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THEREUPON,

            GERALD D. ARMSTRONG,

the deponent herein, being first duly sworn on oath,

was examined and deposed as follows:

             EXAMINATION

BY MR. DANDAR:

  Q   Please state your full name.

  A   Gerald David Armstrong. G-e-r-a-1-d.

  Q   Do you also go by Gerry?

  A   Yes.

  Q   Okay. And, Mr. Armstrong, are you here today

under subpoena that I had served on you?

  A   Yes.

  Q   And where do you reside?

    MR. WEINBERG: Excuse me. I would like to see

  the subpoena.

  Q   (By Mr. Dandar) Do you have it with you?

  A   I believe so.

    MR. WEINBERG: And I'd like to conduct some

  voir dire with regard to the circumstances under

  which Mr. Armstrong is here today.

    A  ll right. If we would mark this as the first

  exhibit.

     MR. DANDAR: Well, I'm not going to let you

  voir dire. You can do that in your cross

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examination.

  MR. WEINBERG: No, Ken, then -- no, we cannot.

Then we have a serious problem with this

deposition.

  MR. DANDAR: Well, let's call the judge right

now on the telephone if you have a problem.

  MR. WEINBERG: First I want to talk about it

and I want you to understand what the problem is.

First of all, Mr. Armstrong is subject to a

permanent injunction which was issued in California

in the Superior Court, State of California, for the

County of Marin, on October 17, 1995. Now, that

injunction --

Do you have a copy of it?

  MR. DANDAR: No, I don't. This was argued two

days ago before Judge Moody, and your motion --

  MR. WEINBERG: Well, I don't believe this

issue was argued.

  MR. DANDAR: -- was denied and then you waived

it.

  MR. WEINBERG: No, no.

  MR. DANDAR: And he's under subpoena.

  MR. WEINBERG: No, absolutely not

  MR. DANDAR: All right. That's it. I'm not

going to waste my time with an out-of-country

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deponent while you argue to me what the law is. So

we will simply get Judge Moody on the telephone,

okay?

  MR. WEINBERG: And before we get Judge Moody

shouldn't we establish what the factual basis is

for Mr. Armstrong being here?

  MR. DANDAR: No. You tried to do that at a

hearing and it was denied, and I'm not going to

waste my time.

  MR. WEINBERG: How could we do that when Mr.

Armstrong wasn't at the hearing. It indicates he

was served on December 3rd.

  MR. DANDAR: Of course. He was served when he

was in the State of Florida.

  MR. WEINBERG: And what the injunction

prevents him from doing is in any way cooperating

against Scientology, talking to anybody about

Scientology. Now, how did an out-of-country person

who you noticed for a deposition on November 20th

get here if he was served on December 3rd.

  The fact of the matter is he is in contempt of

court twice out there. There is a bench warrant

that calls for his imprisonment for 28 days. And

the injunction is not just against Mr. Armstrong

but it's against anyone acting in concert with Mr.

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  2:00. Okay.

             EXAMINATION

BY MR. WEINBERG:

  Q   Mr. Armstrong, when were you first contacted

with regard to giving a deposition concerning the Lisa

McPherson matter?

  A   I would say perhaps two weeks ago.

  Q   And where were you when you were contacted?

  A   In British Columbia.

  Q   Who contacted you?

  A   Mr. Dandar.

  Q   By telephone?

  A   Yes.

  Q   Had you communicated with Mr. Dandar prior to

that time?

  A   Yes.

  Q   When?

  A   Some -- I would say some months before I had

let him know who I was. I believe by e-mail.

  Q   When was that? Do you have that e-mail, by

the way?

  A   No.

  Q   What did you say in the e-mail?

  A  I recall that I had, I believed, information

about people being treated similarly to the way I

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understood Lisa McPherson had been treated.

  Q  Specifically what did you say in the e-mail?

  A   That's what I'm saying.

  Q   And you're talking about treated similarly by

Scientology?

  A   Right.

  Q   And did you get a response back from Mr.

Dandar?

  A   I believe so, yes.

  Q   Well, you know so.

  A   Well, I don't have a specific recollection,

but I believe that he did. After that we communicated,

so I believe so.

  Q   Well, after that you communicated on a routine

basis with Mr. Dandar?

  A   No.

  Q   How many times have you communicated with Mr.

Dandar since you e-mailed him?

  A   I did not subsequently communicate with him

again aside from that time some months ago, and until

two weeks ago.

  Q   You seem to have a very good recollection of

events that occurred in 1972 and 1973 and 1976, all

right?

  A   I have --

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  A  I believe so.

  Q   And what did Mr. Dandar say to you?

  A   I believe that it was a simple acknowledgment

of having received whatever I sent him.

  Q   Do you remember specifically what Mr. Dandar

said in his e-mail?

  A   My recollection is that the communication back

was merely an acknowledgment of what I had said to him.

Now, there was a time -- and I think that there was a

subsequent communication when he asked about -- and my

recollection is here that he may have heard -- without --

this is just speculating for the moment -- that he had --

he asked about the injunction.

  Q   The injunction against you?

  A   Right.

  Q   All right. Was this an e-mail or a telephone

call?

  A   My recollection is that it was an e-mail and I

responded, and that was the end of our communications

for several months until this last within two weeks.

  Q   So Mr. Dandar asked you about the injunction

that we'll get into in a little while at or about the

time that you first e-mailed him about having

information that may be helpful to him?

  A   Right.

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  Q  Okay. And what did you respond to Mr. Dandar

about the injunction?

  A   I don't recall specifically. My recollection

is explaining it to him.

  Q   Well, what did you explain to him?

  A   That according to the injunction -- and this

is a recollection, because I would say the same thing to

anyone and I say it to so many people that it's the same

story. That according to the injunction I can only

testify pursuant to a subpoena.

  Q   What else did you tell him?

  A   That's basically it.

  Q   Now, in the communications did you explain to

him that under the injunction you couldn't even

communicate with him about Scientology, that that was a

violation of the injunction? Did you explain that to

him?

  A   I very easily may have.

  Q  Because it is a violation of the injunction

for you to communicate with people about Scientology?

  A   Yes, it is.

  Q   Okay. Did you, back whenever this was a few

months ago, give details to Mr. Dandar about that which

you believe that you could assist him with regard to his

lawsuit?

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  A   Correct.

  Q   When you communicated with Mr. Dandar a few

weeks ago and told him you were coming to Florida, you

were attempting to assist him with regard to a case

against the Church of Scientology, right?

  A  Correct.

   Q Mr. Dandar didn't force you to come to

Florida, did he?

  A  Correct. He had nothing to do with my coming

to Florida.

  Q  Mr. Dandar didn't compel you to come to

Florida, did he?

  A  Correct.

  Q  He didn't serve you with a subpoena requiring

you to come to Florida for a deposition, did he?

  A  Only upon my arrival.

  Q  That's not my -- listen to my question. He

didn't go through a process that caused a subpoena to be

served on you in British Columbia that required you to

travel from one country to another for a deposition, did

he?

  A  Correct.

  Q  You traveled here on your own voluntarily,

correct?

  A  Correct.

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