U.S. Department of Justice
Civil Rights Division
950 Pennsylvania Ave., NW
Criminal Section, PHB
Washington, DC 20530
(202) 514-3204
Fax: (202) 514-8336

COMPLAINT REPORT

I, Gerry Armstrong, declare:

1.      My address is:
#1-45950 Alexander Avenue
Chilliwack, B.C. V2P 1L5
Canada
604-703-1373
gerry@gerryarmstrong.org

2.      I am a citizen of Canada with Canadian passport No. JS274969. I became
a legal resident of the U.S. in 1977, with Alien Registration No. A036304599.

3.      Federal crimes have been committed by the violation of the following:

1. 18 U.S.C. §241
2. 18 U.S.C. §242
3. 18 U.S.C. §371
4. 18 U.S.C. §1512

4.      The participants in these crimes include those individuals or entities who
comprise the “beneficiaries” identified or described in paragraphs 1 and 4 of a document
entitled “Mutual Release and Settlement Agreement,” which purports to be a contract
between those individuals and entities and me executed in December, 1986, specifically:

Church of Scientology International, its officers, agents,
representatives, employees, volunteers, directors,
successors, assigns and legal counsel;
Church of Scientology of California, its officers, agents,

1

representatives, employees, volunteers, directors,
successors, assigns and legal counsel;
Religious Technology Center, its officers, agents,
representatives, employees, volunteers, directors,
successors, assigns and legal counsel;
all Scientology and Scientology affiliated organizations and
entities and their officers, agents, representatives,
employees, volunteers, directors, successors, assigns and
legal counsel; Author Services, Inc., its officers, agents,
representatives, employees, volunteers, directors,
successors, assigns and legal counsel;
L. Ron Hubbard, his heirs, beneficiaries, Estate and its
executor;
Author's Family Trust, its beneficiaries and its trustee; and
Mary Sue Hubbard.

http://www.gerryarmstrong.org/50grand/legal/a1/mutual-release-1986.html

5.      I am providing URLs, as such exist on the date of this complaint, for documents
cited to herein, because the photocopying of these documents and appending the
photocopies hereto as exhibits, and mailing these exhibits, is financially prohibitive. All
webbed documents cited to herein are, to my knowledge and to the best of my ability,
true and correct copies of the original documents from which the webbed copies have
been made. If required, in the course of the official investigation and prosecution
resulting from this complaint, I can and will provide true and correct hard photocopies of
any documents cited to herein.

6.      All of the individuals and entities that comprise the “beneficiaries” are under the
ultimate control and direction of one David Miscavige, who possesses the official titles
within the global Scientology enterprise of Captain of the Sea Organization (“SO”) and
Chairman of the Board of Religious Technology Center (“RTC”). The SO is an
unincorporated pseudo-military entity, members of which occupy positions in other
Scientology organizations, corporations and entities. The global Scientology enterprise is
a dictatorship, Miscavige is the dictator, and corporate identities and borders are ignored,
or are employed by Miscavige and his ruling clique at their whim for purposes of control
and evading legal liability for the enterprise’s crimes and torts.

7.      The events relating to these crimes committed by these individuals and entities
span a thirty-five year period, occurred in many locations, and involve numerous civil
and criminal legal cases and proceedings. I am limiting what facts and events I am
including in this report to only those I believe are necessary to demonstrate the
commission of these crimes and to make the circumstances and actions and the special
Scientology terms, policies and practices understandable. I am also providing some of
my arguments or reasoning for why certain acts or communications by these individuals
and entities constitute these crimes in order to assist investigators and prosecutors, to
explain my own actions, and to ensure that these arguments or reasoning are considered
and addressed.

2

8.      I got into Scientology in 1969 in Vancouver, B.C., Canada, and left the
organization in Los Angeles, California in December 1981. I was recruited into the
organization with a number of promises or representations, which included:

-      that Scientology was a mathematically precise and exact science;
-      that no other subjects on earth except physics and chemistry have had such
grueling testing;
-      that it was based on the scientific research of L. Ron Hubbard;
-      that he was a Civil Engineer and a Nuclear Physicist;
-      that he had many degrees and was very skilled by reason of study;
-      that he was crippled and blinded in the Second World War and cured
himself with his mental science;
-      that Scientology “auditing” psychotherapy raises IQ an average of a point
per hour;
-      that auditing is conducted using an “electropsychometer,” or “E-meter,”
which is a precision scientific instrument that sees below a person’s
consciousness and gives an “auditor” a keen look into the heads and hearts
of people being “audited;”
-      that Scientology improves the health, intelligence, ability, behavior, skill
and appearance of people;
-      that Scientology produces the ability to handle any and all problems;
-      that Scientology auditing produces a mental state called “Clear,” whereat
the person has complete recall of everything that ever happened to him or
anything he ever studied, he does mental computations and studies
anything in less than one-hundredth the time such computations or studies
took before “clearing,” he never gets colds, his vigor, persistence and
tenacity to life are very much higher than anyone has thought possible,
and his physical vitality and health are markedly improved and all
psychosomatic illnesses have vanished and will never return;
-      that Scientology is offered with a money-back guarantee;
-      that Scientology is the most ethical organization on the planet;
-      that Scientology works, works uniformly, and is the only system on earth
that works for improving the health, intelligence, ability, behavior, skill
and appearance of people;
-      that Scientology is the only hope for mankind’s survival;
-      that Scientology can and does do exactly what it says it can do.

9.      From February 1971 until I left in December 1981, I was a member of the SO,
which is structured similarly to the United States Navy. Within the SO “ranks and
ratings” system, I rose to the rank of Ensign. Until September 1975, I was on board the
“Apollo,” the SO’s “flagship,” from which during those years Scientology was operated.
L. Ron Hubbard, his wife Mary Sue, and their four children were on board, along with an
average of over 400 other people comprising “crew,” plus auditing or training customers.
During those years, the ship moved between ports in Morocco, Portugal, Spain and the
Caribbean.

3

10.      Hubbard, as the “Commodore” of the SO, controlled and directed all activities on
board the “Apollo,” and all Scientology organizations and activities internationally
through a number of networks including the Commodore’s Staff Aides (“CS Aides”), the
Flag Bureaus (“FB”), the Commodore’s Messengers Organization (“CMO”), the Flag
Banking Officers (“FBOs), the L. Ron Hubbard Communicators (“LRH Comms”), the
Flag Operation and Liaison Offices (“FOLOs”) and the Guardian Office (“GO”). Under
Hubbard, Mary Sue Hubbard, as the “Controller” ran the GO, which dealt with
Scientology’s non-Scientologist contacts and public, and included the organization’s
finance, public relations, legal and intelligence activities.

11.      During my years on board, I held the positions of “Storesman,” “Boats and
Transport In-Charge,” “Legal Officer,” “Public Relations Officer” and “Intelligence
Officer.” I gained knowledge of organization communication and command channels,
operations, personnel and security. During those years, the ship operation and all
personnel maintained an intelligence cover of, and pretended to be, “Operation and
Transport Corporation” (“OTC”), a Panamanian business management company. All
personnel were required to hide the fact and deny that we were Scientologists or had
anything to do with Scientology. Any failure to maintain our OTC “shore story” or
cover, or any disclosure of any connection to Scientology was a “security breach,”
considered “treason,” and severely punished.

12.      I also gained knowledge of Hubbard’s and Scientology’s worldview, aims, and
“Ethics,” which is the organization’s system of rewards and punishment, including its
“Suppressive Person” (“SP”) doctrine and “Fair Game” policy. In their worldview,
Hubbard and Scientology divide mankind into two groups, Scientologists and non-
Scientologists, called “wogs.” The term “wogs,” in its original meaning, and in its present
meaning outside of Scientology, is a racial epithet equivalent to “niggers.” Inside
Scientology, “wogs” is also a racial epithet, referring to “Homo sapiens.” Hubbard and
Scientology teach that wogs or Homo sapiens are an inferior race, also described
derogatorily in Scientology teachings as “homo sap,” “raw meat,” or “common ordinary
run-of-the-mill garden-variety humanoids.” Hubbard and Scientology teach that
Scientologists comprise a new and superior race of hominid called “Homo Novis” or
“Homo Scientologicus.”

13.      Hubbard and Scientology teach that wogs are less aware, less intelligent and less
ethical than Scientologists, and that wogs think in two dimensions, whereas
Scientologists think in three dimensions. Hubbard and Scientology teach that wogs have
never evolved a workable mental technology but only vicious technology, whereas
Scientologists have in Scientology the only workable mental technology. Hubbard and
Scientology teach that outside of Scientology is the “wog world,” which is a “hell,” and a
“jungle of noncompliance and false reports.” Hubbard and Scientology teach that “wog
justice” is “injustice” and that only Scientology’s “ethics and justice” system works.

14.      Hubbard and Scientology teach that Suppressive Persons, or SPs:

-      are the two and one-half percent most evil wogs in the world;
-      are insane;

4

-      are psychotic;
-      are criminal;
-      are destructively antisocial;
-      are committing hidden crimes continuously;
-      are dramatizing the overt or covert but always complex and continuous
determination to destroy;
-      goof up or vilify any effort to help anybody and particularly knife with
violence anything calculated to make human beings more powerful or
intelligent;
-      automatically will curve any betterment activity into something evil or
bad;
-      are the only thing wrong in this universe;
-      are at the root of every bad condition;
-      can have no friends;
-      include Hitler, Stalin, Dillinger and Genghis Khan;
-      fill the institutions with victims, the hospitals with the sick and the
graveyards with the dead;
-      are the only people who do not get gains from Scientology auditing
therapy;
-      are without any rights of any kind and actions taken against them are not
punishable.

15.      Hubbard and Scientology teach that it is acceptable, ethical, and in fact laudable,
for Scientologists to take aggressive, antisocial and even criminal actions against SPs.
Hubbard called this philosophy, policy and practice “Fair Game.” In one of his “ethics”
policy letters, which is commonly known as the “Fair Game Policy,” Hubbard laid out
how people declared to be SPs were to be dealt with.

ENEMY – SP Order. Fair game. May be deprived of property or injured
by any means by any Scientologist without any discipline of the
Scientologist. May be tricked, sued or lied to or destroyed.

HCO Policy Letter 18 October 1967, “Penalties for Lower Conditions”
http://www.gerryarmstrong.org/50grand/cult/sp/pl-penalties-for-lower-conds.html

16.      Hubbard and Scientology taught that anyone connected to a Suppressive Person is
a “Potential Trouble Source” (“PTS”), so called because he is going to make trouble for
the organization. They taught that connection to an SP is the cause of all illness, and that
a PTS will get better then get worse because of that connection. A person determined to
be PTS was denied auditing and training and removed from certain organization positions
until he had “handled” the SP he was connected to or “disconnected” from the SP.
Scientology has claimed throughout the past thirty-five years that “disconnection” is not a
practice of the organization, but it definitely was and continues to be.

17.      The “Suppressive Person Doctrine,” “Fair Game,” “conditions” – such as
“liability,” “enemy” and “treason” – and penalties or punishment are part of the body of
Scientology writings and practice called “Ethics.” The other two sectors are
“technology,” or “tech,” and “administration,” or “admin.” “Tech” generally refers to

5

“auditing,” which is Scientology’s psychotherapy, and “training,” which is the provision
of courses to teach students in Scientology materials and procedures. “Admin” generally
refers to the management of organizations and the “technology” of management,
including recruitment, advertising, marketing, selling, personnel, communication
systems, finance and productivity control.

18.      “Ethics” was considered the most vital of the three sectors of Scientology, and
was administered very rigidly. The Sea Org’s stated purpose was “To get in Ethics on
the planet,” and the SO operated on a military-like system with military-like discipline.
Command lines ran down from Hubbard as the Commodore and compliance lines ran up
to him. Non-compliance with any order from any senior staff member was immediately
punished with a minimum of a “liability condition” assignment, and could be considered
“mutiny.” “Liability” meant that the person assigned that condition had “taken on the
color of the enemy,” so he was ostracized, had to do an “amends project” consisting of
many hours of extra work, had to “deliver an effective blow to the enemies” and then had
to petition the group to be readmitted.

19.      Organization Ethics personnel used the E-meter to perform “meter checks” on
staff to determine if they were “out-ethics;” e.g., committing “overts” (the Scientology
word for “crimes”) against the organization, “counter-intention” to the organization, or a
“security risk” to the organization. Auditors used the E-meter as a lie detector to perform
“security checks,” or “sec checks,” on staff or public Scientologists to discover their
overts or crimes, their sexual histories, incidents from their past that might be
embarrassing, or incidents for which they could be prosecuted or blackmailed. What a
person being audited or sec checked said was written down in detail, and this record was
maintained by the organization in “auditing files,” “ethics files” and “intelligence files.”

20.      In 1974, Hubbard created the “Rehabilitation Project Force” (“RPF”), a guarded
labor detail or camp, where Sea Org personnel were summarily ordered for indefinite
periods for any infraction or on any whim. Hubbard’s published criteria, any one of
which could result in assignment to the RPF were: 1. an “R/Ser;” 2. a “low OCA non-
producer;” 3. a “repeated stat crasher;” or, 4. an “overt product maker.” An “R/Ser” is a
person on whom an auditor observes a “Rock Slam,” a particular needle movement on
the E-meter, during auditing or sec checking. An R/S meant that the person had an “evil
intention” toward Hubbard or Scientology.

21.      The “OCA,” or “Oxford Capacity Analysis,” is a “personality test” that
Scientology uses as a recruitment device to draw people into the organization, and as a
measurement of people’s personality “improvement” as they progress on their “auditing
programs.” A “low OCA” is a test score with one or more points below an arbitrary line.
A “stat crasher” is a person deemed to be responsible for a statistic dropping in an area,
or project or on an organization post. All of Scientology is operated and controlled by a
system of “statistics” or “stat management.” Every person and post is “statistized” and
must report stats daily and weekly. “Downstats” are punished, whereas “upstats” can to a
degree protect a person from punishment. An “overt product maker” is a person whose

6

work contains errors, whose production is deemed unacceptable for some reason, or
requires correction or repair.

22.      People ordered to the RPF were subjected to a number of punitive and
degrading conditions that included segregation from the “crew,” restriction from crew
areas, wearing black boiler suits, reduction in “pay” to one-quarter the base amount, not
speaking to a crew member unless spoken to, having to run everywhere, doing hard
manual labor and all the dirtiest work, getting a maximum of seven hours sleep, and
eating after the crew whatever was left over. RPFers had to audit each other through a
long auditing program that contained many hours of sec checking, and which could last
for months or even years. RPFers had no free time, got no days off, and could not read
newspapers or magazines, listen to radio, or watch TV. RPFers could not make
telephone calls unless such were specifically ordered and monitored, and Ethics
personnel read all mail RPFers received, and read and censored all mail RPFers sent out
from the RPF.

23.      Scientology claims that assignment to the RPF is voluntary, or even a privilege,
but that is not true. Anyone who asked to leave instead of doing the RPF program was
assigned to the “RPF’s RPF,” an even more degrading and punitive experience, where the
person was guarded at all times, allowed only six hours sleep, docked all pay, had to eat
after the RPF had eaten whatever they left, and did the filthiest of the dirty work. The
RPF’s RPF member could not leave, and in fact no Sea Org member could leave, until he
had been intensely sec checked and had signed a list of his “crimes” that had been
“culled” from his auditing files. Also before the person could leave, all his personal
belongings were searched and he was stripped of any Scientology materials, even if he
had personally purchased them.

24.      The RPF and the RPF’s RPF operated as a forced labor and reindoctrination
camp and as a system and procedure to break the will of anyone thought to be “out
ethics” or “counter intention” to Hubbard or his organization and activities. It was a
shocking, degrading experience to be ordered to the RPF, and the threat of RPF
assignment was used to keep non-RPF crew in line and producing. I was threatened
several times with RPF assignment during my SO years, and assigned twice for a total of
twenty-five months.

25.      Hubbard and Scientology taught that the need for the severe “Ethics” penalties
and conditions such as the RPF was because for the “technology” to work it was first
necessary to “get in ethics.” Hubbard and Scientology taught that since the “tech” was
mankind’s only hope for survival, it was necessary that the people using and delivering
that “tech” be highly disciplined and ethical. Hubbard and Scientology taught that:
“The purpose of ethics is to remove counter intentions from the environment. And
having accomplished that the purpose becomes to remove other intentionedness from the
environment.” In other words, anyone or anything that was “counter intention” to
Scientology’s intentions or activities, and anyone with an intention that differed from the
organization’s intentions was unethical and was to be removed from the environment.

7

Hubbard laid down Scientology’s intentions by order and as policy, and his intentions
were forwarded and opposition removed down through the organizational hierarchy.

26.      In the fall of 1975, almost all of the “Flagship Apollo’s” crew left the ship and
flew from the Caribbean to the U.S. to establish the “Flag Land Base” (“FLB”) in
Clearwater, Florida. A skeleton crew was left on board to maintain and sell the ship. The
organization’s equipment, files and other materiel were shipped by containers to Florida
and brought to Clearwater. The majority of the non-U.S. citizens went to Daytona Beach
to set up a temporary base in a leased motel, and the majority of the U.S. citizens went to
Clearwater to clean up and renovate buildings the organization had purchased to set up
the FLB. Hubbard and his immediate personal staff lived during this period in a Daytona
Beach apartment building not far from the temporary base. In early December 1975, the
Daytona Beach operation moved into the Clearwater buildings, and Hubbard and an
expanded personal staff moved into a vacant apartment complex in Dunedin, Florida, just
a few miles from Clearwater.

27.      Upon my arrival at the Daytona Beach base, I was posted in the Guardian’s
Office Intelligence Bureau, coding and decoding GO telexes, gathering information
locally in areas of concern to base operation and our beachhead in Florida, and compiling
information on potential security risks among the crew, and among customers arriving for
auditing or training. My then wife Terri was posted as Commanding Officer of the
Commodore’s Messenger Organization (“CO CMO”), and worked directly with
Hubbard. After a few weeks, Mary Sue Hubbard decided that I was a security risk
because my mother was “antagonistic to Scientology” and Mrs. Hubbard had me
transferred out of the Intelligence Bureau. I spent a number of days typing and printing
mission orders that Hubbard was writing that ordered and operated various missions,
projects or phases concerning the base being established in Clearwater. I was then
assigned to L. Ron Hubbard’s External Communications Bureau (“LEC”), posted as
Deputy LEC Aide, and sent to the Dunedin apartment complex to set up an office for the
LEC Bureau.

28.      Until into 1976, Scientology hid its purchase of the Clearwater properties, and
the fact that it was Scientology and Scientologists operating in Clearwater, behind a cover
organization called “United Churches of Florida” (“UCF”). The FLB crew, as well as
people arriving for auditing and training, were required to hide from public view any
jewelry, insignia, mimeographed issues, books or other literature that might identify them
as Scientologists, or the operation as Scientology, and it was an act of “treason” to
commit any security breach that might reveal what was going on. The cover was
eventually blown because of official scrutiny from the city government, media
investigations and security lapses.

29.      I was on post as D/LEC Aide at the Dunedin apartment complex, which had the
cover of “United Churches Extension” (“UCE”), until late May 1976. I coded and
decoded L. Ron Hubbard’s telex traffic, and handled his dispatch traffic and mail to and
from Scientology organizations around the world. Hubbard continued to run all aspects

8

of the global Scientology enterprise, and directly ordered and supervised activities at the
Clearwater base, including GO legal, media, PR and intelligence actions.

30.      In about February 1976, the UCE cover was blown and Hubbard and his
location were identified in the local press. As a result, he fled by car from Dunedin with
two crew, including my senior, the LEC Aide, and eventually hid out for four months in a
secret location in Washington, D.C. During these months, I relayed Hubbard’s telex and
dispatch traffic from Scientology organizations around the world via UCE to the
Washington, D.C. hideout, and relayed his telex and dispatch traffic via UCE to the
FLB and to organizations internationally. I also was required to participate in creating the
illusion for organization personnel that Hubbard was still in Dunedin, and creating the
illusion for non-organization persons that Hubbard was outside the U.S.

31.      In May 1976 I was sent on a mission to establish a staging area in an apartment
complex in Culver City, California for Hubbard and his personal staff in anticipation of
their moving to a new secret base then being purchased in La Quinta, California. I drove
by car along with three CMO personnel from Dunedin to Culver City and set up an office
and telex relay unit in the apartment complex. Mrs. Hubbard and her personal staff
arrived within a few days, and L. Ron Hubbard and the SO personnel traveling with him
arrived a day or so later.

32.      Within a few days of Hubbard’s arrival, I got into an argument with Mrs.
Hubbard’s “Communicator,” or secretary. Hubbard deemed me a security risk, and
ordered the head of the U.S. GO Intelligence Bureau to come to the apartment and drive
me to the Los Angeles Intelligence Bureau offices then located in a building called the
Fifield Manor. For the next approximately three weeks I was locked up in a small room
with Intelligence Bureau staff members posted to guard me at all times, and I was kept
under guard whenever I was allowed out of the room to go to the bathroom or for other
needs. While locked up, I was required to write up “confessions” of my overts, or
crimes, and critical thoughts about Hubbard and the organization. Toward the end of that
period, my wife Terri arrived from Florida and was also locked up and guarded with me.

33.      In the beginning of July, Hubbard ordered Terri and me to return to Florida by
plane accompanied by two GO Intelligence personnel as guards. Upon our arrival at the
Flag Land Base we were shown a telex from Hubbard ordering us to the RPF, and a “Flag
Conditions Order” announcing our assignment was issued.
http://www.gerryarmstrong.org/50grand/cult/fco-4517-rpf-assignments.html
Initially, we were the only RPF members in Clearwater. Within a few days, more FLB
crew began to be assigned, and over the next seventeen months until I graduated the RPF
complement grew to about eighty.

34.      During the majority of those months, I was the RPF Bosun, the most senior RPF
member. At one point, I was demoted from the Bosun post, and Terri was demoted from
the “Master at Arms” (“MAA”) post, the second in command of the RPF, for “out
ethics.”

9

http://www.gerryarmstrong.org/50grand/cult/ed-81-rpf-bosun.html We were both also
assigned an extra month in the RPF as punishment for “criminal neglect” and
“slackness.” http://www.gerryarmstrong.org/50grand/cult/eo-24-addl-rpf-duty.html
After about four months, I was reposted as Bosun, and kept that post until I “graduated”
at the beginning of December 1977.

35.      As the Bosun, I acquired knowledge of RPF policies, punishments and other
practices. I was required to detain people against their will, prevent them from leaving,
keep them under guard, force them to perform hard labor as punishment without pay,
subject them to invasive and coercive interrogations, and force them to sign lists of their
“crimes” extracted from their auditing files. I was required to forcibly separate RPF
members from spouses and children, cut them off from information in the outside world,
and enforce the idea that they were “criminals.” The RPF was a degrading experience
that violated people’s civil rights and human dignity.

36.      I was also required to participate in deceiving local officials, people’s families
and the whole world about conditions in the RPF and about violations of local housing
and safety regulations. On a number of occasions while I was in the Clearwater RPF, we
received advanced warnings of official inspections and the whole of the RPF complement
were required to hide the fact that approximately forty people were sleeping in an
unventilated storage room, and more were sleeping in a parking garage. We were
required to hide the fact that the RPF “course room” was in the same unventilated storage
space, and we were required to cover all our mattresses, clothing and course materials
with sheets or blankets to make the space appear to be used for storage. We were
required to delay any punishments of RPF members until the inspectors had left, and we
were required to move any RPF’s RPF details out of any area that might be inspected.

37.      In July 1977, agents of the Federal Bureau of Investigation raided Scientology’s
GO Intelligence Bureaus in Los Angeles and Washington D.C. as a result of an
organization intelligence operative informing the FBI about illegal activities. Eleven
intelligence personnel were subsequently charged with Federal crimes, nine of whom,
including Mary Sue Hubbard, were found guilty of one plea-bargained felony count after
a non-jury trial based on an October 1979 Stipulation of Evidence.
http://www.xenu.net/archive/go/legal/legal.htm The remaining two GO personnel were
tried and found guilty of nine counts of aiding and abetting second degree burglaries. All
eleven were ultimately fined and incarcerated in Federal prisons. At least thirty-four
other Scientologists, including L. Ron Hubbard, were named as unindicted co-
conspirators. The Scientologist informant was granted protective custody by the U.S.
Marshals Service.

38.      The illegal activities detailed in the Stipulation of Evidence included infiltrating
and burglarizing U.S. Federal offices, theft from those offices, buggings, forging of
official identification cards, making false statements before a grand jury, cover-up of
crimes, harboring and concealing a fugitive, and kidnapping. Offices infiltrated or
burglarized by the Scientology operatives included the Intelligence Division of the U.S.
Coast Guard, the U.S.Department of Justice, the Internal Revenue Service, the Drug

10

Enforcement Administration, the U.S. Courthouse for the District of Columbia, the U.S.
Post Office, the Labor Department's National Office, the Federal Trade Commission, the
Department of the Treasury, the U.S. Customs Building, U.S. Attorney’s office, and
private law firms. The Scientology operatives’ plans also included the penetration of one
hundred thirty-six additional government agencies including the Administrative Office of
the U.S. Courts, the CIA, the Executive Office of the U.S. Attorneys, the FBI, and a
number of U.S. Embassies and Consulates abroad.

39.      The Sentencing Memorandum dated December 16, 1980 filed in case of the two
separately tried Scientology officials provides the Government’s view of the
organization’s criminal conspiracy, its “fair game doctrine,” and its campaign to destroy
its “enemies’” civil rights.

[The Scientology conspirators] challenged and attempted to undermine the
judicial and governmental structure of the United States.
….
Thus, they perpetrated a fraud upon the American judicial system.
….
These crimes included: the infiltration and theft of documents from a
number of prominent private, national, and world organizations, law firms,
newspapers, and private citizens; the execution of smear campaigns and
baseless law suits for the sole purpose of destroying private individuals
who had attempted to exercise their First Amendment rights to freedom of
expression; the framing of private citizens who had been critical of
Scientology, including the forging of documents which led to the
indictment of at least one innocent person; and violation of the civil rights
of prominent private citizens and public officials.
…..
[T]hese documents establish beyond question that the defendants, their
convicted co-defendants, and their unindicted co-conspirators, as well as
their organization, considered themselves above the law. They believed
that they had carte blanche to violate the rights of others, frame critics in
order to destroy them, burglarize private and public offices and steal
documents outlining the strategy of individuals and organizations that the
Church had sued. These suits were filed by the Church for the sole
purpose of financially bankrupting its critics and in order to create an
atmosphere of fear so that critics would shy away from exercising the First
Amendment rights secured them by the Constitution. The defendants and
their cohorts launched vicious smear campaigns, spreading falsehoods
against those they perceived to be enemies of Scientology in order to
discredit them and, in some instances, to cause them to lose their
employment.
….
To these defendants and their associates, however, anyone who did not
agree with them was considered to be an enemy against whom the so-
called "fair game doctrine" could be invoked. Allard v. Church of
Scientology of California, [58 Cal. App. 3d 439, 129 Cal. Rptr. 797 (Ct.

11

App, 1976), cert denied, 97 S. Ct. 1101 (1977)]. That doctrine provides
that anyone perceived to be an enemy of Scientology or a "suppressive
person," "[m]ay be deprived of property or injured by any means by any
Scientologist without any discipline of the Scientologist. [He m]ay be
tricked, sued or lied to or destroyed." Id. This policy, together with the
actions of these defendants who represent the very top leadership of the
Church of Scientology, bring into question their claim that their Church
prohibited the commission of illegal acts.
….
The defendants directed and encouraged a number of covert operations
against private individuals and public officials to destroy and discredit
these persons because they had either attempted to exercise their First
Amendment rights by criticizing Scientology or by attempting to carry out
their duties as public officials.
…..
That these defendants were willing to frame their critics to the point of
giving false testimony under oath against them, and having them arrested
and indicted speaks legion for their disdain for the rule of law. Indeed,
they arrogantly placed themselves above the law meting out their personal
brand of punishment to those "guilty" of opposing their selfish aims. ¶The
crimes committed by these defendants is of a breadth and scope previously
unheard. No building, office, desk, or files was safe from their snooping
and prying. No individual or organization was free from their despicable
scheming and warped minds.
…..
These defendants rewarded criminal activities that ended in success and
sternly rebuked those that failed. The standards of human conduct
embodied in such practices represent no less than the absolute perversion
of any known ethical value system. In view of this, it defies the
imagination that these defendants have the unmitigated audacity to seek to
defend their actions in the name of "religion." That these defendants now
attempt to hide behind the sacred principles of freedom of religion,
freedom of speech and the right to privacy -- which principles they
repeatedly demonstrated a willingness to violate with impunity -- adds
insult to the injuries which they have inflicted on every element of society.
These defendants, their co-conspirators, their organization, and any other
individual or group that might consider committing similar crimes, must
be given a clear and convincing message: criminal activities of the types
engaged in here shall not be tolerated by our society.
http://www.suppressiveperson.org/writings/usa-v-kember-budlong-sentencing-memo-1980-01-72.pdf

40.      At the end of December 1977, Terri and I were ordered to the secret
Scientology base that had been established on some properties in La Quinta, California.
Within a day of our arrival, Hubbard also arrived at the properties from Sparks, Nevada.
He had fled from La Quinta in July 1977 at the time of the FBI raids on the GO’s

12

41.      For the next approximately nine months, I worked in various positions on a
Cinematography crew Hubbard had ordered be assembled at La Quinta to shoot
Scientology training movies for which he had written the scripts. My posts included Set
Builder, Assistant Camera, Lighting Grip, Location Scout, Sets In-Charge and Assistant
Producer, and I acted in several of the films. The base personnel’s initial “cover” for the
people and activity on the properties was that we were all “friends of Norton Karno.”
Karno was an attorney who had worked for the GO, handled aspects of Hubbard’s tax
matters, and had been involved in the purchase of the La Quinta properties. When the
movie making increased and started including night shoots, the Cine crew grew to about
a hundred Sea Org members, and a studio was built on another property that had been
purchased nearby in Indio, our cover was changed to “Perfect Pictures,” a company
producing “educational films.”

42.      Security was top priority at La Quinta, as it had been at the Dunedin, Florida
and Culver City, California apartments where I had been with Hubbard. The location of
the base was kept secret from our families, and even from almost all other Scientologists.
In addition to my movie-making duties, for my first few months at La Quinta I also stood
a shift every second day as a night guard outside Hubbard’s residence. I had to stay
perched in a tree, watch for anyone approaching the property, and alert a security unit and
Hubbard’s Messengers by radio if anyone did approach. I was drilled to deny I knew
Hubbard, to refuse service of process, kick into the dirt any documents served, and delay
anyone coming onto the property long enough so that Hubbard could make an escape in a
car that was kept close by for that purpose.

43.      In late September 1978, Hubbard got the idea that I, and five other Cine crew
including Terri, were “joking” about his movie making, and he ordered all of us to the
RPF unit that had been formed at the La Quinta base. I had not been “joking,” and I
requested a “Committee of Evidence,” a Scientology “justice” procedure, to review my
assignment. The “Committee” found me “guilty,” however, and it took me another eight
months to get “reprieved” and admitted back into regular crew.
http://www.gerryarmstrong.org/50grand/cult/findings-recs-1978-10-04.html
During most of my time in the RPF at La Quinta I worked on renovating Hubbard's
residence, carpeting and tiling floors, painting rooms, cleaning and re-insulating the
ducting, and laying brickwork for his walkways.

44.      Around the time of my RPF assignment, the La Quinta cover was blown by
some former crew members who went to the media about abuses at the base. As a result,
Hubbard ordered another property purchased, a resort and golf course at Gilman
Hotsprings, near Hemet, California, and he himself left the La Quinta base and hid out for
some weeks in motels with a few personal staff. In early December 1978, the RPF
members at La Quinta were ordered to Gilman Hotsprings, also known as the “Special

13

45.      In the spring of 1979, on the same day that I was reprieved from the RPF, my
wife Terri announced to me that she had been ordered that either she divorce me or she
could not continue to be a Messenger for Hubbard. She said that she had chosen
Hubbard and that was the end of our relationship. I continued to work on renovating
Hubbard’s home, posted as the LRH Renovations In-Charge. In the summer of 1979, I
was posted as the D/CO HU SU, the head of Hubbard's “Household Unit” at Gilman. My
“juniors” included the LRH Steward, the LRH Carpenter, the LRH Groundsman, the
LRH Electrician and the LRH Gear In-Charge, who was responsible for his personal
belongings stored on the Gilman property.

46.      During this period of time, Hubbard stayed with a number of Sea Org members
on his personal staff in an apartment complex in Hemet. He came to the newly renovated
and decorated house at Gilman on a number of occasion for clandestine meetings with
Mrs. Hubbard or to supervise photographic shoots on the property. I was responsible for
ensuring his home was clean and set up for his stay, and for his security arriving and
leaving the Gilman base. Security for the entire base was top priority as it has been at La
Quinta. Our initial “shore story” at Gilman was a fake organization called the “Scottish
Highland Quietude Club.” I had a cover name of “Gerald Amery,” that had been
arranged when I was in La Quinta, and I was given a “home address” in Los Angeles at a
location I had never been to, but which was controlled by the GO.

47.      At the beginning of 1980, the threat of an imminent raid by some law
enforcement agency was announced by the CMO at Gilman. Everyone was required to
go through all their documents and find and remove anything that showed Hubbard’s
control of Scientology, his control of organization monies, his ordering of staff at Gilman
or staff anywhere to do anything, his having been at Gilman, or his intention to live there.
A commercial paper shredder was rented and operated day and night for weeks to destroy
hundreds of thousands, or millions, of pages of incriminating documents, and the
shredded paper was removed from the property by truck.

48.      During this shredding operation, the LRH Gear I/C came to me with a box of
Hubbard’s papers from his personal storage and asked me if they should be shredded. I
determined that the papers were old letters, diaries and other records predating the
Scientology organizations and without any value as evidence to whatever law
enforcement agencies could conduct a raid. I determined that these old papers had
historical value, however, so I moved them to Hubbard’s Personal Public Relations
Bureau (“LRH PPRO Bu”). I also went into Hubbard’s storage, found several more
boxes of his early papers, and moved these as well to the PPRO Bu.

14

50.      Hubbard approved my petition, I transferred to the PPRO Bu, and was posted as
the LRH Biography Researcher, and LRH Archivist. Because of his fear of being served
with subpoenas in then pending civil lawsuits and an approaching Tax Court trial, within
about a month of my posting, Hubbard fled from the Hemet location along with two
personal staff members, and went into deeper hiding. At the same time, because of a
continuing fear that the Gilman Hotsprings property might be raided by law enforcement,
most of Hubbard’s personal staff, including the PPRO Bu, moved our files, equipment
and operations to the Scientology Complex on Sunset Boulevard in Los Angeles. It was
felt that in the LA Complex we could blend in with other “lower level organization”
Scientology staff members, and not be targeted in a raid.

51.      During my first several months in LA in 1980, I was also assigned as “Mission
Second,” the Sea Org Missionaire under the “Mission In-Charge,” on a mission for
Hubbard called “Mission Corporate Category Sort-out” (“MCCS”), the purpose of which
was to work out an organization strategy and corporate restructuring so that Hubbard
could continue to control and direct the global Scientology enterprise but avoid legal
accountability. As MCCS Second, I dealt with Hubbard’s and the organization’s
attorneys and acquired a knowledge of then-existing legal problems, threats and
illegalities. Because of attempts to serve Hubbard in various lawsuits, I was required to
not admit to Scientologists or wogs that communications from the organization could be
gotten to him. I knew this was untrue, however, and that he was in continual
communication through his personal Scientology staff, and I sent him materials myself
during this period.

52.      In October 1980, one of Hubbard’s attorneys arranged for a wog writer Omar
Garrison to contract with a Scientology publishing company in Denmark to write
Hubbard’s biography. As called for in the contract, I became Garrison’s research
assistant, and worked with him in this capacity until I left the organization in December
1981. I set up an office for Garrison in the LA Scientology Complex, and provided him
with office equipment and supplies. I provided him with approximately one hundred
thousand pages of material from Hubbard’s personal archive, scheduled interviews with
Hubbard’s family members and other people who had known him personally, and helped
Garrison in answering his questions and in any way possible.

53.      Throughout 1980 and 1981, I assembled an archive of approximately five hundred
thousand pages of documentation covering Hubbard’s family, education, writings,

15

military service, travels, accomplishments and other relevant parts of his history. I
traveled to England, Florida, Washington, Oregon, Nevada, Montana, Nebraska, Utah,
Iowa, Kansas, British Columbia and Manitoba collecting biographical material, doing
genealogy research or contacting Hubbard’s relatives or former associates. On behalf of
Scientology, I also purchased a number of people’s collections of Hubbard-related
documents and memorabilia. I purchased file cabinets and a photocopier, made bound
volumes of document copies, and organized and filed originals and copies. I read and
studied thousands of pages of Hubbard’s personal records, many of them in his own
handwriting.

54.      Through this study of Hubbard’s personal records I slowly came to the conclusion
that he had lied about virtually every part of his life, and even in the statements he had
made about himself, or had Scientology’s representatives make about him, which had
drawn me into the organization, and kept me laboring and subjected to frightful abuse all
those years. I discovered and documented during the period when I possessed Hubbard’s
personal records that contrary to his representations, he:

- was not a scientist;
- was not an engineer;
- was not a nuclear physicist;
- did not have many degrees and was not very skilled by reason of study;
- had not been crippled or blinded in the Second World War;
- had not cured himself with his mental science;
- had not been awarded twenty-one medals, including two purple hearts.

Hubbard lied about his travels, his “expeditions,” his family, his friends, his military
service, his involvement in “black magic,” his “research,” his honesty, his “ethics,” his
intentions, wogs, Scientologists, and the promised results of Scientology.

55.      Through my study of Hubbard’s documents and his life, by the time I left
Scientology in December 1981, I had also shed much of the brainwashing or
programming about the “technology” and the organization with which I had been
inculcated throughout my more than twelve years of involvement. I concluded that,
contrary to Hubbard’s and the organization’s representations, Scientology:

- was not mathematically precise and not an exact science, indeed was no
science at all;
- had not had a more grueling testing than all other subjects on earth except
physics and chemistry;
- was not based on Hubbard’s scientific research;
- does not work uniformly, and is not the only system on earth that works
for improving the health, intelligence, ability, behavior, skill and
appearance of people, indeed does not work for improving the health,
intelligence, ability, behavior, skill and appearance of people;
- does not produce the ability to handle any and all problems, indeed it
causes terrible problems;
- is not the most ethical organization on the planet, indeed it is an extremely
unethical organization;

16

- is not the only hope for mankind’s survival, indeed is no hope for
mankind’s survival but is a threat to survival;
- did not do and could not do what it says.

56.      By the time I left the organization, it was becoming obvious to me that I had been
defrauded out of all the years I had served Hubbard and Scientology and the money I had
paid and the effort I had made to obtain their promised results. I concluded that, contrary
to Hubbard’s and Scientology’s representations, as a result of applying or being subjected
to the application of their “technology:”

- I had not improved in health, intelligence, ability, behavior or skill;
- I did not have the ability to handle any problem;
- having attained the state of “Clear,” I did not have complete recall of
everything that ever happened to me or anything I ever studied, I could not
do mental computations and study anything in less than one-hundredth the
time, or indeed any faster than, such computations or study took before
“clearing,” I still got colds, my vigor, persistence and tenacity to life were
not higher than anyone had thought possible, my physical vitality was not
markedly improved, and all psychosomatic illnesses had not vanished to
never return;
- Scientology “auditing” psychotherapy did not raise my IQ an average of a
point per hour, indeed, after over a thousand hours of auditing, my IQ had
not been raised even a single point.

57.      Initially, during 1980, when I started to discover that Hubbard’s own documents
contradicted his published statements about his history, I “explained away” the
discrepancies to myself, or held any judgment in abeyance, thinking that further research
would resolve the discrepancies. I also remained completely devoted to Hubbard and to
Scientology right up until I had no choice but to leave the organization. Gradually,
however, I came to see that Hubbard was in fact lying, and I began to espouse the idea
that for Scientology to succeed, for Hubbard to be able to come out of hiding, and for his
work to be accepted legitimately, we Scientologists had to ourselves stop lying and stop
disseminating Hubbard’s lies.

58.      In pursuit of this idea, I critiqued, edited or rewrote a number of public relations
pieces about Hubbard, “about-the-author” sections of his books, or biographical sketches
that Scientology was disseminating. I attempted to prevent the publication of new
writings containing falsehoods, and to get the organization to remove earlier writings
containing falsehoods from its literature. Some of the people responsible for these
publications were grateful for my research and for my identification and correction of
falsehoods they contained. A very senior executive close to Hubbard, however, Norman
Starkey, became enraged because I was questioning and disproving Hubbard’s claims.
Starkey threatened me, and ordered that I be “sec checked” to find out what I had been
saying that was critical of Hubbard, and what documents I had been giving to the
biographer Garrison. I was able to talk my way out of the sec check, and wrote my
concerns in a dispatch to the staff member who had been ordered to get me sec checked.

17

59.      I had remarried in December 1980 to another SO staff member Joyce, and in
October 1981 she transferred to the PPRO Bu to work with me on the Hubbard
biography. Through her study of Hubbard’s documents, Joyce also came to realize that
he was lying about himself and about Scientology, and that the organization was
publishing and disseminating his lies, and enforcing belief in those lies among
Scientologists. It is strictly forbidden for Scientology staff members, even spouses, to
discuss their criticisms of Hubbard or the organization; nevertheless, Joyce and I began to
talk between ourselves about the lies we had discovered, about organization criminality,
and about our fears of being found out and locked up or worse. During our final few
weeks in the SO, we suspected that we were being electronically bugged, and we only
discussed our criticisms, fears and plans while away from the Scientology property, or in
our room in whispers with a radio turned up loud.

60.      Omar Garrison also recognized that there was a huge discrepancy between what
Hubbard and the organization had written and published about Hubbard’s history and
what was revealed in the source materials I was providing from his personal archive.
Garrison had written three books about Scientology before undertaking the Hubbard
biography, and came to realize that the organization personnel with whom he had dealt in
writing the earlier books had provided him with false information. Garrison was
determined that in the biography project he would not write a panegyric or anything
untrue or unconscientious. He also understood that this determination to write the truth
could bring him into conflict with the people running Scientology and responsible for
the project, including with Hubbard himself.

61.      After I was threatened by the senior executive and ordered to be sec checked
about what I was saying about Hubbard, and because of our dawning awareness of
organizational fraud and criminality, which we could no longer justify, Joyce and I
decided to leave the SO and Scientology. Because of our fear that we would be forcibly
detained, separated, locked up, sec checked, stripped of all our personal Scientology-
related possessions, and forced to sign “confessions” of our “crimes,” we knew that we
could not announce our plan to leave, but had to escape. By this time I knew that sec
checks were invasive, abusive interrogations to break people and obtain information with
which to blackmail and control them, and I knew that I would never again submit to
being sec checked by the Scientology organization.

62.      I also knew that because of the knowledge I had of Hubbard’s and his
organization’s lies, fraud and other criminal activities, because of the enormous security
threat my leaving would be considered by organization leaders, and because of my
determination to not submit to further abuse by Scientology and Scientologists, there was
a very high likelihood that I would be murdered if anyone discovered my intention to
leave. Over a two-week period, Joyce and I moved our small amount of personal effects
out of our room and off the Scientology Complex property a bit at a time. On December
12, 1981 we borrowed one of Garrison’s vehicles, carried our last personal belongings

18

63.      This was a very troubling time for Joyce and me because we had been lied to,
abused and cheated out of so many years of our lives in Scientology, had no money, and
now felt threatened for fair game. Nevertheless, we tried to make the best of our
circumstances, to not become embittered, and to get on with our lives. At Garrison’s
request, because he still needed my help on the Hubbard biography project and offered
me a job in his small publishing company, Joyce and I returned to California in early
1982 and got an apartment in Costa Mesa. Soon after our arrival, we both got jobs in a
law firm in Newport Beach, where we worked until 1984. I continued to help Garrison,
who also had an apartment with his wife in Costa Mesa, with various aspects of the
biography project.

64.      Very soon after our arrival back in California, because of communications with
family and friends, Joyce and I knew that GO Intelligence Bu personnel were
investigating us, and we picked up surveillance near our apartment. A few of the GO
intel reports from that period are listed on this web page: http://www.gerryarmstrong.org/50grand/cult/scientology-ops-docs.html
E.g., http://www.gerryarmstrong.org/50grand/cult/b1-dr-1982-02-22.html
On February 18, 1982, Scientology published a “Suppressive Person Declare” on me for
the “high crimes” of leaving the SO and leaving Scientology, and for “spreading
destructive rumours” about Hubbard.
http://www.gerryarmstrong.org/50grand/cult/ga-sp-declare.html

65.      By the time that Scientology issued its SP Declare on me, I knew that such
publications were instruments of the organization’s policy and practice of “black
propaganda,” or “black PR,” which is itself a key component of fair game. Hubbard
defined black PR as:

- the destroying of the reputation or public belief in persons, companies or
nations;
- a common tool of agencies who are seeking to destroy real or fancied
enemies or seek dominance in some field;
- using slander or lies to weaken or destroy;
- using imagination in order to degrade or vilify or discredit an existing or
fancied image.

Suppressive Person Declares are used by Scientology to degrade or vilify a person whom
organization leaders consider an “enemy” and want to destroy. SP Declares are an
instrument in a campaign to destroy a target’s reputation among all Scientologists and to
create an atmosphere in which further fair gaming of the target becomes laudable.

66.      Hubbard stated in one of his policy directives that labeling someone an “SP” “is a
kind action.” By the time I left the Sea Org, however, I knew that Hubbard’s statement is
utterly false, a justification for antisocial and criminal actions toward SPs pursuant to
black PR and fair game, and actually a further act of cruelty toward people labeled “SP.”

19

By that time, I knew that the people Scientology was declaring, labeling and targeting as
“Suppressive Persons” were:

- not the two and one-half percent most evil wogs in the world;
- not insane;
- not psychotic;
- not criminal;
- not destructively antisocial;
- not committing hidden crimes continuously;
- not dramatizing the overt or covert but always complex and continuous
determination to destroy;
- not goofing up or vilifying any effort to help anybody and particularly
knifing with violence anything calculated to make human beings more
powerful or intelligent;
- not automatically curving any betterment activity into something evil or
bad;
- not the only thing wrong in this universe;
- not at the root of every bad condition;
- not incapable of having friends;
- not in a class with Hitler, Stalin, Dillinger and Genghis Khan;
- not filling the institutions with victims, the hospitals with the sick and the
graveyards with the dead;
- not the only people who do not get gains from Scientology auditing
therapy; and,
- not without any rights of any kind.

67.      By the time I left the SO, I knew that the threat of being labeled an “SP” was used
inside the organization to terrify and control Scientologists, and was a greater threat even
than being RPFed. There was no real recourse to being declared an SP, because it meant
that the declared person was in a class of people whose condition, according to
Scientology teaching, cannot be changed, just as many other conditions or handicaps or a
person’s race cannot be changed. Scientologists used the label of SP very frequently, and
people in my own life, including in my own family, were identified to me as SPs.
Because Scientology taught that SPs cause all illness, every time an organization member
became ill, it was necessary to “find the SP” to whom he was connected and “disconnect”
from that SP. It was a “high crime” for any Scientologist to remain connected to an SP,
and punishable with being “declared” oneself. Hubbard’s SP doctrine, policies and
practices and their enforcement by Scientology brought Scientologists to hate, fear and
fair game SPs, who were in truth generally ordinary, decent, loving human beings.

68.      In April 1982, Scientology leaders set up a “sting” purchase of three sets of
photographs of Hubbard and other people in the Sea Org that were owned by two other
former SO members and me. When I delivered the photos to the “purchaser” to examine
before the “sale,” Scientology personnel seized two of the sets. I went into the Los
Angeles Complex along with Joyce and Mr. and Mrs. Garrison and demanded return of
the photos stolen from me and the other ex-SO members. The Scientology personnel to

20

whom I spoke refused to return the photos, and my ex-wife Terri told me as a threat to
get a lawyer.

69.      Within a few days of Scientology’s theft of the photos, I contacted Boston,
Massachusetts lawyer Michael J. Flynn, whom I knew to be representing a number of
people in lawsuits against the organization. A few days after that, Flynn flew me to
Tampa, Florida and had me driven to Clearwater where he and a number of his clients
were participating in a hearing into Scientology being conducted by local government
officials. I told Flynn about my history, circumstances and the threat I was experiencing,
and he agreed to represent me against the organization.

70.      On April 22, 1982 Scientology published another SP Declare on me, this time
charging me falsely with eighteen additional “crimes” or “high crimes,” including theft,
reselling organizational material for private gain, submitting false purchase orders and
willful loss or destruction of organization property.
http://www.gerryarmstrong.org/50grand/cult/ga-sp-declare-rev.html
In its SP Declare, Scientology also falsely claimed that I was promulgating false
information about Scientology, Hubbard and Scientologists, creating and transmitting
erroneous information under the guise of "documentation," falsifying reports, and altering
documents.

71.      Upon receiving this second SP Declare, I was shocked and terrified because of the
blatant lies about me it contained and because it signaled that Scientology was going to
go all out to destroy my reputation, credibility and life. I therefore asked Omar Garrison
for copies of documents that I believed I would need to defend myself legally and to
demonstrate that what I had been promulgating was true information about Hubbard and
Scientology, that my reports were not false, and the Hubbard documents were not altered.
Garrison was himself fearful that Scientology would steal the documents I had provided
to him for the Hubbard biography, so had already copied much of the documentation and
stored the duplicate documents away from his home. He agreed that I could have
whatever documents I believed were necessary to defend my wife and me and disprove
the black PR on me that Scientology was promulgating.

72.      After obtaining the documents from Garrison, I sent them to Flynn in Boston and
to the law firm of Contos & Bunch in Woodland Hills, California, who had also agreed to
represent me as Flynn’s co-counsel. During this period, I also began to write declarations
concerning my experiences inside Scientology and my knowledge of Hubbard’s lies and
organization fraud and criminality. These declarations would be used by civil litigants
against Scientology and by law enforcement agencies in their investigations of the
organization. E.g., http://www.gerryarmstrong.org/50grand/legal/decl-1982-07-22.html
http://www.gerryarmstrong.org/50grand/legal/affi-1982-07-26.html

73.      In August 1982, using the corporation Church of Scientology of California
(“CSC”) as plaintiff, the organization filed a lawsuit against me in Los Angeles Superior
Court, Case No. C 420153, alleging conversion of the biography documents and breach
of fiduciary duty. Mary Sue Hubbard intervened, alleging conversion and invasion of

21

74.      From at least July to September 1982, Scientology hired a number of private
investigators or other agents to spy on, harass, threaten and terrorize my wife and me.
Acts by organization agents during this period include:

- physical assault, by being struck and pushed around;
- getting in my wife’s and my space and face in an intimidating manner;
- coming onto our property;
- frightening our neighbors;
- spying on and frightening our law firm co-workers;
- running into me bodily with a car;
- terrorizing us on a highway by getting in front of us and slamming on the
brakes, and then coming alongside and into our lane to push us off the
road;
- following us in an intimidating manner wherever we went for days on end.

75.      While the civil litigation proceeded, Scientology attempted to get the Los Angeles
Police Department to bring criminal charges against me, falsely claiming that I had stolen
the documents, which I had provided Garrison pursuant to the contract drafted by
Hubbard’s attorney. Also during this period, beginning soon after I left the SO, the
organization’s intelligence bureau ran an operation to get a Scientology operative, a
writer named Dan Sherman, to pretend to befriend me and get close to me. See, e.g.,
step15 in the GO Intelligence Bureau’s “Armstrong Project” dated February 17, 1982:
http://www.gerryarmstrong.org/50grand/cult/gerry-armstrong-project.html

76.      Not long after the “Armstrong Project” started, Scientology’s Guardian’s Office
intelligence functions were taken over by renamed organization components Office of
Special Affairs (“OSA”) and Religious Technology Center (“RTC”), and Sherman
continued to be operated against me by OSA and RTC. He wrote me a number of letters
and met me on a number of occasions, pretending to be antipathetic to organization
management and supportive of me and the stand I had taken against organization fraud
and abuses. He fooled me completely into believing he was an actual friend who actually
liked me.

77.      In the spring of 1984, a thirty-day bench trial of Scientology’s and Mrs.
Hubbard’s complaints took place, presided over by LA Superior Court Judge Paul G.
Breckenridge, Jr. My cross-complaint had been severed from the complaints and was not
tried. On June 20, 1984 Judge Breckenridge issued a Memorandum of Intended
Decision, which became the Judgment in the case on August 18, 1984.
http://www.gerryarmstrong.org/50grand/legal/a1/breckenridge-decision.html
Judge Breckenridge ruled against Scientology and Mrs. Hubbard, finding that I had
organization authorization to provide Garrison with the documents from Hubbard’s

22

78.      Judge Breckenridge was highly critical of Scientology for its fair game doctrine
and of Hubbard for his lying and tyranny.

In addition to violating and abusing its own members civil rights, the
organization over the years with its "Fair Game" doctrine has harassed and
abused those persons not in the Church whom it perceives as enemies. The
organization clearly is schizophrenic and paranoid, and this bizarre
combination seems to be a reflection of its founder LRH. The evidence
portrays a man who has been virtually a pathological liar when it comes to
his history, background, and achievements. The writings and documents in
evidence additionally reflect his egoism, greed, avarice, lust for power,
and vindictiveness and aggressiveness against persons perceived by him to
be disloyal or hostile.

79.      Judge Breckenridge condemned the organization’s practice of “culling”
Scientologists’ supposedly confidential “auditing files.”

[Mrs. Hubbard] was the head of the Guardian Office for years and among
other things, authored the infamous order "GO 121669” which directed
culling of supposedly confidential P.C. files/folders for purposes of
internal security.
…
The Douglasses and Dincalcises were disaffected Scientologists who had a
concern for their own safety and mental security, and were much in the
same situation as defendant. They had not been declared as suppressive,
but Scientology had their P.C. folders, as well as other confessions, and
they were extremely apprehensive.
…
The court is satisfied that [Defendant Armstrong] did not unreasonably
intrude upon Mrs. Hubbard's privacy under the circumstances by in effect
simply making his knowledge that of his attorneys. It is, of course, rather
ironic that the person who authorized G.O. order 121669 should complain
about an invasion of privacy. The practice of culling supposedly
confidential "P.C. folders or files" to obtain information for purposes of
intimidation and or harassment is repugnant and outrageous. The
Guardian's Office, which plaintiff headed, was no respector of anyone's
civil rights, particularly that of privacy.

80.      Judge Breckenridge also commented on the activities of the individuals
Scientology had hired to harass my wife and me, and on the organization’s effort to
prevent one of my witnesses from testifying.

After the within suit was filed on August 2, 1982, Defendant Armstrong
was the subject of harassment, including being followed and surveilled by
individuals who admitted employment by Plaintiff; being assaulted by one
of these individuals; being struck bodily by a car driven by one of these

23

individuals; having two attempts made by said individuals apparently to
involve Defendant Armstrong in a freeway automobile accident; having
said individuals come onto Defendant Armstrong's property, spy in his
windows, create disturbances, and upset his neighbors. During trial when
it appeared that Howard Schomer (a former Scientologist) might be called
as a defense witness, the Church engaged in a somewhat sophisticated
effort to suppress his testimony. It is not clear how the Church became
aware of defense intentions to call Mr. Schomer as a witness, but it is
abundantly clear they sought to entice him back into the fold and prevent
his testimony.

81.      Judge Breckenridge ruled that my attorneys and I were “free to speak or
communicate upon any of [my] recollections of [my] life as a Scientologist or the
contents of any exhibit received in evidence or marked for identification.” And
concerning the documents held by the Court Clerk, the Judge ruled:

As to the equitable actions, the court finds that neither plaintiff has clean
hands, and that at least as of this time, are not entitled to the immediate
return of any document or objects previously retained by the court clerk.
All exhibits received in evidence or marked for identification, unless
specifically ordered sealed, are matters of public record and shall be
available for public inspection or use to the same extent that any exhibit
would be available in any other lawsuit.
...
All other documents or objects presently in the possession of the clerk [ ]
shall be retained by the clerk, subject to the same orders as are presently in
effect as to sealing and inspection, until such time as trial court
proceedings are concluded as to the severed cross complaint.

82.      Within a day of Judge Breckenridge’s decision, Joyce and I flew to the United
Kingdom where I testified in a child custody case trial involving Scientology, Re: B & G
(Wards) in the High Court in London. In a lengthy judgment issued July 23, 1984, Mr.
Justice Latey censured Hubbard’s lying, and a number of Scientology policies and
practices including teaching people to lie, intelligence operations, punishment and
persecution, the Suppressive Person doctrine, disconnection, fair game, and use of the
law to harass. Justice Latey quoted Hubbard’s directive that provides the organization’s
litigation strategy:

“Level “O” Checksheet by L. Ron Hubbard”:

"The purpose of the suit is to harass and discourage rather
than to win. The law can be used very easily to harass, and
enough harassment on somebody who is simply on the thin
edge anyway, well knowing that he is not authorised, will
generally be sufficient to cause his professional decease. If
possible, of course, ruin him utterly."

Some of the Scientology jargon in its own documents, which I have been
citing may not be clear to someone who has not had to undergo the task of
having them explained over the weeks. But their meaning is clear and they

24

show out of the cult's own mouth the frightening, disgraceful and illegal
lengths to which it is prepared to go and does go.

http://www.xenu.net/archive/audit/latey.html#7a

83.      While Joyce and I were in the UK, Scientology agents surveilled us, made a hang-
up call to our hotel, followed us, and generally terrified us. Three Scientology agents
harassed us at the airport when we were flying back to the U.S., falsely accusing me of
passing “sealed documents” to a bearded Arab in a London tavern. I wrote a declaration
detailing this harassment upon arrival back in the U.S.
http://www.gerryarmstrong.org/50grand/legal/a1/decl-1984-07-01.html
Some time later, Scientology produced declarations from two hired private investigators
falsely swearing that they had observed me pass documents to a bearded Arab as the
organization’s agents falsely stated to Joyce and me at the London airport.

84.      Throughout my LA Superior Court trial, Scientology operative Dan Sherman
continued on his intelligence program, continued to profess his friendship, and was able
to insinuate himself into the group of people opposed to organization abuses who
attended the trial. Sherman met with Flynn and me, claiming to be disaffected with the
organization, and told us that he was in communication with a group of Scientologists
within the organization who were also opposed to the abuses and criminality of
“management,” wanted to reform the organization, and respected what we were doing in
exposing the abuses. Sherman said that the core group, which numbered about thirty-five
individuals, called themselves the “Loyalists,” because they were “loyal” to what was
good and honest in Scientology.

85.      After the trial ended, but before Joyce and I flew to the UK, one of the
“Loyalists,” who identified himself as “Joey,” and who I later learned was a David
Kluge, phoned and asked if I wanted to get my auditing files. Scientology’s leaders knew
I wanted these files because I was attempting to get them in discovery, and my ex-wife
Terri had reported that I wanted them in a debrief she wrote after a meeting we had in
March that year.
http://www.gerryarmstrong.org/50grand/cult/gamboa-debrief-1984-03-12.html
I declined Kluge’s offer because, even though the files were my property, my obtaining
them could be construed as accepting stolen property, and because I was due to fly to the
UK the same day the “Loyalists” said my files would be available. From what I now
know, I have no doubt that this op was designed to entrap me in the commission of a
crime.

86.      After I returned to the U.S., Sherman and Kluge reestablished contact with me,
and we met a number of times over the next five months. In late July 1984, Scientology
commenced a media and legal attack on Michael Flynn falsely accusing him of
masterminding a plot to cash a forged check for $2,000,000.00 on one of Hubbard's bank
accounts. Sherman and Kluge communicated that the “Loyalists” knew that it was a
frame-up and that organization leaders were behind it, and the “Loyalists” were working
to prove it was a frame-up. I was certain Flynn was innocent, and of course he was my

25

attorney and friend, so I was grateful for the “Loyalists’” help in clearing his name, and I
was willing to help them as I could.

87.      Over the next few months, the “Loyalists” sent me a number of messages via
Sherman relating to the Flynn frame-up, including what they claimed was documentary
evidence to be passed on to Flynn and the Assistant U.S. Attorney in Boston who was
investigating the case. Because of their claimed fear of being discovered by organization
leaders and murdered, I met with “Loyalists” Kluge and Mike Rinder in “secret”
prearranged locations in Griffith Park and a Los Angeles area cemetery. Kluge also took
me to a meeting with a woman he identified as “Rene,” a “rich Scientologist who had
been abused by the organization and who might back the “Loyalists” financially,” and a
meeting with an “attorney” “named” “Thomas Janeway.” Kluge also attempted to get me
to fly to Las Vegas to meet another “financial backer,” but on my attorney’s advice
because of the risk I didn’t make the trip. Knowing what I now know, there is no doubt
that each of these meetings was recorded, and was set up to entrap me.

88.      During this period, agents of the FBI who were involved in an investigation of the
organization contacted me, and I met with them and discussed my Scientology
experiences and knowledge. Justice Department attorneys who were litigating
Scientology-related cases contacted me, and I communicated with them and provided
them with declarations concerning my experiences and knowledge. Officers in the
Ontario Provincial Police and the Clearwater, Florida Police Department who were
investigating Scientology also contacted me, and I provided them with testimony about
Hubbard, the organization and my experiences.

89.      A short time after my LA trial, agents in the Criminal Investigation Division of
the IRS in Los Angeles contacted me, and I met with them and provided them with
whatever information I had concerning Hubbard and Scientology. The IRS obtained
access to certain documents and audio recordings of MCCS legal strategy meetings that
the Court Clerk had retained in my case, and which became the subject of the series of
cases entitled U.S. v. Zolin.
E.g., http://www.gerryarmstrong.org/50grand/legal/us-v-zolin-us-sup-1989-06-21.html
See also, http://www.gerryarmstrong.org/50grand/legal/other-scientology-litigation.html

90.      I naturally informed the IRS CID agents with whom I communicated about the
“Loyalists” and about their activities, plans and fears as Sherman, Kluge and Rinder
expressed them to me. The CID agents indicated that they wanted the “Loyalists” to
contact them, and that the CID would protect them, even by getting them into a witness
protection program. I conveyed the CID’s communications to the “Loyalists” via
Sherman and Kluge, and also gave them the contact information for a Justice Department
attorney involved in federal Scientology-related litigation.

91.      On November 8, 1984, immediately following a Griffith Park meeting with
Sherman, and during a meeting with the CID in the LA Federal Building, my car, which I
had parked in an underground parking garage nearby, was broken into and a briefcase

26

92.      On November 30, Peterson wrote to Ms. Dragojevic asserting that Scientology
had no knowledge of the theft and suggesting that the FBI or the IRS were responsible.
http://www.gerryarmstrong.org/50grand/writings/peterson-ltr-1984-11-30.html
In 1991 and 1992, Vicki Aznaran, who had been a high organization executive working
closely with David Miscavige, and who had left in 1987, told me that Miscavige had
admitted to her that he possessed the materials stolen from my car, and described them to
her as “weird poetry.” In a number of conversations between 1998 and 2001, Jesse
Prince, another former high Scientology executive who had worked closely with
organization leader Miscavige, also told me that Miscavige bragged to him about
possessing the materials stolen from my car, and described them similarly as “weird
writing” and “letters to Hubbard.”

93.      In 1985, I filed a California Public Records Act request seeking records that the
LAPD possessed concerning me, including concerning the November 8, 1984 theft of my
briefcase, documents and art. From subsequent correspondence with the LA City
Attorney’s office, and from a study of what was and was not found in the LAPD’s files
concerning the theft, I have formed a belief that the LAPD’s records were altered and/or
destroyed in order to prevent an investigation of this crime. See, e.g.,
http://www.gerryarmstrong.org/50grand/legal/police/ga-ltr-boeckman-1985-12-19.html
http://www.gerryarmstrong.org/50grand/legal/police/boeckman-ltr-1986-03-10.html

94.      During the “Loyalist Op,” Sherman told me that Scientology’s leaders had hired
as their top private investigator Eugene Ingram, who had been a sergeant in the LAPD’s
vice squad, and who reportedly had been fired for, among other crimes, pimping and
aiding drug dealers. Sherman told me that the Loyalists said that the organization had
hired Ingram because he still had a lot of friends on the LAPD who owed him favors. I
knew that Ingram was involved in the Scientology operation to frame Flynn with the
forgery of the $2,000,000 check, and I telephoned his office once to advise him he was
framing the wrong man. I didn’t get Ingram when I called, but he called me back and
threatened that he was going to put a bullet between my eyes. I believe that Ingram is an
unscrupulous and criminal individual and that, as he threatened, he would murder if he
thought he would get away with the crime.

95.      At one point, the “Loyalists,” via Kluge and Sherman, asked for my help with a
lawsuit by which they said they wanted to legally and safely take control of the
organization from the leaders whom they identified as “criminals.” At my request, Flynn
drafted a “bare bones” complaint for the “Loyalists,” which I gave to them and discussed
with Sherman and Kluge. Because both of them claimed that they knew little about legal
matters, a pair of meetings to discuss the complaint were set up on November 17 and 30,

27

96.      While Scientology’s leaders ran their “Loyalist” intelligence op, they continued a
global public black PR campaign against me. See, e.g., OSA International Executive
Directive No. 19, dated September 20, 1984, entitled “Squirrels,” the “routing” on which
shows it was to be posted on every Scientology organization notice board and distributed
to every Scientologist. “Squirrels,” according to Scientology teachings, are “Suppressive
Persons” whom the organization claims are engaging in “weird practices,” or “altering
Scientology,” and who are hated and vilified by organization Scientologists. The black
PR language Scientology uses in this document to attack me and the other five named
individuals, is disgusting and shocking.

Their actions are destructive and aimed at the enslavement rather than the
freedom of man…
[They] have attempted to taint government with their false reports…
[They] have offered false testimony to the IRS in order to protect their
[crimes] against mankind…
[They] have misrepresented Scientology practices to the FBI or Justice
Department in a futile attempt to taint the minds of the government and
the courts against the Church of Scientology…
[T]heir continued desire to drag others to the level of beasts and animals
devoid of spiritual qualities places them in the psychiatric camp of those
who manufacture madness for profit.
http://www.gerryarmstrong.org/50grand/cult/osa-int-ed-19-squirrels.html

97.      Also during this period, Joyce concluded that she could no longer bear the
constant threat from Scientology that we had experienced virtually every day since
leaving the organization. I saw, however, that I could not escape the conflict, that the
threat would be present whatever I did or wherever I went, and that I had a responsibility
to continue to oppose the organization and hopefully bring it to end its abusing and fair
gaming of people. As a result, Joyce and I decided to separate, so that I could carry on
the battle and she would be to some extent free of the threat she felt while living with me.
In December 1984, I moved out of our Costa Mesa apartment, and traveled to my
family’s home in British Columbia for the holidays. Before I left, Kluge called me and
told me that the “Loyalists” wanted action not words, that I had said something wrong,
and they no longer trusted me.

98.      After returning from B.C. in early 1985, I stayed with friends in southern
California for some weeks, then traveled to Portland, Oregon to testify on behalf of the
plaintiff in the trial of Julie Christofferson-Titchbourne v. Scientology, Multnomah
County Circuit Court No. 7704-05184. During my cross-examination, Scientology
attorney Earle C. Cooley revealed that Ingram had videotaped and audio taped my

28

99.      On April 23, 1985, Los Angeles Police Chief Daryl F. Gates issued a public
statement completely repudiating Scientology’s claim that the LAPD had authorized
Ingram’s eavesdropping and declaring the Rodriguez “authorizations” invalid.

It has come to my attention that a member of the L. A. P. D. very
foolishly, without proper authorization and contrary to the policy of this
Department, signed a letter to Eugene M. Ingram, believed to have been
drafted by Ingram himself. The letter purports to authorize Ingram to
engage in electronic eavesdropping. The letter, along with all the
purported authorization, is invalid and is NOT a correspondence from the
Los Angeles Police Department.
The Los Angeles Police Department has not cooperated with Eugene
Ingram. It will be a cold day in hell when we do.
I have directed an official letter to Ingram informing him that the letter
signed by Officer Phillip Rodriguez dated November 7, 1984, and all other
letters of purported authorizations directed to him, signed by any member
of the Los Angeles Police Department, are invalid and unauthorized.
Internal Affairs Division is now investigating the entire incident.
http://www.gerryarmstrong.org/50grand/images/gates-announcement.gif

100.      Scientology sought to have the videotapes of the meetings with Kluge and Rinder
admitted into evidence in the Christofferson trial, and the presiding Judge Donald F.
Londer initially refused, ruling that the organization had made them illegally. After
viewing the tapes in chambers, however, he stated that "the tapes are devastating, very
devastating to the church," and for that reason admitted them into evidence. Despite
Chief Gates’ denouncement of Ingram, Rodriguez and their eavesdropping
“authorizations,” and despite Judge Londer’s ruling that the tapes were illegal, and his
comment that they were devastating to Scientology, the organization immediately
commenced a black PR campaign against me concerning the videotapes that continues to
this day.

101.      Even while the Christofferson trial proceeded, Scientology published and
disseminated internationally an edition of its black propaganda magazine ““Freedom””
containing a mendacious and perverse account of their “Loyalist” operation.
http://www.gerryarmstrong.org/50grand/cult/freedom-1985-04-1.html
The tapes were terribly embarrassing to me because I curse and make some bawdy jokes
while being covertly videotaped. The tapes were also psychologically devastating to me
because of the betrayal, entrapment and hatred by Sherman, Kluge, Rinder, Miscavige
and Scientology that they represent to me. The tapes do not, however, contain or show

29

102.      Because of Scientology’s unceasing lying about its “Loyalist” operation,
including lies by organization leader Miscavige in a sworn declaration, I have detailed
what actually happened in several declarations since 1985. See, e.g., two declarations I
wrote in response to Miscavige and Scientology lies that were filed in the case of
Scientology v. Fishman & Geertz, USDC for the Central District of California, Case No.
CV 91-6425 HLH(Tx).
http://www.gerryarmstrong.org/50grand/legal/decl-1994-02-22.html
http://www.gerryarmstrong.org/50grand/legal/decl-1994-02-20.html

The tapes show that in the fall of 1984, during the reign of the
organization's present supreme leader [Miscavige], the fair game doctrine
was alive and as unfair as ever. The tapes show a mean-spirited,
mendacious and malevolent organization using well-drilled operatives and
electronic gadgetry to attempt, unsuccessfully, to set up an unwitting,
funny, sometimes silly, clearly helpful, at times foul-mouthed, but
otherwise ordinary human male.

103.      Immediately following Scientology’s disclosure of the videotapes in the
Christofferson trial, the organization used staff members Kenneth Hoden, Kathleen
Gorgon, Heber Jentzsch and David Butterworth and its attorney John Peterson to attempt
to get the LA District Attorney to prosecute Flynn, LAPD Chief Gates, two IRS CID
agents and me on various false criminal charges trumped up out of the “Loyalist” op.
This effort to have us prosecuted for Scientology’s own illegal actions, with organization
personnel delivering voluminous materials (“data on the background of Jerry
Armstrong”) to the office of the DA, and meeting and telephoning several times with DA
staff, continued until at least April 1986. At that time, the DA wrote a lengthy letter
rejecting each Scientology charge, criticizing the organization’s refusal to divulge
requested necessary information, and concluding that “there is no evidence in support of
the allegations of criminal conduct.”
http://www.gerryarmstrong.org/50grand/cult/d-atty-ltr-to-hoden-1986.html

104.      Hubbard provided Scientology’s philosophy and policy underlying the
organization’s continuing conspiracy to have me prosecuted on false criminal charges in
a very central directive entitled "The Scientologist - A Manual on the Dissemination of
Material," originally published in 1955, and republished several times since.

The DEFENSE of anything is UNTENABLE. The only way to defend
anything is to ATTACK, and if you ever forget that, then you will lose
every battle you are ever engaged in, whether it is in terms of personal
conversation, public debate, or a court of law. NEVER BE INTERESTED
IN CHARGES. DO, yourself, much MORE CHARGING, and you will
WIN. And the public, seeing that you won, will then have a
communication line to the effect that Scientologists WIN. Don't ever let
them have any other thought than that Scientology takes all of its
objectives.

30

http://www.gerryarmstrong.org/50grand/cult/dissem-of-material-1976.html

105.      In the same directive, Hubbard laid out the other key part of Scientology’s
legal/litigation strategy.

The law can be used very easily to harass, and enough harassment on
somebody who is simply on the thin edge anyway, well knowing that he is
not authorized, will generally be sufficient to cause his professional
decease. If possible, of course, ruin him utterly.

Employing the courts and law enforcement agencies to do Scientology’s “much more
charging” on its manufactured evidence, and using the law to harass and ruin people
utterly, are, of course, unlawful uses of the law and justice system.

106.      In addition to making countless false statements about what the illegally made
videotapes show or contain, Scientology also altered the tapes, at a minimum deleting
audio sections where the organization’s agents acknowledge and discuss its criminal
activities. Scientology also created at least one radically edited videotape version of my
meetings with Kluge and Rinder that uses certain of my statements out of order and out
of context, and adds a Scientologist narrator to create a false and perverse picture of what
was occurring. A number of people have told me that the organization ordered
Scientologists to attend showings of edited versions of the videotapes at various
Scientology locations internationally, and then “regged” (used high pressure sales
techniques on) each of the attendees for $2000 for the organization’s International
Membership Unit’s “war chest.” I was told that Scientology’s “target” for this “reg
cycle” was 25,000 Scientologists, or $50,000,000. See, e.g., this announcement of the
videotape playing that was posted inside and around the Scientology complex in LA and
distributed to Scientologists in or about May 1985.
http://www.gerryarmstrong.org/50grand/cult/ias-flyer-1985-04.html

107.      In September 1985, I moved to Boston to work as a paralegal in Michael Flynn’s
law office. In October, Scientology had one of its personnel file a criminal complaint
with the FBI falsely accusing me of impersonating a Bureau agent. Scientology lawyer
Roger Geller also participated in the impersonation frame-up, calling and repeatedly
writing the FBI to pressure them to prosecute me.
http://www.gerryarmstrong.org/50grand/cult/fbi/index.html
Scientology lawyer Peterson used the Boston Scientologist’s false complaint, and made
the same false impersonation charge, and a false and execrable charge that I was
conspiring “to destroy a religion,” to bolster the organization’s continuing pressure on the
LA DA to charge me in the videotape frame-up.

I am sending you with this letter an affidavit from a Boston Church of
Scientology staff member who was interrupted and harassed by Gerald
Armstrong on Sunday, October 13, 1985. Armstrong impersonated an FBI
officer during this encounter. A complaint has been lodged with the
Boston FBI office and is being followed up by that office right now.
You will recall from our complaint that Armstrong has sought the shelter
of more than one government agency in the midst of his conspiracy to

31

destroy a religion. He is a) continuing to do that; b) continuing his pattern
of harassment against the Church of Scientology.
http://www.gerryarmstrong.org/50grand/cult/fbi/peterson-ltr-1985-10-24.html

108.      The period I was in Boston and working at the Flynn law firm, until December
1986, I felt constantly under attack and threatened by Scientology. Organization agents
surveilled, followed and photographed me, staked out and photographed my residence,
and frightened my housemates. Scientology continued its global black PR campaign
against me, including the “papering” of Boston with issues of the organization’s
““Freedom”” magazine.
See, e.g., http://www.gerryarmstrong.org/50grand/cult/freedom-1986-02-special-4.html

109.      The litigation of my cross-complaint continued in LA, and was made very
unpleasant and troubling by the organization’s dishonest and abusive litigation tactics.
Scientology is in fact globally infamous for such practices, including obstruction, refusal
to comply with court ordered discovery, and destruction of evidence.
See, e.g., http://www.gerryarmstrong.org/50grand/legal/decl-ideman1993-06-21.html
At one point, for no reason but vindictiveness, the organization culled statements from
my “confidential” “priest-penitent privileged” auditing files, gave them to lawyers and
filed them in court. The culled statements concerned embarrassing incidents from my
past, my sexual history, and indiscretions from my youth, plus “incidents” that never
happened but which Scientology manufactured for black PR purposes.

110.      I had by this time come to see this Scientology practice of obtaining a person’s
“confessions” in auditing by creating a relationship of “trust” and promising
confidentiality, and then using those “confessions” against him, as the most despicable of
the organization’s many abhorrent activities. The organization’s culling of my auditing
file, and dissemination of my “confessions” and invented “crimes,” was an emotional
nightmare for me. Two years later, Vicki Aznaran revealed that when my auditing files
were ordered produced in discovery in my case she had been ordered to remove and
destroy anything that would have helped me or been damaging to Scientology.

During litigation between Gerald Armstrong and Scientology, which was
before Judge Breckenridge of Superior Court for Los Angeles County, the
court ordered the production of Armstrong's pre-clear ("PC") folders.
These are files maintained by Scientology on those who submit to
interrogation sessions in a process called auditing. During the course of
that litigation I was ordered to go through Armstrong's folders and destroy
or conceal anything that might be damaging to Scientology or helpful to
Armstrong's case. As ordered, I went through the files and destroyed
contents that might support Armstrong's claims against Scientology. This
practice is known within Scientology as "culling PC folders" and is a
common litigation tactic employed by Scientology.
http://www.gerryarmstrong.org/50grand/legal/aznaran/decl-aznaran-1988-08-09.html

111.      In addition to framing Flynn with the $2,000,000 check forgery, procuring the
phony “authorization” to wiretap him from corrupt LAPD officer Rodriguez, and

32

112.      Scientology sued Flynn and his co-counsel some thirteen times, and filed
numerous false bar complaints against him. Organization agents surveilled, followed and
photographed him in Boston and when he traveled, and infiltrated his office by
pretending to be abused and disaffected ex-Scientologists seeking legal help. The
organization harassed and terrified his family and severely disrupted their lives, and
harassed his associates and former clients. Flynn sued Scientology, Hubbard and Ingram
and described organization fair game actions against him in numerous public statements
and sworn declarations.
See, e.g., http://www.gerryarmstrong.org/50grand/legal/flynn/affi-flynn-1984-08-10.html
http://www.gerryarmstrong.org/50grand/legal/flynn/decl-flynn-1985-04.html

113.      Flynn was for several years a principal guiding spirit and driving force in the legal
battle against Scientology in the U.S., and even internationally, and was involved as
attorney of record or of counsel on behalf of more than twenty claimants against the
organization. During the time he represented me or I worked in his office, he had settled
a number of individual Scientology cases, and on various occasions had had discussions
with organization lawyers concerning the possible settlement of all the Scientology-
related cases in which he was involved. In the fall of 1986, Flynn informed his clients in
those cases, including me, that he had reached an agreement with Scientology for a global
settlement, and he and I agreed on a monetary figure to settle my case.

114.      My cross-complaint was then set for trial in early 1987, and all the organization
fraud, internal abuse and external fair game that would come out in a public trial in Los
Angeles was certainly a motivating factor in Scientology’s desire to settle with Flynn and
all his clients, many of whom would be witnesses for me. He communicated that
Scientology’s leaders said they wanted peace, and that they had promised that if a global
settlement happened they would end fair game forever. I was happy to settle my case and
end the war with Scientology, because it meant, I believed, that there would be no
lengthy appellate process, and that I would be able to live in peace. By this time too,
much of my potential testimony was already publicly available in trial or deposition
transcripts, or in the many declarations I had written since leaving the organization, so I
felt that with Scientology’s promise to end fair game I had fulfilled my responsibility to
the organization’s victims and had earned the peace promised.

115.      I had testified about fifty days in trial or deposition in perhaps ten cases,
Scientology’s lawyers usually conducted abusive, threatening examinations, and the end

33

116.      I have written about the circumstances at the time of the “settlement” in many
declarations, and have waived the attorney-client privilege between Flynn and me as to
our conversations concerning the “settlement.” See, e.g.,
http://www.gerryarmstrong.org/50grand/legal/decl-1997-01-26.html 12:18-18:14.
I was aware of Scientology’s “settlement contracts” by which the organization sought to
prevent its litigation opponents and even its own members from disclosing their
knowledge of its activities, and I had signed such documents while inside the
organization. See, e.g., this “non-disclosure and release bond” that I was required to sign
while on the RPF in Clearwater in 1977, and which at my 1984 trial was ruled to be
unenforceable. http://www.gerryarmstrong.org/50grand/cult/non-dsclsre-rls-bond.html

117.      During the period when Flynn was involved in settlement negotiations with
Scientology’s lawyers, I had spoken and written memos to him stating that I would not be
bound by such a non-disclosure clause. I was willing to not contact the wog media about
Scientology because an ending of media involvement would help facilitate the
organization’s cessation of fair game; in fact I was glad to not have to respond with
media interviews, as I often found them stressful or silly. Since leaving the organization,
I had given interviews to several newspapers; major news magazines such as Time,
Newsweek, People and Forbes; and television news programs such as 20/20, 60 Minutes
and the CBC’s 5th Estate; and I had given in-depth interviews over a number of days to
three different authors writing books about Hubbard and Scientology. Having for years
made all my Scientology experiences and knowledge available to the media, I was
willing to voluntarily stop being available; but I was unwilling to be compelled by
“contract” to not discuss my organization knowledge and experiences with anyone
because such silence would be nonsensical and impossible.

118.      I was not shown the “contract” Scientology wanted me to sign until after I had
flown from Boston to LA where Flynn had been arranging the global “settlement” with
organization lawyers, and upon reading the document I was shocked and sickened.
http://www.gerryarmstrong.org/50grand/legal/a1/mutual-release-1986.html
The “contract’s” language prohibiting any discussion of my experiences or knowledge of
Scientology, prohibiting any assistance to the organization’s adversaries including
governmental agencies, punishing me with a $50,000 “liquidated damages” penalty per
utterance, and requiring that I avoid service of subpoenas, was far worse, and more
ludicrous, cruel and impossible than I had ever imagined. See, e.g.:

[Para. 7D] Plaintiff [Armstrong] further agrees that he will maintain strict
confidentiality and silence with respect to his experiences with the Church

34

of Scientology and any knowledge or information he may have concerning
the Church of Scientology, L. Ron Hubbard, or any of the organizations,
individuals and entities listed in Paragraph 1 above. Plaintiff expressly
understands that the non-disclosure provisions of this subparagraph shall
apply, inter alia, but not be limited, to the contents or substance of his
complaint on file in the action referred to in Paragraph 1 hereinabove or
any documents as defined in Appendix "A" to this Agreement, including
but not limited to any tapes, films, photographs, recastings, variations or
copies of any such materials which concern or relate to the religion of
Scientology, L. Ron Hubbard, or any of the organizations, individuals, or
entities listed in Paragraph 1 above. [ ] Plaintiff agrees that if the terms of
this paragraph are breached by him, that CSI and the other Releasees
would be entitled to liquidated damages in the amount of $50,000 for each
such breach. All monies received to induce or in payment for a breach of
this Agreement, or any part thereof, shall be held in a constructive trust
pending the outcome of any litigation over said breach. The amount of
liquidated damages herein is an estimate of the damages that each party
would suffer in the event this Agreement is breached. The reasonableness
of the amount of such damages, are hereto acknowledged by Plaintiff.

[Para. 7G] Plaintiff agrees that he will not voluntarily assist or cooperate
with any person adverse to Scientology in any proceeding against any of
the Scientology organizations, individuals, or entities listed in Paragraph 1
above. Plaintiff also agrees that he will not cooperate in any manner with
any organizations aligned against Scientology.

[Para. 7H] Plaintiff agrees not to testify or otherwise participate in any
other judicial, administrative or legislative proceeding adverse to
Scientology or any of the Scientology Churches, individuals or entities
listed in Paragraph 1 above unless compelled to do so by lawful subpoena
or other lawful process. Plaintiff shall not make himself amenable to
service of any such subpoena in a manner which invalidates the intent of
this provision.

[Para. 10.] Plaintiff agrees that he will not assist or advise anyone,
including individuals, partnerships, associations, corporations, or
governmental agencies contemplating any claim or engaged in litigation or