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    I, Gerald Armstrong, declare

    1. I am making this declaration to respond to the

application (App.) of the Church of Scientology International,

hereinafter referred to, along with the rest of Scientology's

command and control structure, as "the organization," for an

order to show cause why I should not be held in contempt of

court, and to the declaration of Laurie J. Bartilson (LJB Dec.)

dated December 31, 1992 on which said application is based.

    2. Judge Breckenridge stated in his decision filed June

22, 1984, in the case of Scientology v. Armstrong, Los Angeles

Superior Court No. C 420153, hereinafter referred to as Armstrong

I, affirmed on appeal in Scientology v. Armstrong (1991) 232 Cal.

App. 3d 1060, 283 Cal. Rptr. 917, that:

"[i]n addition to violating and abusing its

own members civil rights, the organization

over the years with its "Fair Game" doctrine

has harassed and abused those persons not in

the [organization] whom it perceives as

enemies. The organization clearly is

schizophrenic and paranoid..."

Ms. Bartilson is a member of the Scientology organization.

    3. Ms. Bartilson states that on June 24, 1992 during a

deposition in this litigation I asserted that I would never

comply with the order of the honorable Ronald M. Sohigian dated

May 28, 1992, hereinafter referred to as the "Sohigian ruling, "



which denied in part and granted in part the organization's

motion for a preliminary injunction brought to enforce the

December 1986 "Mutual Release of All Claims and Settlement

Agreement," hereinafter referred to as the "settlement

agreement." (App. p. 3, l. 3; LJB Dec. p. 2, para. 4) When I

state at page 124 of the June 24 deposition transcript that I

have "absolutely no intention of honoring that settlement

agreement," I mean exactly that. I do not mean the Sohigian

ruling and Ms. Bartilson is something indiscernibly different

from dishonest to so state in her sworn statements. The

settlement agreement cannot be enforced, it is impossible for me

to honor it, and Judge Sohigian refused to enforce it.

    4. Ms. Bartilson states that on October 7, 1992, during

a deposition in this case, I confirmed that I indicated to Los

Angeles Times reporter Robert Welkos my intention not to comply

with the Sohigian ruling. (App. p.4, n.4) Ms. Bartilson also

states that my testimony from that deposition, which she quotes

in her declaration, is an acknowledgement by me of my intention

to wilfully disobey the terms of the Sohigian ruling. (LJB Dec.

p.4, para. 5) There is not one word in my deposition testimony

she has quoted, nor anywhere else, that would indicate to anyone

with eyes to see, an intention by me to disobey the Sohigian

ruling. My statement concerning the injunction, which Ms.

Bartilson has quoted but woefully misinterpreted means only this:

the organization moved the LA Superior Court for an order to

enjoin me from doing anything not permitted by any or all of the



conditions and prohibitions of the settlement agreement; the

Sohigian ruling enjoins me from doing certain things, but

specifically denies the organization's motion as to all the

agreement's conditions and prohibitions except said certain

things. The organization did not appeal that ruling; therefore I

am free from the potential of an order which could have enjoined

me from doing those things which are prohibited by the language

of the settlement agreement but not prohibited by the much

narrower Sohigian ruling.

    5. Ms. Bartilson states that I have threatened in my

letter of December 22, 1992 that if I am not paid $500,000 and

this lawsuit dismissed I intend to travel to South Africa to

testify against a church of Scientology. (App. p.4, 1. 12; LJB

Dec. p. 8, para. 15, 16) My letter contains no such threat, nor

any threat, other than the affirmation, which should not be

perceived as threatening, that I will not be intimidated by the

organization's threats into not living my life and not helping

its victims. Ms. Bartilson should rejoice at that fact because

there very easily may come a time when she will perceive herself,

having been forced by her organization's leader to commit so much

perjury and attack so many innocent people of good will in

violation of all the ethical standards expected by our society of

officers of the court, as a victim, and will herself look for

understanding and help from people her organization has not been

able to intimidate. Only the resolution of the Malcolm Nothling

litigation will keep me from travelling to South Africa to



testify at his trial. I have already been subpoenaed to testify

at that trial and I have promised Mr. Nothling that I will appear

to testify. The $500,000 is not for me but is my estimate of

what my fees and costs are to date in the instant case. Pursuant

to the settlement agreement, the prevailing party in any effort

to enforce the agreement is entitled to the costs of suit and

reasonable attorney's fees. I have already prevailed in this

case, in that by the unappealed Sohigian ruling I have been freed

from all the prohibitions of the settlement agreement, except the

narrow restriction of my right to provide testimony to claimants

or intended claimants against the organization unless pursuant to

subpoena. The $500,000 is unrelated to the Nothling litigation,

but is what I considered was required in order to peacefully and

rationally end the Armstrong litigation without a trial and

without a significant human catastrophe. The organization has,

however, rejected my offer to settle this and any other cases, so

my offer and the whole December 22 letter did not directly or

indirectly assist anyone, thus cannot logically be considered a

violation of the Sohigian ruling. I am not displeased to not

have this case or the Nothling case dismissed because they will

run the course most useful to God, and that may well include the

catharsis of public trials.

    6. Ms. Bartilson states that I intend to voluntarily

assist anyone and everyone opposing Churches I can locate. (App.

p. 4, 1. 16; LJB Dec. p. 8, para. 16) This is silly. I don't

oppose churches, and I don't know anyone who opposes churches.



In fact, in 1986 I founded a church, which, having expanded its

membership more than thirty times in less than seven years, is

one of the world's fastest growing, a fact which probably

explains why the organization opposes it so religiously, since it

claims and desires to be the world's fastest growing church. L.

Ron Hubbard, whom I knew, opposed churches and opposed religion

itself, and his organization, reflecting his schizophrenia and

paranoia, opposes churches and religion, but Mr. Hubbard has

disappeared and I am not attempting to locate him. In fact I am

not even attempting to locate anyone opposing Ms. Bartilson's

non-church organization. Anyone I am to communicate with will be

led to me. It very well may be that at this period of my life

some of these people will be those who oppose the non-church

nature of the Scientology organization, but that is not

surprising because people of good will everywhere oppose such a

nature, and there are such people of good will everywhere.

    7. Ms. Bartilson states that I express in my December 22

letter the viewpoint that the Sohigian ruling places no

restrictions whatsoever on my conduct. (App. p.5, l. 1; LJB Dec.

p. 8, para. 16) The very words Ms. Bartilson has excerpted from

my letter to support her charge show that I do consider that the

ruling does restrict my conduct. "I consider myself free to do

anything anyone can, except testify absent a subpoena." Ms.

Bartilson is also aware that I have appealed the Sohigian ruling

for the reason that it does restrict my conduct, in fact acts as

an unconstitutional prior restraint on my right to speak, and



that, even though the restriction is limited to my not being able

to testify on behalf of claimants or intended claimants against

the organization except pursuant to subpoena, I consider that

injunction illegal as it is obstructive of justice and uses the

authority and powers of the judiciary to assist vexatious and

criminal litigants. The Sohigian ruling does not prohibit my

association with and befriending of all those people I consider

the organization attacks unjustly and senselessly, does not

prohibit my making my knowledge and support available to the Cult

Awareness Network, hereinafter referred to as "CAN," in the

litigation the organization has fomented against CAN, and does

not prohibit my making my knowledge and support available to

entities like Time and people like Rich Behar in their defenses

from the organization's attacks. Nowhere does the Sohigian

ruling state that I may not help those individuals or groups

against whom the organization or its agents is litigating a claim

or intending to litigate a claim. Nowhere does the Sohigian

ruling state that I must sit by while the organization lies,

cheats, abuses innocent people, attacks justice and perverts


    8. Ms. Bartilson states that a paragraph she quotes from

my December 22 letter makes plain what she calls my personal

contempt for a court which would rule against me. (App. p. 5, 1.

10; LJB Dec. p.9, para. 19) This is a wild and crazy concoction.

What I stated, and what I believe is obvious in our system of

jurisprudence, and far from contemptible, is that no court will



order me to not defend myself. I have been sued by the

organization and I am therefore a defendant. If there comes a

day when defendants are not permitted by our courts to defend

themselves, then our courts will be deserving of society's

contempt. Although the organization, which, pursuant to its own

policy, uses our courts to harass its perceived enemies and waste

people's time, money and lives, works for that day, I am not

worried about that day's arrival. At this time I continue with

faith in God Who will not let Justice be no more and Who will not

leave me defenseless. I am not unaware that judges are human,

that some have been compromised and corrupted, and that bucks,

babes and bull are common mechanisms to effectuate judicial

compromise and corruption. I am also not unaware that the

organization has a widely known and occasionally publicized

history of contempt for our judicial system and contumelious

efforts to compromise and corrupt our judiciary. Here, not only

does the organization seek to have this Court prevent me from

defending myself by, inter alia, publicly speaking the truth and

helping the organization's victims, it presses to have me

punished for speaking and helping.

    9. Ms. Bartilson makes much of the fact that I continue to

work as a paralegal in the office of Ford Greene who represents

various people in organization-related litigation. (App. p. 6, 1.

6; LJB Dec. p. 4, para. 6) Yet it is the organization which has

made it necessary for me to work in Mr.Greene's office.

Wherever I go, until the organization publicly and honestly



repudiates "fair game," it will target me and use its

intelligence network and operations, legal machinery and self-

serving madness to destroy me. No employer, other than one who

understands this organization's motives, means and madness, can

recognize and withstand its covert and overt attacks. The

organization puts at risk, because of its pervasive and

calculated hatred of me and its determination to destroy me, any

employer who would hire me. In 1982 its PIs staked out the law

firm where I worked, embarrassed me, terrified my fellow

employees, and it harassed my lawyer employers, including the

firm's senior partner, with frivolous depositions. The

organization attacked my next employer, Michael Flynn, with some

fifteen lawsuits, bar complaints, framed him with the forgery of

a $2,000,000 check, ruined his marriage and finally induced him

to desert me in order to end the attacks. In 1991, the

organization sued another lawyer, Joseph A. Yanny, for daring to

represent me in litigation. Mr. Yanny didn't represent me and

the litigation existed only in the organization's mad

imagination. The organization has now initiated an attack on yet

another of my lawyers, Michael L. Walton, subpoenaing him for a

frivolous deposition, demanding the production of his personal

files and client files, threatening to take his house, and

disrupting his life. The organization has subjected Ford Greene

to false bar complaints, constant surveillance, and a scheme in

which organization lawyers tricked his clients, the Aznarans,

into firing him as their lawyer. It sent an agent to get close



to him, get into his office by deception and steal his client

files. The organization will do whatever it can to compromise

me, any employer and any lawyer, and ruin any relationship of any

kind I may develop with anyone. The organization's malice is

certainly demonstrated in this effort to have me held in criminal

contempt. Based on lies and perversions it wants me jailed for

opposing its antisocial acts, and living my own life. I have no

doubt that the organization leaders have plotted my

assassination, nor that all my friends are at risk from the

organization because of their association with me. I am working

with Mr. Greene because he too is the target of this

organization's attacks, because he understands, and because he

too does not think much of organized evil.

    10. Ms. Bartilson claims that my execution of proofs of

service on July 30, 1992 in the case of Aznaran v. Scientology,

US District Court, Central District of California No. CV-88-1786-

JMI(Ex) is an acknowledgement of my intention to wilfully disobey

the Sohigian ruling (App. p.7, l.10; LJB Dec. p. 6, para. 11) It

isn't. The Sohigian ruling is not intended to and does not

prohibit such clerical tasks which can be done by anyone.

Signing the proofs of service has nothing to do with my

experiences in the organization, concerning which I can provide

testimony to claimants and intended claimants only pursuant to

subpoena. When I received and read the Sohigian ruling I sought

to divine its meaning and apply it sensibly to my life, work and

legal situation. If it meant precisely what it said then I would



have to stop breathing because by breathing I would be indirectly

assisting any person litigating a claim against the organization

entities referred to in sec. 1 of the settlement agreement.

Obviously, therefore, Judge Sohigian did not mean what he stated.

If he meant only that I could not, as opposed to passive

assistance to litigating claimants such as breathing, living and

writing magazine articles for the public generally, physically

act to help such a claimant personally, I would have to ensure

every little old lady or little old man I might escort across any

old road was not such a claimant. I am certain Judge Sohigian

did not intend that. Even an interpretation of the Sohigian

ruling that I am prohibited from indirectly assisting any person

litigating a claim against the organization entities in that

litigation, in some way unrelated to my experiences in and

potential testimony against the organization, leads to

absurdities that Judge Sohigian also could not have intended. I

recognized that the organization would interpret the Sohigian

ruling in an absurd way because its way of interacting with me is

crazy and its stock-in-trade is perversion of logic and truth;

but I reasoned that I could not myself act in an absurd or

illogical fashion and pervert truth out of fear of the

organization's use of my God-given actions to attack me.

Following Ms. Bartilson's tortured logic, if I got a job as a

clerk in the LA Superior Court, for the rest of my life I would

not be able to receive, stamp or file any document from anyone

involved in litigating a claim against any of the organization



entities. Nor could I answer the phone if a lawyer for such a

claimant or even his organization opponents called the Court. If

I got a job as a postal carrier I would have to refuse to deliver

mail to and from any such claimant. If I became a cab driver I

would have to question all my fares and refuse to carry any

claimant or his lawyers or witnesses on their ways to meetings,

depositions and trials. If the same illogic were permitted in

settlement agreements in all cases, and became anywhere near

usual in the litigation industry, nobody in this great country

could do anything for anybody for fear of violating some non-

assistance covenant. The opportunities for unscrupulous groups

like the Scientology organization would be fantastic, for anyone

who signed such an agreement could be easily framed with

settlement violations. Coupled with $50,000-a-crack liquidated

damages clauses the economic possibilities are Hubbardian in

megalomagnitude. Trick the clerk into opening an envelope

containing anti-organization litigation papers; con the cabby

into driving the wrong person to a deposition; photograph the

postman delivering something to a litigant. But I do not believe

Judge Sohigian intended such an interpretation of his ruling, and

I do not believe such non-assistance covenants or orders are

legal or do anything but obstruct the administration of justice

and attempt to destroy men's souls. I believe Judge Sohigian

intended only that I cannot make my organizational experiences,

which are unique to me, available as testimony to claimants or

intended claimants except pursuant to a subpoena. For seventeen



months I have been Ford Greene's sole office helper. I cannot

always tell who is phoning Mr. Greene's office before I speak to

the caller, and sometimes the callers are people litigating

claims against the organization. These same litigants send mail

to and receive mail from Mr. Greene's office. It would be

unprofessional, discourteous and suicidal to not assist those

people by not taking their calls, refusing to handle their mail

or not signing proofs of service if I do handle their mail.

These are clerical tasks which anyone without any organization

experience can perform, and, I believe, are included in Judge

Sohigian's specific non-prohibition from "engaging in gainful

employment rendering clerical or paralegal services not contrary

to the terms and conditions of this order."

    11. Ms. Bartilson states in her declaration:

"In July, 1992 following my receipt of a copy

of a ruling of Judge Ideman in Aznaran v.

Church transferring that case from the

Central District of California to the U.S.

District Court in Dallas, Texas, I received a

telephone call from Armstrong in which he

stated that he was calling from Mr. Greene's

office and that he needed to receive

immediately by fax such transfer ruling of

Judge Ideman. I told Armstrong that the May

28 Order prohibited him from assisting the

Aznarans or any other litigants against the




Church. He replied that he was trying to

help the Aznarans. On behalf of my client

the Church, I allege that the statements made

by Armstrong as relayed in this paragraph are

acknowledgements by Armstrong of his

awareness of the May 28 order, his ability to

act in compliance of such order and his

intention to wilfully disobey its terms."

(LJB Dec. p. 5, para. 9)

Ms. Bartilson's averments are in a different firmament from the

realm of truth. On Friday, July 10, 1992 at approximately 2:10

P.M. Ms. Bartilson called Mr. Greene's office. I answered the

phone, and she asked for Mr. Greene. I advised her that he was

in court. Ms. Bartilson gave me the message that the

organization was filing an ex parte application for relief in

Aznaran from the US District Court's order of June 25, 1992,

attached hereto as Exhibit [A]. She then said, sarcastically,

"You'll just relay the message, right? You won't do any work on

the case?" Because I knew Mr. Greene's office had not received

the order, concerning which Ms. Bartilson was going to be seeking

the ex parte relief, I attempted to relay her message to Mr.

Greene's co-counsel on the Aznaran case, John C. Elstead, who I

thought would have the order. Mr. Elstead's secretary, however,

advised me that he was in Idaho and that she did not know if he

had the order. Because of my understanding of notices of ex

parte applications, because it was Friday afternoon, because I



did not know how long Mr. Greene would be gone from the office

and I had no way of contacting him, because Ms. Bartilson had

already called me and announced the fact of the order and spoken

to me about the ex parte application, and because the relay of

such communications and documents is merely common courtesy

between people in the law business, I called Ms. Bartilson back

and asked her to fax the order she was referring to. Ms.

Bartilson said she wouldn't fax the order unless someone else in

Mr. Greene's office asked for it. I simply said that I was

trying to help her by making sure the information to Mr. Greene

was complete. In her attitude and comments Ms. Bartilson was

snotty, and in her present declaration shameless. The order

granting defendants' motion to transfer the Aznaran case to

Texas, attached hereto as Exhibit [B], was signed on August 26,

1992, a month and a half after Ms. Bartilson's call to me on July

10. She is also fibbing about who I said I was trying to help

and who called whom.

    12. Ms. Bartilson states that in my deposition in this case

taken on October 8, 1992 I admit that I was assisting three

persons, Tillie Good, Denise Cantin and Ed Roberts, and that

whatever it was I said indicates my intention to wilfully disobey

the Sohigian ruling. (App. p. 7, l. 18; LJB Dec. p. 6, para 12)

Yet there is not one word in the deposition pages Ms. Bartilson

cites to that shows I assisted Ms. Good, Ms. Cantin or Mr.

Roberts in violation of the Sohigian ruling. I did not assist

them and I did not violate the ruling.



    13. Ms. Bartilson charges that my interviewing Mr. Roberts

violates the letter and spirit of the May 28 order. (App. p. 8,

19, 20) She fails, however, to provide the date of said

interview. It was November, 1991, six months before the Sohigian


    14. Ms. Bartilson states that my assisting in the relay of

communications between Richard and Vicki Aznaran and Ford Greene

are violations of the Sohigian ruling, for which I should be

found in criminal contempt and jailed. (App. p. 7, l. 5) Her co-

counsel, Andrew Wilson, however, during my deposition in this

case on July 22, 1992, clarified what office clerical duties he

considered were not prohibited by the Sohigian ruling.

"If you answer the phone because one of your

duties is to answer the telephone in the

office, that is not part of your duties as a

paralegal on the Aznaran case.

"if the communication was 'have Mr. Greene

call me,' I wouldn't consider that a

paralegal duty."

(Pages 190, 191 from 7/22/92 deposition, attached hereto as

Exhibit [C]) I took Mr. Wilson's comments to mean that he

recognized that clerical duties which could be performed by

anyone were not prohibited by the Sohigian ruling. I also took

his comments to mean that he was going to interpret the ruling

sanely, and certainly not in the absurd manner Ms. Bartilson has.

I did not consider that when Mr. Wilson was making his statements



he was inviting me to violate the organization's interpretation

of the Sohigian ruling so I could be found in criminal contempt

and jailed.

    15. Ms. Bartilson states that in my letter of December 22 I

include the payment of an unspecified amount to Mr. Roberts as a

condition to ending my "campaign of harassment against the

Church." (App. p. 8, l. 16) Making Mr. Roberts whole

financially is not a condition to anything. I have no campaign

of harassment to be able to end. The organization has a campaign

of harassment toward its innocent members and innocent non-

members, which I have attempted with my December 22 letter to

resolve peacefully. And the organization is, in its present

philosophy and form, not a church.

    16. Ms. Bartilson charges that I sent copies of my December

22 letter to 35 individuals in what can only be described as

deliberate harassment. (LJB Dec. p. 7, para. 14) I, however,

describe my letter differently, and I am not alone. Sending the

letter to the various organization addressees made sense because

they have a right to know about the risk at which they are being

put by the organization's leaders, and because I have a duty to

mitigate my damages in this case. Sending the letter to the non-

organization addressees was a logical courtesy because they are

all affected by the Armstrong litigation, the obstruction of

justice spawned by the organization's settlement agreements, the

Sohigian ruling, and most certainly would be affected by the

organization's ceasing its seemingly ceaseless attacks. I don't



believe any court will order me to not mitigate damages in this

litigation, nor do I believe that any court will order me to not

attempt to make peace with the organization and not attempt to

end the organization's antisocial attitude and actions in order

to avoid a significant human catastrophe. If the organization

transformed its attitude and actions, as they are directed at its

erroneously perceived enemies, into something different from

antisocial, I would be more than willing to desist in my efforts.

    17. Ms. Bartilson describes CAN as "an antireligious group

that advocates the kidnapping and forcible 'deprogramming' of

individuals belonging to religions." (LJB Dec. p. 8, para. 17)

Because of what I learned over the past year and a half of the

organization's attack of CAN and to see for myself what was the

truth I attended CAN's 1992 annual conference, which was held

this past November in Los Angeles. I am thoroughly convinced

that CAN, unlike its attacker, is completely non-antireligious.

I am religious, and CAN, unlike the organization, has never

attacked me. I am also convinced that not only does CAN not

advocate kidnapping and forcible deprogramming of individuals

belonging to religions, it does not advocate kidnapping and

forcible deprogramming of individuals belonging to non-religious,

antisocial hate groups like Scientology. The organization as a

hate group was in full force at the CAN conference with lawyers,

private investigators, thugs and paid picketers whose sole

purpose for being there was to harass CAN members, most of whom

are innocent people of good will whose families or lives have



been hurt by the organization or other cults of a similar

antisocial and destructive stripe.

    18. Ms. Bartilson charges that my making of a videotape of

an interview with Jerry Whitfield is a deliberate violation of

the Sohigian ruling. (App. p. 9, l. 19) She goes on to state

that my production of the videotape interview

"demonstrate[s] most eloquently the contempt

which Armstrong has for the legal process,

plaintiff's rights, and this Court. His

defiance is not accidental or a misstep: it

is deliberate, flagrant, defiant contempt.

If ever a case cried out for the issuance of

an order to show cause, this is the case."

(App. p. 10, l. 16)

The videotape interview is not a violation of the Sohigian ruling

because it does not assist any claimant against any organization

entity in any claim, arbitration or litigation. It is indirect

passive assistance to everyone just as breathing is, and cannot

be enjoined by the ruling unless the ruling is interpreted in a

foolish manner. As explained in paragraph 10 above, I do not

interpret the Sohigian ruling as the organization does because to

do so would be foolish.

    19. Ms. Bartilson claims that Mr. Whitfield is an anti-

Church litigant (App. p. 8, l. 26), and that I made the videotape

for possible use in the case of Angel Casillas v. Jerry & Hana

Whitfield , Los Angeles Municipal Court Case No. 91K49349 (App.



p. 9, l. 14; LJB Dec. p. 10, para 22). The Sohigian ruling, no

matter how the words are interpreted only enjoins me from

assisting claimants or intended claimants against the

organization. It mentions nothing about individuals or groups

defending against organization claims; therefore I am not

enjoined from assisting Mr. Whitfield in the Casillas case.

Notwithstanding that fact, the videotape was not made for use in

the Casillas case, and I have not assisted Mr. Whitfield in that


    20. Ms. Bartilson seems to also recognize the distinction

the Sohigian ruling makes between claimants against the

organization and defendants against the organization because she

carefully explains that

"[w]hile the Church is not presently suing

the Cult Awareness Network in any litigation,

the president of the Cult Awareness Network,

Cynthia Kisser, has initiated an action

against the Church and its president Heber

Jentzsch." (LJB Dec . p. 8, para. 17)

There is no way whatsoever that I will ever be convinced by such

assertions, no matter who makes them, especially an in-house

organization Scientologist lawyer, whose office doubles as the

organization's infamous intelligence bureau, OSA, the Office of

Special Affairs. It is my firm belief that each and every one of

the some thirty lawsuits filed by "individual" Scientologists

against CAN across the United States within the past year has



been fomented, written, filed, financially supported, supervised

by the organization and controlled by its leader. If David

Miscavige, the organization's admitted supreme leader, ordered

the dismissal of any or all of the lawsuits against CAN, it would

be done without objection. The organization's use of cutout

litigants as fronts and getting them to do some of its dirty work

in harassing perceived enemies is common knowledge. Having its

agents, lawyers, members and litigation shills lie about who

their controllers are, or about any other subject as ordered, is

standard organization practice which is also common knowledge.

Because the organization is behind the lawsuits against CAN, I am

free to provide CAN my assistance in its defense. If indeed the

organization is not behind the lawsuits against CAN, and I

completely reject such a position, then I am free to assist CAN

in those lawsuits for the very reason that organization entities

are not parties. If, as Ms. Bartilson perceives it, I cannot

assist anyone in litigation in which organization entities are

not parties, then I would have to retire as a paralegal, and

could never become a lawyer, or for that matter a postal worker

or cabby. I cannot see that Judge Sohigian envisioned such

madness in his ruling.

    21. Ms. Bartilson also charges that the videotape was


"for Whitfield's use in forcible

deprogrammings to force unwilling

Scientologists to renounce their faith."

(App. p. 9, l. 12; p. 10, l. 11)



I have known Jerry Whitfield for approximately six years, and

have known his wife, Hana, for approximately twenty-two years.

The Whitfields perform a function termed "exit counseling," which

involves the education of individuals, who, as Judge Sohigian

stated, "get themselves enmeshed in [the organization's]

extremist view in a way that makes them unable to resist it

apparently," at the request of such individuals' families, in

aspects of the organization which have been deliberately kept

hidden from the individuals while under the organization's

control. Hana Whitfield was a senior aide to L. Ron Hubbard,

worked with him personally, and managed sectors of the

organization for him for many years, so is an ideal person to

educate individuals enmeshed in the organization's extremist view

in the dark and secret side of Scientology that is concealed from

all but the organization's few leaders while they are inside.

That the Whitfields are involved in "forcible deprogrammings" is

a "black PR" attack invented out of whole cloth by the desperate

organization leaders. Black PR or "black propaganda" is a term

used by Hubbard to describe his organization's efforts to destroy

people's reputations with lies and intelligence operations

involving, inter alia, forgeries, frame-ups and entrapment. The

work the Whitfields have been doing is dangerous, because they

are the targets of the organization's doctrine and system of

opportunistic hatred, also called fair game; but there is no

evidence that I am aware of that they have forced anyone to do

anything, or forcibly detained anyone. Scientologists do not




have a faith which can be renounced, if by faith is meant

anything approximating a system of religious belief. L. Ron

Hubbard wrote that Scientology does not depend on belief or

faith. He also wrote that Scientology does not consider or deal

with God, and he attempted to mock God in his organizational

policies. What exit counseling consists of is getting enmeshed

individuals to examine the fact that they have been led by deceit

and coercion to put their faith in secular representations of

secular leaders who do not have their best interests in their

minds and hearts and who are turning their good will against

their families, friends, society and themselves; and that these

leaders are effectuating this perversion of the spirit and will

by the secular means of threat, isolation, lies and denial of

access to facts and the truth.

    22. Ms. Bartilson argues that

"incarceration is an unusually viable vehicle

for impressing upon Armstrong the import of

his obligations, inasmuch as Armstrong has

publicly disavowed money as a meaningful or

valuable commodity." (App. p. 13, l. 11)

Ms. Bartilson supports this argument with a copy of an article

concerning my economic philosophy which appeared November 11,

1992 in the Marin Independent Journal. My present position is

that although money has no value, until it is no longer currency

I will accept what I am given and use it for God's work in the

recognition that all that I am given, including money, has one



Source. My economic theories, however, are no basis for my being

jailed. Following Ms. Bartilson's logic, if incarceration did

not restrain me from helping my fellow men, execution would then

become "an unusually viable vehicle" to get my attention.

    23. The organization's use of this innocuous article from

my local newspaper argues strongly for why I must speak out and

must do what I can to end the organization's mad war with

everyone. In the organization's reply memorandum in support of a

motion to strike my cross-complaint and for sanctions filed in

this case on November 24, 1992, and to which the Marin IJ article

is attached as an exhibit, Ms. Bartilson states that

"just last week Armstrong chose to

gratuitously disclose information concerning

the settlement agreement, in another

violation of its specific terms, to a

reporter interviewing Armstrong on a

completely unrelated subject...Armstrong

refused to testify concerning some of this

same information under oath in deposition in

this action, claiming that his side agreement

with his former lawyer precluded him from

disclosing the amount which he received in

settlement to anyone...Obviously, Armstrong

had no such compunctions about disclosing the

amount to a reporter."

Page 2 from the organization's reply is attached hereto as



Exhibit [D]. In the organization's motion to compel answers to

deposition questions and the production of documents pursuant to

notice of deposition, filed in this case on January 6, 1993, and

to which the Marin IJ article is also attached as an exhibit, Ms.

Bartilson states that "Armstrong has told the media how much he

was paid in settlement." Page 9 from the organization's motion

to compel is attached hereto as Exhibit [E]. In the organization's

November 1992 edition of their publication, "Membership News, "

which is a hate parody of CAN's publication "Cult Awareness

Network News," the organization cites to the Marin IJ article,

lifts the IJ's photograph of me, describes me as looking " like a

cross between Charles Manson and a throwback to the Haight-

Ashbury days of acid trips," and insinuates that I urge

"kidnapping-for-free." The relevant page from the organization's

"Membership News" is attached hereto as Exhibit [F]. I did not

tell the Marin IJ reporter Richard Polito the amount of the

settlement payment, and the organization knows that fact because

its agent, private investigator Eugene M. Ingram, who has

threatened to kill me, who at the CAN conference accused me of

having AIDS and spread that diseased rumor at the conference, who

illegally videotaped me, who framed my lawyer Michael Flynn, who

has filed trumped-up bar complaints against Ford Greene, and who

has harassed countless innocent individuals on the organization's

orders, was told by Mr. Polito back in November 1992 when he

visited the IJ office to "investigate" me that Mr. Polito did not

get the information concerning the organization and the



settlement from me but obtained it from a clip the IJ maintained

in its own files. A copy of the Marin IJ article of March 21,

1992, which mentions the litigation, the settlement and the

$800,000 figure, which facts did not come from me, is attached

hereto as Exhibit [G]. I am a writer, artist and philosopher. I

am the president of The Gerald Armstrong Corporation, I am

involved in charitable projects internationally, and I have been

given the formula for the Unified Field. The organization has

demonstrated by its misuse of the Marin IJ article that it will

attack me and my public persona in whatever I do in life, no

matter how philanthropic my endeavors, or how unrelated they are

to the organization. In the instant application Ms. Bartilson

uses the article to support the organization's effort to have me

thrown in jail. The organization has disrupted every aspect of

my life and will continue to disrupt it and attack everything I

do, even if it means denying the world a way by which some of its

serious problems might be solved.

    24. This is not the first time the organization has

attempted to have me charged criminally and not the first time it

has concocted an effort to have me found in contempt of court.

It tried in 1982 to have the LA Police Department arrest me for

sending documents to my lawyer after it had sued me civilly

concerning the documents and after the subject documents were

surrendered to the clerk of the LA Superior Court. In that case

I was found by Judge Breckenridge, because of the organization's

antisocial nature and acts and my knowledge thereof, to have been



manifestly justified in my actions. The organization tried in

1985 to have the Boston office of the FBI charge me with

impersonating an FBI officer, based on the false statements of an

organization agent. In 1986 the organization attempted to have

the Los Angeles District Attorney charge me as a result of

Ingram's illegal videotaping of me. The LAPD officer involved

with Ingram in the scheme, who was paid at least $10,000 for his

help, was suspended from the force. The DA rejected the

organization's efforts. In Armstrong I, the organization

attempted three times to manipulate the Court into holding me in

contempt. Each of these efforts, all of which were based on the

organization's false sworn statements, was rejected. In this

case, in March, 1992, the organization attempted to have Marin

Superior Court Judge Michael B. Dufficy hold me in contempt of

court. The copy of the Marin Independent Journal article of

March 21, 1992, Exhibit [G] hereto, is an exhibit to that

application, which was also supported by a perjurious declaration

of Laurie Bartilson, and also rejected. So far the organization

pretends to not get the message: that its unscrupulous use of the

courts and law enforcement agencies to attack and threaten

innocent people is recognized for what it is and will not be

tolerated in our society.

    25. I do not believe Ms. Bartilson is a bad person, nor do

I think she honestly believes I am a bad person. I believe she

is deeply troubled by being compelled to perjure herself over and

over and compelled to attack me because she knows I am not the



villain she must make me out to be. I believe she is deeply

troubled by her attacks on CAN, the Whitfields and countless

other people of good will the organization considers targets. I

believe she is deeply troubled by her abuse of the position,

knowledge and rights of officers of the court, and the

organization's use of her professional status. She demonstrates

why people under the organization's control, whether they be

lawyers, doctors, peace officers or postmen, cannot and should

not be trusted. Only the organization's public and honest

renunciation of its antisocial philosophy and practices, and

release of all of those professional and ordinary people from its

control, will render such Scientologists again as trustworthy as

any other free people. Ms. Bartilson is under her organization's

leader's malevolent thumb, she cannot make her own decisions, she

is deluded, dishonest, and frightened. To do what she does she

accepts the organization's pronouncement that Gerry Armstrong is

a "suppressive person," that he is one of the "2 1/2 percent"

most evil persons in the world, that he is "psychotic," driven by

"hidden evil intentions," and "truly insane," that he threatens

the whole future of all mankind, that he really is not worth

saving, and that it is, therefore, pro-survival, ordered and

praiseworthy to attack him. The organization's "legal" position

regarding enquiry into the "suppressive person" doctrine and

attitude, is that it is protected "religious belief," and the

literature, including orders thereon, which must be obeyed, is

"scripture." That may be, in that persons and thoughts are holy,



but by its own choice the organization has brought its socially

repugnant "religious" doctrines into the secular legal arena for

a secular purpose. If Ms. Bartilson rejected the organization's

pronouncements she knows that she would herself be labeled

"suppressive" and herself become fair game's target. She also

knows that the organization has real lawyers doing real things

with real private investigators with real guns, all of whom are

making real money at their tasks, and that that is the real level

to which the organization leaders have taken their unpleasant

game in the real world. In her application Ms. Bartilson asks

for real law enforcement personnel with real guns to really lock

me up in a real jail for real time. Ms. Bartilson should not be

condemned for being manipulated by the organization's

malevolence; she, as all victims, should be viewed with much

compassion. At the same time, she should be restrained and

brought to understand that her acts are malicious, silly and

unacceptable from a member of the bar and society.

    26. The picture the organization is painting and would have

this Court believe is real is that I view the Los Angeles

Superior Court, the Sohigian ruling, and Judge Sohigian with

contempt, and that my acts demonstrate that contempt. My acts,

what I did and said, are detailed above, and I believe

demonstrate something different from contempt. I do not deny

that I was, until I, in my opinion, understood it and resolved

for myself its practical application, perplexed by the Sohigian

ruling. I believe strongly, however, that I have respected the



ruling and, although, as stated above, I believe that, even as I

interpret and respect it, the ruling is illegal, I have not acted

in any way in contempt of it. I believe that Judge Sohigian

created with his ruling an invitation for me to appeal it, and

provided within the ruling itself the appeal's grounds: its

fuzziness, its contradictions, its departure from his hearing

comments, its rewriting of the settlement agreement's

prohibitions, and its statutory and constitutional violations. I

believe Judge Sohigian's ruling strategically left the

organization, because it escaped with sudden relief after the

previous day's hearing in which lie sharply censured its unsavory

practices, unwilling to appeal the ruling. This unwillingness is

something different from the organization's pattern of appealing

everything that can be appealed, and strikingly so here because

Judge Sohigian refused to enforce all but the narrowest slice of

the settlement agreement, and even that he rewrote in my favor.

I believe he offered the organization an opportunity to redeem

itself and it is now clear that his offer has not been accented.

I respect Judge Sohigian's intellect and person and am thankful

he heard the injunction aspect of my case.

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

State of California that the foregoing is true and correct.

Executed at San Anselmo, California. on February 2, 1993.

[Signed] G. Armstrong




© Gerald Armstrong

Exhibit [A]
Ex parte application for relief in Aznaran from the US District Court's Order of June 25, 1992

Exhibit [B]
Order granting defendants' motion to transfer the Aznaran case to Texas 08-26-1992

Exhibit [C]
Armstrong Deposition Pages 190, 191 07-22-1992

Exhibit [D]
Organization's reply to Marin IJ article

Exhibit [E]
Page 9 from the organization's motion to compel

Exhibit [F]
Relevant page from the organization's "Membership News"

Exhibit [G]
Marin IJ article 03-21-1992


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