Declaration of Gerald Armstrong

Armstrong 1

I, Gerald Armstrong, declare:

1. I am making this declaration in response to the allegations made in the reply of cross-defendant  Scientology organization in support of its motion to initiate an investigation of alleged violations of temporary restraining order re contempt.

2. Although I have never met LaVenda Dukoff and have only spoken to her on the one occasion she is refering to at paragraph 19 of her affidavit of June 9, 1986, I have known about her and her involvement and litigation with the organization for several years. I had written a couple of affidavits for her on issues about which I had factual knowledge which arose in her litigation. Ms. Dukoff’s case had settled before I started working for Michael Flynn in September 1985, so her name rarely came up in office conversations. The main impression I formed about her up to the time of her call was that she was a victim of Scientology and unstable. I became aware last fall, when the organization filed the original motion to initiate an   investigation, of its claim, which it based on one of the many affidavits Paulette Cooper signed for it on March 4, 1985, that in the fall of 1982 Ms. Dukoff had telephoned Ms. Cooper and said “Mike (Flynn) showed me the Armstrong documents that were under seal.” I was aware of the organization’s use of its victims and purchased false testimony in its operations (see declarations of Paulette Cooper, Joseph Flanagan, and Michael Flynn of September 30, 1985 re Ala Fadili Al Tamimi and other paid criminals) and I speculated


when I saw the organization’s motion to initiate an investigation that Ms. Dukoff might herself be involved in a Scientology operation. I was, therefore, very alert and very careful when she announced herself on the telephone around the beginning of June.

3. Ms. Dukoff’s call came in on an afternoon when the office was normally closed, because there were only two people there, myself and attorney Robert Joyce. Michael Flynn had left for home only moments before, and following my conversation with Ms. Dukoff I reached him on his car phone and related the details. The phone rang, I answered, and a woman asked for Mr. Flynn. I said he was not in and asked if I could take a  message. She gaveher name and I gave mine. She immediately announced that she had sealed documents from my case and she was going to take them to the press to get Mike Flynn. As soon as she made the  threat, I put her on hold, asked Mr. Joyce to come into my office to hear the call, then switched her onto the speaker phone when I took her off hold. Mr. Joyce was therefore present and heard all of what Ms. Dukoff and I said, except for the first sentence noted above, a threat she repeated a number of times throughout   our conversation.

4. Ms. Dukoff states that she “described some of these documents” to me, documents she earlier states at paragraph 18 Mr. Flynn said were under seal and for which he or she “could go to jail.” In our conversation, she referred to the documents she claimed to possess as “Armstrong documents” or “sealed documents.” She did describe, at my request, two or three of these documents, but very sketchily and, even after some questioning by me, she


could not describe any of her documents with enough specificity for me to identify them or any as “Armstrong documents”; i.e. any of those documents I obtained from Omar Garrison and sent to my attorneys in 1982, and subsequently delivered to the Clerk of the Los Angeles Superior Court pursuant to the Temporary Restraining Order issued August 24, 1982. The only document Ms. Dukoff was able to describe at all intelligently was a “will”, the original of which she said she copied, but she did not know its date or content. I even told Ms. Dukoff that there was no way from what she was telling me that I could know that she even had sealed documents.

5. Ms. Dukoff’s statement that I told her “that exposure of the dissemination of these documents would destroy (my) court case against the Church of Scientology” is incorrect. The only thing I said to her repeated threats to go to the press with “sealed documents” or cause Mr. Flynn or me trouble, was “you ‘ve got to do what you’ve got to do.” I never considered, nor do I consider, that Ms. Dukoff’s going to the press, or   Scientology, or anyone else with sealed documents, or forged documents, or any other kind of documents, would destroy my court case. I would not state such a thing, not only because I was aware from the outset that the whole Dukoff document affair was likely a Scientology operation, but because in truth I do not feel that way. It was Ms. Dukoff who said that her going to the press with sealed documents would hurt me.

6. Ms. Dukoff’s statement that I “obviously recognized these documents as (I) became very upset” is a false conclusion based on falsehoods. I did not recognize any of the Dukoff


documents and did not become upset. I remained calm, did not raise my voice, and said nothing which could be interpreted by any rational person as becoming “very upset.” I was, however, saddened by Ms. Dukoff’s call, by her attack on Mr. Flynn, who she said had “fucked” her and whom she was now “going to  fuck, ” and by the fact the call evidenced another Scientology operation. Following the call I was acutely depressed. Virtually all of Ms. Dukoff’s recitation of our conversation is false.

Executed this 2nd day of August, 1986 at Boston, Massachusetts.

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

[signed] G. Armstrong
Gerald Armstrong