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GREENE, O'REILLY, BROILLET, PAUL, SIMON,
MCMILLAN, WHEELER & ROSENBERG
LAWYERS
LOS ANGELES OFFICE
816 SOUTH FIGUEROA STREET
LOS ANGELES, CALIFORNIA 90017-2516
(213) 482-1122
(213) 482-1350

Attorneys for Plaintiff

 

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

 

LARRY WOLLERSHEIM,

        Plaintiff,

    vs.

CHURCH OF SCIENTOLOGY OF CALIFORNIA, et al.,

        Defendants.


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CASE NO. C 332 027

DECLARATION OF GERALD
ARMSTRONG

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    I, GERALD ARMSTRONG, being duly sworn, state the follow-

ing from my own personal knowledge:

 

    1. I am the defendant and cross-complainant in the

case of Church of Scientology of California v. Armstrong, Case

No. 420 153.

 

    2. I am making this Declaration to support a motion to

have the CHURCH OF SCIENTOLOGY OF CALIFORNIA produce the "audit-

ing" and "ethics" files, of LARRY WOLLERSHEIM now in its or a

connected organization's possession.

 

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    3. During the process of "auditing" in Scientology, a

person being "audited," hereinafter referred to as "preclear, "

communicates to the auditor, his innermost thoughts and

relates incidents from his life which are emotionally charged, embarrass-

ing or for which he could be blackmailed. The auditor writes down

what the preclear says in "auditing reports." The auditor demands

and records details such as the time and place when an incident

occurred, who was present, who knew about the incident, their

relationship to the preclear and their address or general loca-

tion. These "auditing reports" form, along with the auditor's

notes and instructions made after the auditing sessions, the

preclear's auditing files. My own auditing files are from approx-

imately one thousand hours of auditing and total over two feet in

height. These are the files, along with my "ethics" files, and

any copies, notes or excerpts from these files, that I seek to

have delivered to me in my own case.

 

    4. When I became involved with Scientology, and when I

joined the Sea Organization, I did so in part because of the

promises made to me that auditing reports and statements made

during auditing were to be absolutely confidential between auditor

and preclear. I was told that these statements would never be

passed on to others and would not be used against the preclear. I

was never told of use of auditing information by the hierarchy of

Scientology against preclears, nor of the fact that the hierarchy

and the intelligence bureau personnel of Scientology had complete

access to auditing files. My learning of the actual use to which

auditing information is put was a major factor in my leaving the

 

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organization. The fact that the organization refuses to turn over

personal records by claiming they are "protected" by the

"clergyman-penitent privilege" which they have for decades ignored

and abused, is a situation designed by Scientology to bring about

the emotional disintegration of their former members.

 

    5. These files are the individual's property because

they are his statements. Yet, he cannot exert any control over

them, and cannot stop the organization's use of these files as

long as they remain in Scientology's possession.

 

    In my case I am seeking an understanding from these

records of what happened to me during my thirteen years of

involvement with Scientology. There are aspects of the mind

control by HUBBARD and the organization which as yet elude me. I

feel that my auditing records will shed a great deal of light on

this subject, as well as the subject of the fraud perpetrated by

HUBBARD and the Scientology organization against me and my emo-

tional well-being. My emotional stability, I feel, was damaged by

Scientology, both while I was a member and by the attacks on me

after leaving. The continued possession of my personal auditing

records and violation of my rights does not allow any emotional

healing. The organization and HUBBARD and his agents will use the

information from my personal auditing files against me, both in

and out of the legal arena. I seek to prevent HUBBARD and the organiza-

tion from this abusive action. HUBBARD and the organiza-

tion have labelled me their "enemy" and a "suppressive person" (or

one of the 2 1/2 percent most evil people in the world). They do not

 

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consider me a friend, and their motivation for retaining my

personal auditing files in not friendship or interest in my

welfare. They actively seek my destruction.

 

    6. During my years of involvement with HUBBARD and

Scientology I learned by direct observation how the organization

uses preclear's "confidential" auditing information. While

working in the Guardian's Office and L. Ron Hubbard's Communica-

tions Bureau, I coded and decoded telexes which contained such

information gleaned from auditing files. The information came

from the Guardian's Office (or Intelligence Bureau), and without

the knowledge of the preclears. The transmitted information dealt

mainly with the preclear's sexual activities, their family, drug

use, criminal activity in their past, "buttons" (things which

could be used to exert control over the preclears), and things for

which the preclears could be blackmailed. In 1980 and 1981 I

learned from Guardian Office operatives that because of its social

unacceptability and legal problems they could no longer use

auditing information directly. Instead, they gleaned the informa-

tion from auditing files and then sought out "third parties" or

created " third parties" who could provide the same information.

Since the auditing reports contained the time and place where

incidents occurred, and who was present or knew about the inci-

dent, this was relatively easy to do.

 

    In 1980 I was asked by a GO operative to " verify"

information taken from the auditing files of Tonja Burden, a young

girl then considered an "enemy" of Scientology. The operative

 

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knew details from Ms. Burden's "confidential" files [and gave]

these to me to see if I could be the "third party" to

the information in a declaration or as a witness.

 

    7. A number of times during my involvement with

Scientology I was ordered, either by Intelligence Bureau personnel

or HUBBARD's personal agents, to cull usable information from

preclears' auditing files. The information culled was written or

typed into lists and kept by the GO or HUBBAR.D' s agents separate

from the auditing files. This was standard practice with anyone

who requested to leave or did leave the organization or who was

considered in any way a "threat." Undoubtedly it has already

occurred with my "confidential" files.

 

    The classes of information I was ordered to extract

from auditing reports were: anything concerning the preclear's

sexual activities, including time, place, form, event and names

and addresses of all sexual partners; any involvement with drugs,

including time, place, form, event and names of anyone else

involved; any criminal activities with complete details; anything

for which the preclears could be blackmailed; any information on

family members, friends, associates, connections. In short, the

information sought by the Guardian's Office and HUBBARD's personal

agents was intelligence data exactly like that sought and used by

the KGB or the Gestapo.

 

    8. Only in 1982, after leaving HUBBARD's personal

staff and the Sea Organization did I find that the practices

 

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regarding the use of "confidential" auditing files for intelli-

gence purposes existed as written policy long before I joined the

Sea Organization. In a Guardian's Order dated December 16, 1969,

entitled " PROGRAMME: INTELLIGENCE: INTERNAL SECURITY, Mary Sue

Hubbard, then directly responsible to L. RON HUBBARD, wrote:

 

"VITAL TARGETS:

1. This Programme is to be done by

the Asst. Guardian or the D/A/Guardian for

Intelligence, if this post is held sepa-

rately.

2. To establish intelligence files

on all such persons found to be infiltra-

tors, double agents, and disaffected staff

members, Scientologists and relatives of

Scientologists.

 

OPERATING TARGETS:

1. To make full use of all files on

the organization to effect your major

target. These include personnel files,

Ethics files, Dead files, Central files,

training files, processing files and

requests for refunds.

2. To assemble full data by inves-

tigation of each person located for possi-

ble use in case of attack or for use in

preventing any attack and to keep files of

 

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such." (This document was introduced and

admitted into evidence at the trial of the

underlying action against me.)

    If I had known of this policy and practice in 1969 I would never

have become involved with Scientology.

 

     9. The public statement by HUBBARD and the Scientology

organizations is that the purpose of auditing is to free individu-

als. Yet the real use to which auditing is put is to entrap and

control individuals.

 

    Many of the people in Scientology are HUBBARD's

unwitting dupes; they believe that, to some degree at least, their

participation in the covert and illegal use of confidential

auditing files has something to do with freeing individuals.

 

    HUBBARD's personal writings during the period of

his creation of Dianetics and Scientology, however, reveal a

completely different and very non-altruistic motivation. In these

writings, now under seal in the Los Angeles Superior Court,

HUBBARD wrote that he would control this sector of the Universe,

that all men will bow down to his will, and that he has the right

to use men's minds. There are approximately two hundred pages of

such writings presently under seal. These reveal HUBBARD's intent

to control people, his utter disregard for individuals' rights and

his megalomania. The illegal use to which he and his organization

have put and do put preclears' statements, made in confidence, fit

 

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with the pattern of HUBBARD's life and his mental state as shown

in the sealed documents.

 

    10. It is clear to me that the priest-penitent privi-

lege means nothing to HUBBARD or the Scientologists he controls,

other than as a vehicle to prevent the preclear from exerting his

privilege, and at the same time selectively using the information

from the files not relinquished to the preclear because they are

"privileged." It is just this sort of convoluted perversion of

the law and the individual's rights which has been HUBBARD's modus

operandi for more than thirty years.

 

    It is very clear that the refusal to deliver

" auditing" and "ethics" files, which have no possible legal use to

HUBBARD or the organization, is simply harassment.

 

    I declare under penalty of perjury that the foregoing is

true and correct.

 

     Executed this 11th day of February at Los Angeles,

California.

 

[signed]
GERALD ARMSTRONG
Declarant

 

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