Declaration of Lawrence Wollersheim In Opposition To Motions For Summary Adjudication Of 20th Cause Of Action; And 13th, 16th, 17th & 19th Causes Of Action Of Second Amended Complaint

Armstrong 4

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[CT 8052]

Gerald Armstrong
715 Sir Francis Drake Boulevard
San Anselmo, CA 94960
(415) 456-8450
In Pro pria Persona



religious corporation,



GERALD ARMSTRONG; MICHAEL WALTON; THE GERALD ARMSTRONG CORPORATION a California for-profit corporation; DOES 1 through 100, inclusive,



CASE NO. 157 680


Date: 4/21/95
Time: 9:00 a.m.
Dept: One
Trial: 5/18/95

[CT 8053]



I, Lawrence Wollersheim, declare:

1. I am over the age of 18 years. I am a resident of the State of Colorado. I have personal knowledge of the matters set forth herein, and if called upon as a witness I could testify competently thereto.

2. I was an active member of Scientology from the period of 1968 - 1969 through 1979 - 1980.

3. I am the plaintiff in the case of Wollersheim v.Church of Scientology of California, Los Angeles Superior Court No. C 332027. After a four and one half month trial in 1986 I was awarded a judgment against Scientology in the amount of $30,000,000.00. On appeal, the California Court of Appeal upheld the judgment but reduced the damages awarded to $2,500,000.00. Wollersheim v. Scientology, 260 Ca1.Rptr. 331 (1989), upheld by the United States Supreme Court.

4. I have also been sued twice by Scientology pursuant to its "fair game" policy, Scientology v. Wollersheim, US District Court for the Central District of California, No. CV 85-7197 JMI (Bx), which was dismissed against me, and Scientology v. Wollersheim, Los Angeles Superior Court No. BC 074815. I was awarded $135,000.00 in this frivolous lawsuit pursuant to California's SLAPP Statute.

5. Since 1979, I have been the target of the notorious "fair game" policy, originated by Scientology's founder and leader L. Ron Hubbard. This policy calls for critics of


[CT 8054]

Scientology, designated by the organization as "enemies" to be tricked, cheated, sued and destroyed. This policy permits, in fact urges, Scientologists to do virtually anything in the service of Scientology to attack its targeted enemy.

6. In 1993 I, with others, formed a non-profit corporation, FACTNet, Inc., a cult abuse victims advocacy organization that serves as a library and historical preservation archive which collects, preserves and makes available information on groups and organizations which employ sophisticated and dangerous techniques of mind control. For more information on FACTNet, its goals and purposes, see one of FACTNet's publication regarding its mission, history and accomplishments appended hereto as Exhibit [A]. Because of my experiences and knowledge of Scientology, because I have continued to be its fair game target, and because it is widely known as the largest and most psychologically dangerous of all the organizations using advanced psychological coercion practices, FACTNet has a large archive of information on Scientology which it has collected, preserved and made available to our library users.

7. In 1993 I asked Gerry Armstrong to be on the board of directors of FACTNet. I did this because he is known to me to be an abuse victims advocate, and honest and courageous, having stood up against Scientology's fair game practices and its formidable litigation machine for then over a decade, and I trusted him. Armstrong was never involved in the management


[CT 8055]

or operations of FACTNet in any significant way or for any significant length of time. Later, because of the concern that Scientology would mischaracterize Armstrong's relationship with FACTNet, and use its mischaracterization in legal attacks, he resigned his position on our board of directors.

8. I also asked Armstrong to be involved with FACTNet because he is a victim of Scientology's cult abuse and was, and is, defending a case brought against him by Scientology to silence him. I knew from having talked to Armstrong about his pending case, and from reading many documents relating to that case, and from my knowledge of Armstrong's prior history and legal involvement with Scientology, that Scientology was seeking to use the courts to silence him and deny him his Constitutional rights, including his freedom of religion and right and need to defend himself against fair game. I also knew, from my own experience, study and communications with dozens of people affected, that the "settlement agreement" which Scientology was seeking to enforce was one of several such "agreements," which, in my opinion, individually and together constituted a massive obstruction of justice. Armstrong, therefore, like any other Scientology victim, had a need for FACTNet to help him defend himself against that organization, and its litigation and fair game machines. FACTNet has assisted Armstrong, because he is a victim of Scientology's abuse. We have assisted him with fund raising,


[CT 8056]

obtaining legal help, spiritual support, and in telling the world the story of the abuse of Gerry Armstrong.

9. Appended hereto as Exhibit [B] is a true and correct copy of one of FACTNet's research publications entitled "Scientology's Policies Toward Its Adversaries." This document details Scientology's history of unclean hands and general bad faith in bringing actions such as this one. Scientology has been involved in criminal acts against its adversaries, and has used the court systems around the world to support these criminal activities, for decades. If these materials are fully read by the Judge and other decision-makers in the current action, there will be no doubt about why Scientology is trying to silence and crush Armstrong. Their efforts to silence and crush him are to suppress critical knowledge and counter-opinions about Scientology's nature and activities, activities which threaten the public well-being and safety.

10. The information that Armstrong brought with him out of Scientology, that was made public for the first time through his efforts, and became judicially credited during the course of the first lawsuit Scientology brought against him, has been essential to the understanding of Scientology's mind control, fraud, and fair game activities. Armstrong documented and exposed the real nature and history of L. Ron Hubbard, his falsified credentials, vindictiveness and aggressiveness toward anyone who opposed him, and his and his


[CT 8057]

organization's victimization of countless people around the world. Armstrong's material is used by government investigations and by countless people around the world to educate and counsel about Scientology and its actual intentions, practices and dangers. Scientology wants to silence and discredit Armstrong because his materials free victims by giving them access to what they need to make informed choices, and Scientology doesn't want its victims free, but under its domination or shuddered into silence. It is imperative, for free minds and a free society that Scientology not be allowed to achieve its goal of suppression of Armstrong's information.

11. I know that Scientology calls itself a religion, claims that it is organized for only religious purposes, claims that its activities are religious, and that all of its writings on any subject with Scientology; whether they be about financial matters, physical health or how to wash a car; whether they order using the courts to harass people, to utterly ruin critics, and even the "fair game" policy itself, are "religious scriptures."

12. It has come to my attention that Scientology is seeking to have the court in the Armstrong case order the removal or seizure of all materials in FACTNet's possession which relate in any way to Scientology. The order Scientology seeks reads: "within 20 days of the issuance of this Order, Armstrong shall: 1. Remove all information concerning


[CT 8058]

Scientology, the Church and/or any person or entity referred to in paragraph 1 of the "Mutual Release of All Claims and Settlement Agreement" of December, 1986 from any and all databases, electronic or otherwise, within the possession, custody or control of FACTNet." This proposed order that Scientology is trying to push through court against Armstrong is an effort to deceive the judge on the case so that Scientology can later use this overbroad order to harass, raid and destroy a public library and historical preservation archive. FACTNet's library and archive possess thousands upon thousands of documents relating to Scientology and/or Armstrong that have been or are legally in the public domain and/or received from many other sources than Gerald Armstrong. FACTNet possesses many of Scientology's own writings that have been or are legally in the public domain. A court-ordered removal or seizure of these materials, which Scientology itself always claims are "religious scriptures" would be tantamount to seizing Holy Bibles or commentaries on the Bible, in the possession of out-of-favor former members of a Christian church.

13. My 26 years of experience and my study of hundreds of thousands of pages of evidence have brought me to the unshakable conclusion that Scientology is the world's largest secret neo-satanic "religion," with thousands of fanatical members in hundreds of highly organized, centrally controlled "churches" worldwide, using sophisticated mind control and


[CT 8059]

intelligence operations arid-employing hundreds of non-Scientology lawyers and "private investigators" to carry out its goal of smashing all opposition to its mad and dangerous plan for world domination. See "Scientology's Policies Toward Its Adversaries," Exhibit [B] hereto.

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

Executed at 601 16th St, Jefferson County, Colorado, this 7th day of April, 1995.

Lawrence Wollersheim


These links are revised versions of the referenced exhibits:

Exhibit [A]
FACTNet's Mission

Exhibit [B]
Scientology's Policies Toward Its Adversaries