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[CT 8052]

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
LAWRENCE WOLLERSHEIM
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 8053]

 

DECLARATION OF LAWRENCE WOLLERSHEIM

I, Lawrence Wollersheim, declare:

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

the State of Colorado. I have personal knowledge of the

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

could testify competently thereto.

2. I was an active member of Scientology from the

period of 1968 - 1969 through 1979 - 1980.

3. I am the plaintiff in the case of Wollersheim v.

Church of Scientology of California, Los Angeles Superior

Court No. C 332027. After a four and one half month trial in

1986 I was awarded a judgment against Scientology in the

amount of $30,000,000.00. On appeal, the California Court of

Appeal upheld the judgment but reduced the damages awarded to

$2,500,000.00. Wollersheim v. Scientology, 260 Ca1.Rptr. 331

(1989), upheld by the United States Supreme Court.

4. I have also been sued twice by Scientology pursuant

to its "fair game" policy, Scientology v. Wollersheim, US

District Court for the Central District of California, No. CV

85-7197 JMI (Bx), which was dismissed against me, and

Scientology v. Wollersheim, Los Angeles Superior Court No. BC

074815. I was awarded $135,000.00 in this frivolous lawsuit

pursuant to California's SLAPP Statute.

5. Since 1979, I have been the target of the notorious

"fair game" policy, originated by Scientology's founder and

leader L. Ron Hubbard. This policy calls for critics of

 

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[CT 8054]

Scientology, designated by the organization as "enemies" to be

tricked, cheated, sued and destroyed. This policy permits, in

fact urges, Scientologists to do virtually anything in the

service of Scientology to attack its targeted enemy.

6. In 1993 I, with others, formed a non-profit

corporation, FACTNet, Inc., a cult abuse victims advocacy

organization that serves as a library and historical

preservation archive which collects, preserves and makes

available information on groups and organizations which employ

sophisticated and dangerous techniques of mind control. For

more information on FACTNet, its goals and purposes, see one

of FACTNet's publication regarding its mission, history and

accomplishments appended hereto as Exhibit [A]. Because of my

experiences and knowledge of Scientology, because I have

continued to be its fair game target, and because it is widely

known as the largest and most psychologically dangerous of all

the organizations using advanced psychological coercion

practices, FACTNet has a large archive of information on

Scientology which it has collected, preserved and made

available to our library users.

7. In 1993 I asked Gerry Armstrong to be on the board

of directors of FACTNet. I did this because he is known to me

to be an abuse victims advocate, and honest and courageous,

having stood up against Scientology's fair game practices and

its formidable litigation machine for then over a decade, and

I trusted him. Armstrong was never involved in the management

 

 

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[CT 8055]

or operations of FACTNet in any significant way or for any

significant length of time. Later, because of the concern

that Scientology would mischaracterize Armstrong's

relationship with FACTNet, and use its mischaracterization in

legal attacks, he resigned his position on our board of

directors.

8. I also asked Armstrong to be involved with FACTNet

because he is a victim of Scientology's cult abuse and was,

and is, defending a case brought against him by Scientology to

silence him. I knew from having talked to Armstrong about his

pending case, and from reading many documents relating to that

case, and from my knowledge of Armstrong's prior history and

legal involvement with Scientology, that Scientology was

seeking to use the courts to silence him and deny him his

Constitutional rights, including his freedom of religion and

right and need to defend himself against fair game. I also

knew, from my own experience, study and communications with

dozens of people affected, that the "settlement agreement"

which Scientology was seeking to enforce was one of several

such "agreements," which, in my opinion, individually and

together constituted a massive obstruction of justice.

Armstrong, therefore, like any other Scientology victim, had a

need for FACTNet to help him defend himself against that

organization, and its litigation and fair game machines.

FACTNet has assisted Armstrong, because he is a victim of

Scientology's abuse. We have assisted him with fund raising,

 

 
 

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[CT 8056]

obtaining legal help, spiritual support, and in telling the

world the story of the abuse of Gerry Armstrong.

9. Appended hereto as Exhibit [B] is a true and correct

copy of one of FACTNet's research publications entitled

"Scientology's Policies Toward Its Adversaries." This

document details Scientology's history of unclean hands and

general bad faith in bringing actions such as this one.

Scientology has been involved in criminal acts against its

adversaries, and has used the court systems around the world

to support these criminal activities, for decades. If these

materials are fully read by the Judge and other decision-

makers in the current action, there will be no doubt about why

Scientology is trying to silence and crush Armstrong. Their

efforts to silence and crush him are to suppress critical

knowledge and counter-opinions about Scientology's nature and

activities, activities which threaten the public well-being

and safety.

10. The information that Armstrong brought with him out

of Scientology, that was made public for the first time

through his efforts, and became judicially credited during the

course of the first lawsuit Scientology brought against him,

has been essential to the understanding of Scientology's mind

control, fraud, and fair game activities. Armstrong

documented and exposed the real nature and history of L. Ron

Hubbard, his falsified credentials, vindictiveness and

aggressiveness toward anyone who opposed him, and his and his

 
 

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[CT 8057]

organization's victimization of countless people around the

world. Armstrong's material is used by government

investigations and by countless people around the world to

educate and counsel about Scientology and its actual

intentions, practices and dangers. Scientology wants to

silence and discredit Armstrong because his materials free

victims by giving them access to what they need to make

informed choices, and Scientology doesn't want its victims

free, but under its domination or shuddered into silence. It

is imperative, for free minds and a free society that

Scientology not be allowed to achieve its goal of suppression

of Armstrong's information.

11. I know that Scientology calls itself a religion,

claims that it is organized for only religious purposes,

claims that its activities are religious, and that all of its

writings on any subject with Scientology; whether they be

about financial matters, physical health or how to wash a car;

whether they order using the courts to harass people, to

utterly ruin critics, and even the "fair game" policy itself,

are "religious scriptures."

12. It has come to my attention that Scientology is

seeking to have the court in the Armstrong case order the

removal or seizure of all materials in FACTNet's possession

which relate in any way to Scientology. The order Scientology

seeks reads: "within 20 days of the issuance of this Order,

Armstrong shall: 1. Remove all information concerning

 
 

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[CT 8058]

Scientology, the Church and/or any person or entity referred

to in paragraph 1 of the "Mutual Release of All Claims and

Settlement Agreement" of December, 1986 from any and all

databases, electronic or otherwise, within the possession,

custody or control of FACTNet." This proposed order that

Scientology is trying to push through court against Armstrong

is an effort to deceive the judge on the case so that

Scientology can later use this overbroad order to harass, raid

and destroy a public library and historical preservation

archive. FACTNet's library and archive possess thousands upon

thousands of documents relating to Scientology and/or

Armstrong that have been or are legally in the public domain

and/or received from many other sources than Gerald Armstrong.

FACTNet possesses many of Scientology's own writings that have

been or are legally in the public domain. A court-ordered

removal or seizure of these materials, which Scientology

itself always claims are "religious scriptures" would be

tantamount to seizing Holy Bibles or commentaries on the

Bible, in the possession of out-of-favor former members of a

Christian church.

13. My 26 years of experience and my study of hundreds

of thousands of pages of evidence have brought me to the

unshakable conclusion that Scientology is the world's largest

secret neo-satanic "religion," with thousands of fanatical

members in hundreds of highly organized, centrally controlled

"churches" worldwide, using sophisticated mind control and

 
 

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[CT 8059]

intelligence operations arid-employing hundreds of non-

Scientology lawyers and "private investigators" to carry out

its goal of smashing all opposition to its mad and dangerous

plan for world domination. See "Scientology's Policies Toward

Its Adversaries," Exhibit [B] hereto.

I declare under the penalty of perjury under the laws of

Colorado and California that the foregoing is true and

correct.

Executed at 601 16th St, Jefferson

County, Colorado, this 7th day of April, 1995.

[signed]
Lawrence Wollersheim

 

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This document in .pdf format.

 

    

These links are revised versions of the referenced exhibits:

Exhibit [A]
FACTNet's Mission
http://www.factnet.org/mission.htm?FACTNet

Exhibit [B]
Scientology's Policies Toward Its Adversaries
http://www.factnet.org/Scientology/adversa.htm?FACTNet

   

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