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[CT 7960]

Gerald Armstrong
715 Sir Francis Drake Boulevard
San Anselmo, CA 94960
(415) 456-8450
In Pro pria Persona

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

CHURCH OF SCIENTOLOGY INTERNATIONAL,
a California not-for-profit
religious corporation,

        Plaintiff,

    vs.

GERALD ARMSTRONG; MICHAEL WALTON;
THE GERALD ARMSTRONG CORPORATION
a California for-profit
corporation; DOES 1 through 100,
inclusive,

         Defendants.


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CASE NO. 157 680

DECLARATION OF
JONATHAN ATACK
IN OPPOSITION TO
MOTIONS FOR SUMMARY
ADJUDICATION OF 20TH
CAUSE OF ACTION; AND
13TH, 16TH, 17TH &
19TH CAUSES OF ACTION
OF SECOND AMENDED
COMPLAINT

Date: 4/21/95
Time: 9:00 a.m.
Dept: One
Trial: 5/18/95

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[CT 7961]

 

DECLARATION OF JONATHAN CAVEN-ATACK

 

    I, Jonathan Caven-Atack, declare:

    1. 1 am over the age of 18 years. I am a citizen of and resident in
the United Kingdom. I have personal knowledge of the matters set forth
herein, and if called upon as a witness I could testify competently thereto.

    2. 1 am making this declaration in support of Gerald Armstrong's
opposition to motions by the Church of Scientology International for
summary adjudication.

    3. This declaration is a supplement to another headed "General
Report on Scientology
", and should be consulted in conjunction with that
other declaration.

    4. 1 am the author of the book A Piece of Blue Sky (ISBN 0-8184-
0499-X), a 400-page history and analysis of Hubbard and his organizations
published by Lyle Stuart Books in the United States.

    5. A true and correct copy of my booklet, The Total Freedom
Trap - Scientology, Dianetics and L. Ron Hubbard
, is appended hereto
as Exhibit [A].

    6. The testimony of Gerald Armstrong in his successful defence
against the Church of Scientology before Judge Paul Breckenridge (Los
Angeles Superior Court case no. C 420153) was an important source of
information for both of these publications. Armstrong's testimony was
supported by that of other witnesses and through the production of
numerous documents. Scientology accepted the validity of these
documents and was indeed trying to recover them to prevent publication.
These documents included Hubbard's records of black magic ceremonies
and hypnotic rituals he had performed. Testimony and exhibits also added
to existing evidence concerning Hubbard and Scientology's immoral and
illegal attacks upon their perceived opponents under the supposed
"scriptural doctrine" of "Fair Game". Much of the evidence in the case
was brought to light for the first time. This information has been of
tremendous use in freeing victims of Scientology from its deceptions and
pernicious effects.

    7. As Judge Breckenridge ruled "in addition to violating and
abusing its own members' civil rights, the organization over the years with

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[CT 7962]

its 'Fair Game' doctrine has harassed and abused those persons not in the
Church whom it perceives as enemies."

    8. As soon as I began to openly discuss my views concerning
Scientology's immoral practices, I became the target of "Fair Game". I
have been "tricked", "sued" and "lied to", as yet I have not been
"destroyed". In 1980, executives of Scientology's Intelligence Agency, the
Guardian's Office, admitted to a United States court that the doctrine of
Fair Game had never been withdrawn. On 22 July 1980, the Fair Game
doctrine was "cancelled" for the first time in Scientology's history
(Hubbard Communications Office Policy Letter, "Ethics, Cancellation of
Fair Game More About"). On 8 September 1983, the Church of
Scientology International rescinded this cancellation, re-instituting "Fair
Game" as a scriptural doctrine (Hubbard Communications Office Policy
Letter, "Cancellation of Issues on Suppressive Acts and PTSes"). Those
Scientologists who are aware of the doctrine are obliged to follow it as if it
were legally binding. It is a part of their contract with Scientology.

    9. Scientology has admitted that the Guardian's Office had control
of all Scientology organizations until 1982. It is claimed that at that time,
the 1,100 "criminals" who comprised the international staff of the
Guardian's Office were dismissed. Factually, many of these staff members
have been re-employed. The various "bureaux" of the Guardian's Office
were replaced by the Office of Special Affairs, the International Finance
Police, and the Association for Better Living and Education. The Office of
Special Affairs houses the successor organizations to the Guardian's
Office intelligence branches. The former Branch Two, which dealt with
"overt data collection", has been restyled "Office of Special Affairs
Investigation" or "Invest". The former Branch tine (B-1), which dealt with
"covert data collection" and "covert operations", uses lawyers to employ
private detectives to collect information and run harassment campaigns. I
have been the subject of such campaigns for over eleven years.

    10. Appended as Exhibit [B] is a recent example of the Fair Game
campaign against me, an anonymous booklet called Anatomy of a
Propagandist
. The author of this booklet obviously had access to an
unsworn deposition which has not been entered in any case. Such access
could only have been gained through Scientology attorneys Bowles and
Moxon. The booklet largely consists of fabricated or grossly exaggerated
attacks upon my character. I am currently engaged in litigation against
Scientology in the UK for malicious falsehood for the publication of

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[CT 7963]

similar libels and a campaign to destroy my public repute by making
anonymous complaints against me.

    11. Hubbard ordered his subjects to "attack the attacker". Rather
than address the real concerns raised by legitimate enquiry into its
practices and policies, Scientology carries out an ad hominem attack on
the person raising the concerns. This practice, which Hubbard dubbed
"black propaganda" or "dead agenting", is designed and intended to
destroy the dissenter's character and credibility so as to draw attention
away from legitimate concerns. In this way, Scientology need not reform
its practices and can continue with its antisocial behaviour, by bullying
critics into silence. Numerous individuals have been silenced through such
intimidation.

    12. 1 am aware that Gerald Armstrong has been the subject of an
international "Fair Game" campaign. For example, in 1987, after
Armstrong and Scientology had supposedly made peace, I was contacted
by Richard Palmer, a journalist at the London Sunday Times newspaper.
Palmer told me that he had just been visited in London by private detective
Eugene Ingram an employee of Scientology attorneys Bowles and Moxon.
Palmer gve me the business card Ingram had given him and a video tape
extracted from surveillance tapes of Armstrong illegally taken by
Scientology in or about 1985. Scientology has never relented in its attack
upon Armstrong, taking the position that after his "settlement" Armstrong
should be entirely silent about Scientology, but that Scientology could
continue its campaign of defamation against him. It is my understanding
that under this "settlement agreement" Scientology is requesting that
Armstrong pay $50,000 for each statement he makes to anyone concerning
Scientology. This obtains even if his statements are made to correct
Scientology's character assassination of him. It seems unbelievable that
the United States courts could become party to this use of the Fair Game
law.

    13. I sincerely believe that a guarantee of Armstrong's freedom of
speech is vital so that individuals can make informed decisions about
Scientology: I cannot believe that any rational individual would join
Scientology if they were aware of the proven statements of Gerald
Armstrong. Denying such informed consent would be tantamount to
intellectual fascism, and comparable to the Nazi book burnings.

    14. Since 1954, Scientology has drawn upon its constitutional right
to style itself a "religion" in the United States. The same right is of

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[CT 7964]

course granted to other organizations with their origins in black magic
and an antidemocratic manifesto. I have known Gerald Armstrong for
almost eleven years. He is a man of integrity and honour. He has
nothing to gain and everything to lose in his brave struggle to tell the
world the truth about Hubbard and Scientology. 1 know that he
follows this path as a matter of religious conviction. He feels that he
cannot take the easy way out, but must stand up for the truth, even
though he is a lone individual standing up to an organization with
hundreds of millions of dollars and tens of thousands of members. If
Hubbard is to be seen as the founder of a religion, surely he must be
subjected to the same scrutiny that other religious leaders are
subjected to. As a Christian might analyse Buddhism, so Armstrong
has the right to analyse from his own religious perspective the life
and teachings of Hubbard and the activities of Hubbard's " church".
The United States Constitution upholds freedom of belief, so must
also uphold freedom of disbelief. The Constitution also upholds free
speech. Scientology does not charge Armstrong with defamation, but
seeks to prevent him from telling the truth. Scientology does this to
protect its own economic interests by subverting the free will of its
members through information control.

    15. It is ridiculous to think that a Christian church would use the
judicial system to prohibit one of its former parishioners from talking about
the Trinity or the historical truth of the life of Jesus. It is frightening to
think that the courts may silence Armstrong who is afer all pointing out
the irrefutable truth that Hubbard was a black magician who specialised in
controlling his victims through hypnosis and exploitative persuasion.
Hubbard's own documents and many witnesses support this view
conclusively.

    16. 1 have researched and have knowledge concerning
Scientology's Fair Game operations against Armstrong's attorney Michael
J. Flynn. Flynn was an opponent of Scientology from 1979 to 1986. He
championed the victims of Scientology and bravely resisted its smear
campaigns, intimidation and legal attacks upon him. In my own dealings
with Flynn towards the end of 1986 it became apparent that he was weary
of the unrelenting harassment. It is my sincere belief that Flynn was bullied
into submission. This opinion is supported by Flynn's failure to support
Armstrong in his courageous stand against Scientology's Fair Game
litigation. I have seen documents which purport to be part of a settlement
between Flynn and Scientology and can only suppose that he has been
subject to a "settlement" which has scared him out of supporting his client.

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[CT 7965]

    17. In November 1994, the Church of Scientology sought to compel
my deposition testimony in its case against Armstrong. Under English law,
deposition testimony can only be obtained if a witness is unavailable to
give testimony at trial. In April 1995, 1 gave an undertaking to the English
court that I was willing to give testimony in this action. My offer has been
declined. I can only interpret this as a desire on the part of Scientology to
perform cross-examination without giving Armstrong the opportunity to
examine me.

    I declare under the penalty of perjury under the laws of the United
States of America and the United Kingdom that the foregoing is true and
correct to the best of my knowledge and belief.

    Executed in Radcliffe-on-Trent, England, this 9th
day of April, 1995,

[signed]
Jonathan Caven-Atack

 

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Exhibit [A]
The Total Freedom Trap - Scientology, Dianetics and L. Ron Hubbard by Jonathan Caven-Atack

Exhibit [B]
Anatomy of a Propagandist

 

 

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