Gerry Armstrong--"I Declare"

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I DECLARE

A Literary Work Created and Written
by
GERALD ARMSTRONG

I DECLARE
Copyright © 1994 Gerald Armstrong
All Rights Reserved

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I DECLARE

Declaration of Gerald Armstrong

I, Gerald Armstrong, declare:

1. I am a defendant in the case of Church of Scientology International v. Gerald Armstrong,

Michael Walton and The Gerald Armstrong Corporation, Marin Superior Court case no. 157680,

filed July 23, 1993, hereinafter "Armstrong IV." I am making this declaration for all purposes,

including the disposing of the Armstrong IV complaint, which, for literary purposes, is appended

hereto as Exhibit [A].

2. I am a defendant in the case of Church of Scientology International v. Gerald Armstrong

and The Gerald Armstrong Corporation, Los Angeles Superior Court case no. BC 084642,

hereinafter "Armstrong III," filed July 8, 1993. I am a defendant and cross-complainant in the

case of Church of Scientology International v. Gerald Armstrong and The Gerald Armstrong

Corporation, Los Angeles Superior Court, filed February 4, 1992, in Marin Superior Court as

case no. 152229, and transferred March 20, 1992 to Los Angeles Superior Court and given

case no. BC 052395, hereinafter "Armstrong II." I am the defendant and cross-complainant in

the case of Church of Scientology of California and Mary Sue Hubbard v. Gerald Armstrong,

Los Angeles Superior Court case no. C 420153, hereinafter " Armstrong I," filed August 2, 1982.

3. I am a writer, artist and philosopher. I am the founder of and present majority shareholder

in The Gerald Armstrong Corporation, hereinafter "TGAC," also named as a defendant in

Armstrong II, III and IV. I am the sole office support of attorney Ford Greene in San Anselmo,

California. Mr. Greene represents me in Armstrong IV, and, along with attorney Paul Morantz

of Pacific Palisades, California, in I, II and III.

4. I was involved inside the Scientology organization, hereinafter the "organization," from

1969 through 1981 and held many staff positions in the Sea Org, Scientology's elite

quasiparamilitary core. I gained a knowledge of organization policies and operations, worked

closely for period with its founder and leader L. Ron Hubbard, and during my last two years

inside did the research for a biography to be written about the man. I have detailed my

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organization experiences in many declarations and have testified in organization litigation in

depositions and at trials approximately 55 days in some 20 lawsuits from 1982 through 1993.

5. On June 20, 1984, following a lengthy bench trial in Armstrong I, LA Superior Court

Judge Paul G. Breckenridge, Jr. issued a memorandum of intended decision, a copy of which is

appended hereto as Exhibit [B]. Finding in my favor, he wrote, inter alia:

"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 [organization] 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." (Ex. B, at p. 8, l. 18)

On July 20, 1984 Judge Breckenridge ordered that his intended decision be deemed his statement

of decision, and on August 10, 1984 entered it as judgment. The organization appealed.

6. On July 29, 1991 the California Court of Appeal, Second District, Division 3 issued its

opinion, a copy of which is appended hereto as Exhibit [C], affirming the Breckenridge decision.

The Court of Appeal stated, inter alia, that the organization's " suppressive person declares" had

"subjected Armstrong to the 'Fair Game Doctrine' of the [organization] which permits a

suppressive person to be 'tricked, sued or lied to or destroyed...[or] deprived of property or

injured by any means by any Scientologist....'" (Ex. C, Church of Scientology v. Armstrong,

283 Cal. Rptr. 917, at p. 920)

7. The Armstrong I cross-complaint, which, on the organization's motion had been bifurcated

from the underlying case before the 1984 trial, settled in December, 1986. Armstrong II and III

are breach of contract actions for damages and enforcement of the conditions of the central

document in the settlement entitled "Mutual Release of All Claims and Settlement Agreement,"

hereinafter the "settlement agreement," which the organization has attached as an exhibit to its

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Armstrong IV complaint, and which is appended hereto as Exhibit [D].

8. I am an expert in the identification of the organization's fraudulent nature, practices and

statements, and "fair game," the organization's fundamental philosophy and practice of

opportunistic hatred, and I have testified as an expert in these areas. Because of what I know

and my willingness to communicate freely to anyone who wants to hear, I am fair game's target.

I have been subjected to the organization's cynical and dangerous legal and extralegal operations

from 1982 to the present. I have documented dozens of instances of fair game in action toward

me in my earlier declarations and oral testimony. See, for example, paragraphs 6 through 9 and

19 and 20 of my declaration of March 16, 1992, a copy of which is appended hereto as Exhibit [E],

filed in Armstrong II in Marin County in opposition to Scientology's motion for a preliminary

injunction. The Armstrong IV lawsuit is another instance of fair game. It is based on the

perjurious statements of organization lawyer Andrew H. Wilson, it is meritless and malicious.

9. The central charges of the Armstrong IV complaint are that:

(a) beginning in February, 1990, and continuing until the present I wilfully and

repeatedly violated the settlement agreement;

(b) fearing that the organization would seek to collect the damages, which it claims to be

due pursuant to the settlement agreement's liquidated damages clause, I conspired with

Michael Walton to fraudulently convey to him in August 1990 my interest in the real

property situated at 707 Fawn Drive in Sleepy Hollow, Marin County, California, for the

purpose of rendering myself "judgment-proof;"

(c) in 1988 I transferred my material assets to TGAC at the time I embarked on a

campaign to harass the organization with the intention of preventing the organization

from collecting money from me pursuant to the liquidated damages clause, and that

TGAC exists solely to make me judgment-proof;

(d) in August, 1990 I transferred to Michael Walton cash and stock in TGAC with the

intent to defraud the organization in the collection of its damages; and

(e) the organization should get $4,800,000.00 for all this fraud.

10. I will deal first with certain specific averments in the complaint; then with certain material

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facts which the organization and its lawyer, Mr. Wilson, were aware of before filing the verified

complaint, but which have been disregarded in favor of fakery; and finally I will provide additional

material facts and documentation to fill in any gaps in the historical events and their context which

underlie the complaint and support the inevasible conclusion that it is frivolous, malicious and

should be dismissed.

11. Mr. Wilson states:

"Armstrong, a former Church member who sought, by both litigation and covert means,
to disrupt the activities of his former faith, displayed through the years an intense and

abiding hatred for the Church, and an eagerness to annoy and harass his former co-

religionists by spreading enmity and hatred among members and former members."

(p. 2, l.4)

The organization, as it has been and is operated, is not a church. It is neither a house of worship

of God, nor a sanctuary for His children. Moreover, in Hubbard's claims of scientific verifiability

for his prohibitive psychotherapy he insisted specifically that Scientology's efficacy did not,

unlike religion, depend on faith. My Scientology involvement since I left from inside in 1981

has been with the organization's power structure; that is, the few who control all personnel,

communication and finance units and decisions, the organization's litigation machine, intelligence

and propaganda bureaus, its private investigators, and all of those segments' dirty tricks. My

message has been that the power structure's policies and actions to harass and destroy labeled

enemies, its doctrine of opportunistic hatred, and its spreading of enmity are not religious, not

effective, and have only brought the organization and Hubbard inevitable ignominy. My message

is that the only religious act in the world is forgiveness, that Hubbard lied when he defined

forgiveness as "condemnation," that he miscalculated madly when he attempted to program

himself with the idea that all men were his slaves, and then acted as if they were, and that the

organization could just as easily be engaged in the emancipation of its members as their

enslavement. I do not urge enmity among its members and former members even toward the

policies and practices of defrauding and brutalizing the innocent, but do urge understanding

and forgiveness. That I disrupt the power structure's activities - its rewriting of history, daily

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fraud, mockery of religion, use of the law to harass, assault on our justice system, abuse of the

good, bullying of the weak, and intimidation of those who should be the weak's defenders -

I admit. These antisocial activities will continue to be disrupted until the organization realizes

that such activities simply don't work, and out of self-interest forsakes the litigation business,

discontinues the war on the innocent, and either becomes religion or drops that immodest

mantle. But the disruption flows only from the organization's own antisocial actions, which

rebound on their manufacturer if any target stands up, doesn't duck and is willing to take a few

hits. I have no intelligence bureau, propaganda apparatus, private investigators, litigation

machine and no hundreds of millions to finance them. I have no fair game policy, and no

underlings to implement it if I did have one. I have no lawyers willing to lie for a little lucre and

no operatives to steal documents, frame judges, compromise jurors, trick, sue or destroy

invented and then targeted "enemies." Scientology's power structure is a big, black pot

desperately seeking kettles to tarnish.

12. Mr. Wilson states:

"[the organization] sought, with the Agreement, to end all of Armstrong's covert

activities against it, along with the litigation itself." (p. 2, l. 9)

I had no covert activities against the organization. It is the organization with its army of agents,

private investigators and lawyer cutouts which carries on its periculous, albeit ridiculous, covert

war. Hubbard patterned his espionage apparatus on the system developed by Hitler's spy master,

Reinhard Gehlen, and the power structure has continued Hubbard's dark and secret methods to

this day. The organization did not seek to end the litigation with me, and has not sought to end

its use of litigation to achieve its global antisocial goals. It sought to silence me with threats and

eliminate my ability to defend myself by contracting away from me my own attorneys, Michael

Flynn of Boston, Massachusetts and Contos & Bunch of Woodland Hills, California, who had

represented me throughout the Armstrong I litigation, so that it could keep its litigation machine

running, continue to obstruct justice, use the law to harass, deny redress to its victims, and

steamroll its opposition. Hubbard and his organization had ruthlessly and unremittingly attacked

Mr. Flynn, my good friend and the prime mover for seven years in a national effort to bring

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Scientology to justice, suing him some fifteen times, filing false bar complaints against him,

infiltrating his office, stealing documents, framing him with the forgery of a $2,000,000 check,

libeling him internationally, and, according to Mr. Flynn, attempting his assassination. The

organization threatened his law practice, family and life, hurt his marriage, and finally forced him,

in his desperation to end the threats, to sign a contract with the organization to not help me

should the organization attack me after the contract's signing. Even its own settlement

agreement (Ex. D) belies the organization's claim that it sought to end the Armstrong I litigation.

Paragraph 4B allows the organization, following the December, 1986 settlement, to maintain the

appeal from the Breckenridge decision, while requiring me to obstruct justice by not opposing

any future appeals. Coupled with the likewise illegal contracts requiring my attorneys to not

represent me in any such future appeals or in any action by the organization to enforce the

settlement agreement, the agreement's intended effect was to remove any opposition to the

organization's litigation juggernaut. My attorneys' signing of the non- representation contracts

is understandable and wholly excusable when the threat of the organization's attacks on them is

understood.

13. Mr. Wilson states:

"the Agreement contained carefully negotiated and agreed-upon confidentiality

provisions and provisions prohibiting Armstrong from fomenting litigation against [the

organization] by third parties." (Ex. A. p. 2, l. 12)

This is the big black pot feigning blindness by its layers of autogenous soot. The organization

is very likely the most litigious entity this world has ever known. I have consistently done

whatever I could to unfoment its litigation; in fact I have adjured it to get out of the litigation

business completely, and to seek solutions to its problems through peaceful means and open

and honest communication. So far it refuses to communicate with its targets, hides behind

corrupt lawyers, and rejects openness and honesty in favor of luciferian litigiosity. Fomenting

litigation is one of the organization's principal weapons in its war against its victims, its

critics, the justice system and the world. The declaration of U.S. District Court Judge James M.

Ideman dated June 17, 1993, a true copy of which is appended hereto as Exhibit [F],

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shows one respected jurist's insight into the organization's abuse of the legal process and its

fomentation of litigation:

"[the organization's] noncompliance [with the Court's orders] has consisted of

evasions, misrepresentations, broken promises and lies, but ultimately with refusal.

As part of this scheme to not comply, the [organization has] undertaken a massive

campaign of filing every conceivable motion (and some inconceivable) [Judge Ideman's

parens in original] to disguise the true issue in these pretrial proceedings. Apparently

viewing litigation as war, [the organization] by this tactic [has] had the effect of

massively increasing the costs to the other parties, and, for a while, to the Court. The

appointment of the Special Master 4 years ago has considerably relieved the burden

to this Court. The scope of [the organization's] efforts have to be seen to be believed

..... Yet it is almost all puffery -- motions without merit or substance."

(Ex. F, p. 2, para 4, 5; filed June 21, 1993 in Religious Technology Center,

Petitioner v. U.S. District Court, Respondent, David Mayo, Real Party in Interest,

No. 93-70281 in the 9th Circuit Court of Appeals)

14. Mr. Wilson states:

"In or about February, 1990, Armstrong began to take a series of actions which directly

violated provisions of the Agreement." (Ex. A., p. 2, l. 20)

In the fall of 1989, at the time I received a series of threats from organization lawyer Lawrence

E. Heller, and after enduring without response almost three years of post- settlement fair game,

I came to the conclusion that by allowing myself to be intimidated by the threats I would be

abetting the organization's obstruction of justice, and that I had an inalienable right, and

arguably even a duty, regardless of whatever the settlement agreement said, to not obstruct

justice. My first action, and my only action, in February, 1990, was to petition the California

Court of Appeal, Second District, Division Three for permission to respond in the appeal,

No. B 025920, from the 1984 Breckenridge decision, which the organization had been able to

maintain during all the intervening years. At the same time I petitioned Division Four of the

Second District for permission to respond in another appeal, No. B 038975, that the organization

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had taken from a 1988 Los Angeles Superior Court order granting the motion of contra-

organization litigant Bent Corydon to unseal the Armstrong I court file, which had been

sealed since the December, 1986 settlement. The organization opposed both petitions, Division

Three granted the petition to respond in the appeal from Breckenridge, and I filed a reply in

Division Four to the opposition in the unsealing appeal, supported by a declaration dated

March 15, 1990, in which I detailed many of the organization's post settlement threats and

attacks and stated my position regarding the unenforceability of several conditions of the

settlement agreement. The March 15, 1990 declaration, along with the exhibits thereto,

except for the Breckenridge decision (Ex. B to this declaration), is appended hereto as

Exhibit [G]. Since my documents were filed openly in the appeals and served on all opposing

counsel, the organization is fully aware of what I did in 1990, and that I had the Court of

Appeal's permission to do it. Mr. Wilson's allegation that I began in February, 1990 to directly

violate the settlement agreement contradicts an earlier allegation the organization and Mr.

Wilson made in the Armstrong II pleadings. In the amended complaint filed June 4, 1992,

a copy of which is appended hereto as Exhibit [H] , the organization states:

"As soon as he finished spending the money he extracted from [the organization]

as the price of his signature, in June, 1991, Armstrong began a systematic campaign

to foment litigation against [the organization] by providing confidential information,

copies of the Agreement, declarations, and "paralegal" assistance to litigants actively

engaged in litigation against his former adversaries." (Ex. H, p. 2, l. 27).

The June, 1991 date would not work well in the organization's Armstrong IV fraudulent

conveyance figment, so the February, 1990 starting date for my " violations" was fabricated.

Similarly the allegation would not work that as soon as I had finished spending the

settlement money I began whatever I did that the organization calls in its various documents

a "systematic campaign." I could have spent the money; I could have fraudulently conveyed

my assets; I couldn't have done both. I did neither. Nor did I begin a campaign, systematic

or not, to foment litigation against any of the organization's entities.

15. Mr. Wilson states:

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"Fearing that [the organization] would seek to collect the liquidated damages owed by

his breaches, Armstrong, .... fraudulently conveyed all of his property, including real

property located in Marin County, cash, and personal property to defendants Michael

Walton, the Gerald Armstrong Corporation, and Does 1-100, receiving no consideration

in return." (Ex. A. p. 2, l. 22)

I have never feared the organization collecting damages of any kind against me, nor even its

seeking to collect damages. I do have an undeniable concern that before it comes to its senses

or saner minds prevail in the organization the power structure will have me assassinated or do

something else diabolical and dangerous, and this has produced in me an awareness of threat

and is a fact of my present psychological condition. These people are quite capable of violent

and criminal acts, they are armed, and their head private investigator, Eugene M. Ingram, a

former LAPD vice sergeant, who is reported to have been busted from the force for pandering

and taking payoffs from drug dealers, in 1984 threatened to put a bullet between my eyes,

and in November, 1993 spread the rumor in broad daylight that I have AIDS. But I have

never feared that the organization can win in court or ever be awarded damages against me.

I do not believe any court in this country will order me to obstruct justice, not defend myself,

nor even not profit monetarily from, much less communicate about, on-going, open-court

lawsuits in which I have been sued for millions of dollars. The organization operates in

pretended blindness to the way rational people view its litigiousness, its abuse of process,

its greed and its suppression of its members' decent natures. My conveyance of 707 Fawn

Drive to Michael Walton, my forgiving of debts owed to me, and my giving away of cash,

personal effects and TGAC stock were not motivated by fear of the organization perhaps

suing me and conceivably, although not beyond improbably, being awarded monetary

damages in any such lawsuit. To the contrary, I believe that should any of the Armstrong II,

III or IV cases go to trial I will be awarded attorney's fees, costs and damages, and that either

the organization will agree to rescind the settlement agreement's unfair and unenforceable

clauses or our courts will rule them illegal. I had believed throughout 1990 and 1991 that it was

entirely likely that the organization would never sue me, even after attorney Heller's threats of

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litigation, since it had to know that it could never win in an uncompromised court, and that

any lawsuit it might bring against me would only bring it further disgrace. I gave away my

assets after a great deal of contemplation, which included acceptance of the fact that

thereafter if I stood up against injustice I would have to stand up to the organization,

and for that matter any organization, individual, army or nation, essentially penniless.

My amended answer to the Armstrong II amended complaint, a copy of which is

appended hereto as Exhibit [I], filed and served on Mr. Wilson October 8, 1992, states:

"Armstrong denies that he ever extracted money from the ORG. Armstrong

denies that in June, 1991 he had finished spending his money. In August 1990

Armstrong had given away all his assets for reasons unrelated to the ORG,

except that he evaluated that because the ORG committed so much harm with

its billions of dollars there was no reason not to give his money away, and

that it was better to combat the ORG's tyranny without money than not to

combat it with wheelbarrow loads of it. Armstrong denies that in June, 1991

he began any campaign, provided any confidential information to anyone,

copies of any agreement, declarations, and paralegal assistance to any

litigants."(Ex. I. p. 3, para. 3, l. 23)

I believe that in exchange for my willingness to renounce what were my worldly assets

in August, 1990, I have received consideration far beyond what I imagined at the time.

I could not and did not attempt to predict in August, 1990 what would happen in the

years that have followed. I proceeded with the faith that our Creator was the Source of

the idea of renunciation and that I could trust Him to guide me and care for all my needs.

The subsequent years have shown me that my willingness flowed from His grace and that

my trust was exceedingly well placed.

16. Mr. Wilson states:

"Armstrong caused his own personal assets to be transferred to [TGAC] without

adequate consideration in order to evade payment of his legal obligations, and

defendant Armstrong has completely controlled, dominated, managed and

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operated [TGAC] since its incorporation for his own personal benefit." (Ex. A. p. 4, l. 15)

"Armstrong transferred his material assets to [TGAC] in 1988, at the time of his

embarkation on the campaign of harassment..., and with the intention of preventing

[the organization] from obtaining monetary relief from Armstrong pursuant to the

liquidated damages clause. Hence [TGAC] exists solely so that Armstrong may be

"judgment proof." (Ex. A., p. 5, l. 3)

Again to make irrefutable facts fit his fraudulent conveyance fiction, Mr. Wilson has,

frankly, fudged. I incorporated TGAC in 1987 and activated it at the beginning of 1988. At

that time I also transferred to the corporation all my drawings and other artwork, writings,

rights thereto, office equipment and supplies, and I provided startup capital. In exchange I

received one hundred percent of TGAC's stock. Mr. Wilson's conclusion that one hundred

percent ownership of the corporation which owned my products, rights to their commercial

exploitation, plus office materiel was not adequate consideration for those products, rights

and materiel, is dissemblingly dense. His allegation that I embarked in 1988 on a campaign

of harassment is duplicitously daft. Yet this is utterly unsurprising standard Scientological

operating procedure. Very simply, the organization requires its members and its lawyers to

lie; and should they ever decide to stop lying, its members and lawyers become fair game.

The only thing I did in 1988 regarding the organization was to remain silent in the face of its

continuing post-settlement threats and attacks. Mr. Wilson's assertion that TGAC exists

solely to make me judgment proof, if it were not being made by an officer of the court under

the paw of the pestiferous power structure of this contumelious cult for its pernicious

purposes of revenge, fair game, black propaganda, attack on my friends, waste of everyone's

time, and my psychological and economic destruction, would just be faintly funniferous

flapdoodle.

17. Mr. Wilson states:

"The consideration paid to Armstrong was fair, reasonable and adequate."

(Ex. A., p. 7, l. 1)

I agree that the consideration was reasonable. The organization

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paid me as recompense for its fraud and abuse over the more than twelve years I devoted

to L. Ron Hubbard and for the five years of fair game harassment after I left. It settled with

me out of court in December, 1986 rather than face the trial of my Armstrong I cross-

complaint, then set for March, 1987. It again defrauded me at the time of the settlement

because it represented, through my attorney Michael Flynn, that it was discontinuing

fair game and getting out of the litigation business. It did not pay me, nor did it even offer

to pay me, to be fair game's willing victim and a tool the rest of my life in its abuse of our

justice system and suppression of our brothers.

18. Mr. Wilson is aware of the truth behind his untruthful statements in the Armstrong IV

complaint, but has chosen, in order to forward his client's malicious intentions, to ignore

that truth. He is aware, as shown in paragraph 14 above, since he is an attorney of record

in the case, that in the Armstrong II complaint the organization has claimed that in June,

1991 I began what it calls "a systematic campaign to foment litigation." Mr. Wilson, as

shown in paragraph 15 above, is also aware that I stated in my answer in Armstrong II that

I had given away my assets in August, 1990, for reasons unrelated to the organization.

These reasons are in truth irrelevant to any of the organization's claims in any of the

Armstrong cases, but incredibly have been made relevant by Mr. Wilson due to his

dishonest insistence, in order to justify his further harassment of me with the filing of

Armstrong IV, that my renunciation was the product of some conspiracy to defraud

the organization that pays him to attack me.

19. In my deposition in Armstrong II taken on July 22, 1992 by Mr. Wilson, pages 266

through 270 from the transcript of which are appended hereto as Exhibit [J], the following

exchanges occurred:

(For clarity I have integrated into the quoted sections the corrections I made in

the deposition transcripts in my reviewn of my testimony pursuant to the California

Code of Civil Procedure)

"Q. (Mr. Wilson) How about this, why don't you just tell me, tell me the business

of the Gerald Armstrong Corporation is.

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A. (Me) The Gerald Armstrong Corporation possesses a number of Gerald
Armstrong's artistic and literary works, possesses rights to a number of his

inventions and rights to certain formulas, and is in the business of bringing

peace and exploiting its assets for commercial and peaceful purposes.

Q. Okay. What does it do to exploit its assets for commercial purposes?

Make anything, sell anything?

A. It sells things and it makes things.

Q. What does it make.

A. It makes sculptures, cards, works of art, literary works, campaigns.

Q. What campaigns does it make?

A. It is a contributor and possessor of certain rights within the group known

as the Runners Against Trash and the same within the organization known as

the Organization of United Renunciants.

Q. What is the Organization of United Renunciants?

A. It is an organization dedicated to the preservation of the world through

peaceful means.

Q. What have the people in the organization renounced, if anything?

A. The people in the organization renounce money.

Q. Does that mean they give away their money?

A. They can if they want.

Q. Did you give away the money that the Church paid you in settlement?

A. Well, I'm, that's not a very well worded question, because I gave away all

my assets including my money.

Q. When?

A. When? August 1990.

Q. Who did you give it to?

A. A number of people.

Q. Can you tell me who they are?

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A. No.

Q. Did you give any of it to Michael Walton?

A. Yes.

Q. Why did you give it away?

A. Because I considered that I was guided to do so.

Q. By whom?

A. The Source of all that is.

Q. Who is that?

A. God.

Q. Now when God guided you to give away all your assets, did [H]e guide you to

give them to particular people or did you make that decision?

A. I believe that I was guided each step of the way.

Q. Okay. When you say you gave it away, I take it you didn't receive anything

in return in terms of monetary compensation?

A. Right.

Q. Can you tell me why you decided to give some of it to Michael Walton?

A. Because it was logical.

Q. Why?

A. And because I was so guided.

Q. Can you tell me what about it was logical?

A. I guess initially it's logical because he was a friend of mine in close proximity to

me, and I believed that he had a need at that time." (Ex. J. p. 266, l. 12 - p. 269, l. 3)

20. In my deposition in Armstrong II taken on October 8, 1992 by Scientologist lawyer

Laurie J. Bartilson, Mr. Wilson's co-counsel in II, III and IV, pages 459 through 475 from

the transcript of which are appended hereto as Exhibit [K], the following exchanges occurred:

" Q. (Ms. Bartilson) And if I ask you how much of the proceeds were still remaining

in your pocket at some period later when you gave away all of your assets on the

instruction of God, you won't tell me that either, correct?

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A. (Me) Correct. (Ex. K. p. 460, l. 25 - p. 461, l. 4)

Q. Does the Gerald Armstrong Corporation have any material assets?

A. Yes.

Q. Generally what are those assets, categories of things?

A. It owns original artwork and it has rights, inasmuch as such are assertable, in

certain inventions and formulas. (Ex. K. p. 463, l. 12 - l. 24)

Q. What is its (TGAC's) function?

A. It cares for, archives, promotes and exploits the works of Gerald Armstrong, and

it is a vehicle for peace." (Ex. K. p. 469, l. 19 - l. 22)

21. In my deposition in Armstrong II taken on March 10,1993 by Ms. Bartilson, pages

555 through 557 from the transcript of which are appended hereto as Exhibit [L], the

following exchange occurred:

" Q. Did you transfer that large body of work to The Gerald Armstrong Corporation

in August of 1990?

A. No. The Gerald Armstrong Corporation already owned those things.

Q. So was it The Gerald Armstrong Corporation transferring it away or the right

to it away?

A. The Gerald Armstrong Corporation owned a number of things. I gave away the

corporation. The corporation possessed a number of assets.

Q. So at the beginning -- at the end of the transaction the corporation still owned

the assets, but different people owned The Gerald Armstrong Corporation?

A. Correct.

Q. You are still a part-owner President of The Gerald Armstrong Corporation, are

you not?

A. I am now.

Q. But you were not in August of 1990?

A. Correct.

Q. You have since reacquired it?

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A. Correct.
Q. How much of the stock do you presently own in The Gerald Armstrong Corporation?

A. Eighty." (Ex. L, p. 556, l. 14 - p. 557, l. 11)

22. In the deposition of Michael Walton in Armstrong II taken on February 23, 1993

by Mr. Wilson, pages 39 through 42 from the transcript of which are appended hereto

as Exhibit [M], the following exchanges occurred:

" Q. (Mr. Wilson) And he's never transferred any property to you?

A. (Mr. Walton) Yes, he has.

Q. What has he transferred to you?

A. He transferred his interest in Fawn Drive to me.

Q. And what consideration did you pay him for that?

A. None.

Q. It was a gift?

A. Yes.

Q. And when did that occur?

A. I think it was around the time of the Desert Storm. I don't -- I really don't -- I'm

not quite sure. I can tell you it was -- it was approximately a year before the --

No, I can't tell you that either. I'm really not sure.

Q. Do you know why he transferred it to you?

A. I know what he told me.

Q. What did he tell you?

A. I'm trying to remember it. Let me think about it and see if I can remember under

what circumstances. I don't believe this has any relation to any representation.

[G]erry told me that he'd had a vision from God.

Q. That's it?

A. That's the reason. That's when he divested of all the property that I know of."

(Ex. M. p. 39, l. 9 - p. 40, l. 13)

23. On four days from the fall of 1991 through the spring of 1992 organization

-17-

Scientologist attorney Kendrick Moxon, of Bowles and Moxon, attorneys of record in

Armstrong I, II, III and IV took my deposition in Religious Technology Center, Church

of Scientology International and Church of Scientology of California v. Joseph A. Yanny,

Los Angeles Superior Court case no. BC 033035, known in the Scientology litigation arena

as Yanny II. This case involved the organization's claim that Mr. Yanny, formerly one of its

lawyers, was representing me in litigation against the organization. The claim was spurious,

invented as a way to attack Mr. Yanny and me, and the case was dismissed by the Court

before trial. The organization appealed and on January 11, 1994 the California Court of

Appeal, Second Appellate District, Division Three affirmed the judgment of dismissal

(B068261). During my deposition of March 17, 1992, pages 449 through 462 from the

transcript of which are appended hereto as Exhibit [N], the following exchanges occurred:

" Q. (Mr. Moxon) Did Yanny ever give you any money? Has he ever given you

any money?

....

A. (Me) Mr. Yanny has bought some meals for me, Mr. Yanny has paid for parking.

He has not given me any money other than that.

THE REFEREE (Honorable Thomas T. Johnson): And you stayed in his house?

A. Right

Q. Didn't he pay for you to come down to Los Angeles?

A. What that became was Mr. Yanny's purchase of stock in [T]he Gerald Armstrong

Corporation.

Q. Who owns the Gerald Armstrong Corporation?

....

A. The Gerald Armstrong Corporation is owned by stockholders, and I decline to

divulge who all the stockholders are.

....

THE REFEREE: The testimony is that there is a corporation. I take it there have been

questions in the past about the purpose of the corporation. There is testimony that

-18-

there are shareholders. More than one shareholder I take it?

A. Yes, your Honor.

THE REFEREE: And that Mr. Yanny is a shareholder. Is Mr. Yanny a majority

shareholder?

A. No.

THE REFEREE: Without saying who the shareholders are, how many shareholders

are there?

A. I believe 12.

THE REFEREE: Are you a shareholder?

A. No, I'm not.

THE REFEREE: I'll sustain the objections to any further questions on this

shareholdings. Is the corporation registered with the state of California?

A. Yes, your Honor.

THE REFEREE: How old is the corporation?

A. 1987.

THE REFEREE: Let's go on to something else.

....

Q. How much money did Yanny give you for stock in the Gerald Armstrong

Corporation?

....

A. $1,000.

Q. When did he give it to you?

A. My recollection is July and August or September, 1991.

....

Q. How many shares did that give Mr. Yanny?

A. One.

Q. One share?

A. One.

-19-

Q. Do the shares have any specific value?

A. $1,000.

Q. Did anybody else give you $1,000 to buy a share?

A. Yes.

....

THE REFEREE: What's the purpose of the inquiry?

MR. MOXON: The purpose is that I believe, and I would like to explore, whether or

not money has been acquired by Mr. Armstrong through some improper means

through a sham corporation that was established for the purpose of paying him off

for his work in relation to the situation we're involved in, and potentially for his

testimony.

....

THE REFEREE: Let me suggest another question. You can certainly ask him whether

a share of stock was issued for the payments.

Q. Was a share of stock issued to Mr. Yanny?

A. It has his name on it. It has not been delivered to him yet.

Q. Why not?

I have not finished the artwork.

Q. Are you drawing the share?

A. No, the share is a printed share. Each share which I issue has artwork on it. And

I have not had the opportunity and I have not ... been in a place to perform that artwork.

....

Q. How many shares of stock does this corporation possess?

A. One hundred.

Q. What does Yanny get in exchange for his share of stock.

A. One percent ownership in the corporation.

....

THE REFEREE: What the purpose of the corporation? Somebody went to the state

-20-

and got permission to have a corporation. What's the purpose of the corporation?

A. The corporation provides philosophic services. The corporation owns all

my literary and artistic works. It is my expectation that the corporation will become

profitable and [ ] those people who have had the courage or wisdom to invest in

the corporation, as a result of the profitability of the corporation, wealthy."

24. The idea of giving away my house, TGAC stock and other assets, and forgiving all

debts owed me, came to me in August, 1990. This idea, which I consider Divinely inspired,

came, I believe, in answer to my prayer during that period requesting guidance concerning

humanity's condition, and specifically the then developing Middle East crisis following

Iraq's August 2, 1990 invasion of Kuwait. I was moved by media reports of the invasion,

the global tension, and the daily events of Desert Shield, and I sought to know what,

if anything, God wanted me to do. The idea of renunciation of worldly wealth, although

coming at that time as a surprise, and unclear as to the details for its accomplishment,

was not altogether illogical because I had long recognized that money, greed and power

motivated much of the madness that made human beings war against each other.

25. Renunciation first entered my consciousness when I was quite young, probably

less than ten years old, during a period I attended Sunday School or Sunday services at

the Anglican Church in Chilliwack, British Columbia, Canada where I was born and raised.

An essential message of the Christian Gospel, which I learned during that period of my life,

is the storing up of treasure, not in the world where it can be stolen, lost or destroyed, but

in Heaven where it is kept safe eternally. My earliest recollection of a specific teaching on

the subject, and one which has stayed with me throughout my life, is the story of the rich

young man, reported in Matthew, Mark and Luke. The King James Bible, Chapter 19 of the

Gospel According to St. Matthew, a copy of which is appended hereto as Exhibit [O], contains

the following passage:

"And, behold, one came and said unto [Jesus], Good Master, what good thing shall

I do, that I may have eternal life?

And he said unto him, Why callest thou me good? There is none good but one,

-21-

that is, God: but if thou wilt enter into life, keep the commandments.

    He saith unto him, Which? Jesus said, Thou shalt do no murder, Thou shalt

not commit adultery, Thou shalt not steal, Thou shalt not bear false witness,

    Honour thy father and thy mother: and, Thou shalt love thy neighbour as

thyself.

    The young man saith unto him, All these things have I kept from my youth

up: what lack I yet?

    Jesus said unto him, If thou wilt be perfect, go and sell that thou hast, and give

to the poor, and thou shalt have treasure in heaven: and come and follow me.

    But when the young man heard that saying, he went away sorrowful: for he

had great possessions.

    Then said Jesus unto his disciples, Verily I say unto you, That a rich man

shall hardly enter into the kingdom of heaven.

    And again I say unto you, It is easier for a camel to go through the eye of a needle,

than for a rich man to enter into the kingdom of God.

    When his disciples heard it they were exceedingly amazed, saying, Who then can

be saved?

    But Jesus beheld them, and said, unto them, With men this is impossible; but with

God all things are possible.

    Then answered Peter and said unto him, Behold, we have forsaken all, and

followed thee; what shall we have therefore?

    And Jesus said unto them, Verily I say unto you, That ye which have followed me,

in the regeneration when the Son of man shall sit in the throne of his glory, ye

also shall sit upon twelve thrones, judging the twelve tribes of Israel.

    And every one that hath forsaken houses, or brethren, or sisters, or father, or

mother, or wife, or children, or lands, for my name's sake shall receive an

hundredfold, and shall inherit everlasting life.

    But many that are first shall be last; and the last shall be first."

-22-

Ex. O, Matthew, 19, 16 - 30.

It was not until some time in 1983, more than a year after leaving the organization that I

began to understand the wisdom of these words, and only in August, 1990 that I was led

to follow them.

26. During my years inside the Scientology organization I was subjected to L. Ron

Hubbard's very different philosophy and practices concerning treasure, value and his brand

of ethics. In the few times he mentions God in his writings, Hubbard attempted to mock Him,

and he ridiculed the thought of Heaven. In his "upper level" secret directives Hubbard

wrote that Christ is an implant, a Scientology term meaning a fixed idea electronically installed

by force and pain to control and suppress its human victim. In exchange for money paid for

his pricey psychotherapy Hubbard promised the worldly treasures of increased IQ, better

communication skills, power, physical health, and the ability to make even more money.

Unable to deliver on these secular promises, however, Hubbard and his organization, in

response to the thousands of people who have been defrauded and requested refunds

pursuant to his "money-back guarantees," have employed an army of lawyers to con our

courts with the idea that these representations are "religious" and the ill-gotten and often

extorted payments "donations." Hubbard stated as his organization's financial "Governing

Policy," MAKE MONEY....MAKE MONEY. MAKE MORE MONEY. MAKE OTHER PEOPLE

PRODUCE SO AS TO MAKE MONEY. The United States Tax Court thought this policy so

noteworthy it quoted it in its official reports in Church of Scientology of California v.

Commissioner of Internal Revenue, 83 TC 381 (1984) at 422. Hubbard and his organization

justified their uncharitable policies and nature with a concept he called "rewarding

downstats," which meant that the unable, infirm and poor should not be helped because

helping such persons only rewarded them for being unable, infirm or poor. A related

Hubbardian "truth" which permeated the organization was that people "pull in" the bad

things which happen to them; that is, they bring upon themselves, or deserve, their

difficulties or tragedies. This concept is used not only to excuse Hubbard and his

organization's disregard for human suffering in all its forms, but to extol the suffering

-23-

they have heaped on their "enemies." The attack on, for example, writer Paulette Cooper

to ruin the woman (the organization's intelligence bureau under Hubbard's direction, in a

scheme called "Operation Freakout," which had as its stated purpose to either get her

imprisoned or driven insane, obtained through trickery her fingerprints on sheets of paper

which were then used to send "anonymous" bomb threats to political figures) was right,

"pro-survival" and ethical, because Ms. Cooper pulled it in. While this idea supports the

Scientological group psyche in its organization, and in the entity it presents as plaintiff

and defendant in our courts, its policy, philosophy and psychology do not allow the

application of the same idea to L. Ron Hubbard or to the power structure that replaced

him after his death in January, 1986. It is forbidden inside the organization even to think

a critical thought about Hubbard or Scientology, and grounds to be declared "fair game"

to expound either the idea that perhaps he may have done something to pull in some of

the names he's been called; e.g., bigamist, bully, charlatan, cheat, liar, megalomaniac,

swindler, wife beater; or that just maybe some of the persons the organization attacks do

not deserve it. This double and twisted standard that Hubbard implanted in the

Scientological mind keeps the organization's employees and customers ignorant of wisdom

and blind to the madness of their actions, words and appearance. But reasonable and

rational non-Scientologists are not blind to these things, as shown herein in the

Breckenridge decision (Ex. B) and the Ideman declaration (Ex. F). Hubbard was shrewd

enough to understand that even to the brainwashed a persona of "egoism, greed [and]

avarice" (Ex. B, p.9, l.2) would trigger rejection; thus in public and in the legal arena he

applauded his generosity and flatly denied the suggestion of inurement, In a public

relations piece that went to every Scientologist in the world, and to any non-Scientologist

who wanted one and many who didn't, he wrote that for all his work in saving mankind

he was paid less than an average organization staff member. I was an average staff

member during this assertion's international dissemination and I was paid between $4.30

and $17.20 per week. Hubbard paid himself untold millions. He had complete control of the

organization and all organization bank accounts, and concocted amazing schemes for

-24-

international money laundering; all while having his organization's personnel swear in

civil litigation, criminal cases and official investigations that he had resigned as Scientology's

director in 1966 and from that date had played no part in the organization's management.

In keeping with his secret affirmations that "all men are my slaves," and "I have the right

to use men's minds as I please," by which he programmed himself in the early days of his

"development" of Dianetics and Scientology, he kept his workers impoverished while he

ripped off millions illegally from the "charitable" corporations in which they labored. The

new power structure has embarked on a glossy PR campaign in which it laments that all

Scientology services aren't free and that it needs to charge what it does to "help create a

safe and pleasant environment for everyone." A more accurate statement of the

organization's fiscal philosophy is the article in the May 6, 1991 Time magazine, on the cover

of which over an erupting octopodous monstrosity is blazoned "Scientology - Cult of

Greed." I know personally a great number of people who have been victimized, abused,

ripped off and discarded for no other reason than to satisfy the power structure's

avariciousness. It is my knowledge of this cult of greed and the threat its leaders think I am

to their shaky house of fraud that has brought them and their attorneys to attack me so

relentlessly. I acknowledge that it is possible to view the giving away of my possessions

in 1990 as a reaction to the years of inculcation with Hubbardian greed and

meanspiritedness; but I do not see it that way. Hubbard and his organization were never

able to destroy in me my God-given nature. Even inside the organization, in circumstances

which made charity, compassion and understanding dangerous activities, Hubbard and his

enforcers were never able to achieve total suppression. They were not successful with me,

and I believe it will be ultimately shown that they will not have been successful with anyone;

nor is suppression of anyone by any regime, state or entity entirely successful. It is our

God-given nature that brought every person into Scientology and the Sea Org, and willing

to live, work, fight for a cause, and endure terrible abuse, without thought of profit, bank

accounts, investments or retiring. In his abuse of that divine nature Hubbard proclaimed

it a "high crime" to even discuss retiring with one's fellow Scientologist workers. My analysis

-25-

is that the use of our highest nature by an individual or organization for purposes not in our

best interest; that is to say, suppression, is not merely not religion, it is irreligion; and as

irreligion it should be stood up to and seen for what it is. My position in the litigation is that,

by justice, law, this country's constitution, and God's Will, I am free to communicate that

analysis in all the ways it can be said and by any means and media there are to say it.

27. I have considered myself a professional artist and writer since 1984. In the fall of

that year organization operatives broke into the trunk of my car and stole a book manuscript

with original art I then valued at $50,000.00. I demanded my things returned to me but the

organization denied possessing them. I have recently been advised by former organization

executive Vicki Aznaran that during a time when she was involved organizationally with

its present leader David Miscavige in operations against "enemies," he acknowledged the

organization's theft of my manuscript and scoffed at my work's literature. Also in the fall

of 1984 the "Armstrong Operation," in which the organization had used one of its covert

agents, Los Angeles spy story writer Dan Sherman, to get close to me to set me up in a

number of situations, culminated in my being videotaped in conversations with two other

organization agents, David Kluge and Mike Rinder. At the end of 1984 I split up with my

wife Jocelyn, who had escaped with me from the organization in December, 1981, and in

early 1985 I travelled to Portland, Oregon for the trial of Julie Christofferson v. Scientology,

Multnomah County, Oregon Circuit Court, Case No. A7704-05814. During my cross-

examination at the trial in April, 1985, the Armstrong Operation videotapes and the fact

that Sherman, Kluge and Rinder, who had been presenting themselves as my friends,

afraid for their lives, and seeking my help to reform the organization's criminal nature, were

actually covert operatives intent on destroying me, were " introduced" by organization

lawyer, Earle Cooley. In September, 1985 I moved to Boston and worked at the Flynn, Joyce

& Sheridan law firm until the December, 1986 settlement. The organization continued to

run operations against me during this period, I continued to write and draw, allowed God

to work on my mind and heart, and in 1986 founded a church.

28. In January, 1987 I moved to Oakland, California, and then purchased a home in the

-26-

Berkeley-Oakland hills where I lived until 1989 when I purchased a new home in the same hills.

During this period I wrote and drew and followed what I prayed was guidance. I set up and

worked out of an office, on the urging of Michael Walton incorporated TGAC, started running

and helped whomever I could. Although I knew the organization still viewed me as an enemy

and had attacked me in various ways after the settlement I did not become substantially

reinvolved with it in the legal arena until the fall of 1989 and spent virtually no time until then

on organization-related matters. I became an accredited Teacher of God during this period,

and also was given my first glimpse of the resolution of the economic problems facing the

world. This glimpse, which I wrote into an essay entitled "A Crash Course in Speculation, "

a copy of which is appended hereto as Exhibit [P], was a step toward my renunciation, which

itself is, I believe, an incident of planetary salvation. My reinvolvement with Scientology is

described in my declaration of March 15, 1990 (Ex. G hereto), my declaration of December 25,

1990, a copy of which is appended hereto as Exhibit [Q], and in the boxes of documents filed

in the four Armstrong cases. I filed the December 25, 1990 declaration as an appendix to a

response brief in the appeal (B 038975) of the order unsealing the Armstrong I court file for

Bent Corydon.

29. I first met attorney Michael Walton in about April 1982, shortly after we both began

working at the law firm of Feldsott, Lee and Van Gemert in Newport Beach, California. We

became friends and stayed friends when I left southern California, moved to Portland, Boston

and the Berkeley-Oakland hills. We spent many hours together through those years and

talked for many hours about many things, including my art, writings, inventions and

philosophic ideas, and we considered doing various projects together involving these

products or ideas. Mr. Walton was familiar with my Scientology history and litigation, the

organization had taken his deposition in Armstrong I, claiming it was needed because he

was for some matters my administrative senior in the Feldsott firm, and he attended several

days of my trial in 1984. He has represented me in literary and legal matters and I have

consulted with him on a number of occasions since that time. Before becoming a lawyer

he taught English in university, he is a writer, and for a period of time before the December,

-27-

1986 settlement, considered writing a book himself about Hubbard.

30. One of the things I did with the money I was given in settlement of Armstrong I was to

form a partnership with Fairfax architects Rushton-Chartak and San Anselmo builders Grizzly

Hill Construction to purchase a rare piece of property at 707 Fawn Drive in the unincorporated

land of Marin County and build thereon a spec house, hereinafter "Fawn." I provided the

initial capital, the work was done and the house completed toward the end of 1989. At the

same time an unusual phenomenon in the California half-million-or-so dollar house market

occurred; it dried up and crashed. For me all of a sudden it made economic sense to buy

Fawn myself. When that idea arose, the idea of hooking up with Mr. Walton and doing some

of our often-discussed projects together also arose, and fairly naturally, because he had been

thinking about leaving the south and Fawn was a reasonably big house which could sensibly

contain his law office, my business, our respective companions and his one-year old son.

We arrived at an arrangement which worked for both of us, I sold my East Bay house, and

the five of us moved into Fawn in May, 1990. I made the down payment for the Fawn purchase

and put enough cash into a joint checking account to cover a year's mortgage and utilities

payments. Although to a Scientologist, the organization's lawyers or other similarly hard-

nosed business persons it can certainly be argued that I put more than my share of capital

into Mr. Walton's and my venture, in which it would also be mainly my creations or ideas

which would be commercially developed, and that there is therefore something wrong,

suspicious or even fraudulent in so doing, to me these actions rather reflect rightness and

probity. I was dedicated to my work being God's and to doing some creative projects with

Mr. Walton, I had generally had a something different from ungenerous nature, and I knew,

as expressed in my 1989 essay "A Crash Course in Speculation, " that money has no value.

Renunciation has, of course, greatly reduced my numismatic largess.

31. Within a month or so of the move into Fawn, Mr. Walton's friend Jody and their son

Dylan moved out, we got our offices functioning and spent a lot of time getting the house

and yard functioning. I ran, and with my helpmeet Lorien Phippeny developed into

demonstrated workability a program to have the world's runners clean the planet of its street

-28-

litter. I joined a running club and bought a mountain bike. Before the move to Marin County

Mr. Walton had already agreed to represent me in the organization's appeal (B 025920) from

the Breckenridge decision, permission to respond in which I had already obtained from the

Court of Appeal in February, 1990, and we filed a Respondent's Brief on July 9, 1990.

32. Also in February, 1990 I received an invitation from the IRS to discuss my 1987 tax return.

The discussion did occur, the IRS issued an Information Document Request, and I responded

on April 24 with a book which I have given the working title Auditing Gerald Armstrong.

A copy of the manuscript along with its supporting documents, except for those which

are already exhibits to this declaration, is appended hereto as Exhibit [R]. This complete book

was produced by me on March 10, 1993 in attorney Wilson's office pursuant to the

organization's request for production in Armstrong II. He and the organization were therefore

aware of the following facts from the Auditing GA manuscript before they filed the Armstrong

IV complaint:

    A. That I had written "A Crash Course in Speculation;"

    B. That in July, 1987 I had offered to the captors then holding several hostages

in Lebanon my house, and for that matter my life, without monetary consideration,

and for reasons unrelated to the organization;

    C. That in the summer, 1989 edition of Common Ground I had offered my

philotherapeutic sessions at no cost;

    D. That Nancy Rodes had declared under penalty of perjury on November 28,

1989 that she knew me to be a religious figure and had been my hagiographer

since 1984; and,

    E. That TGAC has never existed solely so that I may be "judgment roof."

33. Even though I was aware of Jesus's admonition to his disciples to not be troubled by

wars and rumors of wars (Mark 13, 7; Luke 21,9), I was undeniably affected by the media

images of Desert Shield as it built into Desert Storm and the international diplomatic drama

that accompanied the military operations. I had already been moved, I felt, to enter the political

and sociological landscapes, as I believe is shown by the letter to the captors, "Crash Course"

-29-

and their recipients lists. I had also considered and argued in these other political matters -

the hostages, the economy - that something could be done about them, and that what I thought

could be done was, at least on paper, a better idea. It was not out of the ordinary or out of

character, therefore, for me to consider that I could do something about Desert Shield, Desert

Storm or the whole blessed Middle East. It was at that time that the idea came to me to give

away my worldly possessions and to give myself to the cause of peace. After some thought,

I transferred my interest in Fawn to Mr. Walton, divided my one hundred percent ownership

of TGAC equally between my friends Nancy Rodes, Michael Douglas, Lorien and Mr. Walton,

and forgave all debts owed to me. I knew by this time that our Source is also the source of

everything, including money, and that He would provide for me all that I would need to carry

out His work. I also was fully aware that I was engaged with the organization on the legal

battlefield, and although I was confident of the outcome, I had no idea what would happen on

the road toward that day. I recognized that the organization's ruling clique was motivated by

the same forces of money, greed and power that made men war against each other and that

my renunciation was spiritually directed at bringing peace for the organization no less than

the rest of the world. And, as I stated above, I accepted the fact that should my legal battle

with the organization continue I would more likely than conceivably litigate indeed in forma

pauperis. I communicated my decisions to everyone directly affected by them, took care

of the paperwork needed to make the decisions legally effective, and tied up various loose

ends. It became clear to me that the renunciation had left me unattached and free to travel

wherever I was called should I be. I gave my car to Lorien, but she returned it, and we took

a trip together during September through the western states and British Columbia to develop

a sociological concept that had come to me. When we returned to California Lorien moved

to Santa Cruz and I, not then being called to go elsewhere, stayed at Fawn where I worked on

some house and grounds projects, continued to maintain TGAC's office, and kept picking up

trash. I also came up with what I thought was a good plan for resolving the Middle East crisis

and I communicated this plan to various media and certain leaders or envoys I thought were

in positions to do something about it. In my letter to Saddam Hussein of November 1, 1990 I

-30-

offered, as I had with the Lebanese captors in 1987, to exchange myself for the hostages then

being held in Iraq; but I did not sweeten the deal with my interest in a house, as I had done

in the earlier offer, because I had already conveyed it to Mr. Walton. Copies of this letter,

my November 7, 1990 letter and list of addressees to which they went, my December 10, 1990

and January 10, 1991 letters are appended hereto as Exhibit [S].

34. On December 28, 1990 I filed a response brief and appendix (Ex. Q hereto) in the B 038975

appeal (see paras. 14 and 28 above). On December 31, Mr. Walton married Solina Behbehani,

and she and her teenage son Sephy moved into Fawn. Oral argument in the two appeals,

B 025920 and B 038975, was heard on February 20, 1991. At some point during the months

following my renunciation it became clear to me that I would go in the world wherever my

help was asked for, and, as much as was sensibly safe, courteous and wise, provide my help

without monetary remuneration. Initially only Mr. Walton asked for my help so I had no

reason to leave Fawn. Then Nancy Rodes asked me to help her complete and clean a house

she had built in the Oakland hills, which I did through the spring of 1991. This worked well

because she was broke and I worked for free. I returned to Fawn for a couple of weeks to

complete a painting project I'd started earlier, then traveled to British Columbia for my

parents' fiftieth wedding anniversary. While in B.C. I received a call from Malcolm Nothling

in Johannesburg, South Africa who asked for my help in a lawsuit he had brought against

the organization which was then set for trial in August. He said he had not been able to find

else in the world willing to testify about the organization's policies and practices.

Having already put the organization on notice in February, 1990 that I considered the

restrictions of the settlement agreement unenforceable, and after listening to Mr. Nothling's

story, and because he asked, I agreed to help him. I told him, however, that I wanted first to

see if his situation could be resolved peacefully without the hatred and waste which seem

to be the hallmarks of the organization's legal confrontations. A copy of my effort, a letter

to attorney Eric Lieberman, who represented the organization in the Armstrong I appeal and

in many of its appellate matters, is appended hereto as Exhibit [T]. Mr. Lieberman sent me a

letter rejecting my peace proposal, I flew to Johannesburg and helped Mr. Nothling, but did

-31-

not testify because the organization was able to obtain a postponement of the trial.

35. Soon after my arrival back from Canada and just before leaving for Johannesburg I got a

call from attorney Joseph Yanny, who'd become a good friend over the previous year or more,

and who had come into the case of Richard and Vicki Aznaran v. Scientology, US District

Court for the Central District of California case no. CV-88-1786-JMI, after the Aznarans were

tricked by the organization into firing their lawyer of more than two years, Ford Greene.

The organization had immediately filed a mountain of summary judgment and other motions.

Mr. Yanny said he needed my help. I traveled to Los Angeles in the few days I had before

I was scheduled to fly to South Africa, on July 16 wrote a declaration, a copy of which is

appended hereto as Exhibit [U], concerning the effect of the 1986 "global settlement" on

litigants against the organization and in the legal community, and generally helped out

in the moral support department. Mr. Yanny is a member of my church and we have talked

many times over the past few years on matters of the soul.

36. As I was leaving for South Africa I learned from Mr. Yanny that the organization had

sued him for allegedly inducing me to breach the settlement agreement. In response to that

charge, between planes in New York I wrote a declaration dated July 19, 1991, a copy of

which is appended hereto as Exhibit [V], in which I stated my philosophy regarding my calling

to help.

"But more than a desire to protect myself or right the organization's unjust acts

towards me, however, I helped Mr. Yanny for the simple reason that he asked. I will

do the same for anyone....It is not only the right of all men to respond to requests

for help, it is our essence. If I was induced, therefore, to help Mr. Yanny, or

anyone else, it was our Creator Who induced me."

The organization's lawsuit against Mr. Yanny actually claimed that he was representing me

in Scientology-related litigation, which was, the organization also claimed, since he had for

a period of time represented it in various matters, a breach of his continuing duty to it.

Although I had consulted Mr. Yanny regarding some of my literary and artistic products

and ideas, he had never represented me in any litigation and I had never consulted him

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about my organization legal battle. The organization's allegation that he represented me

had no basis in fact and the complaint was dismissed.

37. While I was in South Africa the California Court of Appeal on July 29, 1991 affirmed the

Breckenridge decision, and I learned that Judge Ideman in the US District Court had

reinstated Ford Greene as counsel for the Aznarans. When I arrived back in the US I

returned to Fawn and a day or so later dropped by Mr. Greene's office, which, as Heaven

would have it, is maybe two and a half miles away in uptown San Anselmo. It became instantly

clear that Mr. Greene, in a very tangible way, as much as anyone else in the world, really did

need my help. He faced the Everest of motions, which the organization had filed when the

Aznarans were lawyerless, with no time, no staff, no sleep, little organization, hopelessly in

debt, hounded by creditors, his own car held by a creditor garage. Again I achieved near

perfect economic symbiosis: he had no money and I worked for free. To render it a truly

irrefusable deal, I had wheels. I knew my way around a law office, had something of a history

of document assembly, could run a photocopier, stapler and hole punch, answer a phone,

and had an adequate command of the Canadian language. I was blessed with an

understanding of the cultic manufacturers of the paper mountains that threatened to crush

Mr. Greene, his office, and the Aznarans along with them. And I recognized that Mr.

Greene, in spite of whatever had brought him to the point of desperation where he truly

needed my kind of help, had a really good mind and heart, a unique talent, was, as I had

begun to see we are, guided, and with great luck and hard work might survive. So I've been

working with him, as his sole office support, since August 15, 1991. We have both survived,

worked hard, taken a few hits, and Mr. Greene can now afford to pay me something and does.

When things were really lean some other good friends have loaned me money, TGAC sold

a couple of shares to still others, and always money has arrived, as God would have it, in

His unmistakably mysterious ways. Mr. Greene has successfully defended me in the four

cases the organization maintains against me and has helped me as I have helped him.

38. Immediately upon my return from South Africa I received a copy of a lawsuit the

organization had filed August 12, 1991 against seventeen named United States agents,

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Church of Scientology International v. Xanthos, et al., US District Court for the Central

District of California, No. CV-91-4301 SVW(Tx). Included in the complaint, a copy of which

is appended hereto as Exhibit [W], was the allegation that:

"The infiltration of the Church was planned as an undercover operation

by the LA CID (Criminal Investigation Division of the IRS) along with

former Church member Gerald Armstrong, who planned to seed church

files with forged documents which the IRS could seize in a raid. The CID

actually planned to assist Armstrong in taking over the Church of

Scientology hierarchy which would then turn over all Church documents

to the IRS for their investigation." (Ex. W. P. 14, l. 3)

Although I had seen this organization attack line in many forms and venues since 1985, this

1991 charge signaled to me that the organization was not about to peacefully end its legal

and psychological war in which I was one of its most hated enemies. In recognition of

that fact as well as logistical reasons I moved out of Fawn and into Mr. Greene's law office

at the same time as I started working with him. Mr. Walton and I had already picked up

organization surveillance at Fawn, his stepson Sephy was very troubled by the threat he

perceived, everyone in the house felt threatened to some degree by the organization, and I

did not want to bring any danger to this family, who were my dear friends and completely

uninvolved with my Scientology conflict.

39. When I began working with Mr. Greene I almost immediately picked up surveillance,

and very shortly thereafter the organization began to attack with declarations and motions

filed in the Aznaran case, accusing me of violating various court orders, illegal activities and

acting as Mr. Yanny's covert agent in Mr. Greene's office. In response to this paper

onslaught, on September 3, 1991 I wrote a declaration, a copy of which is appended hereto

as Exhibit [X], which was filed by Mr. Greene in Aznaran.

40. On October 3, 1991 the organization filed a motion in Armstrong I to enforce the settlement

agreement, I opposed, and on December 23 at a hearing where I was represented by attorney

Toby Plevin, Los Angeles Superior Court Judge Bruce R. Geernaert denied the motion. Judge

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Geernaert was familiar with the case, having inherited it after Judge Breckenridge's retirement

and having unsealed the file on Bent Corydon's motion. On February 4, 1992 the organization

filed Armstrong II in Marin County and on March 20 it was transferred to Los Angeles Superior

Court. The organization brought a motion to enjoin me from violating the settlement and on

May 28, 1992 Judge Ronald M. Sohigian entered a partial injunction, a copy of which is

appended hereto as Exhibit [Y], prohibiting me from assisting litigant claimants against the

organization, but refusing to prohibit me from doing anything else the organization might

consider settlement agreement violations. I filed an appeal from the Sohigian injunction,

Scientology v. Armstrong, No. B 069450 in the California Court of Appeal, Second

Appellate District, Division Four. At this date the appeal has been fully briefed and is

awaiting the scheduling of oral argument.

41. In October, 1992, stirred by the imminent national election, I came up with a plan for

initiating the peaceful transformation of the nation's, and the world's, economic system

through the Organization of United Renunciants, hereinafter "OUR, " which I had conceived

of and founded some time earlier. I wrote a series of short essays on the plan and the

thought underlying it and sent a pack of these materials to several political and media

persons. A copy of OUR basic pack, including the list of its initial recipients, is appended

hereto as Exhibit [Z]. In one of the essays entitled "OUR Deadline" I write:

"George Bush's deadly deadline to Saddam Hussein gave me the idea of issuing

OUR deadline. The fact that it was OUR deadline resulted in the Organization of

United Renunciants. Organizing renunciants made sense because I had, in August

1990, as a result of understanding the Persian Gulf crisis, and accepting the idea

of renunciation as guidance, given away all my money, real estate, paper holdings

and personal effects and forgiven all debts owed me."

42. On November 11, 1992 the Marin Independent Journal published an article entitled

"Is money the root of problems? Critic of cash, credit urges monetary abolition," a copy of

which is appended hereto as Exhibit [AA], dealing in manifestly good humor with my economic

idea and OUR plan for its implementation. IJ reporter Richard Polito writes:

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    "Fellow renunciants will renounce all cash and credit, stop taking money, forgive

all their debts and stop keeping financial records.

    The critic of credit has already put his money where his doubts are. He gave it

all away. And it was more than pocket change.

    Armstrong won an $800,000 settlement in a harassment suit against the Church of

Scientology six years ago." (Ex. AA)

43. Because the Nothling case was set to go to trial in February, 1993, on December 22, 1992

I again wrote to the organization to see if a communication from me could initiate a peace

process. A copy of my letter, addressed to David Miscavige, the person who in every sense

can order anything within the organization or its corporate, financial or legal affairs anywhere

in the world and enforce compliance with all such orders, is attached hereto as Exhibit [BB]. I

sent copies of the letter to an extensive list of people I thought should be apprised of its

content. Having been accused by the organization so stridently for more than a year of

"fomenting litigation" against it, I made a special point and, I think, an honest effort, in this

letter, and in my other communications, to unfoment its litigation. I include in the letter a

statement of an aspect of my belief, which, I believe, is central to understanding the

organization's conflict with me.

"I believe that everyone will become a person of good will, that everyone already

is, has been and will forever be, that there is progress and perfection, hope and

reason, that to know who we are we must accept the truth of our relationship to

our Creator, that all about us that we made is illusion, that we have reason to be

grateful that is so, that our Creator, God, our Father Loves us in the same Love

by which He created us and holds us always safe and always loved in that Love,

that we, His children, are one and One with Him, that the means by which He is

remembered, and hence our relationship, and hence who we are, and hence

what we know, is forgiveness, that forgiveness is the recognizing of illusion for

what it is, that creation is our nature, and that everything is all there is."

(Ex. BB, p. 10)

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The organization appears in its statements and efforts to view me as competition in what it

claims as its niche, which it calls "applied religious philosophy," in what it apparently perceives

as the salvation market. Appended hereto as Exhibit [CC], for example is a copy of an

organization directive in which I am labelled a "squirrel," a hate word the organization uses

for people it considers its competition. Hence it seeks to destroy my reputation and resorts

to outrageous legal shenanigans to have me judicially silenced. In truth, although some of

what I say or do could be construed as applied religious philosophy, I have never used this

description. I do not compete with Scientology for anything, and certainly not for its paying

customers. I promote the philosophy that salvation is free, and the organization promotes

a philosophy that says that the only workable means of salvation costs a certain, and

generally escalating, quantity of money, or, for its employees, a certain number of years of

labor, and that the organization possesses and owns said only workable means and the only

workable delivery system. My philosophy is owned by everyone, and the living God is its

Source, as He is of everything. Scientology proclaims that its deceased leader L. Ron

Hubbard is salvation's source. I neither sell nor use the organization's philosophy and my

delivery system is different in every way from the organization's. If people want to pay for

salvation and take something not indistinguishable from a significant amount of time

getting saved they can go to Scientology. Those who want immediate salvation without

any sacrifice or cost whatsoever can come to me. The organization does not even accept

as customers anyone who believes that salvation is available right now without sacrifice,

so I am in no way a competitor. The organization banks on the idea that there are people

who want to pay money for salvation, so it promotes to that paying public. I bank on

the idea that we're already saved, so for Heaven's sake don't spend good money on it. Since

I am not looking for anyone who wants to pay for salvation, and do not even consider that

if someone feels he wants to pay for it I have something to sell him, I truly am not in

competition with the organization. There are, admittedly, probably more people who want

salvation to be free than there are who want to pay for it, but that is just the way

Providence has dealt out preferences for freedom versus cost. Also admittedly, in a strictly

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business sense, my philosophy has another undeniable advantage because in this world

everyone can afford the salvation I offer; whereas those who can afford Scientology's road

to salvation, without even taking into account the desire to devote the time the organization

says is required, are considerably fewer in number. But the organization enjoys certain

advantages as well because of its administrative structure and technology; for example,

its policy prohibiting its customers from mixing practices. Once people become

Scientology's customers the organization will not permit any to come to me to be saved

and continue on its salvation program, what it calls the "bridge to total freedom." In fact

the persons I had saved would not even be allowed to continue to hang out with their

Scientologist friends, and those Scientologists would be prohibited from hanging out with

their former friends once I've saved them. Those kinds of prohibition wouldn't work well in

my delivery system, so anyone I save is at liberty to jump ship and take up Scientology's

cross, and still, as far as I and my philosophy are concerned, hang out with me or anyone

else in the world. This does not put a great strain on me, it's true, because in my system, as

stated above, salvation doesn't take time, nor does it have to be repeated. There is, of course,

the matter of the other people the organization also rejects and refuses to save even

if they could afford the program; for example, drug users, the mentally ill, convicted felons,

present criminals, shock victims, critics, people declared suppressive persons, and people

connected to people declared suppressive persons. Thus there may be some crossovers, but

it is silly of the organization to complain because I save those souls it rejects. By its

Suppressive Person Declares in 1982 (see, Ex. C, p. 920), the settlement agreement in 1986

(Ex. D), and its lawsuits to enforce the agreement up to present time, the organization has

sought to prevent me from having access to its means of salvation and delivery system.

The settlement agreement required that I

"never again seek or obtain spiritual counselling or training or any other service

from any Church of Scientology, Scientologist, Dianetics or Scientology auditor,

Scientology minister, Mission of Scientology, Scientology organization or

Scientology affiliated organization." (Ex.D at p. 10)

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If persons are rejected by Scientology because they had a criminal conviction, took LSD,

testified truthfully in organization litigation, are crazy, or were, as I had been, declared a

suppressive person, and such persons still want salvation, they can come to me. I save

everyone and believe there is nothing anyone can do to prevent his being saved. I simply do

it for free, whereas the organization charges its customers to do it to them. Clearly,

Scientology has its public and its market and I have mine. I do not advertise to those who

want to pay for salvation so there is no way I can possibly threaten the organization's

customer pool. In fact I don't advertise even to those who want salvation at no cost, but

simply trust that God will lead to me, without charge, those people I am to save. If

Scientology moved into my field and started saving people without cost of any kind, it

would conceivably have a reason to view me as competition and consequently would have

an excuse to ruin my reputation and have me judicially restrained from practicing my

profession. I think that if the organization really were to move into my technological field,

however, it would see that it's wide open and there are more than plenty of customers who

don't want to pay for salvation, can't, or both, to go around. I tried the organization's

philosophy for a significant number of years, and because I am intellectually sound,

observant, trained in wisdom, and willing to talk and testify about my observations and

can form reasoned opinions thereon, I am, in the litigation world, an expert therein. It

goes without saying that when lots of people are willing to talk about their organizational

observations I will cease to be considered an expert. But even until that day dawns,

although I am an expert in what the organization sells as its means to salvation, I am not

in competition with it. There is no reason for it to feel threatened by my beliefs or my

salvatory methodology, and no reason for it to vilify me or work so assiduously to get

some court to silence me. I follow the system perfected by Jesus Christ which is not

even in competition with nothing or no one.

44. On December 31, 1992 the organization filed an ex parte application in Armstrong II

for an order to have me held in contempt of court. The application and the supporting

declaration of attorney Bartilson, along with the exhibits thereto, except those which are

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already exhibits to this declaration, are appended hereto as Exhibit [DD]. Exhibit G to the

Bartilson declaration is my December 22 letter to David Miscavige (Exhibit [BB] hereto),

and exhibit R is a copy of the November 11 Marin Independent Journal article (Exhibit AA

hereto