I, Gerald Armstrong, hereby swear under the pains and penalties of perjury as follows:

1. I have read the Declaration of Debbie Laubscher dated March 19, 1986 which was used by Defendant Scientology in the Summary Jury Trial proceeding in the case of Burden vs. Church of Scientology, et al., and I have examined the documents appended to Ms. Laubscher’s Declaration.

2. A number of the exhibits to the Laubscher Declaration are copies of documents which I collected in 1980 and 1981 and assembled in what became known as the “Hubbard Archives;” e.g., the naval records (see Laubscher Attachments 1 and 2), the Ledora May Hubbard manuscript entitled “Economics and the Individual,”and L. Ron Hubbard’s Boy Scout book (see Laubscher Attachment 7).

3. In 1980 and 1981, pursuant to a contract negotiated by Hubbard’s attorney, I delivered approximately 80,000 pages of copies of the documents from the “Hubbard Archives” to an author, Omar V. Garrison, for the writing of a biography of Hubbard. I also delivered Garrison a number of originals which he was to sort through and copy as needed. Towards the end of 1981 it became apparent to me from an examination of the “Hubbard Archives” documents that Hubbard had lied about virtually every part of his history and that I had been defrauded, and I left Hubbard’s

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employ and his organization. Thereafter, because of what I knew about the fraud, Hubbard and the organization mounted an attack on me in compliance with Hubbard’s policy called “Fair Game.” To defend myself I obtained from Garrison copies of a number of the documents I had earlier provided him, and a few originals, and I sent these to my lawyers.

These documents, which have become known as the “Armstrong documents,” in September 1982 were placed under seal in the Los Angeles Superior Court and remain there at this time.

The Scientology organization sued me to obtain possession of the “Armstrong documents,” and a Judgment, attached hereto as Exhibit A, was entered in my favor. Certain of the exhibits to the Laubscher Declaration are copies of documents included in the “Armstrong documents” still sealed in the LA Superior Court; e.g., “Agreement to Enroll in Correspondence Course” dated April 18, 1941, and letter from Baker, Beedy & Magee dated May 27, 1941. I could, if necessary, locate these and other exhibits to the Laubscher Declaration in
the “Armstrong documents” in Los Angeles.

4. It is clear from my examination of the exhibits to the Laubscher Declaration that the Scientology  organization is still using L. Ron Hubbard’s documents to support its claims, including copies of sealed “Armstrong documents.”

5. I am personally aware that in the case of Christofferson vs. Church of Scientology, Mission of Davis, et al., number A 7704-05184, in the Circuit Court of the State

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of Oregon, for the County of Multnomah, the Scientology  organization was ordered to produce and did produce copies of some of the same documents which had been “Armstrong  documents” and sealed in the Los Angeles Superior Court.

Signed under the pains and penalties of perjury this 12th day of April, 1986 in Boston, Massachusetts.

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