Declaration of Gerald Armstrong

Armstrong 1

I, GERALD ARMSTRONG, hereby declare as follows:

1. I have reviewed the document copies produced by plaintiff and cross-defendant Church of Scientology of California, hereinafter referred to as the “organization,” pursuant to this Court’s orders of July 2, 1985, September 9, 1985 and December 9, 1985. The documents were not designated as to which discovery requests they were being produced under. They were received in a stack of 139 pages which I have numbered in the same order as received. They consist of 57 pages of documents from my Guardian’s Office Intelligence or B-1 files and 82 pages of “success” stories taken from my preclear (or auditing or processing) files.

2. I have personal knowledge that the organization has in its possession or control the following documents which it has not produced in the instant case but did produce for my viewing, but not for release to me, in March 1985, in the case of Christofferson v. Church of Scientology, Mission of Davis, et al, Case No. A 7704-05184, in the Circuit Court of the State of Oregon, for the County of Multnomah:

1. 14 page “time track”

2. O/W write up 4/4/72

3. $3.00 fine from Boats I/C 10/20/72

4. $250.00 promissory note 11/2/72


5. 4 page personnel survey 1/5/73

6. Orders of the Day (OOD’s) - re Non-Existence assignment 8/21/73

7. Flag Conditions Order (FCO) 2513 Committee of Evidence re visas 8/21/73

8. OOD’s re missed muster 8/25/73

9. Knowledge report from Deck Engineer 9/16/73

10. Doubt formula 10/10/73

11. Findings - Court of Ethics - FCO 2639-1 11/14/73

12. Treason Formula 11/20/73

13. Liability Formula 6/12/74

14. Flag Personnel Order (FPO) 515 Temporary Port Captain 7/7/74

15. Enemy Formula 7/13/74

16. Liability Formula 7/15/74

17. FCO 2507 Delayed Mission 8/14/73

18. FCO 2782 LRH Cramming Order 1/4/74

19. FCO 2848 Shore Ethics 1/30/74

20. FCO 2892 LRH Order 2/12/74

21. FPO 950 Warrant Officer 2/23/74

22. FPO 969 Port Captain In-Training 2/25/74

23. FPO 2926 Port Ethics 3/4/74

24. OOD’s absent study - 3/24/74

25. FCO 2972 PR Study 3/31/74

26. FCO 2972 cancelled 4/1/74

27. FCO 3024 Port Captain’s Office 5/18/74

28. Confusion Formula 7/13/74

29. Treason Formula 7/13/74


30. Liability Formula 7/15/74

31. No report report 9/26/74

32. FCO 3562 Exec Study 2/3/75

33. Liability assignment (vital info) 3/26/75

34. FCO 3793 Org Program No. 1 4/21/75

35. FCO 3813 Stale Justice 5/2/75

36. FCO 3939 Clearing stations 6/7/75

37. Note from Mary Sue Hubbard re parents 7/11/75

38. Note Ron Anderson to Mary Sue Hubbard 7/13/75

39. 11 pages of data for CSW to join Guardian’s Office (GO) 9/12/75

40. Dispatch to GO BRII Dir. re Mother 9/16/75

41. Non-disclosure bond 9/22/75

42. Letter to Fosdick from Andrew Armstrong 10/6/75

43. Letter to Fosdick from P.J. Armstrong 10/75

44. 12 page Compliance report re Mother 11/19/75

45. Bond re UCE 12-75

46. FCO 4517 RPF Assignment 7/1/76

47. 12 page Basic auditing checksheet 7/28/76

48. 15 page metering course checksheet 7/30/76

49. Declaration re RPF 7/28/76

50. $750.00 promissory note 7/28/76

51. 3 page Rudiments Course checksheet 8/20/76

52. Executive Directive 81 Area Estates (ED AE) RPF Bosun 10/10/76

53. Ethics Order (EO) 24 AE Additional RPF duty 10/17/76

54. PRF Personnel Order - supply officer 8/28/76


55. Undated RPF Treason formula

56. 3 page First Dynamic Danger Formula 12/7/76

57. Dispatch re Curacao Consulate 2/2/77

58. 3 page Liability Formula 2/12/77

59. Dispatch re Moosejaw, Saskatchewan arrest 3/8/77

60. Dispatch re Chilliwock, B.C. arrest 3/8/77

61. Security

62. FCO 4901 Comm Ev. 8/22/77

63. FCO 4906 Findings and Recommendations 8/30/77

64. Note - Parents caused trouble

65. PTS check 9/2/77

66. Larry Price recommendation 11/30/77

67. Attestation stats in normal in PRF 11/30/77

68. David Mayo Commendation 11/30/77

69. Senior C/S report 11/30/77

70. 3 page Letter Tonja Burden to L. Ron Hubbard 12/77

71. 2 page report from Tonja Burden on her father 12/77

72. 5 page report from Terri Armstrong re Tonja Burden 12/15/77

73. Order from Assistant Guardian SU re G. Armstrong 12/20/77

74. Answer from Hubbard re petition from G. Armstrong 3/28/78

75. Report from Clarisse Barnett re G. Armstong 3/28/78

76. 5 page summary of Jamaica debrief 4/13/78

77. Treason Formula 9/27/78

78. Enemy Formula 9/27/78

79. Liability Formula 9/27/78


80. RPF Hat checksheet 9/29/78

81. RPF Basic Hat checksheet 10/1/78

82. Solo Auditor checksheets 10/1/78

83. Conditions Order 384 WHQ RPF 12/19/78

84. Doubt Formula 12/22/78

85. Conditions Order 288-3 re Posting 4/3/79

86. R Renovations statistics 12/8/79

87. Request chit withdrawal 12/9/79

88. Refusal to withdraw chit 12/9/79

89. Petition to Hubbard 1/8/80

90. CSW from Laurel Sullivan re G. Armstrong 1/18/80

91. Non-existence (NE) formula 2/3/80

92. NE Formula to Mary Sue Hubbard 2/5/80

93. Hubbard’s answer to NE 2/8/80

94. 7 pages of OCA, Leadership, IQ, aptitude test results 2/9/80

95. Mary Sue Hubbard answer to NE 2/11/80

96. 5 page GO interview re Tonja Burden 3/25/80

97. 2 pages re biography project 5/80

98. Dispatch to Leo Johnson re Martin Leslie 9/2/80

99. 2 page report re off-policy actions in the RPF 10/16/80

100. 6 page CSC “covenant” 1/20/81

101. GO interview re UCE 6/2/81

102. 11 page report to Sue re biographical sketches 6/18/81

103. 2 page letter from Jocelyn Armstrong to Holli Carlson re parents 7/6/81


104. 5 page report from Jocelyn re parents 7/6/81

105. Report from Gary Reisdorf re G. Armstrong 8/14/81

106. Report from HCO Chief Product Development Org International (PDOI) re G. Armstrong 8/17/81

107. 16 page critique of Research & Discovery biography 9/1/81

108. 4 page report to Sue Anderson re pack 10/18/81

109. 4 page biography debug project 10/30/81

110. 2 page report re Nibs 11/9/81

111. Dispatch from Lois to Donna re biography 11/9/81

112. 4 page report to Donna re biography 11/10/81

113. 17 page report Donna to Lois including G. Armstrong’s report 11/14/81

114. Report from Don Johnson re G. Armstrong 12/13/81

115. Report Don Jonson to Terri Gamboa re G. Armstrong 12/14/81

116. Report from Vaughan Young re G. & J. Armstrong 12/15/81

117. 6 page report from V. Young re G. & J. Armstrong 12/15/81

118. Report from Marcus Swanson re G. & J. Armstrong 12/21/81

119. Dispatch to Don Johnson re G. Armsrtrong 12/30/81

120. Dispatch Don Johnson to Barbara DeCelle 1/2/82

121. Report Don Johnson to Ciruss Slevin 1/2/82

122. Report Barbara DeCelle to Don Johnson 1/2/82

123. Report V. Young to B. DeCelle

124. Report from Jeannine Boyd re G. Armstrong 1/12/82


125. 4 page report from V. Young on meeting with G. Armstrong 1/17/82

126. Same 4 page report to the case supervisor (C/S) 1/17/82

127. Report from Brad Ballentine re Brown family 1/20/82

128. 4 page report to Roberto of interviews re D. Brown 1/20/82

129. 3 page letter from D. Brown to H. Carlson 1/20/82

130. 2 page report from Peeter Alvet of interview of Marilyn Brewer 1/21/82

131. 2 page report from Brad Ballentine of interview of Laurel Sillivan 2/12/82

132. Report from V. Young on what G. Armstrong knows 2/12/82

133. Report from DGIUS (Donna) to DG US re G. Armstrong 2/12/82

134. “Summary” re G. Armstrong

135. Part of “analysis” (of 1982)

136. “Gerry Armstrong Project” 2/17/82

137. Report from H. Carlson to Senior C/S 2/20/82

138. Dispatch from Snr. C/S to H. Carlson 2/21/82

139. Report from B. Ballentine to Roberto re G. Armstrong’s files 2/22/82

140. Telex to SU from AGI GLA 2/23/82

141. B. Ballentine daily report (DR) re G. Armstrong 2/24/82

142. 4 page report from Branch I Director Flag GO Intelligence re H. Carlson and G. Armstrong 2/25/82


143. 9 page delcaration of Terri Gamboa re Tonja Burden 2/25/82

144. AGI GLA DR re G. Armstrong 2/26/82

145. B. Ballentine interview of B. DeCelle 3/1/82

146. DR re G. Armstrong

147. DR re G. Armstrong (folders) 3/4/82

148. DR re G. Armstrong 3/5/82

149. DR re G. Armstrong 3/8/82

150. Physical description of G. Armstrong

151. DR re G. Armstrong 3/10/82

152. DR re G. Armstrong surveillance

153. DR re G. Armstrong stakeout 3/11/82

154. DR re G. Armstrong stakeout 3/12/82

155. DR re G. Armstrong stakeout 3/15/82

156. DR Guardian Activities Scientologist (GAS) called B. Ballentine 3/16/82

157. DR re G. Armstrong 3/17/82

158. DR re G. Armstrong and Alan Walter 3/18/82

159. DR re G. Armstrong to Dick Sullivan 4/1/82

160. Letter from Dick Sullivan to G. Armstrong 4/12/82

161. 4 pages re Burden deposition in Paulette Cooper case 4/82

162. HCO Policy Letter “Field Auditor Fees” 4/29/82

163. 4 page declaration by T. Gamboa 5/21/82

164. 3 page report re meeting with Kohlweck 5/26/82

165. 2 page “confidential” report re Nibs 6/1/82

166. Note G. Armstrong C/O John Compton

167. Report from AGI GLA re “Flynn Forum” 5/31/82


168. Report from DGI US re G. Armstrong being served 6/2/82

169. Description of G. Armstrong and address

170. 2 page report from B. Ballentine re “disaffecteds” 6/12/82

171. 3 page comparison of G. Armstrong Burden affidavits

172. 3 page analysis of G. Armstrong Burden affidavit of 6/25/82

173. 12 pages copy of article from “Look” Dec. 1950

174. 2 pages re G. Armstrong’s accusations against “Church”

175. Subpoena for Omar Garrison 8/31/82

176. 13 page affidavit from Ford Schwartz

177. 3 page J. Armstrong time track 8/16/82

178. 8 pages notes from G. Armstrong deposition

179. 4 page GO report re Walt Logan, etc. 8/29/82

180. Page 2 of report from Kathy, DG PR US

181. “Clearwater Sun” article re Nibs Hubbard 11/14/82

182. CIC X-file list re M. Parsons

183. 11 page report from Theresa Parsons 12/27/82

184. 2 page report from V. Young re “Time” and G. Armstrong 1/14/83

185. 12 pages G. Armstrong deposition excerpts

186. 3 pages “New York Times” article 1/6/83

187. “Time” article 1/31/83

188. 5 page “debrief” of T. Gamboa re G. Armstrong 3/12/84

189. 10 page G. Armstrong declaration for FBI 9/6/84


190. “St Petersburg Times” article 4/20/84

3. What the organization produced as my B-1 file in the Christofferson case was in fact only a portion of the actual file. On April 4, 1985, I testified about what items I could determine with certainty were missing from what was produced. My testimony and statements of counsel on that date are attached
hereto as Exhibit A. At page 4069, defense attorney, Harry Manion, described the compilation of the B-1 time track:

“MR. MANION: All the documents referenced in the time track: They are collected throughout the organization in Ethics files, in Knowledge Reports, in Flag Orders. The man was in the organization, according to his own testimony, for eleven years. Hundreds and hundreds of documents and other sources, talking to people, were used to compile the time track.

At page 4070, the Court ordered the production of all documents omitted from my B-1 files, including all documents up to date; i.e., April 4, 1985, and attorneys for defendant organization (the same organization as plaintiff and cross-defendant in the instant case) agreed to produce all such documents.

These documents, however, were never produced. They include up to April 1985 at least the following:

1. The documents from which the entries on the 14 page “time track” were excerpted or on which the entries were based.


2. The documents from my “ethics” and “personnel” files.

3. The records and documents concerning my incarceration in the US GO Intelligence Bureau in Fifield
Manor in June 1976.

4. The interview of me done by GO Intelligence official, Brian Roubinek, in July/August 1976 in Clearwater, Florida.

5. The Compliance reports or progress reports to each of the targets of the “Gerry Armstrong Project” of February 17, 1982, attached hereto as Exhibit B.

6. The statements, notes, names, dates, incidents, connections, data or other information culled from my pc (or preclear, or auditing, or processing) files.

7. The documents, materials or information on which the report of September 30, 1982 re Dead Agenting Gerry Armstrong is based.

8. The orders or correspondence to the private investigators who surveilled my wife, Jocelyn, and me
beginning in May 1982, and who assaulted me, ran into me, attempted to involve Jocelyn and me in freeway accidents, and who followed and harassed us through September 1982. Also the daily PI reports from each day of this period.

9. The orders, reports, materials, briefings, and documents concerning a visit and subsequent telephone
calls to me by Mark Rathbun in February through April 1984. Rathbun stated to me that the organization had done an “eval” regarding me, so this would include the eval, all accompanying “data,” documents and the


resultant “program.” An “eval,” or evaluation, is a mimeographed issue type, only approved with supporting documentation.

10. The mission, project or program orders pursuant to which Terri Gamboa met with me on March 8, 1984, and subsequently wrote her “debrief” of March 12, 1984 attached hereto as Exhibit C. There could not be
“debrief” without there being a “briefing” on orders.

11. The orders, reports, correspondence and documents concerning surveillance and harassment by organization agents in London in June 1984. A copy of a declaration I wrote on July 1, 1984 concerning the surveillance and harassment is attached hereto as Exhibit D.

12. The orders, reports, correspondence and documents relating to the operation in June 1984 to use my pc folders to lure me into a trap. This operation was acknowledged by the two organization agents, Mike Rinder and “Joey” in the videotapes illegally taken of me in November 1984.

13. The orders, reports, correspondence, and documents relating to OSA INT Executive Directive 19, of
September 20, 1984, a copy of which is attached hereto as Exhibit E. OSA or Office of Special Affairs is the new name given to the Guardian’s Office. Its functions are the same.

14. The orders, reports and documents concerning the photographing of me by organization members on
November 8, 1984 in Los Angeles, including the


photographs taken.

15. The orders, reports, correspondence, materials and documents concerning the burglarizing of the trunk of my car on November 8, 1984, and the theft therefrom of a manuscript and artwork of approximately 350 pages, and various documents relating to this litigation. This includes the stolen materials themselves.

16. The copies made by organization agents known to me as “Joey” and “Rena” of my writings and drawings which she requested as a potential publisher, and which I loaned to her on November 9, 1984. These consisted of approximately 250 pages of personal creative works which were copied without my knowledge, and the copies of which were kept by the organization.

17. The records, reports, orders, correspondence, documents and audio and video recordings of a meeting, arranged by organization agents posing as “reformers,” between an attorney Thomas Janeway and me in November 1984 in Encino, California. Janeway pretended to be working for these “reformers” and attempted to entrap and compromise me.

18. The records, reports, correspondence, orders, documents or materials relating to the obtaining of false authorizations “directing” the videotaping and wiretapping of my attorney, Michael Flynn and me, in November and December 1984. Three of these phony authorizations are attached hereto as Exhibit F.

19. The records, reports, correspondence, orders, audio


and video recording, documents or materials relating to an attempt by organization agents to get me to fly to Las Vegas, Nevada in the fall of 1984 to meet with a proposed “backer” of their intended litigation to “reform” the organization.

20. The correspondence, reports, statements, documents or materials supplied to or received from the Los Angeles Police Department, or any officer thereof, in 1982 through 1984 in various attempts to have criminal charges brought against me in connection with the Hubbard archives (or “Armstrong documents.”) It is known that the organization corresponded at least with one officer, S.J. Capuano in the N.E. Detective Division in this effort to have me arrested.

21. The orders, reports, projects, programs, briefings and debriefings, audio and video recordings, and all related documents and materials concerning what the organization calls the “Armstrong operation.” This operation, which in fact began right after I left the organization, involved the use of a friend, Dan Sherman, to get close to me, feed me false information, compromise me and frame me, with the goals of destroying my reputation, my ability to testify in Scientology litigation, my emotional and physical well-being, my economic base, my marriage and my life. On page 2 of the February 17, 1982 “Gerry Armstrong Project,” Exhibit B, is the statement:

“Step 15) Persue (sic) the potential existing line


that might be available to us via a trusted GAS who is a writer and who is respected by Gerry. This would require some reach from Gerry, though, as he might be suspicious if this GAS made a big reach for him.”Dan Sherman is the “trusted GAS.” GAS stands for Guardian Activites Scientologist, a covert operative of the GO not formally posted on staff. The “Armstrong Operation” became known to me in April 1985, when the organization attorneys announced that meetings I had had with two individuals, “Joey,” and Mike Rinder, as arranged by Sherman, had been secretly videotaped. Sherman, Joey and Rinder represented themselves as part of a group seeking to reform the organization and have it cease its tortious and criminal activities, such as the actions taken against me. Attorneys John G. Peterson and Earle C. Cooley stated in Christofferson that there were no written documents of any kind regarding this operation. Their statements to the Court in that regard on April 11, 1985 are attached hereto as Exhibit G. Their statements must, however, be regarded, given the magnitude of the operation, the expense, the number of people involved, and the modus operandi and policies of the organization regarding working only off of written programs and orders and complying in writing to all orders, as perjurious. There are thousands if not tens of thousands of pages of documents not produced: daily reports, weekly reports, battle plans, statistic reports, PI reports, CSW’s, projects, programs, evals, targets,


compliance reports, orders, nudges, debugs, requests for funds, budgets (FP’s), accounting reports, cross file sheets, exception sheets, computer data and files, briefings, debriefings, drillings, video recordings, audio recordings, wiretap recordings, etc. These orders, reports, documents and recordings involved at least:

Gerald Armstrong

Jocelyn Armstrong

Michael Flynn

Dan Sherman

Mike Rinder



John Peterson

Clayton Ruby

Eugene M. Ingram

Philip Rodriquez

Terri Gamboa

Thomas Janeway

Peterson’s statement on April 11, 1985, at page 4692 of Exhibit that the videotaping of me “was done by the Toronto attorney (Clayton Ruby) and a private investigator (Eugene M. Ingram), not me, not the Church,” is also perjurious. Dan Sherman was an organization GAS member, and Rinder and Joey, the two individuals who were bodywired, who set me up, and who appeared in the video, were organization members. Peterson’s duplicity is also


shown in his declaration dated April 17, 1985, filed in this case and several other cases around the country and attached hereto as Exhibit H. Although on April 11, before the Oregon Court Peterson professed no knowledge of the “Armstrong Operation” and no “Church” involvement, in his declaration he claimed to have “personal knowledge” and stated that (at Par. 5) “Joey and the Loyalists ( the group claiming to be reformers) were created only after the Church learned of Armstrong and Flynn’s desire to get an inside source within the Church.” (Emphasis added)

22. The orders, reports, compliances, briefings, documents, audio and video recordings, photographs and
the materials relating to the forgery and attempted cashing of a $2,000,000 check on the Bank of New England account of L. Ron Hubbard in 1982, and the operation to frame Michael Flynn and me with the crime. Sherman and the “Loyalists” stated to me, in order to draw me into the “Armstrong Operation,” that it was their intention to, and they stated they could, prove that Flynn was innocent and the organization was knowingly framing him. They went so far, in order to demonstrate to me their intent to help prove Flynn’s innocence, as to provide me with a document, a handwritten copy of which is attached hereto as Exhibit I, to be passed to the authorities investigating the check scam. In his “Declaration in Opposition to Motion for Attorneys’ Fees” dated July 30, 1984 and filed in this case, John Peterson claimed that


Michael Flynn was guilty of the forgery and the attempt to cash the forged check, and he attached an affidavit by one Ala Fadili Al Tamimi in support of his claim. Later evidence revealed that the organization paid Tamimi $25,000 for the affidavit. And further evidence has revealed that the organization knew in early 1984 that Flynn had nothing to do with the check scam that the Tamimi affidavit was false, yet it continued, through its attorneys, the operation to frame him. The PI behind the frame-up is Eugene M. Ingram, the same person who illegally videotaped me. In his “testimony” before the Los Angeles Police Department Board of Rights, regarding Philip Rodriquez’ unlawful and false authorization of the videotaping and wiretapping of Michael Flynn and myself, Earle C. Cooley also accused me of involvement in the Hubbard check forgery. Cooley’s testimony is attached hereto as Exhibit J. At pp. 177, 178, Cooley states:

“I think the proof of this pudding is in the eating, on the tapes and on the transcripts. The crimes were as represented. If you look at the letter of authorization signed by officer Rodriguez, it seems to me that every one of those crimes was uncovered, and that its investigation, if you will allow me, ought to be focused on the criminals, who are the ones who have brought about this hearing through a complaint on the part of Michael Flynn who himself is being investigated by a grand jury, the federal grand jury in the city of Boston right now, as well as Mr. Armstrong and others


that were involved in the two million dollar check forgery which is talked about on those tapes and is part of the coverup that is attempted by phony documents being planted in the files of the Church.”(Emphasis added)

There are thousands, if not tens or hundreds of thousands, of documents relating to the Hubbard check
forgery, the purchased perjured testimony and the attempts to frame my attorney Michael Flynn and me with the “crime.” These include at least: daily reports, weekly reports, battle plans, battle plan reports, statistic reports, PI reports on a daily basis from at least 1982 to the present, CSW’s, mission orders, projects, programs, evals, targets, estimates, compliance reports, progress reports, orders, nudges, debugs, requests for funds, budgets (FP’s), accounting reports, cross file sheets, excerption sheets, computer data and files, briefings, drillings, debriefings, audio and video
recordings, wiretape recording, etc. These orders, reports, correspondence, documents and recordings involve at least:

Gerald Armstrong

Jocelyn Armstrong

Michael Flynn


Mike Rinder

Eugene M. Ingram

John Peterson


Earle C. Cooley

Ala Fadili Al Tamimi

Wayne Hollingsworth

Stacy Young

Heber Jentzsch

Gary Pappas

Daniel Lenzo

Donald Randolph

L. Ron Hubbard

Akil Abdul Amiar Al Fadili Al Tamimi

Andrew Lenarcic

Jeff Chevelle

Mark Rathbun

Larry Reservitz

George Kattar

All the documents could be cross-filed under various headings or names or code names.

23. The correspondence, orders, reports, statements, documents photographs, or materials relating to the “Freedom” tabloid issue 61, published in August 1984, a reduced copy of which is attached as Exhibit K.

24. The correspondence, orders, reports, statements, documents photographs or materials relating to the
article entitled “Ex-U.S. Attorney’s Role in Check Forgery Surfacas in Boston Court” in the “Freedom”
tabloid issue 62, published in October 1984, a reduced copy of which is attached hereto as Exhibit L.


4. Following my testifying in Christofferson, the organization continued its attack on me with numerous other operations to discredit, harass and intimidate me, and destroy my life. There are thousands of pages of documents as yet not produced, concerning the incidents and acts as follows:

1. The correspondence, orders, reports, statements, photographs, documents or materials relating to the
“Freedom” tabloid published in April/May 1985, a reduced copy of which is attached hereto as Exhibit M.

2. The correspondence, orders, reports, statements, photographs, documents or materials relating to the
“Freedom” tabloid published in May 1985, a reduced copy of which is attached hereto as Exhibit N.

3. The correspondence, orders, reports, statements, documents or materials relating to the “advertisement” attached hereto as Exhibit O which appeared in “The Oregonian” newspaper of May 30, 1985, in Portland, Oregon, particularly with regard to the statement:

“Another one of Christofferson’s key witnesses, Gerry Armstrong, a government informant, was indisputably shown to have engaged in an operation to infiltrate the Church of Scientology. Armstrong’s plot, based on evidence submitted in court, appears to have been conceived with the advice and consent of Flynn and members of the IRS Intelligence Branch. It indicated the planting of forged documents in the church which could then be “discovered” by government agents in planned raids on church premises. The forged documents


would incriminate the church in nonexistent illegal activities and would serve as a basis for the indictment of current church management.”

4. The correspondence, orders, reports, statements, documents or materials relating to the organization’s radio show “Freedom Magazine” on station WTTP in Boston on June 11, 1985, a transcript of which is attached hereto as Exhibit P.

5. The correspondence, orders, reports, statements, documents, payments, receipts or materials delivered to or received from L. Fletcher Prouty relating to G. Armstrong. Prouty has signed a number of false declarations concerning me in relation to the videotapes since April 1985.

6. All edited versions of the videotapes which had originally been made of me in November 1984. Attached hereto as Exhibit Q is a flyer distributed to Scientologists in April and May 1985 directing them to a showing of an edited version of the tapes. Also, Earle Cooley, during his testimony before the LAPD Board of Rights showed an edited version of the videotapes. (See Exhibit J, pp. 156-174.) Also, edited versions were shown to various members of the media, including at least the CBC, CBS, the “Sacramento Bee.” An edited version was also used by organization personnel as a promotional device, showing members the version, misinterpreting its content and significance and requesting from these members $2,000.00 each. The projected target was 25,000


people “regged” for $2,000.00, or a total of $50,000,000.00 on the basis of these illegal videotapes of me.

7. The correspondence, orders, reports, statements, documents or materials, relating to the editing of the videotapes, including the editing which occurred prior to the Christofferson trial, plus the audio section edited out of the videotapes.

8. The correspondence, orders, reports, statements, documents or materials relating to the delivering of edited versions of the videotapes to any members of the media.

9. The correspondence, orders, reports, statements documents or materials relating to me sent to any media including newspapers, television and radio.

10. The correspondence, orders, reports, statements, documents or materials, relating to the showing of the videotapes or edited versions thereof to staff or public Scientologists, including any briefings given, requests for “donations” or funds, any projects, programs or evals related to this operation and any financial records of said operation.

11. The correspondence, statements, documents or materials supplied to or received from the Los Angeles
District Attorney’s office in 1985 or 1986 in an attempt to have criminal charges brought against me in connection with the videotaping of me by the organization. At page 167 of Earle Cooley’s testimony at the Board of Rights on


October 4, 1985, (Exhibit J), he states: “charges have been filed with the District Attorney of this County” and at page 168 that “there were two submissions to him (the DA), an initial submisssion and he called for additional materials, and additional materials went to him last week.”

12. The correspondence, orders, reports, statements, documents or materials relating to the photographing of my residence in Boston, Massachusetts on October 7, 1985, including all photographs created.

13. The correspondence, orders, reports, statements, documents or materials relating to the mugging and
robbery of me outside my residence in Boston on October 25, 1985.

14. The correspondence, reports, statements, documents or materials supplied to or received from the Federal Bureau of Investigation in 1985 or 1986 in an attempt by the organization to have criminal charges brought against me in connection with an incident allegedly occurring on October 13, 1985, in Boston, Massachusetts. Attached hereto as Exhibit R is a declaration I wrote immediately following being interviewed by an FBI agent regarding this attempt to frame me.

15. The correspondence, reports, statements, documents or materials concerning the operation to bring false criminal charges against me via the FBI as described in 13 above.

16. The correspondence, orders, reports, statements,


documents or materials relating to the “Freedom” tabloid published in February 1986, a reduced copy of which is attached hereto as Exhibit S.

17. The correspondence, orders, reports, statements, documents or materials relating to the operation to have several hundred copies of the “Freedom” tabloid (Exhibit S) planted in the building where I work on February 11, 1986 during my deposition in the case of Burden v. Church of Scientology.

18. The correspondence, orders, mission orders, reports, telexes, statements, documents or materials relating to an operation or mission in February and March 1986 involving organziation agent, Meryl Dubay, the purpose of which was to “Black PR” me among plaintiffs and witnesses in various cases against the organization.

19. The correspondence, orders, reports, statements, documents or materials, relating to the photographing of my residence on March 21, 1986.

20. The correspondence, orders, reports, statements, documents or materials regarding me delivered to the Internal Revenue Service in 1985 or 1986.

I declare under the penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Executed this 9th day of April, 1986 at Boston, Massachusetts.