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          I, MICHAEL J. FLYNN, swear under the pains and

penalties of perjury that the following is true and correct.


          1) I am the attorney for Gerald Armstrong. In

April-June 1984, I appeared for Mr. Armstrong as trial counsel

in the case of Church of Scientology and Mary Sue Hubbard v.

Gerald Armstrong, Los Angeles Superior Court.


          2) During the Armstrong trial, extensive evidence

was introduced, both documentary and testimonial, relating to

the fraudulent and criminal conduct of L. Ron Hubbard in

connection with his relationship with the Church of

Scientology. This conduct began in the 1950's and continued

at least up until November 1982 as established by the evidence

in the trial.


          3) There was also extensive evidence in the

Armstrong trial relating to L. Ron Hubbard's background, which

for the most part, had been completely falsified by the Church

and by L. Ron Hubbard with respect to Hubbard's professional,

educational, health, miltary career and marital background

qualifications and credentials. Literally thousands of

documents in the form of hundreds of exhibits supported an

overwhelming testimonial record that Hubbard was in fact, a

-page break-


"pathological liar" as eventually ruled by the Trial Court,

and that he had in fact, manipulated and absconded with Church



          4) During the trial, specific issues arose relating

to the "MCCS Mission" which was a Scientology/Hubbard program

to conceal Hubbard's control of Scientology, shield him from

liability, shield him from the fact that millions of dollars

of Church funds had been funnelled to him, and to perpetuate

this fraud in the future without Hubbard incurring liability

for it. Although the Court actually sealed the "MCCS"tapes

containing such evidence, there was evidence relating to

Hubbard's control of Church funds in the trial itself and in

an affidavit of Gerald Armstrong that had previously been

filed in the case of Burden v. Church of Scientology. This

affidavit specifically relates to the MCCS Mission. The

affidavit is not under seal and has never been under seal.

This affidavit specifically quotes from the MCCS tapes which

are under seal. In one of the tapes as set forth in the

Armstrong affidavit, the highest legal official of the Church

of Scientology is quoted as saying that Hubbard's taking 2.1

million dollars of Church funds "was a classic case of

inurement, if not fraud." The tapes also reveal, as set forth

in the Armstrong affidavit, that throughout the history of the

Church, while it was holding itself out as an entirely

legitimate, separate and distinct religious corporate entity,



not under the control of L. Ron Hubbard, this in fact was a

fraud, the Church corporations were "shams" and Hubbard had

control of everything.


          5) As a result of the foregoing evidence and an

abundance of additional extremely detailed evidence, for the

most part supported by documents including cancelled checks,

Swiss bank account numbers, correspondence and miscellaneous

other documents, it became obvious that Hubbard had in fact,

engaged in criminal and fraudulent conduct with respect to his

control of the Church of Scientology. Much of this evidence

and the conclusions about Hubbard's conduct were reported

extensively in the media in the New York Times, the Los

Angeles Times, the St. Petersburg Times, the Clearwater Sun

and additional publications. It is my assumption that as a

result of this extensive media coverage, at some time after

the Armstrong trial, and after the Court had issued its

findings of fact, the Criminal Investigation Division of the

IRS began an investigation. After the Armstrong trial, I was

contacted by several investigators from the Criminal

Investigation Division of the Los Angeles office of the

Internal Revenue Service.


          6) I was first contacted by Mr. Al Lipkin, Mr.

Daniel Rocha, and Mr. Al Restuccia of the C.I.D. These

gentlemen informed me that they were conducting an



investigation in connection with the Church of Scientology and

L. Ron Hubbard and they sought my cooperation. I told them

that I would give them my full cooperation and provide copies

of any documents, affidavits, exhibits, etc. which were not

under seal and which related to the Church of Scientology and

L. Ron Hubbard. I also told them that my clients, which

included numerous former high level Scientologists, including

Gerald Armstrong, William Franks, Laurel Sullivan, Howard

Schomer, and others would give their full cooperation in

connection with the investigation of the C.I.D. Mr. Lipkin

and either Mr. Restuccia or Mr. Rocha came to my office and

spent several days examining documents relative to this

subject. They thereafter contacted many of my clients.


          7) At no time did Mr. Restuccia, Mr. Lipkin, Mr.

Rocha or any other member of the C.I.D., or for that matter

any other state or federal agency ever provide any information

to me as to the course of their investigation, the evidence

that they had collected, their conclusions, or anything else.

In fact, Mr. Restuccia, Mr. Rocha and Mr. Lipkin conducted

themselves with the utmost professional courtesy and

discretion, and never disclosed any information to me of any

nature or description during the course of their



          8) Subsequently, pursuant to its written policies,



including the "Fair Game Doctrine," "Attack the Attacker" and

its "Black Propaganda" policies, the Church of Scientology

engaged in a world-wide smear campaign, through press

conferences, news releases, and publication of its Freedom

magazine claiming that myself and several of my clients

including Gerald Armstrong were in a massive conspiracy with

the IRS, the FBI, the United States Government, the Canadian

Government, the United States Attorney's Office, and sundry

others to destroy freedom of religion in America. These

claims are absurd on their face. Among the more specific and

ridiculous allegations of Hubbard and Scientology are that

C.I.D. agents offered or promised various benefits to myself

and my clients in exchange for manufacturing evidence and in

effect framing L. Ron Hubbard and his Church. Suffice it to

say that these allegations are completely unfounded, totally

false and have no basis in fact or reality. Indeed, the

allegations themselves reflect the paranoid condition of both

Hubbard and the Church which was noted by the trial judge in

the Armstrong. The judge specifically ruled that the Church

and Hubbard were "paranoid and schizophrenic," were actually

utilizing the "Fair Game Doctrine" right up to the time of the

trial to "destroy" Hubbard's perceived enemies, and that it

had engaged in forms of blackmail and extortion.


          9) Upon information and belief, the present campaign

of the Church of Scientology alleging the conspiracy between



myself and various governmental agencies, is simply an effort

to divert the ever-increasing compendium of legal decisions

which have reached the same conclusions as the court in the

Armstrong case with regard to the background and activities of

Hubbard and his Church. In order to avoid civil and criminal

sanctions for their past conduct, Hubbard is now engaging in

his classic Black propaganda campaign to attack and discredit

those who are engaged in litigation against him. In fact,

there is no truth in the absurd claims of him and his agents.


          Signed under the pains and penalties of perjury this

24th day of September, 1985 under the laws of California,

Massachusetts, and Florida.


Signature of Michael J. Flynn Declaration of -09-24-1985








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