I, GERALD ARMSTRONG, declare and state that:

1. I am the defendant and cross-complainant in the case of Church of Scientology of California vs. Gerald Armstrong, Los Angeles Superior Court No. C420153. I was a member of Scientology from 1969 to 1981 and have been involved in litigation with various Scientology entities, hereinafter referred to as "the organization", since 1982. I have testified approximately 47 days in trials or depositions in at least 10 cases against Scientology. I am very knowledgeable in Scientology litigation and operations, and am qualified to render the opinion in Paragraph 7 below.

2. In 1985 and throughout 1986, I worked as a paralegal in the law firm of Flynn, Joyce and Sheridan in Boston, Massachusetts. I worked on all the organization-related litigation handled by the firm during that period. Michael Flynn was the prime mover in much of the organization-related litigation throughout the United States until December 1986 when he settled all the cases in which he was involved. I was represented in Armstrong by Flynn, Joyce and Sheridan and the law firm of Contos and Bunch in Woodland Hills, California until the settlement.

3. In a declaration I executed December 25, 1990, which I filed in the California Court of Appeal in the organization's appeal (Civ. No. B038975) from a Superior Court ruling unsealing the Armstrong court file, which had been sealed in December, 1986, I detailed the circumstances of and my involvement in the settlement. In that declaration, I waived the attorney-client privilege between Mr. Flynn and me only as to our

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conversations concerning the settlement, and I reiterate that waiver at this time, and extend it to include my other attorneys.

4. During the settlement negotiations and thereafter, I learned from Mr. Flynn, and two other attorneys in both firms which represented me in Armstrong, that all the attorneys who had been involved in the organization-related litigation had agreed, as part of the settlement, to not represent or assist anyone in any future litigation against the organization.

5. Each of the law firms involved was also required, as part of the settlement, to turn over to the organization its Scientology-related documentary evidence, as was each of the litigants. Each of the litigants, moreover, was required, as part of the settlement, to not assist any aggrieved party in future litigation against the organization, and to avoid service of process in such litigation. These conditions are stated in the settlement agreement I signed in December 1986, a copy of which is marked and exhibited herewith as Exhibit "1".

6. Since the settlement, the organization's attorneys have threatened me on six occasions that I would be sued if I violated the settlement's restrictions. The organization meanwhile has itself violated the letter and spirit of the settlement regarding me on numerous occasions. I have detailed these instances in my December 25, 1990 declaration and a declaration I executed on March 15, 1990 which was also filed in the above-referenced appeal.

7. The effects of the December 1986 settlement agreements in the legal community and on future individuals aggrieved by the organization are obvious. Potential attorneys,

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knowing or learning that they would be denied the documentary evidence which had previously been available, denied assistance from the key witnesses against the organization, and denied assistance from the most knowledgeable attorneys in the world in this field of litigation would be more than reluctant to accept representation of aggrieved individuals. Add to that, the general knowledge in the legal community of the harassive and threatening practices of the organization toward adverse attorneys, and the fact that well respected attorneys such as Mr. Flynn had agreed to an unethical or illegal settlement to escape the litigation, and it is no surprise that this country's attorneys avoid representing the organization's many victims. The victims are effectively cut off from communication with witnesses and access to evidence, and their ability to obtain any legal representation denied.

I declare under the penalty of perjury under the laws of the United States and the State of California that the foregoing is true and correct and based on my personal knowledge, except those matters stated on information and belief, and as to those matters, I am informed and believe them to be true.

Executed this 16th day of July, 1991, at Los Angeles,

California.

[signed] G. Armstrong

GERALD ARMSTRONG

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