[CT 7779]

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

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

[CT 7780]

DECLARATION OF HANA ELTRINGHAM WHITFIELD

I, Hana Eltringham Whitfield, declare:

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

2. I was an active member of the Church of Scientology International, hereinafter "CSI," and its predecessor, the Church of Scientology of California, hereinafter "CSC," from March, 1965 to August, 1984.

3. Appended hereto as Exhibit [A] is a true and correct copy of my declaration executed April 4, 1994 and filed in the case of Church of Scientology International v. Steven Fishman and Uwe Geertz , Case No. CV 91 6426 HLH. This declaration provides accurate information as to my history in Scientology, the positions I held and my responsibilities, the lengthy training I received in the auditing techniques of Scientology founder and leader L. Ron Hubbard, hereinafter "Hubbard," and in his organization and executive management techniques, and some of the extensive knowledge I have of Scientology's policies, bulletins and procedures. It also contains a description of the extreme hardships I experienced while a Scientologist and the insidious "fair game" practices to which my husband, Jerry Whitfield, and I were subjected after we left Scientology and dared to discuss our experiences and opinions. We continue to be targets of fair game to this day.

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[CT 7781]

4. My husband and I now work professionally with families who have a loved one in Scientology. Families hire us to inform and educate their loved ones about the secret and hidden, and the actual, policies and practices of Scientology and their dangers, and of Scientology's ongoing, complex campaign to keep these secrets hidden from the public and from most of its members until they have been completely indoctrinated and are under Scientology's absolute control. Having the information we provide, the loved ones are then more able to make informed choices about their adherence to Scientology and participation in its activities. My husband and I also work with Scientologists who have doubts about their involvement in Scientology and approach us on their own for information. We have been doing this work of informing and educating successfully since 1985.

5. Because of my long tenure in Scientology and holding many executive positions, I have personal knowledge of the fact that people are drawn into Scientology by false representations and then held in it by various manipulative techniques, often to their physical, emotional and mental detriment.

6. As an example, I was drawn into Scientology in early 1965, in Johannesburg, South Africa, through reading Hubbard's book, "Dianetics the Modern Science of Mental Health," by its astonishing claims, some of which were: A. Those who reach "clear," a state guaranteed by

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[CT 7782]

Hubbard, can be tested for any and all psychoses, neuroses, repressions and compulsions (all aberrations) and can be examined for any autogenetic (self-generated) diseases, also known as psychosomatic ills, and the tests will show the "clear" entirely free of such.

B. Tests of the clear's intelligence will show it to be high above the norm.

C. A clear can remember everything that has ever happened to him and everything he has studied.

D. A clear's health is greatly improved and he will never again experience any psychosomatic illness of any kind. A clear never gets colds.

E. A clear's ethical, moral and professional standards are the highest.

F. A clear thinks and acts completely rationally in any circumstances at any time.

7. After reading "Dianetics" I was convinced that Hubbard had discovered the cure for all mental and physical ills, that attaining clear was the most desired aim in the world and should be sought by the whole human race. So strong were my beliefs, started by my reading of "Dianetics," that I held them unwaveringly for twenty years, despite experiences that, were I in a normal frame of mind, would have caused me to leave the group many years earlier, and despite continually seeing behavior and mental and physical conditions in "clears" and in Hubbard himself, which belied his Dianetics promises.

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[CT 7783]

8. The book, "Dianetics the Modern Science of Mental Health," which is used extensively in the Scientology organization in its initial "auditing" programs and " auditor" training, was considered so important by Hubbard and Scientology's senior management executives, that its public bookstore sales records were manipulated and falsified for years by Scientologists in order to keep it on the U.S. "best seller" lists. "Auditing" is Scientology's psychotherapeutic processing, which it calls, for "religious" purposes, "pastoral counseling."

9. While becoming involved in the Johannesburg Scientology Organization I also heard many stories about Hubbard and read Scientology's biographies about him. These included the stories that he was a much decorated hero of World War II, that he received extensive war wounds including blindness and lameness, yet recovered fully through his own research and techniques, which he had further developed into Dianetics and included in his book. I was deeply impressed with what I heard and read about him.

10. I know hundreds if not thousands of Scientologists across the years who were drawn into Scientology by the same claims as I was.

11. Once in contact with Scientologists, neophytes (what Scientologists cynically call "raw meat") are manipulated and indoctrinated rapidly and more deeply into an array of false and delusionary convictions about Scientology. From personal

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[CT 7784]

experience some of these are:

A. That only Hubbard's procedures in Scientology can break one free of the repetitive, never-ending birth-death pattern, also known as reincarnation, a core belief of Scientology. It is often stated that "Scientology is the only road to total freedom."

B. That only Scientologists have the answers to the Universe and Life itself.

C. That only by strict and unconditional adherence to Scientology's policies and practices, can one regain one's complete abilities and eternal survival as a spiritual being.

D. That the whole human race except for Scientologists is doomed to eternal oblivion.

E. That a Scientologist will only progress in life and reach his spiritual and physical goals by living and associating with other Scientologists, to the point of severing connections to family and/or spouse and children and/or friends if they are disinclined to become Scientologists, are slow in showing interest, or express criticisms or diverging perspectives to those of Scientology.

F. That a Scientologist living on his own in a non-Scientology or "wog" community will be unable to maintain the improvements he achieved in Scientology, but will uncontrollably deteriorate into, the same eternal

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[CT 7785]

oblivion destined for "wogs."

G. That people who frequently display emotions of antagonism, anger, fear, sorrow, apathy or even chronic pain, are deemed by Hubbard to be chronically "down tone" or low in emotional tone. Hubbard wrote that such people cannot be reasoned with, that they do not deserve any civil rights of any kind and that one of two ways to deal with them is to dispose of them quietly and without sorrow. From this contemptuous and antisocial attitude the fair game doctrine became acceptable to Scientologists.

H. That all Hubbard's writings, taped lectures, policies, bulletins and techniques are "sacred scriptures" which cannot be changed or canceled except by Hubbard himself - even though he died in 1986.

I. That all Hubbard's writings, taped lectures, policies, bulletins and techniques - the sacred scriptures - are correct as written and any disagreement with them or difficulty with them by anyone reading or studying them is the reader's or student's fault, not Hubbard's.

J. That any criticism of Hubbard, his family, writings, techniques, policies or philosophy is tantamount to a criminal act and shows that the person has undisclosed crimes against Hubbard or Scientology.

K. That if a person's information can be controlled the

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[CT 7786]

person can be controlled. Hubbard was a master of control of information within Scientology's ranks.

L. That criminal or socially deviant actions which were carried out by Scientology and later exposed, were "against policy" and done by misguided "individuals" who went astray.

12. The most glaring example of how Scientology deals with its exposed criminality is the following. In 1966 Hubbard formed within Scientology and organization called the Guardian's Office, hereinafter "GO." Its publicly stated purpose was to "safeguard Scientology." Its hidden agenda, based on Hubbard's policies or "scriptures," was to attack, sue, intimidate, harass and threaten into silence anyone who spoke and wrote negatively about Hubbard and his group. The vast majority of Scientologists knew nothing of the acts, including serious crimes, against people, or Hubbard's secret policies which brought them into being. They believed the GO was constructively extending Scientology's influence into society through social programs such as education, drug addiction, conducting charity drives, and other public relations " good works." When eleven top Scientology executives, including Hubbard's wife Mary Sue Hubbard, were convicted and imprisoned in the late 1970s Scientologists the world over, including my husband and me, were told that the trial was unjust in the extreme as all Mary Sue and her GO staff had done was steal xerox paper. We never were told that

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[CT 7787]

the eleven GO staff were imprisoned for obstruction of justice, breaking into Justice Department offices, wire tapping, and impersonating federal officials, among other things. We were also never told about the GO's covert intelligence operations and terror tactics against targeted individuals, how the GO set them up in "crimes,"and had them falsely prosecuted, which surfaced through the 1977 FBI raid on GO headquarters in Los Angeles and Washington, D.C. Scientology staff were forbidden to read newspapers and magazines or to watch TV in the late 1970s and early 1980s at Scientology's central base in Clearwater, Florida, and we were forbidden to speak to journalists; all of which prohibitions kept us uninformed of true events. Then in the early 1980s, due to its tarnished public image, the GO was renamed the "Office of Special Affairs," hereinafter "OSA," and was allegedly " reorganized." Scientologists over the world were told that those responsible for the crimes had been removed and that "we don't do that anymore."

13. The experiences of many former Scientologists during the post-GO, OSA era, however, including those of Gerald Armstrong, hereinafter "Armstrong," and my husband and me, as well as lawyers litigating against Scientology and other viewed " enemies," show that the practices of harassment, intimidation, threats, law suits and more continue unabated. In essence, the practice of fair game goes on as before.

14. In our work, my husband and I use a great deal of

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[CT 7788]

information made public by Armstrong. This includes his declarations in various lawsuits as well as his own lawsuit, Church of Scientology of California v. Gerald Armstrong, Mary Sue Hubbard Intervenor, Los Angeles Superior Court No. C 420153, which resulted in 1984 in the widely known and used " Breckenridge decision." This decision, in Armstrong's favor, condemned fair game and other Scientology practices including the misuse of Scientologists' confessions in supposedly confidential auditing sessions. The Armstrong case also brought to light Armstrong's discoveries of many lies Hubbard told about his past and his credentials, which were used in Scientology's promotion and marketing of its services, as well as fair game actions against perceived enemies.

15. The information about Scientology's secret agenda, fair game practices and Hubbard's misrepresentations which was revealed through the Armstrong trial and case provided many Scientologists access to the truth about Scientology for the first time, and enabled many to break free from Hubbard's and Scientology's manipulation and hold.

16. My husband and I have ourselves been targets of extensive fair game operations and "black propaganda," since 1985. Black propaganda is a term Hubbard used to designate a practice of destroying someone's reputation with lies, often from hidden or unnamed sources. Those operations that my husband and I know of are detailed in my declaration, Exhibit A, at paragraphs 69 to 93 and 128 to 135. In summary, we have

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[CT 7789]

been subjected to:

A. Surveillance by Scientology hired private investigators, hereinafter "PI's," and Scientology staff 24 hours a day for weeks at a time in the United States and Europe.

B. Surveillance by Scientology PIs and staff while talking with families and their loved one.

C. Repeated false accusations on TV, radio and in writing, that we were kidnappers and do forced deprogrammings.

D. Repeated attempts to obtain our long distance phone records.

E. Invasion of our AMEX credit card accounts by impersonating my husband.

F. Harassment of our families in America, Europe and South Africa by Scientology PI's, some of whom represented themselves as federal government officials.

G. Filing false complaints against us with various State authorities. None of these came to anything.

H. Attempting to implicate my husband falsely in a bomb threat against a Scientology front group, Sterling Management Systems, in 1989. (In the late 1970s Scientology was found responsible for the harassment of New York freelance writer Paulette Cooper, including the manufacture of false bomb threats by Cooper.)

I. Harassment of at least fifty of our friends and

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[CT 7790]

associates by Scientology PI's in America, Canada, Europe and Australia.

J. Creation of "dead agent" packs of information designed to destroy my husband's and my reputations. Innumerable copies of these, each different from the last, have been mailed to friends and colleagues, and even persons we did not know, and handed out at conventions, conferences and meetings of former Scientologists and/or former cult members. Dead agent packs on myself include three different, and false, charges that I killed my father thirty years ago, that I masterminded his murder by another, and that I attempted the murder myself. The packs contain photographs of a severely battered, bruised and unrecognizable dead man's face. They contain my younger sister's 1946 affidavit which detailed incest she experienced while growing up. They contain memos written in the early 1990s by my former husband Guy Eltringham, an active Scientologist, to OSA, giving them information about me under the headings, " Possible means to reduce her influence or effect," and "Other information which possibly would not be in her ethics or pc ("preclear," auditing, or "pastoral counseling") files."

K. David Miscavige, head of Scientology world wide, falsely told over 700 top Sea Organization staff in the early 1990s that I killed my father and was serving time

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[CT 7791]

in a South African prison. (The Sea Org is the top echelon of Scientology management and operations wherein the members sign a contract for a billion years.)

L. False accusations by Scientology attorneys that my husband and I were guilty of theft of Scientology documents.

M. A malicious and completely unsubstantiated lawsuit filed against my husband and me for "false imprisonment." The plaintiff, a Scientologist, who was following us, was stopped and briefly detained by police for suspicious behavior and apparently driving an unlicensed vehicle. Thereafter he filed the lawsuit against us. He dismissed the suit in 1993.

N. Scientologists have repeatedly demonstrating outside our home, carrying signs and handing out leaflets stating that we are kidnappers, that I am a murderer, and my husband a thief, drug dealer and wife beater.

17. While in Scientology and going through extensive training in Hubbard's auditing techniques, I was gradually exposed to and became familiar with Hubbard's writings and his attitudes concerning God, Jesus Christ and Christianity.

18. In 1965, after I arrived at Hubbard's then worldwide Scientology Headquarters at Saint Hill in East Grinstead, England, I was a full time student. Toward the end of 1965 or early 1966, because of a wave of anti-Scientology sentiment in the press, Hubbard gave orders that all Saint Hill "auditors"

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[CT 7782]

were to wear clerical garb and a "Scientology cross," and that from then on "Sunday Services" were to be held in the "Chapel." In fact the "Chapel" was routinely and usually used as a course room. It was the course room in which I studied 10 or more hours daily, and sometimes seven days a week. I was confused when I first heard Hubbard's orders; I had not previously known his public statement that Scientology was a religion. Hubbard further told the Saint Hill staff and students, myself included, that his orders were to create the impression among the government, press and public that Scientology was a proper religion. But it was common knowledge among dedicated Scientologists that Hubbard's orders were designed to deceive non-Scientologists in order to gain acceptance for Scientology.

19. In 1966, while studying the upper levels of the "Saint Hill Special Briefing Course," which covered all of Hubbard's " technical" developments from 1950 to 1966, I studied a bulletin entitled "Routine 3 Heaven," dated May 11, 1963, a true and correct copy of which is appended hereto as Exhibit [B]. In it, to my increasing astonishment and concern, Hubbard wrote that he did not believe in Christianity, God, Heaven and Christ. He wrote, moreover, that he had just discovered that Heaven did exist as an electronic implant, that it was created by an false belief by an "implant station" 43 trillion years ago, that the implant contained "angels,""plaster saints," signs to "Hell," the "pearly gates,"

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[CT 7793]

"Joseph, " the "Madonna and child," "Bethlehem," and various other Biblical symbols. Hubbard wrote that the implant, Heaven, was false and full of lies, and that religion was based on lies. He wrote that the "Creator of Heaven" had entrapped us all and that only Scientology had the way to free us again.

20. Having been brought up in a basically Christian family, and having attended church regularly while growing up, and personally believing in Christ and God, I was shocked to read this and other related bulletins with similar anti-Christian and anti-religion assertions.

21. However, because of Hubbard's claims in the bulletin that the information was discovered through thousands of hours of " scientific research" and not based on opinion, that all Scientology data came from "long, arduous and painstaking research" and is "common to all minds and all men and can be demonstrated on anyone," and that he and Scientology sought "freedom, the betterment of Man," that he had researched and compiled it for "the greatest good for the greatest number," and, importantly, that honest people could accept it, and because of my faith in Hubbard, I consciously chose, without further independent investigation, to accept it as correct over the religious faith of my upbringing. All Scientologists who get past this point do the same.

22. From then on I felt I was one of the initiated, one of the chosen and that I was really on the "Road to Total

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[CT 7794]

Freedom." The "special" nature of Scientology and its unique role in the salvation of mankind was deeply re-emphasized in my mind. From then on I was fully aware of Hubbard's duplicity in molding Scientology's double agenda. Externally Scientology showed itself as religious and sensitive to deep social and humanitarian issues and actively participating in social activities of all kinds. Internally it condemned all religious believers as aberrated and worthless, and, depending on their degree of opposition to Scientology, labelled them merely a nuisance, or suppressive and "fair game."

23. From that point on I regularly read Hubbard's writings or listened to his tape lectures which stated his and Scientology's anti-religious beliefs and practices. In late 1968 or early 1969, on board Hubbard's flagship, the "Royal Scotman," I read a bulletin by Hubbard entitled "Resistive Cases Former Therapy," dated September 23, 1968, a copy of which is appended hereto as Exhibit [C], which expanded on his "scientific research" assertion that God and Christ are electronically implanted ideas. He wrote that Christ was part of an implant 75 million years ago, that the Niocene Creed invented Him to "implant their way to power," and that the Christian Church still uses implanting.

24. Miscavige, Scientology's current leader, recently mandated that eligibility for OT 9 and OT 10, the "top" levels on Scientology's auditing pyramid not yet "released" for public consumption, includes completing the "Saint Hill

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[CT 7795]

Special Briefing Course." From personal experience I can verify that the more a Scientologist is exposed to and indoctrinated in Hubbard's fantastic beliefs and ideas, the more ardent, aggressive and criminally inclined the Scientologist becomes, and more like Hubbard.

25. Throughout the years I practiced and applied Hubbard's auditing techniques, in the 1960s, 70s and 80s, I can verify that those Scientologists who held onto religious and spiritual beliefs and values not espoused by Scientology, despite being gradually exposed to teachings such as those in Exhibits B and C hereto, were considered particularly "aberrated." In the early stages of their adherence to Scientology, such persons were quietly tolerated and smugly labeled as " former therapy cases." (Ex. C) Then at some point, and at the direction of their "case supervisor," they were ordered into specific auditing actions designed to systematically desensitize their particular religious beliefs and ideas. They were also frequently ordered to obtain "case cracking auditing" to resolve their "religious aberrations" and to simultaneously study Scientology teachings.

26. This was done not only with Christian-thinking people. During the years of 1968 through the early 1970s when we sailed the northern African and Moroccan coastlines with Hubbard, I heard him say several times that any Arab or Moroccan who wanted to join the ship's crew could do so as long as he or she passed basic security requirements, and

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[CT 7796]

could remain on board indefinitely only if he or she fully converted to Scientology and had received full auditing resolution of his or her former beliefs and practices. Hubbard said that only such full conversion would raise them above suspicion and enable them to stay.

27. I feel very strongly that it is in the public's interest to continue to have complete access to information that Armstrong helped make public, and in which he is an authoritative source. Public individuals and Scientologists have a right to all the information available about Scientology, both good and bad.

28. It is unconscionable that Scientology thinks that it can say whatever it wants about Armstrong's information and knowledge, about his legal cases, and about Armstrong himself , and that Armstrong cannot even respond, much less have the same freedom to say what he knows to be true about himself and Scientology. It is unconscionable that Armstrong's former attorney Michael Flynn, in order to get himself out from under the threat of fair game, permitted such an agreement to be presented to Armstrong and his other clients to "settle" their cases. It is also unconscionable that any court in this or any country could consider, much less order, the enforcement of such an " agreement." There are very few who stand up to the evil that Scientology practices. These should be supported by our justice system, not silenced.

I declare under the penalty of perjury under the laws of

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[CT 7797]

the California that the foregoing is true and correct.

Executed in Los Angeles. California this 6th day of April, 1995.

[signed Hana Whitfield]
Hana Eltringham Whitfield

Exhibit [A]
Revised Declaration of Hana Whitfield re Motion for Costs 03-08-1994

Exhibit [B]
HCOB May 11, AD 13 [1963] ROUTINE 3 HEAVEN © 1963 L. Ron Hubbard

Exhibit [C]
HCOB 23 September 1968 RESISTIVE CASES FORMER THERAPY © 1968 L. Ron Hubbard