on. That is just a point of reference.

Q BY MR. FLYNN: Now, as you sit here on the witness

stand today and prior to your cross-examination, you are aware

that all of your PC files are in the possession of the

plaintiff in this action; is that correct?

A Yes.

Q And when the SP Declare was issued on you, were

you fearful of that fact?

A Yes.

THE COURT: Well, when the PC goes into an auditing

session, are there any representations made whether or not

anything he says is in confidence or is he under an

understanding that everything he says is going to be

available for later use?

THE WITNESS: Your Honor, when I first became involved

 

 

 

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in Scientology, I asked on that specific point and there are

representations made within Scientology literature and by

Mr. Hubbard that the information is kept confidential.

It wasn't until some six or seven years later

that I learned that, in fact, it was available for use by

the Intelligence Bureau of the organization, and the fact

that it was used, could be used however they wanted.

THE COURT: Did you rely upon those representations

of confidence?

THE WITNESS: The initial ones?

THE COURT:Yes.

THE WITNESS: Yes.

THE COURT: All right, you may continue, counsel.

BY MR. FLYNN: Now, the policy of representation

is set forth in several publications, including the Auditors

Code; is that correct?

A Yes.

Q Now under what circumstances did exhibit 500 6S

"Estimate in Reader's Digest" come into your hands?

A This was provided to me to give to Mr. Garrison

by Vaughn Young sometime in the fall of 1981.

Q And did you read it at that time?

A Yes.

Q Did you provide it to Mr. Garrison?

A Yes.

Q And did that confirm your understanding that the

organization was, as you put it, acting as an intelligence

agency in collecting hundreds of files on people including me?

 

 

 

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A Yes.

Q And with respect to a list of people, including

Michael Flynn, Paulette Cooper, Reader's Digest, Rockefeller,

L., Margaret Singer, Nan McLean, Eugene Methvin, and John

Clark, was there an indication that 30 feet of information

had been gone through and 200 files to make up a set of index

files?

A Yes.

Q And did you check the accuracy at any time of

the information contained in exhibit 6S?

MR. HARRIS: "At any time" while he had it in his

possession or before he left the church or at any time in

Mr. Flynn's office? What is the reference, Your Honor?

Q BY MR. FLYNN: Before you left the church, did

you attempt to try to check the accuracy of exhibit 6S?

A I don't believe that I did anything at that time.

I provided it to Mr. Garrison with -- I had understood that

it was accurate at that tine, that everything that was laid

out here was exactly -- not that the substance o£ the reports

were accurate because I had by that time begun to perceive

that, in fact, there were no enemies who sere out to get

Scientology, that that was a created mechanism by which to

keep the troups in line.

 

 

 

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But I assumed that the information given on the

amount of data collection and amount of volume of the files

which were examined in order to come up with this estimate

were accurate.

Q And after you left the organization, when you

were working for Mr. Garrison, did you make any efforts to

ascertain the accuracy of the contents of the exhibit 6S?

A I believe only in -- I questioned you as to the

accuracy of some of the allegations in here, the connections

to the Rockefellers and to John Clark.

Q And did exhibit 6S confirm for you that the

organization had been collecting files on people such as

myself?

A Yes. I already knew that. So it never really

acted as a confirmation so much.

The mass of it, I was not perhaps totally aware

of. But it was a -- it was just another fact which was added

to the already growing awareness of these activities.

I myself was in the Intelligence Bureau both on

the ship and in Daytona. So I was already drilled in

intelligence acitivities and on data collection, so forth.

Q What was your state of mind before you left the

organization, Mr. Armstrong, with regard to how the

intelligence agency of the church collected information on

people such as myself?

A Well, they used whatever source, either covert

or overt in the data collection.

Overt data collection would simply be going

 

 

 

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through old newspapers or public reports or all the -- in

your case, going through all the files for any trial which

you had been involved in; examining the backgrounds of your

clients, of your family. This would be involved with an overt

data collection.

Then there would be a covert data collection which

would be getting someone in close to you, putting a plant

in your office; putting a plant in the office of someone

connected to you.

MR. LITT: These are --

MR. HARRIS: Let him go. It is state of mind.

Q BY MR. FLYNN: Go ahead.

MR. HARRIS: This is being offered for state of mind,

as I understand it?

THE COURT: Well, I don't recall at this point.

Q BY M. FLYNN: The question was specifically what

was your state of mind; is that correct, Mr. Armstrong, before

you left the organization with regard to how information is

collected by the church?

A Right. This is what I knew at the time on the

methods of data collection, the specifics of how that would

be done. As an intelligence personnel, this is how I would

go about collecting information on you and which I knew the

organization, if they were collecting information on you,

would go about doing it.

Q Did it range from outright burglary to looking

up in newspapers, collecting information?

MR. LITT: Objection.

 

 

 

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THE COURT: I don't know what "outright burglary" is.

I have heard of a righteous burglary.

Q BY MR. FLYNN: What was your understanding as to

the means the organization used, Mr. Armstrong?

MR. HARRIS: His state of mind as to the means; is that

the question, rather than understanding?

THE COURT: I guess it is state of mind, Understanding

is a state of mind; belief is a state of mind; knowledge is

a state of mind.

 

 

 

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THE WITNESS: Data collection which I have mentioned

and within covert activities such as burglary, theft,

plants, blackmail.

Q BY MR. FLYNN: And did you understand that

to be an ongoing practice of the organization throughout

the period of time that you were involved?

A I did not know of it probably until some

time in probably 1980. I became very aware of the extent

of the covert intelligence activities.

Q And was that a factor with regard to giving

or sending to me all of the documents that you sent to me;

namely, the organization's collection and use of

information against enemies?

A Yes.

Q And at that time you perceived yourself to

be an enemy; is that correct?

A Yes. I should say that I believed that they

perceived me to be an enemy.

Q And why did you send me exhibit 500-6T?

A This covers a time when Mr. Hubbard was on

probation, I believe in 1950 or 1951 in San Luis Obispo,

I believe, although I am not sure. I can't see there.

In any case, it showed that Hr. Hubbard had

been apparently convicted of a crime or a misdemeanor

or something and had been put on probation in 1950.

Q And with regard to exhibit 500-6U, why did

you send me those collection of pictures with a dispatch

from a Terry Milner?

 

 

 

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A This is a letter from the then DGNF US.

That is the head of the intelligence bureau in the United

States, and it was addressed via Mary Sue to Ken Urquhart

was the LRH personal communicator on board the ship at

that point. It is dated 25 September, 1973, and it

concerns the photos which are in this envelope here and

indicated that the -- it states that the photos -- it

says, "Actually most of it belonged to Nibs."

Nibs was L. Ron Hubbard, Jr., and I knew of

the - that Nibs or L. Ron Hubbard, Jr. was viewed as

an enemy by the organization, and there was a possibility

from this dispatch that these photos had been stolen from

Nibs. Hence I sent it to you.

Q And did you determine whether or not there

was a conflicting claim between the organization as to

whether Nibs had given the photos voluntarily or as to

whether they had been stolen and whether anybody had been

requested to sign a particular document with respect to

them?

MR. HARRIS: That is about three compound questions,

Your Honor.

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

Q What if anything, did you learn about the

dispute over these photographs, Mr. Armstrong?

A I don't know of a dispute over the photographs.

However, in connection with -- or a conversation with

Nibs, he said --

MR. LITT: Can we have a time frame here.

 

 

 

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THE WITNESS: Yes, this was probably a month ago,

something like that.

MR. LITT: Your Honor, this is supposed to be why

he sent these things. It was done well before a month ago.

THE COURT: Well, he's already testified. This

goes to something else, but I don't know if it is terribly

relevant.

MR. LITT: It is hearsay.

MR. FLYNN: I will withdraw it.

THE COURT: Let's take a 10-minute recess.

(Recess.)

 

 

 

 

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THE COURT: In the case on trial, let the record reflect

that counsel are present; the witness has retaken the stand.

State your name again for the record, sir. You

are still under oath.

THE WITNESS: Gerald Armstrong.

MR. FLYNN: Your Honor, I think I am very close to

completing the direct examination.

Q Mr. Armstrong, with regard to 500 6V through 500

6Y, did you send those to me to assist in the defense of the

claims that the organization vas making against you?

A Yes.

Q And with regard to 500 6Z, why did you send my

office that?

A This file contained a number of blank pieces of

stationery, one from U.S. Naval Hospital and another, a letter,

apparently, on Explorer Club stationery and signed by a Robert

Lees. And it is sort of a letter of recommendation for

Mr. Hubbard.

My belief is that Mr. Hubbard in fact wrote it

and signed it for Mr. Lees.

 

 

 

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I sent you this stuff because I had come

across in the course of this biography research a number

of such documents which appear that Mr. Hubbard had written

on someone else's letterhead, letters for himself or had

filled in for someone else, and in one case a fitness

report and in another case a statement of the medals that

he had earned during the war, and that was just to me a

small evidence of the type of fraud is which Mr. Hubbard

engaged.

Q Now, is one of those documents that you

referred in your last answer a document involving a

Commander Thompson which is not under seal?

A Yes.

MR: LITT: Would you say that again? I missed that.

THE COURT: Which is not under seal.

MR. LITT: Is one of those documents in 6-V not

under seal? Is that the question?

MR. FLYNN: No.

Q Is one of the documents you referred to

that evidenced Mr. Hubbard's signing someone else's name

as evidence of the fraudulent activity of Mr. Hubbard

not under seal?

A Yes.

Q And where did you last see it?

A Inside the organization.

Q And what is that document?

A It was a -- either a fitness report or

something similar around the time of the end of the war,

 

 

 

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and there is a signature on it by a Commander Thompson,

and the signature, my recollection is, is done in a broad

blue pencil crayon or a blue marker of some sort, not a

felt marker but a crayon marker, and I had other materials

from that period in Mr. Hubbard's writing which were also

done with this same marker.

THE COURT: I think it is probably conclusionary.

You can say it is a similar marker.

THE WITNESS: That is correct, Your Honor.

Q BY MR. FLYNN: Now did this document contain

representations about Mr. Hubbard's Naval background which

was totally contrary to every other document you found in

his Naval records?

A Well, what comes to mind is the number of

medals which are listed on this particular document, and

it was a different number of medals. He was awarded four

medals during the war. He has claimed to Scientologists

two numbers, one being 28 medals and palms; one being 21

medals and palms, and this was a figure in between those

amounts, in between 4 and 21, and gay recollection is that

it also included a Purple Heart.

The Purple Heart later showed up in a

color photograph of the medals which Mr. Hubbard claimed

he had been awarded during the war.

Q And was it your belief that Mr. Hubbard had

written this document?

A Yes.

Q Now with regard to exhibit 7-A, Mr. Armstrong,

why did you send my office that document?

 

 

 

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A This document dated 4 March, 1967 which is a

dispatch from LRH entitled "Saint Hill and OT Activities,

Expenses," this document has to do with the original -- the

origins of the Sea organization, payment of Sea organization

personnel then called the Sea Project and Mr. Hubbard's paying

these people at this time.

Q As their being employees of Mr. Hubbard?

A Yes.

Q And with regard to exhibit 7B through 7H, did

you send me these materials to defend yourself, Mr. Armstrong?

A Yes.

Q And among those documents, was exhibit 7F written

by Mr. Hubbard to be signed by a Tom Esterbrook?

A Yes.

Q And with regard to 7I, is 7I data on L. Ron

Hubbard?

Did you send me 7I as more data on L. Ron Hubbard's

background, his claims about his background?

A Yes.

Q And, lastly, exhibit 7J; what did you send me

7J?

A This set of papers refers to Hubbard Explorational

Company, OTS and this contains Mr. Hubbard's handwriting in

places and his initials. And it is signed by him. And it

refers to transfer of monies from HEC, OTS, LRH, CFS.

Q And did you believe that necessary to prove as

part of your defense that L. Ron Hubbard had been receiving

monies from the Church of Scientology?

 

 

 

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A Yes.

Q Now, with respect to all the documents that have

not been brought up, but are presently found under seal which

have not been marked as exhibits in the 500 series, why did

you send me those documents?

A The complete mass of documents which is what --

whatever I was able to obtain from Hr. Garrison which he,

for the most part, had duplicate copies of for the biography

project, the mass of them together show a complete picture

or, at least, a more complete picture than the exhibits which

we took out of that mass of documents. All of them add to

the overall picture regarding Mr. Hubbard and regarding his

use of the organization, his control of the organization;

the misrepresentations of his academic credentials and military

career and so on.

The whole thing together gives a very complete

picture of those facts.

Q Now, when Terry Gamboa told you to get a lawyer

and you received the SP Declare, were you aware of the policy

of L. Ron Hubbard regarding the use of the law set forth in

the Level Zero Check Sheet?

A I was. I was aware of the way that Mr. Hubbard

had used the law and ordered the organization to use the law.

I was aware that the law was used in order to

attack individuals, in order for the purpose of harassment.

So if that is what you mean, I was aware of that

fact.

Q And was it your belief at the time that you

 

 

 

 

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retained me, Mr. Armstrong, that you were going to be attacked

through the law by Mr. Hubbard's organization?

A Yes.

Q And what, if anything, did you believe with regard

to the scope of the litigation that Mr. Hubbard and his

organization could subject you to?

A I didn't know the scope in legal terms, but I

knew they could bring incredible weight both legally and

extra-legally against me.

Q And based on that belief did you send me as many

documents as you felt you could obtain that you could use

to defend yourself?

A Yes.

 

 

 

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Q Now, in your SP Declare you were accused on

April 22, 1982 of:

"Being found to be promulgating

false information about the church, its founder

and members. He used his position to create

and transmit erroneous information under the

guise of documentation. Altered documents have

been found in this area."

Was that of particular significance to you?

A What that signified to me was that the

organization was carrying out what is called inside a

"Black Propaganda Campaign" in order to discredit me,

in order to discredit the statements which I made about

Mr. Hubbard, about the organization. That was the

significance that that had.

I saw that this document was being put

out within the Scientology network and connected organizations

internally, and that the purpose was to create an

atmosphere into which it then became acceptable for further

acts by the organization or by the intelligence operatives

or as it turned out by private investigators against me.

Q Now, at that time were you familiar with

the policy regarding Black Propanda written and copy-

righted by Mr. Hubbard set forth in what has been referred

to as the Green Books?

A Yes.

Q And again what are the "Green Books,"

Mr. Armstrong?

 

 

 

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A The Green Books are the public published

policy, mostly written by Mr. Hubbard, having to do with

Scientology organization policy. They are statements of

policy. They are policy letters which are supposed to

govern Scientology organizations.

MR. FLYNN: May that be marked as the next

exhibit in order, Your Honor?

THE COURT: Triple B.

MR. HARRIS: Which appears to contain a potpourri

of items. It is collectively, I suppose.

THE COURT: Yes, collectively.

Q BY MR. FLYNN: Now, what did you understand

the basic policy as set forth in exhibit triple B with

regard to Black Propaganda to be, Mr. Armstrong?

A That Black Propaganda was false statements

from hidden sources designed to discredit and destroy

the reputation of the person who was being lied about.

Q And when you read the SP Declare with regard

to altered documents and making false statements about

Mr. Hubbard, did you believe that to be part of the policy

on Black Propaganda?

A Yes.

Q What if anything was your belief with regard

to the necessity of procuring documents from Mr. Garrison

to defend yourself against Black Propaganda?

A That it was necessary.

Q Now there was a statement on the Suppressive

Person Declare dated April 22, 1982 of about your espousing

 

 

 

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the views of Timothy Leary?

A Yes.

Q Is there any truth in that allegation on

the SP Declare, Mr. Armstrong?

A No.

Q And did you consider that to be Black

Propaganda?

A Yes.

Q And what was your state of mind with regard

to why that charge was made in the SP Declare?

A I saw a couple of possibilities, the first

that is that it came out of whole cloth, that it was part

of the Black PR campaign. It was to set up an atmosphere

inside the organization so that people inside the organization

did not believe me but felt that I had freaked out on LSD

or that I had gone off the deep end.

The other thing was I had already been told

by Laurel just a week or so prior to leaving that she

knew of operations in which LSD was put in people's

toothpaste so there was another threat I felt from that

quarter, and the other possibility was the planting of

drugs on me.

Q Now at the time you left did you know or had

you seen a declaration of an Ann Rosenbloom?

A Yes.

Q And did Miss Rosenbloom work in the Commodore

Messenger's org for Mr. Hubbard?

A Yes.

 

 

 

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Q And were you aware that drugs had been put

in one of her drinks by a Joseph Lisa?

A I had seen that, I believe. I do not recall

the specifics of it. I had heard that within the

organization.

Q Now, do the use of drugs have particular

significance to a Scientologist?

A Yes.

 

 

 

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Q In what sense?

A To a Scientologist who is not in the inner circle,

at the top of the organization working directly with

Mr. Hubbard, it is viewed that drugs are not to be used.

In fact, aspirin is not to be used. And one can't

be audited within a certain time of having even used aspirin.

Even medical drugs are frowned upon. And street

drugs of any description, certainty, are frowned upon.

Q And, if any, bearing did that have in your mind

with respect to the claim that you were associated with

Timothy Leary?

A This was an effort to discredit me by connecting

me up to LSD and Timothy Leary.

Q Now, in 1978-1979 when you were working with

Mr. Hubbard at La Quinta and at Gilman Hot Springs did you

have the opportunity to observe his behavior?

A Yes.

Q And what did you observe?

A During the period in which we were shooting movies

in La Quinta and out in the desert and at various locations,

I was able to observe him for long periods of time on a daily

basis several hours a day. And my observation was that his

behavior was highly irrational.

He yelled, in my opinion, without meaning. He

raged at people. He swore a great deal. His language was

atrocious.

I was definitely in fear because of the way that

he raged at the slightest little thing on the movie set.

 

 

   
 

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His messengers -- he was continually surrounded

by messengers. And they acted the same way, yelling at people

on the set, yelling at the various units for not performing

their functions correctly. It was highly irrational.

Q Was he abusive?

A Yes.

Q And did he assign people to the rehabilitation

project force for minor infractions?

A Yes.

Q Now, in the summer of 1983 did you become aware

that Mr. Garrison had reached a settlement with Mr. Hubbard's

representatives?

A Yes.

Q And at that time what, if any, formal offer did

you make to the plaintiff and the intervenor with regard to

returning documents that are under seal?

MR. LITT: Are we -- it is fine with me if he wants

to go into settlement matters in this case. But I assume

that is what is happening now?

MR. FLYNN: Your Honor, they offered the letters of

Mr. Peterson with regard to making the demand for the return

of the documents.

MR. LITT: It is an element of the case, Your Honor.

MR. FLYNN: It is our belief that the first time that --

MR. LITT: That is fine. Okay,

Q BY MR. FLYNN: What, if any, formal offer did

you make for the return of the documents under seal,

Mr. Armstrong?

 

 

 

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A What I went over with my attorney Bruce Bunch

and my understanding that he relayed to Mr. Litt at that time

was that we would deliver to Mr. Hubbard or his agents any

of the materials which would not be needed for the defense

of this case or the cross-complaint.

We requested that copies of any of the originals

which we deemed were necessary for evidence would be provided

to us and that the originals could be delivered to Mr. Hubbard.

Q Why did you send my office original documents?

A I guess because that is what I had. But I --

my reasoning at the time was that original documents would

be necessary in order to assist in the authentication of

all of these materials.

Mr. Hubbard had been claiming since a long time --

and I knew of his letter from 1953 or 1977 to Mr. Garrison

which ultimately made its way to Mr. Garrison in which he

claimed that his records had been stolen in 1953 and that

the government had been putting forged or altered documents

into his dossier.

I had heard this a number of times just prior

to leaving.

A man by the name of Harvey Haber, who was an

organization person then in charge of selling Mr. Hubbard's

fiction work, "Man, The Endangered Species," which later was

renamed "Battle Field Earth," he at that time had or had

seen, but in any case, had in his hands at one time just

prior to that, somewhere around December, 1981 --

 

 

 

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MR. LITT: Is that what Mr. Haber told Mr. Armstrong?

THE WITNESS: That is correct.

MR. HARRIS: There will be an objection; hearsay

unless it is for again --

THE COURT: Well, it is his state of mind. Had to

do with the originals.

THE WITNESS: That Mr. Hubbard had stated that he

had heard that there was some questions regarding statements

he had made about his past, and he stated, and this was

relayed to me by Mr. Haber that he wanted everyone to

know that this dispatch had gone from Mr. Hubbard to

David Miscavige.

Anyway he wanted everyone to know that

everything Mr. Hubbard had said about himself and

everything that the PR's had said about him was, in fact,

true, and I had a great deal of concern that the organization

might come out and say that all these documents are

forgeries because if they were copies, I certainly was not

going to have their assistance in the authentication of

these documents. This is a claim which has been made

before and I was concerned about it.

So, I had originals and rather than copy

them all at expense which I couldn't afford, and because I

felt that we would run into an authentication problem or

perhaps that these were all FBI created documents, I

elected to send you originals.

Q BY MR. FLYNN: And, in fact, in your SP Declare

you were accused of alteration of documents; is that correct?

 

 

 

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A That is correct.

Q Now, has it been your belief and under-

standing, Mr. Armstrong, throughout this litigation that

the Church of Scientology has had copies of all

documents under seal or Mr. Hubbard's representatives?

A My belief is that they have copies of

virtually/all of it, copies in one form or another.

Q And what is the basis for that belief?

A Because of the nature of the documents

which are herein because of the place from which they had

come, because of the subject matter, because of the

organization's interest in these things, and because of

the -- those are areas in which documentation would have

been collected by B-1 in order to handle the questions

which continually come up in these areas.

Q Now in your deposition you were asked about

the source of originals from two areas in which you said

you didn't believe that there were copies left in those

two sources; you recall that testimony?

A Whether or not I had left materials in

archives?

Q Correct.

Q Now when you answered that question, was it

your belief at the time that there were copies in other

areas other than the two that you were questioned about?

A My belief is that for at least the vast

majority of the originals which are under seal there are

copies, either copies of the letters, copies of the documents

 

 

 

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under seal or within the organization, either at GOWW,

GOUS, my archives, Controller archives. Some of them were

went to Mr. Garrison. So, my belief is that the vast

majority of them, I have no way of confirming that, but

knowing the contents and knowing the location from which

they came, that is my belief.

MR. LITT: Just a moment. Is this being introduced

for his state of mind as to why he sent originals because

if it is introduced for fact, it is not fact and his

opinion without fact as to whether there are things in the

archives to establish that there are such things in the

archives is improper because there is no foundation for

that.

THE COURT: Well there is no way for him apparently

to go check the archives, and I will overrule your

objection. He can give his opinion on that subject. The

weight to be given to it is something else again.

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

it is necessary to have possession of copies of the

documents that are under seal for purposes of prosecuting

your cross-complaint?

A Yes.

Q While you were collecting the documents,

did you have conversations with Laurel Sullivan regarding

inurement to Mr. Hubbard in connection with your services

as an employee of Mr. Hubbard's?

MR. LITT: Objection. This is going back directly

into MCCS, Your Honor.

 

 

 

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THE COURT: I don't know whether it is or it isn't.

MR. LITT: But we have to establish that before

he answers the question and goes into attorney-client

privileged areas. Apparently from the --

 

 

 

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MR. FLYNN: It has nothing to do with MCCS, Your Honor.

MR. LITT: May I finish, please, Mr. Flynn? And then

you can speak.

Thank you.

Your Honor, I think there should be an inquiry

whether or not anything about "inurement," was placed upon

consultation with attorneys concerning various tax matters.

I think the court will find that whatever

Miss Sullivan said was as a result of consultation with

attorneys and plans that were being developed in relationship

thereto.

I think that it is appropriate for there to be

that preliminary inquiry before this simple question is asked

under these circumstances.

MR. HARRIS: Also, Your Honor, I understood that

Mr. Flynn was going to put Miss Sullivan on the stand and

then he would recall him in respect to those items.

MR. FLYNN: This has to do with the biography project,

Your Honor, and his understanding with regard to during the

biography project he had to be an employee of Mr. Hubbard

because if he wasn't an employee of Mr. Hubbard, it would

have been inurement to Mr. Hubbard if he was an employee of

the church and a violation of the Internal Revenue laws.

MR. LITT: And presumably some lawyer who might be right,

might be wrong and some lawyer whose advice may have been

followed or may not have been followed, if that is --

THE COURT: We'll receive it to show his state of mind

on the subject.

 

 

 

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The objection is overruled.

Q BY MR. FLYNN: What was your understanding, aside

from any conversations with any lawyers, Mr, Armstrong, with

regard to who you worked for and why when you were doing the

biography project?

A That was at that time inurement which was a

subject which was discussed between Laurel and myself a great

number of times. And in those conversations, it -- what was

discussed and the conclusion was reached was that because

I was involved in a project directly working for Mr. Hubbard

for which he would make a great deal of money, I had to be

paid by Mr. Hubbard and could not be a part of the

organization; otherwise, the inurement charge would follow.

MR. FLYNN: Your Honor, that is all I have on direct with

the one proviso we had previously discussed about Laurel

Sullivan.

I have an exhibit coming that I would like to

put into evidence that is the book that Mr. Armstrong

mentioned, "The Science of Survival" that is dedicated to

the daughter of L. Ron Hubbard, Alexis Valerie. I don't have

the book at the present time. I am supposed to receive it

at 1:30.

THE COURT: We'll worry about that later, then.

You may cross-examine, Mr. Litt.

MR. LITT: Well, actually we are both in the course

of time going to cross-examine, but on different subject

matters.

THE COURT: All right.

 

 

 

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CROSS-EXAMINATION

BY MR. LITT:

Q Mr. Armstrong, when you left the church on

December 12, 1981, aside from archives materials, what

materials did you take with you?

MR. FLYNN: Your Honor, at this point it is my

understanding that the defense or the plaintiff and the

intervenor, having in their case read excerpted portions of

Mr. Armstrong's deposition, are precluded from re-examining

in areas that constitute the areas which have been read into

the record from excerpted portions of the deposition.

This question was specifically asked and answered

in the excerpted portions of the deposition.

THE COURT: I am not any more anxious than anybody else

to have a lot of repetitive testimony. But on the other hand,

I don't know if there is anything that precludes the cross-

examination unless it is cumulative or unnecessarily

repetitive.

At this point I would overrule the objection.

MR. FLYNN: Would you just note my objection to any

area which is repetitive to what has already been read as

the record subsequently shows?

THE COURT: I'll deem that you are making it. I have

no way, of recalling at this point what has been read and what

hasn't.

Let's go forward anyway. We are past square one.

Do you remember the question?

THE WITNESS: Yes. Your Honor.

 

 

 

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THE COURT: You may answer it.

THE WITNESS: Here, on the final day when I finally

left --

Q BY MR. LITT: Let me clarify my question.

My question isn't what you took out on that day,

but up until that day; in other words, through December 12

what material other than archives material had you taken from

church files or copies thereof?

MR. FLYNN: Your Honor, again, I don't intend to keep

on objecting.

THE COURT: Why are you doing it, then?

MR. FLYNN: Church files; we believe they are L. Ron

Hubbard files.

If it could be understood that church files mean

L. Ron Hubbard files, I won't object. But the statement of

Mr. Wertheimer in his letter that all of these documents are

in the ownership and possession of L. Ron Hubbard, we believe

is pretty conclusive evidence that that was the case at the

time.

THE COURT: For whatever it is worth, the church is

taking the position that they were the bailee of these

particular documents. And the question is being asked in

that context. So rather than get into any discussion over

who was the owner, we'll take it in that context.

You may answer.

THE WITNESS: The documents which I had which were in

addition to archives documents which I viewed were my documents

were copies of any financial transactions or, at least,

 

 

 

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whatever I had from as long as I had been involved or as long

as I had been collecting those records.

I had copies of pay vouchers; I had copies of

accounting which I had done for all the projects going back,

I believe, as far back as the ship, but perhaps not that far

back.

In any case, those were what I took.

And in addition to any archives material which

I have provided to Mr. Garrison, I had transparencies of

slides which I took when I left the organization.

I spoke to Barbara DeCelle right around that time,

the day following when I was driving out and let her know

that I had these and why I had them; that I still had some

work to do with them.

I took my personal letters, but those were my

personal letters.

Q What personal letters?

A Personal letters which I had in the organization.

Q Did they have to do with Scientology matters?

A No.

Q Why don't you -- I'ut not asking you for the

contents, but can you elaborate on what you are referring

to when you are referring to personal letters?

A I keep in the archives area a file which contained

all of my correspondence with my family. It was just a file.

There were probably two or three, various family members

involved. And I took all of that stuff out.

I took out copies of it when I did the final

 

 

 

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accounting.

I took a copy of the letter which I sent to

Barbara DeCelle at the -- the day that I left and copies of

the checks which I sent turning in the balance of any funds

which I had for the biography project.

I sent one check to Mr. Hubbard via LRH accounts,

Jim Isaacson. And I retained copies of that correspondence

and the checks.

I think that is what comes to mind at this time.

Q BY MR. LITT: Did you take any correspondence

or other materials that are not archives documents themselves?

Do you know what I mean when I say archives

documents? Just to make sure we have our terms straight,

I mean documents that are being collected for archives as

opposed to any correspondence that might have related to them,

but are not archives materials themselves.

A Okay. I understand.

 

 

 

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Q Did you take any correspondence or other

materials not archive documents relating to your activities

in connection with the archives project or related matters

over the previous two years?

A I believe only what I have told you about.

There were copies of financial records.

Q Well, you don't have to repeat it.

A Okay. My best recollection is just what

I have told you.

Q Now so have you now described for me everything

that you took when you left, aside from archive documents?

A When I left I took --

Q Up to when you left.

A Do you mean specifically from files, not

my personal materials, not my clothes?

Q Right.

A Are you asking a broader question that you

originally did?

Q I am not asking a broader question. I just

want to make sure that I have a full answer to that.

A I believe what I have told you is everything

other than archival materials that I took during the period

when I was leaving the organization.

Q All right. Now, have you written any letters

since -- well, let me take starting with the period 1980,

have you written any letters other than within Scientology

channels -- can I use that phrase? Do you know what I

mean/when I use that phrase?

 

 

 

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A Okay.

Q Did you understand it because if not, we

will get it cleared up.

A Yes.

Q Other than within Scientology channels

starting with the period 1980, did you write any letters

or have any correspondence with anyone on the subject of

Scientology and your attitude toward Scientology, and I

will take that for 1980 through 1982.

A Other than Scientology channels?

Q Right.

Q Okay. There is one that comes to mind,

and that was a letter to a man by the name of Perry

Chapdelaine who was an early Dianeticist and he lived

somewhere in Tennessee. I don't recall the city, somewhere

near Nashville, I believe, and I wrote to him on some of

my feelings at that point about Scientology or about

Scientology practices.

In 1982 I wrote to Laurel Sullivan, to

Dick Sullivan. I don't recall if there was anyone else

during that period specifically on Scientology. It is

possible, but that is what comes to mind.

Q Did you have any correspondence with any

family members on that topic?

A It would have been a very small amount in

which it would have been mentioned. I don't know, not

a great deal.

Q Do you have copies of your correspondence

 

 

 

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to Perry Chapdelaine, Laurel Sullivan and Dick Sullivan?

A No. The letter -- there were a number of

letters to Perry Chapdeline in the period of 1980, '81,

at least one which I mentioned some of my feelings about

some of the Scientology practices. That would have been

left in the organization in the archive area when I left.

Correspondence with Laurel or Dick Sullivan,

I don't have those.

Q All right. Now you mentioned in your

direct testimony that you at some point began keeping

a record, and I wasn't sure how frequent this record was,

of your experiences, I guess it was with what you called

harassment; am I right about that?

A Yes.

Q When did you begin keeping that record?

A My recollection is it is some time in

August, mid-August 1982.

Q And up until what period of tine did it

go?

A Up to I believe somewhere in September,

perhaps up to September 20, September 22. That would be

the date on which I last perceived one of the private

investigators tailing or shadowing me.

Q And was the purpose of this record to record

while matters were fresh in your mind what had transpired

on a particular day or a particular occasion?

 

 

 

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A Well, that was part of it. I felt that I was

at that time the object of an incredible campaign. And I

wanted to document the facts.

Q And so you wrote down everything that occurred

on a daily basis with respect to the subject of Scientology

or what you felt was related to that topic?

A I wrote down incidents regarding the private

investigators at that time, not necessarily my thoughts

regarding Scientology, but this is -- it is a fairly detailed

description on a daily basis of what I viewed incidents of

harassment.

Q Okay. Now, aside from that document -- which

I'll come back to -- from the time that you left Scientology

on December 12, have you kept on records or notes other than

this record of private investigators, journals or diaries

in which the topic of Scientology or your attitudes towards

Scientology is mentioned?

A At some point in the summer of 1982, summer or

spring of 1962 I wrote what was a chronology which brought

me up to my beginning in Scientology through 19 -- probably

1974. I was still on the ship. So I had that. I think it

amounted to maybe 20 or 30 pages typewritten. Other than

that, other than writings which are not a documentation of

any facts, there is nothing.

I do write notes to myself. These are more

introspective notes, sort of trying to determine what happened

and what happened to me mentally through those years.

I don't know if that is what you are seeking,

 

 

 

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but those are the only other notes or records. And they are

not a documentation of events that were going on on that day,

but rather a mental documentation. Those are the only things

that I have or did.

Q Are these notes that you have referred to

collected in a particular -- are they kept together in a file,

or do you maintain them?

A Well, I have a number of them. They are a pretty

big mass and not all of they refer to Scientology. But there

are references to Scientology and references to Mr. Hubbard.

But they are just my personal notes. And, yes, I do maintain

them.

They are not particularly well organized, but

they take up, I guess, about six inches in depth.

Q And did you begin engaging in this practice from

the time you left?

A No, it began, I suppose sometime after the

harassment that went on -- that was a pretty intense period.

And it just began right after that.

Q Have you ever written anything for publication

or for possible publication that referred to either directly

or sort of by the use of different names, but in reality was

a reference to your experience in Scientology?

MR. FLYNN: Does this include communications with

counsel, Your Honor?

MR. LITT: None of my inquiries include communications

with counsel.

THE WITNESS: There was a thing which I wrote, I guess,

 

 

 

 

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in 1982. And it would have been in May of 1982. And I never

completed it. It was -- it dealt mainly with the paranoia

that I was going through at that time and my behavior at that

time.

I was walking around in the middle of the night

with a knife and peering out of the windows and that sort

of thing. And the terror that was in my mind at that time.

And I gave -- I'm sorry --

 

 

 

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Q Do you still have a copy of that?

A I believe I do.

MR. LITT: Your Honor, we would ask that we have

produced for us the following materials:

One, the record of -- the court should

understand, as we have said before, that on the matters

that we are dealing with here this case was not prepared

on that basis, so there are some materials that might

otherwise have been obtained that weren't obtained, but

given the nature of Mr. Armstrong's testimony, I think it

is reasonable that we obtain it at this point.

We would like the record made by

Mr. Armstrong of his experiences with the private

investigators.

We would like his chronology of the positions

and other things that he's held in Scientology. I think

he said from joining until 1974.

We would like, and it is perfectly agreeable

with us that the court review first to pull out, only

the portions that are relevant because I am not interested

in having private materials of Mr. Armstrong on other

subjects, but these notes that he's written that reflect

his attitudes and feelings about Scientology or

Mr. Hubbard.

We would like that and we would like a copy

of this draft that he wrote in May of 1982 which dealt

with his mental state at that time and I guess sort of a

fictional work. I am not completely clear.

 

 

 

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MR. FLYNN: Your Honor, my reaction is that we have

no problem producing any of it with the one caveat that

I'd like to examine it, and barring any attorney-client

privilege -- I know that Mr. Armstrong sent me a recitation

of the chronology of his history in Scientology some time

during the summer of 1982. I am not sure whether that is

the second or mot, but my reaction is we have no problem.

THE COURT: All right. Well we will take a recess

until 1:30.

(The noon recess was taken until 1:30 p.m.

of the same day.)

 

 

 

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Los Angeles, California; Wednesday, May 16, 1984; 1:30 p.m.

---0---

 

THE COURT: In the case on trial, let the record reflect

that counsel; the witness has retaken the stand.

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. Litt.

 

GERALD ARMSTRONG,

resumed the stand, having been previously sworn, testified

further as follows:

 

CROSS-EXAMINATION (Resumed)

BY MR. LITT:

Q Mr. Armstrong, when we left off this morning we

were talking about the variety of materials that you might

have in your possession. Let me just clear up one thing.

If I understand your testimony correctly, when you left your

post, other than archives materials that you gave to Omar

Garrison, you didn't have copies of any file materials

pertaining to the archives projects activities; is that

correct, internal correspondence, anything like that?

A Correct. Other than what I have told you about.

Q Well, maybe you can explain something for me;

there have been a series of exhibits that have been marked

in this case that so far as I can determine were not produced

 

 

 

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in discovery by the church. And I'm interested in knowing

where some of those materials -- how they came into your

possession; for instance, there is exhibit DD, the Dive Bomber

dispatch; where is that from?

A I obtained a copy of the Dive Bomber dispatch

during the beginning of my work on the biography project.

And that was in February, 1980.

I subsequently gave it to Mr. Garrison.

 

 

   
 

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Q And then did Mr. Garrison give it to you?

A Yes.

Q When was that?

A It would have been some time in 1982.

MR. FLYNN: I believe that document is under seal

and was marked as an exhibit under seal.

MR. LITT: Well I may be incorrect about that. Let

me check.

MR. FLYNN: It is E under seal.

MR. LITT: Okay.

Q There is some correspondence that was marked

as an exhibit by you, and I believe and you can correct

me if I am wrong, that they are not under seal. For

instance, there is exhibit GG, which is a letter to

Alan Wertheimer from Larry Brennan of January 2, 1981;

exhibit FF -- I may have the date wrong on that --

exhibit FF is a letter from Alan Wertheimer to

Larry Brennan of December 2, 1981; exhibit EE is a letter

from Alan Wertheimer to Larry Brennan of November 17, 1980.

Where did those come from?

A Originally I obtained them from Laurel

while working on the biography project. Subsequently I

gave them to Omar Garrison, and a year or many months

later I obtained them from Mr. Garrison after this

lawsuit began.

Q So after the lawsuit began and after you

had been ordered to turn over all materials in the archives

you then went and obtained materials from Mr. Garrison

 

 

 

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that you had provided to him in your capacity as archivist;

is that right?

A At that point they were attached as exhibits

to a declaration which was filed.

Q By whom?

A By me in this case some time in -- be

September 1982.

Q All right. So you had to prepare a

declaration to be filed in September 1982; is that correct?

A That is correct.

Q And this was after the temporary restraining

order required you to return all the archives materials

had been entered; is that correct, August 24th?

A I believe all the archives materials had

been, but I think that that is correct.

Q And then after that order had been entered,

you went and obtained from Mr. Garrison additional

materials that had been provided to him in your capacity

as archivist; is that correct?

A To the best of ay recollection, I believe so.

Q And let's go through some of the others.

Is that when you obtained a copy of the

contract between Mr. Garrison and PUBS DK?

A It is -- I don't know if I obtained that at

that point or not. I believe my recollection is here

that I had already sent that or shown it to Mr, Flynn,

but it is also possible that at that time I obtained it

from Mr. Garrison.

 

 

 

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Q And the letter that you have testified to

addressed to C -- Controller of 15 October, 1980; is that

something you had given Mr. Garrison?

MR. FLYNN: What exhibit?

MR. LITT: That is exhibit J.

THE WITNESS: What is the date of that?

Q BY MR. LITT: October 15, 1980 is the letter

to the Controller.

A I am not sure. My recollection is that that

was produced at a deposition. That is my recollection,

but it could be -- I really don't know on that one.

 

 

 

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Q Okay.

A My recollection is that the organization produced

it at a deposition or used it in some way in connection with

this lawsuit.

Q And exhibit HH which is a letter from you addressed

to Gale, where did you get that from?

A Mr. Garrison.

Q So that is something you had given Mr. Garrison

in your capacity as an archivist?

A Yes.

Q And in September of 1982 you went back and got

that from him also?

A I don't know if I got it at that time or earlier,

but in any case, I got it from him. I had given him that

thing because we had a great deal of concern at that point

about Jocelyn's or my being locked up. And I gave it to him,

a copy of it.

And sometime later I asked him to see if he could

locate it. And he did. And he gave it to me.

Q Exhibit II, which is a letter from you to Cirrus

of November 25th, 1981, did you get that from Mr. Garrison

also?

A I believe so.

Q And that was in September, '82?

A It possibly is around the time of the lawsuit

at which point I had to obtain documents relating directly

to that subject.

MR. LITT: I'm going to move to strike the last portion

 

 

 

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of the answer.

THE COURT: All right. it will be stricken.

Q BY MR. LITT: Exhibit JJ, a document of

November 18, 1981, which is a communication from Vaughn Young

concerning the biography debug, did you get that from

Mr. Garrison?

A I got that from Mr, Garrison, but it was a lot

later.

Q When was that?

A Sometime in 1983.

Q And you went back to Mr. Garrison in 1983 and

you asked him to give you documents that you had given to

him while you were in the archives post?

A Basically, yes.

Q And exhibit AA which is your nonexistence letter

of February 3rd, 1980, did you get a copy of that from

Mr. Garrison at some point?

A Who is that document to?

Q That is the one, if I remember correctly, that

doesn't have a name on it. It just says to blank. And from

Senior PPRO Research.

A I believe you produced this document in this

trial.

Q That is correct, But did you get a copy of that

by some other means from Mr. Garrison as well?

A I am not following you.

Q My question is aside from the fact that it was

produced by the church, at some point did you go to

 

 

 

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Mr. Garrison and get a copy of it prior to that?

A No, I don't -- well, I don't believe he had a

copy. I don't -- I -- I am a bit confused.

Are there two copies? Are there two such

documents?

Q Are there two such documents? Well, once you

have a Xerox machine, there can be an endless number of

documents.

A The only -- the first time I recall seeing it

is when it was produced by you in this trial. That is the

first time since l980 or '81.

Q Exhibit KK, which is a handwritten note from

Vaughn to Sue of November 28, 1981, is that another document

that you went to Mr. Garrison to obtain?

A Yes.

Q And that document also you had given to him while

you were archivist?

A Yes.

Q And exhibit LL, which is a November 28, 1981,

document from Vaughn Young, did you obtain that from

Mr. Garrison as well?

A Yes.

Q And exhibit TT, which is an October 30th, l981

draft of a document, did you get that from Mr. Garrison as

well?

A Could you describe the document in a little more

detail?

Q it is -- let me just double check it here.

 

 

 

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It is a document dated October 30th, 1981.

At the top it says "CO LRH ED." But it is not

an issue; formerly presumably somebody's draft. And it says

"Project biography debug personnel Vaughn Young, IC."

Did you go back to Mr. Garrison and get that from

him?

A Yes.

 

 

 

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Q Now, many of these materials that we have

been discussing here were not materials addressed to

Mr. Garrison; is that correct?

A That is correct.

Q They were materials that you had given him

because you thought he should be aware of them given the

fact that he was working on a biography pursuant to the

contract with PUBS DK?

A That is at least part of the reason. That

is the underlying reason.

Q Is there some other reason?

A Mr. Garrison was at that time attempting

to renegotiate his contract. We had become aware of the

fraudulent basis for the contract. Some of the clauses

which he had agreed to he was enticed into by fraudulent

representations.

MR. LITT: Your Honor, I am going to move to strike

all of that as a conclusion.

THE COURT: All right. I will strike it.

Q BY MR. LITT: In addition to giving it to him

in your capacity as an archivist, you gave it to him for

purposes of his renegotiating the contract with PUBS DK;

is that correct?

A I gave it to him to inform him of what was

being done.

Q So you felt that in your opinion there were

things being done that weren't right; is that correct?

A There had been things which had been done

 

 

 

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which were not right.

Q Okay. So you made the decision on your own

that there were certain internal church material that he

should see; is that correct?

A Yes.

Q And so you gave it to him; is that correct?

A Yes.

Q That is why you were acting as archivist?

A Yes.

Q Did you check with any senior about doing

that?

A On some of those. My recollection is that

Laurel knew about the Wertheimer letters, but the others

I don't believe I checked with anyone.

Q Now there are also some biography sketches

that were produced or used by you.

Did you get those from Mr. Garrison, also?

MR. FLYNN: Can we have a little more specificity,

Your Honor?

THE COURT: Sustained.

Q BY MR. LITT: Exhibit S, I believe, but

I am not absolutely positive on that -- no, no.

Q That was a magazine; is that correct?

MR. FLYNN: Are you talking about the magazines

such as "Successes in Scientology," "PRO"?

MR. LITT: No. That is not what I am talking about.

Q Exhibit H is a document entitled "A Brief

Biography of L, Ron Hubbard" and at the top it says

 

 

 

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"Originally Printed Circa 1960."

MR. FLYNN: That is a sealed document, Your Honor,

which is identical to -- that is a sealed document which

is a copy which is identical to exhibit S, I believe.

MR. LITT: Your Honor, Mr. Armstrong can answer

the question. I as trying to get some things straight.

THE COURT: Well, of course, the witness doesn't

have any cross reference to what the exhibit is, but let's

go ahead.

Q BY MR. LITT: Are there any other materials

that you obtained from Mr. Garrison after the TRO was

entered in this case that you had given to him in your

capacity as archivist?

A There way be others. If there are, they

have been produced at one deposition or another to the

best of my knowledge.

Q Now, Mr. Armstrong, do you have in your

possession a set of Orders of the Day from the Apollo?

A No. I can clarify --

Q Have you had at some point?

That is all right. I will ask the questions,

Mr. Armstrong.

Have you had such a set in your possession

at one time?

A I have not a complete set but a partial set

from the period approximately 1970 to 1974.

 

 

 

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Q Is it complete for that period of time?

A No.

Q But you don't presently have those in your

possession?

A No.

Q Where are they?

MR. FLYNN: Your Honor, this, I believe, is a set that

belongs to one of my contacts whose identity the person seeks

to preserve, if you're talking about the same set.

THE COURT: Well, where did you get it from?

THE WITNESS: I got it from someone named Jim Dincalci.

MR. FLYNN: Okay. that is a second set.

Q BY MR. LITT: When did Mr. Dincalci give these

to you?

A I would think somewhere probably in early 1983.

Q Did you ask them for them, or did he volunteer

them to you, or what?

A He mentioned that he had had them. and my best

recollection is that he said did I want them.

I said yes and I took them.

MR. LITT: May I have one moment, Your Honor?

THE COURT: Yes.

Q BY MR. LITT: What about any other materials?

You didn't take anything from your personnel or student files

when you left; is that correct?

A That is correct.

Q Have we covered everything now that you obtained

from Mr. Garrison?

 

 

 

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A I am not sure how to answer that question.

Q Well, in terms of anything having to do with the

biography or materials provided to him in connection with

his biography work that you subsequently obtained from him

other than archives materials themselves?

A I believe no.

Q Now, with respect to the orders of the day,

Mr. Armstrong, that we were discussing before, you said that

Mr. Dincalci had given you the set from 1970 to 1975: is that

correct?

A I think I said ' 74. It may be '74 or '75. And

I can't tell you the date that it starts or ends or even what

percentage of the total orders of the day are comprised.

Q Do you remember being asked in interrogatories

in this case regarding a set of documents known as orders

of the day from the Apollo for the period of 1970 to 1975,

"Please state, A, where you obtained these documents and,

B, the date that the documents were obtained by you"?

A I don't recall the specific question, but it is

very likely.

Q The document entitled "Interrogatories propounded

to defendant Armstrong by intervenor Mary Sue Hubbard and

plaintiff Church of Scientology of California" at page 25;

the document has a proof of service of the December 14, 1983.

Can you take a look at that, Mr. Armstrong, and

tell me if that refreshes your recollection?

A Okay.

Q Does that refresh your recollection? Do you

 

 

   
 

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remember that document?

A I do recall the question which I have now looked at.

Q Showing you a set of what is entitled "Further

responses of defendant Gerald Armstrong to interrogatories

propounded by intervenor Mary Sue Hubbard and plaintiff Church

of Scientology of California," do you recognize your signature

there as verifying the responses executed on March 5, 1984?

A Yes.

 

 

 

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Q All right, and here next to the question No. 150,

the answer to A which is where you obtained these documents,

referring to Order of the Day is, "on the Apollo"; is

that correct?

A Yes.

Q And the answer to B, the date that these

documents were obtained by you is, "1971 to 1975"; is

that correct?

A Okay.

Q Is that correct?

A Which?

Q 1971 to 1975 for B.

A Yes.

Q Did you prepare those answers?

A I believe so.

Q Were they correct at the time?

A Yes.

Q Are they correct now?

A Yes.

Q I thought you had just told us that you

obtained your copies of the Orders of the Day from Jim

Dincalci?

A Well those ones, and I did not have, I believe,

the Van Schaick deposition with me, and I had seen virtually

every order of the day published between 1971 and 1975

because I was on the ship at the time, so I obtained each

one of those documents at that time, and that is what I

was referring to when I wrote that.

 

 

 

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Q That is what you were referring to when you

wrote the answer?

A That is correct. If you are talking about

specific ones which I did not recall from Van Schaick,

I believe I would have said in the Van Schaick deposition

that I had seen all these documents prior to when I was

on board the ship. They were not new documents to me,

and I also think in Van Schaick that I laid out the obtaining

of the documents at both times.

Q So, let's get this clear.

You had Orders of the Day when you were on

the Apollo?

A Yes.

Q And you claim you no longer have those?

A That is correct.

Q But you got another set from Jim Dincalci?

A Not a complete set, but at least a partial

set from '70 through '74.

Q Okay. All right, now, let me ask you some

questions about materials that you have read in the course

of your years in Scientology.

What do you recall reading in the year 1969

on the subject of Scientology?

A "Dianetics, The Modern Science of Mental

Health," "Science of Survival," "Problems of Work," "New

Slant on Life," book on Scientology ethics.

Q Was that the title or did it have a title?

A It may be "Introduction to Scientology Ethics."

 

 

 

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There were several magazines or pamphlets

from that period from 1969, the titles of which I don't

recall, but there was a great number of them. Part of

"8-8008","8-80," some of the "Credibility of Human Ability,"

Phoenix lectures.

Those are what I recall.

Q All right. That was in the year 1969; is

that right?

Q And do you recall what you read in 1970?

A More of the same materials; "History of Man,"

"8-8008," "8-80."

A You studied those materials further?

A Yes. I also did during that period a pack

of materials called "The Hubbard Standard Dianetics Course."

I did the pack of materials of "Policies

Dealing with Scientology Finances."

Those are what I recall.

Q So far you have listed books and you said

there were several publications in 1969 and 1970; do you

remember any of them?

THE COURT: He's just listed a bunch of books.

MR. LITT: I am sorry.

Q I mean periodical-type publications as opposed

to books.

A There were a number from that period. There

was one called "Success." I believe there is one entitled

"Scientology."

The early editions of "Advance." I don't

 

 

 

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know if those were in '69 or '70, but definitely the "Advance"

magazine in that period.

There were promotional pieces put out on

the Sea Organization. There may have been other magazines,

the titles of which I don't recall right now.

 

 

 

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Q What kind of promotional materials on the Sea

organization?

A Promotional materials --

Q Can you identify them in any way?

A I believe I have produced one here in this trial.

But there were other ones as well which showed pictures of

the ship and they were recruiting promotional pieces.

Q All right. Now, in 1971 was the year you joined

the ship; is that right?

A Yes.

Q And do you recall what materials on the subject

of Scientology you read in that year?

A There was an initial course which I did called

the Check Out Mini Course.

Q Let's leave courses alone for the moment.

How about books first?

A I don't believe I -- not that I recall anyway,

any particular book from that period. There were mostly

course packs, materials assembled into packs.

Q All right. Let's take your years on the ship,

Mr. Armstrong; first, again addressing ourselves to books,

what books did you read in addition to what you have already

stated while you were on board ship in that time period; in

other words, 1971 to 1975?

A I read at least pieces of a book called Dianetics

Today.

I read The Ship's Org Book.

I read pieces of the Scientology Dictionary.

 

 

 

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I read a book called Volume Zero.

I read pieces from the other volumes of the OEC

Course. That is principally it that I can recall at this

time -- oh, I'm sorry. I also read A Spy and His Masters

and The Art of War. And I think there was another one called

Total Espionage.

Q What about periodicals?

A I read the O0DS which came out every day,

I read Advance Magazine.

I read --

Q Did you read that regularly? Was that published

on some kind of regular basis?

A Yes. It was, I believe, monthly, maybe bi-monthly,

publication. In any case, it came out regularly while we

were on board.

I read the policies and technical bulletins as

they were published on board.

I read the PRO publication. I don't recall its

name. I think it changed from PRO News. But it was something

similar. And that was put out as a newsletter during a period

of time on board. That is what I recall.

Q Okay. Now, during that period did you read any

materials that were designed to sort of introduce Scientology

to others; for instance, some of these I am not that familiar

with. So I may have my dates wrong. But, for instance, the

Basic Scientology Picture Book or What is Scientology, books

like that; did you read any of those, or were you familiar

with them?

 

 

 

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A What is Scientology, I believe, was published

in 1978. So we wouldn't have had that on board.

I do recall The Picture book. I don't believe

I -- my perception of it was that it vas an introductory thing

to get people into Scientology. And I did not look at it

in depth.

 

 

 

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Q And what other introductory things like "Scientology

A New Religion Emerges in This Space Age"?

A I saw that during that time as well.

Q And were you familiar with it at all?

A To some degree. I had sent a copy to my

parents, I think to a Member of Parliament, so I was to

some degree familiar with it.

Q All right, now, let's take the period of

leaving the ship. Other books and periodicals that you

read?

A Part of "What is Scientology?" Part of

the "Volunteer Minister's Handbook."

Those are the only later books that I recall

reading. There may be more and I continually looked back

over the earlier books. Somewhere along the line I read

"Dianetics, The Original Thesis," "All About Radiation."

That is one of the earlier books I read.

"E Meter," "How to Operate the Emeter," "E

Meter Essentials" and these would have been after the ship.

I would have read those in the RPF.

Q You read books about the E Meter when you

were in the RPF?

A Yes.

Q The E Meter being what is used in the course

of auditing by an auditor, this machine that you called

having electrodes?

A Yes.

Q What about tapes, did you listen to tapes

 

 

 

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of Mr. Hubbard?

A Yes.

Q What was the first tape that you recall?

A The first one was given at a lecture, a public

lecture in Vancouver and I really don't recall the name

of it.

Then I did a set of tapes: called the "Study

Tapes," I listened to the study tapes. It would have

been in 1969/1970. On board the ship I listened to --

actually I listened to some more tapes on board the Bollivar

in the beginning of February 1971 called the "Welcome to

the Sea Org" series.

Then I listened to a number of tapes, particularly

on the RPF. There were several tapes which I listened

to having to do with auditing. Those are what I recall

right now.

I listened to a number of the "Philadelphia

Doctorate" tapes, and "The Story of Dianetics and Scientology,"

"Ron's Journal 67."

Q When was this that you heard these? Was

this all on the ship?

A I think I heard "Ron's Journal 67" in Vancouver,

but I also heard it on the ship and "Story of Dianetics

and Scientology" that would have been perhaps 1979 or '80.

Q The "Philadelphia Doctorate" tapes when was

that?

A I heard some of those very early on in Scientology,

but I listened to several of them in 1980 and '81 while

doing the biography work.

 

 

 

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Q Now, Mr. Armstrong, you have spent quite some

time testifying. And I want to review some things just so

I understand what it is.

You are saying -- you have claimed that there

are certain misrepresentations that are shown by these

documents. And I would like to see if I can get an

understanding of, in a general way, what the purported

misrepresentations are.

As I understood it, you claim that there are

misrepresentations concerning Mr. Hubbard's war record; is

that correct?

A Yes.

Q All right. and you claim that those

misrepresentations include representations about medals that

were received; is that right?

A Yes.

Q And does it also include representations about

how many theatres of war that he was in?

A Yes.

Q And does it also include representations concerning

an incident with some submarines or something like that?

I am just trying to understand what it is you

are saying. I hear a lot of different things from Mr. Flynn

and whatever. So I'm trying to find out from you exactly

what it is.

MR. FLYNN: There is a list that has been marked as

an exhibit.

THE COURT: He has a right to cross-examine. We don't

 

 

 

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need editorial comments.

Let's go forward.

THE WITNESS: The alleged incident with the submarines,

I am not certain about.

Q BY MR. LITT: Okay. So, so far in the war I have

these two things; what is it you contend with respect to

Mr. Hubbard's war record that constitutes misrepresentations?

A He was not a commander of a squadron of corvettes;

he did not -- was not cripled and blinded in the war; he was

not the first casualty of the Far East; he was not flown home

in the Secretary of the Navy's private plane; he was not

replaced by 15 officers of rank at the beginning of the war.

Those are what comes to mind right now.

Q Does that cover the war record that you claim?

A I can perhaps continue on.

The final result is that he is not --

Q I are not asking you for the final result. I am

asking you for what it is you claim are misrepresentations

concerning Mr. Hubbard's war record.

Is there anything else that you claim has been

represented that in your opinion is wrong, concerning his

war record?

A There are at least these. There may be more.

Those are what I recall right now.

Q Those are the ones that you consider at least

significant? Would that be a fair statement?

A I think -- well, what I consider of significance

is the overall picture of it.

 

 

 

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Q So it is not a question of whether or another

particular thing is inaccurate, but it is, in your view, the

fact that when taken as a whole, there is a wrong picture

given?

A There is the quantity which adds to a whole.

Q Now, what about Mr. Hubbard's youth or teenage

years; I think you made some reference in the course of your

testimony about his travels in the Near East; what is it that

you claim constitutes misrepresentations about Mr. Hubbard's

travels in Asia?

A His claim of studying for several years, from

1924 to 1929 in the Far East; his having been in India, having

studied in China under Llama priests; his being in Mongolia

wandering through the Far East for years, those sorts of

things.

Q Are those the main ones?

A My recollection right now, yes.

Q All right. Then I understand that you claim that

there are misrepresentations about Mr. Hubbard's credentials?

A Yes.

Q And those have to do with either academic

credentials or things that he has done; is that correct?

A Yes.

Q Let's take the academic credentials; what do you

claim has been misrepresented concerning Mr. Hubbard's

academic credentials?

A That he graduated from George Washington

University; that he is a member of the first course in the

 

 

 

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U.S. in atomic physics; that he was an atomic physicist; that

he was an anthropologist; that he was a civil engineer; that

he attended postgraduate studies at Princeton University,

Q All right. What about his activities? What is

your claim on that?

A The claim that he had done the first complete

mineralogical survey of Puerto Rico: that he had supplied

hydrographic information to the Hydrographic Office from

his Caribbean cruise; that he had rewritten the Alaskan Pilot;

that he had been the initiator of LORAN; that he had supplied

underwater pictures to the university of Michigan; that he

had studied several savage cultures.

Those are what I recall right now.

Q All right. And is there anything else on his

activities?

A I'm sure there are more.

I believe the list is very extensive. That is

what comes to mind at this moment.

Q And then I understand that you claim that there

were misrepresentations, scientific misrepresentations,

representations that were claimed to be scientific; is that

part of what you are contending?

A I assume you mean the scientific claims regarding

the workability or the guarantees offered by Dianetics and

Scientology?

Q I don't know, I'm trying to find out what you

mean. I don't mean anything except to ask you the question

to find out what you mean.

 

 

 

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A Okay. In my mind there are those

misrepresentations regarding the subject.

Q regarding the claims that Scientology can

accomplish?

A That it can raise I.Q, a point per hour; that

it can cut reaction time by 30 percent.

Q Are those the only two? Are there other things

that you claim are misrepresentations?

A I think there are a great number; that it can

produce a state of Clear; that it can produce a state of OT

where a person is knowingly a cause over matter, energy, space,

and time. Those are scientific claims.

 

 

 

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Q Any others or are those the key ones?

A There are many others; that it can cure a

common cold; that a Clear cannot get a cold; that it can

cure arthritis.

Q Okay, and it is your contention that these

documents show these claims to be false; is that right?

A The documents show Mr. Hubbard making the

claims. I am the proof that they are false.

Q You are the proof that they are false because

those things --

A I had a thousand hours of auditing, and I

am not a thousand intelligent quotient points smarter.

Q Okay. All right, so, you are the proof and

I take it other former Scientologists are the proof that

these claims about Scientology are not correct; is that

right?

A I think that I am and they are certainly

a part of it.

Q But let me see if I understand this correctly.

Is it also your claim that the documents

show that these things are not true?

THE COURT: When you say "things," he's talked about

a lot of things, Counsel.

Q BY MR. LITT: I mean the complete set of

these claims about what Scientology can accomplish.

A I believe that they will show that they are

part of that proof.

Q Is there anything else that you claim has

 

 

 

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been represented scientifically that you claim is a

misrepresentation?

MR. FLYNN: For the record, Your Honor, I don't

believe any of this was gone into on direct, but I have

no objection to it.

MR. LITT: Well, he talked at length about science

and I am just trying to understand what we have here, what

the claims of misrepresentation are that he took the documents

in order to defend himself about it.

THE COURT: Well, it becomes rather convoluted the

way it is being phrased.

I trust that this is not simply discovery

for the upcoming fraud lawsuit.

MR. LITT: No, it is not. The problem is, Your

Honor, that there are hundreds of documents. We are trying

to understand what it is that is supposed to be in issue.

THE COURT: Well, he didn't even talk about, as

I gather -- he refrained from discussing the truth or falsity

of doctrines of Scientology. That would not be something

that is triable under the First Amendment, and they have

refrained from getting involved in that, but I guess if

you want to keep asking about it, he will probably tell

you his opinion about it.

MR. LITT: No. The problem is, Your Honor, he's

said in his direct examination that Scientology has held

itself out to be a science and that is false. I can find

the court four or five different places, so we are left

with this general statement that Scientology is claimed

 

 

 

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to be a science.

THE COURT: I can remember him reading Mr. Hubbard's

statement that it is a science and not something else,

and then saying that it is something else and not a science.

I gather if that is what you want to know, yon can ask

that.

MR. LITT: I am just asking for what his contentions

are. we don't intend to go into all of this, but we just

want to understand what are the purported misrepresentations.

MR. FLYNN: They are set forth very explicitly in

exhibit double V, so Mr. Litt need only go through the

four pages of exhibit double V line by line.

THE COURT: I agree with Mr. Litt. He's got a right

to cross-examine.

I agree with Mr. Flynn that we may be wasting

a lot of time. If you want to refer to that list and ask

him whether those are the ones, go down one by one, it

would be one way of doing it.

MR. LITT: It would be longer than what I am trying

to do is to get some categories which I am almost done

with.

Q The next area I gather is moneys from the

church supplied to Mr. Hubbard. You claim there have been

misrepresentations about that?

A Yes.

Q And about the control of the church by

Mr. Hubbard?

A Yes.

 

 

 

 

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Q And on the question of moneys, what do you

claim are the misstatements?

A That Mr. Hubbard was not receiving any money

from the organization; that he was getting paid less than

a staff member. That is principally it.

Q All right, and then I understand that this

question of "Dive Bomber" which I won't go back into, but

you claim that is a misrepresentation.

Now, have I covered in the list we have just

gone through, have I covered the main areas or have you

covered the main areas that you claim constitute misrepre-

sentations concerning Mr. Hubbard?

A Those are what come to mind right now. I

think that ultimately another area will develop, and that

is Mr. Hubbard's intention and what exactly he set up the

Sea Organization and Scientology for.

 

 

 

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A I believe that those things are being

misrepresented. They were misrepresented to me and

misrepresented to the public.

Q Referring to the fact that it was set up for

Scientology and you claim it was set up for him personally,

is that the idea?

A More that it is an intelligence mechanism by which

he can obtain control over people.

Q Okay. All right. Mr. Armstrong, now, let's go

to the time when you first came into contact with Scientology;

you were in Vancouver at that time; is that right?

A Chilovac, British Columbia.

Q And do you recall when you first and in whatever

form were introduced to Scientology? Do you recall as

specifically as possible when that was?

A The first time was a magazine article. I believe

it was in the Star Weekly Newspaper, in the magazine section

on the weekend. And would have been -- I don't know the year,

maybe '67, maybe earlier than that, maybe '65, '66.

Q That it had been written?

A That it was published.

Q But you first read it in '69?

A No. I first read it -- that was the first time

I had ever seen the word Scientology.

Q And at that time nothing came of it; is that

correct?

A That is correct.

Q All right. Now, at some point -- and my question

 

 

 

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now is just at what point -- in 1969 you came in contact with

something having to do with Scientology which ultimately ended

up with your becoming involved in Scientology; right?

A Yes.

Q When was that?

A That would have been in the late spring, early

summer of 1969.

Q And at that time what were you doing?

A I was at that time logging for a living in British

Columbia.

Q And you had been a student prior to that and had

dropped out of school; is that right?

A That is correct.

Q And were you in Vancouver where you were doing

the logging, or were you in a more rural area?

A Well --

Q Or do I just not understand the geography of

Canada?

A I was logging -- I was living in a logging camp

at that time out in the bush, out in the woods.

Q And was it at the logging camp that you had some

further contact with Scientology, or were you in the city,

or what?

A No. I came home for a weekend. Home was Chilivac

at that point.

Q Okay. And what form did the contact that you

had at that point with Scientology take? Were you given a

publication again, or what?

 

 

 

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A No, I was told about it by two friends of mine.

And they told me about another person who we knew who had

just come back from Toronto after being involved with

Scientology for some time in Vancouver and Toronto.

Q So these two friends had a discussion with you

and then did you decide to seek out Scientology in some form

to find out more about it?

A Then I spoke to the person who was himself --

who had been involved in Scientology for a number of years.

Q And this was a social conversation; did you know

the person?

A Yes.

Q And where did this conversation occur? Do you

remember?

A I believe the first time I met the person was

at a lake near Chilovac.

Q And do you remember his name? Was it a he?

A Yes. His name was Roger Benett.

Q And the two people that had told you about what

he had been doing, do you remember their names?

A One was Doug Brown and one was Gordon Harris.

Q So you met with Roger Benett and he told you about

Scientology?

A Yes.

Q What did he tell you about Scientology?

A He told me that -- we spoke for some days on the

subject at that time.

He told me about Clear.

 

 

 

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He told me about auditing.

He told me about L. Ron Hubbard,

He told me about Sea Org.

He told me about OT.

He told me about his own auditing.

He told me about how the mind worked according

to Mr. Hubbard.

He told see about how auditing worked relative

to the mind.

He told me about the exactness of it.

He told me about the power of it, about the powers

of operating thetan or OT. That was mainly it.

Q Now, you said that you had conversations over

several days; were these -- did the two of you just get

together and discuss this subject for several days, or what?

A Through the next month or so, I saw him several

times often for many hours at a time. He gave me the books

out of his library at that time.

Q Which books were those?

A Brahms works; 8-80; 8-8008; New Slant on Life;

Dianetics and Modern Science of Mental Health.

There was another several books. He had a

complete library of books that were published to that date.

Q These are the books that you recall him giving

to you?

A Yes,

Q And in the course of that month period while you

were having discussions with him, did you read these books?

A I read a lot of them, yes.

 

 

 

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Q All right. Now, so, you met him someplace

and started this discussion which turned out, as I understand

it, to be 1ike a month-long discussion about whether --

about Scientology which I gather you found interesting

and wanted to pursue at the time; is that correct?

A The conversation was not a month long, but

we met several days ever the course of a month, at the

end of which I went to the Scientology franchise in Vancouver,

but --

Q I understand. I don't mean that you had

a literal 30 days in a row conversation, but in the course

of a month you had several, several hour conversations;

correct?

A Yes.

Q All right. Now, you listed a whole range

of things that he told you about. Let's take a few of

them.

You say that he told you about the state

of Clear; what did he tell you about that?

A That a person who was Clear had no reactive

mind. Could not be stimulated by external stimuli. He

was in total control of his mind. Could not get sick.

Q And I take it he told you what the reactive

mind was in Scientology?

A Yes.

Q And what did he tell you about that?

A That the reactive mind was the accumulation

of incidents of pain and unconsciousness and the incidents

 

 

 

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connected to that. He explained to me ingrams, secondaries

and locks.

Q And he told you about auditing, the relationship

of auditing to these concepts that you have just been describing?

A Yes.

Q What did he tell you about that?

A About the process of auditing, repetitive

processes, of earlier similar processes, of erasure and

of obtaining the -- something called basic basic, and in

that way the eradication of the reactive hind and the production

of the state of Clear.

Q And you mentioned, I think, that he told

you something about his own auditing; is that right?

A Yes.

Q And what did he you about that?

A He had been audited in Toronto and he had

been audited on - what he told me about was the first

couple of grades. I remember him telling me about grade

zero.

I believe it was grade zero communications

release and the fact that he had become a communications

release in a matter of three seconds.

Q And did he -- you say that he talked about

the operating thetan; is that right?

A Yes.

Q Did he talk about what the thetan was?

A Yes.

Q What did he tell you about that?

 

 

 

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A That the thetan was the entity that controlled

the mind, used the mind for the control of the body and

was the entity that viewed the pictures in the mind, and

that this entity could be knowingly exterior from the body

and that that was the state producable in Scientology,

and that an OT could operate the body knowingly from outside

the body and could leave the body at will.

Q Did he tell you that thetan was a notion

of the spirit being independent of the body or soul or

whatever phrase you want to use, something like that?

A Well, no. He spoke in very scientific terms

and he quoted from the factors and from the axioms of Scientology

and his description was more along the lines of the axioms,

not located in space and time kind of description, able

to postulate and perceive. Not so much that it was a spirit

in the religious sense, but that it was a scientific, definable

term and he spoke in those kinds of terms.

Q And then he described to you the powers of

an operating thetan. What more did he describe to you

than you have already told us about that?

A He went into the control over matter, energy,

space and time, the fact that these OT's could be where

they wanted and do what they wanted.

Q And did he tell you anymore about how the

mind worked than what you have already described as you

recall?

A Yes. We spent a great deal of time going

over the consecutive record of mental image pictures, the

 

 

 

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time track, how it vas created, how it is alleviated, the

process of auditing.

THE COURT: Well, we are going to take a 15-minute

recess.

(Recess.)

 

 

 

 

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THE COURT: Let the record show that counsel are

present; the witness has retaken the stand.

State your name again for the record, sir. You

are still under oath.

THE WITNESS: Gerald Armstrong.

THE COURT: Mr. Flynn.

MR. FLYNN: If Your Honor please, I have borrowed this

book from someone that is dedicated to Alexis Valerie Hubbard.

And I would like to give it back to her and enter Xeroxed

copies of the dedication page of three separate printings

of the book from '51 up to 1956, if I could.

THE COURT: Mark these Xeroxed copies as next in order,

CCC.

Counsel, do you have any objection to that

procedure?

MR. LITT: No, Your Honor.

THE COURT: All right. For the record, what is the

name of the book?

MR. FLYNN: Science of Survival by L. Ron Hubbard; first

edition of which is copyright 1951 by L. Ron Hubbard.

THE COURT: Very well.

You may continue, Mr. Litt,

MR. LITT: Thank you, Your Honor.

Q Mr. Armstrong, when we were talking about this

series of conversations that you had with Mr. Benett, do you

recall anything else that he told you concerning the general

philosophy or belief, the system of Scientology in this

series of discussions that you haven't described already?

 

 

 

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A The only other thing that I recall, he talked

about something called "Spinning the paradox of life and

death." And what that was, I never did find out from him

or I could never quite phathom it until possibly many years

later. But he went on at some length about it. That is the

only other thing that sort of sticks in my mind from that

period.

Q And you said that he told you something about

Mr. Hubbard; do you recall anything be told you about

Mr. Hubbard?

A That he was on board the ship, the Apollo; that

he was in the Mediterranean at that time; that he was the

sole developer of this whole thing; that he was OT; that he

was -- Roger, used the name synthesized, synthesized the

Eastern philosophy with the Western scientific approach,

something like that.

 

 

 

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That was mainly it at that time.

Q Now I gather that after this series of discussions,

that you were interested in pursuing Scientology more;

is that correct?

A Well, I was interested in finding out about

it. At this point I went and talked to a Scientologist

in Vancouver.

Q All right, and who was that; do you recall?

A My first contact was with someone and I seem

to recall his name was Hanson. I don't recall his first

name and I only saw him this one time down in Vancouver.

He was an OT-6 and that had particular significance at

that time because that was the highest level of OT which

had been released by Mr. Hubbard that I knew up to that

time, so it was significant that I met this gentleman in

Vancouver.

I spoke with him just a very few minutes,

and that was the last time I ever saw him. I had long

conversations and attended lectures shortly thereafter.

Q And these were in Vancouver at the Little

Mountain Mission or franchise or whatever?

A Yes.

Q And in attending the lectures, you were still

working at the logging camp and coming down the weekends;

is that it or evenings?

A Well around that time I had moved from a

different logging camp. I was logging up in a different

part of British Columbia, and I had a different home in

 

 

 

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Chilovac, so it was just the first few times I went down

to Vancouver on weekends.

Approximately the beginning of September

1969 I moved to Vancouver and got a completely different

job and started attending lectures, and shortly thereafter

got involved with Scientology on a continual basis from

then on.

Q The lectures that you attended, do you recall

who gave those?

A The person who lectured at that time was

someone by the name of Graham Leese, and he was the owner

and executive director of the franchise.

Q And he was the man one who gave the lectures?

A Later there were other people, another person

by the name of Kingsley Wimbush lectured, and there were

a few people throughout that period who gave lectures.

Q And the lectures, the general topic of the

lectures, what was the general topic of the lectures?

A It was mainly selling courses, the next course

to be taken.

Q I am not sure I understand. You said you

attended a series of lectures. The series of lectures

wasn't about Scientology. It was about some other course

that people should take?

A No, it was about Scientology, but the aspect

of Scientology that it was about was the next course.

In Scientology there is a series of courses which one takes,

series of steps, a gradient into and out of Scientology,

 

 

 

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and I was being lectured to about the next course that

I should take; initially the first course and then a second

course.

Q In the course of the lectures, was there

discussion about the various tenets or beliefs in a general

way of Scientology on certain topics, similar to what you

have talked about with Roger Bennett?

A I think similar to that, yes.

Q And then did you after hearing those introductory

lectures, did you take a course?

A Yes.

Q And what was the name of that course?

A It was called the Communications Course.

Q And then you completed that course, and then

did you take another course?

A Yes.

Q Now what course was that?

A It was called the HQS or Hubbard Qualified

Scientologist Course.

Q And those courses were also on the subject

of Scientology and Scientology belief system on various

topics?

A The initial courses were a series of drills

which were done. Information was provided prior to doing

the drills and then drills were done.

Q Okay, and after you took these two courses,

you decided to join the staff of the Little Mountain Organization?

A Some time after that I actually came on and

 

 

 

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got paid as a staff member and that was after I began the,

I guess, the third course which was the -- called the Hubbard

Standard Dianetics Course.

Q All right, and when was it that you made

the decision to go on the staff of the Little Mountain

Organization?

A Some time in 1972 -- I am sorry, 1970. It

would have been fairly early in the year, maybe April.

Q Now at that time had you concluded that

Scientology offered something that at that point made sense

to you?

A Yes.

Q And that it offered something like it would

help you and help others?

A Yes.

 

 

 

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Q And were there things in your own life that you

were trying -- problems in your own life that you were trying

to solve at that time that you felt that Scientology would

or had been helping you solve?

A That it would help me, yes.

Q How about had your experience for this, I guess,

six-month period indicated that it was something new in the

contacts that you had had with it to date as you viewed it

then?

A Yes.

Q And had you had any auditing at that point, the

point in April, 1970 when you went on staff; had you

participated in auditing?

A Around that time, either just prior to during

that period -- no. Actually, before I went on staff I began

auditing, I received what is called the Scientology grades.

Q Okay. And how many hours of auditing had you

participated in at the time that you went on staff if you

recall?

A My recollection is 40 hours.

Q And had you at that point found that auditing,

along with Scientology in general, was something that seemed

to you to be useful for yourself and others?

A I thought so at the time.

It was much more that it promised a usefullness.

I had not solved what I felt was where I was at,

the problem which was essential to me. I was told after doing

the auditing steps, that that would only happen at Clear.

 

 

 

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So I felt like it was a gradient that I was going

up and sooner or later what I sought would happen.

Q All right, Now, when you say it hadn't yet

solved the problem or problems, I don't know for sure, that

you were interested in, in a general way, what was it? What

were the things that were of concern to you at the time that

contributed to your joining Scientology?

A I perceived that I did not really experience

things in the sense that things would logically be

experienced; but that I experienced the experience. I was

one step removed from experience. I lived in concepts,

not in the reality of the world.

I knew that I was not courageous enough to step

outside that, And I sought in Scientology the vehicle to

get outside that and to be honest and to be courageous enough

to live in the reality of the world.

I was promised that at Clear, that that stage

was altered and that out of that would grow the courage to

be able to live in the reality and not live out of experienced

experience or concepts.

Q All right. And at the time you concluded that

based on your experience with Scientology, up to that point,

that Scientology would help you to accomplish this thing;

is that correct?

A This was the state of Clear --

Q No, no. My question is did you conclude in

April, 1970 that Scientology would help you to solve these

problems that you were concerned with?

 

 

 

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A That Scientology would resolve those problems.

Q Would help you to deal with those problems.

A Yes.

Q Now, were there any other factors? For instance,

did you feel that Scientology would help solve society's

problems?

A Yes.

Q And did you feel that Scientology would help to

deal with problems of drugs?

A Yes.

Q Had you been told that Scientology was opposed

to the use of drugs at that time?

A Yes.

Q And did Scientology in any way help you in a

personal sense to deal with any problems of drugs that you

may have had?

MR. FLYNN: Objection, Your Honor.

THE COURT: That is rather assuming some facts not in

evidence. I'll sustain the objection.

Q BY MR. LITT: In terms of the question of drugs,

was there any change for you after coming into Scientology

with respect to your -- prior to Scientology, and without

asking you any details, had you used any drugs at all?

A Yes.

Q And Scientology helped you to stop using drugs?

A I had stopped using drugs prior to my getting

into Scientology, I did not use drugs through the time that

I was in Scientology.

 

 

 

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Whether or not a conclusion can be drawn from

that, I don't know.

MR. LITT: May I see exhibits N, R, S, and P?

THE COURT: Are you talking about exhibits that are

under seal?

MR. LITT: No; N, R, S, and T are the regular markings.

I don't believe that any of these are under seal.

Q Now, Mr. Armstrong, showing you exhibit N which

is a document entitled "PRO News" that you testified about

in the course of your direct examination, that particular

copy of that publication, is that your copy?

A No. This is Mr. Flynn's copy.

Q So Mr. Flynn showed this copy to you at some

point?

A Yes.

Q When was that?

A Maybe a month or so ago.

Q And how about exhibit R which is a magazine

entitled "Successes of Scientology"; is that your magazine?

A No.

Q And when did you first see that?

A In Vancouver.

Q I mean this particular one.

A Oh, at the same time, from Mr. Flynn.

 

 

 

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Q And with respect to Advance 7 which is exhibit

T, is it true that you first saw this particular copy from

Mr. Flynn about a month ago?

A Yes.

Q And with respect to exhibit X which is entitled

"Scientology, The Field Staff Member Magazine" you first

saw this about a mouth ago?

MR. FLYNN: You mean as opposed to --

Q BY MR. LITT: This particular document.

A Yes.

Q At the same time did Mr. Flynn show you other

documents or publications?

A Yes. We saw some others during that time,

yes.

Q All right now as I understand your testimony,

you have a specific recollection that you saw the "PRO

News" dated April 1970 in Vancouver?

A It is either this one, one real similar,

but in any case I have seen this very early on in Vancouver.

Q But do you remember when you saw it when

you say early on?

A 1969, 1970.

Q You think you had seen the biography earlier?

A Right.

Q Do you know whether you had seen this PRO

News itself or only the biography?

A It was either this or another one similar,

very similar to that. I don't recall all the notes on

 

 

 

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the front because I saw so many of these things, but I

definitely saw with this story in Vancouver.

Q All right. Then, exhibit R, this booklet

entitled "Successes of Scientology" you have a particular

recollection of having seen that?

A Yes, in Vancouver.

Q A copy of that?

A Yes.

Q Do you remember when that was?

A No, it would have been around the same time.

I think both of these publications, this one and that one,

were on sale or they were sold in the Scientology Mission.

I believe they sold for either a dollar or 50 cants each

at that tine, but I bought both of these.

Q Okay, and you read them?

A Yes.

Q So you read not only the biographical part,

but the contents?

A Yes.

Q And exhibit R, the contents deal with, do

they not, statements from a variety of people about their

experience with Scientology and how it helped them?

A Yes.

Q Okay, and you found that of significance?

A Yes.

Q And exhibit S, I take it you also read the

contents of that; is that correct?

A Yes. I don't know if I read every word,

 

 

 

 

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but I would have gone through it, yes.

Q And the booklet itself is approximately 40

pages, 39 or 40 pages long if you include the back; is

that correct?

A Yes.

Q And it discusses a variety of things about

Scientology's belief system; does it not?

A Yes.

Q Discusses, for instance, the eight dynamics?

A Yes.

Q And what are the eight dynamics; do you know?

A The --

Q You don't have to describe every one.

A It divided up the human existence into eight

parts, divided up the urge for survival into survival along

eight separate dynamics or eight distinct parts or paths.

Those are the eight dynamics.

Q Okay, and they go through a range of things

including one's self, family, group, et cetera, is that

right?

A Yes.

Q And you read in here the information about

the tone scale; is that correct?

A Yes.

Q And an article called -- there are articles

called "States of Existence," "Road to Clear," "Scientology

Training," "The Reactive Mind."

You read those things -- "Dianetics"?

 

 

 

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A Yes.

Q And in this exhibit T which is approximately

-- it doesn't have numbered pages, it looks like it is

about 16 pages. Similarly it has a variety of articles

on Scientology and different reports about Scientology

and what it stands for or experiences within Scientology

organizations or what Scientology organizations do?

A Yes.

Q And you read those as well?

A Yes.

Q And this "Advance 7" do you recall when you

read that?

A I believe I saw that same "Advance" while

in Vancouver.

Q Do you recall when?

A 1969 or 1970.

Q Now, Mr. Armstrong, you joined staff in April

1970 and what were your duties?

A I sold books. I gave lectures. I gave courses.

I wrote letters. I mimeographed issues. Took care of

files. I cleaned the building. I sold courses and took

care of the banking.

Q And did you do more auditing during that

period as well?

A I believe that the auditing which I was involved

continued on past the point of my joining staff, yes.

Q And I believe you said that up until April

1970 you had about 40 hours of auditing. Taking the remainder

 

 

 

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of the year, about how many more hours of auditing did

you have?

A I don't know if I had any more during that

year.

Q You can't recall?

A To the best of my recollection I had 40 hours.

There may have been some hours of what is called review.

 

 

 

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A When the auditing doesn't work a particular way,

a review of that auditing is done. And there are various

procedures that are gone through until the person gets the

desired result.

So I complained at one point that I did not get

the desired result and I had some of this review auditing.

My recollection is that I used up the 40 hours which were

allocated for the -- for this auditing. I only paid for

40 hours. And I would have had to pay for more hours to get

more auditing. I think it ended at 40.

Q Okay. Let's take the courses that you say you

lectured; you gave lectures; is that right?

A Yes.

Q And did these lectures have a title?

A I don't believe so.

Q Well, these lectures were for new people who were

coming in and being introduced to Scientology?

A That's correct.

Q And you gave lectures similar to the lectures

you had heard some months before?

A Yes.

Q And in these lectures what would you tell people

in general?

A Information from the communications course that

I was selling what auditing was; what the promises of

auditing were. That was mainly it.

Q And did you give them a general description of

how auditing worked and the concepts of the mind that we have

 

 

 

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already talked about as it pertains in Scientology?

A Yes.

Q Basically, you gave them the kind of review that

you have described that Roger Benett gave to you, perhaps

not as such depth, but some of the various elements of

Scientology belief; correct?

A Yes. My lectures were mainly about what the

courses that a person would take would be about.

Q Okay, And then this course, the communications

course, it also had another name; didn't it?

A Not at that time.

Q Subsequently it had another name; didn't it ever

have the name "The Hubbard Apprentice Scientologist, A

Scientology Course"?

A Yes.

Q But that was afterwards?

A I did not hear that name until I had left the

Vancouver area.

Q And you taught this communications course; is

that correct?

A That is correct.

Q And the communications course, among other things,

was designed to introduce people to certain fundamental

concepts within Scientology; is that correct?

A Yes.

MR. FLYNN: Your Honor, I object at this point. We

spent several days -- I don't know whether this is a First

Amendment area or not.

 

 

 

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But Mr. Litt argued pretty vehemently against

going into anything having to do with the philosophy or

religion of Scientology itself. Whether it is or not, it

is hard for me to tell the way the questions are framed.

I don't believe this has been the subject of direct, number

one.

If Mr. Litt is waiving his claimed First Amendment

Rights on this issue, I think the record should show that.

I don't see any relevancy to this whole line of

questioning on philosophy.

MR. LITT: It has been claimed here that Mr. Armstrong

entered and participated in Scientology based upon what he

had been told about Mr. Hubbard's background. We are

establishing -- and I think have largely established

already -- that he joined Scientology because what he had

learned about Scientology made sense to him at the time.

We are not going into whether any of these things

are correct or not or true or false, but simply what his

state of mind was about what he told people about, what he

did, what he learned, what his motivation was for joining.

I think in light of this claim that has been made

throughout this testimony, that --

THE COURT: I'll overrule the objection.

This is only your first day, I don't expect

to spend the rest of my life on this case. Let's try to move

it along.

MR. LITT: I agree, Your Honor. We'll move through

this period. But we want to show what his general experience

 

 

 

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and attitude was in Scientology. I think there has been

testimony about characterizing it a certain way.

THE COURT: All right.

Q BY MR. LITT: And in the courses that you taught,

among the concepts that you taught were concepts about

Scientology's view of the mind; is that correct?

A Yes.

Q And Scientology's view of the thetan?

A Yes.

Q And the notion that the thetan is the individual

himself and not the body or the mind?

A Yes.

Q And what, that Scientology is -- well, the

relationship between Scientology and Dianetics?

You can answer yes or no. We don't need --

A It may have been mentioned. That varied according

to time. And I really can't say what the relationship was

at that time or even if we covered it in lectures.

Q Okay. What did you tell people about what

Scientology itself was? If people asked you for a one-line

definition of Scientology, what would you tell them?

A The science of knowing how to know.

Q And you also explained the concept of auditing

to people and how auditing worked?

A Yes.

Q And you then spent time discussing with people

about how to improve communications; is that right, between

people?

 

 

 

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A Yes.

Q And how people could learn to communicate with

others better using Scientology?

A Something to that effect, yes.

Q All right.

Now, you said that at a certain point you had

somebody come and talk about the Sea organization; correct?

A Yes. There were two lectures that I recall

concerning the Sea organization to some degree at least.

One of them was a specific Sea Organization Mission. And

one of the purposes of which was recruitment.

The other one was another Sea Organization

Mission, but it was for some other purpose; although

recruitment was, again, a part of it. And I don't recall

what the -- it was an event of some sort and there was --

I don't recall what else was being promoted at that time,

but there was something else.

 

 

 

 

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Q Okay, and in general, you were told that

the Sea Organization was a group of highly dedicated Scientologists

who had committed their life to Scientology; is that right?

A There was such a concept. The way it was

promoted was usually the people who are working directly

with Ron, getting in ethics on the planet.

Q And getting in ethics was a reference to

Scientology concept? In other words, people were saying

that people in the Sea Org were working directly with

Mr. Hubbard and using Scientology to help the world, something

like that? That is what you believed: wasn't it?

A Well it was more along the lines of the world

is an unethical place. There are enemies of mankind who

are destroying the planet and the resolution of that is

to get in ethics, to make it an ethical environment in

which honest actions can have rights.

Q So it was your understanding that the Sea

Org was made up of a group of dedicated people who worked

with Mr. Hubbard who were trying to deal with the situation

on the plant that you have described?

A That is correct.

Q And to change it for the better as you understood

it then and as it was presented to you?

A Yes.

Q All right, and after hearing this, do you

recall who were the people who did this --- gave you these

talks?

A The first one that I attended, I can't tell

 

 

 

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you which came first, but any recollection is that the first

one was Heber and Yvonne Jench. They may not have been

married at that point, so it may have been Heber Jench

and Yvonne Gillam, but they mere definitely the main people

involved in the main event, and the other one was Laurel

Watson. She gave a talk, a lecture.

Q And I wasn't sure whether you said one of

these were sort of mainly focused on the Sea Org itself;

is that right?

A That is the talk given by Laurel.

A Okay, and as a result of hearing these and

your experience in Scientology, you decided to make this

commitment and join the Sea Org; is that right?

A Yes, some time around that.

Q And I take it that at the time you were

enthusiastic about doing this?

A Well, I don't know if enthusiasm is the correct

emotion there. I think maybe I was so frightened that

I did it.

Q You made the decision before you were in

the Sea Organization to join it because you were frightened

about what would happen to the world if the Sea Org didn't

accomplish its mission; is that what you are referring

to?

A Yes. If every Scientologist didn't do everything

he could to help Ron clear the planet.

Q And at the time you agreed that that goal

of clearing the planet was a positive goal?

 

 

 

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A Yes.

Q But nonetheless you made this decision to

commit your whole life to this and you weren't enthusiastic,

simply afraid; is that your testimony?

A I think that is a great deal of a motivation,

a great deal of a motivation which kept me in for so many

years. I think I possibly --

Q Right now we are talking about your joining

the Sea Organization.

A I am explaining that.

Q Okay. So your testimony is that you joined

the Sea Organization because you were afraid?

A I wanted to do whatever I could. I had to

overcome a great deal of fear to do that, but I wanted

to do whatever I could to help this man clear the planet,

to make it an ethical environment, to bring honesty and

integrity to planet Earth.

 

 

 

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Q Right. But your characterization of that is that

you did all of this and made your commitment because of fear;

is that right?

A I am saying that fear was a part of it.

I was being told that we had better get ready

because death's dark curtain is about to descend on this

planet. And there is a great deal of fear wrapped up with

being in Scientology.

I had -- the future of the earth depended on

what I did right there and now in Scientology, quote

Mr. Hubbard.

Q What you and others did?

A Well, what I as an individual did.

Q Okay. So you were afraid; you made this life

long commitment and you left Vancouver then and flew to

Los Angeles; is that right?

A Yes.

Q And you did all of this very rapidly; is that

right?

A The leaving Vancouver, the flying?

Q Well, from the time that these recruitment

speeches that you heard, speeches for people to come into

the Sea organization until the time that you went to

Los Angeles, how long a period was that?

A I went back logging for a period of that time

to make some money. And I sold everything that I had and

bought what was necessary for joining the Sea organization

and went off and joined.

 

 

 

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It probably took -- it was over several months.

Q Okay. So when did these talks from Laurel Watson

and Heber and Yvonne Jench occur?

A During two points in 1970. I don't recall the

exact date, but they predated my leaving.

Q All right. Now, you went to Los Angeles and then

shortly thereafter you, along with several other people,

were sent to the Mediterranean; is that right?

A We were flown to Madrid, Madrid, Spain, and down

to Algeciras which, I believe, is on the Atlantic side of

the Mediterranean.

Q Did you make that trip from Los Angeles to Madrid

with other people?

A Yes.

Q Who were those people?

A One of them was named Amanda Struan; one was named

John Murphy; one of them was named Jim Hausen and there was

another one. I think his last name was Rivera. But I don't

recall his first name. It is a Latin name.

Q Okay. And did all of those people then travel

to the ship with you?

A Yes.

Q And was the ship in Madrid at the time, or did

you have to travel some place else to get to the ship?

A No. The ship was in Tangiers, Morocco.

Q You traveled there by water?

A We flew to Madrid, took the train from Madrid

to Algeciras and from Algeciras across by ferry to Tangiers;

 

 

 

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across the Straits of Gibraltar.

Q This was 1971; what month?

A Early February, 1971.

Q Okay. Now, I am not going to spend much time

on the ship, but I have a couple of questions on that

period.

You described some duties you had where you

were in charge of greeting the people who you would meet

at various portal was that the port captain? Was that --

A I did that regularly from about 1972 through

1975. But it depended on which position I was holding at

the time as to who I would meet when I was the ship's rep.

I generally met -- when we arrived into port,

I would meet the pilot; then the port guard and customs

agent and the port authority for clearing the ship into

port, submitting all the documentation necessary for the

clearance of the vessel into the country.

 

 

 

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Q Now, were part of your duties at certain

points to transport people when the ship was docked, to

drive people to various places? There were vehicles on

board the ship; right?

A I would have been doing the transport of

people during an early period of time when I was -- first

of all when I was called the ship boats and transport in

charge which would have been approximately February or

March.

Q Let me interrupt you because we can short

circuit some of this. I really am looking for brief answers.

Were some of your duties that you would drive

people around at various times? That is all.

A Not when I was greeting these port officials

-- yes.

Q Now your testimony on direct was that throughout

the period of time that you were on board the ship you

were in fear; is that right? I seem to recall some such

testimony.

A Yes.

Q Was this the same kind of fear that you have

described before that you just described earlier that you

were afraid for humanity or what would happen to the planet?

A There was a lot of, I think, a lot of factors,

a lot of fears of different things.

I was afraid of not making it.

Q "Not making it" in Scientology, you mean?

A Yes; not being a good Sea Org member, a fear

 

 

 

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of being RPF'd, fear of being SP, fear of falling out of

favor with L. Ron Hubbard.

There was a number of factors like that which

did not create a state of peace of mind.

Q Now at some point did you leave the ship

before the ships themselves stopped sailing?

A I am not quite sure --

Q Didn't you and your then wife, Terry Gamboa,

at some point take a trip off the ship for some period

of time?

A Yes.

Q When was that?

A In, I believe, September of 1975.

Q Okay, and you went to see your parents; is

that right?

A Yes.

Q And it had been reported to your parents,

had it not, that something had happened to you, either

that you had been killed or you had been shanghaied; is

that right?

A Yes.

Q You and Terry went to see your parents to

reassure them that you were all right; is that right?

A Yes.

Q And how long were you on this trip?

A The segment to Canada?

Q Well, were there other parts to the trip

as well as the trip to Canada?

 

 

 

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A Yes. We also visited Terry's parents. Her

mother was living in Los Angeles. Her father was living

in Phoenix.

Q In total the trip that you took?

A About a month.

Q So you and Terry were gone for

about a month; correct?

A Yes.

Q And you visited both your parents and Terry's

parents and reassured them, did you not, that you were

fine?

A Yes.

Q And you talked to them about Scientology;

correct?

A Yes.

Q Tried to make them feel comfortable with

the fact that you were in Scientology?

A Yes.

Q And to assure them that you were happy in

Scientology?

A Yes.

Q And that you liked what you were doing?

A Yes.

Q And that they shouldn't be concerned about

you?

A Yes.

Q And that you were doing what you thought

was important to you?

 

 

 

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A Yes.

Q All right. Now you believed all those things

when you told them that, didn't you, or were you lying

to your parents?

A I did lie to my parents regularly.

 

 

 

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Q I am asking you about this discussion; you

believed those things, then, didn't you, Mr. Armstrong, that

you were telling me?

A I did -- at a minimum. I believed that it was

right for me to tell them that.

Q You are not answering my question.

A I know. It is a difficult question to answer.

Q You have got to try to answer it.

Didn't you believe those things then?

A One of those things -- yes; at least on some

level I believed those things.

Q And you then voluntarily returned to the ship

with your wife; isn't that right?

A Yes.

Q Nobody made you return; you returned because you

wanted to; is that right?

THE COURT: You have got a compound question there,

counsel.

MR. LITT: I am sorry, Your Honor.

Q You returned because you wanted to; isn't that

correct?

A Yes.

Q Nobody forced you to return to the ship; isn't

that correct?

A That is true.

Q Now, Mr. Armstrong, you testified that you gave

some books to your -- I believe you said to your parents

and also to someone else while you were on this trip that

 

 

 

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you have described; is that right?

A Yes.

Q And the name of this particular book that you

gave is "Scientology a World Religion Emerges in the Space

Age"; is that right?

A Yes.

MR. LITT: May we have this marked next in order, Your

Honor?

THE COURT: Plaintiff's 23.

MR. LITT: Your Honor, I am going to spend some time

on this particular book. So if -- it is up to the court;

I can begin, but it is five minutes to 4:00. And so we

can --

THE COURT: We might as well use the five minutes.

MR. FLYNN: Your Honor, may I register an objection

to the use of any part of the book?

THE COURT: Well, I don't know what the first question

is. We'll deal with the question when it is asked.

Q BY MR. LITT: Well, the first question is you

gave people this particular book because you felt it would

give them an introduction --

THE COURT: I don't know that there is any evidence

that he gave people --

MR. LITT: The people that I am referring to --

Q That is, your parents and somebody from Parliament

or something like that?

A Yes. Actually, I took one to the member of

Parliament, but he wasn't there. So I ended up giving it

 

 

 

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to the chief of police of the town that I was from.

Q And you gave both of these people that book

because you felt that it would give then a good general

introduction to Scientology for someone who was not familiar

with it and who hadn't had any experience with it; is that

correct?

A I think the prime motivatiou in giving them the

book was because I was ordered to do so by the assistant

controller for intelligence, Jimmy Mulligan. I was briefed

by him before leaving the ship. And this was part of the

DA materials which he provided to me and which I was to

provide to the official who my mother had contacted in trying

to find out where I was.

 

 

 

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Q But the reason for that was that this was

a general introduction that would explain, it does explain

basic concepts of Scientology that we have already talked

about; right? Do you recall that?

MR. FLYNN: I am going to object. You mean the basic

concepts as the witness now understands them?

MR. LITT: No, as he understood them --

MR. FLYNN: Or the basic concepts that he says are

falsely represented?

MR. LITT: The basic concepts as he understood them

at the time.

MR. FLYNN: Well it would call for speculation,

too, Your Honor.

He said he did it on orders of a fellow named

Mulligan, and Mr. Mulligan was attached to the intelligence

unit, so he'd be speculating as what Mr. Mulligan's intentions

were.

THE COURT: Well t is ambiguous. It is not quite

clear whose intentions we are talking about.

Q BY MR. LITT: You testified earlier, Mr. Armstrong,

that you were generally familiar with this book; correct?

A Yes.

Q And you had at least read it in a -- if not

in detail, you had reviewed it, correct, before you gave

it to your parents?

A Yes, not in detail but I had looked at it.

Q And you agreed at the time, didn't you, that

it presented a basic introduction for a non-Scientologist

 

 

 

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concerning several concepts of Scientology and information

that would be helpful to understand Scientology?

A Well, that was a part of it. That wasn't

the way I was viewing --

Q My question --

MR. FLYNN: Your Honor, could the witness finish?

MR. LITT: The: answer is nonresponsive, Your Honor.

THE COURT: Well, then, let's read the question

back and listen to it carefully.

(Record read.)

THE COURT: Well it is a compound question and you

asked if he agreed. You could ask him what his state of

mind was. I don't know, agreement involves two people

usually.

Q BY MR. LITT: Your state of mind at that

time, Mr. Armstrong, was it not that this book explained

several basic ideas of Scientology?

A Okay.

 

 

 

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Q Right.

A At least to some degree, yes.

Q And it was presented in a way that you felt could

be understood by someone who was not a Scientologist?

A Yes.

Q And so you then gave this book to your parents

and to this chief of police, feeling that it would provide

them such a basic introduction for a non-Scientologist;

didn't you?

A That was part of the reason, yes.

THE COURT: We'll take our recess. We'll reconvene

tomorrow morning at 9 o'clock.

(At 4:00 p.m., an adjournment was taken

until Thursday, May 17, 1984; at 9:00 a.m.)

 

 

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