I, Gerald Armstrong, declare

1. I am making this declaration to provide certain facts to correct certain statements presented as material facts in the "Separate Statement of Undisputed Facts with Reference to Supporting Evidence in Support of Motion of Cross- Defendant Church of Scientology International for Summary Adjudication of Gerald Armstrong (sic); Does the Second and Third Causes of Action of the Amended Cross-Complaint."

2. Attached hereto as Exhibit [A] is a declaration I executed March 15, 1990 and filed in the Court of Appeal in support of a Petition for Permission to Respond in the appeal the Scientology organization took from the decision of Judge Paul G. Breckenridge, Jr. in the case of Scientology v. Armstrong, Los Angeles Superior Court Case No. C 420153 ("Armstrong I ").

3. Attached hereto as Exhibit [B] is a declaration I executed December 25, 1990 and filed in the Court of Appeal in the Scientology organization's appeal in Armstrong I. These two declarations detail the organization's acts against me from the December, 1986 settlement to the date of their execution. I considered these acts in violation of the letter and spirit of that settlement.

4. I had fought hard, and survived much adversity and very threatening organization attacks from 1982 through 1986, just to be able to state the truth about my experiences in and knowledge of Scientology. Judge Breckenridge had stated in his Memorandum of Intended Decision issued June 20, 1984 in Armstrong I, a copy of which is attached hereto as Exhibit [C], that I was "free to speak or communicate upon any of [my] recollections of [my] life as a Scientologist or the contents of any exhibit received in evidence or marked for identification and not specifically ordered sealed." In signing the settlement agreement it was not my intention that this freedom would be taken away, and that the Scientology organization could thereafter attack me with impunity by characterizing me as a liar, criminal and agent provocateur. That is why it was completely logical to me that my attorney Michael Flynn, who participated in the settlement negotiations along with Scientology attorney Lawrence E. Heller, would and did state to me before I signed the settlement agreement that the provisions which prevented me from disclosing my experiences or communicating freely were "not worth the paper they're printed on; "they're unenforceable."

5. I also discussed with Mr. Flynn before signing the settlement agreement the fact that it prevented the Scientology organization from speaking out against me or disclosing my experiences in the organization. I based this on: (1) that I would never allow Scientology to slander me while I had to remain mute; and (2) because each of the "releases" within the settlement agreement was only up to the date of execution of the document. Therefore, my intent was that if any Scientology organization disclosed any information concerning me, I in turn would be automatically free to respond with my own statement of my own experiences and knowledge. Nevertheless, I did seek peace with the organization, and did not respond to its attacks and disclosures until I was threatened several times, and knew I had to respond to not obstruct justice.

6. I did not know at the time of the settlement that Mr. Flynn had entered into separate agreements with Scientology's lawyers, copies of which are attached hereto as Exhibits [D] and [E], that had the effect of facilitating the Scientology organizations' overturning of Judge Breckenridge's decision. These documents were disclosed by Scientology in the course of the appeal of Armstrong I. I also learned only after signing that Mr. Flynn, Julia Dragojevic and Bruce Bunch, all of whom represented me in Armstrong I , had signed similar settlement agreements which they said prevented them from assisting me in my defense of the organization's later efforts to enforce the settlement agreement. Prior to my signing the settlement agreement, Mr. Flynn indicated to me that "if anything happened in the future [he would] be there for me." Since the organization filed its various actions against me to enforce its settlement agreement, all three of my former attorneys have indicated in conversation that they would like to assist me against Scientology's lawsuits, but are afraid of reprisals from Scientology if they do so.

7. I was inside Scientology from 1969 through 1981, held many organization positions, and gained a knowledge of organization structure, policies and practices. Attached hereto as Exhibit [F] is a policy I am familiar with written by L. Ron Hubbard entitled "Penalties for Lower Conditions." This document states what is commonly known as the "Fair Game Policy." I am familiar with the term "SP" or "Suppressive Person" and the term "SP Order." An "SP Order" is also know as an "SP Declare" or "Suppressive Person Declare."

8. Attached hereto as Exhibit [G] and [H] are two "Suppressive Person Declares" published by CSI in 1982, labeling me a "Suppressive Person." I am familiar with the way Scientologists and the organization view and treat "Suppressive Persons," and I know that pursuant to its policy I have been viewed and treated as a "Suppressive Person" without cessation from 1982 to the present.

9. I am familiar with one of the Scientology organizations' policies, written as an article entitled "Dissemination of Material" by L. Ron Hubbard and published in a Scientology book entitled Magazine Articles on Level O Checksheet. This article, a copy of which is attached hereto as Exhibit [I], contains the direction:

"The law can be used very easily to harass, and enough harassment on somebody who is simply on the thin edge anyway, well knowing he is not authorized, will generally be sufficient to cause his professional decease. If possible, of course, ruin him utterly."

I have been involved in Scientology- related litigations since 1982 and have observed that the direction and philosophy given by Hubbard in this policy are completely consistent with the manner in which the Scientology organization has used the law in its cases against me.

10. I am familiar with the claim of the Scientology organization that its policies, including the above Exhibits F and I are religious "scripture." I am also familiar with policies that state that L. Ron Hubbard's policies must be followed exactly, and other policies which subject any staff members who do not comply with orders or policies to Various "ethics penalties." Such "ethics penalties" are many, are commonly assigned and enforced, and range up to and including labeling persons "Suppressive Persons," and targeting them for "Fair Game."

11. The concept of "Fair Game" is also applied to people who have never been staff members, but who are perceived as "enemies" of the organization. I was aware both while inside Scientology and after leaving that Michael Flynn was the target of "Fair Game." While working in his law office in 1985 and 1986 I became aware of approximately a dozen lawsuits filed against him by Scientology, several bar complaints, a "black propaganda" campaign against him in the courts and media, and an effort to have him charged with forging a check for $2,000,000 on one of L. Ron Hubbard's bank accounts. "Black propaganda" or "black PR" is a term Hubbard gave to the practice of destroying someone's reputation with lies originated from unknown sources. I have been the target of an international "black PR" campaign by Scientology since 1982. The organization has falsely accused me of crimes, including crimes against humanity, of perversions, and has tried several times to have me jailed for things either never done or instigated by the organization itself. Attached hereto as Exhibits [J], [K], [L], [M], [N] and [O] are affidavits filed within a year after the settlement by organization employees Kenneth Long and Sheila Chaleff in the case of Scientology v. Miller & Penguin Books, in the High Court of Justice, London, United Kingdom, Case No. 6140. In these affidavits Scientology falsely accuses me of violations of various court orders and of being an "agent provocateur of the US government."

12. Attached hereto as Exhibit [P] is a declaration executed by Scientology attorney Lawrence E. Heller on or about November 1, 1989 and filed in the case of Corydon v.CSI, et al. Los Angeles Superior Court Case No. C 694 401. This declaration was filed in support of one of the Scientology organizations' Motion to Delay or Prevent the Taking of Certain Third Party Depositions by Plaintiffs, attached hereto as Exhibit [Q], also filed in the Corydon case on or about November 1, 1989. I am familiar with these documents because I am one of the third parties whose deposition Scientology attempted to prevent, and because I attended the hearing in Corydon at which Scientology's motion was denied.

13. CSI and the other Scientology organizations have falsely claimed at various times that I worked for attorney Joseph Yanny as a paralegal on the case of Aznaran v. Church of Scientology of California, et al., United States District Court for the Central District of California, No. CV 88-1786 JMI (Ex) (the "Aznaran case"). I was never asked by Mr. Yanny to be a paralegal for him on the Aznaran case. I was never paid by him to be a paralegal for him on the Aznaran case. And I was never a paralegal for Mr. Yanny at any time on the Aznaran case.

The only thing I did on the Aznaran case on or about July 16, 1991 which had anything to do with Mr. Yanny was to write and/or execute two declarations. I did so as a percipient witness to the organization's obstruction of justice and abuse of process stemming from its "settlement agreement" with me, and as a percipient witness to a telephone conversation.

14. A briefcase containing an original manuscript and drawings and other documents was stolen out of the trunk of my car when it was brokwn into in the fall of 1984. In 1992 I learned from Vicki Aznaran that David Miscavige, whom I know to be the head of all of Scientology, bragged to her of having my things and described my writings and drawings to her.

15. I had a dream in 1985, which the Scientology organization obtained through an intelligence operation it ran against me from 1982 to 1985. The organization filed the dream in Armstrong I for the purpose of embarrassing me and destroying my reputation. It had no relation to the issues in the Armstrong I case. The dream was specifically sealed by Judge Breckenridge during the pendency of the Armstrong I cross- complaint, and then generally sealed with the rest of the Court file at the time of the settlement. In August, 1991 I learned while in South Africa that Scientology had sent it to its South African lawyers for use against me in the case of Malcolm Nothling v. Scientology in which I was to testify. Scientology's lawyers let Mr. Nothling's lawyers know that they had the dream and ridiculed me for having dreamed it.

16. Attached hereto as Exhibit [R] is a declaration I executed September 3, 1991, and which was filed September 4, 1991 in the Aznaran case.

    17. Attached hereto as Exhibit [S], is page 52 from the Reporter's Transcript of Proceedings at a hearing on December 23, 1991 in Armstrong I on Scientology's motion to enforce the settlement agreement. I was present when Judge Geernaert made the statement: "So my belief is, Judge Breckenridge, being a very careful judge, follows about the same practice and if he had been presented that whole agreement and if he had been asked to order its performance, he would have dug his feet in because that is one....of the most ambiguous, one-sided agreements I have ever read. And I would not have ordered the enforcenment of hardly any of the terms had I been asked to, even on the threat that, okay, the case is not settled. I know we like to settle cases. But we don't like to settle cases and, in effect, prostrate the court system into making an order which is not fair or in the public interest."

18. CSI has alleged that before the file in this case was moved to Los Angeles, but after the TRO was issued, I discussed my experiences with the Scientology organization for hours with attorneys for litigants against protected entities. CSI has not provided an accurate citation for this allegation. It is untrue.

19. Attached hereto as Exhibit [T] is a document purporting to be a transcript prepared by CSI of a news show "Headline News" on Cable News Network on March 20, 1992. This document is CSI's Exhibit C to its Verified Second Amended Complaint for Damages and for Preliminary and Permanent Injunctive Relief for Breach of Contract filed herein April 5, 1994.

20. I am familiar with the documents filed in the instant case. Attached hereto as Exhibit [U] is an order issued by Judge Michael B. Dufficy on March 27, 1992. Attached hereto as Exhibit [V] is a letter dated March 26, 1992 from Scientology attorney Andrew Wilson to Judge Dufficy. Attached hereto as Exhibit [W] is an order issued by Judge Michael B. Dufficy on March 22, 1992.

21. The Scientology organization has alleged in the press and in court many, many times since 1985 that I planned to plant forged documents in the organization and have them "found" in a government raid. This never happened. It is part of an intelligence operation the organization ran against me over many years, and still keeps live with its false allegations such as it has made about me the case of Church of Scientology International v. Xanthos, et al., United States District Court for the Central District of California, Case No.91 4301 SUW (Tx). The organization made the allegations in the Armstrong I case, which was sealed at its insistence.

22. Attached hereto as Exhibit [X] is a declaration I executed August 26, 1991. Exhibits I authenticated therein are a letter from L. Ron Hubbard to the FBI dated September 7, 1955, and a Technical Bulletin written by Hubbard July 22, 1956.

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 July 20, 1994

GERALD ARMSTRONG

Exhibit [A]
Armstrong Declaration 03-15-1990

Exhibit [B]
Armstrong Declaration 12-25-1990

Exhibit [C]
Breckenridge Decision

Exhibit [D]
Flynn Agreement

Exhibit [E]
Flynn Agreement

Exhibit [F]
Hubbard, L. Ron HCO PL 18 October, 1967 PENALTIES FOR LOWER CONDITIONS © 1967 L. Ron Hubbard

Exhibit [G]
Armstrong Suppressive Person Declare

Exhibit [H]
Armstrong Suppressive Person Declare (revised)

Exhibit [I]
Magazine Articles on Level O Checksheet

Exhibit [J]
Kenneth Long/ Sheila Chaleff Affidavit

Exhibit [K]
Kenneth Long/ Sheila Chaleff Affidavit

Exhibit [L]
Kenneth Long/ Sheila Chaleff Affidavit

Exhibit [M]
Kenneth Long/ Sheila Chaleff Affidavit

Exhibit [N]
Kenneth Long/ Sheila Chaleff Affidavit

Exhibit [O]
Kenneth Long/ Sheila Chaleff Affidavit

Exhibit [P]
Heller Declaration 11-01-1989

Exhibit [Q]
Motion to Delay or Prevent the Taking of Certain Third Party Depositions by Plaintiffs 11-01-1989

Exhibit [R]
Armstrong Declaration 09-03-1991 (filed in Aznaran)

Exhibit [S]
Page 52, Reporter's Transcript of Proceedings 12-23-1991 (Armstrong I)

Exhibit [T]
Purported transcript prepared by CSI of "Headline News" on Cable News Network
03-20-1992.

Exhibit [U]
Judge Michael B. Dufficy Order 03-27-1992 (Corydon)

Exhibit [V]
Wilson letter to Judge Dufficy 03-26-1992

Exhibit [W]
Judge Michael B. Dufficy Order 03-22-1992

Exhibit [X]
Armstrong Declaration 08-26-1991