I, Gerald Armstrong, declare

     1. I am making this declaration to support an opposition to the motion of Church of Scientology International, hereinafter referred to, along with the rest of Scientology's command and control structure, as "the organization," to compel answers to deposition questions and the production of documents.

     2. The organization is run as a criminal operation with a stated goal of world domination, which is to be accomplished by, inter alia, the elimination of all its perceived opponents. I have been involved in litigation with the organization since 1982, I was inside the organization from 1969 to 1981, spent a great deal of time with its founder and leader L. Ron Hubbard, and I have intimate knowledge of its antisocial and criminal nature, intentions and practices. I am an expert in the fraudulent representations of Hubbard and his organization, and I am an expert in its basic philosophy and practice which Hubbard, termed "fair game." The fair game doctrine states that anyone declared an enemy of the organization or "suppressive person"

"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 destroyed." [1]

The organization claims that this doctrine has been canceled, but I know that claim to be merely an instance of fair game - a lie. Fair game, the organization's most basic philosophy, is accurately defined as opportunistic hatred; that is to say, it uses whatever opportunity it has to put its self- generated hatred into practice. Even the organization's hatred is opportunistic; it is generated knowingly and intentionally for the calculated purpose of excusing and justifying its criminal acts. This opportunistic hatred flows from the conscious determination of Hubbard, who programmed himself, as shown in his own documents which were admitted into evidence at trial in the case of Church of Scientology of California v. Gerald Armstrong, Los Angeles Superior Court Case no. C 420153, hereinafter referred to as Armstrong I, to hate mankind and use that hate to dominate it. Hubbard stated that "all men are [his] slaves," and that he had "the right to use men's minds as [he] wished." [2]Hubbard was a megalomaniac who stated that he was "given this sector of the universe to control." My study of Hubbard's life and his writings, some 500,000 unpublished pages of which I possessed while inside the organization, showed that he hated women, African-Americans, Jews, children, doctors, the clergy, writers, judges, anyone in any walk of life, and especially hated Scientologists. Pursuant to fair game, since I left the organization's clutches, I have been assaulted, run into bodily by an organization agent's car, almost involved in a freeway "accident" by another, threatened with assassination, sued twice and threatened with lawsuits another five times, illegally videotaped, and framed with crimes. At least three times the organization attempted to have false criminal charges filed against me, and another four times has attempted to have me held in contempt of court based on its false statements. It has paid corrupt private investigators to make false sworn statements about me and paid at least one corrupt Los Angeles Police Officer for his assistance in framing me. Its personnel and its lawyers have filed countless perjurious sworn statements about me in courts around the world. It has carried out a massive "black propaganda" campaign among its members and in the media internationally aimed at destroying my reputation and credibility. One of its private investigators was paid to spread the rumor, less than three months ago, that I have AIDS. It has subjected me to some thirty days of depositions and fifteen days of cross-examination in trials. It has attacked my church and its members. It has stolen from me an extremely valuable manuscript, photographs, original art and other documents. It has surveiled me constantly and harassed my friends, family and neighbors. Its agents caused me problems at my first job after I left the organization, it terrorized my fellow workers and harassed my bosses. It extracted whatever statements it considered would embarrass me from my supposedly confidential "auditing," or counseling files, and used them for that purpose. It used a friend to get close to me, betray me and set me up in an intelligence operation to frame me with a crime. It sued my former lawyer, Michael Flynn, some fifteen times, filed false bar complaints against him, infiltrated his office, stole documents, framed him with the forgery of a $2,000,000 check, according to him attempted his assassination, threatened his law practice, family and life, ruined his marriage, and finally drove him, out of his desperation to end the threats, to desert me and sign a contract with the organization specifically to not help me in my battle against its criminality. In December 1986, in order to free Michael Flynn and several other people from the organization's attacks, I signed a settlement agreement, which Mr. Flynn advised me was unenforceable, and which the organization, having contracted away Mr. Flynn from representing or helping me, is now attempting to enforce in the instant lawsuit. The organization is right now using this Court, in an effort, based on the perjured declaration of a Scientologist lawyer, Laurie Bartilson, the very same who has authored this motion to compel, to have me jailed for violating that unenforceable agreement. The organization has filed false bar complaints against my present lawyer, Ford Greene, infiltrated his office, stole documents, attempted to have him held in contempt of court based on its false statements, threatened him, subjected him to constant surveillance, harassed his friends, and disrupted his law practice and life. The organization has now initiated a campaign of harassment toward another of my lawyers, Michael L. Walton, with a patently frivolous deposition, a demand for his personal records and his client files, the direct threat to force him and his family from his house, and the implied threat to his law practice, family and life. Judge Breckenridge stated in his decision in Armstrong I, affirmed on appeal in Scientology v. Armstrong, (1991) 232 Cal. App. 3d 1060, 283 Cal. Rptr. 917 [3]:

"In 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 Church whom it perceived 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."

The organization's stated policy regarding our court system is to use it "to harass" opponents and "ruin them utterly." The organization seizes every opportunity to use the courts as a tool of fair game. It is right now using this Court in its effort to deny me employment, ruin me economically, and have Ford Greene removed from effectively defending me. This is the organization which now asks this Court to assist it to further its malevolent goals. This is the organization which now asks this Court to compel me to answer its irrelevant but malevolently intended questions, and to compel me to provide it with documents to which it has no legitimate right, but which it has not so far been able to steal. This is the organization which Judge Breckenridge found in 1984 to have unclean hands [4]. Not only has this organization not washed them since, they have added layer upon layer of crime and carnage. I will not be this organization's willing victim even if it kills me.

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 3, 1993

GERALD ARMSTRONG

[1] HCO PL 18 October 1967 PENALTIES FOR LOWER CONDITIONS © 1967 L. Ron Hubbard

[2] The Admissions [.pdf ]

[3] 283 Cal. Rptr. 917 [.pdf]

[4] The Breckenridge Decision [.pdf]