Gerry Armstrong--Declaration of Gerald Armstrong 09-15-1995

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CT 5894

Gerald Armstrong
715 Sir Francis Drake Boulevard
San Anselmo, CA 94960
(415)456-8450
In Propria Persona

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF MARIN

CHURCH OF SCIENTOLOGY INTERNATIONAL,
a California not-for-profit
religious corporation,

Plaintiff,

vs.

GERALD ARMSTRONG; MICHAEL WALTON; THE GERALD ARMSTRONG CORPORATION
a California for-profit corporation; DOES 1 through 100,
inclusive,

Defendants.

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No. 157 680

DECLARATION OF
GERALD ARMSTRONG
IN OPPOSITION TO
MOTIONS FOR SUMMARY
ADJUDICATION OF 20TH
CAUSE OF ACTION; AND
13TH, 16TH, 17TH &
19TH CAUSES OF ACTION
OF SECOND AMENDED
COMPLAINT

Date: 9/29/95/
Time: 9:00 a.m.
Dept: One
Trial Date: Not Set

DECLARATION OF GERALD ARMSTRONG

I, Gerald Armstrong, declare:

1. I have personal knowledge of the facts set forth in this

declaration and could competently testify thereto if called as a

witness.

2. I am a Christian.

3. My life, in every moment and breath, is God's and in His

Hands. I have been saved from eternal separation and hell to

become a son of God by His Grace alone, and drawn by Him to trust

and follow His Son Jesus Christ as my Lord and Savior. I have

been filled with God's Holy Spirit, and given by Him all peace,

wisdom and love. I have been saved for God's Purposes to His

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CT 5895

Glory. I believe that His Purpose for me and all the world is

salvation. I believe that the only difference of any meaning at

any time between me and anyone else on this earth is this belief

in God's Plan for salvation.

4. As a Christian and as a son of God I have been led and

will be led into all of my life's situations and to all of the

people I have encountered and will encounter for His Purposes

alone. I believe that from God come all things, including the

trust in Him, the willingness to believe on Him, free will, peace,

wisdom and love.

5. I was raised as a "Christian" in the Anglican Church in

Chilliwack, B.C., Canada, and I retained some of the Christian

learning of my youth through my Scientology years. I was in

Scientology from the age of 22 to the age of 35. When I first got

into Scientology it professed, as it does with every new person,

to be completely compatible with Christianity. It claimed to be a

science, and its promises "demonstrably true." It claimed that it

and its promises were the product of the scientific research of L.

Ron Hubbard, Scientology's founder and leader, who also claimed to

be an engineer and a nuclear physicist. Hubbard claimed that his

techniques, procedures, end results and products had been

subjected to the "rigors of the scientific method." Scientology

also claimed to be "religion in the oldest meaning of the word,"

and "pan-denominational," accepting people of all religions and

beliefs, but itself not requiring belief to deliver on its

promises. In those days Scientology published a booklet called

"Scientology and the Bible," in which Biblical quotations were

compared as similar in meaning to quotations from Hubbard's works.

6. Throughout my Scientology years I put my faith in

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CT 5896

Hubbard, and in his philosophy, mental "science" and

organizational policies. Through God's Grace and Wisdom I came to

see that this was a misplaced faith. I came to see that despite

that misplaced faith, God never deserted me, that He was with me

and keeping me safe every moment, just as He is now. Throughout

my Scientology years, through abuse, danger, and betrayal, He kept

my heart from being hardened beyond salvation.

7. God kept me from being completely taken over by

Scientology through all the years of indoctrination, mind control,

"ethics," threat and punishment; and through the more than a

thousand hours of mental processing, what Scientology calls

"auditing." When Hubbard assigned me twice to the Rehabilitation

Project Force (RPF), Scientology's prison, for a total of twenty-

five months, when he had his messengers order my wife Terri to

leave me, when I was ordered security checked for questioning

Hubbard's truthfulness, God brought me through safely, made me

stronger and wiser, and kept my heart from hardening. I now know

that I was so deeply involved with Scientology, so devoted to an

ungodly man and his ungodly teaching, only God's Own leading me,

through His mysterious way, could have saved me. He led me into

the Hubbard archive and biography project, brought me to study the

man's secret papers and document his duplicity, and freed my faith

from Scientology, on which it had been misplaced.

8. I now see that Scientology is the clever human invention

of a clever human who took his human cleverness as far as it would

go for his own glorification. I believe that God used me, an

unsaved man, an uneducated, unrefined and very imperfect vessel,

to accomplish part of His Plan for Scientology, Scientologists and

salvation. I can see how it took someone with a God-given

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CT 5897

history, character and skills such as He gave me to bring out of

Scientology, to the light, and to the minds and hearts of all

those whom God sent to listen, a testimony of the character of

Scientology's product and "source." I believe that God continues

to use me to reflect the unworthiness and bankruptcy of Hubbard's

attempt to create his own salvation plan, against the

infallibility and peaceful grandeur of God's Plan.

9. In my post-Scientology period, when first in the outside

world, confused and afraid, God took me in His Hands for

particular care and teaching. When Scientology's leaders sent

hired private investigators to spy on me and my wife, and

essentially to terrorize us, God kept me, in spite of my fear and

desperation, emotionally intact. God used Scientology's

"Suppressive Person Declares," which, when I heard of and read

gave me the shakes, to make me stronger and to bring the ungodly

practice of "declaring" people, and targeting them as "fair game, "

to light. He allowed Scientology to sue me so that its abuse of

His children, the pathology of its "religious leader," and the

baseness of its "theology" would be brought to light through my

1984 trial and the resulting "Breckenridge decision." When

Scientology's leaders still resisted God's chastening, He caused

the 1991 published opinion Scientology v. Gerald Armstrong, 283

Cal.Rptr. 917.

10. At the first hearing in my case in 1982, God somehow put

into my hands a tiny tract of Bible quotes which I held and put my

heart on as fear gripped at me. I've lost it since; it was about

two inches square, and yellow colored, my first post-Scientology

reach for God's Word. Throughout the 1984 trial, where I was on

the stand for about ten days, I depended on the Twenty-third Psalm

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CT 5898

to calm my mind and heart. Between questions, over and over, "The

Lord is my shepherd; I shall not want....Yea, though I walk

through the valley of the shadow of death, I will fear no evil:

for Thou art with me..."

11. God allowed Scientology's leaders to "cull" my
"preclear

folders." They took out of my supposedly confidential counseling

files embarrassing or unsavory incidents from my past, and then

divulged them in court and elsewhere, so that light would be shone

on this terrible practice. God allowed these leaders to

disseminate invented disgraceful incidents, as if I had

"confessed" them during "auditing." God allowed me to humiliated

and my heart to be broken over and over by the cruel acts directed

by Scientology's leaders.

12. God allowed me to be terrorized, my car broken into, my

drawings and writings to be stolen, other writings and ideas of

mine perverted and held up to ridicule. He allowed Scientology's

leaders to become intoxicated by their own lies so that they would

try time after time to have me jailed on their false and

manufactured criminal charges. He allowed their self-deception,

so that they concocted a perverse intelligence scheme to entrap me

in a crime and have me prosecuted. He allowed Scientology's

leaders to put their faith in a base private investigator, Eugene

Ingram, whom they would use to illegally videotape me, and who

threatened to put a bullet between my eyes. God allowed the heart

of an Los Angeles Police Department Officer, Philip Rodriguez, to

be tempted by greed, and paid for a false authorization to

Scientology to illegally videotape me. He allowed my friend Dan

Sherman to use our friendship to betray me, to lead me with kind

words into danger, to set me up, to trick from me my thoughts and

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CT 5899

writings, and to break my heart.

13. God allowed my own judgment to be clouded so that I

would continue to walk unheeding into Scientology's intelligence

scheme. In my childhood He gave me a desire to help the needy and

the oppressed. He let Scientology's leaders divine and fix upon

this God-given desire, and then manipulate the desire for their

own purposes. It was during this period, when I sensed that I

indeed might be walking into a trap, that I sensed God's close

Presence, began to understand guidance, hoped and believed that I

was being guided, and chose in the face of danger to keep going

forward into whatever God unfolded. He allowed me to curse and to

say things in ignorance or anger while being secretly recorded and

videotaped, so that Scientology's leaders would be deluded into

thinking these words would destroy me. In their delusion and rush

to expose and destroy me, their trap, criminality and malevolent

purposes were themselves exposed. Asking nothing more than my

small willingness to go forward in faith, God brought me safely,

albeit shamed and shaken, through all of Scientology's schemes,

snares and temptations.

14. God allowed Scientology's leaders to also attack my

attorney Michael Flynn, my good friend, benefactor and champion in

the legal battle. God allowed Scientology to sue him some fifteen

times, to threaten him, his family and career, to frame him with

forgery, to pay known criminals to bear false witness against him,

and, according to him, to attempt his assassination. God allowed

Scientology's leaders to think they could destroy Flynn with their

"black propaganda," "dead agent" packs, "noisy investigations,"

and the compromise and turning of other clients. Scientology

worked for seven years to achieve this destruction. God brought

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CT 5900

me to Flynn, and him to me, and brought us to fight alongside each

other in a legal and spiritual battle against the threat and evil

of Hubbard and his organization from 1982 through 1986. In 1985

through 1986 I worked in his office in Boston. I depended on

Flynn in those days. I loved him as if he were a big brother, and

I tried in my role and capacity to help him and support him as a

younger brother should.

15. I lived my own life as well, away from the Scientology

battle, during those years, being brought ever closer to God.

When I was alone, at times in terrible fear, He kept me safe, and

allowed my heart to break, over and over. I believe He spoke to

me, and that at times, as early as 1983, I wrote His Words to me

under His guidance in what seemed to be dialogues. He gave me the

idea for the true protection of His Children in this world, and

moved me in 1986 to found a church, based on this concept. The

Church, which is free to everyone, including Scientologists, has a

belief, a corollary, and the obvious. The belief, out of Jesus's

teachings (See, e.g. Matthew 18:20) is that when members of the

Church are together, God is present. The corollary is that

whatever is said or done when members of the Church are together

is sacred. The obvious is that it is always thus. Scientology's

lawyers attack my Church but it remains and lives under God's Will

for His Glory.

16. With Scientology facing tremendous exposure and

liability in my cross-complaint for years of outrageous fair game

attacks, and having just suffered a $30,000,000 verdict in the

case of Lawrence Wollersheim v. Scientology, Los Angeles Superior

Court No. C 332027, God, almost incomprehensibly, then allowed

Flynn to lose heart. Flynn "negotiated" a deal with Scientology

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CT 5901

which involved getting his clients to agree to the organization's

demanded contractual condition of silence about their

"experiences," while not demanding the same protection for his

clients. Many of these clients had been the target of

Scientology's "black propaganda" campaigns. He also agreed to get

his clients to agree to a "liquidated damages" penalty of $50,000

per comment about their experiences. Flynn did this while

believing, and having ample experience to justify believing, that

the settlement agreements were evil, as was the entity which was

insisting on the "agreements" being signed as a condition of

settlement. Flynn knew Scientology's word was not to be trusted,

yet he conveyed and gave support to Scientology's "promise" that

it was going to discontinue fair game.

17. God allowed Scientology to harass, threaten and

compromise Flynn, and allowed Flynn to be persecuted and

compromised, for His Purpose to His Own Glory. After flying me

from Boston to Los Angeles in December, 1986, Flynn presented the

settlement documents to me for the first time. Upon reading the

conditions in the "agreement," I was, as I've stated many times

since, heartsick. I protested that it was impossible to live by

Scientology's conditions, and that the "liquidated damages"

penalty of $50,000 each time I might speak to anyone about my then

seventeen years of experiences, was madness. And then God allowed

Flynn to say the words, from his fear and desperation, but

ultimately from truth, "Gerry, it's not worth the paper it's

printed on. It's unenforceable. You can't contract away your

Constitutional rights." God allowed Flynn to point out to me my

release of Scientology and my dismissal of my lawsuit, and allowed

him to say, "That's what they're paying you for."

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CT 5902

18. Flynn conveyed to me a picture of all who depended on me

to sign the evil documents to get them "free" from Scientology's

threat. He said that Scientology had promised to cease all "fair

game" actions, to cease the attacks on all the settling

individuals, and on every one else. He said that Scientology

wanted the opportunity, which, he said, the settlement would give

them, to prove that they had turned over a new leaf, and had

ceased fair game. He said that he had to get out of the fight,

that he had done enough, that he had paid his dues, that

Scientology had ruined his marriage, his wife's health and his

life. He said that if I didn't sign all I would get would be more

of the same attacks, threat and misery. He said that I had to get

on with my life, that I too had to get out of the litigation, get

away from Scientology's threat, and that everyone had to get out

of it, out of the madness of this battle with evil.

19. God made me aware of His Spirit at that moment, when I

was alone, rejected from Mike Flynn's heart, and yelled at by

another "client" as a "deal breaker," simply for caring. God

showed me a glimpse of the future at that moment; that I might be

left alone, that I might be persecuted, but that I should not

fear; and that I should at that time give everyone involved what

they wanted, what they thought they needed to be free. So,

because of Flynn's promise of the agreement's unenforceability, my

desire to end the threat if possible for everyone, Scientology's

promise to end fair game, and God's Assurance, I did sign.

20. After the "settlement," God gave me a time of some quiet

and joy to write, draw, get strong after years of deteriorating

health, to hang out with friends, and to be drawn ever closer to

Him. In 1987 He chose me and came to me in the undeniable

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CT 5903

Physical Substance of His Love, and gave me a greater view of my

future role in His Plan. In 1988 He brought me to offer my life

in exchange for the captives then held in Lebanon. He schooled me

in the understanding of His Nature and set me on the path to

become by 1989 one of His Teachers. Also in 1989 He gave me an

understanding of the valuelessness of money, and a glimpse of His

solution for the grinding cruelty of the world's economic system.

He brought to me a glory of four-leaf clovers. He showed me that

through my life He could bring to the world the mathematical proof

of His guidance. He moved me to run like the wind, and to pick up

the world's trash, all for His Glory.

21. During the post-settlement years, God also allowed the

hearts of Scientology's leaders to grow ever harder and to

manifest in attack after attack on my character and credibility.

It became clear, and saddened me greatly, that these leaders had

not stopped "fair game," but were using the cessation of the

litigation by Flynn and his clients as an opportunity to continue

their antisocial practices unchecked. They published their own

false versions of my history, delivered their "black propaganda"

packs on me to the press, which included documents Scientology

itself had insisted be sealed in my case and in other cases. They

used Gene Ingram in their attacks, disseminating to the press an

edited version of his illegal videotape, which had also been

sealed in my case. They filed false affidavits attacking me in

civil cases and in their litigation with the IRS. Scientology's

lawyers threatened through Mike Flynn, that if I responded to the

attacks, or even talked to any of the opposing attorneys in a case

in which Scientology filed its false affidavits about me, they

would consider my talking a breach of the "agreement," and would

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CT 5904

sue me.

22. God allowed my heart to be broken by each attack and the

daily knowledge that Scientology had not ceased fair game, yet He

kept me from responding with anything other than sadness for

almost three years. Then, in the fall of 1989, I was served with

a deposition subpoena by the attorney for Bent Corydon in the case

of Corydon v. Scientology, Los Angeles Superior Court No. C694401.

Following this I received a series of calls from Scientology

attorney Lawrence Heller who threatened that, even pursuant to

Corydon's subpoena, if I testified about my knowledge of Hubbard

and Scientology I would be sued. I was deeply troubled by

Heller's threats, the idea of succumbing to those threats, and the

injustice and evil the settlement agreements had spawned. God

brought me at that time to a determination to do what I could to

bring to light and correct that injustice and evil. When I began

to research my rights, responsibilities and how to proceed, I

learned that through the intervening five years Scientology had

been able to maintain an appeal, Scientology v. Armstrong, No.

B025920, from the 1984 Breckenridge decision, and my first actions

concerned that appeal.

23. Much of my history and legal involvement with

Scientology from that point is told in the declarations and other

documents appended hereto. Exhibit A is a true and correct copy

of a declaration I executed March 15, 1990 and filed in the

B025920 appeal and a consolidated appeal, No. B038975, along with

true and correct copies of certain exhibits which were appended to

the original declaration.

24. Exhibit B hereto is a true and correct copy of a

declaration I executed December 25, 1990 and filed in

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CT 5905

Scientology's appeals, along with true and correct copies of

certain exhibits which were appended to the original declaration.

25. Exhibit C hereto is a true and correct copy a Court of

Appeal published opinion affirming the Breckenridge decision.

Scientology v. Armstrong, 283 Cal. Rptr. 917 (Cal. Ap. 2nd Dist.

1991). Exhibit D hereto is a true and correct copy of

Scientology's motion to seal record on appeal in Appeal Nos.

B025920 and B038975, supporting declaration. Exhibit E hereto is a

true and correct copy of my opposition to the motion to seal

record on appeal, supporting declaration, and exhibits thereto.

Exhibit F hereto is a true and correct copy ofrder of the Court of

Appeal dated December 5, 1991 denying the motion to seal record.

26. Exhibit G hereto is a true and correct copy of a

declaration I executed March 16, 1992 and filed in the instant

case (which then had Marin Superior Court No. 152229), along with

true and correct copies of certain exhibits which were appended to

the original declaration.

27. Exhibit H hereto is a true and correct copy of a

declaration and literary work, entitled "I Declare," I executed

January 13, 1994, along with certain exhibits thereto. I wrote "I

Declare" for filing in a lawsuit Scientology brought against me in

1993, in which it charged that my giving away my worldly assets

and forgiving debts owed me in 1990 were "fraudulent conveyances."

The organization asserts that my renunciation was to avoid the

claims it raised in another lawsuit it brought in 1992 for

liquidated damages stemming from what it alleges are breaches by

me in 1991 of its 1986 settlement agreement. My renunciation had

nothing to do with Scientology, but was the result of my asking

God in prayer for guidance at the time of, and precipitated by,

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CT 5906

the Middle East crisis which built into Desert Storm, and the

trouble I felt about the world situation, the general state of

mankind, and what God wanted me to do.

28. The answer, which I truly believe is God's, was to give

my things away, take only what I needed, and then, under His

guidance, to go wherever my help was asked for. That is what I

did and how I have tried to live my life ever since. My life has

been forever changed from that decision and from following that

guidance. I had no idea where I would be led or what I would do,

other than to try to discern and do God's Will. I know I have not

always discerned correctly, and I know that I still have an old

willful nature. I also know that God has drawn me steadily,

through joyful times, and through difficult, threatening and

tearful times, closer and closer to Him, and that He has given me

a new nature which is Christ's.

29. As God would have it, some of the people who were led to

me and asked for my help following my 1990 decision to go where He

led me were those who had been fair game's victims in the post-

global settlement period. In June, 1991, a South African man,

Malcolm Nothling, who had been defamed and defrauded by the

organization, called for my help. In July, 1991, Joseph Yanny, a

former attorney for Scientology, who had become its fair game

target and was attempting to assist other Scientology victims,

Richard and Vicki Aznaran, asked me to help. In the Aznaran's

case, the effect of the settlement agreements on their ability to

obtain counsel and on their ability to oppose Scientology's

efforts to deny them due process became relevant. In August,

1991, God led me to Ford Greene, one of the few surviving

attorneys willing to take cases on behalf of Scientology's

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CT 5907

victims. Ford also asked for my help. All of this history is

covered in detail in "I Declare."

30. Seizing on my responses to the requests for help from

people God had sent to me, Scientology's leaders have, since 1991,

carried out a withering litigation campaign to silence and destroy

me through judicial enforcement of the settlement agreement.

Throughout the litigation and until recently I was defended by

Ford Greene, for whom I, also until recently, worked as his sole

office assistant, and who became through the years my good friend.

Scientology first brought a motion to enforce in the original

case, Scientology v. Armstrong, Los Angeles Superior Court No. C

420153, which was denied. They then filed a lawsuit for breach of

contract, Scientology v. Armstrong, Marin Superior Court No.

152229, which was transferred to Los Angeles Superior Court and

given number BC 052395. They obtained a partial injunction in

that case in May, 1992, which I appealed. The appeal, Scientology

v. Armstrong, Cal. Ap. 2nd Dist. No. B 069450, stayed proceedings

in BC 052395 from March, 1993 through May, 1994. During the stay

Scientology filed two more lawsuits against me, Los Angeles

Superior Court No. BC 084642, and Marin Superior Court No. 157680,

the "fraudulent conveyance" action for which I wrote "I Declare."

Scientology also tried repeatedly to have me found in contempt of

court and jailed for alleged violations of the partial injunction,

some of which "violations" Scientology's own personnel

manufactured. This period was threatening and difficult, but I

was buoyed by the hope that some court would see through

Scientology's lies and attacks, and a certainty was developing in

me that God's Will in His good time would triumph.

31. What I saw and see as an unconscionable unfairness has

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CT 5908

perplexed me throughout this litigation. Scientology claims that

by the "agreement" they can say whatever they want about me, and

that I cannot respond in any way. Such a concept is un-American

and patently unfair. If I had known that this is the meaning of

the settlement agreement, and that any court could possibly

consider that this is its meaning; that Scientology is free to

attack me or anyone else, that it was going to be fair game as

usual, but without my being legally able to respond or defend

myself or anyone else, I would never, for all the money in the

world, have signed that terrible document. The whole set of

"settlement agreements," which are commonly known as the "Flynn

agreements," are unfair to anyone who litigates either as a

defendant or plaintiff against Scientology, since these agreements

remove knowledgeable witnesses from the legal arena and drive up

litigation costs. The "agreements" are also unfair to the public

because they allow Scientology's leaders to rewrite history, lie

about judicially credited information, attack the sources of that

information without response, and convey the idea that it is

futile to speak the truth or oppose their tyranny. These

"agreements" obstruct justice. There is also a tragic unfairness

worked on all those people trapped inside Scientology and abused

by the organization because the agreements abet the denial of

accurate information to those Scientologists and convey a sense of

hopelessness to any who might begin to break free and might be

contemplating seeking redress for that abuse. These unfairnesses

have been a major factor in my continuing in the litigation,

despite the threat and difficulty, in the hope that some court

will adjudge the agreements illegal. If such unfairnesses are

ultimately ruled fair, it will be unfair to anyone who looks to

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CT 5909

our justice system for justice; and the justice system will become

fair game to those who seek injustice.

32. There is another unfairness crafted by Scientology's

lawyers in connection with the attacks on me which is particularly

troubling. Throughout the litigation I have written and spoken to

Mike Flynn dozens of times asking him to come forward and provide

a declaration concerning the circumstances at the time of the

settlement, the duress Scientology subjected him to, the duress

his other clients were subjected to, the picture of this duress

that he conveyed to me, and Scientology's promise to cease fair

game. I have asked him dozens of times to confirm in a

declaration the representations he made to me about the

unenforceability of the liquidated damages penalty, that it was

"not worth the paper it's printed on," that my release of

Scientology was only to the date of the signing of the agreement,

that my responses to its post-settlement attacks were not breaches

of the agreement, and that Scientology obtained his willingness to

have his clients and himself sign the "agreements" by fraud, as

evidenced by the fact that fair game continued as before. Flynn

has said throughout this litigation, however, that he signed an

agreement like the one he had me sign, and he is afraid that

Scientology will sue him, as it has me, and again make his life

hell if he helps me. Ford requested Scientology to release Flynn,

as a percipient witness, from the "contract" by which they prevent

his assisting me, but Scientology has refused. Flynn continues to

say that the agreement is evil, and the Scientology organization

is evil, but that the courts of this country cannot deal with

Scientology. He says that although he is saddened by my plight

and wants to help me in my case he cannot and will not. This

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CT 5910

unwillingness by Flynn to come forward and tell the truth, which,

if he did, I believe would bring any judge on the case to rule the

settlement agreement illegal and end the litigation, has many

times through these years greatly disheartened me. Nevertheless,

I now see that even this aspect of this spiritual war is in God's

Hands and He is using it to His Glory.

33. Since the beginning of 1994 when I wrote "I Declare,"

Scientology has continued without relent to press its litigation

assault on me. On May 16, 1994, the Court of Appeal denied my

appeal, ruling that the partial injunction was not an abuse of the

Judge's discretion, and declining to address the legality or

illegality of the underlying settlement contract. On July 28,

1994, after an evidentiary hearing, Los Angeles Superior Court

Judge Diane Wayne dismissed all of the contempt charges against

me. In August, 1994, Ford brought a summary adjudication motion

on my behalf in the fraudulent conveyance action, based in part on

a religious defense, since the idea of conveying my worldly assets

was God's answer to my prayer to Him, and the acts which flowed

from that idea were, although unrelated to Scientology,

religiously motivated. Exhibit I is a true and correct copy of a

declaration I executed August 12, 1994 and filed in support of

this summary adjudication motion, along with true and correct

copies of certain exhibits which were appended to the original

declaration. Judge Thomas, in denying my motion ruled that "the

religious beliefs of the parties are irrelevant in determining the

issues in this action."

34. In the fall of 1994, the three cases Scientology had

pending against me were, on the organization's request,

consolidated in Marin County and given one number, 157680.

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CT 5911

Scientology brought a motion seeking summary adjudication of three

causes of action, two for providing declarations in cases against

the organization, and one for talking to the media. Ford filed

an opposition to the motion based on the organization's subjecting me

to duress through Mike Flynn to get me to sign its settlement

agreement, the invalidity of the liquidated damages provision, and

on the "absolute" litigant's privilege. On January 27, 1995 Judge

Thomas granted summary adjudication as to two of the three causes

of action, ruling, among other things and amazingly, that I had

"fail[ed] to raise a triable issue as to whether the liquidated

damaged provision is invalid," and that I had "not raised a

triable issue regarding duress."

35. In early January, for reasons known to us and God, my

attorney and friend Ford Greene also lost heart. It had been

coming to me through the years that this litigation, although set

in a context of secular laws and courts, really concerned deep

religious issues. After Ford filed our opposition to

Scientology's summary adjudication motion, therefore, I prepared

and filed, unfortunately six days late, a declaration and exhibits

which addressed the religious issues as I then saw them. A true

and correct copy of this declaration and the exhibits thereto are

appended hereto as Exhibit J. Judge Thomas struck my declaration

for late filing and assessed $700.00 in sanctions against me.

36. On February 23 Ford substituted out of my case.

37. On February 27 I received Scientology's motion for

summary adjudication of its twentieth cause of action.

Scientology seeks by this motion a permanent injunction, which

would be much broader than the preliminary injunction now in

place, and which would prohibit me from, inter alia, "discussing

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CT 5912

with anyone, not a member of [my] immediate family or [my]

attorney, Scientology, the Church [etc.];" "acquiring ... any ...

writings, recordings, documents, or books of any kind, which

discuss or concern Scientology, the Church [etc.];" and would

require that I "[r]emove all information concerning Scientology,

the Church [etc.]... within the possession, custody or control of

FACTNet;" and "[r]eturn to the Church any documents [I] now

[have]... which discuss or concern Scientology, the Church [etc.],

other than documents which have been filed in this litigation."

38. On March 10 I applied for an extension of two weeks to

be able to oppose this motion which Judge Thomas granted. On

March 17 Scientology served on me another motion for summary

adjudication of four causes of action: No. 13, for giving a

videotaped interview concerning my Scientology experiences; No.

16, for talking to a Newsweek reporter about Scientology's efforts

to get its materials into the public school system; No. 17, for an

interview on E! Television; and, No. 19, for providing

declarations which discuss my Scientology experiences for filing

in the case of Scientology v. Steven Fishman, et al., U.S.

District Court for the Central District of California, Case No.

91-6426 HLH (Tx).

39. Because I had been ill, lacked the necessary equipment

and funds, lacked real attorney knowledge and skills, and was

utterly unable to prepare the oppositions, on March 29 I again

applied to Judge Thomas for more time. He gave me one week. On

April 7, facing the same situation and problems, I again applied

for more time, and also requested an order that Scientology free

Mike Flynn from the contract which prevented him from providing me

a declaration regarding the circumstances at the time of the

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CT 5913

global settlement, and Judge Thomas denied my application. I was

unable to complete my oppositions, even within the time I

requested, I am now late, and at the mercy of the Court and

Scientology. Nevertheless, I proceed.

40. Appended hereto as Exhibit K through DD are true and

correct copies of the following documents:

K. Declaration of Garry L. Scarff, executed

February 11, 1993 and filed herein in opposition to

order to show cause re contempt;

L. Scientology publication entitled ""FACTNet" -

Perversions, Criminality and Lies;"

M. Scientology publication entitled ""FACTNet"

Still Off the Rails;"

N. Letter from Michael Rinder, Church of

Scientology International executive and director of

plaintiff herein, to Mirror Group Newspapers in London,

United Kingdom;

O. Set of Bates-stamped Scientology publications,

known as "dead agent documents" concerning Gerald

Armstrong and Judge Paul G. Breckenridge, Jr., produced

by Scientology herein, and authenticated by Scientology

representative Lynn R. Farny;

P. Declaration of David Miscavige, executed

February 8, 1994 and filed in Scientology v. Steven

Fishman, supra;

Q. Article "Catch a Rising Star," by John H.

Richardson in Premiere, September, 1993;

R. Letter from Gerald Armstrong to Lawrence

Wollersheim dated January 21, 1994 resigning as

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CT 5914

director;

S. Ex parte application to continue hearing on

motions for summary adjudication and declaration thereto

executed April 7, 1995, and denied by Judge Gary W.

Thomas;

T. Scientology press release from Nancy O'Meara

and Andrew H. Wilson regarding January 27, 1995 ruling

by Judge Gary W. Thomas granting summary adjudication;

U. Letter from Church of Scientology

International President Heber Jentzsch to E! Television

dated August 5, 1993;

V. Letter from Ford Greene to Laurie Bartilson

dated February 19, 1992;

W. Letter from Ford Greene to Laurie Bartilson

dated February 24, 1992;

X. Letter from Laurie Bartilson to Ford Greene

dated March 2, 1992;

Y. Partial transcript of proceedings, December

23, 1991, in Scientology v. Armstrong, Los Angeles

Superior Court No. C 420153;

Z. Excerpts from transcript of deposition of

Michael Douglas, taken herein (case no. on face page is

incorrect) August 30 and September 2, 1994;

AA. Excerpts from transcript of deposition of

Nancy Rodes, taken herein August 30, 1994, and "mutual

release agreement" executed December 5, 1986;

BB. Declaration of Kenneth D. Long in support of

plaintiff's reply in support of motion for summary

adjudication of the fourth, sixth and eleventh causes of

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CT 5915

action of plaintiff's second amended complaint, filed

herein January 20 1995;

CC. Revised By-Laws of Church of Scientology

International.

41. In its motions, Scientology labels Vaughn and Stacy

Young, Hana Whitfield and Lawrence Wollersheim "anti-

Scientologists." They are not anti-Scientologists, but are pro-

Scientologist. What they are "anti-" is the leaders of

Scientology ordering fair game attacks on them, and on anyone.

They are opposed to Scientology's leaders' deceiving

Scientologists and subjecting Scientologists to coercive and

abusive practices to their detriment. Calling the Youngs, Ms.

Whitfield and Mr. Wollersheim "anti-Scientologists" is

Scientology's leaders' "black propaganda," pursuant to their " fair

game" philosophy.

42. Lawrence Wollersheim and I have been friends for over

ten years. I know him to be a target of Scientology's fair game

for many years, and someone who has been able to successfully

stand up to its attacks, and stands up for others, such as myself,

who are Scientology's fair game targets. In 1993 he asked me, in

large part, I believe, because he also viewed me as both a victim

of cult abuse and an advocate for other victims, to be on the

board of directors of a cult victims advocacy organization he was

forming, which eventually became known as FACTNet, Fight Against

Coercive Techniques Network. FACTNet functions as a library and

historical preservation archive, collecting, preserving and making

available information on groups using dangerous mind control

practices. When I agreed to be a director of FACTNet I was not

intending to participate in its operations, and have not ever been

-22-

CT 5916

involved in its operations. I suggested that my role in FACTNet

could be one of strategy, planning and consultation, but even

whatever I did in that role was negligible. In January, 1994,

Scientology threatened to sue FACTNet and some related groups and

individuals because of their association with me. To remove or

reduce this threat I resigned my position on FACTNet's board. I

have had no official role or involvement in FACTNet since that

time. I have no control of FACTNet, and the order that

Scientology seeks in this case that I remove all the materials

from FACTNet's library and archive which relate to Scientology is

impossible. I am a FACTNet library card holder, like many others

around the world. I have donated and sent materials to FACTNet

for preservation purposes, as everyone with information on

dangerous cults' coercive practices and antisocial activities may

do. The bulk of what I sent FACTNet concerned Scientology's

private investigator Eugene Ingram, his fair game efforts against

me, and his effort in 1985 and 1986 to frame Mike Flynn with the

forgery of a $2,000,000 check on an L. Ron Hubbard bank account.

Ingram is not named as a beneficiary in the 1986 "settlement

agreement." He has participated in Scientology's fair game

attacks on me since at least 1984. In 1992 he spread the rumor at

the national convention of the Cult Awareness Network ("CAN") that

I had AIDs. He has also participated in Scientology's fair game

attacks on Wollersheim, and many other people that Scientology's

leaders target. Scientology describes the materials I sent to

FACTNet as "anti-Scientology." They are not. They tell the truth

about some of the Scientology organization's activities and

criminal and antisocial practices. As a victim of cult abuse and

as a present target of Scientology's fair game attacks, I use

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CT 5917

FACTNet's services and facilities to support my defense in the

legal arena and as a safeguard against Scientology's extra-legal

attacks and threat. FACTNet has assisted me with research, fund-

raising, getting my story told, and spiritual understanding.

43. In support of my opposition to Scientology's motions for

summary adjudication several people, all of them my friends -

Lawrence Wollersheim, Hana Whitfield, Dennis Erlich, Margery

Wakefield, Keith Scott, Malcolm Nothling, Jonathan Atack and Nan

McLean - have come forward and provided declarations. They did

this at considerable risk to themselves. Ms. Wakefield and Ms.

McLean signed Flynn agreements similar to mine in 1986, and

Scientology has attacked them in court proceedings since then

based on claimed violations of those agreements. Scientology has

pending an effort to have Ms. Wakefield found in contempt of court

and jailed for up to 22 years for daring to speak the truth about

her experiences and knowledge. Scientology's recent fair game

efforts to destroy the reputations of Ms. Whitfield, Mr.

Wollersheim and Mr. Atack are shocking. Each one of these people

has knowledge of fair game, and each continues to be its target to

this day. My former attorney Ford Greene continues to be a fair

game target. It is for all of these people and the thousands of

others of good heart like them around the world who have become

targets of Scientology's fair game doctrine that I speak, write

and fight. One day that ungodly threat will be removed.

44. Around March 12 and continuing for about two weeks I

experienced what I believe was both my spiritual death and my

rebirth, brought on me by God. He showed me the nature of the

evil that I had been chosen to oppose, and He showed me the

spiritual battle with that evil. At times an oppressive evil came

-24-

CT 5918

to overwhelm me. I lost strength and acuity. For stretches of

hours my heart ached and I prayed, as Jesus prayed, that if it

were possible this cup be taken from me; nevertheless that God's

Will be done. At times God came to me, spoke to me, and held me

in His Strength and Love. He showed me that persecution must be

endured for His Cause, and assured me that He would never leave

me. He showed me that in this civilized country we carry out our

crucifixions in courtrooms. He showed me the souls I fought for,

and why He chose me to fight through all those years. My strength

has not returned to normal, and I am forever altered. God brought

me to surrender my battle to Him that His Will be done, for unless

He does it I haven't got a prayer. I will run whatever race He

calls me to run as fast and as far as He moves me. Sometimes He

will appear to lose the race on earth to win it in Heaven.

45. Scientology is anti-Christian. To the uninitiated, it

professes to be compatible with Christianity. It states in its

"catechism," published in 1992 in its promotional book What is

Scientology?,

"Scientologists hold the Bible as a holy work and

have no argument with the Christian belief that Jesus

Christ was the Savior of Mankind and the Son of

God...¶There are probably many types of redemption.

That of Christ was to heaven."

In Scientology's actual teachings, however, in the policies and

procedures which indoctrinated Scientologists must follow, Jesus

Christ, Heaven, and Almighty God, are false ideas "implanted" in

man by electronic gadgets to achieve, not man's redemption, but

his enslavement. Scientology teaches, moreover, that its

procedures, developed by L. Ron Hubbard, are the only way to free

-25-

CT 5919

man from that "Christian" slavery.

46. The main target of Scientology's promotion and marketing

are Christians, and by far the largest percentage of Scientology's

members come from Christian backgrounds. Using Scientology's own

figures from What is Scientology? this amounts to fifty-three

percent of its members. The second largest percentage comes from

Judaism, which worships the same God, Jehovah, as Christianity,

the same God, Hubbard teaches is an "implant." But Scientology

not only teaches that the God of Christianity and Judaism is an

implant; Scientology enforces the acceptance of that teaching with

its system of "ethics" punishments, its "auditing procedures, " and

its institutionalized mockery of God and Christ. Anyone in

Scientology who professed a belief in Christ, or God, or who

sought help through prayer, was viewed and handled as a

"psychotic." Such a person was segregated, given special auditing

to break his belief, and, if the "aberration" persisted, he would

be "off-loaded." I learned very quickly inside Scientology to

disavow any belief in God, to not mention Him, to not look to Him

for wisdom or help, and to view Christians as "aberrated" and

"dramatizing the Christ implant." I learned very quickly that

inside Scientology even thinking of Christ or God as real was

labelled as an "other practice," a punishable "ethics offense" or

"overt," which would become the subject of a "security check" on

Scientology's "E-meter," its lie detector.

47. In this recent period of spiritual battle God brought to

me a teaching by Jesus, recorded at Matthew 12:31,32 and Mark

3:28,29, which I see as the key to why He chose me for His Cause.

Jesus states in Mark:

"28 Verily I say unto you. All sins shall be

-26-

CT 5920

forgiven unto the sons of men, and blasphemies wherewith

soever they shall blaspheme:

29 But he that shall blaspheme against the Holy

Ghost hath never forgiveness, but is in danger of

eternal damnation."

When in his "theology" Hubbard asserts that Christ and God are

"implants," he blasphemes the Holy Spirit, the one unforgivable

sin. People drawn into Scientology and brought to adopt this

blasphemy are in grave spiritual danger.

48. In this latter period, it also became clear to me that

my experiences in Scientology, which I now see as religious,

indeed sacred, because they were created and motivated by God for

His Glory, are also religious by Scientology's own pronouncements.

In either case, under our Constitution, Scientology cannot use the

courts to silence me about those religious experiences. What

Scientology is seeking to have the courts order in its pending

motions for summary adjudication is in violation of and barred

by both the Establishment and Free Exercise Clauses of the First

Amendment. Scientology claims to be a religion, and organized

exclusively for religious purposes. Scientology claims that all

of its policies, directives and writings of all kinds on the

subject, its organization and practices are "religious

scriptures." Scientology claims that its Sea Organization,

members of which sign a billion year contract, is a "religious

order." I was in the Sea Org from 1971 through 1981, the period

of almost all of my significant experiences about which

Scientology seeks to silence me.

49. What if I had been, instead of a Scientologist, a member

of a Christian church; had been declared by the "church" leaders

-27-

CT 5921

"fair game;" had been the target a public campaign by the church

to assassinate my reputation; had been assaulted by private

investigators hired by the "church's" board of directors; had been

the target of an attempt to involve me in a highway "accident;"

had been spied on and harassed for weeks on end by these private

investigators; had had the contents and substance of my

"confessions" or pastoral counseling divulged publicly and used

against me; had been sued by the "church;" had been subjected to

false criminal charges and attempts to have me jailed; had been

entrapped by "church" officials; and had been secretly and

illegally videotaped by "church" agents; and so forth? All of the

acts listed in the preceding sentence were carried out by

Scientology against me and formed the basis of my cross-complaint.

What if I had cross-complained against the "Christian church" and

its "leaders" for the emotional distress resulting from these

torts and abuses? Is it conceivable that, as a condition of

settlement of the lawsuit against the Christian church, it or its

leaders could demand silence about my religious experiences, about

Christ, Christianity, God, and Christianity's Scriptures, the Holy

Bible? Is it conceivable that a court could compel me to pay

$50,000 each time I thereafter said anything about my religion, my

religious experiences, Christ, Christianity, the Bible or God? Is

it conceivable that a court in this country could order me jailed

if I communicated about these Things? Is it conceivable that I

could not even discuss with other Christians their experiences of

Christianity; and is it conceivable that I could be compelled to

pay $50,000 and jailed for each time I discussed the experiences

of other Christians with them? Is it conceivable that in the face

of continuing attacks by the Christian "church" leaders after the

-28-

CT 5922

"settlement" I must still remain silent about my "religion" and

his "religious experiences?"

50. No Christian church would consider imposing such

conditions in a "settlement." No court would consider enforcing

such conditions against a Christian. Why then do courts enforce

such conditions at the insistence of Scientology against people it

has abused? The answer is that our courts are often deceived,

confused and blinded by evil, and as a result give evil favorable,

special treatment; and to the detriment of goodness and justice.

Only an organization or individual of such an evil and malevolent

nature that they cry out to be brought to the light of truth would

consider using our justice system to keep that nature hidden.

51. As Christ taught, and as a child of God, my practice is

forgiveness. As all that I have done has by Christ been forgiven,

I have forgiven everything anyone has ever done to me, every act

or thought of persecution. What I cannot forgive, however, for I

have not the power to forgive it, is Hubbard's, Scientology's

leaders' Scientologist's and anyone else's blasphemy of God's Holy

Spirit.

52. I believe, moreover, that Scientologists will not

recognize their need for forgiveness as long as they blaspheme the

Holy Spirit, and they will persecute me as long as they commit and

promote this blasphemy; so I ask them to stop. I ask as well that

they not persecute the little ones, those who are the least among

us, those whom Scientology's leaders call "suppressive persons,"

"PTSes" or "degraded beings," for in that persecution they

persecute Christ Himself. I know that God for His Purposes chose

me to be persecuted; and to care and hurt when the little ones are

persecuted. I care, then, what Scientology does to me, for it is

-29-

CT 5923

doing it and will do it to anyone else. It is to all of these,

and to all those in Scientology, that God has sent me. I believe

that we are in the end times, and that God has sent His

messengers, teachers and prophets onto His Elect, wherever they

are, in whatever country, city, prison, church or cult, to gather

them onto Himself. As stated by the Apostle at I. John 2:22:

"Who is a liar but he that denieth that Jesus is

Christ? He is antichrist, that denieth the Father and

the Son."

In the end times it is expected that antichrist would use man's

laws and courts to enforce his evil contracts by which he would

bind, torment and destroy God's sons. God chose me to be

persecuted by Scientology's leaders, using their organization's

tax-exempt millions, and in violation of the nation's

Constitution, as Apostles of old were persecuted, and all God's

Disciples have been persecuted throughout history. This need not

be, for persecution can end in no time and without downside.

Nevertheless, God allows and uses the persecution of His Children,

His Messengers, Teachers and Prophets to prove His great Mercy and

Love and the power of His marvelous plan of salvation, both for

the persecutors and those persecuted. God knows which souls He

will reach through my words, story and persecution. They may be

few; nevertheless, He desires that all should be saved.

53. All that I have done in all my life is for this moment

in God's Plan. I ask for mercy if that be God's Will.

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CT 5924

I declare under the penalty of perjury under the laws of the

State of California that the foregoing is true and correct.

Executed at San Anselmo, California, on September 15, 1995

[signed] G. Armstrong

GERALD ARMSTRONG

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