CT 5894

DECLARATION OF GERALD ARMSTRONG

I, Gerald Armstrong, declare:

1. I have personal knowledge of the facts set forth in this declaration and could competently testify thereto if called as a witness.

2. I am a Christian.

3. My life, in every moment and breath, is God's and in His Hands. I have been saved from eternal separation and hell to become a son of God by His Grace alone, and drawn by Him to trust and follow His Son Jesus Christ as my Lord and Savior. I have been filled with God's Holy Spirit, and given by Him all peace, wisdom and love. I have been saved for God's Purposes to His

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Glory. I believe that His Purpose for me and all the world is salvation. I believe that the only difference of any meaning at any time between me and anyone else on this earth is this belief in God's Plan for salvation.

4. As a Christian and as a son of God I have been led and will be led into all of my life's situations and to all of the people I have encountered and will encounter for His Purposes alone. I believe that from God come all things, including the trust in Him, the willingness to believe on Him, free will, peace, wisdom and love.

5. I was raised as a "Christian" in the Anglican Church in Chilliwack, B.C., Canada, and I retained some of the Christian learning of my youth through my Scientology years. I was in Scientology from the age of 22 to the age of 35. When I first got into Scientology it professed, as it does with every new person, to be completely compatible with Christianity. It claimed to be a science, and its promises "demonstrably true." It claimed that it and its promises were the product of the scientific research of L. Ron Hubbard, Scientology's founder and leader, who also claimed to be an engineer and a nuclear physicist. Hubbard claimed that his techniques, procedures, end results and products had been subjected to the "rigors of the scientific method." Scientology also claimed to be "religion in the oldest meaning of the word," and "pan-denominational," accepting people of all religions and beliefs, but itself not requiring belief to deliver on its promises. In those days Scientology published a booklet called "Scientology and the Bible," in which Biblical quotations were compared as similar in meaning to quotations from Hubbard's works.

6. Throughout my Scientology years I put my faith in

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Hubbard, and in his philosophy, mental "science" and organizational policies. Through God's Grace and Wisdom I came to see that this was a misplaced faith. I came to see that despite that misplaced faith, God never deserted me, that He was with me and keeping me safe every moment, just as He is now. Throughout my Scientology years, through abuse, danger, and betrayal, He kept my heart from being hardened beyond salvation.

7. God kept me from being completely taken over by Scientology through all the years of indoctrination, mind control, "ethics," threat and punishment; and through the more than a thousand hours of mental processing, what Scientology calls "auditing." When Hubbard assigned me twice to the Rehabilitation Project Force (RPF), Scientology's prison, for a total of twenty-five months, when he had his messengers order my wife Terri to leave me, when I was ordered security checked for questioning Hubbard's truthfulness, God brought me through safely, made me stronger and wiser, and kept my heart from hardening. I now know that I was so deeply involved with Scientology, so devoted to an ungodly man and his ungodly teaching, only God's Own leading me, through His mysterious way, could have saved me. He led me into the Hubbard archive and biography project, brought me to study the man's secret papers and document his duplicity, and freed my faith from Scientology, on which it had been misplaced.

8. I now see that Scientology is the clever human invention of a clever human who took his human cleverness as far as it would go for his own glorification. I believe that God used me, an unsaved man, an uneducated, unrefined and very imperfect vessel, to accomplish part of His Plan for Scientology, Scientologists and salvation. I can see how it took someone with a God-given

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history, character and skills such as He gave me to bring out of Scientology, to the light, and to the minds and hearts of all those whom God sent to listen, a testimony of the character of Scientology's product and "source." I believe that God continues to use me to reflect the unworthiness and bankruptcy of Hubbard's attempt to create his own salvation plan, against the infallibility and peaceful grandeur of God's Plan.

9. In my post-Scientology period, when first in the outside world, confused and afraid, God took me in His Hands for particular care and teaching. When Scientology's leaders sent hired private investigators to spy on me and my wife, and essentially to terrorize us, God kept me, in spite of my fear and desperation, emotionally intact. God used Scientology's "Suppressive Person Declares," which, when I heard of and read gave me the shakes, to make me stronger and to bring the ungodly practice of "declaring" people, and targeting them as "fair game, "to light. He allowed Scientology to sue me so that its abuse of His children, the pathology of its "religious leader," and the baseness of its "theology" would be brought to light through my 1984 trial and the resulting "Breckenridge decision." When Scientology's leaders still resisted God's chastening, He caused the 1991 published opinion Scientology v. Gerald Armstrong, 283 Cal.Rptr. 917.

10. At the first hearing in my case in 1982, God somehow put into my hands a tiny tract of Bible quotes which I held and put my heart on as fear gripped at me. I've lost it since; it was about two inches square, and yellow colored, my first post-Scientology reach for God's Word. Throughout the 1984 trial, where I was on the stand for about ten days, I depended on the Twenty-third Psalm

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to calm my mind and heart. Between questions, over and over, "The Lord is my shepherd; I shall not want....Yea, though I walk through the valley of the shadow of death, I will fear no evil: for Thou art with me..."

11. God allowed Scientology's leaders to "cull" my "preclear folders." They took out of my supposedly confidential counseling files embarrassing or unsavory incidents from my past, and then divulged them in court and elsewhere, so that light would be shone on this terrible practice. God allowed these leaders to disseminate invented disgraceful incidents, as if I had "confessed" them during "auditing." God allowed me to humiliated and my heart to be broken over and over by the cruel acts directed by Scientology's leaders.

12. God allowed me to be terrorized, my car broken into, my drawings and writings to be stolen, other writings and ideas of mine perverted and held up to ridicule. He allowed Scientology's leaders to become intoxicated by their own lies so that they would try time after time to have me jailed on their false and manufactured criminal charges. He allowed their self-deception, so that they concocted a perverse intelligence scheme to entrap me in a crime and have me prosecuted. He allowed Scientology's leaders to put their faith in a base private investigator, Eugene Ingram, whom they would use to illegally videotape me, and who threatened to put a bullet between my eyes. God allowed the heart of an Los Angeles Police Department Officer, Philip Rodriguez, to be tempted by greed, and paid for a false authorization to Scientology to illegally videotape me. He allowed my friend Dan Sherman to use our friendship to betray me, to lead me with kind words into danger, to set me up, to trick from me my thoughts and

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writings, and to break my heart.

13. God allowed my own judgment to be clouded so that I would continue to walk unheeding into Scientology's intelligence scheme. In my childhood He gave me a desire to help the needy and the oppressed. He let Scientology's leaders divine and fix upon this God-given desire, and then manipulate the desire for their own purposes. It was during this period, when I sensed that I indeed might be walking into a trap, that I sensed God's close Presence, began to understand guidance, hoped and believed that I was being guided, and chose in the face of danger to keep going forward into whatever God unfolded. He allowed me to curse and to say things in ignorance or anger while being secretly recorded and videotaped, so that Scientology's leaders would be deluded into thinking these words would destroy me. In their delusion and rush to expose and destroy me, their trap, criminality and malevolent purposes were themselves exposed. Asking nothing more than my small willingness to go forward in faith, God brought me safely, albeit shamed and shaken, through all of Scientology's schemes, snares and temptations.

14. God allowed Scientology's leaders to also attack my attorney Michael Flynn, my good friend, benefactor and champion in the legal battle. God allowed Scientology to sue him some fifteen times, to threaten him, his family and career, to frame him with forgery, to pay known criminals to bear false witness against him, and, according to him, to attempt his assassination. God allowed Scientology's leaders to think they could destroy Flynn with their "black propaganda," "dead agent" packs, "noisy investigations," and the compromise and turning of other clients. Scientology worked for seven years to achieve this destruction. God brought

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me to Flynn, and him to me, and brought us to fight alongside each other in a legal and spiritual battle against the threat and evil of Hubbard and his organization from 1982 through 1986. In 1985 through 1986 I worked in his office in Boston. I depended on Flynn in those days. I loved him as if he were a big brother, and I tried in my role and capacity to help him and support him as a younger brother should.

15. I lived my own life as well, away from the Scientology battle, during those years, being brought ever closer to God. When I was alone, at times in terrible fear, He kept me safe, and allowed my heart to break, over and over. I believe He spoke to me, and that at times, as early as 1983, I wrote His Words to me under His guidance in what seemed to be dialogues. He gave me the idea for the true protection of His Children in this world, and moved me in 1986 to found a church, based on this concept. The Church, which is free to everyone, including Scientologists, has a belief, a corollary, and the obvious. The belief, out of Jesus's teachings (See, e.g. Matthew 18:20) is that when members of the Church are together, God is present. The corollary is that whatever is said or done when members of the Church are together is sacred. The obvious is that it is always thus. Scientology's lawyers attack my Church but it remains and lives under God's Will for His Glory.

16. With Scientology facing tremendous exposure and liability in my cross-complaint for years of outrageous fair game attacks, and having just suffered a $30,000,000 verdict in the case of Lawrence Wollersheim v. Scientology, Los Angeles Superior Court No. C 332027, God, almost incomprehensibly, then allowed Flynn to lose heart. Flynn "negotiated" a deal with Scientology

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which involved getting his clients to agree to the organization's demanded contractual condition of silence about their "experiences," while not demanding the same protection for his clients. Many of these clients had been the target of Scientology's "black propaganda" campaigns. He also agreed to get his clients to agree to a "liquidated damages" penalty of $50,000 per comment about their experiences. Flynn did this while believing, and having ample experience to justify believing, that the settlement agreements were evil, as was the entity which was insisting on the "agreements" being signed as a condition of settlement. Flynn knew Scientology's word was not to be trusted, yet he conveyed and gave support to Scientology's "promise" that it was going to discontinue fair game.

17. God allowed Scientology to harass, threaten and compromise Flynn, and allowed Flynn to be persecuted and compromised, for His Purpose to His Own Glory. After flying me from Boston to Los Angeles in December, 1986, Flynn presented the settlement documents to me for the first time. Upon reading the conditions in the "agreement," I was, as I've stated many times since, heartsick. I protested that it was impossible to live by Scientology's conditions, and that the "liquidated damages" penalty of $50,000 each time I might speak to anyone about my then seventeen years of experiences, was madness. And then God allowed Flynn to say the words, from his fear and desperation, but ultimately from truth, "Gerry, it's not worth the paper it's printed on. It's unenforceable. You can't contract away your Constitutional rights." God allowed Flynn to point out to me my release of Scientology and my dismissal of my lawsuit, and allowed him to say, "That's what they're paying you for."

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18. Flynn conveyed to me a picture of all who depended on me to sign the evil documents to get them "free" from Scientology's threat. He said that Scientology had promised to cease all "fair game" actions, to cease the attacks on all the settling individuals, and on every one else. He said that Scientology wanted the opportunity, which, he said, the settlement would give them, to prove that they had turned over a new leaf, and had ceased fair game. He said that he had to get out of the fight, that he had done enough, that he had paid his dues, that Scientology had ruined his marriage, his wife's health and his life. He said that if I didn't sign all I would get would be more of the same attacks, threat and misery. He said that I had to get on with my life, that I too had to get out of the litigation, get away from Scientology's threat, and that everyone had to get out of it, out of the madness of this battle with evil.

19. God made me aware of His Spirit at that moment, when I was alone, rejected from Mike Flynn's heart, and yelled at by another "client" as a "deal breaker," simply for caring. God showed me a glimpse of the future at that moment; that I might be left alone, that I might be persecuted, but that I should not fear; and that I should at that time give everyone involved what they wanted, what they thought they needed to be free. So, because of Flynn's promise of the agreement's unenforceability, my desire to end the threat if possible for everyone, Scientology's promise to end fair game, and God's Assurance, I did sign.

20. After the "settlement," God gave me a time of some quiet and joy to write, draw, get strong after years of deteriorating health, to hang out with friends, and to be drawn ever closer to Him. In 1987 He chose me and came to me in the undeniable

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Physical Substance of His Love, and gave me a greater view of my future role in His Plan. In 1988 He brought me to offer my life in exchange for the captives then held in Lebanon. He schooled me in the understanding of His Nature and set me on the path to become by 1989 one of His Teachers. Also in 1989 He gave me an understanding of the valuelessness of money, and a glimpse of His solution for the grinding cruelty of the world's economic system. He brought to me a glory of four-leaf clovers. He showed me that through my life He could bring to the world the mathematical proof of His guidance. He moved me to run like the wind, and to pick up the world's trash, all for His Glory.

21. During the post-settlement years, God also allowed the hearts of Scientology's leaders to grow ever harder and to manifest in attack after attack on my character and credibility. It became clear, and saddened me greatly, that these leaders had not stopped "fair game," but were using the cessation of the litigation by Flynn and his clients as an opportunity to continue their antisocial practices unchecked. They published their own false versions of my history, delivered their "black propaganda" packs on me to the press, which included documents Scientology itself had insisted be sealed in my case and in other cases. They used Gene Ingram in their attacks, disseminating to the press an edited version of his illegal videotape, which had also been sealed in my case. They filed false affidavits attacking me in civil cases and in their litigation with the IRS. Scientology's lawyers threatened through Mike Flynn, that if I responded to the attacks, or even talked to any of the opposing attorneys in a case in which Scientology filed its false affidavits about me, they would consider my talking a breach of the "agreement," and would

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sue me.

22. God allowed my heart to be broken by each attack and the daily knowledge that Scientology had not ceased fair game, yet He kept me from responding with anything other than sadness for almost three years. Then, in the fall of 1989, I was served with a deposition subpoena by the attorney for Bent Corydon in the case of Corydon v. Scientology, Los Angeles Superior Court No. C694401. Following this I received a series of calls from Scientology attorney Lawrence Heller who threatened that, even pursuant to Corydon's subpoena, if I testified about my knowledge of Hubbard and Scientology I would be sued. I was deeply troubled by Heller's threats, the idea of succumbing to those threats, and the injustice and evil the settlement agreements had spawned. God brought me at that time to a determination to do what I could to bring to light and correct that injustice and evil. When I began to research my rights, responsibilities and how to proceed, I learned that through the intervening five years Scientology had been able to maintain an appeal, Scientology v. Armstrong, No. B025920, from the 1984 Breckenridge decision, and my first actions concerned that appeal.

23. Much of my history and legal involvement with Scientology from that point is told in the declarations and other documents appended hereto. Exhibit A is a true and correct copy of a declaration I executed March 15, 1990 and filed in the B025920 appeal and a consolidated appeal, No. B038975, along with true and correct copies of certain exhibits which were appended to the original declaration.

24. Exhibit B hereto is a true and correct copy of a declaration I executed December 25, 1990 and filed in

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Scientology's appeals, along with true and correct copies of certain exhibits which were appended to the original declaration.

25. Exhibit C hereto is a true and correct copy a Court of Appeal published opinion affirming the Breckenridge decision. Scientology v. Armstrong, 283 Cal. Rptr. 917 (Cal. Ap. 2nd Dist. 1991). Exhibit D hereto is a true and correct copy of Scientology's motion to seal record on appeal in Appeal Nos. B025920 and B038975, supporting declaration. Exhibit E hereto is a true and correct copy of my opposition to the motion to seal record on appeal, supporting declaration, and exhibits thereto. Exhibit F hereto is a true and correct copy ofrder of the Court of Appeal dated December 5, 1991 denying the motion to seal record.

26. Exhibit G hereto is a true and correct copy of a declaration I executed March 16, 1992 and filed in the instant case (which then had Marin Superior Court No. 152229), along with true and correct copies of certain exhibits which were appended to the original declaration.

27. Exhibit H hereto is a true and correct copy of a declaration and literary work, entitled "I Declare," I executed January 13, 1994, along with certain exhibits thereto. I wrote "I Declare" for filing in a lawsuit Scientology brought against me in 1993, in which it charged that my giving away my worldly assets and forgiving debts owed me in 1990 were "fraudulent conveyances." The organization asserts that my renunciation was to avoid the claims it raised in another lawsuit it brought in 1992 for liquidated damages stemming from what it alleges are breaches by me in 1991 of its 1986 settlement agreement. My renunciation had nothing to do with Scientology, but was the result of my asking God in prayer for guidance at the time of, and precipitated by,

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the Middle East crisis which built into Desert Storm, and the trouble I felt about the world situation, the general state of mankind, and what God wanted me to do.

28. The answer, which I truly believe is God's, was to give my things away, take only what I needed, and then, under His guidance, to go wherever my help was asked for. That is what I did and how I have tried to live my life ever since. My life has been forever changed from that decision and from following that guidance. I had no idea where I would be led or what I would do, other than to try to discern and do God's Will. I know I have not always discerned correctly, and I know that I still have an old willful nature. I also know that God has drawn me steadily, through joyful times, and through difficult, threatening and tearful times, closer and closer to Him, and that He has given me a new nature which is Christ's.

29. As God would have it, some of the people who were led to me and asked for my help following my 1990 decision to go where He led me were those who had been fair game's victims in the post-global settlement period. In June, 1991, a South African man, Malcolm Nothling, who had been defamed and defrauded by the organization, called for my help. In July, 1991, Joseph Yanny, a former attorney for Scientology, who had become its fair game target and was attempting to assist other Scientology victims, Richard and Vicki Aznaran, asked me to help. In the Aznaran's case, the effect of the settlement agreements on their ability to obtain counsel and on their ability to oppose Scientology's efforts to deny them due process became relevant. In August, 1991, God led me to Ford Greene, one of the few surviving attorneys willing to take cases on behalf of Scientology's

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victims. Ford also asked for my help. All of this history is covered in detail in "I Declare."

30. Seizing on my responses to the requests for help from people God had sent to me, Scientology's leaders have, since 1991, carried out a withering litigation campaign to silence and destroy me through judicial enforcement of the settlement agreement. Throughout the litigation and until recently I was defended by Ford Greene, for whom I, also until recently, worked as his sole office assistant, and who became through the years my good friend. Scientology first brought a motion to enforce in the original case, Scientology v. Armstrong, Los Angeles Superior Court No. C 420153, which was denied. They then filed a lawsuit for breach of contract, Scientology v. Armstrong, Marin Superior Court No. 152229, which was transferred to Los Angeles Superior Court and given number BC 052395. They obtained a partial injunction in that case in May, 1992, which I appealed. The appeal, Scientology v. Armstrong, Cal. Ap. 2nd Dist. No. B 069450, stayed proceedings in BC 052395 from March, 1993 through May, 1994. During the stay Scientology filed two more lawsuits against me, Los Angeles Superior Court No. BC 084642, and Marin Superior Court No. 157680, the "fraudulent conveyance" action for which I wrote "I Declare." Scientology also tried repeatedly to have me found in contempt of court and jailed for alleged violations of the partial injunction, some of which "violations" Scientology's own personnel manufactured. This period was threatening and difficult, but I was buoyed by the hope that some court would see through Scientology's lies and attacks, and a certainty was developing in me that God's Will in His good time would triumph.

31. What I saw and see as an unconscionable unfairness has

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perplexed me throughout this litigation. Scientology claims that by the "agreement" they can say whatever they want about me, and that I cannot respond in any way. Such a concept is un-American and patently unfair. If I had known that this is the meaning of the settlement agreement, and that any court could possibly consider that this is its meaning; that Scientology is free to attack me or anyone else, that it was going to be fair game as usual, but without my being legally able to respond or defend myself or anyone else, I would never, for all the money in the world, have signed that terrible document. The whole set of "settlement agreements," which are commonly known as the "Flynn agreements," are unfair to anyone who litigates either as a defendant or plaintiff against Scientology, since these agreements remove knowledgeable witnesses from the legal arena and drive up litigation costs. The "agreements" are also unfair to the public because they allow Scientology's leaders to rewrite history, lie about judicially credited information, attack the sources of that information without response, and convey the idea that it is futile to speak the truth or oppose their tyranny. These "agreements" obstruct justice. There is also a tragic unfairness worked on all those people trapped inside Scientology and abused by the organization because the agreements abet the denial of accurate information to those Scientologists and convey a sense of hopelessness to any who might begin to break free and might be contemplating seeking redress for that abuse. These unfairnesses have been a major factor in my continuing in the litigation, despite the threat and difficulty, in the hope that some court will adjudge the agreements illegal. If such unfairnesses are ultimately ruled fair, it will be unfair to anyone who looks to

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our justice system for justice; and the justice system will become fair game to those who seek injustice.

32. There is another unfairness crafted by Scientology's lawyers in connection with the attacks on me which is particularly troubling. Throughout the litigation I have written and spoken to Mike Flynn dozens of times asking him to come forward and provide a declaration concerning the circumstances at the time of the settlement, the duress Scientology subjected him to, the duress his other clients were subjected to, the picture of this duress that he conveyed to me, and Scientology's promise to cease fair game. I have asked him dozens of times to confirm in a declaration the representations he made to me about the unenforceability of the liquidated damages penalty, that it was "not worth the paper it's printed on," that my release of Scientology was only to the date of the signing of the agreement, that my responses to its post-settlement attacks were not breaches of the agreement, and that Scientology obtained his willingness to have his clients and himself sign the "agreements" by fraud, as evidenced by the fact that fair game continued as before. Flynn has said throughout this litigation, however, that he signed an agreement like the one he had me sign, and he is afraid that Scientology will sue him, as it has me, and again make his life hell if he helps me. Ford requested Scientology to release Flynn, as a percipient witness, from the "contract" by which they prevent his assisting me, but Scientology has refused. Flynn continues to say that the agreement is evil, and the Scientology organization is evil, but that the courts of this country cannot deal with Scientology. He says that although he is saddened by my plight and wants to help me in my case he cannot and will not. This

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unwillingness by Flynn to come forward and tell the truth, which, if he did, I believe would bring any judge on the case to rule the settlement agreement illegal and end the litigation, has many times through these years greatly disheartened me. Nevertheless, I now see that even this aspect of this spiritual war is in God's Hands and He is using it to His Glory.

33. Since the beginning of 1994 when I wrote "I Declare," Scientology has continued without relent to press its litigation assault on me. On May 16, 1994, the Court of Appeal denied my appeal, ruling that the partial injunction was not an abuse of the Judge's discretion, and declining to address the legality or illegality of the underlying settlement contract. On July 28, 1994, after an evidentiary hearing, Los Angeles Superior Court Judge Diane Wayne dismissed all of the contempt charges against me. In August, 1994, Ford brought a summary adjudication motion on my behalf in the fraudulent conveyance action, based in part on a religious defense, since the idea of conveying my worldly assets was God's answer to my prayer to Him, and the acts which flowed from that idea were, although unrelated to Scientology, religiously motivated. Exhibit I is a true and correct copy of a declaration I executed August 12, 1994 and filed in support of this summary adjudication motion, along with true and correct copies of certain exhibits which were appended to the original declaration. Judge Thomas, in denying my motion ruled that "the religious beliefs of the parties are irrelevant in determining the issues in this action."

34. In the fall of 1994, the three cases Scientology had pending against me were, on the organization's request, consolidated in Marin County and given one number, 157680.

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Scientology brought a motion seeking summary adjudication of three causes of action, two for providing declarations in cases against the organization, and one for talking to the media. Ford filed an opposition to the motion based on the organization's subjecting me to duress through Mike Flynn to get me to sign its settlement agreement, the invalidity of the liquidated damages provision, and on the "absolute" litigant's privilege. On January 27, 1995 Judge Thomas granted summary adjudication as to two of the three causes of action, ruling, among other things and amazingly, that I had "fail[ed] to raise a triable issue as to whether the liquidated damaged provision is invalid," and that I had "not raised a triable issue regarding duress."

35. In early January, for reasons known to us and God, my attorney and friend Ford Greene also lost heart. It had been coming to me through the years that this litigation, although set in a context of secular laws and courts, really concerned deep religious issues. After Ford filed our opposition to Scientology's summary adjudication motion, therefore, I prepared and filed, unfortunately six days late, a declaration and exhibits which addressed the religious issues as I then saw them. A true and correct copy of this declaration and the exhibits thereto are appended hereto as Exhibit J. Judge Thomas struck my declaration for late filing and assessed $700.00 in sanctions against me.

36. On February 23 Ford substituted out of my case.

37. On February 27 I received Scientology's motion for summary adjudication of its twentieth cause of action. Scientology seeks by this motion a permanent injunction, which would be much broader than the preliminary injunction now in place, and which would prohibit me from, inter alia, "discussing

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with anyone, not a member of [my] immediate family or [my] attorney, Scientology, the Church [etc.];" "acquiring ... any ... writings, recordings, documents, or books of any kind, which discuss or concern Scientology, the Church [etc.];" and would require that I "[r]emove all information concerning Scientology, the Church [etc.]... within the possession, custody or control of FACTNet;" and "[r]eturn to the Church any documents [I] now [have]... which discuss or concern Scientology, the Church [etc.], other than documents which have been filed in this litigation."

38. On March 10 I applied for an extension of two weeks to be able to oppose this motion which Judge Thomas granted. On March 17 Scientology served on me another motion for summary adjudication of four causes of action: No. 13, for giving a videotaped interview concerning my Scientology experiences; No. 16, for talking to a Newsweek reporter about Scientology's efforts to get its materials into the public school system; No. 17, for an interview on E! Television; and, No. 19, for providing declarations which discuss my Scientology experiences for filing in the case of Scientology v. Steven Fishman, et al., U.S. District Court for the Central District of California, Case No. 91-6426 HLH (Tx).

39. Because I had been ill, lacked the necessary equipment and funds, lacked real attorney knowledge and skills, and was utterly unable to prepare the oppositions, on March 29 I again applied to Judge Thomas for more time. He gave me one week. On April 7, facing the same situation and problems, I again applied for more time, and also requested an order that Scientology free Mike Flynn from the contract which prevented him from providing me a declaration regarding the circumstances at the time of the

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global settlement, and Judge Thomas denied my application. I was unable to complete my oppositions, even within the time I requested, I am now late, and at the mercy of the Court and Scientology. Nevertheless, I proceed.

40. Appended hereto as Exhibit K through DD are true and correct copies of the following documents:

K. Declaration of Garry L. Scarff, executed February 11, 1993 and filed herein in opposition to
order to show cause re contempt;

L. Scientology publication entitled ""FACTNet" - Perversions, Criminality and Lies;"

M. Scientology publication entitled ""FACTNet" Still Off the Rails;"

N. Letter from Michael Rinder, Church of Scientology International executive and director of plaintiff herein, to Mirror Group Newspapers in London, United Kingdom;

O. Set of Bates-stamped Scientology publications, known as "dead agent documents" concerning Gerald
Armstrong and Judge Paul G. Breckenridge, Jr., produced by Scientology herein, and authenticated by Scientology representative Lynn R. Farny;

P. Declaration of David Miscavige, executed February 8, 1994 and filed in Scientology v. Steven
Fishman, supra;

Q. Article "Catch a Rising Star," by John H. Richardson in Premiere, September, 1993;

R. Letter from Gerald Armstrong to Lawrence Wollersheim dated January 21, 1994 resigning as

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director;

S. Ex parte application to continue hearing on motions for summary adjudication and declaration thereto
executed April 7, 1995, and denied by Judge Gary W. Thomas;

T. Scientology press release from Nancy O'Meara and Andrew H. Wilson regarding January 27, 1995 ruling
by Judge Gary W. Thomas granting summary adjudication;

U. Letter from Church of Scientology International President Heber Jentzsch to E! Television dated August 5, 1993;

V. Letter from Ford Greene to Laurie Bartilson dated February 19, 1992;

W. Letter from Ford Greene to Laurie Bartilson dated February 24, 1992;

X. Letter from Laurie Bartilson to Ford Greene dated March 2, 1992;

Y. Partial transcript of proceedings, December 23, 1991, in Scientology v. Armstrong, Los Angeles
Superior Court No. C 420153;

Z. Excerpts from transcript of deposition of Michael Douglas, taken herein (case no. on face page is
incorrect) August 30 and September 2, 1994;

AA. Excerpts from transcript of deposition of Nancy Rodes, taken herein August 30, 1994, and "mutual
release agreement" executed December 5, 1986;

BB. Declaration of Kenneth D. Long in support of plaintiff's reply in support of motion for summary
adjudication of the fourth, sixth and eleventh causes of

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action of plaintiff's second amended complaint, filed herein January 20 1995;

CC. Revised By-Laws of Church of Scientology International.

41. In its motions, Scientology labels Vaughn and Stacy Young, Hana Whitfield and Lawrence Wollersheim "anti-Scientologists." They are not anti-Scientologists, but are pro-Scientologist. What they are "anti-" is the leaders of Scientology ordering fair game attacks on them, and on anyone. They are opposed to Scientology's leaders' deceiving Scientologists and subjecting Scientologists to coercive and abusive practices to their detriment. Calling the Youngs, Ms. Whitfield and Mr. Wollersheim "anti-Scientologists" is Scientology's leaders' "black propaganda," pursuant to their " fair game" philosophy.

42. Lawrence Wollersheim and I have been friends for over ten years. I know him to be a target of Scientology's fair game for many years, and someone who has been able to successfully stand up to its attacks, and stands up for others, such as myself, who are Scientology's fair game targets. In 1993 he asked me, in large part, I believe, because he also viewed me as both a victim of cult abuse and an advocate for other victims, to be on the board of directors of a cult victims advocacy organization he was forming, which eventually became known as FACTNet, Fight Against Coercive Techniques Network. FACTNet functions as a library and historical preservation archive, collecting, preserving and making available information on groups using dangerous mind control practices. When I agreed to be a director of FACTNet I was not intending to participate in its operations, and have not ever been

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involved in its operations. I suggested that my role in FACTNet could be one of strategy, planning and consultation, but even whatever I did in that role was negligible. In January, 1994, Scientology threatened to sue FACTNet and some related groups and individuals because of their association with me. To remove or reduce this threat I resigned my position on FACTNet's board. I have had no official role or involvement in FACTNet since that time. I have no control of FACTNet, and the order that Scientology seeks in this case that I remove all the materials from FACTNet's library and archive which relate to Scientology is impossible. I am a FACTNet library card holder, like many others around the world. I have donated and sent materials to FACTNet for preservation purposes, as everyone with information on dangerous cults' coercive practices and antisocial activities may do. The bulk of what I sent FACTNet concerned Scientology's private investigator Eugene Ingram, his fair game efforts against me, and his effort in 1985 and 1986 to frame Mike Flynn with the forgery of a $2,000,000 check on an L. Ron Hubbard bank account. Ingram is not named as a beneficiary in the 1986 "settlement agreement." He has participated in Scientology's fair game attacks on me since at least 1984. In 1992 he spread the rumor at the national convention of the Cult Awareness Network ("CAN") that I had AIDs. He has also participated in Scientology's fair game attacks on Wollersheim, and many other people that Scientology's leaders target. Scientology describes the materials I sent to FACTNet as "anti-Scientology." They are not. They tell the truth about some of the Scientology organization's activities and criminal and antisocial practices. As a victim of cult abuse and as a present target of Scientology's fair game attacks, I use

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FACTNet's services and facilities to support my defense in the legal arena and as a safeguard against Scientology's extra-legal attacks and threat. FACTNet has assisted me with research, fund-raising, getting my story told, and spiritual understanding.

43. In support of my opposition to Scientology's motions for summary adjudication several people, all of them my friends - Lawrence Wollersheim, Hana Whitfield, Dennis Erlich, Margery Wakefield, Keith Scott, Malcolm Nothling, Jonathan Atack and Nan McLean - have come forward and provided declarations. They did this at considerable risk to themselves. Ms. Wakefield and Ms. McLean signed Flynn agreements similar to mine in 1986, and Scientology has attacked them in court proceedings since then based on claimed violations of those agreements. Scientology has pending an effort to have Ms. Wakefield found in contempt of court and jailed for up to 22 years for daring to speak the truth about her experiences and knowledge. Scientology's recent fair game efforts to destroy the reputations of Ms. Whitfield, Mr. Wollersheim and Mr. Atack are shocking. Each one of these people has knowledge of fair game, and each continues to be its target to this day. My former attorney Ford Greene continues to be a fair game target. It is for all of these people and the thousands of others of good heart like them around the world who have become targets of Scientology's fair game doctrine that I speak, write and fight. One day that ungodly threat will be removed.

44. Around March 12 and continuing for about two weeks I experienced what I believe was both my spiritual death and my rebirth, brought on me by God. He showed me the nature of the evil that I had been chosen to oppose, and He showed me the spiritual battle with that evil. At times an oppressive evil came

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to overwhelm me. I lost strength and acuity. For stretches of hours my heart ached and I prayed, as Jesus prayed, that if it were possible this cup be taken from me; nevertheless that God's Will be done. At times God came to me, spoke to me, and held me in His Strength and Love. He showed me that persecution must be endured for His Cause, and assured me that He would never leave me. He showed me that in this civilized country we carry out our crucifixions in courtrooms. He showed me the souls I fought for, and why He chose me to fight through all those years. My strength has not returned to normal, and I am forever altered. God brought me to surrender my battle to Him that His Will be done, for unless He does it I haven't got a prayer. I will run whatever race He calls me to run as fast and as far as He moves me. Sometimes He will appear to lose the race on earth to win it in Heaven.

45. Scientology is anti-Christian. To the uninitiated, it professes to be compatible with Christianity. It states in its "catechism," published in 1992 in its promotional book What is Scientology?,

"Scientologists hold the Bible as a holy work and have no argument with the Christian belief that Jesus
Christ was the Savior of Mankind and the Son of God...¶There are probably many types of redemption. That of Christ was to heaven."

In Scientology's actual teachings, however, in the policies and procedures which indoctrinated Scientologists must follow, Jesus Christ, Heaven, and Almighty God, are false ideas "implanted" in man by electronic gadgets to achieve, not man's redemption, but his enslavement. Scientology teaches, moreover, that its procedures, developed by L. Ron Hubbard, are the only way to free

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man from that "Christian" slavery.

46. The main target of Scientology's promotion and marketing are Christians, and by far the largest percentage of Scientology's members come from Christian backgrounds. Using Scientology's own figures from What is Scientology? this amounts to fifty-three percent of its members. The second largest percentage comes from Judaism, which worships the same God, Jehovah, as Christianity, the same God, Hubbard teaches is an "implant." But Scientology not only teaches that the God of Christianity and Judaism is an implant; Scientology enforces the acceptance of that teaching with its system of "ethics" punishments, its "auditing procedures, " and its institutionalized mockery of God and Christ. Anyone in Scientology who professed a belief in Christ, or God, or who sought help through prayer, was viewed and handled as a "psychotic." Such a person was segregated, given special auditing to break his belief, and, if the "aberration" persisted, he would be "off-loaded." I learned very quickly inside Scientology to disavow any belief in God, to not mention Him, to not look to Him for wisdom or help, and to view Christians as "aberrated" and "dramatizing the Christ implant." I learned very quickly that inside Scientology even thinking of Christ or God as real was labelled as an "other practice," a punishable "ethics offense" or "overt," which would become the subject of a "security check" on Scientology's "E-meter," its lie detector.

47. In this recent period of spiritual battle God brought to me a teaching by Jesus, recorded at Matthew 12:31,32 and Mark 3:28,29, which I see as the key to why He chose me for His Cause. Jesus states in Mark:

"28 Verily I say unto you. All sins shall be

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forgiven unto the sons of men, and blasphemies wherewith soever they shall blaspheme:

29 But he that shall blaspheme against the Holy Ghost hath never forgiveness, but is in danger of

eternal damnation."

When in his "theology" Hubbard asserts that Christ and God are "implants," he blasphemes the Holy Spirit, the one unforgivable sin. People drawn into Scientology and brought to adopt this blasphemy are in grave spiritual danger.

48. In this latter period, it also became clear to me that my experiences in Scientology, which I now see as religious, indeed sacred, because they were created and motivated by God for His Glory, are also religious by Scientology's own pronouncements. In either case, under our Constitution, Scientology cannot use the courts to silence me about those religious experiences. What Scientology is seeking to have the courts order in its pending motions for summary adjudication is in violation of and barred by both the Establishment and Free Exercise Clauses of the First Amendment. Scientology claims to be a religion, and organized exclusively for religious purposes. Scientology claims that all of its policies, directives and writings of all kinds on the subject, its organization and practices are "religious scriptures." Scientology claims that its Sea Organization, members of which sign a billion year contract, is a "religious order." I was in the Sea Org from 1971 through 1981, the period of almost all of my significant experiences about which Scientology seeks to silence me.

49. What if I had been, instead of a Scientologist, a member of a Christian church; had been declared by the "church" leaders

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"fair game;" had been the target a public campaign by the church to assassinate my reputation; had been assaulted by private investigators hired by the "church's" board of directors; had been the target of an attempt to involve me in a highway "accident;" had been spied on and harassed for weeks on end by these private investigators; had had the contents and substance of my "confessions" or pastoral counseling divulged publicly and used against me; had been sued by the "church;" had been subjected to false criminal charges and attempts to have me jailed; had been entrapped by "church" officials; and had been secretly and illegally videotaped by "church" agents; and so forth? All of the acts listed in the preceding sentence were carried out by Scientology against me and formed the basis of my cross-complaint. What if I had cross-complained against the "Christian church" and its "leaders" for the emotional distress resulting from these torts and abuses? Is it conceivable that, as a condition of settlement of the lawsuit against the Christian church, it or its leaders could demand silence about my religious experiences, about Christ, Christianity, God, and Christianity's Scriptures, the Holy Bible? Is it conceivable that a court could compel me to pay $50,000 each time I thereafter said anything about my religion, my religious experiences, Christ, Christianity, the Bible or God? Is it conceivable that a court in this country could order me jailed if I communicated about these Things? Is it conceivable that I could not even discuss with other Christians their experiences of Christianity; and is it conceivable that I could be compelled to pay $50,000 and jailed for each time I discussed the experiences of other Christians with them? Is it conceivable that in the face of continuing attacks by the Christian "church" leaders after the

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"settlement" I must still remain silent about my "religion" and his "religious experiences?"

50. No Christian church would consider imposing such conditions in a "settlement." No court would consider enforcing such conditions against a Christian. Why then do courts enforce such conditions at the insistence of Scientology against people it has abused? The answer is that our courts are often deceived, confused and blinded by evil, and as a result give evil favorable, special treatment; and to the detriment of goodness and justice. Only an organization or individual of such an evil and malevolent nature that they cry out to be brought to the light of truth would consider using our justice system to keep that nature hidden.

51. As Christ taught, and as a child of God, my practice is forgiveness. As all that I have done has by Christ been forgiven, I have forgiven everything anyone has ever done to me, every act or thought of persecution. What I cannot forgive, however, for I have not the power to forgive it, is Hubbard's, Scientology's leaders' Scientologist's and anyone else's blasphemy of God's Holy Spirit.

52. I believe, moreover, that Scientologists will not recognize their need for forgiveness as long as they blaspheme the Holy Spirit, and they will persecute me as long as they commit and promote this blasphemy; so I ask them to stop. I ask as well that they not persecute the little ones, those who are the least among us, those whom Scientology's leaders call "suppressive persons," "PTSes" or "degraded beings," for in that persecution they persecute Christ Himself. I know that God for His Purposes chose me to be persecuted; and to care and hurt when the little ones are persecuted. I care, then, what Scientology does to me, for it is

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doing it and will do it to anyone else. It is to all of these, and to all those in Scientology, that God has sent me. I believe that we are in the end times, and that God has sent His messengers, teachers and prophets onto His Elect, wherever they are, in whatever country, city, prison, church or cult, to gather them onto Himself. As stated by the Apostle at I. John 2:22: "Who is a liar but he that denieth that Jesus is Christ? He is antichrist, that denieth the Father and the Son."

In the end times it is expected that antichrist would use man's laws and courts to enforce his evil contracts by which he would bind, torment and destroy God's sons. God chose me to be persecuted by Scientology's leaders, using their organization's tax-exempt millions, and in violation of the nation's Constitution, as Apostles of old were persecuted, and all God's Disciples have been persecuted throughout history. This need not be, for persecution can end in no time and without downside. Nevertheless, God allows and uses the persecution of His Children, His Messengers, Teachers and Prophets to prove His great Mercy and Love and the power of His marvelous plan of salvation, both for the persecutors and those persecuted. God knows which souls He will reach through my words, story and persecution. They may be few; nevertheless, He desires that all should be saved.

53. All that I have done in all my life is for this moment in God's Plan. I ask for mercy if that be God's Will.

/

/

/

/

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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 September 15, 1995

[signed] G. Armstrong

GERALD ARMSTRONG

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