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I Gerald Armstrong, depose and state:

     1. I am a Canadian citizen and a resident of San Anselmo,

California, USA.

    2. I am a writer and artist and I am the assistant of

attorney Ford Greene.

    3. I am making this statement with the intention that it

be introduced in the trial now set for February 21, 1994 in the

High Court in London of cases 1984 S No. 1675 Scientology AOSH Eu

& Af -v- Scott, et al and 1986 C No. Scientology RECI -v- Carter,

et al.

    4. It is my understanding that these cases involve the

taking and distribution of certain Scientology writings often

referred to as "upper level materials." I am a witness to the

following facts which will be raised at trial.

    5. I became involved with Scientology as a customer in 1969

in Vancouver, B.C. I worked on staff there in 1970 and in

February 1971 joined the Sea Organization (SO or Sea Org),

Scientology's quasiparamilitary core organization in Los Angeles.

I was flown to Spain and joined the Sea Org's flag ship,

" Apollo," in Morocco. L. Ron Hubbard, the Sea Org's " Commodore,"

was on board and operated Scientology internationally through the

"crew" which numbered, during my stay on board of four and a half

years, around four hundred. All my staff positions on board

involved personal contact with L. Ron Hubbard, Mary Sue Hubbard,

administrative organization staff and people in the ports and



countries the "Apollo" visited. These on-board positions

included "Ship's Representative"/legal representative, " Port

Captain" /public relations officer, and "Information Officer"/

intelligence officer.

    6. In the fall of 1975 after the ship operation moved

ashore in Florida I was posted in the Guardian's Office (GO)

Intelligence Bureau connected to Hubbard's Personal Office. From

December 1975 through June 1976 I held the post of Deputy LRH

External Communications Aide handling Hubbard's written and telex

traffic to and from Scientology organizations. From July 1976 to

December 1977 I was assigned, on Hubbard's order, to the

Clearwater, Florida unit of the "Rehabilitation Project Force"

(RPF), the SO prison system. In 1978 I worked in Hubbard's

cinematography crew in La Quinta, California making movies under

his direction until the fall of that year when he again assigned

me to the RPF, this time for eight months first in La Quinta,

then at a newly purchased base in Gilman Hotsprings near Hemet,

California. From the time I got out of the RPF in the spring of

1979 and until the beginning of 1980 I worked in Hubbard's

"Household Unit" (HU) at Gilman, the SO unit which took care of

Hubbard's house, personal effects, transport, meals and so forth,

as the "Purchaser," "Renovations In-Charge" and " Deputy

Commanding Officer HU."

    7. Throughout 1980 and until I left the organization in

December 1981 I held the organization posts in Hubbard's

"Personal Public Relations Bureau" of "LRH Archivist" and "LRH



Personal Researcher." I assembled in Los Angeles an archive of

Hubbard's writings and other materials relating to his history to

be used as, inter alia, the basis for a biography to be written

about the man. I also worked in Los Angeles for the first few

months of 1980 on Mission Corporate Category Sortout (MCCS),

which had the purpose of restructuring the Scientology enterprise

so that Hubbard could continue to control it without being liable

for its actions. Beginning in the fall of 1980 and continuing

until my departure, I provided the biographical writings and

other materials, as I collected and organized them, to Omar

Garrison, who had contracted-with the organization to write the

Hubbard biography. I interviewed many people who had known Mr.

Hubbard at periods throughout his life, including almost all of

his known living relatives. I traveled several thousand miles

collecting biographical information and conducting a genealogy

search, and arranged the purchase of a number of collections of

Hubbard-related documents and other materials from individual


    8. Through my research and study of documentary evidence,

mostof it from Mr. Hubbard's personal archive, I learned that he

had lied about his past, credentials, accomplishments,

relationships and intentions. I disproved many of the claims

made by Hubbard in his biographies printed in Scientology

publications and used in promotion of the man and his philosophy

and psychotherapy, and I attempted to get the organization

executives responsible for these publications to correct the



disproved claims. As a result I was ordered to be security

checked, an interrogation employing an electronic meter as a lie

detector, a procedure I had undergone many times in the Sea Org.

I had by this time also disproved the significant representations

Hubbard had made about himself or his "technology" which had

drawn me into and kept me in the organization for over twelve

years; e.g., that he was an engineer and an atomic physicist,

that he had been crippled and blinded in combat in WW II and had

cured himself with his mental science discoveries, that it was a

matter of medical record that he had twice been pronounced dead,

that his psychotherapy had been subjected to rigorous scientific

testing, that it cured all psychosomatic ills and raised IQs a

point per hour of. therapy (I had by this time had well over a

thousand hours), that he had been remunerated for his labors less

than staff members were paid (in my case between $4.30 and $17.20

per week throughout my SO years), and that he and his

organization were ethical and well-intentioned. When it became

clear to me that I was not going to be able to get the

organization or Hubbard to admit to the lies and take a more

honest path I left, along with my then wife Jocelyn.

    9. Following my departure the organization published a

" Declaration" dated February 18, 1982 labelling me a "Suppressive

Person (SP)." The terms "SP" or "suppressive person" are painful

hate words, which have the effect of instilling terror in the

people so labelled. An SP is described in Scientology's

literature as completely psychotic and destructive, one of the



two and a half percent truly evil people on the planet. SPs are

viewed as enemies of Scientology and mankind and are targets for

the organization's philosophy and practice of opportunistic

hatred Hubbard called the "Fair Game Policy," which states

specifically that enemies may be lied to, cheated, sued and

destroyed without discipline of the Scientologist committing such

acts. My SP Declare also accused me of "spreading destructive

rumors about senior Scientologists." I knew in early 1982 that I

was the target of Guardian's Office intelligence operations

because certain friends were contacted and interrogated about me

by known GO intelligence personnel, and I had detected

organization personnel spying on my wife and me. The

organization also appropriated a set of photographs I had

entrusted with an associate,.Virgil Wilhite, and when I demanded

their return one of Hubbard's lieutenants told me to get a


    10. A few days later I met with attorney Michael Flynn who

agreed to defend me against the organization, which on April 22,

1982 published a second SP declare accusing me of eighteen

"crimes, high crimes and suppressive acts," including, inter

alia, promulgating false information about Hubbard and the

organization. In the spring and summer of 1982 I obtained from

Omar Garrison, with his permission, some of the documents I had

delivered to him while in the organization which I considered I

would need to defend myself against the organization's charges in

the SP declares and whatever actions they would bring against me



in the non-Scientology courts. I sent these to Mr. Flynn and to

Contos and Bunch, a California law firm which by then had agreed

to represent me in Scientology litigation. The organization

filed suit against me in the Los Angeles Superior Court on August

2, 1982 and the Hubbard biography documents I had sent to my

lawyers were ordered by the Court to be deposited with the clerk

where they stayed until December, 1986.

    11. In August and September 1982 the organization employed a

number of private investigators to surveil and harass my wife and

me. During that period one of these investigators assaulted me

bodily, and another struck my body with a car, and attempted to

involve me a freeway accident by getting in front of my car and

slamming on his brakes and pulling alongside my car and swerving

into my lane. The organization also attempted to get the Los

Angeles Police Department to bring criminal charges against me in

connection with the Hubbard documents which had become the

subject of the litigation in the Superior Court.

    12. I filed a cross-complaint in 1982 against various

Scientology corporations for fraud and the intentional infliction

of emotional distress. The cross-complaint was bifurcated from

the underlying document case and never tried because it settled

in December 1986. The document case was tried without a jury by

Judge Paul G. Breckenridge, Jr. who rendered a decision on June

20, 1984. Judge Breckenridge's decision is appended hereto as

Exhibit [A]. The opinion of the California Court of Appeal, Second

Appellate District, Division Three issued July 29, 1991 affirming



the Breckenridge decision is appended hereto as Exhibit [B].

Between that time and the settlement the organization continued

its "fair game" campaign against me which included at least these

acts: a) attempted entrapment; b) illegal videotaping; c) filing

false criminal charges against me with the Los Angeles District

Attorney; d) filing false criminal charges against me with the

Boston office of the FBI; e) filing false declarations to bring

contempt of court proceedings against me on three occasions; f)

obtaining from English private investigators, who had harassed me

in London in 1984, perjured affidavits accusing me falsely of

passing documents to a bearded stranger in the Olde Cock Tavern

on Fleet Street; disseminating internationally Scientology

publications falsely accusing me of crimes, including crimes

against humanity; g) culling and disseminating information from

my supposedly confidential auditing (psychotherapy) file.

    13. Following the December 1986 settlement the organization

continued its fair game campaign against me in violation of the

spirit and letter of the settlement agreement. The

organization's violations include at least: a) use of my name and

a false and unfavorable description of my organizational

experiences in 1987 in a "dead agent" pack relating to writer and

anti-Scientology litigant Bent Corydon; b) filing several

affidavits in the fall of 1987 in the case of Church of

Scientology of California v Russell Miller and Penguin Books

Limited, case no. 6140 in the High Court of Justice in London

England, falsely accusing me of violations of court orders in the



Armstrong case, and falsely labeling me "an admitted agent

provocateur of the U.S. Federal Government;" c) delivering a

copy of an edited version of the 1984 illegal videotape of me to

the London Sunday Times; d) threatening me with lawsuits on six

occasions if I did not abet the organization's obstruction of

justice; e) threatening to release a description I'd written of

a dream I'd had, and which the organization had stolen from a

friend of mine, if I did not assist the organization in

preventing Bent Corydon from gaining access to the Armstrong

court file; f) using my name and a false rendition of the

organization's 1984 videotape operation where organization

intelligence operatives attempted to entrap me into the

commission of a crime in the case of Church of Scientology

International v. 17 Agents, case no. 91-4301 SVW filed August 12,

1991 in US District Court, Central District of California; g)

using the same false rendition of the 1984 "Armstrong Operation, "

perjurious declarations by organization lawyers and a general

attack on my character and truthfulness in various pleadings

filed in August and September, 1991 in the case of Aznaran v.

Church of Scientoloqv of California, et al, No. CV 88-1786 JMI in

US District Court, Central District of California; h) suing me

in 1992 and twice more in 1993 for alleged violations of the 1986

settlement agreement based on the false statements of the

organization's lawyers and its leaders; i) two times in 1993

attempting to have me jailed for contempt of court based on the

false sworn statements of its lawyers; j) distributing copies



internationally of the 1985 dream organization lawyers had

threatened to release as stated in e) above (I wrote this

recitation of a dream, which was sexual in content, in a graphic,

vulgar style, and the way the organization has perverted its

significance has made its distribution embarrassing and

distressing to me. The dream was specifically sealed in the Los

Angeles Superior Court arid the organization has violated that

sealing order in order to use this document to attack me); k)

using its head private investigator to spread the lie that I have


    14. I have testified approximately--55 days in trial. or

depositions in more than 15 Scientology-related cases. I am an

expert in the fraudulent nature of Scientology and its use of

"fair game," and I have testified as an expert in these areas. I

am also knowledgeable regarding the organization's efforts to

hide its actual control and to shield those who control it from

legal responsibility with "buffer" corporations, secret orders,

secret command lines, organization-wide agreement to lie to

protect those in actual control, and threat of extreme

retribution toward anyone who violates that agreement to lie.

    15. In his decision, Judge Breckenridge found:

"In addition to violating and.abusing its own members

civil rights, the organization with its "Fair Game"

doctrine has harassed and abused those persons not in

the Church whom it perceives as enemies. The

organization clearly is schizophrenic and paranoid, and


this bizarre combination seems to be a reflection of

its founder LRH. The evidence portrays a man who has

been virtually a pathological liar when it comes to his

history, background and achievements. The writings and

documents in evidence additionally reflect his egoism,

greed, avarice, lust for power and vindictiveness and

aggressiveness against persons perceived by him to be

disloyal or hostile." (Exhibit A, p. 8, 1. 18 - p. 9,

1. 4).

I observed the organization's abuse of its members' civil rights

throughout the years I was inside. This abuse included false

imprisonment; use against people of their statements made in

supposedly confidential auditing-sessions; use of auditing

techniques in a coercive manner, e.g., security checks to find

"traitors" or "security risks," or to "turn on rockslams" by

which the person would be assigned to the RPF, which is itself an

abuse of basic human rights, and is itself a setting in which

auditing is coercive, since a person cannot get out of the RPF

unless he or she submits to auditing; the practice of

disconnection, which breaks apart and alienates families;

tricking or forcing members to lie, including perjuring

themselves in sworn testimony in legal proceedings; threat of

"ethics," "Fair Game," RPF, disconnection and dirty tricks; and

denying its members access to the truth about the nature of the

organization while subjecting them to an unending barrage of

distortions, half-truths and outright lies.



    16. In a case the organization filed against me in 1992 to

enforce the December, 1986 settlement agreement, Los Angeles

Superior Court Judge Ronald M. Sohigian stated on May 27, 1992:

"The information (Gerald Armstrong's experiences inside

the Scientology organization) that's being suppressed

in this case, however, is information about extremely

blame-worthy behavior of [the Scientology organization]

which nobody owns; it is information having to do with

the behavior of a high degree of offensiveness and

behavior which is meritorious in the extreme.

It involves abusing people who are weak. It involves

taking advantage of people who for one reason or

another get themselves enmeshed in-this extremist view

in a way that makes them unable to resist it

apparently. It involves using techniques of coercion."

The pages from the transcript of the hearing before Judge

Sohigian in which he made this statement are appended hereto as

Exhibit [C].

    17. I was myself enmeshed in Scientology's extremist view

for many years and have known personally hundreds of other people

just as enmeshed. I am also known by hundreds of people around

the world as someone who brought to light the truth about L. Ron

Hubbard's history, through his documents which were used in

evidence at my 1984 trial and through my willingness to talk

freely about what I had found in my assembly and study of his

documents. Many people have thanked me personally for exposing



the truth as I saw it about L. Ron Hubbard and his organization,

and for thus freeing them from the lies which had kept them

enmeshed in the organization's extremist view. The exposure of

any of the organization's "secrets," including the " upper level

materials" serves the same purpose; that is, it frees people from

the organization's unhealthy and often dangerous domination. One

of Hubbard's and his organization's techniques of domination was

to claim possession of secret knowledge, which they also claim is

vital to the sanity, health and future of everyone under their

control, and for which the organization charges astronomical sums

of money to view. Exposure of these "secret" materials reveals

them for what they really are: more techniques and untruths to

further enmesh the organization's victims. Exposure is in the

public interest.

    This statement is true to the best of my knowledge and


Exhibit [A]
Breckenridge Decision

Exhibit [B]
283 Cal.Rptr. 917

Exhibit [C]
Hearing Transcript Excerpt 05-27-1992 [.pdf]


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