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EXHIBIT B

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

PEGGY BEAR,

Plaintiff

v.

CHURCH OF SCIENTOLOYG OF NEW
YORK, CHURCH OF SCIENTOLOGY
MISSION OF EAST MANHATTAN,
CELEBRITY CENTER, INC., CHURCH
OF SCIENTOLOGY OF CALIFORNIA,

Defendants


DONALD BEAR,

Plaintiff

v.

CHURCH OF SCIENTOLOGY OF NEW
YORK, MISSION OF EAST MANHATTAN,. CELEBRITY CENTER, INC., CHURCH
OF CALIFORNIA,

Defendants.


 

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81 Civ. 4688 (MJL)

 

 

 

 

 

 

 

81 Civ. 6864 (MJL)

   

 

EXHIBIT C

ARMSTRONG DECLARATION II

 

1

 

DECLARATION OF GERALD ARMSTRONG

 

I, GERALD ARMSTRONG, being duly sworn, hereby state and

declare as follows:

 

1) In September of 1980, I was staff member of L. Ron Hubbard, Director of the Church

of Scientology of California. My superior was Laurel

Sullivan, and during that time I worked with her on two

projects, an authorized biography of L. Ron Hubbard and the

Mission Coporate Category Sort Out (MCCS). Laurel and I

were involved in MCCS when the project was initiated,

before the Church sought any legal advice and before the

September 1980 meetings occurred, which are described in my

first affidavit.

 

2) The MCCS Mission was initiated from orders we received

from L. Ron Hubbard. Hubbard ordered us to figure out a

way in which his control of the Church of Scientology could

be hidden, yet he would still maintain de facto control.

This was done to hide Hubbard's control of the Church of

Scientology and the numerous benefits he inured from it.

If Hubbard's control was known, he would become involved in

the litigation confronting the Church. His inurement of

Church benefits would also affect litigation with the

Internal Revenue Service which was then being fought

concerning the Church of Scientology's tax exempt status.

2

 

The whole purpose of the MCCS Mission was to defraud the

federal government, litigants against the Church, and the

Courts into believing Hubbard had no involvement with the

Church of Scientology, and therefore was protected from

litigation. The corporate restructuring of the Church was

to be performed to meet this objective. All of the activi-

ties performed by anyone involved in the MCCS Mission,

including the attorneys, were done to achieve this fraudu-

lent end.

 

3) The two meetings which are described in my prior

affidavit were part of a series of meetings, whose purpose

was to obtain the fraudulent and illegal objective of the

MCCS Mission.

 

4) Barbara De Celle was also involved in the MCCS

Mission. She borrowed the tape recorder and the tapes used

to record the meetings described in my prior affidavits

from me. Several months later in the summer or fall of 1981, she

gave me the tapes and told me they belonged to the

biography project. At that time, I was working exclusively

as a research assistant to Omar Garrison, the author hired

to write the biography of Hubbard. De Celle and everyone

else who was on staff knew that any materials that were

given to me for the biography would be turned over to

Garrison. Garrison had no connection with MCCS and was not

even a Scientologist. After Barbara De Celle gave me the

3

 

tapes, I turned them over to Garrison.

 

5) Barbara De Celle voluntarily gave me the tapes of her

own volition. I never asked for them, nor did I

surreptitiously take them from her desk. She gave them to

me one day when I happened to pass by her disk.

 

6) I have described these tapes in other affidavits which

I have signed. One such affidavit was executed in the

summer of 1982 for use in the case of Burden v. Church of

Scientology of California, Middle District of Florida, C.A.

No. 80-501-Civ-T-K. To my knowledge, my description of

those meetings, which is identical to the description

contained in the affidavit I filed in this case is still

part of the public record of the Burden case, and has never

been struck.

 

Signed this 31st day of December, 1984 under the

pains and penalties of perjury.

[notary stamps, handwritten and seal]
Signed in my presence in the Municipality
of Richmond, Province of British
Columbia, Canada this 31st
day of December 1984.

A Notary Public in and for the Province of British Columbia
Non Expiring - lifetime Commission.

NANCY SCHICK
#201 - 6200 #3 RD.
RICHMOND, B.C.
V6Y 2B3
NOTARY PUBLIC
270-8644
[notary seal]

[signed] Gerald Armstrong

GERALD ARMSTRONG

 

 

Image of Signature page

 

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