Declaration of Gerald Armstrong

Armstrong 2

CT 1686


I, Gerald Armstrong, having personal knowledge of the following, hereby declare and.state:

1. I became involved with Scientology as a customer in 1969 in Vancouver, British Columbia. I worked on staff there in 1970 and in February 1971 joined the Sea Organization (SO or Sea Org) in Los Angeles. I was flown to Spain and joined the Sea Org's flag ship, "Apollo," in Morocco. L. Ron Hubbard, the Sea Org's "Commodore," was on board and operated Scientology internationally through the "crew" which numbered, during my stay on board of four and a half years, around four hundred. All my staff positions on board involved personal contact with L. Ron Hubbard, Mary Sue Hubbard, administrative organization staff and people in the ports and countries the "Apollo" visited, and included "Ship's Representative" (legal representative), "Port Captain" (public relations officer), and "Information Officer" (intelligence officer).

2. In the fall of 1975 after the ship operation moved ashore in Florida I was posted in the Guardian's Office (GO) Intelligence Bureau connected to Hubbard's Personal Office. From December 1975 through June 1976 I held the post of Deputy LRH External Communications Aide, a relay terminal for Hubbard's written and telex traffic to and from Scientology organizations. From July 1976 to December 1977 I was assigned, on Hubbard's order, to the "Rehabilitation Project Force" (RPF), the SO prison system. In 1978 I worked in Hubbard's cinematography crew in La Quinta, California, making movies under his direction until the fall of that year when he again

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assigned me to the RPF, this time for eight months first in La Quinta, then at a newly purchased base in Gilman Hot Springs near Hemet, California. When I got out of the RPF in the Spring of 1979 and until the beginning of 1980, I worked in Hubbard's "Household Unit" (HU) at Gilman, the SO unit which took care of Hubbard's house, personal effects, transport, meals and so forth, as the "Purchaser," "Renovations In- Charge" and "Deputy Commanding Officer HU."

3. Throughout 1980 and until I left the organization in December 1981 I held the organization posts in Hubbard's "Personal Public Relations Bureau" of "LRH Archivist" and "LRH Personal Researcher." I assembled in Los Angeles an archive of Hubbard's writings and other materials relating to his history to be used as, inter alia, the basis for a biography to be written about the man. I also worked in Los Angeles for the first few months of 1980 on Mission Corporate Category Sortout (MCCS), which had the purpose of restructuring the Scientology enterprise so that Hubbard could continue to control it without being liable for its actions. Beginning in the fall of 1980 and continuing until my departure, I provided the biographical writings and other materials, as I collected and organized them, to Omar Garrison, who had contracted with the organization to write the Hubbard biography. I interviewed many people who had known Mr. Hubbard at periods throughout his life, including almost all of his known living relatives. I traveled several thousand miles collecting biographical information and conducting a genealogy search, and arranged the purchase of a number of collections of Hubbard-related

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documents and other materials from individual collectors.

4. As a result of the activities described above, I have become very familiar with Scientology policies, practices, and policy documents. I also know that the Church of Scientology of California, as part of the Scientology organization, has followed and implemented these policies and practices, including those described below.

5. Attached to this declaration as Exhibit A is a true copy of a portion of volume II of The Technical Bulletins of Dianetics and Scientology, by L. Ron Hubbard, the founder of Scientology. It includes (at page 157) the following description of Scientology's practice of using litigation to harass its opponents:

The purpose of the suit is to harass and discourage rather than to win. [ ¶ ] The law can be used very easily to harass, and enough harassment on somebody who is simply on the thin edge anyway...will generally be sufficient to cause his professional decease. If possible, of course, ruin him utterly.

6. Attached to this declaration as Exhibit B is a true copy of an internal Scientology document, Guardian Order 166, dated October 7, 1971. This document was written by the then Guardian, Jane Kember, at that time the most senior Scientology official under L. Ron Hubbard and his wife, Mary Sue Hubbard.GO 166 was included in the Intelligence Course Pack which I studied while I was the Intelligence Officer on Scientology's ship the "Apollo" in the 1970's. This document includes the following explanation that Scientology legal strategy in the U.S. is to use litigation as a financial club:

The button used in effecting settlement is purely financial. In other words, it is more costly to continue the legal action than to settle in some fashion. ... [ ¶ ]

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Therefore, it is imperative that legal US Dev-T his opponents and their lawyers with correspondence (a
lawyer's letter costs approx $50), phone calls (time costs), interrogatories, depositions and whatever else
legal can mock up. [ ¶ ] One of the bright spots of US legal is that even if you lose you don't pay your opponent for his lawyers fees.

The phrase "Dev-T" is a term which Scientology uses to mean to cause someone to do unnecessary work.

7. Since leaving the Scientology organization, I have monitored the conduct of the organization, including the Church of Scientology of California. I am familiar with, and have been a target and victim of the "fair game" doctrine, which was described by the California Court of Appeal decisions in Church of Scientology v. Armstrong, Allard v. Church of Scientology, and Wollersheim v. Church of Scientology . Although Scientology claims that the "fair game" doctrine has been abandoned, I know from personal experience that this is not true, at least as recently as this year. For instance, Scientology attempted in the first few months of 1993 to have me jailed for contempt of court based on the false declaration of a Scientologist lawyer, Laurie Bartilson, for acts which Scientology itself set up. This is only the most recent of over a decade of "dirty tricks" which Scientology personnel have directed at me.

8. From my personal experience, I know that Scientology does use the litigation approach described by Hubbard and Kember in the quotes above. In various cases, Scientology has subjected me to over 35 days of depositions. As a paralegal working on cases involving Scientology for 16 months for Boston attorney Michael Flynn and for almost two years for California attorney Ford Greene (to the present), I have observed

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Scientology's litigation practices. Scientology regularly attempts to bludgeon the opposition into submission with a blizzard of meritless paper, motions, depositions, appeals, writs, Bar complaints, criminal complaints, perjured testimony, and other improper and abusive tactics.

9. I am also aware that Scientology uses an attack strategy against judges who rule against it, which includes claims of bias and prejudice and frequently personal attacks. For instance, in my case, Church of Scientology of California v. Armstrong, L.A. Superior Court No. C 420153, Scientology twice tried unsuccessfully to disqualify Judge Breckenridge from the case because of alleged bias, and levied personal attacks on him, accusing him publicly of Nazi affiliation. Similarly, in Aznaran v. Church of Scientology of California, U.S.D.C. C.D.Cal # CV-88-1786-JMI, Scientology unsuccessfully attempted to recuse Judge James Ideman because of alleged bias.

10. Attached to this declaration as Exhibit C is a true copy of the June 20, 1984 decision by Judge Paul G. Breckenridge, Jr., in the case of Church of Scientoloqy of California v. Gerald Armstrong, L.A. Superior Court No. C 420153, which was affirmed on appeal at 232 Cal.App.3d. 1060, 283 Cal.Rptr. 917 (1991).

I declare, under penalty of perjury, that the foregoing is true and correct.

Executed this 4th day of June, 1993, at Oakland, California.

Gerald Armstrong