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[CT 7507]

HUB LAW OFFICES
Ford Greene, Esquire
California State Bar No. 107601
711 Sir Francis Drake Boulevard
San Anselmo, California 94960-1949
Telephone: (415) 258-0360

Attorney for Defendant
GERALD ARMSTRONG

SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF LOS ANGELES

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

        Plaintiffs,

vs.

GERALD ARMSTRONG; DOES 1
through 25, inclusive,

         Defendants.


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No. BC 052395

DECLARATION OF GARRY L. SCARFF
IN SUPPORT OF OPPOSITION TO
MOTION TO COMPEL

Date: February 19, 1993
Time: 8:30 a.m.
Dept: 30

Trial Date: May 3, 1992
Discovery Cut-Off: None
Motion-Cut-Off: None

 

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GARRY L. SCARFF declares:

1. My name is GARRY L. SCARFF. I live at 2137 N.E. Weidler

St., Portland, Oregon 97232. My telephone number is (503) 281-

9088. I am above the age of eighteen years old and provide the

following testimony of my own first-hand knowledge. I could and

would provide the same testimony in open court were I required to

do so.

2. From 1982 through August 1992, I was a member of the

CHURCH OF SCIENTOLOGY. For the two years preceding 1992 I was an

operative of SCIENTOLOGY in the Los Angeles area where I have

 

 

Page 1           DECLARATION OF GARRY L. SCARFF IN OPPOSITION TO MOTION TO COMPEL

   

 

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[CT 7508]

worked closely with EUGENE INGRAM, a licensed private investigator

whose income is solely derived from SCIENTOLOGY.

3. EUGENE INGRAM, at the direction of SCIENTOLOGY, has

attempted to ruin FORD GREENE on a personal and professional basis

because of his activities on behalf of the Cult Awareness Network,

his outspoken and public criticism of SCIENTOLOGY, his

representation of former Scientologists, particularly Richard and

Vicki Aznaran, and his current working relationship with GERALD

ARMSTRONG, a former high-ranking Scientologist.

4. The operations against FORD GREENE are coordinated

through the CHURCH OF SCIENTOLOGY INTERNATIONAL in Los Angeles.

In this regard, I knew that the person who directed and controlled

these operations was DAVID MISCAVIGE, the head of Scientology.

5. In 1987 I was directed by SCIENTOLOGY to represent

myself as a survivor of the People's Temple immolation in

Jonestown, Guyana and befriend FORD GREENE in order to perpetrate

a Scientology operation on him. During Christmas 1987 FORD

invited me to spend the holiday with him. When I was in his

office alone during that period of time, I availed myself of his

confidential legal records, legal files of his clients, a rolodex

of his contacts and photographed his office.

6. In approximately September 1991 at a McDonald's

Restaurant located in Albany, Oregon, EUGENE INGRAM showed me a

letter to the Federal Bureau of investigation which I read. The

letter from INGRAM stated that FORD GREENE was involved in the

trafficking of drugs and the misuse of his law office by trading

homosexual favors for the rendering of legal services. INGRAM

frequently discussed his desire to have FORD GREENE indicted under

 

Page 2          DECLARATION OF GARRY L. SCARFF IN OPPOSITION TO MOTION TO COMPEL

   

 

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[CT 7509]

the RICO statutes.

7. On or about December 20, 1991, I attended a meeting at

SCIENTOLOGY's OFFICE OF SPECIAL AFFAIRS in Los Angeles where the

law offices of BOWLES and MOXON are located. Present at that

meeting were the following individuals: KENDRICK MOXON, TIMOTHY

BOWLES, RANDY SPENCER and ERIC MORAN, all of whom are attorneys at

Scientology's in-house law firm, BOWLES AND MOXON. Also present

were EUGENE INGRAM, and DAVID BUTTERWORTH, the director of

Scientology's OFFICE OF SPECIAL AFFAIRS. One purpose of this

meeting was to develop a plan to destroy the personal and

professional credibility of FORD GREENE and to continue attempts

to have him disbarred from practicing law because he represented

litigants against SCIENTOLOGY.

The operations that were proposed and developed at this

meeting included the following:

a. To create a public scheme portraying FORD GREENE as a

sex fiend. This was to be accomplished through EUGENE INGRAM's

manipulation of Margery Wakefield, a former client of FORD GREENE

with a history of mental instability. INGRAM was to go to Florida

and dupe Ms. Wakefield into signing a declaration that would be

detrimental to FORD GREENE.

b. INGRAM asked me to execute a declaration stating that

when I stayed with FORD GREENE over the Christmas holidays in 1987

Ford induced me to get drunk on alcohol and stoned on marijuana at

which time INGRAM told me to state that FORD sodomized me and

forced me to orally copulate him. INGRAM also told me to state

that I did not admit to this in an earlier (false) declaration

because FORD was to have threatened to send his drug dealer

 

 

Page 3          DECLARATION OF GARRY L. SCARFF IN OPPOSITION TO MOTION TO COMPEL

   

 

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[CT 7510]

contacts to kill me if I stated anything of the homosexual attack.

c. INGRAM also wanted me to swear that FORD GREENE was a

paying and frequent patron of a San Francisco bathhouse, that FORD

GREENE was infected with the AIDS virus, and was intentionally

passing it to others.

d. INGRAM also sought to expand on what he called the "fuck

buddy" relationship between FORD GREENE and GERALD ARMSTRONG. One

of INGRAM's suggestions was to set FORD GREENE up with a new male

client who then would provide a declaration swearing that GREENE

agreed to barter his legal services in return for sex.

e. Another of INGRAM's suggestions was that I go to San

Anselmo and break into and enter GREENE's office when he was not

present and plant cocaine and child pornography in his desk and

then advise the police of GREENE's illegal possessions.

f. Ingram also suggested tampering with FORD GREENE's

automobile by severing its brakes lines in order to produce a

serious accident. When I said to Ingram that it could also kill

GREENE, INGRAM responded, "There's no loss in a dead fag." INGRAM

also suggested orchestrating an accident involving GREENE on the

Golden Gate Bridge that would result in GREENE's car going over

the side of the Bridge.

g. INGRAM and SCIENTOLOGY have also attempted to have

GREENE disbarred by filing complaints with the State Bar.

8. At the instigation of EUGENE INGRAM, DAVID BUTTERWORTH

and the aforementioned attorneys in BOWLES AND MOXON I have

executed declarations in which I made false statements of fact.

With respect to FORD GREENE, the false statements of fact that I

made included, but were not limited to, the following:

 

Page4           DECLARATION OF GARRY L. SCARFF IN OPPOSITION TO MOTION TO COMPEL

   

 

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[CT 7511]

a. FORD GREENE is a homosexual. The truth is I have no

basis for this statement;

b. FORD GREENE frequented the Castro Street area (a gay

area) in San Francisco. I have no factual basis for this

statement;

c. While nude FORD GREENE hugged me and would not let go.

This is false.

d. GREENE took a picture of me, naked, as I was leaving the

shower. This is false.

9. INGRAM, BUTTERWORTH and lawyers at BOWLES AND MOXON

repeatedly expressed that they would do anything to prevent GERALD

ARMSTRONG and FORD GREENE from working together.

Pursuant to the laws of the State of California, I hereby

declare the foregoing to be true and correct. Executed on

February 11, 1993 at Portland, Oregon.

 

[Signed] Garry L. Scarff

GARRY L. SCARFF

 

Page5           DECLARATION OF GARRY L. SCARFF IN OPPOSITION TO MOTION TO COMPEL

This document in .pdf format.

 

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