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AFFIDAVIT OF GERRY ARMSTRONG

    I, Gerry Armstrong, hereby swear under the pains and

penalties of perjury as follows:

    1) I have personal knowledge of the following facts:

    2) I was a member of the Sea Organization of

Scientology from February 1971 to December 1981, during which

time I held many positions and was in many locations where I

directly observed L. Ron Hubbard and other Scientology

executives. At no time did I ever get the impression that

Mr. Hubbard or any other senior executive considered that

Scientology is a religion. What I knew to be a fact

throughout all the time I spent in Scientology, and what was

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expressed to me as policy by other Sea Org members, was that

Scientology operated totally as a business, and its efforts to

be recognized as a "religion" were only to evade taxation and

government regulations.

    3) In January 1980, I was assigned to a project to

collect materials about L. Ron Hubbard for the purpose of

providing documentation for a biography to be written by

Omar V. Garrison. During the following two years I read

several thousand pages of documentation, much of it written by

Mr. Hubbard himself. Never before had anyone within

Scientlogy ever had all this information assembled in one

place or had the opportunity to view and assimilate the whole

truth about L. Ron Hubbard. From these documents and other

sources I learned that Mr. Hubbard had continually

misrepesented himself and had lied about his past, his

accomplishments and credentials. I learned also from the

documents I collected that Mr. Hubbard had lied about how and

why Scientology had been established as a "religion". In a

despatch he wrote in early 1980 to the people in charge of the

projects he had ordered to remedy his legal problems with the

IRS and various damage claim cases, he stated that the

creation of Scientology as a "religion" was not his idea but

had come about when the membership of Scientology in the early

1950's, unbeknownst to him, had voted to form a "church". I

personally saw and read that despatch. Mr. Hubbard's

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statement is a lie. In a letter to the head of Scientology in

the US in early 1953, Mr. Hubbard stated:

"We don't want a clinic. We want one in

operation but not in name. Perhaps we could call

it a Spiritual Guidance Center. Think up its

name, will you. And we could put in nice desks

and our boys in neat blue with diplomas on the

walls and 1. knock psychotherapy into history and

2. make enough money to shine up my operating

scope and 3. keep the HAS solvent. It is a

problem in practical business.

    "I await your reaction on the religion

angle. In my opinion, we couldn't get worse

public opinion than we have had or have less

customers with what we've got to sell. A

religious charter would be necessary in

Pennsylvania or NJ to make it stick. But I sure

could make it stick. We're treating the present

time beingness, psychotherapy treats the past and

the brain. And brother, that's religion, not

mental science."

I found a great deal of similar evidence in the materials I

assembled before I left Scientology. Mr. Hubbard's life has

been a continuing pattern, since the early 1940's, of

fraudulent business practices, tax evasion, flight from

creditors and those seeking recompense, and then going into

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hiding, outside the reach of wronged individuals and legal

jurisdictions. In short, it is the life of a con man.

    4) In early 1980 I was also assigned to a mission,

the purpose of which was to work out legal strategies, and get

them implemented, which would allow Mr. Hubbard to still

control all of Scientology via his Commodore's Messenger

Organization while being shielded from any lawsuits or legal

involvements and responsibilities. One of the main problems

which had to be resolved by this mission, and one of the

arguments used in various court cases as proof that

Scientology was not a religion, was the fact that Scientlogy

was set up so that funds inured to the benefit of L. Ron

Hubbard. For years Mr. Hubbard had had his legal

representatives claim that he was not paid by Scientology,

other than a $35,000.00 annual consultant's fee, and royalties

from sales of his books. Another claim was that he did not

control Scientology monies. The fact is he had absolute

control of all Scientology accounts. As late as 1980 I saw a

despatch from him in which he ordered that unlimited

Scientology funds were approved for a project to get him a

Nobel Prize. Another fact is that he received millions of

Scientology dollars directly from a foreign corporation called

Religious Research Foundation. Payments for auditing or

courses at Flag by non-US Scientologists went into RRF

accounts which Mr. Hubbard controlled absolutely and used

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totally for his own purposes.

    5) I have personal knowledge of policies of the Church of

Scientology relating to the following facts, or I have had

possession of documents and tapes relating to the following

facts:

    6) On or about September 28, 1980, a meeting took place in

the Cedars Complex at Los Angeles, California, one of the

corporate headquarters of the Church of Scientology of

California, (CSC). The meeting was attended by Charles Parselle,

(C.P.), Deputy Guardian for Legal, (DGL), at WW, who was in

charge of all legal activities for Scientology throughout the

world and Laurel Sullivan, (L.S.), the personal representative of

L. Ron Hubbard, a long term senior executive of Scientology and

then In Charge, I/C, of a special legal Mission, (MCCS), which

mission was seeking to conceal Hubbard's control of Scientology

and develop strategies to effectuate actual control by Mr.

Hubbard without incurring legal responsiblity. Dick Sullivan, a

junior executive of the MCCS mission, pursuant to orders, tape

recorded the meeting. The individuals in attendance at this

meeting are knowledgeable of the fact that Mr. Hubbard has always

controlled all aspects of CSC including its bank accounts,

policies, etc.

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    7) At the meeting, the following exchange took place

relating to the corporate structure of the Organization and Mr.

Hubbard's position in the structure. This exchange was tape

recorded with the knowledge and assent of all present:

L. S. "There is no need for them to be the actual Board of
Directors.

C.P. "There's no need at all for them to be the Board of
Directors in order for them to run the Church, but the
authority of the Church has to lie somewhere, and on some
basis. And since the Church has always chosen a corporate
entity, eventually the authority is going to have to vest
with the Board of Directors. The only reason it's worked so
long without that occurring is because everyone has
effectively been bound by the authority of LRH and have
ignored corporate lines."

    8) It was common knowledge among senior executives of CSC

that Mr. Hubbard had absolute control of all large corporate bank

accounts and that he, alone, had the authority to order

withdrawal of very large amounts from these accounts. He

controlled these accounts through various people, mainly CMO

members. Neither the "Directors" of CSC nor any other CSC execu-

tives had such authority or control. This policy was practiced

throughout the period of at least 1970 to when I left the Organi-

zation in December, 1981.

    9) Mr. Hubbard received millions of dollars through a dummy

corporation (R.R.F.), specifically set up to funnel money to him

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which should have been paid to CSC by foreign customers paying

for "Flag" services. "Flag" is part of CSC. At a strategy

meeting on September 29,1980, held by several high ranking

senior executives of the Church, the purpose of which was to develop

legal strategies to shield Mr. Hubbard but funnel corporate money

to him, the following exchange took place. This exchange was

tape recorded with the knowledge of all present. The following

people were some of those present:

a. Charles Parsell, Deputy Gardian Legal World Wide, (CP)

b. Alan Wertheimer, attorney for L. Ron Hubbard working
with Laurel Sullivan and the MCCS Mission, (AW)

c. Laurel Sullivan, L. Ron Hubbard's Personal
Representative and I/C of MCCS, (LS)

d. Dick Sullivan, husband of Laurel Sullivan and a junior
executive on the MCCS Mission, (DS)

The exchange was as follows:

CP: "Right. That's a very helpful exercise. And also I
may say this, that it is very very helpful for LRH to have
his own attorneys, i.e. yourselves, because for many years
we have been missing this essential service and we have done
this exercise of trying to think of the way it would be on
the one side and trying to think of the way it would be on
the other side and it really doesn't work very well to do
that. It doesn't work to represent both parties at the same
time. Especially if you also happen to be a Scientologist
and involved in that particuar way as well. So, I'm with
relief representing the Church interest and I certainly
invite you to represent Ron's interest as much as you can.
I say that RRF, which is as far as I am concerned part of
the Church, made a mistake when it paid over that 2.1
million. RRF had nothing ... We could say that RRF and CSC
are part of the same Church, even through they are
corporately different. I mean if anything was a sham
corporation, it's RRF.

-7-

AW: "As I understand it, RRF receives monies that would
otherwise be due the California Church for services rendered
by the California Church to people outside of the country
who decide to pay the Church from outside the country.

CP: "That's right.

AW: "So that's basically right?

CP: "That's right. Foreign - non-US Scientologists who
wish to pay for Flag services pay RRF and then go to Flag
and take the services. RRF was originally supposed to hold
the money until the service was rendered and then pay it to
CSC. But in fact, it has not really done that and so CSC
has rendered much service to may foreign Scientologists and
RRF has got the money. Fortunately for us, RRF wasn't
incorporated until 1973 and we are now litigating 1972. So,
I haven't really tried to sort this one out but it obviously
is the classic case (loud laugh) of inurement, if not
fraud.

(Several laughs)

LS: "Well put.

Speaker Unidentified: "It's all privileged.

DS: "The tape recorder is going here, Charles

CP: "However, as you can see, our finanical direction is
really weighted to this solution and it is an ongoing battle
which I will eventually win because I am the one who has to
litigate the case next year and we obviously have to handle
RRF. The way we will probably handle it is by simply saying
it is party of the same Church, in fact. Now that, of
course, goes directly contrary to what you're doing which is
to split LRH off from the Church and to talk about the
corporate intergrity of the different Churches.
Unfortunately, the Churches do not have any corporate
integrity. And our efforts to give them corporate integrity
have not hitherto been successful. Now when you talk around
a table like this and there is no Internal Revenue agent
present, (whispered: I hope so), bugged or otherwise, one
can work out solutions. But when you are a few weeks away
from a trial and everything you say is going to be rammed
down your throat, then you have to start looking at what
actually happened. And it's very difficult to assign signi-
ficances to things other than what was actually being done

-8-

at the time. We are trying to say for example that Flag in
1970 is a part of California Church which is probably true
but there is no documentation to say that and the truth of
the matter is that Marty Greenburg, the accountant, decided
to include Flag's accounts in California accounts some years
later for convenience. So the decision, what is - the IRS
can say and are in fact alleging that Flag in those years,
1970 - 1972, was an unincorporated association to which
CSC's income inured on a grand scale. We cannot point to a
document which says, 'Actually Flag was part of CSC during
the years of question' because it doesn't exist because no
one really thought of it. So, we have to have a different
theory of the case, which is going to account for all facts
and omitted facts which do exist.

Speaker Unidentified: "Is this the why of efforts to
create corporate integrity in 1980?"

    10) It is common knowledge among senior executives of the

Organization and it is the policy of CSC that Members of the

Boards of Directors of the various Scientology corporations are

mere figureheads, without authority or control, not for internal

corporate reasons, but rather to vest control in Mr. Hubbard. I

have personal knowledge that in order to carry out this corporate

fraud, Organization executives have engaged in various unethical

practices including backdating phony Board Minutes and forging

signatures.

    11) I learned through my study of the documentation I

assembled, and from more than ten years of observation of Mr.

Hubbard and the Scientology movement, that Mr. Hubbard has

cruelly deceived his followers to the point where they will

themselves lie and attempt to deceive others about the truth

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concerning him and Scientology. Scientology spokesmen and

witnesses have stated that Mr. Hubbard doesn't control the

organizations. The fact is he has absolute control, including

financial control, and Scientolgists know it. Between 1978 and

1980 I participated, along with at least 250 other Scientolgists,

in several massive operations to destroy or hide the evidences of

Mr. Hubbard's control. Scientology spokesmen and witnesses have

claimed that throughout 1980 and 1981 Mr. Hubbard could not be

reached through the organization, or that organization executives

did not know where he was. The fact is, the most senior execu-

tives were in continual communication with him throughout this

period. Scientology spokesmen and witnesses have gone to great

lengths to "prove" that Scientology is a valid religion, while

knowing that it was simply a behavior therapy masquerading as a

"church," and making a mockery of actual honest religious prac-

tices. In 1980, Watchdog Committee, the senior CMO body, respon-

sible only to Mr. Hubbard and senior to every Scientology

organization, ordered that every Sea Org member

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had to complete the Minister's Course in two weeks or they

would be assigned to the RPF. The reason given was to make

every Sea Org member a "minister of the church of Scientology"

and so avoid the US Selective Service draft then pending.

What most Scientologists, and especially Sea Org members,

don't know is that Mr. Hubbard had duped them. My knowledge,

based on documentation and observation, is that the major

reason for Mr. Hubbard's calling Scientology a "religion", in

addition to tax evasion, is to hide behind Constitutional

guarantees for religions and so carry out his scheme of mind

control to keep his followers duped. He has systematically

and knowingly lied to and defrauded his followers, kept them

from finding out the truth or becoming free with cruel and

bizarre treatment, as for example with the RPF, and kept them

economically and mentally suppressed, while he made millions

of dollars from their labor.

    12) I am personally aware that Mr. Hubbard's policy of

Fair Game is still a practice of Scientology. Since I left

the organization with my wife in December 1981, I have been

declared an enemy, and I believe my life and my wife's life,

are in danger.

    Signed under the pains and penalties of perjury this

26th day of July, 1982.

[signed]
GERRY ARMSTRONG

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