I, Gerald Armstrong, declare

1. I am making this declaration to respond to the application (App.) of the Church of Scientology International, hereinafter referred to, along with the rest of Scientology's command and control structure, as "the organization," for an order to show cause why I should not be held in contempt of court, and to the declaration of Laurie J. Bartilson (LJB Dec.) dated December 31, 1992 on which said application is based.

2. Judge Breckenridge stated in his decision filed June 22, 1984, in the case of Scientology v. Armstrong, Los Angeles Superior Court No. C 420153, hereinafter referred to as ArmstrongI, affirmed on appeal in Scientology v. Armstrong (1991) 232 Cal. App. 3d 1060, 283 Cal. Rptr. 917, that:

"[i]n addition to violating and abusing its own members civil rights, the organization over the years with its "Fair Game" doctrine has harassed and abused those persons not in the [organization] whom it perceives as enemies. The organization clearly is schizophrenic and paranoid..."

Ms. Bartilson is a member of the Scientology organization.

3. Ms. Bartilson states that on June 24, 1992 during a deposition in this litigation I asserted that I would never comply with the order of the honorable Ronald M. Sohigian dated May 28, 1992, hereinafter referred to as the "Sohigian ruling,"

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which denied in part and granted in part the organization's motion for a preliminary injunction brought to enforce the December 1986 "Mutual Release of All Claims and Settlement Agreement," hereinafter referred to as the "settlement agreement." (App. p. 3, l. 3; LJB Dec. p. 2, para. 4) When I state at page 124 of the June 24 deposition transcript that I have "absolutely no intention of honoring that settlement agreement," I mean exactly that. I do not mean the Sohigian ruling and Ms. Bartilson is something indiscernibly different from dishonest to so state in her sworn statements. The settlement agreement cannot be enforced, it is impossible for me to honor it, and Judge Sohigian refused to enforce it.

4. Ms. Bartilson states that on October 7, 1992, during a deposition in this case, I confirmed that I indicated to Los Angeles Times reporter Robert Welkos my intention not to comply with the Sohigian ruling. (App. p.4, n.4) Ms. Bartilson also states that my testimony from that deposition, which she quotes in her declaration, is an acknowledgement by me of my intention to wilfully disobey the terms of the Sohigian ruling. (LJB Dec. p.4, para. 5) There is not one word in my deposition testimony she has quoted, nor anywhere else, that would indicate to anyone with eyes to see, an intention by me to disobey the Sohigian ruling. My statement concerning the injunction, which Ms. Bartilson has quoted but woefully misinterpreted means only this: the organization moved the LA Superior Court for an order to enjoin me from doing anything not permitted by any or all of the

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conditions and prohibitions of the settlement agreement; the Sohigian ruling enjoins me from doing certain things, but specifically denies the organization's motion as to all the agreement's conditions and prohibitions except said certain things. The organization did not appeal that ruling; therefore I am free from the potential of an order which could have enjoined me from doing those things which are prohibited by the language of the settlement agreement but not prohibited by the much narrower Sohigian ruling.

5. Ms. Bartilson states that I have threatened in my letter of December 22, 1992 that if I am not paid $500,000 and this lawsuit dismissed I intend to travel to South Africa to testify against a church of Scientology. (App. p.4, 1. 12; LJB Dec. p. 8, para. 15, 16) My letter contains no such threat, nor any threat, other than the affirmation, which should not be perceived as threatening, that I will not be intimidated by the organization's threats into not living my life and not helping its victims. Ms. Bartilson should rejoice at that fact because there very easily may come a time when she will perceive herself, having been forced by her organization's leader to commit so much perjury and attack so many innocent people of good will in violation of all the ethical standards expected by our society of officers of the court, as a victim, and will herself look for understanding and help from people her organization has not been able to intimidate. Only the resolution of the Malcolm Nothling litigation will keep me from travelling to South Africa to

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testify at his trial. I have already been subpoenaed to testify at that trial and I have promised Mr. Nothling that I will appear to testify. The $500,000 is not for me but is my estimate of what my fees and costs are to date in the instant case. Pursuant to the settlement agreement, the prevailing party in any effort to enforce the agreement is entitled to the costs of suit and reasonable attorney's fees. I have already prevailed in this case, in that by the unappealed Sohigian ruling I have been freed from all the prohibitions of the settlement agreement, except the narrow restriction of my right to provide testimony to claimants or intended claimants against the organization unless pursuant to subpoena. The $500,000 is unrelated to the Nothling litigation, but is what I considered was required in order to peacefully and rationally end the Armstrong litigation without a trial and without a significant human catastrophe. The organization has, however, rejected my offer to settle this and any other cases, so my offer and the whole December 22 letter did not directly or indirectly assist anyone, thus cannot logically be considered a violation of the Sohigian ruling. I am not displeased to not have this case or the Nothling case dismissed because they will run the course most useful to God, and that may well include the catharsis of public trials.

6. Ms. Bartilson states that I intend to voluntarily assist anyone and everyone opposing Churches I can locate. (App. p. 4, 1. 16; LJB Dec. p. 8, para. 16) This is silly. I don't oppose churches, and I don't know anyone who opposes churches.

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In fact, in 1986 I founded a church, which, having expanded its membership more than thirty times in less than seven years, is one of the world's fastest growing, a fact which probably explains why the organization opposes it so religiously, since it claims and desires to be the world's fastest growing church. L. Ron Hubbard, whom I knew, opposed churches and opposed religion itself, and his organization, reflecting his schizophrenia and paranoia, opposes churches and religion, but Mr. Hubbard has disappeared and I am not attempting to locate him. In fact I am not even attempting to locate anyone opposing Ms. Bartilson's non-church organization. Anyone I am to communicate with will be led to me. It very well may be that at this period of my life some of these people will be those who oppose the non-church nature of the Scientology organization, but that is not surprising because people of good will everywhere oppose such a nature, and there are such people of good will everywhere.

7. Ms. Bartilson states that I express in my December 22 letter the viewpoint that the Sohigian ruling places no restrictions whatsoever on my conduct. (App. p.5, l. 1; LJB Dec. p. 8, para. 16) The very words Ms. Bartilson has excerpted from my letter to support her charge show that I do consider that the ruling does restrict my conduct. "I consider myself free to do anything anyone can, except testify absent a subpoena." Ms. Bartilson is also aware that I have appealed the Sohigian ruling for the reason that it does restrict my conduct, in fact acts as an unconstitutional prior restraint on my right to speak, and

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that, even though the restriction is limited to my not being able to testify on behalf of claimants or intended claimants against the organization except pursuant to subpoena, I consider that injunction illegal as it is obstructive of justice and uses the authority and powers of the judiciary to assist vexatious and criminal litigants. The Sohigian ruling does not prohibit my association with and befriending of all those people I consider the organization attacks unjustly and senselessly, does not prohibit my making my knowledge and support available to the Cult Awareness Network, hereinafter referred to as "CAN," in the litigation the organization has fomented against CAN, and does not prohibit my making my knowledge and support available to entities like Time and people like Rich Behar in their defenses from the organization's attacks. Nowhere does the Sohigian ruling state that I may not help those individuals or groups against whom the organization or its agents is litigating a claim or intending to litigate a claim. Nowhere does the Sohigian ruling state that I must sit by while the organization lies, cheats, abuses innocent people, attacks justice and perverts religion.

8. Ms. Bartilson states that a paragraph she quotes from my December 22 letter makes plain what she calls my personal contempt for a court which would rule against me. (App. p. 5, 1. 10; LJB Dec. p.9, para. 19) This is a wild and crazy concoction. What I stated, and what I believe is obvious in our system of jurisprudence, and far from contemptible, is that no court will

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order me to not defend myself. I have been sued by the organization and I am therefore a defendant. If there comes a day when defendants are not permitted by our courts to defend themselves, then our courts will be deserving of society's contempt. Although the organization, which, pursuant to its own policy, uses our courts to harass its perceived enemies and waste people's time, money and lives, works for that day, I am not worried about that day's arrival. At this time I continue with faith in God Who will not let Justice be no more and Who will not leave me defenseless. I am not unaware that judges are human, that some have been compromised and corrupted, and that bucks, babes and bull are common mechanisms to effectuate judicial compromise and corruption. I am also not unaware that the organization has a widely known and occasionally publicized history of contempt for our judicial system and contumelious efforts to compromise and corrupt our judiciary. Here, not only does the organization seek to have this Court prevent me from defending myself by, inter alia, publicly speaking the truth and helping the organization's victims, it presses to have me punished for speaking and helping.

9. Ms. Bartilson makes much of the fact that I continue to work as a paralegal in the office of Ford Greene who represents various people in organization-related litigation. (App. p. 6, 1. 6; LJB Dec. p. 4, para. 6) Yet it is the organization which has made it necessary for me to work in Mr.Greene's office. Wherever I go, until the organization publicly and honestly

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repudiates "fair game," it will target me and use its intelligence network and operations, legal machinery and self-serving madness to destroy me. No employer, other than one who understands this organization's motives, means and madness, can recognize and withstand its covert and overt attacks. The organization puts at risk, because of its pervasive and calculated hatred of me and its determination to destroy me, any employer who would hire me. In 1982 its PIs staked out the law firm where I worked, embarrassed me, terrified my fellow employees, and it harassed my lawyer employers, including the firm's senior partner, with frivolous depositions. The organization attacked my next employer, Michael Flynn, with some fifteen lawsuits, bar complaints, framed him with the forgery of a $2,000,000 check, ruined his marriage and finally induced him to desert me in order to end the attacks. In 1991, the organization sued another lawyer, Joseph A. Yanny, for daring to represent me in litigation. Mr. Yanny didn't represent me and the litigation existed only in the organization's mad imagination. The organization has now initiated an attack on yet another of my lawyers, Michael L. Walton, subpoenaing him for a frivolous deposition, demanding the production of his personal files and client files, threatening to take his house, and disrupting his life. The organization has subjected Ford Greene to false bar complaints, constant surveillance, and a scheme in which organization lawyers tricked his clients, the Aznarans, into firing him as their lawyer. It sent an agent to get close

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to him, get into his office by deception and steal his client files. The organization will do whatever it can to compromise me, any employer and any lawyer, and ruin any relationship of any kind I may develop with anyone. The organization's malice is certainly demonstrated in this effort to have me held in criminal contempt. Based on lies and perversions it wants me jailed for opposing its antisocial acts, and living my own life. I have no doubt that the organization leaders have plotted my assassination, nor that all my friends are at risk from the organization because of their association with me. I am working with Mr. Greene because he too is the target of this organization's attacks, because he understands, and because he too does not think much of organized evil.

10. Ms. Bartilson claims that my execution of proofs of service on July 30, 1992 in the case of Aznaran v. Scientology, US District Court, Central District of California No. CV-88-1786-JMI(Ex) is an acknowledgement of my intention to wilfully disobey the Sohigian ruling (App. p.7, l.10; LJB Dec. p. 6, para. 11) It isn't. The Sohigian ruling is not intended to and does not prohibit such clerical tasks which can be done by anyone. Signing the proofs of service has nothing to do with my experiences in the organization, concerning which I can provide testimony to claimants and intended claimants only pursuant to subpoena. When I received and read the Sohigian ruling I sought to divine its meaning and apply it sensibly to my life, work and legal situation. If it meant precisely what it said then I would

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have to stop breathing because by breathing I would be indirectly assisting any person litigating a claim against the organization entities referred to in sec. 1 of the settlement agreement. Obviously, therefore, Judge Sohigian did not mean what he stated. If he meant only that I could not, as opposed to passive assistance to litigating claimants such as breathing, living and writing magazine articles for the public generally, physically act to help such a claimant personally, I would have to ensure every little old lady or little old man I might escort across any old road was not such a claimant. I am certain Judge Sohigian did not intend that. Even an interpretation of the Sohigian ruling that I am prohibited from indirectly assisting any person litigating a claim against the organization entities in that litigation, in some way unrelated to my experiences in and potential testimony against the organization, leads to absurdities that Judge Sohigian also could not have intended. I recognized that the organization would interpret the Sohigian ruling in an absurd way because its way of interacting with me is crazy and its stock-in-trade is perversion of logic and truth; but I reasoned that I could not myself act in an absurd or illogical fashion and pervert truth out of fear of the organization's use of my God-given actions to attack me. Following Ms. Bartilson's tortured logic, if I got a job as a clerk in the LA Superior Court, for the rest of my life I would not be able to receive, stamp or file any document from anyone involved in litigating a claim against any of the organization

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entities. Nor could I answer the phone if a lawyer for such a claimant or even his organization opponents called the Court. If I got a job as a postal carrier I would have to refuse to deliver mail to and from any such claimant. If I became a cab driver I would have to question all my fares and refuse to carry any claimant or his lawyers or witnesses on their ways to meetings, depositions and trials. If the same illogic were permitted in settlement agreements in all cases, and became anywhere near usual in the litigation industry, nobody in this great country could do anything for anybody for fear of violating some non-assistance covenant. The opportunities for unscrupulous groups like the Scientology organization would be fantastic, for anyone who signed such an agreement could be easily framed with settlement violations. Coupled with $50,000-a-crack liquidated damages clauses the economic possibilities are Hubbardian in megalomagnitude. Trick the clerk into opening an envelope containing anti-organization litigation papers; con the cabby into driving the wrong person to a deposition; photograph the postman delivering something to a litigant. But I do not believe Judge Sohigian intended such an interpretation of his ruling, and I do not believe such non-assistance covenants or orders are legal or do anything but obstruct the administration of justice and attempt to destroy men's souls. I believe Judge Sohigian intended only that I cannot make my organizational experiences, which are unique to me, available as testimony to claimants or intended claimants except pursuant to a subpoena. For seventeen

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months I have been Ford Greene's sole office helper. I cannot always tell who is phoning Mr. Greene's office before I speak to the caller, and sometimes the callers are people litigating claims against the organization. These same litigants send mail to and receive mail from Mr. Greene's office. It would be unprofessional, discourteous and suicidal to not assist those people by not taking their calls, refusing to handle their mail or not signing proofs of service if I do handle their mail. These are clerical tasks which anyone without any organization experience can perform, and, I believe, are included in Judge Sohigian's specific non-prohibition from "engaging in gainful employment rendering clerical or paralegal services not contrary to the terms and conditions of this order."

11. Ms. Bartilson states in her declaration:

"In July, 1992 following my receipt of a copy of a ruling of Judge Ideman in Aznaran v. Church transferring that case from the Central District of California to the U.S. District Court in Dallas, Texas, I received a telephone call from Armstrong in which he stated that he was calling from Mr. Greene's office and that he needed to receive immediately by fax such transfer ruling of Judge Ideman. I told Armstrong that the May 28 Order prohibited him from assisting the Aznarans or any other litigants against the

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Church. He replied that he was trying to help the Aznarans. On behalf of my client the Church, I allege that the statements made by Armstrong as relayed in this paragraph are acknowledgements by Armstrong of his awareness of the May 28 order, his ability to act in compliance of such order and his intention to wilfully disobey its terms." (LJB Dec. p. 5, para. 9)

Ms. Bartilson's averments are in a different firmament from the realm of truth. On Friday, July 10, 1992 at approximately 2:10 P.M. Ms. Bartilson called Mr. Greene's office. I answered the phone, and she asked for Mr. Greene. I advised her that he was in court. Ms. Bartilson gave me the message that the organization was filing an ex parte application for relief in Aznaran from the US District Court's order of June 25, 1992, attached hereto as Exhibit [A]. She then said, sarcastically, "You'll just relay the message, right? You won't do any work on the case?" Because I knew Mr. Greene's office had not received the order, concerning which Ms. Bartilson was going to be seeking the ex parte relief, I attempted to relay her message to Mr. Greene's co-counsel on the Aznaran case, John C. Elstead, who I thought would have the order. Mr. Elstead's secretary, however, advised me that he was in Idaho and that she did not know if he had the order. Because of my understanding of notices of ex parte applications, because it was Friday afternoon, because I

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did not know how long Mr. Greene would be gone from the office and I had no way of contacting him, because Ms. Bartilson had already called me and announced the fact of the order and spoken to me about the ex parte application, and because the relay of such communications and documents is merely common courtesy between people in the law business, I called Ms. Bartilson back and asked her to fax the order she was referring to. Ms. Bartilson said she wouldn't fax the order unless someone else in Mr. Greene's office asked for it. I simply said that I was trying to help her by making sure the information to Mr. Greene was complete. In her attitude and comments Ms. Bartilson was snotty, and in her present declaration shameless. The order granting defendants' motion to transfer the Aznaran case to Texas, attached hereto as Exhibit [B], was signed on August 26, 1992, a month and a half after Ms. Bartilson's call to me on July

10. She is also fibbing about who I said I was trying to help and who called whom.

12. Ms. Bartilson states that in my deposition in this case taken on October 8, 1992 I admit that I was assisting three persons, Tillie Good, Denise Cantin and Ed Roberts, and that whatever it was I said indicates my intention to wilfully disobey the Sohigian ruling. (App. p. 7, l. 18; LJB Dec. p. 6, para 12) Yet there is not one word in the deposition pages Ms. Bartilson cites to that shows I assisted Ms. Good, Ms. Cantin or Mr. Roberts in violation of the Sohigian ruling. I did not assist them and I did not violate the ruling.

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13. Ms. Bartilson charges that my interviewing Mr. Roberts violates the letter and spirit of the May 28 order. (App. p. 8, 19, 20) She fails, however, to provide the date of said interview. It was November, 1991, six months before the Sohigian ruling.

14. Ms. Bartilson states that my assisting in the relay of communications between Richard and Vicki Aznaran and Ford Greene are violations of the Sohigian ruling, for which I should be found in criminal contempt and jailed. (App. p. 7, l. 5) Her co-counsel, Andrew Wilson, however, during my deposition in this case on July 22, 1992, clarified what office clerical duties he considered were not prohibited by the Sohigian ruling.

"If you answer the phone because one of your duties is to answer the telephone in the office, that is not part of your duties as a paralegal on the Aznaran case. "if the communication was 'have Mr. Greene call me,' I wouldn't consider that a paralegal duty."

(Pages 190, 191 from 7/22/92 deposition, attached hereto as Exhibit [C]) I took Mr. Wilson's comments to mean that he recognized that clerical duties which could be performed by anyone were not prohibited by the Sohigian ruling. I also took his comments to mean that he was going to interpret the ruling sanely, and certainly not in the absurd manner Ms. Bartilson has. I did not consider that when Mr. Wilson was making his statements

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he was inviting me to violate the organization's interpretation of the Sohigian ruling so I could be found in criminal contempt and jailed.

15. Ms. Bartilson states that in my letter of December 22 I include the payment of an unspecified amount to Mr. Roberts as a condition to ending my "campaign of harassment against the Church." (App. p. 8, l. 16) Making Mr. Roberts whole financially is not a condition to anything. I have no campaign of harassment to be able to end. The organization has a campaign of harassment toward its innocent members and innocent non-members, which I have attempted with my December 22 letter to resolve peacefully. And the organization is, in its present philosophy and form, not a church.

16. Ms. Bartilson charges that I sent copies of my December 22 letter to 35 individuals in what can only be described as deliberate harassment. (LJB Dec. p. 7, para. 14) I, however, describe my letter differently, and I am not alone. Sending the letter to the various organization addressees made sense because they have a right to know about the risk at which they are being put by the organization's leaders, and because I have a duty to mitigate my damages in this case. Sending the letter to the non-organization addressees was a logical courtesy because they are all affected by the Armstrong litigation, the obstruction of justice spawned by the organization's settlement agreements, the Sohigian ruling, and most certainly would be affected by the organization's ceasing its seemingly ceaseless attacks. I don't

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believe any court will order me to not mitigate damages in this litigation, nor do I believe that any court will order me to not attempt to make peace with the organization and not attempt to end the organization's antisocial attitude and actions in order to avoid a significant human catastrophe. If the organization transformed its attitude and actions, as they are directed at its erroneously perceived enemies, into something different from antisocial, I would be more than willing to desist in my efforts.

17. Ms. Bartilson describes CAN as "an antireligious group that advocates the kidnapping and forcible 'deprogramming' of individuals belonging to religions." (LJB Dec. p. 8, para. 17) Because of what I learned over the past year and a half of the organization's attack of CAN and to see for myself what was the truth I attended CAN's 1992 annual conference, which was held this past November in Los Angeles. I am thoroughly convinced that CAN, unlike its attacker, is completely non-antireligious. I am religious, and CAN, unlike the organization, has never attacked me. I am also convinced that not only does CAN not advocate kidnapping and forcible deprogramming of individuals belonging to religions, it does not advocate kidnapping and forcible deprogramming of individuals belonging to non-religious, antisocial hate groups like Scientology. The organization as a hate group was in full force at the CAN conference with lawyers, private investigators, thugs and paid picketers whose sole purpose for being there was to harass CAN members, most of whom are innocent people of good will whose families or lives have

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been hurt by the organization or other cults of a similar antisocial and destructive stripe.

18. Ms. Bartilson charges that my making of a videotape of an interview with Jerry Whitfield is a deliberate violation of the Sohigian ruling. (App. p. 9, l. 19) She goes on to state that my production of the videotape interview

"demonstrate[s] most eloquently the contempt which Armstrong has for the legal process, plaintiff's rights, and this Court. His defiance is not accidental or a misstep: it is deliberate, flagrant, defiant contempt.

If ever a case cried out for the issuance of an order to show cause, this is the case." (App. p. 10, l. 16)

The videotape interview is not a violation of the Sohigian ruling because it does not assist any claimant against any organization entity in any claim, arbitration or litigation. It is indirect passive assistance to everyone just as breathing is, and cannot be enjoined by the ruling unless the ruling is interpreted in a foolish manner. As explained in paragraph 10 above, I do not interpret the Sohigian ruling as the organization does because to do so would be foolish.

19. Ms. Bartilson claims that Mr. Whitfield is an anti-Church litigant (App. p. 8, l. 26), and that I made the videotape for possible use in the case of Angel Casillas v. Jerry & Hana Whitfield , Los Angeles Municipal Court Case No. 91K49349 (App.

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p. 9, l. 14; LJB Dec. p. 10, para 22). The Sohigian ruling, no matter how the words are interpreted only enjoins me from assisting claimants or intended claimants against the organization. It mentions nothing about individuals or groups defending against organization claims; therefore I am not enjoined from assisting Mr. Whitfield in the Casillas case. Notwithstanding that fact, the videotape was not made for use in the Casillas case, and I have not assisted Mr. Whitfield in that case.

20. Ms. Bartilson seems to also recognize the distinction the Sohigian ruling makes between claimants against the organization and defendants against the organization because she carefully explains that

"[w]hile the Church is not presently suing the Cult Awareness Network in any litigation, the president of the Cult Awareness Network, Cynthia Kisser, has initiated an action against the Church and its president Heber Jentzsch." (LJB Dec . p. 8, para. 17)

There is no way whatsoever that I will ever be convinced by such assertions, no matter who makes them, especially an in-house organization Scientologist lawyer, whose office doubles as the organization's infamous intelligence bureau, OSA, the Office of Special Affairs. It is my firm belief that each and every one of the some thirty lawsuits filed by "individual" Scientologists against CAN across the United States within the past year has

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been fomented, written, filed, financially supported, supervised by the organization and controlled by its leader. If David Miscavige, the organization's admitted supreme leader, ordered the dismissal of any or all of the lawsuits against CAN, it would be done without objection. The organization's use of cutout litigants as fronts and getting them to do some of its dirty work in harassing perceived enemies is common knowledge. Having its agents, lawyers, members and litigation shills lie about who their controllers are, or about any other subject as ordered, is standard organization practice which is also common knowledge. Because the organization is behind the lawsuits against CAN, I am free to provide CAN my assistance in its defense. If indeed the organization is not behind the lawsuits against CAN, and I completely reject such a position, then I am free to assist CAN in those lawsuits for the very reason that organization entities are not parties. If, as Ms. Bartilson perceives it, I cannot assist anyone in litigation in which organization entities are not parties, then I would have to retire as a paralegal, and could never become a lawyer, or for that matter a postal worker or cabby. I cannot see that Judge Sohigian envisioned such madness in his ruling.

21. Ms. Bartilson also charges that the videotape was created

"for Whitfield's use in forcible deprogrammings to force unwilling Scientologists to renounce their faith." (App. p. 9, l. 12; p. 10, l. 11)

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I have known Jerry Whitfield for approximately six years, and have known his wife, Hana, for approximately twenty-two years. The Whitfields perform a function termed "exit counseling," which involves the education of individuals, who, as Judge Sohigian stated, "get themselves enmeshed in [the organization's] extremist view in a way that makes them unable to resist it apparently," at the request of such individuals' families, in aspects of the organization which have been deliberately kept hidden from the individuals while under the organization's control. Hana Whitfield was a senior aide to L. Ron Hubbard, worked with him personally, and managed sectors of the organization for him for many years, so is an ideal person to educate individuals enmeshed in the organization's extremist view in the dark and secret side of Scientology that is concealed from all but the organization's few leaders while they are inside. That the Whitfields are involved in "forcible deprogrammings" is a "black PR" attack invented out of whole cloth by the desperate organization leaders. Black PR or "black propaganda" is a term used by Hubbard to describe his organization's efforts to destroy people's reputations with lies and intelligence operations involving, inter alia, forgeries, frame-ups and entrapment. The work the Whitfields have been doing is dangerous, because they are the targets of the organization's doctrine and system of opportunistic hatred, also called fair game; but there is no evidence that I am aware of that they have forced anyone to do anything, or forcibly detained anyone. Scientologists do not

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have a faith which can be renounced, if by faith is meant anything approximating a system of religious belief. L. Ron Hubbard wrote that Scientology does not depend on belief or faith. He also wrote that Scientology does not consider or deal with God, and he attempted to mock God in his organizational policies. What exit counseling consists of is getting enmeshed individuals to examine the fact that they have been led by deceit and coercion to put their faith in secular representations of secular leaders who do not have their best interests in their minds and hearts and who are turning their good will against their families, friends, society and themselves; and that these leaders are effectuating this perversion of the spirit and will by the secular means of threat, isolation, lies and denial of access to facts and the truth.

22. Ms. Bartilson argues that

"incarceration is an unusually viable vehicle for impressing upon Armstrong the import of his obligations, inasmuch as Armstrong has publicly disavowed money as a meaningful or valuable commodity." (App. p. 13, l. 11)

Ms. Bartilson supports this argument with a copy of an article concerning my economic philosophy which appeared November 11, 1992 in the Marin Independent Journal. My present position is that although money has no value, until it is no longer currency I will accept what I am given and use it for God's work in the recognition that all that I am given, including money, has one

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Source. My economic theories, however, are no basis for my being jailed. Following Ms. Bartilson's logic, if incarceration did not restrain me from helping my fellow men, execution would then become "an unusually viable vehicle" to get my attention.

23. The organization's use of this innocuous article from my local newspaper argues strongly for why I must speak out and must do what I can to end the organization's mad war with everyone. In the organization's reply memorandum in support of a motion to strike my cross-complaint and for sanctions filed in this case on November 24, 1992, and to which the Marin IJ article is attached as an exhibit, Ms. Bartilson states that

"just last week Armstrong chose to gratuitously disclose information concerning the settlement agreement, in another violation of its specific terms, to a reporter interviewing Armstrong on a completely unrelated subject...Armstrong refused to testify concerning some of this same information under oath in deposition in this action, claiming that his side agreement with his former lawyer precluded him from disclosing the amount which he received in settlement to anyone...Obviously, Armstrong had no such compunctions about disclosing the amount to a reporter."

Page 2 from the organization's reply is attached hereto as

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Exhibit [D]. In the organization's motion to compel answers to deposition questions and the production of documents pursuant to notice of deposition, filed in this case on January 6, 1993, and to which the Marin IJ article is also attached as an exhibit, Ms. Bartilson states that "Armstrong has told the media how much he was paid in settlement." Page 9 from the organization's motion to compel is attached hereto as Exhibit [E]. In the organization's November 1992 edition of their publication, "Membership News, " which is a hate parody of CAN's publication "Cult Awareness Network News," the organization cites to the Marin IJ article, lifts the IJ's photograph of me, describes me as looking " like a cross between Charles Manson and a throwback to the Haight-Ashbury days of acid trips," and insinuates that I urge "kidnapping-for-free." The relevant page from the organization's "Membership News" is attached hereto as Exhibit [F]. I did not tell the Marin IJ reporter Richard Polito the amount of the settlement payment, and the organization knows that fact because its agent, private investigator Eugene M. Ingram, who has threatened to kill me, who at the CAN conference accused me of having AIDS and spread that diseased rumor at the conference, who illegally videotaped me, who framed my lawyer Michael Flynn, who has filed trumped-up bar complaints against Ford Greene, and who has harassed countless innocent individuals on the organization's orders, was told by Mr. Polito back in November 1992 when he visited the IJ office to "investigate" me that Mr. Polito did not get the information concerning the organization and the

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settlement from me but obtained it from a clip the IJ maintained in its own files. A copy of the Marin IJ article of March 21, 1992, which mentions the litigation, the settlement and the $800,000 figure, which facts did not come from me, is attached hereto as Exhibit [G]. I am a writer, artist and philosopher. I am the president of The Gerald Armstrong Corporation, I am involved in charitable projects internationally, and I have been given the formula for the Unified Field. The organization has demonstrated by its misuse of the Marin IJ article that it will attack me and my public persona in whatever I do in life, no matter how philanthropic my endeavors, or how unrelated they are to the organization. In the instant application Ms. Bartilson uses the article to support the organization's effort to have me thrown in jail. The organization has disrupted every aspect of my life and will continue to disrupt it and attack everything I do, even if it means denying the world a way by which some of its serious problems might be solved.

24. This is not the first time the organization has attempted to have me charged criminally and not the first time it has concocted an effort to have me found in contempt of court. It tried in 1982 to have the LA Police Department arrest me for sending documents to my lawyer after it had sued me civilly concerning the documents and after the subject documents were surrendered to the clerk of the LA Superior Court. In that case I was found by Judge Breckenridge, because of the organization's antisocial nature and acts and my knowledge thereof, to have been

25

manifestly justified in my actions. The organization tried in 1985 to have the Boston office of the FBI charge me with impersonating an FBI officer, based on the false statements of an organization agent. In 1986 the organization attempted to have the Los Angeles District Attorney charge me as a result of Ingram's illegal videotaping of me. The LAPD officer involved with Ingram in the scheme, who was paid at least $10,000 for his help, was suspended from the force. The DA rejected the organization's efforts. In Armstrong I, the organization attempted three times to manipulate the Court into holding me in contempt. Each of these efforts, all of which were based on the organization's false sworn statements, was rejected. In this case, in March, 1992, the organization attempted to have Marin Superior Court Judge Michael B. Dufficy hold me in contempt of court. The copy of the Marin Independent Journal article of March 21, 1992, Exhibit [G] hereto, is an exhibit to that application, which was also supported by a perjurious declaration of Laurie Bartilson, and also rejected. So far the organization pretends to not get the message: that its unscrupulous use of the courts and law enforcement agencies to attack and threaten innocent people is recognized for what it is and will not be tolerated in our society.

25. I do not believe Ms. Bartilson is a bad person, nor do I think she honestly believes I am a bad person. I believe she is deeply troubled by being compelled to perjure herself over and over and compelled to attack me because she knows I am not the

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villain she must make me out to be. I believe she is deeply troubled by her attacks on CAN, the Whitfields and countless other people of good will the organization considers targets. I believe she is deeply troubled by her abuse of the position, knowledge and rights of officers of the court, and the organization's use of her professional status. She demonstrates why people under the organization's control, whether they be lawyers, doctors, peace officers or postmen, cannot and should not be trusted. Only the organization's public and honest renunciation of its antisocial philosophy and practices, and release of all of those professional and ordinary people from its control, will render such Scientologists again as trustworthy as any other free people. Ms. Bartilson is under her organization's leader's malevolent thumb, she cannot make her own decisions, she is deluded, dishonest, and frightened. To do what she does she accepts the organization's pronouncement that Gerry Armstrong is a "suppressive person," that he is one of the "2 1/2 percent" most evil persons in the world, that he is "psychotic," driven by "hidden evil intentions," and "truly insane," that he threatens the whole future of all mankind, that he really is not worth saving, and that it is, therefore, pro-survival, ordered and praiseworthy to attack him. The organization's "legal" position regarding enquiry into the "suppressive person" doctrine and attitude, is that it is protected "religious belief," and the literature, including orders thereon, which must be obeyed, is "scripture." That may be, in that persons and thoughts are holy,

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but by its own choice the organization has brought its socially repugnant "religious" doctrines into the secular legal arena for a secular purpose. If Ms. Bartilson rejected the organization's pronouncements she knows that she would herself be labeled "suppressive" and herself become fair game's target. She also knows that the organization has real lawyers doing real things with real private investigators with real guns, all of whom are making real money at their tasks, and that that is the real level to which the organization leaders have taken their unpleasant game in the real world. In her application Ms. Bartilson asks for real law enforcement personnel with real guns to really lock me up in a real jail for real time. Ms. Bartilson should not be condemned for being manipulated by the organization's malevolence; she, as all victims, should be viewed with much compassion. At the same time, she should be restrained and brought to understand that her acts are malicious, silly and unacceptable from a member of the bar and society.

26. The picture the organization is painting and would have this Court believe is real is that I view the Los Angeles Superior Court, the Sohigian ruling, and Judge Sohigian with contempt, and that my acts demonstrate that contempt. My acts, what I did and said, are detailed above, and I believe demonstrate something different from contempt. I do not deny that I was, until I, in my opinion, understood it and resolved for myself its practical application, perplexed by the Sohigian ruling. I believe strongly, however, that I have respected the

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ruling and, although, as stated above, I believe that, even as I interpret and respect it, the ruling is illegal, I have not acted in any way in contempt of it. I believe that Judge Sohigian created with his ruling an invitation for me to appeal it, and provided within the ruling itself the appeal's grounds: its fuzziness, its contradictions, its departure from his hearing comments, its rewriting of the settlement agreement's prohibitions, and its statutory and constitutional violations. I believe Judge Sohigian's ruling strategically left the organization, because it escaped with sudden relief after the previous day's hearing in which lie sharply censured its unsavory practices, unwilling to appeal the ruling. This unwillingness is something different from the organization's pattern of appealing everything that can be appealed, and strikingly so here because Judge Sohigian refused to enforce all but the narrowest slice of the settlement agreement, and even that he rewrote in my favor. I believe he offered the organization an opportunity to redeem itself and it is now clear that his offer has not been accented. I respect Judge Sohigian's intellect and person and am thankful he heard the injunction aspect of my case.

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

Executed at San Anselmo, California. on February 2, 1993.

GERALD ARMSTRONG

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© Gerald Armstrong

Exhibit [A]
Ex parte application for relief in Aznaran from the US District Court's Order of June 25, 1992

Exhibit [B]
Order granting defendants' motion to transfer the Aznaran case to Texas 08-26-1992

Exhibit [C]
Armstrong Deposition Pages 190, 191 07-22-1992

Exhibit [D]
Organization's reply to Marin IJ article

Exhibit [E]
Page 9 from the organization's motion to compel

Exhibit [F]
Relevant page from the organization's "Membership News"

Exhibit [G]
Marin IJ article 03-21-1992