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[CT 7779]

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
HANA WHTIFIELD
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 7780]

 

DECLARATION OF HANA ELTRINGHAM WHITFIELD

I, Hana Eltringham Whitfield, declare:

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

the State of California and I have personal knowledge of the

matters set forth herein, and if called upon as a witness

herein I could testify competently thereto.

2. I was an active member of the Church of Scientology

International, hereinafter "CSI," and its predecessor, the

Church of Scientology of California, hereinafter "CSC," from

March, 1965 to August, 1984.

3. Appended hereto as Exhibit [A] is a true and correct

copy of my declaration executed April 4, 1994 and filed in the

case of Church of Scientology International v. Steven Fishman

and Uwe Geertz , Case No. CV 91 6426 HLH. This declaration

provides accurate information as to my history in Scientology,

the positions I held and my responsibilities, the lengthy

training I received in the auditing techniques of Scientology

founder and leader L. Ron Hubbard, hereinafter "Hubbard," and

in his organization and executive management techniques, and

some of the extensive knowledge I have of Scientology's

policies, bulletins and procedures. It also contains a

description of the extreme hardships I experienced while a

Scientologist and the insidious "fair game" practices to which

my husband, Jerry Whitfield, and I were subjected after we

left Scientology and dared to discuss our experiences and

opinions. We continue to be targets of fair game to this day.

 

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[CT 7781]

 

4. My husband and I now work professionally with

families who have a loved one in Scientology. Families hire

us to inform and educate their loved ones about the secret and

hidden, and the actual, policies and practices of Scientology

and their dangers, and of Scientology's ongoing, complex

campaign to keep these secrets hidden from the public and from

most of its members until they have been completely

indoctrinated and are under Scientology's absolute control.

Having the information we provide, the loved ones are then

more able to make informed choices about their adherence to

Scientology and participation in its activities. My husband

and I also work with Scientologists who have doubts about

their involvement in Scientology and approach us on their own

for information. We have been doing this work of informing

and educating successfully since 1985.

5. Because of my long tenure in Scientology and holding

many executive positions, I have personal knowledge of the

fact that people are drawn into Scientology by false

representations and then held in it by various manipulative

techniques, often to their physical, emotional and mental

detriment.

6. As an example, I was drawn into Scientology in early

1965, in Johannesburg, South Africa, through reading Hubbard's

book, "Dianetics the Modern Science of Mental Health," by its

astonishing claims, some of which were:

A. Those who reach "clear," a state guaranteed by

 

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[CT 7782]

 

Hubbard, can be tested for any and all psychoses,

neuroses, repressions and compulsions (all aberrations)

and can be examined for any autogenetic (self-generated)

diseases, also known as psychosomatic ills, and the tests

will show the "clear" entirely free of such.

B. Tests of the clear's intelligence will show it to be

high above the norm.

C. A clear can remember everything that has ever

happened to him and everything he has studied.

D. A clear's health is greatly improved and he will

never again experience any psychosomatic illness

of any kind. A clear never gets colds.

E. A clear's ethical, moral and professional standards

are the highest.

F. A clear thinks and acts completely rationally in any

circumstances at any time.

7. After reading "Dianetics" I was convinced that

Hubbard had discovered the cure for all mental and physical

ills, that attaining clear was the most desired aim in the

world and should be sought by the whole human race. So strong

were my beliefs, started by my reading of "Dianetics," that I

held them unwaveringly for twenty years, despite experiences

that, were I in a normal frame of mind, would have caused me

to leave the group many years earlier, and despite continually

seeing behavior and mental and physical conditions in "clears"

and in Hubbard himself, which belied his Dianetics promises.

 

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[CT 7783]

 

8. The book, "Dianetics the Modern Science of Mental

Health," which is used extensively in the Scientology

organization in its initial "auditing" programs and " auditor"

training, was considered so important by Hubbard and

Scientology's senior management executives, that its public

bookstore sales records were manipulated and falsified for

years by Scientologists in order to keep it on the U.S. "best

seller" lists. "Auditing" is Scientology's psychotherapeutic

processing, which it calls, for "religious" purposes,

"pastoral counseling."

9. While becoming involved in the Johannesburg

Scientology Organization I also heard many stories about

Hubbard and read Scientology's biographies about him. These

included the stories that he was a much decorated hero of

World War II, that he received extensive war wounds including

blindness and lameness, yet recovered fully through his own

research and techniques, which he had further developed into

Dianetics and included in his book. I was deeply impressed

with what I heard and read about him.

10. I know hundreds if not thousands of Scientologists

across the years who were drawn into Scientology by the same

claims as I was.

11. Once in contact with Scientologists, neophytes (what

Scientologists cynically call "raw meat") are manipulated and

indoctrinated rapidly and more deeply into an array of false

and delusionary convictions about Scientology. From personal

 

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[CT 7784]

 

experience some of these are:

A. That only Hubbard's procedures in Scientology can

break one free of the repetitive, never-ending birth-

death pattern, also known as reincarnation, a core belief

of Scientology. It is often stated that "Scientology is

the only road to total freedom."

B. That only Scientologists have the answers to the

Universe and Life itself.

C. That only by strict and unconditional adherence to

Scientology's policies and practices, can one regain

one's complete abilities and eternal survival as a

spiritual being.

D. That the whole human race except for Scientologists

is doomed to eternal oblivion.

E. That a Scientologist will only progress in life and

reach his spiritual and physical goals by living and

associating with other Scientologists, to the point of

severing connections to family and/or spouse and children

and/or friends if they are disinclined to become

Scientologists, are slow in showing interest, or express

criticisms or diverging perspectives to those of

Scientology.

F. That a Scientologist living on his own in a non-

Scientology or "wog" community will be unable to maintain

the improvements he achieved in Scientology, but will

uncontrollably deteriorate into, the same eternal

 

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[CT 7785]

 

oblivion destined for "wogs."

G. That people who frequently display emotions of

antagonism, anger, fear, sorrow, apathy or even chronic

pain, are deemed by Hubbard to be chronically "down tone"

or low in emotional tone. Hubbard wrote that such people

cannot be reasoned with, that they do not deserve any

civil rights of any kind and that one of two ways to deal

with them is to dispose of them quietly and without

sorrow. From this contemptuous and antisocial attitude

the fair game doctrine became acceptable to

Scientologists.

H. That all Hubbard's writings, taped lectures,

policies, bulletins and techniques are "sacred

scriptures" which cannot be changed or canceled except by

Hubbard himself - even though he died in 1986.

I. That all Hubbard's writings, taped lectures,

policies, bulletins and techniques - the sacred

scriptures - are correct as written and any disagreement

with them or difficulty with them by anyone reading or

studying them is the reader's or student's fault, not

Hubbard's.

J. That any criticism of Hubbard, his family, writings,

techniques, policies or philosophy is tantamount to a

criminal act and shows that the person has undisclosed

crimes against Hubbard or Scientology.

K. That if a person's information can be controlled the

 

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[CT 7786]

 

person can be controlled. Hubbard was a master of

control of information within Scientology's ranks.

L. That criminal or socially deviant actions which were

carried out by Scientology and later exposed, were

"against policy" and done by misguided "individuals" who

went astray.

12. The most glaring example of how Scientology deals

with its exposed criminality is the following. In 1966

Hubbard formed within Scientology and organization called the

Guardian's Office, hereinafter "GO." Its publicly stated

purpose was to "safeguard Scientology." Its hidden agenda,

based on Hubbard's policies or "scriptures," was to attack,

sue, intimidate, harass and threaten into silence anyone who

spoke and wrote negatively about Hubbard and his group. The

vast majority of Scientologists knew nothing of the acts,

including serious crimes, against people, or Hubbard's secret

policies which brought them into being. They believed the GO

was constructively extending Scientology's influence

into society through social programs such as education, drug

addiction, conducting charity drives, and other public

relations " good works." When eleven top Scientology

executives, including Hubbard's wife Mary Sue Hubbard, were

convicted and imprisoned in the late 1970s Scientologists the

world over, including my husband and me, were told that the

trial was unjust in the extreme as all Mary Sue and her GO

staff had done was steal xerox paper. We never were told that

 

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[CT 7787]

 

the eleven GO staff were imprisoned for obstruction of

justice, breaking into Justice Department offices, wire

tapping, and impersonating federal officials, among other

things. We were also never told about the GO's covert

intelligence operations and terror tactics against targeted

individuals, how the GO set them up in "crimes,"and had them

falsely prosecuted, which surfaced through the 1977 FBI raid

on GO headquarters in Los Angeles and Washington, D.C.

Scientology staff were forbidden to read newspapers and

magazines or to watch TV in the late 1970s and early 1980s at

Scientology's central base in Clearwater, Florida, and we were

forbidden to speak to journalists; all of which prohibitions

kept us uninformed of true events. Then in the early 1980s,

due to its tarnished public image, the GO was renamed the

"Office of Special Affairs," hereinafter "OSA," and was

allegedly " reorganized." Scientologists over the world were

told that those responsible for the crimes had been removed

and that "we don't do that anymore."

13. The experiences of many former Scientologists during

the post-GO, OSA era, however, including those of Gerald

Armstrong, hereinafter "Armstrong," and my husband and me, as

well as lawyers litigating against Scientology and other

viewed " enemies," show that the practices of harassment,

intimidation, threats, law suits and more continue unabated.

In essence, the practice of fair game goes on as before.

14. In our work, my husband and I use a great deal of

 

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[CT 7788]

 

information made public by Armstrong. This includes his

declarations in various lawsuits as well as his own lawsuit,

Church of Scientology of California v. Gerald Armstrong, Mary

Sue Hubbard Intervenor, Los Angeles Superior Court No. C

420153, which resulted in 1984 in the widely known and used

" Breckenridge decision." This decision, in Armstrong's favor,

condemned fair game and other Scientology practices including

the misuse of Scientologists' confessions in supposedly

confidential auditing sessions. The Armstrong case also

brought to light Armstrong's discoveries of many lies Hubbard

told about his past and his credentials, which were used in

Scientology's promotion and marketing of its services, as well

as fair game actions against perceived enemies.

15. The information about Scientology's secret agenda,

fair game practices and Hubbard's misrepresentations which was

revealed through the Armstrong trial and case provided many

Scientologists access to the truth about Scientology for the

first time, and enabled many to break free from Hubbard's and

Scientology's manipulation and hold.

16. My husband and I have ourselves been targets of

extensive fair game operations and "black propaganda," since

1985. Black propaganda is a term Hubbard used to designate a

practice of destroying someone's reputation with lies, often

from hidden or unnamed sources. Those operations that my

husband and I know of are detailed in my declaration, Exhibit

A, at paragraphs 69 to 93 and 128 to 135. In summary, we have

 

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[CT 7789]

 

been subjected to:

A. Surveillance by Scientology hired private

investigators, hereinafter "PI's," and Scientology staff

24 hours a day for weeks at a time in the United States

and Europe.

B. Surveillance by Scientology PIs and staff while

talking with families and their loved one.

C. Repeated false accusations on TV, radio and in

writing, that we were kidnappers and do forced

deprogrammings.

D. Repeated attempts to obtain our long distance phone

records.

E. Invasion of our AMEX credit card accounts by

impersonating my husband.

F. Harassment of our families in America, Europe and

South Africa by Scientology PI's, some of whom

represented themselves as federal government officials.

G. Filing false complaints against us with various

State authorities. None of these came to anything.

H. Attempting to implicate my husband falsely in a bomb

threat against a Scientology front group, Sterling

Management Systems, in 1989. (In the late 1970s

Scientology was found responsible for the harassment of

New York freelance writer Paulette Cooper, including the

manufacture of false bomb threats by Cooper.)

I. Harassment of at least fifty of our friends and

 

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[CT 7790]

 

associates by Scientology PI's in America, Canada, Europe

and Australia.

J. Creation of "dead agent" packs of information

designed to destroy my husband's and my reputations.

Innumerable copies of these, each different from the

last, have been mailed to friends and colleagues, and

even persons we did not know, and handed out at

conventions, conferences and meetings of former

Scientologists and/or former cult members. Dead agent

packs on myself include three different, and false,

charges that I killed my father thirty years ago, that I

masterminded his murder by another, and that I attempted

the murder myself. The packs contain photographs of a

severely battered, bruised and unrecognizable dead man's

face. They contain my younger sister's 1946 affidavit

which detailed incest she experienced while growing up.

They contain memos written in the early 1990s by my

former husband Guy Eltringham, an active Scientologist,

to OSA, giving them information about me under the

headings, " Possible means to reduce her influence or

effect," and "Other information which possibly would not

be in her ethics or pc ("preclear," auditing, or

"pastoral counseling") files."

K. David Miscavige, head of Scientology world wide,

falsely told over 700 top Sea Organization staff in the

early 1990s that I killed my father and was serving time

 

 

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[CT 7791]

 

in a South African prison. (The Sea Org is the top

echelon of Scientology management and operations wherein

the members sign a contract for a billion years.)

L. False accusations by Scientology attorneys that my

husband and I were guilty of theft of Scientology

documents.

M. A malicious and completely unsubstantiated lawsuit

filed against my husband and me for "false imprisonment."

The plaintiff, a Scientologist, who was following us, was

stopped and briefly detained by police for suspicious

behavior and apparently driving an unlicensed vehicle.

Thereafter he filed the lawsuit against us. He dismissed

the suit in 1993.

N. Scientologists have repeatedly demonstrating outside

our home, carrying signs and handing out leaflets stating

that we are kidnappers, that I am a murderer, and my

husband a thief, drug dealer and wife beater.

17. While in Scientology and going through extensive

training in Hubbard's auditing techniques, I was gradually

exposed to and became familiar with Hubbard's writings and his

attitudes concerning God, Jesus Christ and Christianity.

18. In 1965, after I arrived at Hubbard's then worldwide

Scientology Headquarters at Saint Hill in East Grinstead,

England, I was a full time student. Toward the end of 1965 or

early 1966, because of a wave of anti-Scientology sentiment in

the press, Hubbard gave orders that all Saint Hill "auditors"

 

 

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[CT 7782]

 

were to wear clerical garb and a "Scientology cross," and that

from then on "Sunday Services" were to be held in the

"Chapel." In fact the "Chapel" was routinely and usually used

as a course room. It was the course room in which I studied

10 or more hours daily, and sometimes seven days a week. I

was confused when I first heard Hubbard's orders; I had not

previously known his public statement that Scientology was a

religion. Hubbard further told the Saint Hill staff and

students, myself included, that his orders were to create the

impression among the government, press and public that

Scientology was a proper religion. But it was common

knowledge among dedicated Scientologists that Hubbard's orders

were designed to deceive non-Scientologists in order to gain

acceptance for Scientology.

19. In 1966, while studying the upper levels of the

"Saint Hill Special Briefing Course," which covered all of

Hubbard's " technical" developments from 1950 to 1966, I

studied a bulletin entitled "Routine 3 Heaven," dated May 11,

1963, a true and correct copy of which is appended hereto as

Exhibit [B]. In it, to my increasing astonishment and concern,

Hubbard wrote that he did not believe in Christianity, God,

Heaven and Christ. He wrote, moreover, that he had just

discovered that Heaven did exist as an electronic implant,

that it was created by an false belief by an "implant station"

43 trillion years ago, that the implant contained "angels,"

"plaster saints," signs to "Hell," the "pearly gates,"

 

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[CT 7793]

 

"Joseph, " the "Madonna and child," "Bethlehem," and various

other Biblical symbols. Hubbard wrote that the implant,

Heaven, was false and full of lies, and that religion was

based on lies. He wrote that the "Creator of Heaven" had

entrapped us all and that only Scientology had the way to free

us again.

20. Having been brought up in a basically Christian

family, and having attended church regularly while growing up,

and personally believing in Christ and God, I was shocked to

read this and other related bulletins with similar anti-

Christian and anti-religion assertions.

21. However, because of Hubbard's claims in the bulletin

that the information was discovered through thousands of hours

of " scientific research" and not based on opinion, that all

Scientology data came from "long, arduous and painstaking

research" and is "common to all minds and all men and can be

demonstrated on anyone," and that he and Scientology sought

"freedom, the betterment of Man," that he had researched and

compiled it for "the greatest good for the greatest number,"

and, importantly, that honest people could accept it, and

because of my faith in Hubbard, I consciously chose, without

further independent investigation, to accept it as correct

over the religious faith of my upbringing. All Scientologists

who get past this point do the same.

22. From then on I felt I was one of the initiated, one

of the chosen and that I was really on the "Road to Total

 

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[CT 7794]

 

Freedom." The "special" nature of Scientology and its unique

role in the salvation of mankind was deeply re-emphasized in

my mind. From then on I was fully aware of Hubbard's

duplicity in molding Scientology's double agenda. Externally

Scientology showed itself as religious and sensitive to deep

social and humanitarian issues and actively participating in

social activities of all kinds. Internally it condemned all

religious believers as aberrated and worthless, and, depending

on their degree of opposition to Scientology, labelled them

merely a nuisance, or suppressive and "fair game."

23. From that point on I regularly read Hubbard's

writings or listened to his tape lectures which stated his and

Scientology's anti-religious beliefs and practices. In late

1968 or early 1969, on board Hubbard's flagship, the "Royal

Scotman," I read a bulletin by Hubbard entitled "Resistive

Cases Former Therapy," dated September 23, 1968, a copy of

which is appended hereto as Exhibit [C], which expanded on his

"scientific research" assertion that God and Christ are

electronically implanted ideas. He wrote that Christ was part

of an implant 75 million years ago, that the Niocene Creed

invented Him to "implant their way to power," and that the

Christian Church still uses implanting.

24. Miscavige, Scientology's current leader, recently

mandated that eligibility for OT 9 and OT 10, the "top" levels

on Scientology's auditing pyramid not yet "released" for

public consumption, includes completing the "Saint Hill

 

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[CT 7795]

 

Special Briefing Course." From personal experience I can

verify that the more a Scientologist is exposed to and

indoctrinated in Hubbard's fantastic beliefs and ideas, the

more ardent, aggressive and criminally inclined the

Scientologist becomes, and more like Hubbard.

25. Throughout the years I practiced and applied

Hubbard's auditing techniques, in the 1960s, 70s and 80s, I

can verify that those Scientologists who held onto religious

and spiritual beliefs and values not espoused by Scientology,

despite being gradually exposed to teachings such as those in

Exhibits B and C hereto, were considered particularly

"aberrated." In the early stages of their adherence to

Scientology, such persons were quietly tolerated and smugly

labeled as " former therapy cases." (Ex. C) Then at some

point, and at the direction of their "case supervisor," they

were ordered into specific auditing actions designed to

systematically desensitize their particular religious beliefs

and ideas. They were also frequently ordered to obtain "case

cracking auditing" to resolve their "religious aberrations"

and to simultaneously study Scientology teachings.

26. This was done not only with Christian-thinking

people. During the years of 1968 through the early 1970s when

we sailed the northern African and Moroccan coastlines with

Hubbard, I heard him say several times that any Arab or

Moroccan who wanted to join the ship's crew could do so as

long as he or she passed basic security requirements, and

 

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[CT 7796]

 

could remain on board indefinitely only if he or she fully

converted to Scientology and had received full auditing

resolution of his or her former beliefs and practices.

Hubbard said that only such full conversion would raise them

above suspicion and enable them to stay.

27. I feel very strongly that it is in the public's

interest to continue to have complete access to information

that Armstrong helped make public, and in which he is an

authoritative source. Public individuals and Scientologists

have a right to all the information available about

Scientology, both good and bad.

28. It is unconscionable that Scientology thinks that it

can say whatever it wants about Armstrong's information and

knowledge, about his legal cases, and about Armstrong himself

, and that Armstrong cannot even respond, much less have the

same freedom to say what he knows to be true about himself and

Scientology. It is unconscionable that Armstrong's former

attorney Michael Flynn, in order to get himself out from under

the threat of fair game, permitted such an agreement to be

presented to Armstrong and his other clients to "settle" their

cases. It is also unconscionable that any court in this or

any country could consider, much less order, the enforcement

of such an " agreement." There are very few who stand up to

the evil that Scientology practices. These should be

supported by our justice system, not silenced.

I declare under the penalty of perjury under the laws of

 

-17-

   

 

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[CT 7797]

 

the California that the foregoing is true and correct.

Executed in Los Angeles. California this 6th

day of April, 1995.

 

[signed Hana Whitfield]
Hana Eltringham Whitfield

 

- 18-

This document in .pdf format

 

   

    

Exhibit [A]
Revised Declaration of Hana Whitfield re Motion for Costs 03-08-1994

Exhibit [B]
HCOB May 11, AD 13 [1963] ROUTINE 3 HEAVEN © 1963 L. Ron Hubbard

Exhibit [C]
HCOB 23 September 1968 RESISTIVE CASES FORMER THERAPY © 1968 L. Ron Hubbard

   

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