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DECLARATION OF KENNETH LONG

I, KENNETH LONG, declare as follows:

1. I am over 18 years of age and a resident of the State

of California. The matters set forth herein are based on my

personal knowledge.

2. On Marsh 15, 1990, Gerald Armstrong ("Armstrong")

executed a declaration in the above-captioned case. His

declaration was tiled in support of plaintiff's Motion for an

Order Directing Non-Interference with Witnesses and

Disqualification of Counsel and, in paragraphs 22-31, 33-35 and

38-39, Armstrong referred to several affidavits I executed in

October, 1987.

3. The crux of Armstrong's complaint about

those affidavits is probably found at paragraph 35 of his

declaration. There, Armstrong quotes from an affidavit I

executed on October 7, 1987, and in which I described my

January, 1987 discovery that Armstrong had knowingly violated

orders issued by Los Angeles Superior Court. Taken together,

my October, 1987 affidavits demonstrate that:

a. In August, 1982, Armstrong was ordered by

Judge John L. Cola to surrender certain documents

and materials to the custody of the Clerk of the

Los Angeles Superior Court.

b. Armstrong later attested, on numerous

occasions, that he had surrendered all such

documents and materials, and that he had none in

his possession.

c. In January, 1987, following settlement of

 

 

   

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Scientology of California ("CSC"), Armstrong

turned over to CSC all Church-related documents in

his possession. I personally inspected the

documents turned over by Armstrong, and found a

number of copies of the documents which Armstrong

had previously sworn that he had surrendered to

the Clerk of the Court.

d. Based on my discovery of these documents,

I concluded that Armstrong had intentionally

perjured himself on numerous occasions, and had as

well knowingly violated orders issued by judges at

all levels ranging from the Los Angeles Superior

Court to the Supreme Court of the United States.

4. These affidavits ware executed in the case of Church

of Scientology of California v. Russell Miller and Penguin

Books, Limited ("Miller"), Case No. 6140 in the High Court

of Justice located in London, England. In Miller, CSC sued

author Russell Miller and his publisher Penguin Books for

breach of confidence arising out of Miller's use of some of the

documents described in paragraph 2 above. Under United Kingdom

legal procedure, since CSC had made out a prima facie case for

breach of confidence against Armstrong in Church of

Scientology of California and Mary Sue Hubbard v. Gerald

Armstrong, LASC Case No. C 420153, it was possible to extend

that breach of confidence claim to Miller and Penguin Books by

linking them to Armstrong. The affidavits, therefore, were required to

detail the elements of the breach of confidence

claim against Miller and Penguin, and the claim could not have

 

 

   

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been brought without explaining the underlying actions taken by

Armstrong.

5. There is no provision in the settlement agreement with

Armstrong which would prohibit CSC from using information

obtained through litigation with Armstrong in seeking legal

remedies for wrongs committed by third parties.

I declare under penalty of perjury under the laws of the

State of California that the foregoing is true and correct.

DATED: March 26, 1990

 

[signed]
Kenneth Long

 

 

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