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    I, Gerald Armstrong, declare and state that:

    1. I was a Scientologist and held many positions in many sectors of

Scientology, hereinafter referred to as "the organization," from 1969 to 1981.

I have been involved in organization litigation as a witness, defendant,

plaintiff and paralegal from 1982 until the present. I have testified in three

trials and in depositions in ten organization cases approximately forty-seven

days. I have authored over twenty-five declarations concerning L. Ron

Hubbard, Scientology practices and the litigation. I am by trade a

philosopher, writer and artist. In 1986 I founded a church which now has

many members internationally.

    2. I am the defendant and cross-complainant in the case of

Church of Scientology of California v. Armstrong Los Angeles Superior Court

No. C420153. A decision in that case was rendered after a lengthy bench

trial by Judge Paul Breckenridge, Jr. on June 20, 1984. The California

Court of Appeal opinion, No. B025920, issued July 29, 1991, affirming the

Superior Court's decision, has recently been filed in this case as an exhibit to

the Aznarans' oppositions.

3. In December 1986 I entered into a settlement agreement with the

organization, a copy of which is filed herewith as Exhibit [1]. The organization

did not honor the agreement, however, but has continued a program of

threats and attacks to this day. I have detailed what I knew of these threats

and attacks up to March 15, 1990 in my declaration of that date. The

circumstances at the time of the settlement and a rebuttal of various

organization attacks are contained in a declaration I executed on December

25, 1990. I can supply these declarations to the Court if it so wishes.

    4. I make this declaration to respond to various allegations about me

made by the organization in its papers recently filed in this case.

    5. Organization attorney Laurie Bartilson states that my aid to

attorney Ford Greene in preparing the Aznarans' recently filed oppositions to

organization motions "violated this Court's orders and the Local Rules."

(Defendants' Opposition To Ex Parte Application To File Plaintiffs' Genuine

Statement of Issues [sic] Re Defendants' Motions ( 1 ) To Exclude Expert

Testimony; and (2) For Separate Trial On Issues of Releases and Waivers;

Request that Oppositions Be Stricken; hereinafter "Opp To Ex P", p.2,3.) I aid

Mr. Greene and the Aznarans out of my own free will and my sense of right

and wrong. If I am ordered by any lawfully constituted court to cease

rendering such aid I will.

    6. Ms. Bartilson states that I "[am] employed by Joseph Yanny on this

very case."(Opp To Ex P p.4) I am not.

    7. Ms. Bartilson states that for me "to now have switched [my] aid to

Greene's office further taints all (emphasis in original) of the papers filed by

Greene..."(Opp To Ex P p.5) It doesn't, because there was not and is not any


    8. Ms. Bartilson states that my aiding Mr. Greene "is grounds for [his]

disqualification."(Opp to Ex P p.5) It isn't; but if this Court were so to order

me, I will comply.

    9. Ms. Bartilson suggests that Mr. Greene should be disqualified

because I am "a paralegal formerly employed by defendant's lawyers." (Opp

To Ex P p.5) I have never been employed by any organization lawyer.

10. Ms. Bartilson declares that "[she has] been informed by private

investigators hired by [her] law firm that [I] was present at Ford Greene's

offices many times from August 3, 1991 through at least August 21, 1991,



often for hours and days at a time." (Opp To Ex P p.9, para 4) I was outside

the United States from August 3 until August 10, and not in Marin County

where Mr. Greene's office is located until August 13, 1991. Filed herewith as

Exhibit [2] are copies of my boarding passes for my flights from San Francisco

to Johannesburg, South Africa on July 19 and 2 0, returning August 9 and 10.

    11. Organization attorney William Drescher states that "[a]s [I am]

Yanny's paralegal on this case, [my] near affiliation as an assistant to Ford

Greene is truly outrageous." (Supplemental Memorandum In Support of

Defendants' Motion To Dismiss Complaint With Prejudice; hereinafter "Supp

Memo," p.4) I am not Mr. Yanny's paralegal on this case, and my affiliation

with Mr. Greene is wholly peaceful, lawful, decent, helpful, respectful, and


    12. Mr. Drescher states that "Yanny's involvement in this case

continues, this time through a different "extension"--the improper activities

of Yanny's paralegal, Gerald Armstrong." (Supp Memo p.5) I am not Mr.

Yanny's paralegal. I answered his call for help during the period he was

attorney of record in this case. I spent parts of two days on July 15 and 16

in Mr. Yanny's office during which time the only "work" I did was to write

two declarations, one of which was also used by Mr. Greene. Mr. Yanny gave

me no instructions or suggestions at any time to pass on to Mr. Greene or to

anyone else involved in the Aznaran litigation. I am not Mr. Yanny's

"extension" into this case. This organization's actions in attempting to deny

their victims, the Aznarans, not only legal representation but support to the

Aznarans' legal representatives is what is improper.

    13. Mr. Drescher states that in 1984 I was " plotting against the

Scientology Churches and seeking out staff members who would be willing to

assist [me] in overthrowing Church leadership." (Supp Memo p.5) The



organization is not a church. Organization operatives David Kluge and

Michael Rinder sought me out and gained my trust through a close friend

whom the organization coerced into participating in an operation to attempt

to entrap me. The organization operatives stated that they wanted to reform

the organization and rid it of its criminal activities and they asked me to

help. They said they wanted to save Scientology from its criminal

leadership. They stated they were operating secretly within the

organization for fear of, inter alia, being killed. They used my willingness to

communicate and to help to attempt to enveigle me into the commission of a

crime. When that failed, the organization simply twisted my refusal to

participate in the suggested criminal act into further accusations.

    14. Mr. Drescher states that "[t]he Church obtained information about

[my] plans and, through a police-sanctioned investigation, provided (me] with

the "defectors" [I] sought." (Supp Memo p.5) That the organization and its

lawyers have told this lie so many times in so many jurisdictions over so

many years has not made it any more true now than when they concocted

the plot. I was videotaped. The videos are still embarrassing to me because

I use foul language. What I say does not mean what the organization and its

lawyers say it means. A private investigator (who, during this period

threatened to put a bullet between my eyes) obtained a false authorization

from an LAPD officer, who was himself suspended six months for his

participation in the crime. The organization did not obtain information

about my plans; it created the whole operation, including what my " plans" were to


    15. Mr. Drescher states that "[o]n November 30, 1984 [I] met with one

Michael Rinder, an individual whom [I] thought to be one of [my] " agents"

(but-who in reality was loyal to the Church" (parens in original). (Supp



Memo p.5) I never considered Rinder my agent, nor did I consider that I

had any agents. Rinder was not loyal to the "church." He was being operated

by what the operatives called the "criminal leadership."

    16. Mr. Drescher states that "the conversation [was] recorded with

written permission from law enforcement." (Supp memo p.5) It wasn't. The

Chief of the LAPD denied authorizing the illegal operation, and the officer

was suspended for his 'permission."

    17. Mr. Drescher quotes some out-of-context statements from my

November 1984 meeting with Michael Rinder and avers that they meant

that I was recommending that the group of "reformers" did not need "actual

evidence of wrongdoing to make allegations in Court against the Church

leadership." (Supp Memo p.5) My answer to Rinder is out of frustration

because he appeared to be unable to understand that a complaint contains

allegations, and the proof of the allegations is achieved through

documentation and testimony, including even the well-known fact of the

organization's long history of destruction of evidence, obtained through the

litigation up to the end of trial. Elsewhere and in other conversations I

discussed with the "reformers" what was actually known and documented,

and which could be alleged in the complaint they insisted they wanted to

file. I discussed with the 'reformers" an inventory of criminal acts for which

we knew the organization was responsible. They included burglary of state

and federal offices, theft, obstruction of justice, blackmail, assault, civil rights

violations, immigration fraud, tax fraud, attempted entrapment of Federal

judges, framing of my own attorney Michael Flynn, the use of preclear folder

information against all Scientologists, all the acts which flowed from " " fair"

game," and the use of their charitable corporation funds to carry out these

criminal acts.



    18. Organization attorney Eric Lieberman states that "the utter

disregard of the truth that the Aznarans have made the trademark of their

litigation effort, bears the unmistakable signature of Gerald Armstrong,

whose theory of litigating against Churches of Scientology, as captured on

videotape in 1984, is not to worry about what the facts really are, but

instead to choose a state of "facts" that should survive a challenge by the

Church and "just allege it."" (Reply In Support of Defendants' Motion For

Summary judgment Based On the Statute of Limitations; hereinafter "Reply

Stat Lim," p.2,3) This is not true. It is simply further exploitation of the

fruits of the organization's covert actions against me: the illegal 1984

videotape regarding what the organization calls the "Armstrong Operation."

Until I started to help Mr. Greene, I had nothing to do with the Aznaran case,

which was filed in April 1988, except for my help to Mr. Yanny described in

paragraph 12 above. I have given no facts to the Aznarans, nor any legal

strategy. Besides the declarations I have written, all of which are now

before this Court, I have written not one word in any of the filed papers. My

help to Ford Greene in all of the papers recently filed has been in

proofreading, copying, collating, hole-punching, stapling, stamping,

packaging, labeling, air freighting and mailing. Mr. Greene and I have had

several conversations during this period, some of which certainly concerned

the litigation.

    19. Mr. Lieberman states that "[i]t is clear that [my] influence and

philosophy permeates the Aznaran's oppositions." (Reply Stat Lim p.3) I

pray that that is true, because my philosphy in litigating against the

organization is to tell the truth, have the faith that, no matter what lies the

organization tells or operations it runs or how threatening the organization

appears to be, truth will prevail; that, no matter how the organization



perverts the law, manipulates courts, testifies falsely, fights unfairly, wields

religion as a sword and then a shield and abuses the legal process, justice

will, if fought for honorably, triumph.

    20. Mr. Lieberman states that [o]n August 19, 1991 [I] admitted to

one of defendants' counsel that [I ] was at Greene's office "helping out.""

(Reply Stat Lim p.3) I admitted no such thing. I was doing nothing even

faintly improper which would require admission. I have been completely up

front about my being in Mr. Greene's office and helping him. It is the

organization which has skulked around and engaged in improprieties which

it should admit to. I was so shocked when I discovered the organization

operatives videotaping me on August 2 0 that I wrote Mr. Lieberman to

protest the harassment. When I found the operation continuing on August

21 I again wrote Mr. Lieberman, and called his office, advised one of his

associates of the operation and pleaded that it be called off. Copies of my

letters are filed herewith as Exhibits [3]and [4]. Mr. Lieberman has not

answered my letters, has not mentioned them in his papers, which he signed

on August 26, but has escalated the attack on my character and intentions.

The operation has continued at least until August 30. Because of its form

and nature, and because of my knowledge of organization operations and its

philosophy of opportunistic hatred, I believe that this operation does not

have as its major goal the proof that I am helping Mr. Greene. I believe its

goal is intimidation and the assembly of intelligence information for future


    21. Mr. Lieberman states that "the real thrust of the Aznarans'

Opposition is ....the "just allege it" philosophy of Yanny's paralegal, Gerald

Armstrong." (Reply Stat Lim p.33) I am not Mr. Yanny's paralegal, and "just

allege it" is really the organization's litigation theory. L. Ron Hubbard



established the Guardian's Office and then the Office of Special Affairs to

carry out his way of litigating.

"In the face of danger from Governments or courts ......

If attacked on some vulnerable point by anyone or anything or

any organization, always find or manufacture (emphasis added)

enough threat against them to cause them to sue for peace." L.

Ron Hubbard, Policy Letter of 15 August, 1960 "Dept of Govt

Affairs." (Exhibit [5] )

    22. Mr. Lieberman states that "[my] "helping out" while the Opposition

was concocted not only reveals the continuing taint of Yanny's involvement

with this case, it establishes the guiding principle that resulted in [the]

Opposition..." (Reply Stat Lim p.34) Not one thing, not the ability to

proofread, photocopy, collate, hole-punch, staple, package, label, air freight

or mail that I did in connection with the preparation of the Aznarans'

oppositions, did I learn from Mr. Yanny. Not the ability to spot and confront

organization operatives did I learn from Mr. Yanny. Not the ability to write,

nor any fact or idea or word in any declaration did I learn from Mr. Yanny. I

have been the target of "fair" game since I left the organization in 1981, and

understand its philosophy. I know the organization's litigation theories and

practices and I understand the psychopathology of L. Ron Hubbard and why

he and his organization came to be viewed by Courts as paranoid and

schizophrenic. There is nothing Mr. Yanny could possibly tell me which

would surprise me or be additional to what I know about this organization.

Mr. Yanny has provided no "guiding principle" whatsoever. The organization,

by making and maintaining fair game as its guiding principle, established the

guiding principle in this litigation. The fair game doctrine will dog the

organization as long as there are honest and free men or until the



organization, not denies its existence, but completely and sincerely

repudiates it.

    23. Mr. Lieberman states that "[my] philosophy of litigation is that

facts and the truth are irrelevant and that all that is required to prevail is to

allege whatever needs to be alleged." (Reply Stat Lim p.34) I have survived

all the cross-examination and depositions by the organization, the

documentation attacks by the organization, the character assassination by

the organization, the use of my preclear folder information, the operations,

the threats, the assaults, because truth is relevant. Although there

undoubtedly is some memory loss over the past twenty-two years, and

although there may even be some discrepancies in forty-seven days of

sworn testimony, I have survived examination and cross-examination

because I have, as much as is humanly possible, told the truth. I have said

what I have known, known when I didn't know something, and stated my

opinions as opinions. It is my opinion that one honest man can confront and

vanquish a dishonest organization, no matter how big or how organized.

Gratefully there are a few honest men to make the work lighter.

    24. Mr. Lieberman states that "[t]he Aznarans' desperation to defeat

this motion is so profound that they resort not only to the "just allege it"

litigation philosophy of Joseph A. Yanny's paralegal assigned to this case,

Gerald Armstrong, but also to enlisting Armstrong's help in this cynical, say-

anything-you-have-to approach to the truth." (Reply In Support of

Defendants' Motion For Summary Judgment Pursuant To the First

Amendment; hereinafter Reply First Am, p. 2 ) I am not Mr. Yanny's

paralegal, and I am not assigned to this case. The desperation which

resulted in the enlisting o my help had a purely logistical basis. Mr. Greene

faced a mountain of organizational motions which required oppositions, and



no time to do them. He has no employees but a secretary who comes in a

couple of evenings a week sometimes and sometimes on Saturdays. He

needed simple office backup in the form of proofreading, photocopying,

collating, hole-punching, etc. I am blessed with those simple office skills,

and I have a knowledge of the subject matter and the cause in which Mr.

Greene labors. I am aware of the awesome disparity of resources between

Mr. Greene and the army of law firms, lawyers, paralegals, secretaries, and

organizational legal machinery of his opposition. I am aware of the

organization's policies and practices of neutralizing or eliminating the legal

support of its enemies. How could anyone resist a call to help in this

situation? It was not a conspiratorial thought that plunked me down over a

year ago within running distance of the Hub Law Offices and sporting the

same zip code. What it was was merely making the inevitable not only

funny but easier.

    25. Organization attorneys have made much of the fact that Joseph

Yanny has been enjoined from representing me in litigation. adverse to the

organization. (Op To Ex P p.10; Supp Memo p.4) He is, of course, its former

attorney. I have been working with Mr. Greene since August 17. I have not

seen nor heard one word of Mr. Yanny's influence in this case, beyond the

fact that the organization just alleged it.

    I declare under penalty of perjury under the laws of the State of

California and the United States that the foregoing is true and correct.

    Executed on September 3, 1991 at Sleepy Hollow, California.


G. Armstrong


Exhibit [1]
Mutual Release and Settlement Agreement 12-06-1986

Exhibit [2]
Copies of Armstrong's boarding passes [.pdf]

Exhibit [3]
Letter to Lieberman 08-21-1991

Exhibit [4]
Letter to Lieberman 08-22-1991

Exhibit [5]
HCO Policy Letter of 15 August 1960 DEPT OF GOVT AFFAIRS © 1960 L. Ron Hubbard


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