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    I, Gerald Armstrong, hereby swear under the pains and

penalties of perjury as follows:

    1. I became involved with Scientology in 1969 in

British Columbia, Canada. In Los Angeles, California in 1971, I

joined Scientology's Sea Organization, then the group of the

most "elite" of Scientologists who worked directly for L. Ron

Hubbard. The Sea Org was then promoted as "Ron's personal

org." I remained in the Sea Org until December 1981.

    2. Within a week of joining the Sea org, I was ordered

to the "Apollo" or "Flag," the flagship of the organization,

then in Tangiers, Morocco. I remained on board, except for a

few missions (specific operations or programs given to a group

of individuals sent by the Sea Org Operations Bureau to carry

out) ashore, until September 1975. Throughout 1972 and 1973, I

was the ship's "legal" representative, responsible for dealings

with immigration, the port authorities, customs, police,

shipping agents, and ship and crew documents. In 1974, I held

ship public relations positions and was responsible for

promoting the ship and our activities aboard to the local people

in the ports we visited. In late 1974, I became the ship's

intelligence officer, a position I held until I left the




    3. In the fall of 1975, I transferred from the

"Apollo" to a land base being established in Florida.

Eventually all the crew and students came ashore to Florida,

leaving only a skeleton crew on board to sell the vessel. A

temporary base or staging area was set up in Daytona Beach. I

worked in Daytona Beach in the intelligence bureau in the

Guardian's Office (GO). The GO then contained 4 major bureaux:

Intelligence, Public Relations, Legal and Finance. It was the

semi-autonomous militant branch of Scientology, all powerful in

all organizations. The head of the GO, under L. Ron Hubbard,

was his wife, Mary Sue Hubbard.

    4. At the beginning of December 1975, I was sent on a

mission to set up a communications unit for L. Ron Hubbard in

Dunedin, Florida about six (6) miles from Clearwater where the

permanent Flag Land Base was then being established. I worked

in Hubbard's communications unit in Dunedin until the end of May

1976, when I travelled to Culver City, California to set up

another communications unit for Hubbard.

    5. In Culver City, because I got into an argument with

Mary Sue Hubbard's Communicator (secretary), Hubbard deemed me a

"security risk" and had me removed from the property by the US

head of GO intelligence, Dick Wiegand Hubbard had me locked up

and guarded for three (3) weeks in the Scientology intelligence



office in Los Angeles. At the end of that time, he ordered me

and my wife, Terri, back to Florida, to the Clearwater base.

    6. In Clearwater, a telex from Hubbard awaited Terri

and me ordering us into the Rehabilitation Project Force (RPF),

a virtual prison Hubbard had created for any Sea org members

whom he considered were in violation of or "counter-intention"

(CI) to his orders or policies. I spent from July 1, 1976

through December 1, 1977 in the RPF, a total of 17 months.

During about a year of my sentence, I was, within the RPF, in

charge of it, including all but the last few days the plaintiff,

Tonja Burden, spent in the RPF.

    7. Shortly after "graduating" from the RPF, I

transferred with Terri to the Commodore's Messenger Organization

(CMO) unit in Los Angeles. The CMO, in which I was never

formally posted, was the Sea Org Unit, comprised mainly of girls

and young women who ran messages for the Commodore, L. Ron

Hubbard. They were his agents, and their orders had to be

obeyed as if they were his. In Los Angeles, I was ordered to

retrieve Ms. Burden, from her parents' home in Las Vegas after

she escaped from the RPF in Clearwater in mid-December 1977.

    8. At the end of December, Terri and I transferred to

Hubbard's secret base in La Quinta, California. Hubbard, who

had been in hiding in Sparks, Nevada, following and as a result


of the FBI raid on Scientology's intelligence offices in July

1977, arrived back at the La Quinta property at the same time.

It had been determined that Hubbard would not be indicted in the

Federal criminal case the Government brought against the GO

hierarchy for burglaries, theft, and obstruction of justice, and

it was therefore safe for him to return to La Quinta, although

he still took various security precautions even there. Mary Sue

Hubbard, the Controller and head of the GO, and, under Hubbard,

in charge of all of Scientology internationally, had been

indicted in the Federal criminal case, and she left the La

Quinta property within a day or two of his return.

    9. At La Quinta, I was primarily involved in film

production. Hubbard had written some scripts for Scientology

"training" or promotional films and the La Quinta crew, which

grew from around 80 to over 150 in 1978, formed the production

crew and actors pool. Hubbard ran every aspect of the

film-making and personally directed the actors and technical

crew on the set. I worked in sets, lighting, the camera unit,

was the location scout, and for a brief time, until Hubbard

busted me, was in charge of the whole shoot crew as the cine

crew chief. I also was, throughout the first few months of

1978, a night guard every second night outside Hubbard's house

on the property.

    10. Around September 1978, Hubbard again assigned me



to the RPF, this time in a unit which he had established on the

La Quinta properties. This assignment was because Hubbard

thought I had joked about training drills he had ordered for the

shoot crew on this occasion, I spent 8 more months in the RPF

until I was able to get reprieved. The La Quinta RPF mainly

worked on renovations and improvements to Hubbard's home:

tiling his floors, painting, cleaning and reinsulating the

ducting, carpeting, and brickwork for his walkways.

    11. Because of his fear that the cover or "shore

story" for the La Quinta property was going to be blown (" shore

stories" will be dealt with later in this affidavit), Hubbard

ordered in the fall of 1978, the purchase of another property, a

550 acre golf course and motel complex at Gilman Hotsprings near

Hemet, California. The RPF transferred at the beginning of

December to Gilman and began the renovations and decoration of a

home and offices for Hubbard on the property. After reprieval

from the RPF in the spring of 1979, I continued to work on the

renovations project, and by the summer I became the LRH

Renovations In-Charge and the head of Hubbard's Household Unit

at Gilman. Under me organizationally were Hubbard's steward,

carpenter, groundsman, a electrician and the LRH Gear In-charge

who was responsible for his personal belongings stored on the

Gilman property.

12. Although we completed the renovation of his home



and offices according to his instructions, and although he many

times indicated his intention to reside there, Hubbard never, to

my knowledge, slept on the property. He came there several

times in 1979 under very tight security which, while he was at

Gilman, I was responsible for. He came to supervise

photographic promotional work a number of times, and he came

several times to meet with Mary Sue Hubbard at their house.

They arrived separately at an appointed time from different

locations, and left separately after their meetings. Throughout

1979 Hubbard lived in an apartment complex in Hemet with 10 or

so Sea Org staff. This location was kept secret even from the

majority of personnel at Gilman. and those of Ls who did know

referred to it only as "x."

    13. At the beginning of 1980, a possible raid by the

FBI or other law enforcement agency was announced by the CMO at

Gilman. In anticipation of this raid, which never occurred,

everyone on the property was ordered to destroy anything which

showed that Hubbard controlled Scientology, that he controlled

bank accounts, that he had been ordering staff at Gilman

anywhere to do anything, that he had even been to Gilman, that

he intended to reside at; Gilman, and anything which showed him

in a bad light. Each person was required to go through every

paper in his area and destroy any evidence of these facts. A

commercial shredder was rented and operated day and night for

two weeks. Hundreds of thousands of pages were destroyed; the


(shredded paper taken off the property in large trucks.

    14. In the middle of this shredding operation, my

junior, the LRH Gear I/C came to me with a box of papers from

Hubbard's storage and asked if they should be shredded. I

looked through them and found they were very old letters,

diaries and other papers predating 1950 when Hubbard had begun

to build the Dianetics and Scientology organizations. I

determined these papers should have no evidentiary value to any

law enforcement agency who might raid the property, but had

historical value, so I moved them to Hubbard's Personal Public

Relations Bureau, then headed by his PRO Laurel Sullivan. I

then went into Hubbard's storage and found several more boxes of

similar materials.

    15. Having worked in PR and Intelligence on the ship

and been on Hubbard's personal staff for some time, I was aware

of many of the disparaging claims the press and other " enemies"

of Hubbard were making about his past, and I felt that with

these newly found papers, which even Hubbard's Personal PRO did

not know existed, we could document the truth about him for the

first time and put an end to the attacks on him, which he

continuously stated, were lies. I therefore, sent a petition (Exhibit [A]) to

Hubbard to gather up all his papers, create an archive, and

provide the documentation to a writer to do a major,

authoritative biography about his life which would prove through



solid documentation that his critics were lying. He approved

the petition and I transferred to his Personal PRO Bureau and

began assembling biographical materials from the Gilman storage,

and eventually, from many other sources. A copy of his approval

is attached hereto as Exhibit [B].

    16. I wrote to Hubbard about the materials I had

discovered and the biography project a few more times in the

first two months of 1980. One of his replies to me, in this

case to my delineation of what I was doing and a request from

him of what he personally needed and wanted from me, is attached

as Exhibit [C]. Shortly after this, because of his fear that he

would be served with a summons or subpoena in any of the

lawsuits then being brought by former Scientologists who felt

they had been damaged by the organization, Hubbard left "x," and

went into deeper hiding with two of his messengers, Pat and Anne

Broeker. One of these former Scientologists known at that time

to be speaking out against Hubbard's practices and organization

conditions was Tonja Burden. I knew about these legal matters

because in February of 1980 I was ordered along with Laurel

Sullivan, onto a mission, entitled Mission Corporate Category

Sortout (MCCS), the purpose of which was to work out a corporate

strategy to let Hubbard continue to control the various

Scientology organizations, but shield him from legal




    17. Because of attempts to serve Hubbard in several

lawsuits, I was instructed by Laurel Sullivan that we could not

admit that communications could be gotten to him from the

Scientology organizations. I knew this was not true and that he

was in continual communication with the organization via David

Miscavige, one of his messengers. I received a message myself

some months after Hubbard "disappeared," to send him a copy of

one of his manuscripts that I had found, and I was able to send

it from Laurel to Miscavige to Hubbard. I also knew that Pat

Broeker, who was with Hubbard, could be contacted and arrive in

the Los Angeles area in a matter of three hours. Nevertheless,

because the communication line to Hubbard could not be

acknowledged, I did not report to him again about the biography

project. I did report to Mary Sue Hubbard a number of times

throughout 1980 and 1981 and received from her replies to my

reports. One of her replies is attached hereto as Exhibit [D]. I

also obtained a letter of introduction, a copy of which is

attached hereto as Exhibit [E], from Hubbard's Personal Secretary,

Pat Brice to assist me in conducting interviews of Hubbard's


    18. Throughout 1980 and 1981, I assembled an archives

of something like 500,000 pages of documentation about the life,

writings, and accomplishments of L. Ron Hubbard. A chart

showing some of the sources of this Biography Archives is

attached as Exhibit [F]. In October 1980, Hubbard using a Danish



publishing company, actually run by the Guardian's Office under

him, contracted with a non-Scientology author, Omar V. Garrison,

to write his biography. Pursuant to this contract, I provided

Garrison with approximately 100,000 pages of biographical

research materials and assisted him with arranging interviews

with Hubbard's family members and early friends or associates,

getting him needed supplies, and answering his many questions as


    19. Through the course of my research from many

documentary sources I was able to determine the facts behind

most of the significant representations that Hubbard made about

himself, or which he had ordered his public relations staff, the

GO, recruiters, and sales personnel make about him. Attached

as Exhibits [G], [H], and [I] are biographical materials written by

Hubbard and published and disseminated by Scientology

organizations. They were used for public relations, recruitment

or sales purposes. I was myself brought into Scientology and

the Sea Organization, and kept in the Sea Org for almost eleven

years, by the representations made in these materials and others

like them.

    20. Exhibit [G], entitled "L. Ron Hubbard," was

published widely in Scientology magazines, and books from the

late 1960's throughout the 70's. It contains several claims

about Hubbard which deeply impressed me when I was being brought



into Scientology.

A. That he was in China when he was fourteen,

spent the next several years in travel throughout

Asia, and studied with lama priests in China and India;

B. That he graduated in mathematics and

engineering at George Washington University; and

then became a member of the first US course in

nuclear physics;

C. That he was crippled and blind at the end of

the war and fully cured himself with his


D. That it was a matter of medical record that he

had twice been pronounced dead.

    21. Exhibit [H] entitled " A Brief Biography of L. Ron

Hubbard" was widely circulated in the 1960's and 1970's. It

contains many of the representations which influenced me to

become involved in Scientology and to work for Hubbard; some

were the same or similar to those in Exhibit G.

A. That he earned a bachelor of science degree

from George Washington University in civil


B. That he spent several years in travel



throughout Asia from the age of fourteen, and

studied with lama priests in China and India;

C. That he attended the Princeton School of

Government, and obtained a Ph.D. from Sequoia


D. That he excelled in his subjects at university;

E. That he was the character, and had the

adventures of "Mr. Roberts," after whom the movie

was made;

F. That Scientology is an organized body of

scientific research knowledge about life and the


G. That Dianetics and Scientology can raise IQ

about one point per hour of processing (auditing).

Also that skill and efficiency can be raised. The

raises can be tested by very severe regimens and

can be found to be stable.

    22. Exhibit [I], is a policy written by Hubbard entitled

"PE Handout." PE or Personal Efficiency Course is an

introductory course to get people into Scientology. The policy

contains an article entitled "What is Scientology?" which per

the policy was to be reprinted separately and was required to be

given to new people brought in. The policy was reprinted

republished and copyrighted into the 1980's. I used this

material myself when trying to sell people Scientology in 1970.



It contains numerous representations about Hubbard and

Scientology which sold me on the man and the subject.

A. That Hubbard was a civil engineer (CE);

B. That he was a doctor of philosophy (Ph.D.);

C. That he was a nuclear physicist;

D. That he was educated in advanced physics and

higher mathematics;

E. That he was a student of Sigmund Freud;

F. That Scientology was the first major and

complete breakthrough by the exact sciences into

the field of the humanities;

G. That Scientology is the only successfully

validated psychotherapy in the world;

H. That it is a precision science;

I. That its results are easily demonstrated claims

that can be duplicated by competent practitioners

at will;

J. That it is the first science to prove that IQ

and intelligence can be improved and are not

inherent in a person;

K. That it is the first mental science to subject

itself to the most severe validation tests;

L. That is it the first science to make whole

classes of backward children averagely bright;

M. That it is the first science to determine the



basic cause of disease.

    23. Hubbard promoted himself in much the same way

outside of Scientology. Attached hereto as Exhibit [J] is a copy

of Hubbard's autobiographical submission in 1967 to "Who's Who

in California." Again, he claims to have a bachelor of science

degree in civil engineering from George Washington University in

1934, a doctor of philosophy degree from Sequoia University; and

to have served in five theatres in World War II, commanded

escort vessels from 1941 to 1946, and been awarded 21 medals and

palms. (Palms are small representations of a palm leaf added to

a military decoration awarded a second time.)

    24. My research throughout 1980 and 1981, however,

revealed a very different, and to me shocking picture of

Hubbard, his past, credentials, accomplishments and Scientology.

A. He had not graduated in mathematics, nor was he

educated in higher mathematics;

B. He was not educated in advanced physics;

C. He did not obtain a bachelor or science degree;

D. He was not a civil engineer;

E. He was not a nuclear physicist;

F. He was not a member of the first US course in

nuclear physics;

G. He did not excel in his subjects at university;



H. He attended George Washington University two

years, 1931 and 1932. He was placed on probation

after the first year, and in the second year his

grades deteriorated. He failed both his

mathematics courses his first year and got D's when

he repeated them the second year. The one course

he took in molecular and atomic physics he failed.

He did not return to George Washington University

thereafter. (A copy of his academic transcript,

which I had in the biography archives, is attached

hereto as Exhibit [K]);

I. Hubbard did not pursue post-graduate studies at


J. During the war, he attended a less than four

month course in military government which was given

by the Navy on the Princeton campus.

K. His Ph.D. was from a "diploma mill" and was

arranged for him, on his insistence, by early


L. He was never a student of Sigmund Freud (unless

reading something written by Freud made him a

"student," in which case most of the literate world

is to some degree).

    25. I had diaries Hubbard kept of his time spent in

Asia and correspondence between him and his parents and



associates from the period, and was able to determine fairly

accurately the truth behind his claims about this period.

A. He was not in China at fourteen and did not

spend several years travelling throughout Asia;

B. He did not study with lama priests;

C. He was never in India;

D. He attended school in the United States during

the years from 14 through 18;

E. Hubbard's father, who was a naval officer, was

stationed on Guam, and Hubbard travelled twice by

ship to Guam to the US and back, one in 1927 and

once in 1928. On those trips the ships stopped

briefly at various Asiatic ports in Japan, China,

Hong Kong and the Philippines. The only time

Hubbard travelled into the interior of China was on

a tour sponsored by the YMCA given to children of

US service personnel stationed in the Pacific. His

total time in Asia was a few weeks.

    26. I amassed approximately two thousand pages of

documentation concerning Hubbard's wartime career: what he was

doing, what vessels he was on, fitness reports and medical and

VA disability records. The truth is far different from the

public representations.



A. He was not crippled nor blinded during the war;

B. He did not cure himself with his discoveries;

C. He was not "Mr. Roberts";

D. He did not command escort vessels from 1941 to


E. He was not awarded 21 medals and palms;

F. At the beginning of World War II, Hubbard was

assigned to Naval Intelligence in Australia. He

was there briefly until ordered back to the U.S. as

unsatisfactory for the duty, and after his return

was transferred out of Intelligence. He had

command of two vessels: the first for a month

during refit; the second for two and a half months

during outfitting and shakedown. He was removed

from command of the first for exceeding orders, and

from command of the second when he fired the ships'

guns in Mexican waters causing an international

incident. In a diary he kept through part of the

war he revealed that he had had his men lie for him

in the Naval Board of Investigation convened to

investigate the incident. He claimed to have sunk

two Japanese submarines during the shakedown cruise

during his second command, but the Commander of the

Northwest Sea Frontier, Admiral Fletcher stated in

a report, attached hereto as Exhibit [L], that "an

analysis of all reports convinces me that there was


no submarine in the area." Hubbard spent the last

few months of the war in a naval hospital with a

duodenal ulcer. He was awarded four standard

medals for his wartime service. A copy of a letter

from the Department of the Navy listing his naval

assignments and medals is attached as Exhibit [M].

At war's end he was awarded a ten percent

disability for the ulcer. In 1946, he appealed the

disability award, claiming in addition to ulcers to

have "conjunctivitis" or inflammation of the eyes,

and an infection in the hip joint contracted as a

result of his transition from the tropics to the

eastern winter cold. In October 1947 he wrote to

the Veteran's Administration asking for psychiatric

treatment stating "I cannot account for no rise

above long periods of moroseness and suicidal

inclinations." In December 1947 at a VA

examination he claimed injuries from 1942 from

falling off a ladder. In 1948 he was able to get

his disability award increased to forty percent for

the duodenal ulcer, infection of the eyes, bursitis

of the right shoulder and arthritis of multiple

joints. In a handwritten document from this

period, Hubbard reveals the truth behind his

disability claims. He stated: "Your stomach

trouble you used as an excuse to keep the navy from



punishing you ....Your hip is a pose ....Your foot

was an alibi ....When you tell people you are ill,

it has no effect upon your health. And in the

Veterans' Administration examination you'll tell

them how sick you are; you'll look sick when you

take it; you'll return to health one hour after the

examination and laugh at them. No matter what lies

you may tell others, they have no physical effect

on you of any kind." The transcript where this was

read into the record in the case of Church of

Scientology of California v. Armstrong, in Los

Angeles, California is attached hereto as Exhibit

[N]. In July and August 1951 Hubbard attended

another set of VA medical examinations and

complained of the same conditions for which he was

receiving a disability pension (and which he would

claim in his Dianetics and Scientology promotional

literature he had already cured himself of).

Attached hereto as Exhibit [O] are copies of

Hubbard's physical examination results, VA reports,

and related documents from the period 1941 to

1951. Attached as Exhibit [P] is a letter from the

VA stating Hubbard was still receiving the 40%

disability compensation in 1973. Exhibit [Q],

correspondence between various individuals in the

GO, including Mary Sue Hubbard, show that the



organization and Mrs. Hubbard possessed L. Ron

Hubbard's naval documents at least by 1976.

    27. As the wide gap between Hubbard's claims about

himself and the reality evidenced by the documentation I had

assembled became manifest, I attempted to get the public

relations and promotion executives on his staff or in

organization positions to change the biographical materials

being published and disseminated about the man. I critiqued a

number of these biographical sketches, about-the-author sections

of books, and promotional pieces, pointing out what I knew to be

false, misleading, unverifiable or hyperbole. One of these

"critiques" written to Barbara DeCelle, then the person in

charge of republication of Hubbard's works to make more income

for him, is attached hereto as Exhibit [R]. One of the reasons I

had gotten into Scientology had been the promise of truth,

honesty, and a higher level of ethics, and I considered, when

the falsehoods became obvious to me, that we, organizationally,

had to correct them and strip them from the literature.

    28. In November 1981, when word of my attempts to

correct Hubbard's misrepresentations reached the little group of

messengers then running the organization for him and attempting

to extricate him from all his legal problems, one of them,

Norman Starkey, ordered in response that I be sec checked. By

this time I also knew the truth about sec checking, or security



checking: that it is a brutally accusative interrogation in

which the E-Meter, the electrometer used in Scientology auditing

or therapy, is employed as a lie detector. The grilling can go

on for hours. The purposes are to intimidate and break the

subject, and get from him details later usable by intelligence

or security personnel against him. It has nothing to do with

therapy or helping anyone. A few days after learning of

Starkey's order that I be sec checked, I decided to leave the

organization. Before that, I sent a report, a copy of which is

attached hereto as Exhibit [S], to Cirrus Slevin in the CMO, the

person to whom Starkey's report about me had gone. In my

report, I again pointed out a number of falsehoods Hubbard had

written about himself, and indicated why I had been seeking to

have them corrected. By December 1981, I knew that Hubbard

would never allow the lies to be expunged from his writings and

could never himself face the truth, and on December 12, along

with my wife, Jocelyn, I left.

    29. Toward the end of my time in the Sea Org, because

of my study of the archives materails, I began to perceive that

I had been drawn into Scientology and the Sea Org and kept there

by a web of lies, by Machiavellian mental control techniques

and by a terrible fear generated by Hubbard and his

organization. After I left and was able to distance myself

somewhat from the oppressive environment of the Sea Org, and to

integrate to some degree, albeit with great difficulty, back



into society, the picture of what the organization actually was

and did and had done to me, became clearer and clearer. That I

had been defrauded out of money and twelve and a half years of

my life, and that I had been abused and my civil rights trampled

was obvious. I was broke, broken and confused; nevertheless, I

did not wish to attack Hubbard or the organization. I was

willing to live and let live. Only when it became clear that I

would not be allowed to get on with my life, when I became,

right after leaving, a target of organization intelligence

operations, and a Black Propaganda campaign to destroy my

reputation, and when Hubbard's agents stole a set of valuable

photographs from me, did I take a stand against the abusive and

criminal practices of his organzation. I had become "Fair

Game," meaning according to Hubbard's policy by the same name,

that I could "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." Scientology has

claimed that the policy had been cancelled, but I knew from

first hand knowledge that it had not. And what I had done to

have this brutal policy inflicted upon me was to do my research

work too well, to learn too much, and to try to make known what

I had found to improve organization conditions.

    30. An important aspect of Sea org life, and a factor

in controlling personnel and keeping them inside and cut off

from the outside is the use of "shore stories," the name Hubbard



gave to cover stories or guises. Before I was sent to the

"Apollo" from Los Angeles at the beginning of 1971, I was

briefed and drilled on the shore story I was to use enroute. I

was to be an employee of Operation and Transport Corporation,

Limited (OTC), a buisness management company. I could not use

any Scientology words on the trip and was to deny being a

Scientologist. On the "Apollo" I was given a pack of materials

about the ship and OTC to study and was examined and drilled on

these materials, and had to be able to field questions thrown at

me by the Port Captin, the officer responsible for getting the

shore story believed by the local people, before I was allowed

to go ashore. I to deny any connection between OTC and

Scientology. I had to feign ignorance of L. Ron Hubbard's

position on board or his control of the operation, and if

possible even that he was aboard. I was not to divulge what my

pay was if asked but was to offer an evasive answer like "the

pay is really good." If asked about religion I was to think

back to the religion I had been raised in and answer something

about that.

31. When I became the ship's "legal" representative,

then Port Captain, and finally intelligence officer, I

personally briefed and drilled hundreds of people on the OTC

story and other shore stories. Foreign personnel being sent

into the U.S. on a mission I briefed and drilled on a cover to

explain the various stamps in the passports, then sent them to a



consulate or embassy in a country the ship didn't visit to

obtain a "visitor's visa." This was in flagrant violation of

immigration laws because the people were in fact going to the

U.S. to work, and their statements about what they had been

doing up to then were false.

    32. Another shore story was projected to get around

maritime regulations. The ship could not pass the requirements

set by the International Convention for Safety of Life at Sea

(SOLAS) for passenger vessels, so Hubbard labelled her a

"yacht." By law, however, a yacht could have only a small

maximum number of passengers; that is, people paying for their

passage and not actually performing crew functions, and we had

several times the allowable limit. People coming to the ship

for courses or auditing paid to be on board and were not crew.

To circumvent passenger vessel regulations, however, we had

these people sign the ship's articles as crew, and they were

given ship positions on the crew list and issued fake seamens'

books. The maritime authorities in several ports questioned the

ship's status and our non-compliance with SOLAS requirements and

these authorities were "handled" with the "yacht" story and

bogus inspections we had done to make it look like we exceeded

safety requirements by having a ''SOLAS inspection" done although

not required to. The fact was the ship was grossly overcrowded

with nowhere near enought lifeboat capacity for the complement,

which from 1971 through 1975 averaged over 400 people, and most



of the lifeboats themselves were unseaworthy. She was overladen

with her Plimsoll or load line completely under water. She was

not insured, and in fact, because of her condition, could not be

insured. But all of these facts were hidden from the

authorities and crew and passengers alike.

    33. Even to our families and friends back home, and

between ourselves there were shore stories. As soon as I came

on board I was briefed that the ship's location, any of the

activities and conditions on board, and any difficulties I might

be having could not be revealed in any letters. Mail was left

unsealed and was read by the Master-at-Arms (MAA) or ethics

officer, the person responsible for discipline and punishment,

before it was sent off the ship to later be posted from

Denmark. If anyone left the ship for any reason, to go on a

mission or on leave, his baggage was first inspected by the MAA,

or any the gangway guard or quartermaster (QM) and anything

which would reveal the ship's location, like clothing labels,

cigarettes or toiletries from the countries we visited was


    34. There was constant attention to " security" on

board, not physical safety, but the "enemy" finding out what we

were up to. Any breach of security was dealt with in the

harshest way. Every person on board was urged to report anyone

else who violated security rules, or any other rule for that



matter. Scientology words could not be used ashore, nor could

Scientology literature be visible to local people at any time.

If local people ever came on board, or inspections done for any

reason, a "clean ship drill" was called and all crew knew to

hide any Scientology materials from view. Paper trash was never

thrown out in the garbage, but saved until it could be dumped at

sea when the ship sailed between ports. No one was allowed off

the ship without permission, and there was always a "restricted

list" of persons specifically not allowed ashore kept by the

gangway QM. Anyone who was considered a security risk, who

wanted to leave the Sea org, or who for any reason was assigned

a "lower condition," or "ethics penalty," which at any time

could be dozens of crew or students, was restricted to the

ship. If a gangway QM allowed ashore anyone without permission,

particularly anyone on the "restricted list," the QM would be

assigned a lower condition for breach of security. By Hubbard's

policy, security violation was assigned "treason," one of the

lowest conditions, which carried with it other punishment

including loss of "pay," and twenty-five or more hours of

"amends," work to be done in addition to the work of one's own


    35. Although people who resisted Hubbard's policies,

or who became seriously ill and unable to work, or who were

labelled "deadwood" were from time to time offloaded, meaning

they were kicked off the ship or out of the Sea Org, when people



asked to leave they were not allowed to. They were assigned a

"lower condition," usually "doubt," and subjected to lengthy sec

checks. Usually they were guarded and sometimes locked up.

Anyone who announced he wanted to leave was considered

"psychotic" and treated as such. He was labelled a " suppressive

person," meaning in Hubbard's "mental technology" that he was

one of the 2 1/2 % most evil people in the world and " destructively

antisocial." Although people finally did leave the ship if they

persisted in their demand to go, it was only after they had been

thoroughly sec checked, signed waivers, bonds, releases, lists

of their "crimes" excerpted from their auditing files, and

promissory notes for all the auditing and courses they had taken

while in the Sea Org. From time to time individuals being held

on board would "blow," meaning escape, and jump ship and attempt

to get away. Usually they were brought back before they could

complete their getaway. Everyone's passport was kept locked up

on board by the ship's representative so it was extremely

difficult for anyone who did manage to get off the ship to get

back home as he would have no travel documents. Such people, if

desperate enough, would make their way to a consulate and attempt

to have a new passport issued. Knowing this we staked out the

consulate the person was likely to go to and were usually able

to retrieve them before they approached any consulate

officials. I was involved in numerous such recoverings of

"blown" crew or students. If the person got to the consulate

and told his story it was considered a serious "shore flap" or



danger to security, as the facts that he had been held against

his will and refused his own passport would emerge. In that

event, we would carry out a "dead agent caper" against the

"blown" person. The "dead agent caper" meant to

"counter-document" anything derrogatory someone (it originally

applied to enemy "agents") was saying about you so that the

person is not believed and as an "agent," is "dead." The person

who went to the consulate would be "dead agented" or " DAed" with

a story that he had stolen money or been a troublemaker or

similar so that his story about conditions on board would not be

believed. There were a number of such occurrences while I was

on the Apollo working in the Port Captain's office.

    36. The idea that there were enemies of Scientology,

that these enemies were "suppressives" who sought to destroy

anything which helped mankind, and that these enemies dealt in

lies about Hubbard and Scientology which had to be "dead

agented" was something which permeated all of Scientology but

was, at Flag, at the top of the Sea Org, a constant awareness.

Hubbard wrote continually about "the enemy," the " war" we were

fighting, the need for vigilance, dedication and sacrifice.

Psychiatrists, psychologists, doctors, international bankers,

intelligence agencies, Internal Revenue Service, the press,

government, consular officials and later even scientists: these

were the "enemy." These were "suppressive persons." He wrote

that they drugged and hypnotized people and sent them into



organzations to then pretend to go insane with Scientology

treatment or that they were sent in to spy on our activities.

We were continually warned to be aware of infiltrators or

"plants," and from time to time "plant checks," special sec

checks to locate plants were done on staff. This group

of "enemies" Hubbard stated were the "merchants of chaos, "

profiting from the illness and insanity they created. The

"enemy" was a multibillion dollar conspiracy , and we, with the

only workable mental technology on the planet, were the last

hope mankind had. This "enemy" and the threat to everyone was

what we all were told necessitated the tight security and the

severe discipline, and was in part why I at least tolerated the

miserable conditions. Through time, however, Hubbard's

perceived "enemies" more and more became people close to him,

staff members, people who had been completely dedicated to him

for years. Purges occurred and these dedicated people were

themselves labelled "suppressive."

    37. Out of his fear of the "enemy," Hubbard created in

1966 the Guardian's Office (GO), and headed it with his wife,

Mary Sue. Three years later, after the creation of the Sea Org,

Mary Sue became the Controller, and Jane Kember became the

Guardian under her. The operational headquarters of the GO was

"Worldwide" (GOWW) located at Hubbard's former home in East

Grinstead, Sussex, England. Under WW was the "United States

Guardian's Office (USGO), responsible for GO activities in the



Unitied States. Each Scientology organization had attached to

it a local GO, which reported to the "continental" GO, which

reported to GOWW, which in turn reported to the Controller and

finally Hubbard. The GO was semi-autonomous in that it did not

follow normal organzation lines and operated on its own secret

policies called Guardian Orders, Guardian Program Orders,

Guardian Finance Orders and other GO internal issue types. The

GO was all-powerful in every organzation except where its

activities would counter Hubbard's explicit orders. He operated

the GO via his wife, much as he operated the Sea org via his

messengers and personal aides. Within the GO were four main

bureaux: intelligence, public relations, legal and finance.

The most powerful of these was intelligence, and it was

intelligence which waged a secret and vicious war on the


    38. GO intelligence, also known as "B-1" as it was

Bureau One in the GO organization structure, contained two

branches: Branch 1 was external, Branch 2 was internal

security. Hubbard patterned B-1 after the system developed by

Reinhard Gehlen, the World War II Nazi spy master. When I was

the intelligence officer in the Port Captain's office on board

the Apollo in 1974 and 1975, I was for most purposes directly

junior, to Brian Roubinek, the Assistant Guardian for

Intelligence (AGI) in the Flag GO. Roubinek brought on board

with him the "Information Full Hat," the GO intelligence



training manual for B-1 personnel, and gave it to the Port

Captain's office for our training. Attached hereto as Exhibit [T]

is a copy of the manual's "checksheet," which lists the policies

to be studied and drills to be done as individual steps in the

training. The use of "Information" for " Intelligence" is itself

a shore story to cover what the intent and practices of B-1

actually were. The Policy Letter "Intelligence and Security"

attached hereto as Exhibit [U] shows that " information" is

"intelligence." The types of operations carried out by B-1

against Hubbard's perceived enemies and what I was instructed in

by the AGI Flag, are shown by the report on "Successful and

Unsuccessful Actions," attached hereto as Exhibit [V], and also

appearing on P. 6 of the manual, written by the Deputy Guardian

for Intelligence at WW, Mo Budlong, to the Guardian, Jane

Kember. Budlong was the head of the B-1 network under Kember.

The report lists among the successful actions: using 2D on

someone high in the government to seduce them over to our side

(2D means sex); infiltrating an enemy group; covert third

partying (meaning starting conflicts between individuals or

groups with rumors, the source of which remains hidden);

forgeries; direct theft of documents.

    39. In addition to being the Controller, over top of

the Guardian's Office, Mary Sue Hubbard was also referred to as

Commodore's Staff Guardian (CSG) and had yet another official

position, Deputy Commodore. As CSG, she was part of the


Commodore's Staff Aides, a group of approximately 10 executives

who were the Commodore's, Hubbard's, personal staff, and were

the senior management body under Hubbard in all Scientology. As

CSG, Mrs. Hubbard also had the responsibility of coordinating GO

and Sea Org actions. Any correspondence from anyone on the ship

into the GO network, except directly to the Flag GO once it

became established on board, had to be sent via Mrs. Hubbard by

her order. As Deputy Commondore by policy she replaced Hubbard

as head of the Sea Org whenever he was absent. At all times,

however, up until her removal as Controller in 1981 due to her

conviction and sentencing in the Federal criminal case brought

against the hierarchy of the GO for burglarizing Federal

agencies, theft and obstruction of justice, she was the second

in command of all Scientology organizations, answerable only to

L. Ron Hubbard.

    40. There was not one activity in the Sea Org, or in

Scientology organizations everywhere which Hubbard did not

control. That is not to say that he cooked the meals or

personally decided where each person slept, but could at any

time he wished do these things, and these things and every

detail of Sea Org life were done or established pursuant to his

policies and orders. His control on board the "Apollo," and in

the land bases he moved to after 1975 was effectuated on a

direct, immediate and verbal basis via his messengers, the CMO.

They ran between Hubbard and all other crew and students,



relaying his verbal orders and reporting back to him the

recipients' answer or compliance. The CMO also took care of

many of Hubbard's personal needs and desires, but their primary

duty was running his verbal orders and getting compliance to

them. The messengers acted as if they were Hubbard; they were

trained to deliver his verbal messages exactly as he stated

them, including with the identical intonation and emotion.

Their orders could not be disobeyed. Non-compliance with any

order was punished with at least a lower condition of

"liability" with ten hours or more of "amends" work and no

liberties. To get out of the condition of "liability" required

petitioning each crew member individually and obtaining a

majority approval. Usually, non-compliance with an LRH order

was dealt with far more severely than this, and intentional

non-compliance was almost unheard of. It was the duty of anyone

receiving a verbal order from Hubbard, directly or via a

messenger, to report the order in writing to the LRH Personal

Communicator (LRH Pers Comm) who would record it in the log of

Hubbard's orders he maintained and for which he also had a duty

to enforce compliance. Written orders from Hubbard to anyone

went via the LRH Pers Comm, not the messengers, at least until

1976 and in some matters thereafter, and these too were logged

for compliance. The CMO maintained a separate "Messenger Log"

which contained all Hubbard's orders handled by the messengers,

as well as a record of when Hubbard worked, slept, ate, what

activities he was involved in at any time, and what messengers



were on which watch. There were four six-hour messenger watches

daily, and usually three messengers on each watch. They

remained with Hubbard or within yelling range at all times,

including waiting outside his quarters throughout the night as

he slept until he called them when he waked.

    41. His control of the various land based Scientology

organizations and personnel was effectuated through the two

major organizational arms: The GO and the Sea Org. The GO,

which Hubbard controlled through Mary Sue Hubbard, both by his

policies which governed its structure, planning and programming,

and by his orders directing specific actions or operations,

dealt with external matters, those areas or problems which

potentially could prevent the non-GO Scientology service

organizations from doing their jobs, which was selling auditing

and courses and making money. The public groups the GO was

responsible for included the press, government, legal and

"opposition groups." The GO, by its mandate from Hubbard,

called the "LRH Heavy Hussars Hat," could, however, move into

and take over any part or function in any organization on a

by-pass of the Sea Org executives normally in charge. The GO

executed tremendous control throughout all of Scientology and

was, until around 1981 the most powerful of Hubbard's two main

control lines.

    42. He effectuated control of the normal service



organzation functions; that is, advertisitng, sales, auditing,

courses and income-generating actions, through an elaborate

heirarchical management system. Directly below Hubbard and

forming part of his personal staff were the Commodore's staff

Aides, one assigned to each of the seven standard divisions in

all Scientology service organizations. The CS Aides, including

Mary Sue Hubbard as CSG, formed collectively the Aides Council

which had a strategy coordination function under Hubbard.

Beneath the CS Aides, and utilized by them and Hubbard in the

management of all service organizations were the Flag Bureaux

(FB). The FB originated and operated programs for each service

org internationally. A program is a series of steps or targets,

orders to be carried out by individuals named in the program as

responsible for each target. The FB also briefed, fired and

operated missions; that is, small groups of personnel sent on

mission orders, which, like programs contained a series of

targets, to perform a specific task and return to base. Another

FB Unit was the External Communications Bureau which sent and

received all telexes and written correspondence for the

flagship, and all Scientology management. Telexes, which were

always coded, and mail were sent and received daily. Beneath

the FB organizationally during the 1970's were the Flag

Operations Liaison Offices FOLO's)' one in each of the

geographical areas in which there were Scientology service

orgs. The FOLO's were manned by crew considered Flag staff, and

had the responsibility, as the link between the FB and service



orgs, to relay communications and get Flag's programs executed.

    43. Another channel by which Hubbard directly

controlled Scientology orgs and activities was the LRH

Communication (LRH Comm) network. An LRH Comm was posted in

every organization or franchise internationally and were headed

by the Flag LRH Comm (CS-7). The LRH Comm network was, similar

to the GO, an "autonomous network," and the LRH Comm in any

organization was not under the local organization executive

director, but subject only to the orders of his network

seniors. Every LRH Comm had as his duties to get compliance

with Hubbard's orders, enforce Hubbard's policy letters, and to

take whatever actions were necessary to carry out Hubbard's

intention for the organization.

    44. Hubbard had complete control of Scientology

finances, both through his policies and directly.Anything he

ordered be bought would be immediately on the basis of his "LRH

order." He was the only person in the organization with that

power. Anyone else needing to purchase anything to do his job

had to get a purchase order approved in a budget by the

Financial Planning (FP) Committee. The budget then had to be

approved by the Treasury and Finance Bureau executives, and

finally by Hubbard, if he chose to. Even on the flagship which

was collecting money from all service organizations

internationally and was holding millions in Sea Org reserve



funds, Hubbard would at times initiate an austerity campaign and

reduce allocation of many budget items. There were times the

ship ran out of toilet paper, and other times when the

Clearwater Flag Land Base (FLB) was set up he ordered that

everyone eat only rice and beans. There were many times on the

"Apollo" when just to be able to do my job I paid for my own

transportation and bought customary gifts for officials in the

ports out of my own pocket, even though I was being paid only

ten dollars per week, because I could not get approval for these

necessities in the FP budgets. Hubbard set crew "wages" and had

wages docked if he considered someone was not performing well on

post. While most crew were kept impoverished, and unable to buy

clothes and the barest of necessities, Hubbard was fleecing the

Scientology organizations of millions of dollars through a

Liberian "desk drawer" corporation called Religious Research

Foundation (RRF). Non-U.S. students and people coming for

auditing to the Apollo, and later the FLB, paid their money for

services purchased to RRF, not the Church of Scientology. These

funds did not then show up in Scientology account books.

Hubbard had complete control of RRF, and transferred millions to

himself from this phony corporation. The money being taken in

by RRF, which provided no service to anyone, should have been

paid to the Church of Scientology of California, a U.S.

corporation, which was claiming to the Internal Revenue Service

during theis period that the flagship Apollo was its "marine




    45. During this period, when millions of dollars of

Scientology funds were inuring to Hubbard in fraudulent

transactions from shell corporations, he was disseminating to

staff and public paying customers a totally different picture,

another shore story. In a promotional piece, entitled "What

Your Fees Buy," attached hereto as Exhibit [W] , distributed widely

and used by Scientology salesmen when selling auditing and

courses, Hubbard wrote the bald-faced lie, "the fees you pay for

service do not go to me." He stated, "I draw less than an org

staff member" draws only about four pounds a week." (This is

the $10.00 per week we received on board.) He claimed that he

was not even receiving royalties for his books. It was not

until almost the end of my Scientology "career" that I learned

that Hubbard's statements about his income from Scientology were

lies, and that like thousands of other staff who had labored in

disgraceful conditions for paupers' wages, which he set, I had

been cruelly defrauded.

    46. The disparity between the way Hubbard lived and

was treated on board and the conditions and treatment of most of

the crew was enormous. He had a spacious stateroom, as did Mary

Sue Hubbard, a large auditing room, a sumptuous office, which

was referred to as his "research room," and an enormous and

elegant living and dining room. All these spaces were

off-limits to crew and students. Hubbard had his own steward,



cook, cleaners, and driver in addition to the messengers who

catered to his every whim. Mrs. Hubbard had her own steward, as

did the Hubbard children. The Hubbards ate separately from

everyone else and ate different food prepared in their own

galley by their own cook. Much of the Hubbard's food was flown

in with couriers from the United States, whereas crew food was

purchased locally. Some of the top executives among the crew

shared small cabins and married couples generally had a cabin,

but for those crew berthed in dormitories, the conditions were

very bad. The dorms were cramped, bunks had been installed

three high, there was virtually no room to store personal

belongings, the ventilation was inadequate, the spaces smelled,

and they were roach-infested. Much of the ship was

roach-infested and despite attempts to get rid of them,

including a "roach derby" initiated by Hubbard in which

messengers fined any crew if roaches were found in their work or

berthing spaces, the roach problem remained until we all moved

ashore in the fall of 1975. In the last year or so of the

Apollo's operation as the flagship, as the on-board complement

grew and berthing space shrunk, due to the ever-expanding need

for offices and work areas, many of the crew were forced to

sleep above decks wherever they could find a spot. If it rained

too hard they picked up their blankets and moved inside into

crew dining rooms.

    47. The demand for production and the threat of



punishment for low production were so great at all times that

much of the crew existed in a state of continual exhaustion.

For years, I averaged something like four hours of sleep a night

and many others had to work equally long hours. Although there

was an official schedule for crew, it was impossible to adhere

to it because of the work load imposed by Hubbard and senior

executives. As most of the crew could not afford decent

clothing, many worked in virtual rags. Clothes had to be washed

in buckets and there were no drying facilities aboard. Many

crew members did not care for themselves hygienically and body

odor, especially in the dormitories, was at times oppressive.

Because space was so limited and holds, which should have

contained crew baggage, had been turned into mimeograph, file

rooms, or RPF berthing, there were, except in the Hubbards'

areas, piles of clothing, personal belongings and junk all over

the ship. As I had the job of promoting the shore story to the

local people in the ports we visited; that is, that we were

Operation and Transport Corporation, a highly successful

business consultant firm with the world's most effective

management technology, the crew and ship appearance was a

continual problem and embarrassment to me.

    48. Crew medical and dental needs were given a low

priority, far back of production and discipline. Unless crew

members were badly injured or seriously ill, they did not go to

the doctors. And if they developed a protracted illness, they



were labelled "clinical," and usually offloaded. Individuals

with cancer, even ulcers, both conditions which Hubbard claimed

to be able to cure with Dianetics and Scientology auditing, were

offloaded rather than treated. Crew who became sick and unable

to work had their pay docked for whatever days they missed.

Hubbard also railed against medical doctors in his writings,

claiming that they destroyed and had a vested interest in

people getting ill, and this created an aversion in

Scientologists, certainly in myself, to medicine. The Sea Org

administrative procedures also made getting medical or dental

treatment, difficult. It was hard to get off post for any

reason, and even more difficult if one's statistics were down.

Statistics, the record of the amount of production done, had to

be maintained by each crew member, and "ethics conditions" were

assigned on the basis of the person's statistics. The

statistics had to keep going up or the person would get in

"ethics" trouble. And with down statistics in a given week, it

would be almost impossible to get off the ship. Also, to get

medical or dental attention, unless it was an emergency, a crew

member would have to petition his seniors for permission, and

then would have to ensure there were sufficient funds allocated

in the medical float. I personally was denied both medical and

dental attention on separate occasions when I requested it while

in the Sea org and was told it was because there was not enough




    49. Although the conditions aboard were so abominable

they would shock any normal person's sensibilities, they

remained that way because crew had no possibility of changing

them. The conditions were set by Hubbard, and crew were kept

from changing any of Hubbard's policies or orders by his system

of discipline and punishment he called "ethics." The purpose of

the Sea Org was stated officialy as "to get in ethics on the

planet"; that is, to make the world a more ethical place.

"Ethics" was ever-present in the Sea Org, as a common word,

concept, department and force. "Ethics offenses" were met with

"ethics penalties," which ranged from the "lower conditions, " -

"liability," "doubt," "enemy," " treason, " " confusion," and "no

condition" - each of which required many hours of " amends" labor

be done while still maintaining one's own post production to a

"suppressive person declare." The extent to which ethics

penalties were taken is shown by the "Fair Game Policy,"

attached hereto as Exhibit [X], which stated:

"Enemy - SP (Suppressive Person) 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

Scientology has claimed that "Fair Game" was cancelled by the

policy letter from Hubbard attached hereto as Exhibit [Y]. This

policy states, however, that the use of the term was cancelled,

but the "treatment or handling of an SP" was not. Complaining

about a policy or conditons was an ethics offense. Crew and all



Scientologists were expected to report on one another, wife on

husband and children on parents. Anyone failing to report a

violation of policy or even someone upset or unhappy would

himself be punished. Hubbard created an atmosphere of distrust,

fear and oppression among all staff. It was called " nattering"

and was dealt with very severely. A person soon learned to not

complain, and certainly to not question Hubbard's policy,

because any counter-intention exhibited toward his policy was

also a serious offense. In the Sea Org, what Hubbard called

"ethics," was not ethics at all, but threat and terror to

enforce blind obedience. And Hubbard, who was continually lying

about his past, his accomplishments, his income, and what

Scientology really did, was himself supremely unethical.

    50. He also used the auditing procedure, by which he

claimed to be freeing people, to subtly program them to not even

think a critical thought about the deplorable conditions in

which he kept them. During any auditing therapy session, if the

the person undergoing the auditing, the preclear or "pc," makes any

critical comment, the auditor will immediately demand of the

preclear any overt, that is, any intentionally harmful act, he

has committed. In Hubbard's system, any criticism meant that

the person making it had a hidden undisclosed crime. One of his

bulletins, "Session Must-nots," attached hereto as Exhibit [Z],

states this point:



"When the pc is critical of the auditor, the
organization or any of the many things in life, this is
always a symptom of overts priorly committed by the pc.

"This is a sweeping fully embracise statement - and a
true one. There are no criticisms in the absence of
overts committed earlier by the pc."

Very soon after some auditing in the Sea org I learned that any

criticism I had meant I had done something bad, and after a

while, I even was stopped from thinking any thought critical of

Hubbard or the organization. In Hubbard's dictionary of

Scientology terms, a "critical thought" in fact is defined as "a

symptom tom of an overt act having been committed." The page with

this definition is attached as Exhibit [AA]. This concept,

although programmed into people in auditing pervaded every part

or aspect of the organization. So the criticisms of a crew

member who complained of too little pay, bad living conditions,

or harsh punishment were not listened to, but rather he would be

investigated or sec checked for his "crimes." By contrast,

however, it could never be thought that Hubbard, who was

constantly critical of doctors, judges, scientists,

psychologists, government, teachers, and especially

Scientologists, and Sea Org members, had himself committed

crimes or overts, because such a thought about him was clearly

"critical." Thus, he achieved almost absolute mind control.

    51. He was, through the same mental manipulations and

by bringing staff along through various levels of deception,



able to get them to commit antisocial acts they never dreamed of

when they entered Scientology. One of the most heinous

activities of the organization is the use for intelligence,

security and extortion purposes of the statements made by

preclears to their auditors during the auditing process, in what

the preclears think is complete confidence. Only in late 1975

did I learn of the practice. At that time, I was working in the

Guardian's Office in Daytona Beach coding and decoding telexes.

Every day there were telexes from GO's in organizations around

the world to the Flag GO with information about individuals

taken from their preclear folders. If I had known that

information divulged in auditing was not confidential but would

be freely viewed, excerpted, disseminated and used by the GO, I

would never have gotten into Scientology. But I learned of the

practice six years later, and b;y then made no choices for

myself. Later still, when I was in the RPF, on orders from the

GO, I personally participated in this practice, "culling" the pc

files of people who requested to leave or whom the GO considered

security risks. A person's pc file, or auditing file, contains

everything the preclear says to his auditor during "therapy, "

taken down in note form longhand. It contains the preclear's

whole life, especially the times of upset and emotional change.

The GO ordered culled from the preclear's files any crimes, any

sexual incidents, any drug history, and any embarrassing facts.

For people who requested to leave the Sea Org, thjese things were

typed into a "crimes list" which they had to sign before being



allowed to leave. I received similar orders to "cull" pc files

from the CMO, both in Clearwater and in La Quinta, California.

I know for a fact that my own preclear files have been culled by

GO intelligence since I left the organization and I have

attempted to get them returned to me. In an uthinkably preverse

distortion of reality, Scientology claims these files are

protected by the priest-penitent privilege and refuses to turn

them over to the people whose statements they contain, and whose

property they are. Yet, in that paradigm, the preclear is the

"penitent" for whose protection the privilege exists.

Scientology attempts to cover its crime by invoking the

privilege it violates.

    52. While admitting that preclear files are

"confidential," Scientology has claimed that its use of

information from "ethics" or personnel files, or from " life

history" forms or written "confessions," called overt-withhold

writeups or "O/W writeups," to attack people who have left the

organization is justified because these files and forms are not

"confidential." But that, too, is a distortion of the truth,

because people are in fact led to believe these things, like the

auditing information in preclear folders, are confidential.

Nobody is told when getting into Scientology or the Sea Org that

the forms they fill in and the papers in their files will be

used against them in every way possible to destroy them if they

ever discover they have been defrauded, leave the organization


or seek to obtain redress of wrongs done to them. In fact,

people are led to believe these things will not be used in any

way outside the organization, and certainly not to embarrass or

harm them in any way. That staff would even fill out life

history forms, which list sexual activities and partners, and

drugs taken, or do "O/W writeups" of "crimes" committed or

indiscretions of any kind, is a product of the twisted use to

which "auditing" is put. Because a preclear divulges his

innermost secrets to his "auditor" in the auditing process,

which he is told is absolutely confidential, he becomes willing

later to divulge the same "secrets" in other contexts within the

organization; for example in "life history" forms or "O/W

writeups." He is led along step by step with representations

about the honesty, law-abiding nature, and benevolent intent of

Hubbard and the organization to place more and more trust in

them, trust which will be betrayed in an instant if it serves

Hubbard's and the organization's true purposes: the amassing of

power and wealth.

    54. The betrayal of the trust placed in them and

failure to deliver what they promised people is what has caused

Hubbard and Scientology its many problems. It was not Hubbard's

enemies; like all dictators, he invented his enemies to keep

staff and followers in line and keep them from finding out they

were being lied to. The betrayal of trust began with Hubbard's

lies about himself to sell Scientology. It continued with the



failure of Scientology of live up to its promises made to paying

customers. It did not cure arthritis, ulcers, cancer and a host

of other illnesses as he claimed. Scientology people who have

been "cleared" still get colds, contrary to his " scientific"

claim. It did not raise IQ a point per hour of auditing. If it

had, I would have an IQ somewhere over 1000. It did not

increase ability. When I left the Sea Org, after twelve and a

half years in Scientology, I was broke with no marketable

skills. It did not give me emotional stability, security or

confidence. The whole Scientology/Sea Org experience

emotionally traumatized me. It consciously destroyed in me the

human capacity to trust. The scientific guarantees and the

scientific nature of Scientology, the way he represented it when

luring me into the organization, were lies.

54. Hubbard's strategem to avoid legal responsibility

for his fraudulent claims was to label Scientology a

"religion." But that is just another shore story. The initial

representations by Scientology salesmen are that it is a

"science." The literature is full of such statements. And the

promises of what Scientology will do for a customer are stated

as "scientifically guaranteed," and are in any case secular

representations - such things as increased IQ and ability,

improved appearance, curing colds, allergies, headaches, cancer,

etc. Staff and customers are told that the religious cover is

needed as a defense against Scientology's "enemies."



Scientology is in fact, in its top structure, represented as

antithetical to religion, which is considered a humanoid

aberration, an insanity. Hubbard's intent in labelling his

"science," Scientology, a "religion," can be seen in his letter

of April 10, 1953, attached hereto as Exhibit [BB], to Helen

O'Brien, the head of Scientology in the U.S. at the time.

Hubbard writes about the creation of an auditing clinic

connected to the HAS, the Hubbard Association of Scientologists,

the early Scientology company:

"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."

    55. I first met Tonja Burden on the Apollo in 1974.

She was a little girl then, maybe thirteen or fourteen years of

age, and inexperienced, even for that age. She worked in the

CMO on the ship, in the CMO Estates Project Force (EPF), the

group which did cleaning and other menial tasks, and as a junior

watch messenger, running messages for Hubbard and carrying out

all his wishes, under the supervision of more senior

messengers. Most of the direct contact I had at that time with

Tonja was when she cleaned my cabin. I was then married to



Terri Gillham who was the head of the CMO, and EPF personnel

cleaned the senior messengers' rooms. Although I did not know

Tonja's exact schedule on the ship, I sometimes observed that

she appeared exhausted from lack of sleep. My main impression

from that period was that she was terribly overwhelmed and the

flippant attitude she sometimes projected was just to cover up

the overwhelms. At times, tear would well up in her eyes when

things were particularly stressful for her, and she seemed

unable to communicate her thoughts at those times. I would not

have pressed her to communicate in any case, because emotional

problems were left to auditing, and it was unacceptable to

sympathize with someone in trouble.

    56. When Hubbard's personal staff moved to Dunedin,

Florida, I became the Deputy LRH External Communications Aide,

and several of the messengers including Tonja worked with me in

the LRH External Comm (LEC) Unit. Hubbard created a new shore

story for the Florida operation. The properties in Clearwater

were purchased by a front corporation, Southern Land Development

and Leasing Corporation, and then leased to another phony

organization called United Churches of Florida. The Dunedin

operation was to be United Churches Extension (UCE). As with

the OTC shore story, we were to deny being Scientologists or any

connection between United Churches and Scientology. We were to

maintain the same level of security as on the ship. Scientology

terms were never to be used outdoors and Hubbard was to be



referred to, even in phone conversations only as "the boss."

Generally Tonja worked on telexes in LEC, coding, typing,

transmitting, receiving, decoding and distributing them to

personnel at UCE. Almost all the telexes were originated by or

addressed to Hubbard or his wife, who had her Controller's

office and staff at UCE as well. At times, Tonja also worked in

the mail unit, collecting, logging and packaging the outgoing

mail, and unlogging and distributing incoming mail. There were

generally three mail and telex runs daily. Hubbard operated all

of Scientology internationally from UCE although he concentrated

during that period on the setup and operation of the new Flag

Land Base in Clearwater, Florida. He operated dozens of

missions covering every aspect of the base establishment,

including operating on a direct basis all GO activities in

Clearwater. At least twice he had the GO executives over to UCE

to personally brief them on what he wanted. I do not recall all

of the mail and telex traffic I saw for Hubbard during that

period as there was such an enormous quantity. Among the

operations I do recall, however, were "Program LRH Security -

Code Name: Power," which, along with an accompanying letter from

Hubbard, and a compliance to "Power," a GO project called " Early

Warning System: B-1" is attached hereto as Exhibit [CC], and

"Operation Goldmine" written by Hubbard, a response to which

from the USGO is attached hereto as Exhibit [DD]. A program

folder was maintained for both "Power" and " Goldmine" on LEC, in

addition to several other programs Hubbard operated. The "Early



Warning System" GO project, in order to obtain prediction of any

attempt to serve Hubbard with a subpoena, ordered the

infiltration of the US Attorney's Office in Washington, DC and

Los Angeles, the Internal Revenue Service, the District Attorney

in Los Angeles, the Attorney General of California, the American

Medical Association, the Florda State Attorney General's Office,

the local District Attorney's Office, and the local U.S.

Marshal's office; and the theft of documents from Federal

offices. I was instructed at UCE that if a process server

arrived to serve Hubbard, he was to be alerted and the process

server physically blocked so that Hubbard could make a getaway.

The "Goldmine" report reveals the Scientology corporate

machinations being ordered by Hubbard, and that there was, in

fact, no corporate integrity.

    57. Sometime in February 1976, when the United

Churches cover was "blown" in Clearwater, and it was revealed

that the whole operation was Scientology, Hubbard fled from

Dunedin and went into hiding in Washington, DC. His telexes and

mail continued to go via UCE, however, to create the illusion,

even to staff in Clearwater that he still was there. From UCE,

we relayed them on GO mail lines to the Washington, DC

Scientology organization where he had two messengers working in

the local GO to handle his mail and telex traffic. Tonja stayed

behind and continued to work in LEC with me. I became, along

with my wife, Terri, her "guardian" around that time, a



requirement set by the GO to protect the organization from

liability for the children living at the base without their

parents. It was not a legal guardianship, and it was

meaningless in any case as the conditions were set by Hubbard,

an no one had any power to change them. AT UCE, as on the

ship, Tonja seemed confused about all that was going on,

teary-eyed at times, and constantly overwhelmed. I know she was

not attending school, and was not being given anything remotely

resembling a normal education.

    58. In May 1976, I was sent to Los Angeles on a mission

to set up an LRH External Communications Unit for Hubbard,

there, and did not see Tonja until I was returned to Clearwater

and assigned to the Rehabilitation Project Force (RPF) in July.

And at that time, I could not talk with her because I was an RPF

member, and talking to non-RPF crew was forbidden. Hubbard

created the RPF on board the ship in January 1974. It was

essentially a prison to which crew who were considered

non-producers, security risks, or just wanted to leave the Sea

Org, were assigned. Hubbard's RPF policies established the

conditions. RPF members were segregated and not allowed to

communicate to anyone else. They had their own spaces and were

not allowed in normal crew areas of the ship. They ate after

normal crew had eaten, and only whatever was left over from the

crew meal. Their berthing was the worst on board, in a

roach-infested, filthy and unventilated cargo hold. They wore



black boilersuits, even in the hottest weather. They were

required to run everwhere. Discipline was harsh and bizarre,

with running laps of the ship assigned for the slightest

infraction like failing to address a senior with "Sir." Work

was hard and the schedule rigid with seven hours sleep time from

lights out to lights on, short meal breaks, no liberites and no

free time. They followed a prescribed program of sec checks and

ethics penalties. It took months for RPFers to get through the

program, to graduate back into crew status. Hubbard used the

RPF as threat to enforce obedience on the ship and throughout

the Sea Org. He threatened me with assignment a number of

times. The RPF was a degrading experience and the possibility

of assignment terrifying. When one young woman ordered into the

RPF took the assigment too lightly, Hubbard created the RPF's

RPF and assigned her to it, an even more degrading experience,

cut off even from the RPF, kept under guard, forced to clean the

ship's bilges, and allowed even less sleep. Finally, on July 1,

1976, in Clearwater after having me locked up for three weeks in

Los Angeles, Hubbard carried out his old threat and assigned me

to the new land base RPF. I stayed there seventeen months,

finally getting out on December 1, 1977.

    59. Around September 1977, Tonja was assigned to the

RPF, so I had quite a bit of contact with her again. I had had

no contact with her since my assignment because it was a serious

offense to talk to any non-RPF personnel. I did not even know



what had happened regarding my quasi-guardian relationship to

her. By the time Tonja was assigned I was the head of the RPF

on the inside, and Tonja became my junior. An RPF assignment

was an unbelievably traumatic experience. When it happened to

me, and I was a grown man, I was so devastated that I went into

shock that lasted several days, during which time I could not eat

hardly anything. It was one of only three times I cried during

all my time in the Sea Org, and I was in such heavy grief, my

body convulsed uncontrollably. Tonja too, would sink into deep

grief in the RPF, and there were other times it seemed to me she

was suppressing the overwhelming sadness inside her. There is

no way to really describe the RPF experience, the hopelessness,

the humiliation, the horror. It seemed to go on forever, the

days all identical, no time to oneself, the same blue boiler

suits like prison garb day after day, the same questions in

endless sec checks. I was a fairly intelligent, somewhat

educated adult, already trained to a degree as an auditor, with

seven years experience in Scientology, and it took me seventeen

months to make my way through the RPF program. For Tonja, a

little girl, uneducated, unsophisticated, innocent, and

completely untrained as an auditor, it would have taken years.

In spite of the hopelessness of her situation, and the

oppressive nature of the RPF program, I never saw Tonja quit, or

even quit working, and I never saw her become bitter or

antagonistic. She remained a decent, albeit broken, young

lady. Hubbard's purpose in creating the RPF, and running it as



a prison with the assignees considered criminals, was the

breaking of people's wills, the total subjugation of anyone he

considered exhibited "counterintention" to his goals. He

achieved his purpose with me so well that I thanked him for the

opportunity of doing the RPF, much like prisoners of war who are

broken emotionally and spiritually in prison through deprivation

and mind control techniques thank their captors. Attached

hereto as Exhibit [EE] is a "success story" I wrote when getting

out of the RPF, the last requirement before graduating.

Evidencing my debased state at the time I thanked Hubbard for

giving me my sanity, when in fact, he had done everything he

could to take it from me.

    60. A week or so after my graduation from the RPF I

was transferred with my wife Terri to the CMO office in the Sea

Org "Cedars" complex in Los Angeles. A few days later we

received a telex from the Clearwater CMO Unit stating that Tonja

had fled from the RPF and gone to Las Vegas, Nevada. Terri and

I were ordered to get her back. We drove to Las Vegas and found

Tonja at her parents' home. She was shocked that we had tracked

her down so quickly and she was terrified by us. Terri had been

her senior for some years in the CMO, and I had been her senior

at UCE and in the RPF, and we both intimidated her. She stated

over and over that she did not want to go back. Tears welled up

in her eyes. But Terri and I would not be swaged from our

purpose. We talked to her mother and father, and intimidated



them with veiled threats of what might happen, how it would be

better for all if Tonja came back. We also insisted that

Tonja's coming back and "routing out" properly was the most

ethical thing for her to do. The truth was our purpose was to

get Tonja back, have her sec-checked and get her to sign

waivers, releases and promissory notes, so she would be rendered

harmless to Hubbard and the organization. Tonja was, in fact,

considered a significant threat because she had worked so

closely with Hubbard and potentially knew a great deal about his

con rol of the organization, and GO intelligence operations.

After several hours, and still against her will, Tonja succumbed

to our tactics, and we drove with her to Los Angeles. There we

turned her over to the Los Angeles RPF where she would be sec

checked and made to sign the required documents.

    61. In 1980, I was interviewed by the GO about Tonja,

who was by then considered a major enemy of Scientology, and who

I knew had been a factor in Hubbard's going into deep hiding at

that time. An "affidavit," attached hereto as Exhibit [FF], was

typed up by the GO, and I signed it. It is in part false, and

the overall picture it conveys is nothing like reality. Such

false statements were expected of all Sea Org staff; they were

just more "shore stories" or "acceptable truths," necessary to

combat the "enemy." An example of an "acceptable truth" is

contained in par. 5 of the "affidavit." People were assigned a

condition of treason" or said to be "in treason." But because



the exact word "treasonous," which Tonja used, was not a label

generally attached to people in the RPF, I could write what I

did to make Tonja look like a liar. My denial of the E-Meter

being a lie detector, and the GO's description of it as a

religious artifact in par. 11 is a shore story, and in fact, an

outright lie. Even in Hubbard's own policy, attached hereto as

Exhibit [GG], he states that the "E-Meter is better known as a

lie-detector." The statement in par. 12 that "if any individual

desired to leave the RPF they were free to do so" is also a

perversion of the truth. People could leave, but not without

first being subjected to long sec checks, kept under guard,

forced to sign waivers, releases, promissory notes and

confessions of "crimes" excerpted from their auditing files,

segregated, humiliated, and generally terrorized so they would

be no threat after leaving.

    62. What I did to Tonja, coercing her back to Los

Angeles to subject her to sec checks and force her to sign

documents, and signing myself a false statement against her was

cruel and shameful. It shows the desensitization which had

occurred to me over the years of oppression under Hubbard.

Tonja was a young, innocent girl, herself brutalized by Hubbard

and his organization, yet I perceived her as a "suppressive

person," and "Fair Game," and any act against her, any trick,

any lie, anything to destroy her, as laudable. It was only

after studying the facts of Hubbard's life revealed in the



documents I assembled in the biography archives that I realized

what Hubbard had done to me. And then, like Tonja, because of

what I knew, I became "Fair Game." Since leaving the Sea Org, I

have been sued by Scientology, assaulted by a private

investigator hired by them, run into bodily by a car driven by

another private investigator, an attempt was made to involve me

in a freeway "accident," I was followed and harassed day and

night for over a month, four attempts have been made to bring

false criminal charges against me, my marriage has been

destroyed, my best friend was used to set me up in an intelligence

operation, false "sworn" statements have been made against me by

Scientologists and Scientology lawyers, and my life has

virtually been destroyed.

    Signed under the pains and penalties of perjury this

19th day of March, 1986.

Gerald Armstrong


Suffolk, ss.     March 19, 1986

    Then personally appeared before me the above named
GERALD ARMSTRONG and acknowledged the foregoing instrument to be
his free act and deed.

Before me,

[signed] Lorna Doherty
Notary Public
My Commission Expires: 3/31/89




Exhibit [A]
Armstrong's Petition to Hubbard 01-08-1980 [.pdf]

Exhibit [B]
Hubbard letter to Armstrong approving petition ca 01-11-1980

Exhibit [C]
Hubbard letter to Armstrong re: Biography and New Post Non-Existence 02-08-1980

Exhibit [D]
MSH letter to Armstrong re: Non-Existence formula 02-11-1980

Exhibit [E]
Armstrong Letter of Introduction by Pat Brice, Personal Secretary to Hubbard 07- 29-1980

Exhibit [F]
Chart of sources of Hubbard Biographical Information

Exhibit [G]
Article "L. Ron Hubbard"

Exhibit [H]
Article "A Brief Biography of L. Ron Hubbard" [.pdf]

Exhibit [I]
HCO Information Letter of 14 April 19861 PE HANDOUT © 1961 L. Ron Hubbard

Exhibit [J]
Hubbard's submission to "Who's Who in California." 03-08-1967

Exhibit [K]
Hubbard's academic transcript--George Washington University

Exhibit [L]
Admiral Fletcher report 06-08-1943

Exhibit [M]
Department of the Navy letter listing Hubbard's naval assignments and medals 05- 11-1979

Exhibit [N]
Transcript excerpt in Armstrong 1, Pages 1925, 1926 05-15-1984

Exhibit [O]
Report of Physical Examination (Hubbard) 07-27-1951

Exhibit [P]
VA Letter: Hubbard is receiving 40% disability compensation as of this date 02- 15-1973

Exhibit [Q]
Correspondence between various individuals in the GO, including Mary Sue Hubbard, that shows that the organization and Mrs. Hubbard possessed L. Ron Hubbard's naval documents at least by 1976

Exhibit [R]
Armstrong critique of an about-the-author section

Exhibit [S]
Armstrong Report to Cirrus Slevin 11-25-1981

Exhibit [T]
Guardian Order 131-4 09-09-1974 "Confidential Intelligence Course"

Exhibit [U]
HCO Policy Letter 02-20-1972 INTELLIGENCE AND SECURITY © 1972 L. Ron Hubbard

Exhibit [V]
Report on "Successful and Unsuccessful Actions "03-09-1970

Exhibit [W]
Hubbard Article "What Your Fees Buy"

Exhibit [X]
HCO Policy Letter 18 October 1967 PENALTIES FOR LOWER CONDITIONS © 1967 L. Ron Hubbard

Exhibit [Y]
HCO Policy Letter of 21 October 1968 CANCELLATION OF FAIR GAME © 1968 L. Ron Hubbard

Exhibit [Z]
HCO Bulletin 24 August 1964 SESSION MUST-NOTS © 1964 L. Ron Hubbard

Exhibit [AA]
Dianetics and Scientology Technical Dictionary; definition "critical thought" © L. Ron Hubbard

Exhibit [BB]
Hubbard letter to Helen O'Brien 04-10-1953

Exhibit [CC]
GO Project "Early Warning System: B-1"

Exhibit [DD]
USGO response to"Operation Goldmine" 11-25-1975


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