I, Gerald Armstrong, declare:

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

2. I am making this declaration in response to certain statements, principally those concerning me, made by David Miscavige in his declaration executed February 8, 1994, and filed in the case of Scientology v. Fishman & Geertz, United States District Court for the Central District of California, Case No. CV 91-6425 HLH(Tx).

3. Mr. Miscavige states that I am a proven liar because he has found a discrepancy between a finding of Judge Paul G. Breckenridge Jr. in his decision rendered June 20, 1984 in the case of Scientology v. Armstrong, Los Angeles Superior Court No. C 420153 (Armstrong I), and a statement allegedly made by me and secretly recorded by Mr. Miscavige's covert intelligence operatives in the fall of 1984. (Miscavige dec. p. 31, l. 22 - p. 32, l. 5). Mr. Miscavige is employing one of Scientology's confusion techniques the organization's founder L. Ron Hubbard dubbed "dropped out time." Mr. Miscavige's incidents, which he has linked for purposes of confusion, are years apart.

4. In this civilization fear is generally accepted to be an emotion or state of mind which can either be present or not present, or perhaps present in degrees. It is fairly well accepted that a not abnormal person can be afraid one

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day, when, for example there are a couple of unidentified men at four a.m. outside the person's bedroom window where no men ought to be at four a.m., and not afraid on another day, when the person is, for example, watching the Dodgers beat the Giants. That the person claimed to be afraid at four a.m. Sunday and not afraid at the Wednesday ballgame does not make that person a proven liar. In my case there were more than two years between one time when I was afraid and the next occasion when Mr. Miscavige says I said I was not afraid.

5. In his decision, a true and correct copy of which is appended hereto as Exhibit [A] , Judge Breckenridge states:

"From his extensive knowledge of the covert and intelligence operations carried out by the Church of Scientology of California against its enemies (suppressive persons), Defendant Armstrong became terrified and feared that his life and the life of his wife were in danger, and he also feared he would be the target of costly and harassing lawsuits."

....

"It was thereafter, in the summer of 1982, that Defendant Armstrong asked Mr. Garrison for copies of documents to use in his defense and sent the documents to his attorneys, Michael Flynn and Contos

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& Bunch.

After the within suit was filed on August 2, 1982, Defendant Armstrong was the subject of harassment, including being followed and surveilled by individuals who admitted employment by [Scientology]; being assaulted by one of these individuals; being struck bodily by a car driven by one of these individuals; having two attempts made by said individuals apparently to involve Defendant Armstrong in a freeway automobile accident; having said individuals come onto Defendant Armstrong's property, spy in his windows, create disturbances, and upset his neighbors." (Ex. A. Appendix p. 14, l. 6 - p. 15, l. 3)

6. It is clear that Judge Breckenridge in his statements about my fear of organization legal and extra-legal attacks is referring to my state of mind in the period between the organization's publication of its "Suppressive Person Declares" on me in early 1982 and its filing of Armstrong I in August, 1982. This fear was not irrational or unfounded as the organization itself proved when it harassed my wife and me as Judge Breckenridge found, and did file harassing and costly lawsuits against me. All of these harassing and criminal acts were carried out during Mr.

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Miscavige's control of such activities, which he claims to have wrested from the Guardian's Office, which, itself, just as he himself, according to Mr. Miscavige, "used unscrupulous means to deal with people they perceived as enemies of the Church." (Miscavige dec. p. 17, l. 17).

7. Mr. Miscavige's new Guardian's Office, the Office of Special Affairs, did not end its criminal and abusive tactics with the incidents listed by Judge Breckenridge, but has added ten more years of "fair game" attacks since the 1984 decision, including, but not limited to:

a. attempted framing by entrapment and illegal videotaping;

b. filing false criminal charges with the Los Angeles District Attorney;

c. filing false criminal charges with the Boston office of the FBI;

d. filing false declarations;

e. bringing contempt of court proceedings on three occasions based on false charges;

f. making false accusations in internationally published media of crimes, including crimes against humanity;

g. culling and disseminating information from my supposedly confidential auditing (psychotherapy) files;

h. relentlessly attacking my attorney, Michael Flynn of Boston, Massachusetts with some 15 lawsuits, baseless bar complaints, theft of office

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documents, infiltration of his law practice, framing him with the forgery of a $2,000,000 check, an international black PR campaign, threats to him and his family, and, according to him, attempted assassination; all for the purpose of driving him out of the organization-related litigation in order to leave his clients undefended against the organization's attacks;

i. fraudulently promising to discontinue "fair game" against me if I settled my cross-complaint against the organization, knowing full well that it would continue to attack me in the courts and the marketplace of ideas once I signed its settlement contract, which I did in December, 1986, and once it had contracted with Mr. Flynn to not defend me in future litigation;

j. following the settlement, publishing a false and unfavorable description of me in a "dead agent" pack relating to writer and anti-Scientology litigant Bent Corydon;

k. filing several affidavits in the case of Church of Scientology of California v. Russell Miller and Penguin Books Limited, case no. 6140 in the High Court of Justice in London England which falsely accused me of violations of court orders, and falsely labeled me "an admitted agent provocateur of the U.S. Federal Government";

l. delivering copies of an edited version of an

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illegally obtained 1984 videotape of me to the international media;

m. threatening me with lawsuits on six occasions if I did not abet its obstruction of justice in the Miller case, in the case of Bent Corydon v. Scientology, Los Angeles Superior Court No. C 694401, wherein Corydon had subpoenaed me as a witness, and in the case of Scientology v. Yanny, Los Angeles Superior Court No. C 690211;

n. threatening to release my confidences, which it had stolen from a friend, and which had been specifically sealed by Judge Breckenridge in Armstrong I if I did not assist it in preventing Corydon from gaining access to the Armstrong I court file;

o. on February 4, 1992, filing a lawsuit, Scientology v. Gerald Armstrong, Marin Superior Court Case No. 152229 (" Armstrong II"), transferred to Los Angeles Superior Court and given Case No. BC 052395, alleging contract breaches, which it itself precipitated, for the purposes of, inter alia, obstructing justice, suppressing evidence, assassinating my reputation, retaliation and intimidation;

p. on July 8, 1993, filing a lawsuit Scientology v. Gerald Armstrong & The Gerald Armstrong Corporation, Los Angeles Superior Court Case No. BC 084642 (" Armstrong III") for the same purposes

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as in o. above;

q. on July 23, 1993, filing a lawsuit, Scientology v. Gerald Armstrong, Michael Walton & The Gerald Armstrong Corporation, Marin Superior Court Case No. 157680 ("Armstrong IV") for the same purposes as in o. above;

r. twice more bringing contempt of court charges against me based on false sworn statements.

8. The videotapes from which Mr. Miscavige claims to quote were made in November, 1984. In order to provide a context for how I came to be involved with his operatives who set up the videotaping and to clarify the words of both the operatives and myself which were recorded, and a few of which Mr. Miscavige claims to quote, I am appending hereto as Exhibit [B] a copy of a declaration/screenplay outline I have just completed and called "Find a Better Basket."

9. When I state on the 1984 videotape that I am not afraid, I am answering one of the operatives' questions or challenges which he has been drilled to state. In responding the way I did I am honestly communicating one of the changes I had perceived in my psyche over the almost three years since I left the organization. Because the organization teaches its members to put their faith in what cannot protect them; e.g., data, wins, attacks, hatred, disconnection, leverage, lawsuits, private investigators, fair game, L. Ron Hubbard or David Miscavige; it leaves them with a seemingly irreducible fear. Those who put their faith in God, Wherein lies perfect protection, give up their

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fear. There will still be times when fear will arise, but the reestablishing of faith in God will every time cause that fear to disappear into the nothing it is. I was beginning to learn that wisdom by the time of the 1984 videotaping. In fact it was that learning which seemed to move me to associate with the operatives who only sought my destruction. I have stated many times that I have an undeniable concern that before it comes to its senses or saner minds prevail in the organization its power structure headed by Mr. Miscavige will have me assassinated or do something else diabolical and dangerous, and this has produced in me an awareness of threat and is a fact of my present psychological condition. The power structure is quite capable of violent and criminal acts, or of purchasing such acts. The power structure is armed, and its head PI Eugene M. Ingram has threatened to kill me. The power structure makes a religion of terrifying countless vulnerable and innocent people who do not have my certa inty and do not have my skills to fight the organization's tyranny. For these reasons I oppose its tyranny and its suppressive doctrines and practices. Mr. Miscavige should not be pointing out imagined inconsistencies in whether one of his victims in one year or another was afraid or not of his vicious organization, but should be eliminating all of its viciousness so that no one ever again is made afraid by it.

10. Mr. Miscavige calls the videotaping of me "a police-sanctioned investigation." (Miscavige Dec. p. 31, l. 8 28) This is a lie Mr. Miscavige must tell as if his life depends on it. I provided the truth in "Find a Better Basket."

"Organization lawyers, Earle Cooley and John Peterson, claimed (during the 1985 trial of Julie Christofferson v. Scientology, Circuit Court of the State of Oregon, Multnomah County, No. A7704-05184, that) the Armstrong operation had been authorized by the Los Angeles Police Department, and they produced a letter dated November 7, 1984, ..... signed by an officer Phillip Rodriguez, directing organization private investigator Eugene M. Ingram to electronically eavesdrop on me and Michael Flynn. On April 23, 1985, Los Angeles Police Chief Daryl F. Gates issued a public statement, ..... denying that the Rodriguez letter was a correspondence from the Los Angeles Police Department, denying that the Los Angeles Police Department had cooperated with Ingram, and stating emphatically that all purported authorizations directed to Ingram by any member of the Los Angeles Police Department are invalid and unauthorized. On information and belief, the officer, Phillip Rodriguez, who signed Ingram's letter was paid $10,000.00 for his signature. Also on information and belief, following a Los Angeles Police Department Internal Affairs

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Division investigation and a Police Department Board of Rights, Officer Rodriguez was suspended from the Los Angeles Police Force." ("Better Basket," p. 13, paras. 22 and 23)

A copy of Officer Rodriguez's "authorization" is appended hereto as Exhibit [C], and a copy of Chief Gates' public announcement is appended hereto as Exhibit [D].

11. Mr. Miscavige claims that his illegal videotapes of me capture me acknowledging my real motives, to overthrow his organization's leadership and gain control of it. (Miscavige Dec. p. 32, l.1 - l.3) This is absurd. His own people, operated by him, came to me with their idea, approved by him, as outlined in "Better Basket," of wresting control of the organization from what they called the " criminals" running it. I have never had a desire control the Scientology organization or Scientology, although I recognize that its leaders should be restrained from further abuse of anyone. My real motive in my day-to-day relationship with its leaders is to get it out of the litigation business and get it to cease its assault on the justice system, its abuse of innocence and its threatening of me, my friends and people of good will everywhere. I know David Miscavige personally. I know him to be a bully, a liar and a perfect replacement for L. Ron Hubbard at the controls of his empire. I also know that God is in him as He is in everyone else and that bullying and lying are just mad and useless efforts to fight that fact.

12. Mr. Miscavige states that I advise one of his

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covert operatives to accuse the organization of various criminal acts and when I am told that no evidence exists to support those charges I respond to "just allege it." (Miscavige Dec. p. 32, l. 5 - l. 8) "Better Basket" describes something of the context in which I make a statement differentiating between "allegations" and "proof." The operative I'm talking to is Mike Rinder. Before this meeting I had already, on request of the "Loyalists," provided them with a "bare bones" draft of a complaint. Complaints contain allegations. Complaints do not contain proof. Rinder, who had been represented to me as the Loyalists' " best legal mind" couldn't seem to get the distinction between allegations and proof in the complaint, and I was frustrated in our conversation because he seemed so dense. Now, of course, his denseness is fully understandable. He had to appear stupid and had to deny that there was any "proof" of the sort of allegations that would be made in a complaint because he knew he was being recorded on a videotape which was going to be used to attack, and if possible destroy me. Even what the organization has done to me alone (see, e.g., crimes listed by Judge Breckenridge and the list in paragraph 7 above) is enough for actual true-hearted reformers to bring a lawsuit to take control of the organization from the criminals now in charge.

13. During Mr. Miscavige's videotape operation a briefcase containing a book of my original drawings and writings and other documents was stolen from the trunk of my

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car. My attorney made a demand on the organization for the return of these materials. The organization denied having them. I have recently been advised by Vicki Aznaran, a former organization executive who carried out operations against individuals on Mr. Miscavige's orders, that he told her at the time of their theft that he had them and he described them to her. Knowing that this declaration will be seen by Mr. Miscavige, I herewith renew my demand to him for the return of my materials to me.

    14. I will also take the opportunity to advise this Court that Mr. Miscavige's organization considers that it has me under a contract whereby it may sue me for filing this declaration, not because it is untrue or libelous, but because that is what the organization insists its contract permits. This contract was obtained by Mr. Miscavige as the result of his organization's years of attack on my attorney Michael Flynn, as stated in paragraph 7 subparagraph h. above. In order to get the organization to cease its fair game against Mr. Flynn I had to sign its contract, which, according to Mr. Miscavige, allows him and his agents to say whatever they want about me in any court proceeding or in the media and I may not respond. If I do respond I become subject to a $50,000.00 liquidated damages provision for every utterance, and the target in another Miscavige-ordered costly and harassing lawsuit. The three lawsuits, Armstrong II, III and IV described in paragraph 7, subparagraphs o, p and q, and the contempt of court proceedings at subparagraph r, are all pursuant to this contract. The contract is

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against public policy and illegal. Mr. Miscavige, moreover, entered into a separate illegal contract with Mr. Flynn, which prohibits Mr. Flynn from assisting me in any litigation against the organization. If Mr. Flynn were to assist me he would again be subjected to "fair game." Mr. Miscavige would be wise to rescind all these illegal contracts and discontinue his abuse of the legal process and totally eliminate from his organization the doctrine and practice of fair game, and not merely deny its existence.

15. Mr. Miscavige claims to know a great deal about the IRS dropping me as a witness because of his videotapes. In truth I was not dropped as a witness at all, and my credibility, despite more than twelve years of his organization's attacks on it, is intact. One of the conditions of the 1986 "settlement" with Mr. Miscavige's organization was that in order for the organization to discontinue the "fair game" against Mr. Flynn I had to sign a knowingly false affidavit, essentially stating that Mr. Miscavige's new regime had discontinued the organization's criminal activities. Mr. Flynn claimed that the organization had already tried to murder him and he felt his life and his family were in danger. I fully believed Mr. Flynn because I had myself been the target of fair game for five years by then and had likewise been threatened with murder. I, along with several other of Mr. Flynn's clients, therefore signed these false affidavits which the organization had prepared. The organization then filed the false affidavits in its IRS litigations. Mr. Miscavige

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makes much of the IRS granting his organization tax exempt status. Our government's turning its back on this organization's thousands of victims and apparently ignoring its obnoxious, irreligious and criminal core nature, however, does not make this victimization and antisocial nature either right or religious.

16. Mr. Miscavige also claims that Scientology's philosophy and practice of opportunistic hatred, called "fair game" by L. Ron Hubbard, its originator, doesn't exist. It does. 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 February 22, 1994.

[signed]
GERALD ARMSTRONG

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Exhibit [A]
Breckenridge Decision

Exhibit [B]
"Find a Better Basket"

Exhibit [C]
Rodriguez "authorization"

Exhibit [D]
LAPD Police Chief Daryl Gates' Announcement